ML20206Q876
| ML20206Q876 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/01/1986 |
| From: | Gasper W ARGONNE NATIONAL LABORATORY - ARGONNE WEST |
| To: | |
| References | |
| CON-#287-3149 86-533-01-OL, 86-533-1-OL, OL, NUDOCS 8704220056 | |
| Download: ML20206Q876 (112) | |
Text
3i91 ORIG V ~
DOCKETED USNRC u
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OF PROCKEDINGS2i ag:09
' n ' ' * Y UNITED STATES OF AMERICA CFF GOCf'1Tb:;i ' !
O!
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- - - - - - - - - - - - - - - - - - - - - -x In the Matter of: :
LONG ISLAND LIGHTING COMPANY : Docket No. 50-322-OL-5
- (EP Exercise)
(Shoreham Nuclear Power Station, Unit 1) :
- ASLBP No. 86-533-01-OL
- - - - - - - - - - - - - - - - - - - - - -x O DEPOSITION OF WILLIAM R. GASPER i
Washington, D. C.
Monday, December 1, 1986 l
ACE-FEDERAL REPORTERS, INC.
Stenotype Rqvrters 444 North Capitol Street O w>ewiestee. o.c. 20ooi (202) 347-3700 Nationwide Coverage t
800-336-6646 8704220056 861201 PDR T
ADOCK 05000322 pop
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_C ,061 v
12/1/86 1 UNITED STATES OF AMERICA Jo Walsh NUCLEAR REGULATORY COMMISSION 2
ATOMIC SAFETY AND LICENSING BOARD -
3
X 4 In the Matter of : ,
5 LONG ISLAND LIGHTING COMPANY : Docket No. 50-322-OL-5 (EP Exercise)-
- [
6 (Shoreham' Nuclear Power Station, : -
Unit 1) : ASLBP No. 86-533-01-OL q ----------------------------------g b
8 9 DEPOSITION OF WILLIAM R. GASPER 10 Washington, D. C.
+
b 11 Monday, December 1, 1986 3
/'\ !
\- 12 Deposition of WILLIAM R. GASPER, called for examination l
. . 8 13 Pursuant to notice, at the Law Offices of Kirkpatrick & I i
14 Lockhart, 1900 M Street,.N.W., Washington, D.C. 20036, at 15 9:08 a.m., before GARRETT J. WALSH, JR., a Notary Public in 16 and for the Commonwealth of Virginia at Large, when were i
17 present on behalf of the respective parties:
18 MICHAEL-S. MILLER, ESQ.
SUSAN CASEY, ESQ.
19 Kirkpatrick & Lockhart 1900 M Street, N.W.
20 Washington, D.C. 20036 On behalf of the Intervenor, the County of Suffolk 21 22 O
J
, , . , - - . ~ - - ,-- -- -
'2 l a
-m Ij '. APPEARANCES: (Continuing) 1 .
2 JESSINE A. MONAGHAN, ESO.
Hunton & Williams 3 707 East Main Street l
P. O. Box 1535
,.. 4 Richmond, Virginia 23212 On behalf of the Applicant, Long Island Lighting Company '
5 WILLIAM R. CUM'iING, ESQ. _
6 Federal Emergency Management. Agency .
Washington, D. C.
7 On behalf of FEMA 8 ORESTE RUSS PIRFO, ESQ.
Office of General Counsel ,
g U. S. Nuclear Regulatory Commission Washington, D. C . ',
10 On behalf of the NRC 11 0 12 l 13 14 15 16 17 l
18 l
19 20 21 22 O
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2 Direct Cross 3
William R. Gasper ............ 4 f
4 By Mr. Cumming .......... 101. j By Ms. Monaghan.......... 102 [
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6 7
8 EEE1E11E i
g For Ident'ification !
Gasper Deposition Exhibit Number 1 33 ,i 10 4
J Gasper Deposition Exhibit Number 2 43 g 11 -
O V 2 Gasper Deposition Exhibit Number 3 59 13 ,
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15 16 17
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.2 . Whereupon, j h
3 WILLIAM R. GASPER 4 was called as a witness and, having first been duly sworn, 5 was examined and testified as follows:
il q
6 DIRECT EXAMINATION :!
q BY MS. CASEY:
8 Q My name is Susan Casey. I am an attorney with the r
1 g law firm of Kirkpatrick & Lockhart, and we are representing i
10 Suffolk County in this proceeding.
Generally, I am just going to be asking you about I 11
(^) 12 your involvement in the Shoreham exercise last February. If I i
13 you have any problems understanding a question or want me to j i
clarify.anything, please let ne know. i 14 15 Would you state your name and address for the 16 record, please?
17 A William Richard Gasper, 6200 South Madison, 18 Hinsdale, Illinois.
19 Q. Okay. Would you tell us what you did to prepare 20 for this deposition?
21 A I reviewed the post-exercise assessment, some 22 Personal notes that I had.
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1 Q When were these notes taken?
4 2- A On the day of the exercise. '
3 0 Did you review any other documents?
4 A I reviewed the exercise critique. forms, objective 5
critique forms.
~ s 6 Q The ones you had prepared?
7 A Right, those that I had prepared. '2 8 Q And, did you discuss your testimony with anybody?
9 A With counsel.
10 Q Did you bring any notes or your copies of the j; 11 exercise critique forms with you today?
12 A No, I did not.
i 13 Q Where are those notes now?
14 A They are turned over to counsel.
15 MS. CASEY: I guess once again, Mr. Cumming, we ,
16 will renew our request for these documents.
17 MR. CUMMING: I understand the request. I hope
! with respect to the exercise evaluation critique forms to 18 19 have a decision for you in the near future.
20 With respect to the notes, I haven't had an 21 opportunity to review them. As soon as I review them and i
22 determine whether release is appropriate, I will let you know, n
+ -
~ - - - . - - - , . . , - - - - , -, . -. . - - - - . - - - - - - , . . - -
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V 1 1 BY.MS. CASEY: (Continuing) t 2 O Mr. Gascor, could you tell me generally about l
if 1
3 your educational background?
9
<4 A I have a Bachelor's degree in geology.
5 Q When did you join Argonne_ Laboratory?
~
6 A I've been with them in various capacities since g 1980.
.].
8 Q And, where had you worked previous to that?
9 A I worked at Concrete Specialities Company. ;
i j 10 0 And, I understand that you are an Assistant t
11 Environmental Engineer at Argonne now?
O 12 A That's correct.
l 13 Q What other positions have you held at Argonne? j' 14 You mentioned that you had other jobs there.
15 A I was a consultant to the Lab, a contractor.
16 Q And, what are your job duties and responsibilities l
17 as an Assistant Environmental Engineer?
18 A Primarily now I am working on the FEMA project, 19 the RAC program.
20 Q And, what do you do?
21 A I attend exercises, evaluate exercises, review 22 emergency plans, write post-exercise assessments, those O
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i 1 kinds of things. ,
2 .O And, does this specifically relate to engineering? j A N 3 I don't believe so.
d 4 Q I understand you are also the Regional Coordina- d J
s' 5 tor for FEMA Region II at Argonne? 'j i"
6 A That's correct. -
h o
7 Q And, what does this position involve? '.
l-8 A It's basically coordinating requests from the 3 a e region for any assistance they need, whether it be providing '
.I
.1 10 evaluators for exercises, helping them produce documents, .
l 11 reviewing documents.
l (~T l -
12 I'n just their contact point in Argonne for i
13 coordinating.
14 Q And, with whom do you deal mostly in Region II?
15 A Well, right now they are in a period of transi hk' 16 tion out there.
Shor Mu r&Y I guess Chor Mus::.r would be the primary hr
- 17 contact.
