ML20206M387

Deposition of Mc Jackson.* Deposition Taken on 861120 in Washington,Dc.Pp 1-147.Supporting Documentation Encl.Related Correspondence

ML20206M387
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	11/20/1986
From:	Jackson M Federal Emergency Management Agency, SUFFOLK COUNTY, NY
To:
References
CON-#287-3143 OL-5, NUDOCS 8704200099
Download: ML20206M387 (159)

Text

{{#Wiki_filter:E umocoamoroma, c 3 /#r3 TRAXSCRIPT =a n gg40F PROCEEDINGS,,,,, O [qg.': - r C UNITED STATES OF AMERICA ,,y.7 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD - - - - - - - - - - - - - - - - - - -x In the Matter of: Docket Number LONG ISLAND LIGHTING COMPANY 50-322-OL-5 (EP Exercise) (Shoreham Nuclear Power Station, Unit 1) - - - - - - - - - - - - - - - - - - -x O DEPOSITION OF MARIANNE C. JACKSON Washington, D. C. i Thursday, November 20, 1986 ACE-FEDERAL REPORTERS, INC. Stenotype Reporters 444 North Cmi Washin5_ ton, b.tol Street C.20001 (o,3 (20 )347-3700 Nationwide Coverage 800-336-6646 8704200099 861120 l PDR ADOCK 05000322 G PDR t.

D: position of MARIANNE C. JACKSON, Washington DC, 20 November 1986. LILCO, NRC Docket 50-322-OL-5. CORRECTIONS TO DEPOSITION Prge Line Correction: 7 I ebo w, as A,.fio-fo ou d< n h e~ IO 3 M '3 -h> fcPg '.N s IQ 5 m2J "ou. TL L d4b 1:c "a n o + b u w.s r.e[fwut, 10 1 11 CMonu"T" b 1h" v Il l T d o sp " bMtd'.nc " -40 h er d,c.n = " J v J 1Lo 10 C hos% qo " h " i l lRT II w A

• En, iww & n '.\\-- he k Xpw-_.

I I ( )MNW

o CR28980.1 ~COX/sjg_ 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3 - - - - - - - - - - - - - - - - - -x 4 In.the Matter of: Docket Number 5 LONG ISLAND LIGHTING COMPANY 50-322-OL-5 (EP Exercise) 6. (Shoreham Nuclear Power Station, Unit 1) 7 1 8 DEPOSITION OF MARIANNE C. JACKSON 9 Washington, D. C. Thursday, November 20, 1986 11 ( ); Deposition of MARIANNE C. JACKSON, called for examination 12 pursuant to notice of deposition, at the law offices of 13 Kirkpatrick and Lockhart, 1900 M Street, N.W., Suite 800, at 14 2:05 p.m. before WENDY S. COX, a Notary Public within and for 15 the District of Columbia, when were present on behalf of the 16 respective parties: MICHAEL S. MILLER, ESQ. 17 SUSAN M. CASEY, ESQ. GEOFFREY R. KORS, ESQ. 18 Kirkpatrick & Lockhart 1900 M Street, N.W. ashington, D. C. 20036 19 On behalf of Suffolk County. 20 KATHY E. B. McCLESKEY, ESQ. SCOTT D. MATCHETT, ESQ. 21 MARY JO LEUGERS, ESQ. Hunton & Williams 707 East Main Street 22 (A /~} P. O. Box 1535 Richmond, Virginia 23212 On behalf of Long Island Lighting Company. -- continued -- ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage M336-6646 w-,..,_.,.--,-..,._.._._..._.._-..____,

i 2 APPEARANCES (Continued): 2 WILLIAM R. CUMMING, ESQ. Federal Emergency Management 3 Agency 500.C Street, S.W. 4 Washington, D. C. 20472 On behalf of FEMA. 5 ORESTE RUSS PIRFO, ESQ. 6. Office of General Counsel United States Nuclear 7 Regulatory Commission Washington, D. C. 20555 On behalf of the Nuclear 8 Regulatory Commission Staff. 9 RICHARD J..ZAHNLEUTER,E SQ. Deputy Special Counsel to 10 the Governor Stato of New York 11 Capitol, Room 229 3 Albany, New York 12237 _Q' On behalf of the State of 12~ New York. 13 14 ALSO PRESENT: ELAINE D. ROBINSON 15 Office of Corpor' ate Affairs Long Island Lighting Company 16 17 18 19 20 21 22 0 ACE-FEDERAL REPORTERS, INC. ll02 347 3700 Nationwide Coverase 800 336 6646 _. ~.. _,,.. -7.- y., _ __,..--..,_ ..y

_=.- GI 3 i C O N-T E N T S 2 WITNESS EXAMINATION Marianne C. Jackson by Mr. Miller 4 1 4 by Mr. Zahnleuter 140 by Ms. McCleskey 145 5 6. EXHIBITS 7 JACKSON DEPOSITION NUMBER IDENTIFIED 8 Exhibit 2 52 9 Exhibit 3 71 10 Exhibit 4 133 11 (3' V-12 13 14 15 16 17 L 18 i 19 20 I 21 22 l ACE-FEDERAL REPORTERS, INC. X!2-347 3700 Nationwide Coverage 800 336 6646 v.,,,,..-.......-.~..-....-. .. ~

-28980.1 cox 4 _g. -N] ; 1 2 E 9 C E E D.I y g 5 2 Whereupon, + 3 MARIANNE C. JACKSON ~ 4 was called as a witness and, having first been duly sworn, 5 was examined and testified as follows: 6 EXAMINATION 7 BY MR. MILLER: 8 Q Ms. Jackson, would you please state your name 9 and address for the record. 10 A Marianne C. Jackson. Do you want my home 11 address? (l- } 12 Q Your business address is fine. 13 A Federal Emergency Management Agency, 26 Federal 14 Plaza, New York, New York 10278. 15 Q Ms. Jackson, my name is Mike Miller. I am one 16 of the attorneys of record for suffolk county in the-17 Shoreham licensing proceedings. I am going to be asking 18 you questions today.regarding the February 13, 1986, 19 exercise at the Shoreham plant. Some questions will touch 20 upon matters before that exercise, some questions with 21 regard to matters subsequent to that exercise, but if you 22 have any questions at any time, please tell me and I will g ACE-FEDERAL REPORTERS, INC. 202-347-3700 - Nationwide Coserage 800-3 % 6646

'2898051: cox' 5 I-1 try to clarify my question and make sure you understand s.- 2. before you answer. 3 Would you tell me how long you have been at 4 FEMA? 5 A I have been at FEMA almost'six years. 6 Q What was your first job at PEMA? 7 A My first job at FEMA was public affairs 8 officer. 9 Q Am I correct that you are presently emergency 10 analyst, public information officer? 11 A I received a promotion several years ago to the () 12 emergency analyst position, but I am continuing to do the-13 .public affairs. 14 Q. So public information officer is part of the 15' public affairs? .16 A Right, yes. Actually, they are synonymous, in 17 my mind. 18 Q As an emergency analyst, what do you do? l 19 A As the emergency analyst, I serve as special 20 . assistant to the regional director, handling special 21 projects, spending time developing work plan goals, and 22 evaluating the effectiveness of our program '. f') v ACE-FEDERAL REPORTERS, INC. 202 Nationside Coserage 80(A3364646 ,,, -347-3700 - - - - - -. - -

28980.1 cox 6 s/- 1 implementation. 2 Q Who is the current regional director at-FEMA, 3 Region II? 4-A The current -- we don't have a regional 5 director.. We have an acting regional director. When 6 Frank resigned, the deputy regional director, who was a 7 career civil servant, was appointed acting regional 8 director by the director of the AG, and his name is Norman 9 Steinlauf, S-t-e-i-n-1-a-u-f. 10 Q You said when Frank resigned; that's Frank 11 Petrone'you are referring to? (~) '12 A Hight, yes. -uJ 13 Q You mentioned as part of your job as an 14 emergency analyst, you handle special jobs for the 15-regional director. What would be an example of the 16 special kinds of projects that you handle? 17 A Well, a special project that is a. good example 18 is something I am working on right now. FEMA has a large 19 mission as far as training emergency managers at the state 20 and local level and in other federal agencies. We have 21 gotten involved here in Washington using teleconferencing 22 as a training approach, because it's cheap. O CE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6M6

28980.1 cox 7 's / 1 Unfortunately, in New York City, there have 2 been all sorts of problems finding a site. They couldn't a 4enncu n 3 put an ma4++vg_n on the top of the building, so I am l% 4 embarked on a search for the perfect site for a satellite 5 dish, so that emergency managers in New York can take 6 advantage of these teleconferences. 7 Q Am I correct that the special projects you 8 would handle as an emergency analyst would relate to your 9 role as the public information officer, public affairs 10 person? 11 A I guess they relate, Mike, insofar as (~D 12 communication skills are important and knowledge of the ,.) 13 organization and program priorities are important. 14 Q Did you hold any job before you joined PEMA? 15 A Yes. Before I joined FEMA, I worked for the-6 regional office of the Internal Revenue Service in New 17 York for four years; and prior to that I worked for the 18 Internal Revenue Service in Providence, Rhode Island, and 19 I held other jobs before that too. 20 Q What qualifications did you bring to your job 4 21 at FEMA in your role as a public affairs, public 22 information officer? O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 804336-6M6 ~

-.28980.1 cox.. 8 $_)- 1. A Well, I had eight years experience doing public 2 affairs in another federal agency. I had teaching 3 experience, I have an advanced degree in English 4 literature, which somehow strengthens, we think 5 ' strengthens people's ability to communicate. 6' Q The other federal agency is the Internal 7 Revenue Service? 8 A Right. 9 Q So you had the same sort of public affairs job 10 at IRS as you now have at PEMA? 11 A Yes. I mean, there are differences, but-the ([ 12 job classification is basically the same, according to 13 these federal personnel standards. 4 14 Q Ms. Jackson, were you shown a notice of 15 deposition directed to you for this deposition? 16 A What would a notice of deposition look like? 17 Q It basically is directed to you through your 18 counsel. It says that you will be deposed at a certain ( ( 19 date, time, place, location. l 20 A Yes, I saw that. Q You did see that. Do you recall in there a 21 22 demand that you bring with you any documents in your n s_- i i ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coscrage 800-336-6686 _-.,. _,. _. _. ~... _ - _

28980.1 -cox-9 ( 1 possession, any notes, logs, documents of any kind 2 relatiny to the Shoreham exercise? 3 A I don't recall seeing that. 4 Q Let me ask you, do you have any documents in 5 your possession that relate to the Shoreham exercise? 6-A No. 7 Q At one time I assume you had such documents. 8 A Yes. 9 Q Where did those documents go? 10 A The documents were turned over. During the 11 exercise, we had to turn all our evaluation material in. (j 12 Q Let's break it down into documents that may 13 have been in your possession prior to the date of the 14 exercise. Were there any such documents that would fall 15 in that category? 16 A Would you restate that question. 17 Q Any documents that have been in your possession 18 prior to the exercise, but relating to the Shoreham 19 exercise, were there any such documents; do you recall? 20 A Yes. 21 Q What is the status of those documents now; 22 where are they located? O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Co rage 800-336&t6

28980.1 cox 10 .g \\_f 1 A Oh, I don't have them -- I don't have them 2 anymore. 3 Q Did you destroy them, did you turn them over to 4 counsel? 5 A Either I threw them out -- what I am talking 6 about is, you know, things saying where your hotel is 7 going to be, et cetera, et cetera, what team you are on, 8 when the briefings will be. Basically adminis trative 9 stuff. I did do a fact sheet for distribution to the 10 press, explaining the FEMA role. You know, it was a 11 standard public affairs handout, trying to make some sense t( ) 12' of what was going on out there. I am not certain -- I 13. know those haven't been destroyed, because I keep a file 14 copy, and I don't recall turning it over to somebody. 15 MR. MILLER: Mr. Cumming, if that document has. 16 not been produced it would fall within our request for 17 production of documents. 18 MR. CUMMING: It's been produced. 19 MR. MILLER: Thank you. 20 BY MR. MILLER: 21 Q Another example, Ms. Jackson, were you involved 22 in any way in the preparation and review of the scenario O ACE-FEDERAL REPORTERS, INC. 202 Nationwide Coverage 800-336-6M6 - - -347-3700....

28980.1 cox 11 .,m:() 1

for the Shoreham exercise?

2 A Definitely not, no. 3 Q Were you involved in any way in the preparation 4 and review of the exercise objectives?- 5 A No. No, I-wasn't. 6 Q So with the exception of this fact sheet that 7 you have mentioned, is there any other document that you 8 can recall that would have been prior in time to the date 9 of exercise regarding this Shoreham exercise? 10 A Well, remember, there was so much 11 correspondence back and forth, there was so much (v) 12 controversy around the' exercise, and as the public affairs 13 officer, you know,=I had to answer press inquiries about 14 what.it was we were doing and why we were doing it. But I 15 am sure-that all those documents that I referred to, 16 letters from this person and that person, I assume that 17 you already have them. I couldn't begin to list what they 18 are, the whole history', really, of the correspondence 19 between all the parties that are involved in this. 20 Q Do you know if your files have been searched-in 21 response to request for production of documents by Suffolk 22 County and turned over to counsel for FEMA for production p.O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80433MM6

28980.1 cox-12 , ~.. ~(_) 1. to the County? 2 A My own personal, are you asking about my own 3 personal? 4 Q Any files in your possession,. custody or 5 control. 6 A Yes. 7 Q They have been turned over to counsel for FEMA? 8 A Yes. 9 MR. MILLER: I assume, Mr. Cumming, they will 10 be turned over to us if we request them? 11 MR. CUMMING: Subject to.our privilege. ) 12 BY MR. MILLER: t 13 Q Did you bring any documents with you today, 14 Ms. Jackson, at all? 15 A No. 16 Q With respect to any documents that would be 17 subsequent to the time of the exercise, would you answer 18 me the same that those documents in your possession, 19 custody or control have been turned over to counsel for 20 FEMA for production to the County? 21 A Yes. 22 Q Any documents from the day of the exercise, <g ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 80 4 336-6646 {

28980.1 cox 13 ~ i,< - 1 your answer is the same? 2 A Yes. 3 Q So to your knowledge at this time, there are no 4 documents that have not been made available to your 5 counsel, to FEMA's counsel? 6 A Yes. 7 Q There are no documents? '8 A Yes. f 9 Q We deposed earlier this morning, Ms. Jackson, 10 Mr. Laine, who mentioned in his deposition that he turned . documents he generated during the exercise over to you at 11 ( 12 the end of the exercise; 'do you recall that, do you recall 13 Mr. Laine doing that? 14 A I rea71y don't recall. 15 Q Do you recall collecting documents from any 16 FEMA evaluators or controllers or simulators, any people 17 of that kind following the exercise, collecting for, I k 18 assume,-dissemination to someone else? i 19 A No. I really -- no, I really den't recall on 20 that. That was very confusing. 21 Q Who did you give your documents to, the 22 documents you generated during the exercise? oU m ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 .~.. _... ~.

28980.1 cox 14 (,/ 1 A I gave them to whoever was assisting Roger, you 2 know, the RAC Chairman. ^ 3 Q' Roger Kowieski? 4 A -Right. 5 Q To the best of-your recollection, other than 6 your own documents, you did not have custody of someone 7 else's documents from that day? 8 A If Hugh Laine gave me documents, then I turned 9' them over to Roger. 10 Q Do you recall when you first heard about the 11 Shoreham exercise that was scheduled and held on February f'T 12~ 13, '86? O 13 A Well, no. I would have to look at a chronology 14 of the events leading up to it. But it was discussed for 15 months; and then finally, you know, the NRC wrote to FEMA 16 and asked-us to do it, those'two options. We said, yes, 17 we would do it. So I definitely knew that. 18 Q You knew there were discussions going on pretty 19 far before the time -- A Oh, yes, definitely. 20 21-0 Were you involved in those discussions? 22 A Oh, I was involved in discussions about what fm (_) ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(Xh336-66'$

28980.1. .cox 15 ,-b, -1 might happen. 2 0 Who would those discussions have-been.with? 3 A It really was a matter of discussion in the 4 office,'and everybody' who had any responsibilities for 5 this program discussed the Shoreham situation. 6 Q Were you ever involved in any discussions in 7 terms of'decisionmaking before deciding whether or not the 8 Shoreham exercise would go forward? 9 A Oh, definitely not, definitely not'. 10 Q So your discussions were more -- they were 11 really more in terms of the fact that Shoreham-was a f~') 12 'well-publicized plant and it would be talked about in the. v 13 New York office because of-that? r ~14 A Yes. 15 Q 'When did you-first learn that the Shoreham-16 exercise was going to go forward on February 13, 1986? 17 A I don't know. Can I look at this post-exercise 18 assessment? 19 Q Sure. 20 A This is our final document that came out of 21 this thing. 22 MR. CUMMING: Let the record show that the 4 O ACE-FEDERAL REPORTERS, INC. 202 347 Nationwide Coserage 800-33MM6 ~ . - -. -3700

28980.1 cox 16 ( (j 1 witness is reviewing the FEMA post-exercise assessment 2 dated April 17, 1986. 3 TIIE WITNESS: Well, it was somewhere between 4 June 20, 1985, when NRC first asked FEMA to conduct an 5 exercise, and then on October 12, 1985, when FEMA 6 -requested that we conduct the exercise in accordance with, 7 you know, option 2. 8 BY MR. MILLER: 9 Q I think you mean to say when NRC requested FEMA 10 ~to conduct the exercise. 11 A Right. What did I say. Well, FEMA. NRC (~i 12 requested FEMA. I 13 Q Subsequent to that October 12 request by NRC to 14 FEMA, what was your involvement in preparing for the 15 Shoreham exercise, if any? 16 A November 12. 17 Q I am sorry, November 12, is it '85? 18 A Yes. 19 Q Subsequent to that time, what was your 20 involvement in preparing for the Shoreham exercise? 21 MR. CUMMING: Let the record show that FEMA 22 counsel would normally object to this line of questioning, g i ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coscrage 80433MM6