18 Q How long have you been coordinator?
19 A Oh, two and a half years. Two years.
20 Q So, you were the coordinator during the exercise 21 last year?
22 A Right.
-l 8
. ,/3 V And, is'there anybody that you report to at
'l O' 2 Argonne?
&f,WIGM M
W 3 A Ken "crtrSA is the Program Manager there in 4 Argonne.
5 Q Did you have any -- well, I guess I should say, 6 what was your involvement in planning for the exercise last 7 February? ;
8 A I had a very limited role prior to the exercise.
g It mostly involved some clerical things at Argonne, compiling 10 exercise materials, getting packets ready for evaluators.
a Q And, you had no involvement in generating the 11 ]:
pd 12 objectives for this exercise?
13 A No. l 14 Q Did you review the scenarios?
15 A No, I did not.
16 Q Did you see or review the free-play messages?
17 A No.
18 Q Before you went to Long Island for the February 19 drill, were you involved in any other drills concerning the 20 Shoreham plant?
21 A Yes.
22 Q And, when was that?
9 n
()
1 MS. MONAGHAN: Objection. Relevance.
2 MR. .CUMMING: FEMA counsel objects on the 3 relevance, too. But, witness may answer to the best of his i i
. recollection.
5 THE WITNESS: There was the drill in January, I l 1
i 6 believe, of '86. !
l 7 BY MS. CASEY: (Continuing) ,
8 Q Would that have been the one held January 29th !
i e and January 30th?
i 10 MS. MONAGHAN: Objection. Relevance. ,
11 BY MS. CASEY: (Continuing)
(~%
12 Q You may answer. ,
13 A That's -- that sounds accurate.
14 Q Who told you that you were to attend this drill? (
15 MS. MONAGHAN: Objection. Relevancy.
16 MR. CUMMING: FEMA will: pose a continuing 17 objection to this line of questioning, but witness may answer 18 to the best of his recollection.
19 THE WITNESS: I don't recall who told me to go.
20 BY MS. CASEY: (Continuing) 21 Q Do you recall about when you were told about this 22 drill?
O D J
10 i
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5
( I 1 MS. MONAGHAN: A continuing objection on'the 2 grounds of relevance to this line of questioning.
i THE WITNESS: No, I don't.
3 [
4 BY MS. CASEY:' (Continuing) ;
I 5 O Did anybody tell you what the purpose of this [
v 6
drill was?
7 A Yes. The purpose was to go there and observe the f
8 facilities that we would later be asked to evaluate, or to i I
s' acquaint ourselves with locations and method of operation, 10 that sort of thing.
- ,I 11 Q Had you ever heard this drill referred to as a
(~d)
\ 12 " dry run?"
13 A- No.
-14 Q Could you tell me, to the best of your recollec-i i 15 tion, just exactly what you did on Long Island in connection 16 with this drill?
17 I understand there was a training session one 4
18 day; is that correct?
19 A I don't recall. I don't recall a training ses-20 sion.
21 Q Do you recall the actual drill?
22 A Yes. What I recall of that was, I went to the l
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Riverhead staging area during the exercise play, the drill 1
q 2 play. q' /
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3 0 And, utbou't what time was this commenced? Early ]
l 4 in the fjorning?/ l 5 A It was in the morning some time, mid-morning. ;
,6 O So, it didn't begin at,8 a.m.? .
7 A I don't recall.
., 8 O And, once you got to the staging area what did you t
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. A, Well, we went in and had a tour.of the staging ,
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's i i 11 area and then just sat back and watched the drill develop and i
-, . i d ' 12 ', watch,what happened, acquainted ourselves with the players and 13 the facilities. I 14 0 Who conducted the tour? [
' 15 MS. MONAGHAN: Objection as to relevance. J l.
16 THE MITNESS: I don't recall.
17 BY MS. CASEY: (Continuing) .
, -) 18 Q Was it one of the players?
- ,- i 19 A Yes. i 20 MS. MONAGHAN: Objection. Relevance. ,
21 BY MS. CASEY: (Continuing) i 22 Q You say you then observed what happened. What t
12
,q I activities were demonstrated to yqu?
2 MS. MONAGHAN: Objection. Relevance.
3 THE WITNESS: I doh't recall what happened at the
,4 drill.
5 BY MS. CASEY: (Continuing) s 0 Did you observe the staging area' activated? -
7 MS. MONAGHAN: Objection. Relevance.
8 THE WITNESS: Yes.
g BY MS. CASEY: (Continuing) ;
10 0 And you can't recall anything.else about what'you i
saw?
11 l 12 MS. MONAGHAN: Objection. Relevance.
1 13 THE WITNESS: I saw players arrive at.the staging 14 area. I saw players get briefed.and dispatched to their 15 assignments.
16 BY MS. CASEY: (Continuing) 17 O And did you see the dispatch of the bus drivers?
18 MS. MONAGHAN: Objection. Relevance.
19 MR. CUMMING: Objection again on this line of 20 questioning. Witness may answer to the extent he can 21 recollect.
22 THE WITNESS: Could you restate the question, O
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2 BY MS. CASEY: (Continuing) 3 0 'Do you recall observing the dispatch of bus !
a 4 drivers? q
- I 5 A I don't recall. .
6 Q Traffic guides? .j 7 MS. MONAGHAN: Objection. Relevance, i
8 THE WITNESS: I don't recall. ..
g MS. CASEY: You nay have a continuing objection, if i 10 you would like, f i
11 BY MS. CASEY: (Continuing)'
12 Q Do you have any recollection of approximately how 13 many people were there? s 14 MS. MONAGHAN: Objection. Relevance. !)
15 THE WITNESS: No, I don't. ,
16 BY MS.-CASEY: (Continuing) 17 Q Do you recall at what time the drill ended?
18 MS. MONAGHAN: Objection. Relevance.
l
'g i THE WITNESS: No.
20 BY MS. CASEY: (Continuing) 21 Q What did you do after that drill ended?
22 MS. MONAGHAN: Objection. Relevance.
O' I
14
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1 MR. CUMMING: Hitness may answer to the extent he 1
2 recollects.
3 THE WITNESS: "I believe we were Just instructed to {
u l 4 go.home. We were released after the drill ended. ,
5 BY MS. CASEY: (Continuing) a 6' Q Did you have any discussions with,anybody about 7 this drill?
8 MS. MONAGHAN: Objection. Relevance. I l
9 THE WITNESS: No, not that I recall.
10 BY'MS.JCASEY: (Continuing) 11 Q_ Well, is there anything else at all that you can O' 12 tell us about this drill?
13 MS. MONAGHAN: Objection. Relevance.
14 THE WITNESS: I can tell you that we weren't to i 15 take any personal notes, to make any written reviews or 16 assessments of the drill.
17 BY MS. CASEY: (Continuing) 18 Q Do you recall who gave you that instruction?
19 MS. MONAGHAN: Objection. Relevance.
20 MR. CUMMING: Witness may answer the question to 21 the extent he remembers.
22 THE WITNESS: I believe the FEMA team that was O
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15 x- t 1 there instructed all the evaluators that were there for the j 1
2 drill. l
.I l h 3 BY MS. CASEY: (Continuing) fj u
y l- 4 Q Would that have been Mr. Kowieski?- 4 N
5 MS. MONAGHAN: Objection. Relevance. j
{d 6 THE WITNESS: Probably. '
]
7 BY MS. CASEY: (Continuing) j 8 Q Who else from Argonne Lab was present? Was Dr. 1 h
9 Baldwin there?
1 10 MS. MONAGHAN: Objection. Relevance.
i 33 THE WITNESS: I believe so.
O k/ 12 BY MS.-CASEY: (Continuing) .
13 Q Was there anybody else from Argonne ther'e besides j 14 Dr. Baldwin and yourself?
o 15 A I think --
16 MS. MONAGHAN: Objection. Relevance.
17 THE WITNESS: I think Ed Tanzman was there, 18 Possibly Ken Lerner, Al Smith more than likely was there.
19 I think that's all I can recall.
20 BY MS. CASEY: (Continuing) 21 Q And, was anyone present from the NRC?
22 MS. MONAGHAN: Objection. Relevance.
O
16
. ,ry
(_/ .
1 THE WITNESS: I don't recall.;
2 BY MS. CASEY: (Continuing) ~ >
3 Q Do you recall a Mr. Weiss? k e4- MS. MONAGIIAN: Objection. Relevance.
5 THE WITNESS: No, I don't.
7 il 6 BY MS. CASEY: (Continuing) 7 Q At the time that you attended that drill, did you 8 already know that you were going to be an evaluator at the 9 February exercise? .
10 MS. MONAGHAN: Objection. Relevance. ;
i 11 THE WITNESS: Yes. f
.b /) 12 BY MS. CASEY: (Continuing) 13 Q And, when did you first find out that you were 14 going to be an evaluator at the Shoreham exercise? :
15 A I don't know.
16 Q Do you know who told you?
17 A No, I don't. It was probably Ken never nd,_
18 Q What areas were you told that you were goingto 19 evaluate at the Shoreham exercise?
20 A Initially -- you are talking the exercise now, not 21 the drill?
22 Q Let me just pick up on that. Did you evaluate O
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jl 2 MS. MONAGHAN: Objection.. Relevance, j i
l 3 .THE WITNESS: No, I didn't evaluate anything at the j d
4 drill, f 1
5 BY MS. CASEY: (Continuing) ):
?
6 0 Okay.
7 A Initially, I was to be at the Riverhead staging _
8 area,.and-then-I got transferred over to school evacuations. jj
.j g Q Were you given any objectives to evaluate at the i
1 gn Riverhead staging area?
11 A Yes, I was. No, I'm sorry, no, not at the River-0 12 head staging area. No.
13 Q So, you did evaluation there?
l 14 A Right. Correct. What happened was, I traded ,.
15 places. Phyliss Decherman and myself switched roles that day.
16 She went to Riverhead, and I went to the school evacuation.
17 Q And, why was the switch made?
i 18 A I don't recall. I think it may have had some-19 thing to do with cur roles after the exercise as far as 20 writing the report, the post-exercise assessment.
21 Q What was the connection? Were you assigned dif-22 ferent sections of the report?
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(._ 1 1 A Yes. .
I 2 O So, she was assigned to write the Riverhead- q 3 section;'is that correct?
e4 A I don't know that for sure. I don't recall the .
5 exact circumstances on why we were switched. But,-something 6
along those lines.
7 Q And so then did you write the school evacuation 8 section?
s MR. CUMMING: Objection to this line of questioning
, i 10 on a continuing basis.
11 Witness may answer to the extent he has recol-t r's'
(/ 12 lection.
13 THE WITNESS: Would you restate that?
14 BY MS. CASEY: (Continuing) 15 Q So, were you assigned to write the sections of the 16 report dealing with school evacuations?
17 A Yes.
18 0 What did you do to prepare for your assignment as 19 an evaluator of school evacuations?
20 A I read through the evaluator packets that were l
l 21 distributed to the evaluators. I familiarized myself with l
22 the LILCO plan and the applicable OPIPs. I read the l
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^i 1 objectives, reviewed the scenario, acquainted myself with the -[
2 surroundings and the location. j J
3 Q- Had you evaluated school evacuation before at Y 4 other exercises? a
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.5 A Yes, I believe so. q i,
6 MS. CASEY: Let the record reflect that I am 7
handing the witness a copy of a document which has previously 8 been marked as Lane Exhibit 2.
4 g BY MS. CASEY: '(Continuing) 10 Q Mr. Gasper, have you seen this document before? g 4
11 (The witness is looking at the document.)
O k- 12 A I believe so. It looks like one that was given to 13 us as part of the exercise evaluator packets. 1 Did you attend the meeting on February the lith ;!
14 Q 15 that was held between 8:30 and noon?
16 A Yes, I think so.
17 Q Can you tell me what happened at this meeting?
18 A I'm sorry. I can't recollect what happened at that l
l 19 meeting.
20 Q Do you recall Mr. Kowieski speaking?
l l 21 A No, I don't.
I 22 Q Do you recall Ms. Jackson speaking?
O l
- 1 20 s
j 1 A Not at this particular meeting. I do recall both-2 of'them talking prior to'the exercise, at the pre-exercise I
3 briefing. So, I -- but I couldn't tell you if it was during 4 this meeting or not.
5 Q Okay. The document indicates that the-simulators 6 were present at this meeting. Do.you have any recollection 7 about simulators being there?
8 A No, I don't. !
9 Q And, even if you look at this document which lists 10 an agenda for the meeting that doesn't refresh your recol-i 11 lection in any way?
O' 12 A Well, I remember being briefed on the'se items, you 13 know, these items coming up. But, I don't remember it l
~
14 specifically happening at this meeting.
15 I don't recall the meeting.
16 0 When you say you remember being briefed on those 17 items, by whom were you being briefed?
l 18 MS. MONAGHAN: Objection. Relevance.
l
- l. 19 THE WITNESS: Most likely, Roger Kowieski.
I 20 BY MS. CASEY: (Continuing) l 21 0 If you will look at the next page, that notes that l
22 there was a meeting between 1:15 and 3 p.m. Do you recollect
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21
.s~^j 1 anything about that meeting?. .
2 A I recall the speech given by Joe Keller.in
?
3 reference to the dosimetry. I recall thefdisenssions by Tom ~ ,
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>4- Baldwin and Roger Kowieski which dealt with observer assign- E 5 ments and logistics. !
r 6 Q And, how about the detailed' discussion-of your own 7 assignment?
8 A By Baldwin and Kowieski, is that -- you are refer- E 9 ring to Item 2 there? ,
10 Q Right. }
11 A Yes, I recall them discussing my role that day.
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\l 12 Q And, what did they say?
13 MS. MONAGHAN: Objection. Relevance.
14 TH5'NITN5$S: They asked me if I had any questions 15 concerning my assignment, if I knew where I had to be at what 16 times and what to look for.
17 BY MS. CASEY: (Continuing) la Q And, did you have any questions?
19 A No, I did not.
20 0 The following morning, it has listed that you were 21 to drive to your field assignment. Did you do that? .
22 A Yes, I did. I don't know if it was on that morning, CE) i n
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1 though that I did that. But, I did drive. i i
2 Q So, where did you drive? !,
i 3 A To the Shoreham Nading River School, High- School. j i
4 Q Did you talk to anybody there?. ,
~
5 A No, not when I went out to find the location. !
1
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6 Q Did you go anywhere else from the high school or the I
q campus? j l
8 A No. The high school and the school' district offices I g are co-located in one location. So, I familiarized myself with 10 their layout there. ..
11 Q So, you did go,inside the building?
12 A No, I didn't. I just found the two different l
l 13 buildings.
14 Q And, then you just returned to the hotel? I 15 A I believe so. [
16 Q Did you see anything else of Long Island while vou 17 were out there?
18 MS. MONAGHAN: Objection. Relevance, and to the 19 form of the question.
20 THE WITNESS: Just the countryside between the 21 hotel and the school district.
22 O
23 5
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1- BY.MS. CASEY: (Continuing) '
2 Q And, what did you do after you returned to the 3 hotel?
4 A I don't recall. ,
5 Q Did you study your assignment?
6 MS. MONAGHAN: Objection. Relevance.
9 THE WITNESS: I don't know.if I looked over my 8 assignment after I returned or not. More than likely, I did.
g BY MS. CASEY: (Continuing) 10 Q If you will look at Page 3 of Lane Exhibit 2, it ,
L has a schedule there from 1 p.m. to 4 p.m. that the evaluator's j 11 n 12 would study their assignments. Is that --
13 A On Page 3? ,
14 0 Yes. It's towards the center of Page 3.