28980.1 cox 17 ./T - (.) 1 'but has no objection with respect-to this witness. 2 Tile WITNESS: All right. Would you restate 3 that. question again, please. 4 BY MR. MILLER: 5 Q I am trying to pin down some dates. One date 6 you mentioned is November 12, 1985, when NRC made the 7 request to FEMA to proceed with the exercise under option 8 2. 9 A Yes. 10 Q Now, subsequent to November 12, 1985, what 11 involvement did you have, if any, in preparing for the [l 12 Shoreham exercise? ~/ 13 A Well, I mentioned the recall -- earlier I 14 mentioned the administrative stuff about what day it was 15 going -- you know, we-had to set the date. We were .16 concerned'about getting another evaluator to do public 17 information, you know, so 1 suggested we ask Ilugh Laine to 18 do it. I was concerned, because it was my job, it's my .19 job to be concerned about whether or not we are explaining 20 the FEMA role clearly.to the press in connection with the 21 Shoreham exercise. 22 0 Is it fair to say that in relation to your oLJ ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 80 4 336-6646

28980.'1 cox 18 A-1 concern regarding explaining the FEMA role _to~the' press, m 2 that's what led to your. putting together the fact sheet' 3-you already mentioned? 4 A' Yes. '5l 'O Did,you do anything else that'you can recall 6 with respect to your concerns in explaining FEMA's role 7 -properly? 8 A Well, I handled media inquiries as'they came 9 in. I talked to reporters. 10 Q Anything in addition to that? 11 A No. 12 Q With respect to your concerns about getting 13 -another evaluator to do public information, why did you-14 have those concerns? 15 A-Well, because for, you know, for all exercises, 16 you usually need, if it's a full-scale exercise, or an [ 17 exercise the scope of_the LERO exercise,'you need more 18 than one public information evaluator. 19 Q You were-going to be one evaluator? 20 A Right. e 21 Q You needed a second? j-22 A Yes. lO ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6M6

28980.1' cox 19 _, ~.; I' v ). 1 Q 'When was it determined that you were going to 2 be an evaluator at the Shoreham exercise? 3 A Well, it's been the licy, since-I have 4 been with -- the region's policy, up until recently, that W h D I am the lead public information evaluatorg radiological D 5 6 emergency preparedness exercises. So I want to have 7 somebody who will be basically working with-me who 8 understands what is going on. 9 Q So it was just assumed that you were going to 10 be an evaluator at the Shoreham exercise; is that fair to 11 say? [)) 12 A Yes. x. 13 .Q Did you decide that you would be the evaluator 14 at the emergency news center? 15. A Yes. Well, I discussed it with Roger. 16 Q Roger Kowieski? 17 A Yes. 18 Q Did you decide that Mr. Laine would be an 19 evaluator at the EOC? 20 A Yes. That was my recommendation. We needed 21 someone at the EOC to watch those EBS messages being 22 formulated and calling them in to the radio station, so mU ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6

i 28980.1 cox 20 ,I,) 1 that's critical. s 2 Q Other than Mr. Laine, did you personally 3 . request:any other federal person to be an evaluator.at the 4 Shoreham exercise? 5 A No. 6 Q A controller or simulator? 7 A No, no. 8 Q Now, in preparing for your role as an evaluator -9 for the day of the exercise, Ms. Jackson, when do you 10 recall.your first involvement in that regard? 11 A Well, preparing for the exercise. ! (') 12 Q As an evaluator. I am distinguishing, let me %) 13 clarify. 14 MR. CUMMING: Could counsel rephrase. 15 BY MR. MILLER: 16 Q I am trying to -- let me back up. Is it fair 17 to say that you had a role as a FEMA employee at the 18 Shoreham exercise, that is to deal wi th the press, which 19 was different from your role as an evaluator at the 20 Shoreham exercise? 21 A What we did for -- yes, I understand your 22 ques tion now. There was that problem. Bill McAda from nU ACE-FEDERAL REPORTERS, INC. f.. . 202-347-3700 Nationwide Coverage 80433MM6

.28980.1-cox 21 - )' -1 the national office, FEMA public affairs, came up for the 2 exercise. I can't recall if it was at my request or his 3 . request, but I said I am not going to be able to evaluate 4. ~this exercise at the joint news center and also talk to 5 the press. I kind of got corralled on several occasions, 6 but that's what Bill was there to do. 7 Q Wha t was -- Bill Mc Ada. What was he there to 8 do? Which one of those roles? 9 A He was there to deal with the press on the day 10 of the exercise, so that I could evaluate the LERO 11 operations at the emergency news center. [) 12 Q Mr. McAda was stationed at the emergency news %d-13 center-with you during the day of the exercise? 14 A Yes. He came up the day of the exercise. 15 Q Was he at the ENC? -16 A He was at the ENC. 17 Q Were you at the ENC all day long the day of 18 this exercise? 19 A Yes, all day long. i 20 Q Your job on the day of the exercise was 21 strictly one as an evaluator; correct? 22 A Yes. O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80 4 336-6666

-28980.1- 'cox 22 (s! - 1 Q So you at no time dealt with the press? 2 A No, I can't say that. As I said, as I said 3 earlier, several times, I was corralled by some press. 4 So, you know, I spent -- I couldn't estimate how much time 5 talking to some reporters. I tried to avoid them, but it 6 was real difficult. c 7 Q Did you see a conflict between your role as an 8 evaluator and having to actually deal with the press on 9 the day of the exercise? 10 A No. 11 Q If there was no such conflict in your mind, why ( 12' was_it-again that Mr. McAda was brought in to deal with 13 the press? 14 A It's a question of time. If I tried to explain 15 to those reporters how FEMA got involved in that exercise, 16 and the limits of' our involvement, I would not have had 17 any time to evaluate the emergency news center operation. 18 The way the emergency news center operation was set up, I 19 had to be in the briefing room to evaluate the LERO PIO 20 staff briefing the press. I would have to go to all these 21 various rooms. So there is no way that I could hide. 22 Q Mr. McAda is located in FEMA's Washington o ACE-FEDERAL REPORTERS, INC. 202-347-3X0 Nationwide Coverage 800-3364M6

28980.1 cox 23 , ~. i 4 (_/. 1 office? 2 A Yes. 3 Q He is a public affairs specialist; right? 4 A Yes. 5 Q Do you report to Mr. McAda? 6 A Oh, no. No. I report to the regional director 7 in Region II. 8 Q Let me back up again, Ms. Jackson. In terms of 9 your -- the first time you recall your involvement with 10 preparing for your role as an evaluator. 11 A Yes. j ) 12 Q The day of the exercise. 13 A Yes. 14-Q When I say " involvement," for example, did you 15 look or review any materials in preparing to be an 16 eva'luator at the exercise? 17 A No, not that I recall. 4 18 Q At any time before the day of the exercise, you 19 don't recall ever looking at any materials regarding the 20 plan? 21 A No, I don't recall. I may have looked at the 22 objectives on the exercise objectives, but I don't ) 4 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33M686 ~-

L28980.1. .cox 24 L kj! .1 recall. t l 2 Q Do you ever recall looking at the local plan 3 before the exercise? ~ 4 A I reviewed the local plan, 5 Q Where would that have been? r 6 A We were reviewing the local plan for a long 7 time. 8 Q In connection with the RAC's review of the 9 local plan? 10 A Yes. 11 Q The RAC is the regional assistance committee? I'2 A' Yes. 13 Q. You are not a member of the RAC, are you? 14 A I don't believe I am a member of the RAC. I 15' don't believe I am. 16 MR. CUMMING: If'she was, I would be objecting 17 to the testimony. Counsel for FEMA will stipulate she is 18 not a member of-the RAC. 19 BY MR. MILLER: D 2 20 Q Do you consider yourself an advisor,to the RAC, 21 Ms. Jackson? 22 A I guess you could put it that way. O ACE-FEDERAL REPORTERS, INC. 202 347 3700 NationwideCo erage 800 336M

[*. w 28980.1 cox 25 _jn k/ 1 Q' Well, how would you put it? Tell me how you 2 would~put your_ role with respect to.the RAC? 3. A{ For the review of the plans, you'know, I am 4 usually asked to. review pertinent sections of plans, and 15 that's what I do. I submit-my review. 6 Q You submit your review, comments regarding that 7 1 review, to the RAC? v 8 A Yes, to Roger. 9-Q To Roger Kowieski, who was formerly chairman of 10 the RAC? 11 A Right. '( ) 12 Q And to your knowledge, are those comments then 13 used;by the full RAC in conducting its review of various 14 emergency plans? 15 A Right, correct. 16 Q Do you know Joseph Keller? 17 A Yes. 18 Q Do-you know Thomas'Baldwin? 19 A Sure. 20 Q Do you distinguish what you do on the RAC -- 21 MR. CUMMING: Counsel for FEMA objects, but the 22 witness may answer. t O ACE-FEDERAL REPORTERS, INC. i 202 Nationwide Coverage 800-33MM6 -347-3700

,e y ? 28980.1 N 3 26-cox Ih f~h ' i_.) 1. MR. MILLER:. Excuse me; 16t me finish my 2 -question, then you can object -- from what; Joseph Keller .o 3 or Thomas Baldwin would do t'or the RAC? ){ 4 MR. CUMMING: Counsel for FEMA ob'jects to this h 5 line'of questioning but witness has answered the ) 6 question. Are you going to go on a-long time with this t 7 line of questioning? 8 MR. MILLER: Depends o'n the answer. 9 THE WITNESS: They are contractors. I am a full-time permanent fedlaral employee. 301 11 BY MR. MILLER: () 12 Q But with respect to what,RAC's review of the 13-emergency off-site plans and with iespect to what Joseph Y 14 Keller or Tom Baldwin would do, dc';you see a difference? 15 MR. CUMMING: Counsel for FEMA objects, calling 16 for a witness beyond the scope of the witness' e-17 competence. 18 BY MR. MILLER: q* i 19 Q You can answer the qae' o' -), 20 A I don't know how to answer the question. I 21 would have to think about it. It's something I have never 22 really thodght about. q, u (1) / t ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationside Coserage 804336-6M6 _~

28980.1 cox 27 g, $m[ 1 Q Do you sit in on meetings of the RAC? isr[ 2 A Occasionally. t 3 Q Are there instances where the RAC either as a 4 body or through the chairman would ask your advice 5 regarding a matter? 6 A Oh, sure. 7 Q You respond to that request, I assume? 8 A Definitely.

s 9-Q I gather, Ms. Jackson, that your area of 10 expertise is the public, alerting of the public, public 11 information?

() 12 A Yes, emergency public information, rumor patrol 13 and public education. 14 Q Now, you have told me that you have had an 15 involvement with the LILCO plan from the perspective that 16 you had' reviewed that plan in those areas. But with ( 17 respect to preparing to be an evaluator the-day of the 18 Shoreham exercise, can you recall reviewing any materials 19 prior to the exercise? -20 A I think I probably looked at the plan again. 21 Q Do you recall any particular parts of the plan 22 or local procedures? LO l - b i ACE-FEDERAL REPORTERS, INC. 202 4 47-3700 i Nationwide Coverage 800-33MM6 (

~-28980.1 'cox 28 r ~. (), 1 A 'I would look at the parts of the plan that 2 pertained to the emergency news center. 3-Q Now, those five volumes over there, 4' Ms. Jackson, sometimes we confuse the terms, the LILCO 5 plan, usually when I say that I am talking about the plan 6 volume and implementing procedures as well. There are 7 five. volumes over there, including appendix A. Would you 8 have_ looked through any portions of those five volumes 9 that dealt with the ENC? 10 A Oh, I probably did. 11 Q Do you recall anything other than that that you 12 would have looked at prior to the day of the exercise? 13 Maybe the objectives, you said, I think. 14 A Yes. 15 Q Anything else? 16 A No, I don't think there was anything else. 17 Q Did you provide any documents regarding the i 18 LILCO plan in preparation for the exercise to anyone, any 19 other evaluators? 20 A No, no. 21 Q Did Mr. Laine? 22 A No. O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 80433MM6 .j

s. 28980.1-cox' 29 m k._). 1 Q' Mr. Laine received a packet of materials prior 2 to the exercise. That's what he testified to this 3 morning, but you did not give him that packet of 4 materials? 5 A No. That's the observer's packet. You know, 6 -Roger works with his staff, worked with his staff on 7 pulling that together, and.each packet had to be an 8 individual thing. 9 0, Did you receive a~ packet of materials for 4 10 observbrs. just like Mr. Laine? 11 A Oh, sure. (} [ t 12 Q Do you recall what was in that packet? 13 A Well, there was a lot of stuff, the 14 administrative stuff, sheets you were supposed to fill 15 out, pertinent sections of the plan. There was the 16 scenario itself, there were the -- all the locations that 17 were participating in the exercise, there was a list of 18 evaluators, you know, it was like there were maps, there 19 was a lot of stuff. 20 Q I gather, Ms. Jackson, you saw that packet of 4 21 materials sometime prior to the exercise? l 22 A Yes. l (2) i i ACE-FEDERAL REPORTERS, INC. 202 Nationwide Coserage 80lk33 M M 6 l,- , - -. ~... ~. -. --. _ _ -347-3700..,.. _,

28980.1 cox 30 , -( (_) 1-Q' It would have been a day before, two days 2 before, do you recall? 3 A Oh, no, I must have had at least a week. I 4 . probably got it at least a week -- I.eun not sure. '5 Q. ~You would have reviewed all those materials 6 prior to the date of the exercise? 7 A Yes. 8 Q Do you distinguish between the terms 9 " observers" and " evaluators" with respect to FEMA 10 personnel? Were you an evaluator at the exercise or were 11 you an observer? /'~h 12 A I was an evaluator. I think I was an (_)- 13 evaluator. 14 Q What was Mr. Laine? 15 A He was an evaluator. 16 Q I am asking because you refer to the observer 17 packets of materials. 18 A Maybe those terms have been used 19 interchangeably on occasion. 20 MR. MILLER: Let me mark as Jackson Exhibit 1 21 this one-page document dated February 3, 198u, memorandum 22 from Roger Kowieski to all federal observers. O ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coserage MG33MM6

28980.1 coxc 31 pn. \\_)? 1 (Jackson Exhibit 1 identified. ) 2 DY MR. MILLER: -3 Q Ms. Jackson, do you recall having seen this 4 memorandum before? 5 A Yes. 6 Q Do you recall if you attended the briefing on 7 February 7, 1986? ~ 8 A I think I did. 9 Q Is it your understanding that evaluators, the 10 day of the exercise, attended this. briefing? 11 A I can't answer that question without () 12 understanding the distinction you have in your mind 13 between evaluators and observers. 14 Q In my mind, I am not sure there is a 15 distinction. I was wondering if you were making a 16 distinction between those two terms. 17 A. No. 18 Q You are not making that distinction? 19 A No. 20 Q Do you know if all evaluators for the Shoreham 21 exercise attended this briefing? 22 A No. But this is for Region II FEMA people. As /~N , U i ACE-FEDERAL REPORTERS, INC. 202-347 Nationwide Coverage 8(Xh33MM6 -,_..-..__,.._.~_...._3700

~ 28980.1 cox -32 %,s. 1 you'know, we had people coming in from all over the 2 country for that. So this was a briefing, we were trying ~, to kind of get ahead of it and get the FEMA people out of-4- the way on Friday because we had all these other people S coming in. That's why it'was scheduled on Friday. 6 Q This is for the Region II FEMA personnel who 7 were going.to be evaluators-of the Shoreham exercise? 8 A Right. 9 Q To your knowledge they were all invited or 10 requested to attend this briefing on that Friday? 11 A. I think so.- (f 12 0 The reason was just simply cut down the numbers 13 of people that were going to have to be briefed prior to 14 the exercise? 15 A Yes. -That was my understanding, you know, why 16 Roger did'it. 17 Q Do you recall generally what was discussed at 18 that briefing? 19 A We just ran down what was going to be involved, 20 the basic information about the exercise that was 21 provided. 22 Q When you say basic information about the O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 80lk336-6M6

28980.1 cox 33 (m. (_) 1: exercise, that.doesn't really tell me what was discussed 2 at that briefing. I mean, basic information, are you 3 .saying that it was the day of the exercise, the time it 4 was going to start, things of that sort? 5 A Yes. 6 Q Was there anything discussed more-than 7 administrative logistical matters? 8 A Not to my recollection. 9 Q This meeting was scheduled, it was over a 10 two-hour meeting, so for over two hours you discussed such 11 matters as place, time and date, and that was it? () 12 A I don't recall enough about what happened at 13 that meeting to answer your question. 14 Q Do you think you would have taken notes at this 15 meeting? 16 A No. 17 Q Were you the only evaluator at the ENC? 18 A Yes. 19 Q Again, it was -- you were basically the person 20 who decided that's why you would be assigned; is that 21 correct? 22 A I think I made that recommendation to Roger, O ACE-FEDERAL REPORTERS, INC. 202 347-3700 f Jationwide Coverage 2336W46

'28980.1-cox. 34 . (3 V '1 and he followed it. 2 Q Tell me, if you would, describe for me, 3 Ms. Jackson, what your assignment was on the date of the 4 exercise at the ENC? 5 A Well, the emergency news center, and in some 6 places we call it a joint information center, is a 7 requirement that is set forth in 0654, which calls for a O point of contact for the press and also spokespeople who-9 can tell the press what's been going on. I was there to 10 make sure that that was being done; and what I kind of do, 11 when I evaluate the emergency news center, is I pretend I -( ) 12 am a reporter who has found out on the wire service or 13 because there have been EBS messages broadcast and someone 14 has picked up on the EBS messages, I have arrived from an 15 out of town location, or I have arrived from someplace 100 16 miles away. I am walking into that emergency news center, 17 and I want to find out what is going on. So how am I 18 going to find out what is going on at the emergency news 19 center? 20 First of all, I am going to have -- I should 21 have access -- I should be able to find out what has 22 happened up to that point, and what is key is I should be O ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationmide Coverage 8%33MM6