15 (The witness is looking at the document.)
16 A I don't --
17 MS. MONAGRAN: I believe your reference is to 18 Page 4 of that.
19 THE WITNESS: Okay.
20 MS. CASEY: I stand corrected, Page 4.
21 THE WITNESS: Could yon restate your question?
22 O
i 24 ,
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1 BY MS. CASEY: (Continuing) 2 Q .Does that refresh your~ recollection at all as to a what you-did that afternoon? [
.4- .A No. i-5 Q So, you do not remember focusing on any particular ,
6 document or any particular part of the plan in preparation for 7 your assignment? ;
8 A Not specifically during this time period. f i
9 Q Do you recall the general meeting that was held 10 that afternoon, the last meeting before the exercise? !
l i
11 A I recall that there was a meeting. '
(3 k/ '
12 O Do you recall who spoke at this meeting?
13 A No, I don't.
14 Q Do you recall any problems which were raised at 15 that meeting.
16 MS. MONAGHAN: Objection. Relevance.
17 THE WITNESS: No, I don't.
18 BY MS. CASEY: (Continuing) 19 Q So, you really can't tell me anything about those 20 two days; is that correct?
21 A I can't tell you --
22 MS. MONAGHAN: Objection. Relevance. I believe
25 j
('~'/ !
1 also that mischaracterizes the witness' prior testimony.
2 THE WITNESS: I don't think I can tell you anymore 3 than I have. ,
4 MS. CASEY: Okay.
5 BY MS. CASEY: (Continuing) 6' Q Moving along to the next day, the day the exercise 7 was actually held, can you tell me what you- did that morning? :.
Of the day of the exercise? I 8 A t
t 9 Q Right.
's 10 A I drove to the Wading River -- the Shoreham Wading
- 1 11 River School District.
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b' About what time?
12 Q 13 A I arrived there around 8 o' clock. 4 14 Q And, you went directly from the hotel to the ,
15 Shoreham Wading River campus?
16 A Yes.
17 O And, once you got there what did you do?
18 A I went into the School District Administrative 19 Building offices, the Office of the Superintendent of the 20 School Districts, and I believe the principal of the high 21 school is co-located there.
22 Q And, who was the Superintendent, do you recall?
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26 i
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\_/ 1 1 A I don't recall his name.
2 Q Was he introduced to you?
3 A .Yes, he was, d d
4 l0 Do you recall the name of the principal?
f 5 A I don't.
6 Q So, once you went into.the offices what-did you do?
k 1 A I had some conversations with them on what they had d 8 done so far in the day in relation to the exercise.
s 0 Well, let's take the Superintendent. What did he 10 tell you he had done?
t 11 A He said that when he arrived at work -- prior to O
k' his-arrival there had been a call that had notifled them, the 12 13 school, of the alert classification at the plant. (
14 0 And, what did he do in response to that call?
15 A Due to the time of day and what stage the students 16 would be in -- in other words, they hadn't arrived at the 17 school yet, they were still at home or in transit, he issued 18 an early dismissal of schools.
19 Q And, how did he do that?
20 A That I don't know.
21 Q So, all he told you was: I issued an early 22 dismissal of schools?
O
a l
1 27- l
-t i
/^%s
.%' i 3
1 MS. MONAGHAN: Objection. It mischaracterizes the 4
2 witness' prior testimony. .!
il 3 TiiE WITNESS: Yes. He said that he'had issued $
1
. ,4- an early dismissal of schools. f i
U 5 BY MS. CASEY: (Continu?ng) 6 0 And, did he give you any details as to how he had )
i!
7 accomplished that task?
8 A Yes, he did. Ile said that he had notified the g LERO EOC that he was dismissing schools early. He said that to he had contacted the contracted bus company'that provides ;
11 bus service's to the school. And, he had simulated the release O 12 of any st- mts that would have been at the campus.
13 0 What' time does school usually begin'on that l i
14 campus?
15 A I do 't recall.
16 0 Did he tell you at what time he had arranged for 17 this early dismissal?
18 A !!e had received the alert notification, as I recall, 19 around 7:40. And it was as soon as he got to school and was 20 able to act on it. So, around 7:40.
21 0 And, how about your initial conversation with the 22 principal? What did he tell you?
i
,v.
28 I s
/N
! I' A
1 My initial conversation with him, I don't recall z,,
il 2 what he said. j n
N 3 Q Do you know how many schools there are in the d F
I 4 Shoreham Wading River School District?
5 A No, I don't. {
l 6 Q Do you know if the schools that are at this one- .
7 campus, are those the schools for the entire district?
8 A I don't recall. There is only the high school, as s
g I recall, is located at this campus. 1 i
I 10 0 So, do they refer to it as a campus because of the
- t 11 office buildings that are there also?
12 A Right. I don't know if that'snhow they refer to 13 it. That's how I'm talking about it now. 4
\:
14 Q Okay. After the principal and the Superintendent '
15 had discussed early dismissal with you what happened then?
16 A They went on about their normal school day 17 activities.
18 O And, what did you do?
19 A I sat and waited for something else to happen.
20 0 And, what was the next thing that happened?
21 MR. CUMMING: Objection as to form.
22 TIIE WITNESS: Should I answer the question?
O O
29
. i .}
- 7
.t j' 1 MR. CUMMING: Witness may answer- the question.
2 I don't know.what the counsel is referring to. Maybe you can y
3 rephrase it? ,
4 BY MS. CASEY: (Continuing)' .
5 -(L Well, Mr. Gasper, you said that you then sat and d
6 waited for the next thing to happen. .
7 A Yes.
8 Q And, I merely wanted to know what was the next event g to which you responded or took any action or noted or 10 observed?
4 11 A I don't recall what happened next. I stayed there
(
'~
12 past lunch time, past noon. The Superintendent called the 13 LERO EOC and said that they had dismissed all school children -
14 and had sent them home. This was completed by 8:15. .
,5 Q And, then you sat there until noon and you can't 16 recall anything else that happened?
17 A There was very little that happened there beyond 18 the school business, the school day business. Once the i
19 school -- my understanding is that once the school early 20 dismisses and they are " evacuated" then they are taken out of
'l oo 21 the informationgfr m the LERO EOC.
22 So, they would not expect to receive any subsequent l
30 .. '
I d i
calls there or any other notifications at all. So, there was 2 very little that happened after everybody simulated going l is 3 home.
c4- 0 So, what was the rest of your assignment? jl 5 A From there, I went to the -- after noon time, I went to the Seaman Bus Company who is the contra'ctor providing
-6 7 school buses for the school district, one of the contractors.
8 0 And, what precipitated your novement there?
g A Well, things had -- like I said, t'hings had wound 10 down at the school proper, and I went over there to interview .
b 11 the dispatcher of the school buses.
/~}
~'
12 0 And, what did the dispatcher tell you? l l
13 A lie told me that that morning before 8 o' clock they i.
i 14 had received a call from the School District Superintendent 15 requesting 17 buses, two of which actually were dispatched and 16 employed to the school and ran their evacuation routes, the 17 school children pick-up routes.
18 0 Did he tell you anything else?
19 A Ile told me that they had all the required manpower 20 and resources to provide requested assistance to the school, 21 that those items are available.
22 0 liow many students are there in that school?
O e
31 -
t/
1 A I don't know. ,
2 Q Did the bus dispatcher tell you how many. buses they 3 'had available?
4 MS. MONAGHAN: Objection. Relevance. The issue l 5 of how many buses were available was litigated in the context 6 of the emergency plan litigation and is'not an issue here.
7 MR. CUMMING: FEMA counsel has annobjection to l a relevance on a continuing basis on that question also. But, I 9 witness may answer to the best of his recollection.
10 THE WITNESS: Could you restate that question? .
11 BY MS. CASEY: (Continuing) a Q'
k 12 Q Did he tell you how many buses were available? l 13 A He said that there were 17 buses that'had been J 14 requested and were available at that tine. ;
i 15 Q But, you did not know how many students there were 16 in the school; is that correct?
g7 MS. MONAGIIAN: Objection. Relevance.
18 THE WITNESS: I don't recall now how many students 19 there were, that there are.
20 BY MS. CASEY: (Continuing) 21 Q Did you know that morning how many students there 22 were in the school?
(
r 32 .
?
k/ g A Yes.
2 Q And, you were satisfied that 17 buses was sufficient 3 to evacuate this number of students; is that correct?
4 MS. MONAGHAN: Objection. Relevance. ,
5 MR. CUMMING: Objection as to evaluation process.
6 Witness may answer as to the best,of his re' collection.
7 THE WITNESS: I don't believe that that morning I l
8 knew that-that was the required number of buses to have.
9 BY MS. CASEY: (Continuing) 10 Q Did you talk to any bus drivers while you were at i la 11 the Seaman Bus company? l n v 12 A No, I didn't.
13 0 Did yoa check that the 17 buses whose dispatch was 14 simulated actually were available in the bus yard?
15 A Just through interviews with the dispatcher. There 16 were buses there, and there were a lot of buses out on.other 17 school routes at the time I came in.
18 0 But, you did not go out into the yard and count?
1g A No, I did not. I don't know that they are all 20 located down at that garage necessarily.
21 MS. CASEY: I would like to have this document 22 marked as Gasper Exhibit 1. It's a one-page document entitled, O
33 ,
, ]
i A
Y_ "Shoreham Exercise ---Evaluator Aqsignment/ Location Instruc-1 l
2 tions."
3 (The document referred to was marked f i
i' e4 as Gasper Deposition Exhibit Number ind:xx 5 1 for identification.)
1 6
BY MS. CASEY: (Continuing) ,
7 O Mr. Gasper, have you seen this document before? !
I g (The witness is looking at the document.) !
I g A I believe s , yes. It looks famil'iar. I Q And, when did vou first see this document?
10 A I don't recall. Some time prior to the exercise.
11
()'-
12 I believe it came out as part of the exercise packet, evalua-13 tor packet. t i
14 Q Am I correct that this document summarizes your !
15 assignment on the' day of the exercise? ,
16 A I believe so.
17 0 When you got to the Shoreham Wading River School, is you said that you spoke with the Superintendent and he said 19 that he had contacted the EOC.
20 A Uh-huh.
21 Q Did you evaluate the extent of his contact with 22 the EOC?
O z,.
m.
i 34 1
I
,- s.,
,)
1 A Ile had done that prior to my arrival.
2 Q And,'what was the time that he estimated for 3 evacuating the school?
]
i 4 A IIe had later informed the school that they were to i 5 be -- the EOC that the schools had been evacuated by 8:15. l l
6 0 .So, that would be approximately a half an hour to i
7 evacuate the school; is that correct?
A That sounds correct. i 8
cndTA g Q And, did the principal say that that was the time 10 for evacuating the school or for accomplishing early dismis-i i
11 sal? 8 12 A Ile said that the evacuation was complete at 8:15. s i
13 Q Well, I guess I'm a little confused. As"I under- E t
i 14 stood you, he told you that there had been an early dismisal 15 or early closing or a non-opening of the school.
16 A Right.
17 0 And that he took this action after he received the 18 alert at approximately 7:40.
19 A Uh-huh.
20 Q When did the evacuation of the school commence?
21 A Following the -- his receipt of the alert 22 notification. The way I understand it, at that time of the O
35
/ 'T 1 morning, there would be some children at.the school. 'There 2 would be children in the process of arriving at the school 3 at that time. There would be children in transit.
4 So, what he had done was to get buses there to take ,
5 the children that were there back home or wherever and then 6 return, reverse the flow of the children aw'ay from the school y back home, s O So, the 17 bus evacuation would be to remove g children who had arrived at the school early rather than to 10 evacuate the entire school; is that correct?
i 11 A I don't know.
12 O If you will look at Exhibit 1, Point 2 states that 13 you would board the bus and go to the reception center.
I 14 A That's correct.
15 0 Did you do that?
A No, I did not.
16 17 O Why not?
gg A Because when I got at the school, the buses -- the gg two buses that actually ran the routes had already dispatched, had left.
20 21 0 So, you never actually saw these buses?
22 A The buses were there when I arrived. I didn't
[I
~
36 a
.b 1- realize that they were.the buses to demonstrate the evacua-2 tion routes. Then, I went into. the. office there and by the 3 time I had talked with the Superintendent the buses had v
4- already left. i 5 Q And, did you go to the reception-center?
6 A No, I did not.
7 Q So, I assume you also did not go'to the emergency 8 worker decontamination facility?
9 A Correct. ,
10 Q So, after the buses left you stayed at the school 11 until noon and then you went to the bus dispatch company -- *
[~'-) .
12 A Yes.
13 0 -- and interviewed the dispatcher; is that correct? p 14 A Yes. )
15 Q And, what did you do after that?
16 A I went back to the motel. That was the end of my 17 assignment.
18 Before-I went back, I called the FEfiA -- I can't 19 remember the term they used. It was one of the FEMA employees 20 that you were to report in to if you had any problems in the 21 field or you needed any further instructions or to inform them 22 if you were moving out of your assignment or whatever. I O
v
37
'I
( i
(_)\ . :I 1 called her and told her that I was -- what'I had done, the j 2 two locations I had been to. And then I was prepared to go J
3 back to the motel. 9
!L 4 Q And, at approximately what time of the day was i 5 this? ij 1
9 6 A Two o' clock, a little after 2 maybe. - !
7 0 In your interview with the principal and the
]
I 8 Superintendent, did they explain their plans or procedures
}i 9 for the early dismissal?
10 A I don't recall.
- t 11 0 Did they explain their plans or procedures for O 12 evacuation?
13 A They explained that they had a couple of different 14 p?ans available for the way they would implement evacuation, h v
15 0 And, what were these plans?
A I don't know all the details of them but what I ,
16 e
17 recall was one plan would be a staggered evacuation of 1s children. The other would be a mass evacuation.
19 0 IIow would they select which option they were 20 going to use?
21 A I don't know.
22 0 Can you recall any of the details of either of O
i
1 i
![
38' '
g
, i IN. :
G' :
1 those plans?
.{
2 A No, just that they_had the option to use either one j y
3 of those plans, that they had the resources to implement
!j<
4 either one. But, as far as details about it, I don't even h 5 know that we got into that discussion. j k
a O And, they gave you no indication of what criteria j d
q would initiate which plan --
]
p 8 MS. MONAGHAN: Objection. Asked and answered. [
g THE WITNESS: I don't recall if they did. $
10 BY MS. CASEY: (Continuing) 11 0 Mr. Gasper, I'm handing you wilat has previously 12 been marked as Lane Exhibit Number 3. This is a' list taken 13 out of the FEMA report of all the exercise objectives. 5 s
14 Could you tell me which objectives you were [
15 responsible for evaluating?
16 (The witness is looking at the dockunent.)