28980.1 cox 35 / 1 able to find out what government officials have said; and 2 particularly what they have told the people at risk to 3 do. I mean, really, that's it in a nutshell. 4 So I should be able to see copies of emergency 5 -- hard copies of the emergency broadcast messages. There 6 should be maps that explain what has happened, there 7 should be briefings that are informative and complete. 8 That's how I do it. The reason I put myself in the shoes 9 of the reporter is that if a reporter walks in, and picks 10 up contradictions, if he or she, the reporter, has just 11 heard on the radio, is tuned to the EBS station, and has w ( 12 just heard that zones A, B and C have been evacuated, here v, 13 is the county exec or whoever broadcasting that 14 information live, goes into the joint news center, and the 15 spokespeople don't have that information, then the 16 reporter is going to report that it appears that they 17 don't know what they are doing, that there is a 18 contradiction. That is going to cause panic. I was also 19 there to look at the rumor control. 20 0 Is it fair to say, Ms. Jackson, that you 21 basically then defined the parameters of your job as an 22 evaluator at the ENC? / ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage fu13346M6

28980.1 cox 36 y (_) 1 A I defined them? No, well, they were -- all 2 those things that I had to look for were listed on the 3 evaluation sheet. 4 Q Are you referring to the objectives of the 5 exercise? 6 A And whatever it was that I filled out and 7 turned in. 8 Q So what you are telling me, then, is that the 9 parameters of what you were supposed to do at the ENC were 10 defined for you; is that correct? 11 A Yes. (' 12 Q Did you first see those parameters when you got L./ 13 the packet of materials approximately a week before the 14 exercise? 15 A I think I said earlier that I may have seen the 16 objectives before I got the packet of material. They are 17 pretty standard objectives. We have been running -- we 18 have been evaluating these exercises since '80, and all 19 the people who are involved in setting up objectives, and 20 in this case, for a place like an emergency news center, 21 basically know what we expect to see there. 22 Q Did you receive any briefing for the exercise, tO v ACE-FEDERAL REPORTERS, INC. 3c-347-3700 Nationwide Coserage 8043346M6

l' ~ 28980.1 37 cox i L A-V 1 other than the February 7 briefing that Roger Kowieski 2 held? 3 A There were some other briefings out at the t-4 hotel. 5 Q Prior to the time that you traveled to the 6 Shoreham site, or the area of the Shoreham site, did you 7 receive any briefings other than that February 7 briefing 8 in connection with your role as an evaluator? 9 A No, no. 10 Q .That briefing on February 7 was given by 11 Mr. Kowieski;'is that correct? (O. 12 A I think so. J 13 Q During Mr. Laine's deposition, Ms. Jackson, we 14 introduced an exhibit, it was Laine Exhibit 3. Do you 15 have that, Mr. Cumming, you can show the witness? 16 MR. CUMMING: I don't have it. I don't know 17 what happened to the exhibits we had this morning. I 18 don't think Mr. Laine took them. 19 MR. MILLER: This is Laine Exhibit 3. Rather 20 than introduce more paper, I am going to refer to those 21 exhibits. 22 MR. CUMMING: That's fine. O ACE-FEDERAL REPORTERS, INC. 202-347-37(*) Nationwide Coverage RXk))46M6

28980.1 cox 38 ,r m -(_) l' MR. MILLER: That is an extract from the 2 Shoreham exercise. 3 MR. CUMMING: It's an extract from our report. 4 THE WITNESS: Okay. 5 BY MR. MILLER: 6 Q Would you tell me, Ms. Jackson, once you have =7 had a chance to look through those, which objectives you 8 recall having had responsibility for as an evaluator. 9-A I did all of them. 10 Q All of the objectives listed on that? 11 A Yes. It should be in the report too. () 12 Q When you say "all of them," I am not sure how 13 many pages. 14 A Oh, seven, just the emergency news center 15 objectives. 16 Q You did all seven objectives under " emergency 17 news center"? 18 A Yes. 19 Q Did you have responsibilities for reviewing any 20 objectives other than those under " emergency news center" 21 on Laine Exhibit 3? 22 A No, I don't think so. I would have to look at O ACE-FEDERAL REPORTERS, INC. 202 347-37(U Nationwide Coserage an34(M6

2E'980.1 cox 39 (,) 1 the report to see what else I may have looked at. 2 Q But to the best of your recollection now, it 3 was the seven objectives under the emergency news center 4 heading that you had responsibility for? 5 A Yes, that was my major responsibility. 6 Q You were at the emergency news center all the 7 day long of the exercise? 8 A Yes. 9 Q We also this morning introduced an itinerary of 10 the -- for the Shoreham exercise. That was marked as 11 Laine Exhibit 2. () 12 MR. CUMMING: Whoever took my coffee cup may R./ 13 have made off with our exhibits. I carefully left them in 14 place. Mr. Laine may have departed with the exhibits. 15 BY MR. MILLER: 16 Q I will show you what was marked as Laine 17 Exhibit 2, Ms. Jackson. That is the itinerary I referred 18 to. Was this included in the packet of materials you 19 received a week before the exercise; do you recall? 20 A I think it must have been. 21 Q Do you recall when you went to the area of the 22 Shoreham plant? Was it on February 10 or February 117 v/~h ACE-FEDERAL REPORTERS, INC. 202 347-37(1) Nationwide Coserage mX) 33MM6

-m. 28980.1- ~cox 40 , "N-4.,,f 1 The exercise, just to refresh your memory, was held on 2 Thursday the 13th, so the 10th was Monday and the lith was 3 a Tuesday.. 4 A I could look at my travel-vouchers. I got 5 there before -- I am pretty sure I was there by the lith, 6 .if not earlier. 7 Q On the lith, this itinerary indicates there was 8 a joint training session with FEMA evaluators, controllers 9 and simulators. Did you attend that joint training 10 session, do you recall? 11 A I don't recall which ones I attended and which /) 12 ones I didn't. I guess I must have, because I am down (/ 13 here as being on the agenda. 14 Q I take it you have no specific recollection, 15 though, of that training session? 16 A No, no. Somewhere along the line I had to tell 17 those observers what to do with the press, if they had any 10 press inquiries, how to handle it. I do that on every 19 exercise where I am an evaluator, I stand up and say this 20 is what I expect you to do, if you are called by a 21 reporter. 22 Q Again, just for purposes of clarification, I ACE-FEDERAL REPORTERS, INC. M-147 3700 Nationwide Coserage An336-6M6

z 28980,1 cox 41 [i.e 1~ 'think in that sentence you used observers, evaluators. 2 A No. 3 Q You are not distinguishing between the two? 4 A No. 5 Q Do you recall, Ms. Jackson, if any LERO 6 controllers _ attended the February 11 training session?. 7 A Who were the LERO controllers? 8 MR. CUMMING: I can't explain his question. 9 THE WITNESS: Who were the LERO controllers? 10 BY MR. MILLER: 11 Q Let me ask you. Are you aware of the fact that () 12 there were controllers at the Shoreham exercise? 13 A What are controllers? 14 Q Do you know the-difference between a controller 15 and evaluator, simulator, for the purpose of the this 16 Shoreham exercise? 17 A Yes, definitely. 18 Q What is your understanding of what a controller i j 19 was? 20 A A controller is someone who doesn't have a role I 21 as far as evaluator, but they are people who are standing 22 in, they are standing in for individuals who weren't !(1) ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Cmcrage 843%f6m

4 28980.1-cox 42 1 participating in the exercise, mainly county and state 2 officials. We had them because we wanted to evaluate the 3 LERO ability to interface with them. 4 Q Are you defining " controller" to me or S " simulator"? 6 A Maybe I am defining " simulator." Let me think 7 about it. I think I have those two terms confused in my 8 mind. 9 Q Do you have an understanding of whom a 10 controller would have been during this Shoreham exercise? 11 A I think that a controller is a person who O 12 inputs information into the exercise. ,LJ 13 Q Is it your understanding that there were LEHO 14 controllers as well as FEMA controllers; or do you know? 15 A I don't recall. I don't recall. 16 Q On page 2 of this itinerary, Laine Exhibit 2, 17 Ms. Jackson, it indicates "PIO activities to be covered by 18 Marianne Jackson, Roger Kowleski"; do you see that? 19 A Yes. 20 Q What exactly did you do during this training 21 session with respect to public information activities? 22 A I basically told them how to handle the press, oV ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide roserage Ank34M46

28980.1 -cox 43 in, s,/ 1 Q What was your advice? 2 A Well, my advice was the advice that I always 3 give them. Don't talk to reporters if you can avoid it. 4 You know, we had a lot of real aggressive press out there S covering that. So I was particularly concerned that they 6 understand what the policy was. They could give their 7 name and explain what they were doing, and tell a reporter 8 that they couldn't really say any more, because their job 9 was to evaluate whatever function they were assigned to 10 evaluate. 11 Q Would your advice have been the same to any (O, 12 FEMA controllers or simulators? vi 13 A Oh, yes, yes. 14 Q Who was it that should have dealt with the 15 press and who was it that you advised to deal with the 16 press? 17 A Either me or Hill McAda. 18 Q What about Roger Kowleski? 19 A No. 20 Q Frank Petrone? 21 A No. Frank would talk to the press. He was 22 very good with the press. But for control purposes, the o U ACE-FEDERAL REPORTERS, INC. 3,m.m., s.<_ u. ~..,. m-

.-.-..~.-.; ~28980.1 cox 44 , ~. V. 1 policy was it would'come to me. If a. reporter wanted to 2-talk to Frank, they would ask me. Then I would check with 3 Frank.to see if he was interested in.doing it and we would 4 discuss it. That's standard operating procedure for press 5 relations operations. 6 Q I assume from your testimony that with respect 7 to the day of'the exercise, your advice to controllers, 8 s'imula tors, evaluators, was to have the press talk to Bill i 9 McAda? 10 A Right. We also say that we don't have anything - 11 to say. And until the oral critique, which I think was on 12 Saturday morning, we really wouldn't have anything to say 13 about how the exercise went. 14 Q Did you attend the 1:15 to 3:00 p.m. training 15 session? r j 16 A I don't remember. 17 Q That's on February 11; you don't recall? 18 A No. You know, I may have. 19 Q Do you recall at all what you were doing on 20 February 11, 1986? 21 A Well, I was in one of these meetings. I 22 also -- i O 4 ACE-FEDERAL REPORTERS, INC. 202 347-37tU Nationwide Coverage No M&M

e _..._ - ~_ __ ~ k i 28980.1 cox: 45 ,h 1 Q One of what meetings? The first meeting I .2 asked about went from 8:30 to 12:00, the'second. meeting 3 went from 3:00 or so;.you could have been at both 4 meetings? 5 A Yes. 6 Q' You don't recall if you were at one, or both or 7 not? 8 A No, I don't recall, i 9 Q The same question, Ms. Jackson, if you turn to 10 the next page, there was a meeting 1:15 to 5:00, training 11 session with simulators, state and county functions. Do ~ 12 you know if you attended that meeting? 13 A I think I attended that meeting, because I 14 remember -- I think I remember Bernie Weiss from NRC l 15 talking about some stuff. I 16 Q Do you know if you were at that meeting the 17 entire time or just portions of that meeting, or do you 4 18 recall? I' 19 A I don't recall. 20 Q Who was the ENC team leader, or was there one? 21 A I think it was me. ) - 22 Q You were the only evaluator at the ENC? i O J ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide roserage 84336 6M6

= 28980.1 _cox-46 .nwide Coverage 800-33M646

-347-3700

28980.1 =cox o62 (, 1 j' 1 A As I said, it was given to us at one of those 2 briefings; and it was given to all the observers just so 3 they would know in case they had time to call. It was 4 someone from LILCO. I don't remember who it was. 5 Q But the number, you think, was given to all the 6 federal evaluators at the exercise? 7 A Yes, I think so. 8 Q Were all evaluators requested to call that 9 number at some point during the day? 10 A No. What we do on control, this is 11 traditionally the way we have done it on exercises, at I") 12 least in Region II, it's fallen to the PIO to have primary (/ 13 responsibilities for checking rumor control. When I give 14 the press briefing to observers, I say here is the rumor 15 control number. If you have a chance, call it to see if 16 they have accurate information. 17 Q Do you know if anyone tried calling that number 18 other than yourself? 19 A I don't recall, and it would be on -- if they 20 had done it, they might have put it on their evaluation 21 sheets. 22 Q Do you assume if they would have noted that ~~ (G l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-33MM6 m.

28980.1 cox 63 (_) 1 information on their evaluation sheet, that information 2 would have made its way into the FEMA report? 3 A No, not necessarily. Not necessarily. 4 Q The FEMA report, to your knowledge, references 5. this one response by rumor control. 6 A Yes. 7 Q That's the response that you attempted to make 8 and the information that you were given; correct? 9 A Yes. 10 Q You are saying if other people would have tried 11 again through rumor control with the same results or ) 12 different results, that might not have shown up in the 13 FEMA report? 14 A Right. 15 Q At the press briefing you just mentioned, ~ 16 Ms. Jackson, that's the press briefing where you simply 17 said to the evaluators, you are not to deal directly with 18 the press, refer them to me or Bill McAda? 19 A Right. 20 Q Your understanding of the rumor control 21 operation the day of the exercise is that if calls are 22 made to LILCO offices, those calls were then made to the O , o t i ~ ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 80433MM6 .=.,.

s28980.1 cox 64 .( 3 ' C/ ' 1 ENC? 2 A I think what the -- my understanding is the 3~ plan calls for -- calls the general public.to call these 4 LILCd offices. But because the exercise-was so unusual, I 5 am not sure where that number was being answered that we 6 were given. 7 Q All.you know is that you had a number for rumor 8 control, you tried calling that number, at least once you 9 got a busy signal and the other time you got a wrong 10 information; is that correct? 11 A Right. I also know that the people were in the L/~')T -12 emergency news center, because part of the problem was 13 that they weren't getting the EBS messages in a timely 14 basis. That's why they gave me the wrong information. 15 They gave me outdated information. 16 Q Based upon what you have just told me' abo'ut 17 LILCO's runor control operation, what conclusions did you 18 draw about that operation? 19 A Well, we cited it as a deficiency. They-were 20 deficient in that area. 21 Q Let me go on to the media briefing room. I 22 assume you also -- that's the other place where you would !O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmerage 800-336-6M6

4 R 128980.1 cox 65 1,,/ 1-go and you made observations; correct?- 2 A .Yes. ~ 3 Q That's the room where the simulated briefings 4 to the press were actually carried out; correct? 5 A Right. T 6 Q That was Mr. McCaffrey and Ms. Robinson; 7 correct? 8 A-All right. It was Elaine and -- I guess I 9-forget the other person's name. But he was the~LILCO 10 person. 11 Q The LILCO person?

( )

12 A Yes, the LILCO PIO person. 13 Q Were you supposed to evaluate the performance 14 of Ms. Robinson during these press briefings? 15 A Yes. 16 Q Did your responsibilities also include the 17 LILCO person? 18 A No. 4 19 Q That was an NRC person that had that job of 20 evaluating? 21-A Right. 22 Q I take it that in terms of your observations in oO ACE-FEDERAL REPORTERS, INC. 202 347 Nationwide Coverage 800-336-6646 . -_, -3700

2898 0 ~.1

, :cox 66 J f'. ~ -1 the. media briefing room, those observations were limited 2 in time to when LILCO and LERO were holding these mock 3 p'ress reviews?' 4 .A -Exactly. 5 Q. There were six of those'during that. exercise; -6 is that correct? 7 A I have to look at this'. 8-Q Referring to the FEMA report. 9 A Yes. Does it say six in the FEMA report? Oh, i 10 right, yes. Six news--briefings, right. 11 Q Did you observe all six briefings? 12 A Yes. 13 -Q Ms. Ja'ckson,.I assume that you had-the ability 14 to basically move around anywhere you wanted to within the 15 ENC on the day of the exercise? 16 A Yes. Right. 17 Q. You just picked and choose then where you would 18 be at any given time? 19 A Correct. 20 Q In the LERO PIO Work room that you refer to, is 21 that the area where prior to a mock press briefing in the 22 media briefing room, people would advise Ms. Robinson as O d ACE-FEDERAL REPORTERS, INC. M 347 3700 Nationwide Coverage 800 3364M6 ...~.