17 MR. CUMMING: Is this an extra copy this witness 18 is marking up? !
Ig MS. CASEY: Oh, yes.
20 !!R. CUMMING: Feel free to mark it up.
21 THE WITNESS: Okay. I believe on Page- 13, 22 field activity number 1; Page 14, numbyr 7, number 8, number O
r 6
a
- t 39 b
/ 'A i
(_/
) '( '
1 15 and 16. And, as far as I recall, those are the objectives.
2 BY MS. CASEY: (Continuing) 2 0 How did you evaluate field activity'for objective l z+ number 17 l r A Through discussions with the bus dispatcher at the 6 Seaman Bus Company. . i 7 Q So, he was the bmergency worker that you observed, l s is that correct?
A He was the one I talked to about it. And, he ',
9
- i 10 indicated that the bus company did not have any dosimetry
. 1 o
11 equipment available to them.
V 12 0 And you did not interview any of the bus drivers?
13 A Correct. I 14 0 What else did you ask him in reference to dosimetry? l 15 A I asked him if they had equipment available, if 16 they had be
- trained in its use.
17 Q They hadn't been trained? ,
18 A No, they hadn't. So, that was pretty much the end ;
19 of that discussion.
20 Q Did he have any understanding of the protective 21 action guidelines?
22 MR. PIRFO: Objection. It's not competent for i
T*
40 $
d 1 this witness to say what another person knew. !
2 MR. CUMMING: FEMA counsel has the same objection 3 as to the understanding of the other pers.on. l]'
4 Ile can answer to the extent he demonstrated the -- ;;
-i 5 MS. CASEY: I will rephrasa the question. Y I
6 MR. CUMMING: Okay.
7 BY MS. CASEY: (Continuing) h a Q Did you ask him if he had any knowledge of the ij p
g protective action guidelines?
I 10 A I believe I did.
t 11 Q And, what did he respond?
12 A They had received no training in exposure control.
I 13 0 When-you say "they" is that referring to the 14 dispatcher or to.the bus drivers? lf A Both. Employees of the bus company.
15 0 And, in regard to objective 7, can you ask me what 16 37 he did -- can you tell me what you did to evaluate that i
18 bjective?
19 A Interviewed the bus dicpatcher.
20 Q Would you tell me about that interview?
21 A I asked him if supplies of KI were available at the 22 bus garage, if they knew how to take it, use it, distribute O
41 i
(,,/
1 it, et cetera.
2 O Once again, "they" is referring to the --
3 A .The bus employees; the bus company employees. ,
4 Q And, what was his response? ;
5 A He-indicated they did not have KI there, and they ;
r 6 had not been instructed on its use.
7 Q Did he know what KI was?
8 MR. PIRFO: Objection.
. s 9 BY MS. CASEY: (Continuing)
,. 10 Q Did you ask him if he knew what KI was? :
11 A I don't recall. I asked him if they had KI, and he' -
)
(%./ 12 indicated no.
13 Q Okay.- Did the bus dispatcher have any knowledge as t
i
~
14 to who can authorize exposure in excess of the general public 15 protective action guidelines?
16 MR. PIRFO: Objection. You are asking the witness 17 what people had knowledge of, what other people had knowledge 18 of.
19 MS. CASEY: Actually, I believe you have already 20 answered that question.
21 MR. CUMMING: -Is the question withdrawn?
I 22 MS. CASEY: Yes, it is.
l l
-- 4 y g-- - - , , ----gy ,,,,,y ---r-- --- --e--- e v- y-- + - - ,
42 '-
i f%
1 BY MS. CASEY: (Continuing) ,
2 Q Mr. Gasper, would you tell me what you did in a connection with evaluating objective field 15?' f
,q . MR. CUMMING: Objection as to the witness' 5 evaluation process based on deliberative privilege. However, .
t 6 witness to the extent he can answer based on his. recollection 7 may answer it.
8 THE WITNESS: As I've already told you,'I interview- !
g ed the Superintendent of Schools. He indicated that he had 10 issued an early. dismissal of schools, and he had activated .
11 some of the resources to implement that decision. 8 12 BY MS. CASEY: (Continuing) 13 Q What' resources did he ' implement? <
14 A The buses. >
15 0 And, what did you do for objective 16?
16 MR. CUMMING: Objection as to form.
17 THE WITNESS: .Should I answer?
18 MR. CUMMING: Witness may answer if he understands 19 the question.
20 THE WITNESS: I think you had better rephrase the 21 question.
22 O
w
43 '
1 BY MS. CASEY: (Continuing) 2 Q What actions did you take in connection with
}
3 fulfilling your resp'onsibilities to evaluate objective 167 i
4 A I conducted interviews with the. Superintendent of j 5 the School District. l e Q Were these the same interviews that you referred to 7 in your description of what you did in evaluating objective t
8 15?
9 A Correct. .
10 Q And, did you do anything else?
11 A No.
O' 12 MS. CASEY: I think I would like to take a break. ,
13 (Whereupon, a recess is taken at 10:05 a'.m., to 14 reconvene at 10:25.a.m., this same day.) :
15 MS. CASEY: I would like to have this marked as 16 Gasper Exhibit 2, a two-page document, entitled " Exercise 17 Evaluation Critique Form."
18 (The document referred to was marked 19 as Gasp?.r Deposition Exhibit Number indexx 20 2 for identification.)
21 BY MS. CASEY: (Continuing) 22 Q Mr. Gasper, have you seen this document before?
(-
l r
44-t U- 1 A Yes.
2 O Did you fill out documents similar to these on the 3
day of the exercise? [
4 A Yes. (
5 Q' Looking at the first page of this, it should be ,
F 6 objective field 15, I believe you.have already told m'e what 1 7 you observed in connection with this objective; is that cor-8 rect? :
l g A Yes. 1 10 Q Do you recall anything else at this point?
t 11 A No,.I don't.
12 Q What did you write about this objective on your 13 critique form on the day of the exercise, or the day after ,
14 the exercise? ;
MS. MONAGHAN: Objection. The question is com-15 16 Pound.
17 BY MS. CASEY: (Continuing) 18 O Mhat did you write on your copy of this form?
19 MR. CUMMING: Objection as to this line of ques-20 tioning. It goes directly to the deliberative process. To 21 the extent the witness can recall his form, he may answer 22 the question.
O I
l L
-i 45 7,
U 1 BY MS. CASEY: (Continuing) 2 Q Did you discuss what you wrote on your form with 3 somebody else? j i
_. 4
-MR. PIRFO: Objection. We've got two questions now.
5 MR. CUMMING: I would say we have three questions.
~
6 MS. CASEY: Well, I guess we will go back to the 1
first question.
7 ]
8 BY MS. CASEY: (Continuing) 4, g Q Mr. Gasper, do you recall what you wrote on this [
+
10 form? p 11 A Not specifically. Y s !
12 Q Do you recall generally what you wrote on this 13 form?
14 A What I wrote on this form is represented inothe 3 15 post-exercise assessment and basically what we have discussed 16 earlier in regards to the form, in regards to the objective.
17 Q So, you have no independent recollection as to 18 whether the objective was met or not?
19 A That is reflected in the post-exercise assessment 20 as being met, this objective.
21 Q Do you have any independent recollection of that?
i 22 A Yes. I remember that I had indicated that the i
._ ,'Oa
,y - - . - . . , - - - . - , - . - - - - -
,.--.,.7m - ,,., y . ---,
3 46
() objective had been met. .
1 ,
2 Q And, what did you write concerning the objective?
e 3 MR. CUMMING: Objection. This line of questioning -}
4 goes to-the deliberative process. Witness may answer to the f 5 extent he has a recollection. !
6 THE WITNESS: I don't recall specifically what I 7 wrote on this objective form. But, it's as we discussed .h
, [
8 previously and as what is reflected in the post-exercise ll
?
L g report.
i ;
10 BY MS. CASEY: (Continuing) 11 0 When did the early dismissal at the Shoreham Wading u l
12 River School occur?
13 A Following the receipt of the alert notification, at 14 _7:40.- f:
-15 0 So, it occurred at 7:40?
16 A I.can't answer that specifically or exactly. Some- R 17 where around that time, somewhere after 7:40, within the next 18 few minutes. {
19 Q Did it occur before the Superintendent arrived on 20 the campus? ,
21 A No. That's his decision that he made-when he got 22 there.
O ;
47 ,
5
'N .
'% I
~
i 1 Q So, no decision as' to early dismissal can be made 2 until the Superintendent arrives; is that correct?
3 A ,I don' t know that. ;
4 O Did you ask the Superintendent if anyone is p 5 authorized to make the decision in his absence? ,
b 6 A I don't recall. :
7 Q If you had asked him that question, would it be ,
8 reflected ~in your notes on the critique forms?
9 A It could be.,
I 10 MS. CASEY: Once again,-Mr. Cumming, we renew our 0
11 request for these forms. 'l
(~)
. MR. CUMMING: Counsel for FEMA understands the 12 13 request. <
14 BY MS. CASEY: (Continuing) 15 0 When was your assignment switched with Ms.
16 Becherman?
17 MR. MONAGHAN: Objection. Relevance.
18 THE WITNESS: I don't recall the exact time. I 19 think I arrived at the pre-exercise knowing that I was going 5 20 to have this assignment as opposed to the other assignment.
21 BY MS. CASEY: (Continuing) 22 O Had you been given the school evaluator assignment i
48 i 1
'I
(~') I
%/
1 prior to receiving your evaluator. packet?
~
2 MS. MONAGHAN: Obj ection,. Relevance. j
.l 3 THE WITNESS: I don't recall. i
'I.
74 Inf MS . CASEY: (Continuing)
{4 a
5 Q Do you recall whether your evaluator packet referred }
6 to school evaluation oc to the Riverhead staging area evalua-
'.t it i
7 tion? }
- i 8 MS. MONAGHAN: Objection. Relevance, y
g THE WITNESS: I'm not sure. 'i i I 10 BY MS. CASE?: (Continuing) i
~
Y
. 33 Q So, do-you recall whether you ever reviewed those 12 Parts of the LERO plan which deal with school evacuation? !
I 13 A Oh, I definitely reviewed those parts.
{
14 Q When?
15 A In the~ days before the exercise. I'm not sure when 16 I came to the exercise if I knew before I arrived there, 17 arrived in Long Island to participate in pre-e :ercise, but I 18 knew that my assignment had been changed.
19 But I did, prior to the exercise, review all of the 20 applicable documents concerning the school objectives.
21 Q And, how did you get those documents?
22 A They were distributed. Like I said, I don't recall-n de e,
- l
?
y; x
49 j j
, ~\
L-] }
3 if I got them in the' mail beforehand or_they were just switched ,
1 2 Phyllis Becherman and I just actually switched documents while i f
3 we were there in Long Island. I don't recall.
4 But, there was ample time for both.of us to review 5 and go 2hrough the various OPIPs and plans and so on. j 6 Q What can you tell me about OPIP 3.6.57 i r
7 A I don't recall. j 8 0 Is that an OPIP which deals with school evacuation? f i l'
9 A I don't recall. l s
10 Q Did you observe any of the school evacuation h
11 activities at the EOC?
(~~'t ~ 12 A No, I did not.
13 Q Looking at Lane Exhibit 3, who evaluated'~the EOC j i
objective 187 f 14 15 (The witness is looking at the document.)
a 16 A That would be on Page 10? I'm not sure. Whoever l 17 the evaluator was at the LERO EOC assigned to those objectives, but I don't know.
K 18 MaIiw 19 Q Was it Ms. EalenT57 1
20 MS. MONAGHAN: Objection. Asked and answered.
21 THE WITNESS: I don't know.
22
50 l l
/ )
%.J i 1 BY MS. CASEY: (Continuing) 2 Q Did you at any time see any of the documents which J
3 were generated at the EOC concerning school evacuation? I 4 MS. MONAGHAN: Objection. Relevance. q 5 MS. CASEY: Ms. Monaghan, Mr. Gasper is represented q 6 to have evaluated school evacuation. I think anything he can )
7 tell us about what he saw at the exercise and what occurred I 8 at1the exercise is directly relevant to this case, j 9 THE WITNESS:-
Should I answer? ?
10 MR. CUMMING: Counsel requests that you answer the Y
11 question to the best of your recollection. l
+
("%
'- 12 THE WITNESS: Could you ask the question again, a
13 Please? I 14 BY MS. CASEY: (Continuing) 15 Q Have you at any time seen any of the documents t
16 generated at the EOC in connection with school evacuation?
17 MR. CUMMING: Objection to the post-exercise 18 documents. witness may'have seen in reviewing or developing the 19 Post-exercise assessment report.
20 However, witness, to the extent he has recollection, l
21 may answer.
l 22 MS. CASEY: I was unaware that the EOC was
1 i
l 51
,wm
(
i g generating post-exercise documenta, Mr. Cumming.
2 MR. CUMMING: No. The witness reviewed post-3 exercise. Your question said any time, essentially said at >
4, any time had he seen documents. ,
5 Do you mean during the exercise? l
- 6 MS. CASEY
- I'm asking.about doc'uments generated at q the EOC during the exercise concerning school evacuation. And, 8 I want to know if Mr. Gasper has seen any of these documents i I
g at any time.
10 MR. CUMMING: Okay. Objection, and I will restate .
. I it, 11 f 12 Witness may answer the question to the best of his recollection. i 13 ;
i 14 THE WITNESS: I don't recall seeing any documents f
15 generated-from the LERO EOC. l 16 BY MS. CASEY: (Continuing) 17 0 Have you ever seen any documents similar to this 18 before?
19 A I believe I saw a blank document that looked like 20 this that was contained in the OPIP.
21 Q But, you have never seen a filled out version of 22 this document?
i m
m-
52 i i
\~ I don't think so, no.
t A !
i 2 MR. CUMMING: Counsal for FEMA suggests.that we i
3 either mark this for the- record or counsel identify the docu- )
' i 4
ment if you are not going to mark it so that we understand what .;
?
5 the witness referred to. ;
i e
6 MS. CASEY: Let the record reflect tha.t I have shown (
7 the witness a-four-page document. The first pa'ge of this 8 document is entitled " Private and Public Schools Activities f g Status Report."
!O MR. CUMMING: For the record, the format handwrit- ;
}
- it ting which has not been identified by witness. 6
' ('-)N 12 MR. PIRFO: I'm sorry, Ms. Casey. You are not 13 offering this as Gasper Exhibit, whatever it is,_ 3?-
i 14 MS. CASEY: No, I'm not. l 15 MR. PIRFO: Okay. The only problem I have with 16 this is that you have referred to a four-page document, and I r 17 see that the Bates numbers though are not sequential, and this ,
i 18 is really four different documents; is that correct?
19 MS. CASEY: That's correct.
20 MR. PIRFO: Okay.
21 MS. CASEY: The four pages are Bates stamped 722156, 22 723730, 722681, and 72314.
O
--y -------..y-. -y-, ,w- g w.,-- ,, , -9 --
9 - - -,, -r %a 5'
53 ,
I !
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1 MR.-PIRFO: Which consists of two private and public 2 school activities status reports and two LERO message forms.