28980.1 cox. 67 1 fs I) I to the information to provide during the press briefing? s 2 A Yes. -3 0 -That's where the actual information came in-4 over the fax and the telephones and so forth? 5 A-Right, right. 6 Q And-the copies of the EBS messages that came to 7 ENC came in through the LERO PIO work room; is that 8 correct? 9 A Yes. I believe so. I saw that one fax. I 10 think there was one fax machine in that room, and I think 11 that that is the one that they were relying on to get the (} 12 -- for getting the EBS messages from the EOC. 13 Q There were also press releases that were issued ~14 at the ENC; is that correct? 15 A Yes. 16 Q Where were those press releases prepared? T 17 A I don't know. l 18 Q Did you ever see a press release being l 19 prepared? l l 20 A No. l ( 21 Q Did you ever see a press release posted at the l 22 ENC? l oU f ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80tk33MM6

28980.l' cox 60 Q 1 A Yes, I believe I saw some press releases 2 posted. ~3-Q Ms. Jackson, in conducting the evaluation of 4 the ENC on the day of the exercise, I suppose you had 5 occasion to communicate, talk with.various persons at the 6 ENC; is that correct? 7 A Yes. 8 Q Did you talk to players? 9 A Not much. We try to keep that kind of exchange 10 limited. 11 Q When you did talk to players, what would you 12 have talked to them about? 13 A I would ask a question. 14 Q Such as? 15 A Such as have you gotten SBS Number 3 yet, have 16 you gotten EBS Number 5 yet. 17 Q Fairly limited conversations with players? 18 A Yes. 19 Q Did you talk to FEMA controllers? 20 A There weren't any FEMA controllers there. 21 Q Were there any FEMA simulators? 22 A There weren't any FEMA controllers or FEMA O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage MG33MM6

28980.1 cox 69 ,.. ~ (_j ' -1 simulators ~at the ENC. 2 Q So other than players, there were members of -3 the press? 4 A Yes. 5 Q The media? 6 A Yes. I talked to Bill McAda. He was there. 7 Q There were, of course, visitors such as Herb 8 Brown of my law firm, he was there; correct? 9 A Yes. 10 Q Who else would have been at that-facility, 11' players, visitors? -Mr. McAda, yourself? - ['T 12 A Frank Petrone came by. %) 13 Q You did have some occasions to talk to the 14 press during the day? 15 A Yes. 16 Q Did you talk with any of the -- were all the 17 people in these various rooms such as the LERO PIO Work 18 room players in the exercise, to your knowledge? i 19 A I know that there was at-least, I recall that 20 there was one other person who also was an observer 21 there. 22 Q For whom? (E) ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 80433M646 -=- -,,, -..,.,

-28980.1 cox 70 lb.. (-) l' A 'It might have been for the contractor, I don't 2 know. She told me, but I really don't recall. It'wasn't 3 the state. It might have been the contractor. She was 4 basically doing what I was doing. 5 Q Who is the contractor you are referring to? 6 A I don't know. I assume that LILCO, you know, 7 contracted some of this work out. But I know that there 8 was another person there who was doing an evaluation. 9 There was a woman, and that's all I remember. I 10 Q Could it have been LILCO people that were.there 11 acting as observers? -() 12 A Could have been. This is common, I might add. 13 That utilities and the State of New York does it 14 themselves. They bring in their own evaluators. So you 15 have, besides a FEMA evaluators, you have these kinds of 16 subgroups of evaluators. 17 Q Do you recall if you communicated during the 18 day with any LILCO personnel? 19 A No. 20 Q Other than -- I am not talking about -- let's '21 put the players to one side. LILCO personnel other than '22 players? O ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Conerage 80433MM6 u --

28980.1 cox 71 ' V, -1 A No. 2 Q Backing up again, Ms. Jackson, the 3 communications between the ENC and the EOC, to your 4 knowledge, telephone communications and the telefax? 5 A Correct. 6 Q Any other method used,.to your knowledge? 7 A No, not that I observed. 8' Q Ms. Jackson, I am going to show you what we 9 will mark for identification as Jackson Exhibit 3. 10 (Jackson Exhibit 3 identified.) 11 BY iR. MILLER: ( ) 12 Q This is exercise evaluation critique form, 13 dated February 13, 1986, emergency news center. Up in the 14 upper right-hand corner are page numbers, they go'from I 15 page 207 of 219 through 213 of 219. 16 A Yes. 17 Q Have you ever seen these forms before? 18 A Oh, yes. These are the evaluation sheets that 19 we had to use. 20 Q To make sure I understand, these are the sheets 21 that you actually used in putting down your observations 22-of what you saw at the ENC on the day of the exercise; is C) 1 l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80433MM6

28980.1 cox: -72 1 that correct? A Yes. 3 Q Did you note observations on any paper or form 4 other than what I have marked as Jackson Exhibit 3? 5 A Yes. I had to write up a summary, because, you ~ 6 know, because of my quasi-officia1 role as a team leader. 7 I had to pull together like an overview of the emergency 8 public information. 9 Q The summary was written, I assume, after the 4 ^ 10 exercise had ended; is that correct? 11 A Yes. t (}- 12 Q Just in terms of any papers you have generated 13 during the exercise, was there anything other than 14 comments you would have made on the form such as what has 15 been identified as Jackson Exhibi t 3? 16 A. No. It should be just this and the summary. 17 Q We will come back to'the summary, because that' 18 is subsequent to the exercise itself. I am talking about 19 just the exercise. 20 A Okay. During the exercise? -21 Q During the exercise. 22 A Yes. I also kept, you know, kept a log. (1) i ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800 336-6646 -... _ _. _. _ _ _. _. ~..... - _. _ _. _

28980.1 cox 73 .j' 1 Q The log would have indicated what? 2 A Well, basically the log is just a chronology. 3 Q Time line? 4 A It's a time line, when I arrived, what I saw, 5 what the problems were. 6 Q Do you know where your log is now, the log from 7 the day of the exercise? 8 A I believe I turned it in when they asked for 9 all that stuff to be turned in. 10 Q Turned it in to Mr. Kowieski? 11 A Yes. [^) 12 Q And the form such as Jackson Exhibit 3 that you v 13 filled out during your exercise, were they turned into Mr. 14 Kowieski as well? 15 A Yes. 16 Q Do you still have copics in your possession? 17 A No. 18 Q Now, Ms. Jackson, what I have attempted to do 19 here is pull together the critique forms which relate to 20 the seven ENC objectives. 21 A Yes. 22 Q There is one objective per page. These, I will ,.~. .J' ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 8 5 336-6646

E 28980.1-cox 74 ./-

I ).

1 represent'to you, are the forms as produced to us by s '2 Mr. Cumming, your counsel. In other words, there-are 3 certain areas of the form that have been redacted, 4 .particularly under the head ~of " evaluators," there is 5' information redacted; and in the comments and 6 recommendation section. 7 A Yes. 8 Q Anything written there has been redacted. 9 A (Witness nodded head.) 10-Q I assume from your earlier testimony, 11. Ms. Jackson, that you'did evaluate what is identified.as

( )

12 ENC objective 1 on the first page of Jackson Exhibit 3; 13 correct?- 14 A Yes. 15 Q Could.you tell me what you reviewed or observed 16 in ' conducting your evaluation of this objective? 17 A Well, as I said, you know, I got there, I got 18-to the hotel in plenty of time, it was a Holiday Inn, so I 19 sau-them come in at a certain time. They began arriving 20 at 6:41, according to the report, and pulled out all the 2:1 -- pulled out all this equipment. And, you know, 22 approximately one later, one hour later, the phones were g).. q ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646

-28980.1 cox 75 I )~ 1 operational, and they.were ready for the press briefing, m 2 that first press briefing, which.is at 8:44. So it was 3 done well. 4 Q Ms. Jackson, he have no problems whatsoever of 5 your referring to the FEMA report in response to my 6 questions. I would like at least, I would to acknowledge 7 for the record when you are looking at the FEMA report. 8 It may be helpful for you, if you want to look at the 9 report to refresh your recollection, fine. But let's 10 state that. Because otherwise the record will appear, I 11 think, that you are remembering everything that you are (') 12 reading from the report. If you do, that's fine, but I x.s 13 need to know that. 14 A Okay. 15 Q Under the objective listed on the first page of 16 Jackson Exhibit 3, there are some points of review; do you 17 see those? 18 A Yes. 19 Q Tell me your understanding of what these points 20 of review were? 21 A Well, these are things that, you know, if time 22 permits, that we like to look at. t nt> l L ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 804336 # 46 [

28980.1 .cox. 76 . f)/ a 1 Q For.what reason, look at for what reason? s_. 2, A Well, they are kind of -- they are the kinds of 3 things that have to be done in order.to meet the '4 objective.- 5 Q So to determine whether an objective has been 6 met.or has not been met, you were to look, if possible, at 7 the areas listed under these points of review; correct? 8 A Yes. 9 Q So, for example, if you had the time, you would-10 have looked ~at LILCO'OPIP 3.3.3? 11 A Yes. Those-are just the floor plans for the [f) 12 emergency news center, what is stored in the various %) 13 closets, et cetera, et cetera. 14 Q In terms of -- I take it, Ms. Jackson, there 15 wasn't time for you to be looking at the LILCO plan of 16 procedures during the exercise? 17 A No. We had done that before, with the material 18 we were given in our packet'. 19 Q Let's look at the third one down under " points-20 of review": " Presence of system to activate personnel at 21 any time." Do you recall looking at this point of 22 review? O ACE-FEDERAL REPORTERS, INC. 4 202-347-3700 Nationwide Coverage 800-336-6646 .. -.,.. -... ~ - - -. - _... _ ..m...

28980.1 cox 77 1 A You have to use some common sense'here. The 2 LERO PIO -- first of all, the staff, the LERO staff, or 3 whoever they were to activate the thing, showed up, you 4 know, on time, and then they were followed -- they were 5 quickly followed by the LERO PIO people. So, you know, I 6 concluded that there was a system to activate the 7 personnel, at least during the exercise. 8 Q Because people showed up relatively quickly, 9 you concluded that they must have a system to activate 10 those people? 11 A Right. (k) 12 Q With respect to the " Presence of full 13 complement of personnel noted," what would you look at, if 14 anything, to determine whether that aspect of the exercise 15 was satisfied? 16 A Did they i' ave enough people to do the job. 17 Q So you have just basically looked to see if the 18 work was getting done, and if it was, you assume that they 19 had a full complement? 20 A Yes. 21 Q Did you make any notes or observations or 22 comments regarding these specific points that you noted on cU ACE-FEDERAL REPORTERS, INC. u.w.- 8_.

28980.1 cox 78

.-s 3,[ 1 the first'page of Jackson Exhibit 3; do you recall? 2 A If I can refer to the FEMA report on the 3 exercise, the report says that overall activation of the 4 ENC was done well, and I assume that that was pulled from 5 my evaluation critique-form, so I must have indicated on 6 .the form that it was adequate. Or well, actually. 7 Q Do you recall, Ms. Jackson, whether you 8 actually-wrote that sort of coiament or-any comment'under 9 ~the column headed " comments and recommendations" on the 10 day of the exercise? 11 A I don't know. I don't recall. No, I don't I'~) 12 recall. V 13 Q You pointed out by looking at;the FEMA report 14 that your conclusion, under this objective, ENC objective 15 1, was that LERO demonstrated the ability to mobilize this 16 staff and activate its functions in a timely manner? 17 A Yes, yes. 18 Q Do you recall, Ms. Jackson, about what time the 19 ENC was activated and declared operational, I should say? 20 A I will have to refer to the FEMA report. Which 21 says the first press briefing was conducted at 8:44. The 22 news center -- so the news center was up and operational O ACE-FEDERAL REPORTERS, INC. 202-347-3X10 Nationwide Coserage 800-33H646

28980.1 cox 79 <~'s . is-[ 1 by'that point. 2 Q Do you recall about what time the first 3 emergency classification of an unusual event was declared 4 the day of the exercise? 5 A Well, I don't know when the -- I would have to 6 look at the time line. 7 Q Do you recall when an alert was declared on the 't 8 day of the exercise? 9 A I believe that the alert was like 6:25 or 10 something like that. 11 Q And the first press briefing was around 8:44, 'N 12 you say? (J _ 13 A Yes. 14 Q But you concluded that the ENC was activated in 15 a timely manner? 4 16 A Yes. 17 Q Would there be no reason to have press 18 briefings more quickly than over two hours after the 19 declaration of an alert during an actual emergency? 20 A That's an interesting question. I think that 21 you have to bear in mind that as far as emergency public 22 information, the top priority is to get those EBS messages (2) ACE-FEDERAL REPORTERS, INC. 202 347-3M Nationwide Coverage 2336-6M6

4_.- 28980.1 -cox 80 ( ~. (_,)^ 1 out in time. As far as -- I would have to look at an 0654 2 to see when the joint news center, or the emergency news 3 center, is supposedoto be required to be activated. 4 In some places they get it up pretty early. 5 But I don't have any problems with the timing here on the 6 news center. Practically speaking, you know, it takes a 7 while to get one of these centers up and operational and S 8 get people there; and the press is going to find out if 9 there is a problem at a plant, because it's going to be 10 picked up on the wires immediately. 11 So if we are talking about an' hour, hour-and a () 12 half, to get this place opened up and get people there, I i 13 think that that is good. 14 Q I am not talking at any particular time, 15 Ms. Jackson. I understand what you are saying, I think. 16 The FEMA report has the time on it, I think, that we are 17 looking for. I am'looking at table 1-1, page 25. That 18 indicates that an unusual event was declared by the 19 utility, by LILCO, at 5:40 a.m. 20 A Yes. 21 Q The alert was declared at 6:17 a.m., and we-22 have indicated that the first press briefing was at 8:44, ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80 4 336-6646

-28980.1 cox 81 [~}/.- t_ 1. -according to the' FEMA report. That doesn't give you any 2-concerns, Ms. Jackson, in terms of the time between'the 3 declaration of the first two emergency. classifications and 4 the'first press briefing that was held on the day of the e 5 exercise? 6 A No, it doesn't. 7 Q Do you know when the first EBS message was 8 issued on the date of the exercise? 9 A .I am looking at page 26 from the: report. 10- ' Tha't 's the time line on the.EBS messages for protective 11 action. I believe that 6:52 was the first EBS message (]) 12 that was issued. 13 Q Now, what would the press do in your opinion, 14 if you had an EBS' message issued at 6:52, but the facility-15 to deal with:the press wasn't activated for an hour and a 16 Jhalf, until anihour and a half-later had passed?. L - 17. A: Can I explain the difference between an EBS message and news release? 19-Q Sure. 20 A An EBS message is a message from government 21 officials, using a dedicated radio system, and in some 22 places it's tied in with a television system, to get i . O 4 ACE-FEDERAL REPORTERS, INC. 202-347-3700 - Nationwide Coverage 800-336-6M6 4

m ~28980.1- 82 ,N 'cox 7 . ~. s . ri, u i ..y 's ,/ \\_) 1 information to the people at risk. e s 2 That is critical, that is very imp'ortant, being ^' 3 'that is what we always focus in on, are the people.at risk ,3 4 being given complete and timely information as far as what i 5 they are supposed to be doing. 6. " r '3 ^ * "- = - ~ 1 = = = $n E B S, w have this b s 7 15-minute time, we are pretty strict about it, they only ,p s 8 have 15 minutes to get the'EBS message out. I don't think 9 I could possibly~ overemphasize the importance of those EBS s 10 messages. o s What h'ppens, of. course, since we az'e using the-t 11 a [] 12 media, since government officials are using the media to v. 3 13 get the EBS messages out, is going to be picked up, as I, 14 said before, probably by a wire service. You know, one X 4 15 way or the other. People, press-are going to know that sa z .) 16 there is a problem at the plant, and probably they would 17 just run a report that the state, or whoever, ycu.know, is ^ 18 saying that there is a problem, has sounded the sirens, et N 19 cetera, et cetera. I A news release is not that important, because 20 21 news releases are for the press, s ummarizing. riven ts, but 22 they are really not designed to protect people who are at n v 't' i e ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 6M6 JN l

28980.1 cox 83 (,) I risk.in any kind of a situation. That's why we have the .2 emergency broadcast system as a dedicated system, because 3-you really can't rely on the press to say, all right, I am 4-just going to' broadcast messages from the governor about 5 what we should do because of the hurricane heading-towards / 6 New York. 7 Which, you know, leads me back to the question 8 -- to your original question, Mike. If reporters -- the . ). L 'r? 9 first EBS message went out at 6:52. The first press g 10 briefing wasn't held until 8:44. That doesn't, to me, 11 that is not a seriout troblem. It's not a serious (') 12 problem. Because a reporter is just going to have to wait x-13 a little while before he or she.is going to have access to 14 khe officials who are responsible for responding to the t , f. 15

emergency.

I mean, this happens in any kind of disaster, i 16' in any kind of emergency. The information to the people 17 has to go out first. And when the responsible officials li -18 are available, and they should be available as soon as s 19 possible. -But it's a second priority. 20~ Q Thanks for the explanation. You understand the 2f difference between perhaps other plants in-the Shoreham 22 plant from the standpoint of your explanation, and E i (D ACE-FEDERAL REPORTERS, INC. l . 202-347 3700 Nationwide Coverage 800-3E6M6

28980.1 cox 84

(_) 1 government officials. You tie EBS to government officials 2 giving information to people at risk. Under the LILCO 3 plan, those officials would be LERO local officials giving 4 information to people at risk; is that correct? S' A Well, you are suggesting, in my mind, that 6 question raises the whole authority, the whole authority 7 ~ question. 8 Q The whole legal authority question? 9 A Yes. 10 Q If an EBS message, Ms. Jackson, had gone out at 11 6:52, where do you think people, the press, other people, (-)/ 12 would go for their information, if there was no ENC for j 13 them to go to? 14 A Oh, they would call. They would start calJing 15 whoever they would know. 16 Q They would just start calling other people? 17 A Yes. 18 Q They would call their neighbors? 19 A No. I think that they would call government A 20 officials or LERO officials in this kind of lag time; and 21 hopefully those officials will tell them, we are setting 22 up the joint news center, or the emergency news center. O ACE-FEDERAL REPORTERS, INC. 202 Nationwide Coscrage 80Lk336-646 -347-3700

l lI i-- b 28980.1-cox 18 5 qd) 1 What LERO did, and what is a requirement under 0654, is-s 2 that the responsible parties have to conduct annual 3 ' briefings for the press to explain to the press where they. 4 should go in the event of an emergency at the plant. You 5 know, so we are kind of hoping that at all these sites, we 6 are educating the press, so they know there is a joint 7 news center, emergency news center, whatever you call it, 8 that's where they are supposed to go. 9 Q You said though that until the ENC is 10 activated, that people would call LERO officials. What 11 LERO officials would they call? () 12 MS. MC CLESKEY: Object, I don't see any 13 relevance, and a continuing objection to this line of 14 questioning. 15 THE WITNESS: Let me just say that in general, 16 generally speaking, a reporter saw on the AP wire that an '17 EBS message had been issued, you knon, let's use Indian 18 Point, for example, they would call one of the county exec 19 offices or they would call the governor's office in 20 Albany. 21 BY MR. MILLER: 22 Q I am talking about the Sho cham plant and the (q_) ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationside Coserage 800 336-6646

28980.1~ -cox 86 , !'~)N s,. 1 LILCO plan in that plant, who do you think the public or 2 media representatives or anyone else would call to get 3 information? 4 MR. PIRFO: I will object this time. You are .5 just asking her to speculate wildly. 6 MR. MILLER: I am following up on a statement 7' made by the witness. 8 MS. MC CLESKEY: My objection as to relevance 9 on this whole line of questioning stands. To the extent 10 that you are posing a hypothetical, I don't think that you-11' have given enough detail for the witness to adequately ['J ) 12 answer, and to the extent that you are asking her for a 13 legal conclusion as to authority, I object. 14 MR. MILLER: Well, the questions are clearly -15 relevant to the admitted contentions, specifically 16 contentions 38 and 39, which go to the time and the delay 17 between the declaration of the unusual event and alert 18 during the exercise and the time the ENC was activated, 19 and what we contend, county and state, Nassau, contend, 20 would have been the result given making that information 21 available to the public. 22 MR. CUMMING: Counsel for FEMA will state for n~.- ACE-FEDERAL REPORTERS, INC. m.w.- y.y.c-,.

'28980.1 cox 87 j~m_ T,) 1 .the record this is exactly.why,-the reason why the thought s T2 processes, rather than-the events, the day of the 3 exercise, cause a difficult line to be drawn as to what 4 should be objected to and what should not. 5-If counsel for intervenors would like to state 6 this as a hypothetical, we have no objection to the 7 witness answering to the best of her knowledge and 8 belief'. Otherwise, it does seem to me that you have 9 caused the situation to -- the witness to have to 10 speculate ~as to what would happen should certain events 11 occur.

()

12 MR. MILLER: We have to speculate, I agree,. 13 Mr. Cumming, because the Shoreham plant is not operating 14 .and the LILCO plan is a very different plan. Therefore, 15 there is some speculation required. 16 MR. CUMMING: I will object based on 17 relevancy. 18 MS. MC CLESKEY: In addition, Mr. Miller, since-19 your. response was to my objection, EBS was on time and 20 concerned in getting the information to the public. 21 Therefore I don't see any relevance at all to the 22 contentions that you listed and the line of questioning () ACE-FEDERAL REPORTERS, INC. I l 202-347-3700 Nationwide Coverage 800-33MM6

r 28980.1' .cox. 88 . p%;. 1,,) 1 about the ENC, which is basically for the press, coming;up t 2 later. 3 MR.' MILLER: Everyone.has stated'their. 4-objections now. Ms. Jackson, we are.not through. 5 MR. CUMMING: I'want to make it clear, based on 6 her experience, I have no objection toLay witness 7 answering the question if you can phrase the question so .8 that.it is, in fact, relevant and material to the admitted 9-contentions. 10 MR. MILLER: The question I have asked is i 11 relevant and material to the admitted contentions you just .{ } - 12 explained. 13' THE WITNESS: You stated that, but your 14 '_ . explanation missed me. 15 MR. MILLER:- That's my explanation. I.am going 16 to go on unless you instruct her not to answer the next 4 17-question. 18 MR. CUMMING: Ask the next question, then I i - 19 will tell you. 20-MR. MILLER: I have a standing "why." 21 MS. MC CLESKEY: What is that? 22 MR. CUMMING: Could the reporter read it back l L(-) L ACE-FEDERAL REPORTERS, INC. L ( 202 347-3700 Nationwide Coverage 800-336-6646

-28980.1 cox 89 /^)\\ 1 for the record. (. 2 MR. MILLER: It's not necessary, to.save some 3 time. 4-BY MR. MILLER: 5 Q Ms. Jackson, what'is your understanding -- I.am: 6 not trying to rephrase, because I have no idea where I 7 was. I am just going to continue with my question's. What 8 is your understanding as to whom the public or the media 9 would contact prior to the time the ENC is activated under 10 the LILCO plan? 11 MS. MC CLESKEY: Objection. If-you are f 12 . referring to in a real emergency,'the LILCO plan clearly 13 contemplates different participation. 14 MR. MILLER: I appreciate you can state your 15 objection without telling the witness what'you want.the 16 answer to be. Just state your objection, which is-17 relevancy or whatever it is. 18 MS. MC CLESKEY: Well, Mr. Miller, I want her 19 answer to be the truth. 20 MR. MILLER: That's fine, but don't put words 21 in the witness' mouth. 22 MS. MC CLESKEY: I am not attempting to do ("T - (_) ACE-FEDERAL REPORTERS, INC. 202 347 Nationwide Coverage 80433M646 ... -3700

Ih 28980;1- 'cox. 90. 79 -h_)._ 1-sthat. I object to.your question. Its.not clear as a 2 '~ hypothetical as to whether.you are asking her who people 3: would call during an exercise, who people would' call 14 during an emergency, who she thought people might-have 5 called during the exercise. 6 MR.' MILLER: My question-was under the LILCO 7 plan. This witness has stated she has reviewed th'e LILCo. 8 -plan with respect to information regarding public 9 information and awareness. If that's the' case, she should i 10 be able to answer the question: Under the LILCO plan, who 11-is it that the public and the media would contact prior.to j() '12 the time the ENC is activated in the event of an emergency 13 at the Shoreham plant? 14 14R. CUMMING: I don't mean to restate your 15 question, but is your question to the witness do you know 16 what the LILCO plan requires or provides for? 17 MR. MILLER: Of course. 18 MR. CUMMING: Witness may answer the question. 19 MR. MILLER: If the witness doesn't know -- 20 MR. CUMMING: Witness may answer the question. 21 THE WITNESS: So the question is do I know what 22 the LILCO plan provides for as far as who the public

(3 ACE-FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336-6M6 ~. - -. -,....,.... - - -.,,,.....,... -,,, ~. _

28980.1 cox-91 _ y \\. (/ 1' should call? 2 MR. CUMMING: Prior to the ENC being 3 established. 4 THE. WITNESS: Well, the public or-the press? I 5 BY MR. MILLER: 6 Q If you want, we will make them the public first 7 and then the. press second. 8 A I don't know. 9 Q In either case, you don't know? 10 A No. 11 MR. CUMMING: I have no objection to your [~3 12 rephrasing the question as to do you know what happened %,/ 13 the day of the exercise prior to the establishmentfof the 14 ENC. 15 MR. MILLER: That's not the question I want to 16 ask. 17 BY MR. MILLER: 18 Q Ms. Jackson, do you recall looking at the first 19 page of Jackson Exhibit 3, these critique forms? 20 A Yes. il Q What was written under the column " comments and 22 recommendations" by you on the day of the exercise? o> ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33 4 646

(28980.1 cox 92 . /R. . O 1 A .I don't-know. 2-Q -Is it fair to say that if you were to refer to '3 the comments and observations and notes that you made on 4 Lthe day of the exercise on this critique. form, that would 5 . refresh your recollection? 6 A It should. ~ 7 Q So the answer is yes? 8 A Yes. 9 Q Is it fair to say that if you were able to 10 refer to the log that you kept on the day of the exercise, 11 that would refresh your recollection as to the factual () r 12-observations that you made on that day? 13 A Possibly. 14 MR. MILLER: Mr. Cumming, I will again then, as d - 15 we did this morning, restate our request for the completed 16 evaluation critique forms for Ms. Jackson and also in her 17 case, we would request production of her log that was kept 18 on the day of the exercise. 19 MR. CUMMING: Counsel for FEMA will diligently 20 search for such documents. 21 BY MR. MILLER: 1 22 Q Ms. Jackson, look at page 2, please, of Jackson I. (2) I l-ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationside Coverage 800-336-6M6

28980.1 cox 93 [(_,J 1 Exhibit 3. This goes to ENC objective 2. " Demonstrate 2 through rosters the ability to maintain staffing." 3 Did you evaluate what is listed here as the 4 objective 2 for the ENC during the exercise? 5 A Yes. I am referring to the FEMA report, 6 again. I found, or the report states, that I couldn't -- 7 I couldn't evaluate this area because the staffing charts 8 were not at the ENC. They are kept at the LERO EOC. 9 Q So for your finding with respect to this 10 objective, you c.ould not observe it, you could not 11 evaluate it? f') 12 A Right, right. v 13 Q Do you recall if you look at this referenced 14 implementing procedure 3.3.3 attachment on the day of the 15 exercise? 16 A I certainly didn't look at it on the day of the 17 exercise, but I probably looked at it during those couple 18 of days before the exercise when they -- when we had the 19 plan portions to review. This is -- this is a standard 20 thing, to look for the roster. We do it on every 21 exercise. 22 Q Do you know if anyore looked at the roster for r~1 m ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage RKL33MM6

28980.1 cox 94-(-). 1 the ENC on the date of the exercise? 2 A- 'I don't know. 3 Q Do you recall what_you would have written or 4 what you did write under_the column " comments and -5 recommendations" under your critique form? 6 A-I think.I must have written that I wasn't -- I 7 explained why I_wasn't able to observe that. 8-Q Do you recall if anything else was written up 9 there? 10 A I don't recall. 11 Q Looking at page 3 of Jackson Exhibit 3, this j( ) 12 goes to ENC objective 3, " Demonstrate the ability to brief 13 the media in a clear, accurate and timely manner." Did 14 you evaluate that objective during the exercise? 15 A Yes. 16 Q What did you review or observe in evaluating 17 objective 3? 18 A Well, basically, I guess there are two parts to 19 it. First of all, did the LERO PIO staff have clear, 20 accurate and timely information about the response; and, 21 then, secondly, were they able to convey that information-22 clearly, accurately and timely to the press during the

n) i

\\ L ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 80lk336-6646 (

28980.1 -cox 95 ja. (_) I briefings. 2 Q HSo the first part goes to the PIO staff in the 3 LERO work room and the second part goes to essentially 4 Ms. Robinson's performance in giving the mock press 5 release? 6 A Yes, right, correct. 7 Q You observe both of those things during the 8 exercisc? 9 A Yes. The bulk of my time was really spent 10 evaluating those things. 11 Q Evaluating those two things? 12 A Yes. t 13 Q Now, looking at the points of review under ENC 14 objective 3, Ms. Jackson, is it fair to say again these 15 are basically the things you would have wanted to have 16 seen demonstrated in order to make a determination as to 17 whether objective 3 was satisfied, met or not met? 18 A Yes. Except for one thing. Under those points 19 of review, they say " prompt receipt and distribution of 20 hard copy news releases." It really should be "and EBS 21 messages." It's a common -- people commonly confuse those 22 news releases with EBS messages. You know, particularly

.O ACE-FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverar 800-33& % l6

/ K28980.1= cox. 96 1 the people who create these evaluation forms. 2 Q How is it, Ms. Jackson, in looking at these 3-points of review, let's look at, the first one is 4 procedure 3.8.1. Again, I assume on the date of the 5 exercise you did not look at that procedure? 6 A No. I probably looked at it before. 7 Q But the second one, " briefings held regularly 8 and also promptly following new developments." -9 A Yes. 10 Q What would you have looked at to make a 11 determination whether that was done by LERO on the day of 12 the exercise? 13 A Well, I would look at what was happening, and 14 then I would look at when and how often the press 15 briefings were held. 16 Q So you look at how often the press briefings 17 were held? 18 A Yes. 19 Q The manner in which they were held, I suppose? 20 A Yes. 21 Q When it says "promptly follow new 22 developments" -- O ACE-FEDERAL REPORTERS, INC. n.w.~, - - u. c -... \\

4 28980.1 .cox -97 D) (_ 1 A-Yes. 2 Q How promptly should that be? 3 A I feel that press briefings should be held as 4 isoon after EBS messages are issued, which call for 5 protective action, as possible. 6 Q Is that the only time you should hold a press 7 briefing? 8 A No, no. 9 Q When else would you hold a press briefing? 10 A Frequently enough so that new reporters coming 11 in'are briefed. I mean, it would be possible, if I could f( ) 12 - give an example, that there would be only, say, a real 13 slow moving event, and there.was only one EBS message 14 recommending protective action within a 12-hour period. 15 Well, say you would hold a press briefing 16 following the issuance of that particular EBS. But would 17 you just leave it? It wouldn't make sense, as far as your 18 press relations program goes, to have only one in a 19 12-hour period. So it is a matter of judgment. 20 0 The next item, Ms. Jackson, is that briefings 21 should be " accurate, clear and complete." Did you look at 22 that during your evaluation of the ENC? O ACE-FEDERAL REPORTERS, INC. t 3m.m, ~ _ u. e _,.

28980.1 _cox. 98 .N . V 1 A Yes. 2 Q What did.you-look at specifically-to determine 3 whether briefings were accurate, clear'and complete?' 4 A I listened to what the LERO PIO was saying, and 4 5 I looked at the supporting -- the maps and the'other 6 things that-they had in the briefing room. 1 7 _ Q So is it fair to say that you essentially used i 8 your. judgment to' decide whether those factors were met? 9 A Right. 10 Q Essentially, that statement I.just made, that 11 you use your judgment, that would apply to all these 4 ~ (}. 12 factors; correct? You used your judgment in determining 13 whether or not there was prompt receipt and distribution 14 of hard copy news releases? 15 A Well, I think it's a bit more scientific. I 16 don't know what you mean by " judgment." 17 Q Well, when you see the word " prompt," prompt f 18 receipt, I am not sure whether five minutes or 15 minutes 19 would have been prompt. I assume that's the decision that i 20 you were making in your role as an evaluator? 21 A Yes, yes. l 22 Q Therefore, you are exercising some judgment? () ACE-FEDERAL REPORTERS, INC. t .nn -- u. c-. ,,n -

28980.1 cox 99 \\_)/ g 1 A Oh, sure, sure. 2 Q What was your overall conclusion for this 3 objective; do you recall? 4 A If I can refer to the FEMA report. We said 5 that the briefing of the media was partly demonstrated. 6 Again, working with the report, there were problems with 7 -- there were problems with the EBS messages, the timing 8 of the EBS messages. 9 Q Do you recall, Ms. Jackson, if the statements 10 you just made by referring to the FEMA report were all 11 noted in the comments and recommendations section of the (~T 12 critique form? LJ 13 A Yes, I believe they were. 14 Q Do you recall what else, if anything, you noted 15 or commented upon under that section of the form? 16 A No. 17 Q I assume that your recollection would be 18 refreshed if you had your notes and comments and 19 observations to review; is that true? 20 A Yes. 21 Q Do you recall, Ms. Jackson, that there were 22 instances of whether there were -- whether there were / L iV ACE-FEDERAL REPORTERS, INC. 202-347 3700 Naiionwide rmerage 804346M6

'28980.1 cox 100 .i. n;. s-) 1 instances of the LERO spokesperson being unable to answer 2 any. questions from the-press on the day of the exercise?- 3 A I don't recall. 4 Q Do you recall if there were any-instances of' 5 the LERO spokesperson being unable to or providing 6 inaccurate information to the press on the day of the 7 exercise? 8 A I don't believe that any inaccurate information-9 was provided to the press. 10 Q If there would have been such instances, would 11 that have been noted in your notes or observations on this () 12 form? 13 A I believe so. 14 Q Do you recall, Ms. Jackson, that there were 15 instances of delays between the receipt of the EBS. 16 messages and the posting of those messages for the ENC? ~ 17 A Yes. 18 Q Do you recall that there were instances of EBS 19 messages and press releases being posted with deleted 20 material still visible? 21 A Yes, as far as the EBS messages. 22 Q Do you recall, during any of the mock press O ACE-FEDERAL REPORTERS, INC. 202 347-3710 Nationwide Coverage 80lk336-6646

.28980.1-cox .101 n A_j\\ i 1 briefings,.Ms. Jackson, questions from the press'regarding-2 simulated traffic impediments during the exercise? 3 A No, I don't recall. 4 Q Do you recall information provided to the press 5 by the LERO spokesperson regarding traffic impediments 6 that were simulated during the exercise? 7 A I don't recall. 8 Q Were you aware of the fact that the ENC press a 9 briefings were videotaped by LILCO? 10 A

yes, 11 Q

Have you seen that videotape? (~h 12 A No. %) 13 Q Are you aware of the fact that there were 14 simulated traffic impediments on the day of the exercisg? 15 .A Oh, yes, yes. 16 Q Are you aware of the fact that LILCO -- LERO's 17 response to those impediments was judged less than 18 satisfactory by FEMA? 19 A No, I wasn't aware of that. 20 Q Let's look at ENC objective 4 on page 4 of 21 Jackson Exhibit 3, " Demonstrate the ability to share 22 information with other agencies at the ENC prior to its oV ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-3346M6

~ i 28980.1 cox-102 j'y. -(j-1 release." I assume, Ms. Jackson, that you evaluated this 2. objective? ~ 3 'A Yes'. 4-Q What did you review or observe in connection 5 with this-objective? '6 A Just if Elaine coordinated what she was saying 7 with the LILCO PIO. 8 Q Well, is it fair then to say that the only 9 agencies that were involved at the ENC was LILCO and LERO? 10 A Yes. 11 Q Who prepared these critique forms, Ms. Jackson; O, 12 do you know? .%J 13 A No, I don't. 14 Q So by watching the coordination' interplay 15 between Ms. Robinson and the LILCO spokesperson, you drew 16 conclusions about objective 4 of the ENC? 17 A Right. 18 Q Based upon your judgment, you concluded, I 19 think, that this objective was satisfied; is that correct? 20 A We said in the report that emergency personnel 21 at the ENC adequately demonstrated the ability to share 22 information with other agencies prior to its release. g ACE-FEDEIML REPORTERS, INC. 202-347-3700 Nationside Coserage 8043364M6

f28980.1 cox 103 ,'( j 1 LERO and LILCO PIO staff members shared and exchanged 2 information throughout the exercise. 3 Q Again, the. agency there, that is LILCO you are 4 talking about? 5 A Correct. 6 -Q Do you recall whether the statements you just 7 basically read from the FEMA report,RMs. Jackson, would 8 have been noted in the comments and recommendation section 9-of your critique form for this objective? Beyond comments 10 regarding ENC objective 4 in your critique form? 11 A. No. I guess I should point out that if the ~ (3 12 objective was. met, we didn't have to write anything. %,) 13 Q So it's possible you didn't write anything?- 14 A-Right. 15 Q You recall, Ms. Jackson, on the day of the 16 exercise, if at any time during a press briefing the LERO 17 spokesperson was indicating that only certain zones, 18 rather than the entire EPZ, were being recommended to 19 evacuate, even though, in fact, at that time, the 20 protective action recommendation was to evacuate the 21 entire EPZ? 22 A No, I don't recall that. 1 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 8@33646

f --l .28980.1-cox-104' f) (_ 1 Q If that would have happened, do you think that 2 would be' indicated in your notes or comments'on your 3 critique form? 4 A Yes. I think it would have been. 5 Q. Now, on 5, Ms. Jackson, of Exhibit 3, we are 6 dealing with objective-5, " Demonstrate the ability to 7 -establish and operate rumor control in a coordinated 8 manner." 9 MR. CUMMING: Michael, excuse me, I assume we 10 are going on for some period of time. We have been an 11 hour and a half since the last short break. Can we take f') 12 another short break? U 13 MR. MILLER: Sure. Let's go off the record. 14 (Discussion off the record.) 15 BY MR. MILLER: 16 Q Ms. Jackson, at the bottom of the critique form 17 for ENC, objective 5, it notes in big bold letters 18 " Evaluator must identify deficiencies or corrective 19 actions in following pages." Would you have done that for 20 ENC objective 5? 21 A I don't recall. 22 Q Do you recall what you did write in the column O ACE-FEDERAL REPORTERS, INC. M 347 3700 Nationwide Courage kn336-u46

28980.1 cox 105 P (3 (/ 1 . entitled " comments and recommendations" with respect.to 2 ENC objective 5? 3 .A No. 4 Q With respect to the. points of review of that 5 objective, Ms. Jackson, one of those is to determine 6 ' whether the " rumor control number set up with capability 7 to handle multiple calls simultaneously"; do you see that 8 one? 9 A Yes. L 10 0 Did you see or observe anything that would lead 11 you to believe LERO was able to satisfy that point of 12 review? 13 A As I mentioned earlier, I recall getting a busy 14 signal, you know, on one occasion. 15 Q So would that indicate to you that they did not 16 have a capability to handle multiple calls simultaneously? 17 A Yes. 2 18 Q And the last point of review, " ability of rumor 19 control staff to provide current, accurate information in 2 20 a timely manner," I take it that you would have found that 21 that factor was not satisfied during the exercise? e 22 A Yes. O i ACE-FEDERAL REPORTERS, INC. M-347 370) Nationwide roverage RX)-34(M6

28980.1 cox 106-r\\.. - ( JL 1 Q .That's based upon the fact that when you'did 2 get through to rumor control, you got inaccurate outdated 3l information? 4 A Correct. -5 Q Looking at page 6 of Jackson Exhibit 3, ENC 2 6 objective 6, " Demonstrate that the ENC has adequate space, 7 equipment, and supplies to support emergency operations." 8 Again, I assume you had responsibilities for evaluating 9 this objective? 10 A correct. 11 Q What did you look at or observe in making an () 12 evaluation of objective 6? 13 A Well, I looked to see if there were enough ) 14 telephones, if they had enough space, if there were places 15 to sit down, both for the PIO, the LERO PIO staff, and 16 also, you know, the press that were using the facility 17 that day. 18 Q Based upon those observations you made, 19 Ms. Jackson, do you recall what your conclusions were with I 20 respect to this objective? 21 A Referring to the report, you know, which was 22 based on my input, there were problems with copying oV ACE-FEDERAL REPORTERS, INC. 202-347 37(M Nationnide Coserage NXh3h6646

28980.1~ cox 107 ym (_) 1-capabilities, and it seems like-a small thing, I guess, _2 but it had a big effect on getting those EBS messages out 3 to the press.. 4 Q So you found that this objective was not met; 5 is that correct? 6 A Yes, we cited it as a deficiency. 7 Q Do you recall if you followed instructions at 8 the bottom of the critique form in identifying 9 deficiencies or corrective actions with recommendations on 10 the following page? 11 A No, I don't. () 12 Q You don't recall it?- 13 A No. 14 Q Ms. Jackson, you just stated that you made a 15 comment that the FEMA report was based upon your input? 16 A Yes. 17 Q What other input would there have been for the 10 FEMA report with respect to the ENC other than your input? 19 A Looking over the report, I. don't think there 20 would have been any other input. 21 Q Decause you were the only evaluator? 22 A Hight, except to say that as far as the EBS O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage sk33MM6

28980.1 cox 108 fN. () 1 messages go, I was'not at the EOC. So I'did not know what' 2 time they simulated calling those EBS messages into the 3-radio station. On the EBS messages, had a lot of times on 1 4 them-and a lot of signatures, et cetera, et cetera. But I 5 had to rely on the observer at the EOC, because that was 6 the person who was watching the PIO person,. or whoever it 7 was at the EOC, pick up the call, pick up the phone and 8 simulate calling that EBS message in. So I needed that 9 information, you know, after the exercise was over. To 10 see if there were problems, if there were delays in 11 getting the EBS messages down to the ENC. f') 12 Q Were you given that-information at the exercise s_- 13 -- after the exercise? 14 A At the exercise? 15 Q After the exercise. 16 A Yes. 17 0 Immediately after the exercise. 18 A No -- well, we would have to refer to that 19 schedule of meetings and everything. 4 20 Q Okay. You mentioned earlier today that you 21 prepared a summary of what you observed at the ENC? 22 A Yes. l lCE) i I I ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 8 @ 336-6646 1

t , A. 28980.1 scox 109 in.. sl 1 Q In that summary, did you discuss the EBS 2 messages that you were just referring to? 3 Af I.believe I did. 4 Q That summary was prepared the evening of the 5-exercise; is'that correct? Or~the.following day? 6 A I don't. recall. 7 Q Did it have to either be the evening of the 8 exercise or the following day? I 9 A Yes. Q Now, who would have provided that information 10 3, 'il to you about the EBS messages? 12 A Ifwas someone from the EOC. I think it was - 13 Hugh Laine. The evening of the exercise, what we did is 14 we did a time line. You will be hearing this from other 15 people, if you haven't heard it already, where everyone 16 who saw a piece of the action basically said this is the M

L 1

17 time I saw it. So that we were able to fill in this page 18 from the report, you know, the emergency classification 19 time line. 20 Q What page are you referring to? 21 A Table 1.1. Doesn't have a page number on it. t 22. Q So that page of the PEMA report was essentially

.t '

x e, p. %) 4 ACE-FEDERAL REPORTERS, INC. 202 347 370) Nationwide Coverage 8013M-%86

28980.1 =cox 110 1 put together the evening of the exercise? 2 A Exactly. Then we also prepared another one on 3 protective action decisions and EBS times. 4 Q That is page 26? y S A Page 26, yes. 6 Q Was that.'also put together, early evening after 7 the exercise? 8 A. Yes. 9 Q When you say we put those together, who is the 10 "we"? 11-A All the observers. We went back to the hotel, 'i ( , j,12 and I don't know if we got dinner or what. We do this i [ 13 after every' exercise. All the observers convene and we s 14-fill in this time line, and the team leaders kind of giv's ,15 a brief summary of how things went and what information t . (( ,13 they might need from another team so that they can get the 5. 4 i 17-complete picture. 18 Q Looking at that page, page 7 of Jackson Exhibit 19 3, that deals with objective 7, which is to " Demonstrate (' T 20 that the ENC has adcaaate access control and that security 21 can be maintained." You had responsibilities for 22 evaluating this objective, I assume. e sg ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coterare v-804336-6M6 ,.L.,_._

i 28980.1 cox 111 j 1 A Yes. 2 Q Do you recall what you look at in conducting 3 your evaluation of this objective? 4 A Yes. 5 Q What was that? I 6 A Well, I looked at how easy it would have been 1 l l 7 for somebody to get into that area, and they had lots of hJ IM}1 system; s 8 guards all over the place, and they had a h'+<- 9 and in addition, the layout was good, because there 10 weren't that many entrances into the basement at the 11 Holiday Inn. So it was pretty good. s 12 Q Do you recall what you actually wrote in the 13 comments and recommendations section of your critique 14 form? 15 A No. 16 Q Ms. Jackson, let's return for a moment to the 17 itinerary, which is Laine Exhibit 2. 18 0 If you look at page 5 of the pages, 19 Ms. Jackson, that begins a discussion on the date of the 20 exercise. The notation at the bottom of that page, "7:30 21 to 8:30 p.m., meeting of all evaluators, controllers, and 22 simulators with RAC chairman and lead controller." Is () V ACE-FEDERAL REPORTERS, INC. l .m ~_m_. ~~ I

28980.1 'coX 112 (_) 1 that where you put together the time line you were 2-referring to a few moments ago earlier? 3 A Yes. 4. Q That was just a large meeting of everyone, all 5 the federal evaluators connected with the exercise? 6 A Right. 7 0 Who basically conducted that meeting? 8 A I believe it was Roger Kowieski. 9 Q Then if you turn the page, 8:30 p.m. to 10 completion, the event is classified as " team leaders meet 11 with their team members and simulators." (f 12 Under the remarks section, Ms. Jackson, it 13 talks about that the team leaders will develop and 14 exercise highlights, summary, narrative. Is that the 15 summary that you have referred to earlier? 16 A Yes. 17 Q So this indicates that would have been 18 prepared, I guess at least in part, beginning the evening. 19 after the exercise? 20 A Yes. 21 Q On February 13, and then you continued down to 22 February 14, and it appears that perhaps some people were O ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 800 336-6M6

28980.1 cox 113 7._.s (_) 1 still drafting the next morning; that is correct? 2 A Yes. 3 0 In your summary, did you corroborate with 4 anyone else in preparing that summary? 5 A Hugh Laine. 6 Q So you and Mr..Laine prepared the summary? 7 A Yes. 8 Q Mr. Laine's involvement was just from the 9 standpoint of EBS message preparation at the EOC? A 10 A Yes, I believe so. 11 Q So.is it fair to say that the bulk of the ' f'/ ) 12 summary wa.9 prepared by you? \\_ 13 A Yes. 14 Q Approximately how long was this summary? 15 A I don't recall. 16 Q Do you-recall if-it was five pages, 10 pages, 17 two pages? 18 A We are always asked to keep them brief. It was 19 no more than -- I don't think it was no more than one or 20 two pages, typewritten. 21 Q Was the summary, Ms. Jackson, the basis for the. 22 FEMA report? Was your summary of the ENC activities the Av l l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationside Coverage MG33M686 , -... -. =,

28980.1 coy 114 s - w,/ .1 basis for the FEMA report, those sections dealing with the 2 ENC? 3 A I assumed so. 4 Q To your knowledge, would there have been -- 5 let's back up. You have mentioned a log that you have 6 maintained the day of the exercise at the ENC. 7 A Right. 8 0 You have mentioned the completed critique forms 9 in which you put your factual cbservations, notes, on the 10 day of the exercise. You have mentioned the summary that 11 you and Mr. Laine prepared beginning the evening on the , f')') 12 day of the exercise. 13 A Right. 14 Q Now, other than those three things, to your 15 knowledge, was there any other written materials regarding 16 LERO's performance at the ENC, other than those three 17 things; is there anything else? i 18 A Copies of the EBS messages, and copies of the 19 news releases as well, but, more importantly, the EBS 20 messages. 1 21 Q But in terms of observations, critique 22 comments, notes regarding performance, those sorts of c . V i ? l l ACE-FEDERAL REPORTERS, INC. l 202-347-37to Nationwide Coserage 233MM6

28980.1 cox 115 k) I things regarding the ENC, I as.sume they would have been m 2 noted by you in either your log or your critique form or 3 in your summary or in all of those; is that correct? 4 A Yes. 5 Q There would have been no other person noting 6 any of those things? 7 A No. 8 Q But you did not help prepare the actual FEMA 9 report; is that correct? 10 A No. 11 Q You had no drafting responsibility at all for () 12 the FEMA report? Drafting responsibility? 13 A I have review responsibility. 14 Q Did you help draft the FEMA report? 15 A No, thank God. The worst job in the world. 16 Q Can you recall, Ms. Jackson, any notes or 17 observations you would have made on the day of the 18 exercise that don't seem to have made their way into the 19 FEMA report? 20 A No. 21 Q Do you think that everything you noted that day 22 is, indeed, in the final FEMA report? O(~s ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8433M646

~ 28980.1- -cox 116~ I) 1 A-Yes'. s, 2 Q Have you read thezFEMA report to make that 3 determination? 4 A Yes. 5 Q When did you do that? 6 A

Well, I-read it in draf t form, _ and then I read 7

itLin final form. And then I reread it on my sections in 8 preparation for this deposition. 9 Q Did you review the e tire -- have you ever j 10 . reviewed ~the entire FEMA report? 11 A No. (~ } 12' Q So you have reviewed simply those sections -13 relating to the: ENC? 14 A And the summary. 15 Q The up-front summary? 16 A Yes. 17 Q The entire summary or the ENC summary? 18 .A-Oh, the ENC summary. 19 Q Who was your summary given to, the summary-you 20 prepared? 21 A I believe I gave it to Roger. 22 Q Did you have any involvement, from the time ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33MM6

I 28980.'1 cox 117 .,m (_ ) I that' summary was turned in, when was your next involvement 2 with the FEMA evaluation of the Shoreham exercise? 3 A After I turned my summary in to Roger, I may 4 have, what I have done on various exercises, because Roger 5 -or somebody has to make that oral presentation, you know, 6 sometimes I work with them to cut something down or make 7 something readable, because you have team leaders with 8 different levels of writing skills and different styles, 9 so it has to be reviewed, and I think I helped-Roger on 10 the oral critique business of this exercise. 11 Q You are referring to the critique that was 3 -12 given Saturday morning. [J 13 A Saturday morning. 14 Q You turned in the sunmary sometime you think on 15 February.14, which was Friday, and your next real 16 involvement was with helping them prepare for the press 17 critique? 18 A Yes, the oral critique. 19 Q What involvement did you have with that oral 20 critique; what did you do? 21 A First of all, I had to advise the press that we 22 were having it. You know, where and when. And then, you n(/ ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33MM6

28980.1: cox. 118 7_q (_)- 1 know,.I believe, you know, I helped Roger review what he 2 was going to read, and'I believe that Frank actua]1y ended 3l up reading 1the oral critique. 4 Q-Did you write the critique that was read? 5: A No. .Except' insofar as.my emergency news center 6 summary was partLof that statement'. 7 Q Is it-fair to say'that the oral critique was 8 prepared by Roger and/or Frank Petrone taking the summaries prepared by all the team. leaders-and reviewing 10 those to put together their presentation? 11 A I believe so. (v) - ~12 Q On February 14, Ms. Jackson, there are a few 13 things noted on this itinerary. On page 6, of the 14-exhibit, there is a - from 11:00 to 12:00 noon, it's 15 noted "a meeting of the RAC chairman with team leaders." 16 Did you go to that meeting? 17 A I don't recall. 18 Q The next line down, from 8:00 in the morning I l 19 until noon, there was an exit meeting for the FEMA 20 controllers and simulators. Did you go to that meeting; 21 do you. recall? 22 A No, I don't think I went to that meeting. I (Z) ACE-FEDERAL REPORTERS, INC. 202-347-3700 - Nationwide Coverage 80433M4 M

28980.1 cox 119 ) 1 Okay. I don't know. 2 Q If you look on page 7, Ms. Jackson, it talks 3 about the completion of the exercise evaluation forms. 4 It is my understanding from what you have said 5 that at the end of the exercise you took your critique 6 form -- was that the end of the exercise that you took 7 your critique form and handed it in to Mr. Kowieski, end I 8 of the exercise meeting, roughly 5:00 on the 13th? 9 A No. 10 Q When is it that you did that, that you turned 11 in all of your paper to Mr. Kowieski? (v) 12 A I don't know exactly. 13 Q Was it prior to the oral critique on February 14 15th? 15 A yes. 16 Q This time chunk on February 14, 8:30 in the 17 morning till 2:00 in the afternoon, completing the 18 evaluation forms, what is that basically, people were to 19 take their forms and make them more readable and legible? 20 A Yes. 21 Q Do you recall what you did with respect to your 22 critique forms during this time frame? (~) t_/ ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 804336-6M6

28980.1 cox 120 1 A I don't recall. 2 Q Do you recall doing anything with your critique 3 forms that you had filled out during the exercise, 4 subsequent to the exercise and prior to the oral critique? 5 A Somewhere along the line I completed those. I 6 did some work on those critique forms, because during the 7 exercise, I di~dn't have time to fill in the critique 8 form. It's something that you get to to later, really. 9 It has to be, if you are putting something on it, it has 10 to be readable, you have to give examples, you know, rou I () ' 11 just can't be your own notes to yourself during an 12 exercise. 13 Q Let me make sure I understand. During the 14 actual exercise, did you write any -- did you take any 15 notes, make any actual comments, make any notes, note any 16 observations? 17 A Yes, on my time line. 18 Q On your time line? 19 A Yes, or whatever we are referring to. My note 20 says. 21 Q You have mentioned a log. 22 A Right, a log. / ~I l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 804336-6M6 l

28980.'1 cox 121 - ew (_) 1 Q. Other than log, did you do anything else in s 2 writing during the actual time of the actual exercise? 3 A No. 4 Q Then after the exercise, you satLdown with 5 these critique forms and filled them'out based upon what 6 you had noted in your log; correct? 7 A correct. 8 Q Your log that you did during the exercise would 9 have noted the time that you observed an event; is that 10 correct? 11 A Correct. (")T 12 Q And I assume what you observed? 13~ A Correct. .14 Q Then was it simply a matter of transferring 15 those notations to the-critique forms? 16 A -Yes. 17 Q Did you elaborate, when you filled outlthe 10 critique form, from what you'had noted in your logs? 19 A Yes. 20 Q In what way would you have elaborated, expanded 21 upon? 22 A Well, give more background, something that is -oo ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwida Coverage 800-336-6646

28980.1 cox. 122 k,-) 1 still fresh in your mind, but that you didn't want to-2 spend time putting it in on the log, like, for example, 3 the business of the facilities. Well, one glance and you 4 can see that there is enough, that there is enough space. 5 So maybe you would say space is - " space okay." But then 6 you would elaborate to say there was adequate this, that 7 and the other thing. 8 Q Now, on February 14, again, I am looking at 9 page 7, there is a briefing of LILCO that is noted from 10 3:00 to 4:00. Did you attend that briefing? 11. A I don't recall. 'f'/Y 12 Q So is it fair to say that after you completed x_ 13 your critique forms, based upon what you had noted in your 14 logs, the next thing you recall having done in connection 15 with the exercise was preparing for the oral critique? 16 A Correct. -17 Q And after the oral critique on that date, the 18 15th of February, what was your next involvement with 19 respect to the Shoreham exercise? 20 A We had a continuous flow of media inquiries 21 about the exercise. 22-Q So you were back in your role as a public O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6 646 ~

'-?; p ;

c 128980.1 cox 123 T_j-1 information officer of FEMA? 2 A Correct. 3 Q In your role _as an evaluator, and even team 4 leader of.the ENC, did you have any involvement after the 5 exercise was completed and you went after the oral 6 critique on February 15? 7 A-I had to review the draft report. 8 Q Did you review all.the drafts-of the FEMA 9 report, or just one draft, or do you recall?- 10 A I don't recall. 11 Q Again, you reviewed only th se sections f')\\ 12 relating to the ENC; is that correct? m 13 A Yes. 14 Q Other than reviewing those sections on the ENC 15 in the draft FEMA report, did you have any other 16 involvement following the conclusion of the Shoreham 17 -exercise? 18 A Yes, I did. 19 Q What was that? m 20 A Well, we had -- Tom Baldwin was working on the 21 draft of the report, and we had to look at the -- one 22 thing I know that we discussed, we had to look at the time tR O ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 800-334 6646 ~

28980.1: -124 cox- , ~\\ _ (). 1 of the-EBS messages, because that's really, you'know, 2 that's really critical, if they got them out in the 15 3 minutes; and as I mentioned earlier, the EBS messages had 4 a lot of things written on them, so we were trying to, you 5 know, determine for sure what was the correct time.- This 6 is -- this kind of. thing happens all the time when the 7 people who are writing up the report may contact 8 observers. I mean, and ask them questions about what they 9 wrote. 10 Q Was it Mr. Baldwin that contacted you to ask-11 you about the timing of the EBS messages? O 12 A I don't recall. V-13 .Q Were you working with Mr. Baldwin in trying to 14 resolve those questions regarding the timing of the 15 -messages? 16 A No. 17' Q What was the nature of the contact to you on 18 these EBS messages? 19 A I guess Tom, if I recall, was working in the 20 of fice on it, and trying to pull it together, and as 21 questions came up, he would come to me. Maybe I didn't 22 answer that previous question right. O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646

28980.1 cox' 125 ) 1: Q So we talked about after the oral critique, you 2 reviewed a draft of the FEMA report, and you worked or 3 talked to Mr.-Baldwin about the timing of the EBS r 4 messages? 5 A Right. 6 Q So anything else you can think of that you have 7 done since the Shoreham exercise regarding that exercise, 8 other-than' handle press inquiries? 9 A No. 10 0 I assume that your working with Mr. Baldwin on 11 the timing of-the EBS. messages would have preceded your f) 12 review of the FEMA draft-report? v 13 A Yes. 14 Q Do you think, Ms. Jackson, you were able to 15 resolve adequately the timing of these EBS messages? 16 A Yes. 17 Q How did you do that? 18 A I don't recall. 19 Q But you think it was resolved to your 20 satisfaction? 21-A Yes. 22 Q Ms. Jackson, when you were preparing your final (2). ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage t E336-6M6

1 - 28980.1 cox 126 .g A,/ - 1 versions of the critique forms, based upon your log. s 2' A Yes. 3 Q Notes in your log. Do you recall if you did 4 not put in your -- on your critique form, any matters that 5 you had observed as noted in your log? 6 A I beg your pardon. Would repeat that 7 question. 8 Q In other words, were there any matters noted in 9 your log from the exercise itself, that were not also 10 noted on the exercise _ critique forms by you? 11 A I don't recall. (') 12 Q Do you know who drafted the FEMA report? Was %/ 13 it more than one person? 14 A I don't know. 15 Q You don't know who drafted it and you don't 16 know if it was more than one person? 17 A I know that Tom Baldwin worked on it. And,'you 18 know, beyond that, it's speculation, Mike. I don't know. 19 Q Do you know who drafted the ENC sect'ons of the 20 PEMA report? 21 A No, I am not certain. 22 Q Did you have any comments on the draft version n O t ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800 336-6646

28980.1 .cox 127 ,m;, i) 1 of the FEMA report'that you reviewed with respect to the-s 2 ENC? 3 A I don't-recall. 4 Q Do you recall if that draft version'was changed 5 whatsoever in response to anything you would have done? 6 A That's the same question. I don't recall. 7 Q Ms. Jackson, did you have anything to do with 8 the FEMA's' evaluation of the LILCO EBS system during the 9 exercise? 10 A No. I didn't. 11 Q Do you recall about when you reviewed the draft ] ) 12 version of the FEMA report? The final report is dated, I 13 think, April 17, 1986, if that helps. 14 A No,'I don't recall. 1.- 15 Q Ms. Jackson, would you agree with me that i 16 during the exercise, rumor control personnel observed by 17 FEMA were not able to answer questions received from the 18 public because they had not been given accurate up-to-date 19 status reports? 20 A Is that singular or plural? Rumor control 21 people? i 22 Q Personnel? t)- ACE-FEDERAL REPORTERS, INC. l 202 Nationwide Coverage 800-326-M46 .. -347-3700...

4 28980.1 .cox-128 y \\, /. 1 A Personnel. 2 .Q We.can do it single or plural. 3-A I know, based on that one call that I made, that at least one person did not have that information. 4-S 'Q I am sorry, because I think we have covered 6 this, but you do not know if the ENC roster of personnel 7 _ was reviewed by you or anyone at FEMA; is that correct? 8 A Correct. 9 Q Did you see any second or third shift personnel 10 reporting to the ENC? 11 A I don't recall. (p 12 Q Do you recall'if during the exercise LERO 13 simulated a call out of second or third shift personnel? 14 A I don't recall. 15 Q Ms.-Jackson, did you prepare any of the rumor 16 control messages used during the exercise? 17 A-I don't understand your question. i 18 Q Is it your understanding that during the 19 exercise LILCO's district office personnel would get F 20 telephone calls simulating the inquiry from the public? 21 A It's my understanding that that did not happen 22 during the exercise. All I know is that during the O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80433MM6

28980.1 cox 129 t'. (_) 1 exercise, we were given a phone number to call to test 2 rumor control. The other thing I know is that there were 3 rumor control people in the ENC. l 4 Q Do you know if FEMA had anything to do with I f 5 preparing the questions that were simulated coming from l ) 6 the public to LERO's rumor control operation? 7 A Well, sure. 8 Q Did FEMA prepare those questions from the 9 public, simulated questions from the public? 10 A We didn't prepare them. Like, for example, my 11 call, I just called and said, basically, I'm a member of (~)1 12 the general public. If they know you are a FEMA \\_ 13 evaluator, some story, and is it true that such-and-such, 14 and they say, yes. But what I was asking happened to be '15 wrong. 16 Q Tell me your question. What was your question 17 that you asked when you made your call? 18 A I will have to look at this report. It wasn't 19 written. It wasn't written out. It just had something to 20 do with what EPZ had been advised to evacuate, and they 21 gave me the wrong information. 22 Q Do you know if there were any written r~h l \\_/ ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 804336-6M6

-~28980.1 cox 130 . rm '(,[ 1 questions, writt'en in advance of the exercise questions, 2 to LILCO's rumor control operation? 3 A I don't recall. 4 Q You had no involvement if there were, no 5 involvement in preparing those questions? 6 A No, definitely not. 7 Q Is there anywhere in the FEMA report where 8 rumor control is talked about other than in the ENC 9 section of that report? 10 A I don't know. 11 Q I am not going to mark this as an exhibit,-and ' '"N 12 I don't have copies to show to everybody, but this is a

• \\~)

13 rumor. control, it's entitled " Rumor control question 14 number 3." It-has name, blank, rumor control phone 15 number, blank, time, 9:15. It says "This is a drill." 16 .Then it has a question. "My friend in Coram just heard _a 17 siren go off. My family is in Roslyn. What should they 18 do?" Then there is a handwritten response. 19 MS. MC CLESKEY: Mr. Miller, I object to you 20 asking questions from a document you are not going to 21 mark, unless you mark it as an exhibit and give us all 22 copies so we know what you are referring to. O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-(M6

1 28980.1~ .cox. 131 N_/ 1~ MR. MILLER: Fine, we will take a break and 2 make copies. 3 MS. MC CLESKEY: You can go on while it is 4 being' copied. It won't take very long, it's only one 5 page. 6 BY MR. MILLER: .7 Q The question was do you recall this? 8 A No. 9 MR. PIRFO: I am sorry, what was the answer? 10 MR. MILLER: The answer was no. 11 BY M2. MILLER: [v~T-12 Q To your knowledge, Ms. Jackson -- I am going to 13 continue with the questions, unless you want to wait until 14 the copies come back. 15 MS. MC CLESKEY: That would be great. 16 MR. MILLER: That I will continue? 17 MS. MC CLESKEY: It is wonderful that you will 18 continue, since it's 5:30. 19 BY MR. MILLER: 20 Q Ms. Jackson, to your knowledge, did anyone at 21 FEMA involved in this rumor exercise have responsibilities 22 for evaluating LILCO's rumor control, LERO's rumor n < v ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336-6M6

28980.1 ~cox 132 i_) I control, other than yourself? 2 A Yes. 3 Q Who would that have been? 4 A I believe it was all the observers, because 5 everyone, as I explained before, was given the phone 6 number, and asked to call-as time permitted, call rumor 7 control.- 8 Q To your knowledge, no other calls were made 9 other than your-own call; is that correct? 10 A No. 11 MS. MC CLESKEY: Objection, calls 'for-() 12-speculation on the part of the witness. ^ 13 THE WITNESS: No, I don't know. 14 MR. MILLER: I said to her knowledge. 4 15 BY MR. MILLER: 16 Q To your knowledge, the answer is? i 17 A I don't know. 18 Q Have you ever seen anything in writing that 19 indicates anyone other than yourself made telephone calls 1 20 to the rumor control operation? 21 A I don't recall. 22 MR. MILLER: We now have copies of this (1) ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coserage 8M336-6M6

28980.1 cox 133- /~s G 'l -wo'nderful-piece of paper which I:have'already described. 2 Let's mark this as an exhibit, Jackson Exhibit 4. 3 (Jackson Exhibit 4 identified.) 4 MR. MILLER: We have already described the 5

document, f

6 BY MR. MILLER: 7 Q You have already told _me, to your knowledge, 8 you have never seen what is now marked as Jackson Exhibit 9 4. 10-A Yes. I 11 Q Do you know if -- strike that. () 12 Ms. Jackson, wi-th respect to -- let me start 13 again. The Shoreham exercise was an exercise of revision 14 of LILCO's plan; is that correct? '15 ' 'A I don't know what revision it was. 16 Q Are you aware of the fact that since the 17 exercise, there have been revisions to-the LILCO plan by 18 LILCO? 19 A Yes.

i. -

20 Q Are you involved in any way in reviewing the 21 revisions that have been made to the LILCO plan? I 22 A No. n) q-ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33M&6

f .28980.1 cox 134 NJ 1 Q In response to an interrogatory that was served h 1 2 on your counsel, we got back the following answer: 3 " Revision 7 and 8 of LILCO plan are expected to be 4~ reviewed by the following: P..McIntire, M. Jackson," it 5 goes on from there. I will be glad to read the. names if 6 you would like. But is that response inaccurate? 7 A I guess in the future they are going to ask me 8 to take a look-at it again. 9 Q Revisions -- have you reviewed revision 7 or 10 revision 8 of the LILCO plan? 11 A No. (7 12 Q Do you have any reason to anticipate that you %) 13 will be asked to review either of those revisions? 14 A Yes. 15 Q Would that be from the standpoint that we 16 discussed earlier, in your capacity as advisor to the RAC? 17 A Yes, or using my public information expertise. 18 Q You would expect to review just those portions 19 of those revisions relating to the ENC or other public 20 informational matters? 21 A Correct. 22 Q Have you seen LILCO's -- LERO's proposals for i oV ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 804336-6M6

I 28980.1 cox 135 1 resolving deficiencies or corrective actions, recommended 2 corrective actions from the exercise? 3 A No. 4 Q A assume from your earlier answer that you -- 5 it's likely you will see those proposals in connection 6 with the RAC's review of provision 7 and 8? 7 A I don't know. 8 MR. MILLER: Give me just a second. 9 BY MR. MILLER: 10 Q Ms. Jackson, did you believe prior to this, 7 s% 11 were employers apprised that the LERO EBS messages were t N 12 be aired? v 13 MR. CUMMING: Counsel for FEMA objects to the 14 form of the question. Would you restate it. 15 BY MR. MILLER: 16 Q Did you have any reason to believe prior to the 17 exercise that LILCO's messages were going to be aired, 18 broadcast? 19 A That was an area of uncertainty. In most 20 exercises only one EBS message is aired, there is a test 21 message, the sirens are sounded, the lead EBS station runs 22 something saying "if there had been an accident at Indian ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646

o -28980.1~ cox: 136-- .j~q (,) l l'. LPol't, we:would have' asked you to stay tuned,".et cetera, n .2 et cetera. Really, -up' until '--- it was z uncertain-in my -3 mind what was. going to be done,:but then I b'elieve there 4 wasLa court' ruling, and LILCO decided.not'to' sound.the 5 ' sirens. I don't remember-the details of what-happened. 6 .Q Are you saying that1 typically, though~,.thereLis 7 one test EBS message that is broadcast? 8 A Yes. 9. Q Is it your understanding that at.the Shoreham 10 exercise,-that was:also going to be done? 11 A I don't recall what my understanding was. -{ 12 Q It's clear though that there was no EBS. message ~l 13 broadcast'during the Shoreham exercise? 14 A I Lon't;know. -15 Q You don't know whether.they were broadcast or 16 not broadcast? 17 A Correct. 18 Q Have you ever been shown or seen, Ms. Jackson,- 19 the contentions filed in this proceeding on~the Shoreham l 20 exercise, contentions filed by the county, the state, and' 21 the town of South Hampton? 22 A

Yes, i

Q s

ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-33M686

28980.1 ~ cox 137 < y ~l-L 1 -Q-Counsel says yes. 3D 2 A Yes. 3 Q When did you see those-contentions? ' 1 4 A' Just a second. Over the past several days. 5 Q-Did you. review all of-the contentions? 6 A No. 7 Q Did you review the contentions at all, first of 8 all? 9-A Yes. 10 Q Did you review all the contentions? 11 A No. } 12 Q Which contentions did you look atlar review? 13 A Phil McIntire asked me about contentions that i 14 pertain to EBS and emergency news center and rumor 15 control. 16 Q Mr. McIntire asked you about that? 17 A Yes. 18 Q In what connection? Why did he ask you about 19 that? 20 A I don't know. 21 Q Tell me exactly what his question was to you, 22 or what his comment was to you? lO y L-l ' ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800 336-6M6 p

l28980.1 fd l' 138 'cox ( -() 1

• MR. PIRFO:

I.am going.to object te this.line, 2 I don't see any-relevance or that it will lead to 3 anything. It's;r.,elevant because of the 4 MR. MILLER: '5 contentions that are'.in this~ proceeding. 6 MR. FIRFO: I~-don't/see how her reading or not' 7 . reading-the contentions has anything to do with the 8 -litigation of these contentions. 3 . r, n s 1 s fi.r. 9 f> MS. MC CLESKEY: I will n'ote for the. record as n 10 well that Ms. Jackson has not been identified as the t 'h 11 w i t n e s s. b y.7' FEMA in the proceeding. And I support 12 Mr. Pirfo's objection. 13 ' BY MR. MILLER: \\ 14' Qs Back to the matter at hand, Ms. Jackson, could 15' you tell me what Mr. McIntire said to you in connection 16 with the contentions? 17 .A You know, he asked for my input, as fah as an 18 answer to the contentions. I believe it's admit or deny; 19 is that how it goes? 20 MR. PIRIC: I restate my_ objection. 21 MS. MC CLESKEY: I object additionally because 22 it's clear from the answer that the witness doesn't 'f3 () ACE-FEDERAL REPORTERS, INC. ^ 202 347-3700 Nationwide Coverage 800-33&M46

lf' 28980.1 cox' 139 ,-~ . ()\\ 1 understand what you are referring to in the-ques tion, 2 BY MR. MILLER: j 3 Q She understands. Ms. Jackson, have you ever 6 4 _seen anything that looks like that? That's a bound 4, 4 } -\\ ' 5 volume, which I will represent for the record is a bound i' 6 volume of the contentions. 7 A No, I haven't seen this. 8 Q I think what you had in mind, Ms. Jackson, were s j 9 some requests for admissions that were made by FEMA, which 10 counsel will not go into. 11 A Okay. '12 MR. CUMMING: Couns-will state before the 13 witness appeared she was shown the contentions. Counsel 14 will also stipulate that it was the revised standard (s 15 version. 16 MR. MILLER: Those are not the contentions in 17 this proceeding, Mr.-Cumming. I hope you realize that. 18 MR. CUMMING: I don't know what contentions are 19 in this proceeding, Mr. Miller. 20 BY MR. MILLER: 21 Q Ms. Jackson, in light of a little confusion 22 here as to whether you have seen these contentions or

}!

D ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33M646 l _J

28980.1 cox 140 [^j) ( 1-not.-- 2 A Yes. 3 0 -- I will ask -- let me ask the question. Do 4 you feel that you are'in a position to comment at this 5-time on the contentions with respect to your opinion 6 regarding the allegations made under these contentions? 7 MR. CUMMING: Objection, calls for a legal 8 conclusion. 9 MR. PIRFO: Objection. 10 MS. MC CLESKEY: It also calls for 11 speculation. -() 12 MR.' MILLER: I am asking her if ehe is in a 13 position to make that. assumption in this proceeding, to 14 comment upon whether you would agree or disagree with the 15 allegations made in those contentions? 16 THE WITNESS: I am definitely not in that 17 position to do that. i 18 MR. MILLER: Thank you. I have no further 19 questions. 20 EXAMINATION 1 21 BY MR. ZAHNLEUTER: 22 Q 1 have several questions. My name is Richard U / i i l l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 80433M686 1

28980.1 cox 141 /~T \\_/ 1 Zahnleuter. I represent the State of New York, which is a 2 _ party. I believe that you told Mr. Miller a while ago 3 that you reviewed the summaries of your evaluations and 4 submitted them. Did you also say that you reviewed the 5 part of the post-exercise assessments, that is, the 6 . summary? 7 A -I think so. I reviewed in the post-exercise 8 assessment, you know, the draft, the ENC section and, I 9 believe I also reviewed the summary section. 10 Q Do you recall if you reviewed the entire 11 summary section? 12 MS. MC CLESKEY: Objection, asked and .( } 13 answered. 14 THE WITNESS: I don't recall. 15 BY MR. ZAHNLEUTER: 4 16 Q In what capacity did you review the summary 17 section of the post assessment? 18 MS. MC CLESKEY: Mr. Zahnleuter, there are 19 other parties that have spent a significant amount of time 20 taking the deposition here. It was asked and answered. 1 21 MR. ZAHNLEUTER: I recall what was asked, and r 22 this was not asked; please answer. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nanonwide Coverage 804336-6M6

-28980.1 142 cox ,7 3 js,/ 1 MS. MC CLESKEY: The witness is instructed to 2 answer the question. 3 THE WITNESS: I looked at it mainly in my role 4 .as the public affairs person for the region, to see what -5 were we saying, what was coming out of this report, 6 anticipating that when the report was issued, I would have 7 to explain to the press what we said in the report, and 8 also for style, to make sure that no one had made any 9 egregious grammatical mistakes. 10 BY MR. ZAHNLEUTER: 11 Q Who submitted the draft to you for your. review? ' ('i 12 A I think it was Roger Kowieski. V 13 Q Did you make any changes? 14 A I don't recall. 15 Q I direct your attention to Jackson Exhibit 3, 16 and ask you if you had anything to do with the prep 17 ratings or drafting of the points of review regarding the 18 ENC? 19 A No, definitely not, no, no, no. No. 20 Q Do you know who did? 21 A No. 22 Q On the day of the exercise, approximately when O ACE-FEDERAL REPORTERS, INC. 202-347-37(U Nationwide Coverage 800-3364M6

28980.1 cox 143 ,s k,) ' 1 did you arrive at the ENC? 2. A Referring to the report, it states that LERO 3 personnel began arriving at 6:41, and I believe that that 4 is, that has'to be my evaluation, so I was there before 5-6:41. 6 Q Were.you aware at 8:44 in the morning that an 7 'EBS message had been issued? 8 A. I don't recall. 9' Q Do you know when the first time it was that you 10 learned'that an EBS message had been issued? 11 A I don't recall. I'T 12 Q Do you recall what the EBS message said? (/ 13 A Referring to the report, table 1.2. I believe '14 the first EDS message was at 6:52. That was the 15 announcing the alert and calling for the early closing of 16 school. 17 Q Would that EBS message constitute a protective 11 8 action recommendation? 19 A Yes. In my opinion, yes. 20 Q Do you know if at 8:44, at the time of the 21 first press briefing, LILCO, excuse me, LERO knew that an 22 EBS message had been issued?

nU ACE-FEDERAL REPORTERS, INC.

202 347-3700 Nationwide Coverage 800-336-6M6

'28980.1' cox 144 fT 'v/ 1 A Yes. 2 Q How did you know that?' 3 A Because basically I was shadowing Elaine, and 4 she was on the phone to the EOC. She got the information 5 over the phone from the EOC. 6 Q So is it fair to say, then, that you were aware 7 before 8:44 in the morning that an EBS message had been 8 issued? 9 A Referring to the 6:52 EBS. message, or the 10-8:41? 11 Q Either one. 7 12 A Yes. (J 13 Q Is your answer directed toward a particular 14 one? 15 A No. 16 Q Were there any members of the media at the ENC 17-on the day of the exercise for 8:44? 18' A Yes. 19 Q Do you know by what means they were informed 20 that the ENC was a place to go for information? 21 A Yes. 22 Q 110w do you know? O ACE-FEDERAL REPORTERS, INC. 202 347-3700 NationwideCo erage 800-336-6646

28980 1 cox-145 f) A,j. 1 A' Somebody told me, and I don't recall who, that 2 LILCO/LERO had conducted, had advised the' press that that 3 was -- the Holiday Inn was going to be used as the 4 emergency news center. So the press knew that if they 5 were going to get information about the exercise, they 6 would have to go to the emergency news. center. 7. Q They were there before 8:44? 8 A At least one reporter was there before 8:44. 9 -Q You have in front of you the post exercise 10 . assessment. Could you please look at-the first page of 11 the summary section? -( ) 12 A Sure. 13 Q. Having seen that, do you now recall whether or 14 not you reviewed a draft of that? 15 A No, I don't recall. 16 MR. ZAHNLEUTER: I have no other questions. 17 EXAMINATION 18 BY MS. MC CLESKEY: 19 Q Ms. Jackson, I'm Kathy McCleskey. I represent 20 Long Island Lighting. I just have one question for you. 21 As to your area of expertise, do you agree with the 22 portions of the post-exercise assessments that you have n i \\~) ACE-FEDERAL REPORTERS, INC. 202 Nationwide Coserage 800 336-6M6 _.. _ _ _. _.,.._ _. __, _ -_.._- 347-3700. _.. _.. -., _

28980.1 cox 146 Ci V 1 read? 2 A Yes. 3 MR. CUMMING: May we go off the record a 4 second. 5 (Discussion off the record.) 6 MR. CUMMING: No questions. 7 MR. FIRFO: Excuse me -- I have no questions. 8 (Whereupon, at 5:50 p.m., the deposition was 9 concluded.) 10 11 _D/v_%d.: CJR_N O 12 MARIANNE C. JACKSON v 13 14 m 10 15 o g gw s e s n ,1 $4 pf 16 Sj h,* 17 18 l-l 19 l 20 l 21 i l 22 i O l l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 8633MM6

y CERTIFICATE OF MOTARY PUBLIC & REPORTER 147 _,e~ I,.- WEMDY S.-COX the officer before whom the' foregoing deposition was taken, do hereby certify

that, the witness.whose testimony appears in the foregoing:, deposition was duly sworn 'by -me; that the testimony of said witness was taken in shorthand and thereaf ter reduced to typewriting by me or under

.my direction; that said deposition is a true record of the testimony given by said witness; that I am N neither counsel

tor,

'related to, nor employed 'by any of the parties to the action in which this deposition was taken;

and, further, that I am not a relative or employee of any attorney or ' counsel O

Q employed _ by the parties hereto,. nor financially or otherw'.se interested in the outcome of this action. \\ Notary Public ih and for the District of Columbia My Commission Expires 11/14/87 n e . - - -.. - -. ~, ,y., y _,.-m-.___,, ...u

ba s~ FD /4_, N+ Federal Emergency Management Agency 1 Region 11 26 Federal Plaza New York, New York 10278 February 3, 1986 MDDPANDlbi EDR: All Federal Observers FPCM: lbger 'B. ieski Regional Assistance Carmittee Chairman SUR7ECT: Briefing -- Shoreham Exercise There will be a briefing on the Shoreham Exercise for all Pegion II Federal Observers from 9:45 a.m. to 12:00 noon, on Friday, February 7, 1986, in the ERCA. .~ig; \\ O O 731818 3 =

Q V\\ w 4 u\\ SOL _E b 1 SPEAKING POINTS FOR FRANK P. PETRONE l 02/12/86 PRESS BRIEFING O

Introductions

Phil, Roger, Marianne-FEMA & REP TMI 5 sites in Region II 17 exercises 2 remedial exer ~cises NY State Compensating Plan Numerous drills i Shoreham MOU with NRC Reviews (3) plan revisions June 'NRC asks FEMA to evaluate exercise ,( FEMA response - 3 options /, NRC decides - full-scale No finding Oral Critique T-: % - 1 p % y 9 %s GAee - i O i 732053 I

E Y / g\\c_scs-u ( 3 *' W a;ea;....- ;.. c. -

985 :DIA Gradec I, tere; a l

RUMOR CONTROL 00ESTI0rd NO. 3 ' lame: itu:ur Can r>; 3:w.10 %.: 09:15 Time: THIS IS A DRILL My friend in Coram just heard a siren go off. My family is in Roslyn. What should they do? war a u. h .DC / &J .J" eG: 'A I g. fu .a, Co rs-, alA k A yy O w 4,'. n _,f /v' ?~0 :. j. - n .~ s/;

s..

t J u~- s /I/ w p' - l THIS IS A ORILL O 2 oomua

N wv a re ~. n! .l IV ,8 _If 3h = c Es 1u y-j is: 91 _e 1' e v' 6 4 1 M 3 8 9] J 1 1 E. :is. A f ?. ~ g e. o s: 1 is li -] is 3 oc = g i I ) R,. i.I I, I., e -e g; 8e rh I. r. i: 5 g 6 8 - Bi Si s t ill '.. !.ll 11 M u g g g l

l! !!!

5 ma ili! i, = 8 egig 5 5 a g j I. i. i. i. Si = B i i i i i et G = i gj B m O t '5 9 E I 5 i i e a n E I I 1 b i 3 j 8 I t I r E i c -. 2 i

I V

3 I

E ~, 1 3 1 E n

1

= s t 3 y J = I U f 51$. r E s-l 1 5, 2: .d 5 8 ' k I i g 8 u 8 it

• 2 gi 8

j I *t %I E 8-8 2 E 1 $ 1

• I
• Y M

O W 3l E 5il! l :, 1 i 3 3

I f

=

v e

al- -e e a e e 28? e e e e e e U-l =v l a 8-2 l

h me O E we "4 59 e 8 9 1 4 3 I l 8! i: lkk. {E E3 .t W: l u P-io 4. .= .= 8,g 81 3 Eg .1 g g; ea B 32 -3 g g; IE = 8 t. !E E3 55 52 8t IV 34 3 m 5 5U l -i i ~I l [e (i gi B y

i. s. ' j, i l ll c"

E5 5rr d 8 ee M.g s e il 1 itl 9 g[ 11 Ea 11l I!

• 8 I

c 5 seie i 3 I 5 5 A I i i i y g g >a F-M g ? ? ? ? ? a: y g i. i. i. I. i. "j 4 M E! c = [ k22 w E ii! M 1

i*

i 1*3 3 V 2 3 5 a 1 C-y b 33 ) I a g6 g .s a 0 }5.I = 3 E 11

• M:

l !) = _n. m :g e s e-h 5_i-l 3 I8

_l ;s e

i. i z

U J. I h l1.:k = = c

I

-g II _ar-e.f k f3 G 6 o "I b* 6 A 8'W 2 l

~

J we 59 a

a 3 y o t 8 3 I l 1;; i: g it Es si ME i c t g e-ag gg g a Eg .a 3 82 9a sa -s is 84 t- !E 20 15 31 04 83 se E e i Et -i l 'l '1l l 1' ~i i 1 g"e s w 1,j lr l11 l,[li l l ijt = 58 = rr 55 Si $ llI ij! l[ Il !:' t I! $!!g! ma g a i t a =: I { e

== m i I i i .u 5-k$ 0 U 1 i s n y i r a y -g 3 I .a 1 E a ) i I I i a I 8 3 E I i i i 1 1 2 -I2 3 I 2 i s t -ii 1 5 1 :

n a -

i n 2: 2 d ! ! E 3 1 1 s P z e .c S u 3 i 2

• I 3

13 i 1 1E a J E N i 3 P P )- i c - i, ij[ i l i i ^ i

• e

= a a e

e w.

8. c. -I tiv A 8-2 l

2 N t 4 a re ~ 59 a t r, 8_ y .= 5 I l 8l g a i: I a*t

s o

t ME -j j $4 u 98 4 al en 3 8 Ej .a ~ 3 e 8: er b aW -z g ga is 8 t-5E 2: 15 3 Ig v Sc i i g t E.t !, (I' 3 e I i E"e 8 v I,! j ll = A8 i g rr ip1 l,i-I Es 25 s e 111 11 o i ti 1111 sa 8 11,.1 y c t i I I 5 5 A I i i i g. g E idl I i e a i l i a a j e = t ,i = i k! di E w y i i b h r -[1 a g 3 s ! i g ) i 2 5 5 8 1 I g. 1 i ) i 2 2 o i 2 8.g i i C CS b d 4

3 :*

.d 8 52 0 e d M I5 f f5 g:= c _f a" I E a y { _b : > W 1 j g1 s) EA!ii B,1 c. 3 My A 8-2

m, M J re "c Eg E 1 8g -y 8 = t I t:

s 5-l,at 2

r5 g 9_E a I 9s y .gu gl

s. :.

.1

I q

o o .2 er 3 8: aa -z is 84 to s t: si 3 It

v se g

e d Ib rl [c l' = z I E"e 8 v I., I = 58 a_ s a,r r f. i !. ol. i. I. l ~ = . li 5g 9: 5 g il I i p'

n 11 il a.1,.1 1

I 1.. ss v i =g 3 p,- i I ( q g g. I i i i >g F. g Y ? Y Y ? "e i i i i i Ng j g!4 a e e e e s E w 2 ** 2 a = m s" 2 W e 'l

• C.

I 3 3 J 3 6 l ff 5 i s j a I 2

C 2

~ h I l2 I, # g ) 3 1 I FJ l : } j' 3 2 E -4 E I t Ma c m 3 e <1 3 - = t a s. I "O E $1 l u h 5 2 la 1 B- =. c I= b U b$ I I $. t 5 23 a 2* l I E 3 ~E Es s $ i ci li 53 -et a; 22 h G g I E o Ce p 1 My 5 5 8" E l

N i 2< rcn 3 Iar e s.i. a 4 I s !g i 2 \\ mg

g 3-4a EE I

41 G5 i i i g al si 3

2 a1

.3; Ur = 12 32 g4 fE = t. 5:

== ig li !i se i i e I i Ie [,

1. <

-i !llljl!i! !! !h lg ! !II ~ gt a il l !'>li1 a 1,,1,1 Ea l I 8

E I

( =, g p I i i i = =I S t 3 i i i i at g x ,si e = 3 s 1 j l f _i 1 z ~ i e

i. i.

l g =. a 1 3, : ) h 1 -i3 3 1 8, 4 E = 5 1 E i i ii s = E =. =1 i$ E i I 1 i'{ l ~t I 2 I- - ! i e li s! 15 i !g.! zi i i, -) {.1 2 o 5 5 e 1-fi 8 t := s s t Ik I i 1 2 23 3,I

-l W

a 1 i .i rl is t = -53 ) G -3 n =>.i. ; e tE 2s ti e I. I

• v A

3-g

E n D re N4 6I k fV ? 8 4 I

8 8;

\\ (( E5 22 ME j 21 25 I gs' b ii 3 g s g. = n 3 3: Er i 32

3

= g4 rs t. 5: 2 55 it 8t 2* 30 i i e I ge l s! ~5 il [, v ) 11 8 r l:l-leinli,-l 55 = fr i 5. 8 e r ..I 5g Sg 5 g Il } i ll a Il 88 v n s s e! Ils b = E I n i i 3 I 5 5 E .u I i i I g$ g F ? Y ? ? w x e o t g c = c i i I I u t. g E$ E W N _k I I l E E i Ii 1 i I 3

i t

x n - I I k -) 5 i, 3 k i e i -I g i i f[E if i I E I I2 I 1 e 2 I % i I! 2 5 v 1 s s t g = 6 s h I.s5 .j.i ! ! I il ] = s s. U h 22R E O -1i: e

2, 53 elg 3

- 3 5 e w . 6 - 8 j .s .b, y' 0 a 5-E l l __}}