~
i 3 BY MS. CASEY:
(Continuing)
'l 4 ~Q And, is it correct, Mr. Gasper, that you have never ;
5 seen any of these documents before in their filled-out version? j To my recollection, I haven't seen those 5111ed out,
^
6 A l 7 no. ,
8 O Now, you said earlier that the Superintendent told l
g you that-the Shoreham Wading River School has plans for either )
10 a staggered evacuation or an evacuation en masse; is that 11 correct? j 12 A That's correct.
I 13 Q Is the staggered evacuation to be used h those l 14 instances where there are insufficient buses to evacuate all !
15 the children? :
16 MR. MONAGHAN: Objection as to the relevance. The '
17 appropriateness or type of evacuation plan to be used for r
la schools was litigated during the emergency planning hearings 19 in the Summer of 1984 and is not at issue here.
20 MS. CASEY: Ms. Monaghan, Mr. Gasper told me that 21 he interviewed the Superintendent as to the schools plans and 22 Procedures for evacuation. He described two evacuation plans.
b--
~
54 U ~
1 I'm merely trying to find out what these.two plans _ consisted 2 of and under what circumstances each would be used.
3 MR. CUMMING: Witness may answer to the extent he i I
e4- has understanding. 3 5 THE WITNESS: Could you rephrase the question or ;
6 repeat the question', please?
7 BY MS. CASEY: (Continuing) :
8 Q The question was, was the staggered evacuation" plan !
g to be used in those instances when there were insufficient 10 buses to evacuate all f the school children at one time? ;
i 11 A I don't know when they would implement that plan. i r~x l
(^) 12 O And, you did not discuss this with the Superin- !
I 13 tendenty is that correct? f f
14 A No.
Q Going back to the exercise evaluation critique form, 15 field 15, how did you determine that there had been a prompt 16 37 mobilization of buses and drivers?
A In the. interviews with both the Superintendent of 18 19 Schools and the bus dispatcher.
In addition, I told you that when I had arrived at 20 the school at 8 o' clock there were buses there, two buses 21 22 there, for this evacuation.
1
- 1 s- ,
55 :
V But, were you present when the phone call was made 1 O 2 to the bus company?
3 A No, I was not. :1 4 Q Do you know exactly what time the phone call was j.
1 5 made?'
6 A No, I don't. I know that it was after the receipt-7 of the alert notification call.
8 0 Which you believe occurred at 7:40? j, g A Yes.
so 0 Looking at the critique form for field objective !
k 11 16, what did you write concerning this objective? l k-) 12 MR. CUMMING: Objection as to the deliberative 13 Process, based on the deliberative process privileg'e. i i-14 To the extent that the witness has some memory, he l 15 may answer.
16 BY MS. CASEY: (Continuing) 17 Q Mr. Gasper, before you filled out this form, did 18 you discuss what you were going to write with somebody?
19 A No, I did not.
20 Q Now, do you recall what you wrote in connection with 21 that objective?
22 A Not specifically. What I did write is reflected in O
ii s
56 1
.g
,. i
(~) l 1 the post-exercise assessment. f s
1 2 Q And, you have no independent recollection as to j d
3 whether the objective was met? u 4 A The objective, I indicated, I believe, was met.
5 Q Did you read the Shoreham Wading River IIigh School [
6 Emergency Plan Procedures?
7 A- I don't recall. I don' t recall. -
8 Q Are there any written Shoreham Wading River High g School Emergency Plan Procedures?
i A I believe so.
10
- t 11 Q What can you tell me about these plan procedures?
/m. .
J A I can tell you only that they are available at the 12 13 school. I'm not sure that we were given them as a pre-exercis'e i
i 14 document.
15 Q So, at the time that you were evaluating the Shoreha n 16 Wading River's response to the emergency, you did not have 17 their emergency plan procedures available to you, at that 18 time; is that correct?
19 A Like I said, they were available at the school.
20 Q But, did you look at those?
21 A I believe I did.
22 Q Can you tell me anything about those plan
d 57 h
.~
l T j i
\_/ -
1 procedures? .
2 A I don't recall any speci.fics about that.
h 3 Q Did you compare what you observed at the school 0
. with what was written in the plan procedures?. L 5 MR. CUMMING: Objection as-to form. Are you ;
6 referring to the school plans versus the LERO - -
7 MS. CASEY: I'm referring to the plan referenced !i 8 on the objective critique form which Mr. Gasper has told me -q t
g was the written plan of the Shoreham Wading River High School 10 Emergency Plan Procedures. .
i 11 MS. MONAGHAN: I'm going to object to the question 12 as vague. It's unclear whether you are referring to the off-13 site emergency plans for the Shoreham Nuclear Power Station 4 14 or for the Shoreham Wading River High School Emergency Plan 15 16 MS. CASEY: I'm referring to the Shoreham Wading 17 River High School Emergency Plan Procedures which is referenced 18 in the exercise evaluation critique form, which Mr. Gasper has 19 told me was a written plan available at the school.
20 MR. CUMMING: And, you are asking if he compared 21 that plan to what?
MS. CASEY: What he observed at the Shoreham Wading 22
- h
58 r
V 1 River High School.
2 MR. CUMMING: The witness may answer that question.
3 THE WITNE'SS: I believe that I. compared parts of the ;
4 plan with what I observed.. ;-
5 BY MS. CASEY: (Continuing)
{
6 0 Which parts?
7 A I don't recall. (
t' s O Can you get back into it by thinking about what you (
s 9 observed that day?
i 10 A I don't remember any of the specific details about 11 this plan. I know that it was there; I know that I looked at ,
m 12 it. But, I don't know the detailed procedures or how I used 13 them that day. ;
14 Q To your recollection, did what you observed conform 15 to what was written in that plan? .
16 A To my recollection, it did.
17 Q In y6ur position as the evaluator of school 18 evacuation, did you do anything in connection with the 19 dispatch of a bus to the Ridge Elementary School?
20 A No, I did not.
21 Q Have you ever seen the exercise free-play message 22 dealing with the dispatch of this bus?
- - - - - - - . - . . . , . - r- - - - - - , - - , - . , - . - - - - - ,. . , -
59 4
V 1 A I don't believe so.
2 MS. CASEY: I would like to have marked-as Exhibit 3 a two-page. document; the first page of this document is a ;
3 4 filled-out LERO message form; and, the second.page of this j l
5 document is entitled "Shoreham Exercise School Evacuation !
6 Message, LERO EOC, Part 1."
- _ 7 (The document referred to was marked j i
8 as Gasper Deposition Exhibit Number l i
indexx 9 3 for identification.)
10 BY MS. CASEY: (Continuing) 11 Q Have you ever seen either of these documents
\/ 12 before, Mr. Gasper?
13 A I have not. ,
1 14 O Do you know who evaluated the response to this !
15 message? f 16 A No, I don't.
17 Q Does the name Michael Woo ring a bell?
18 A I know the name. I can't associate it with this --
ig MR. PIRFO: Can we go off the record just a 20 moment?
21 (Off the record.)
22
i 60 -
(~')
V- BY MS. CASEY: (Continuing) 1 ,
2 Q You said before you believed you had seen these.
3 Have you seen them?
- 4 'A I have not seen them. ;
5 Q And, did you ever speak to Mr. Woo about'his-6 exercise assignment?
7 A I don't believe so.
8 MR. CUMMING: Is this being introduced.in evidence +
9 Of ~~
10 MS. CASEY: Yes. It's Exhibit 3.
11 MR. CUMMING: Okay. Actually, two documents are f 12 being introduced as Exhibit 3, for the record.
13 BY MS. CASEY: (Continuing) 14 Q Do you recall seeing Mr. Woo at the exercise? :
15 A I don't know Mr. Woo personally. I know his name 16 was -- I know his name as one of the evaluators. I don't 17 know if he was there at the exercise or not.
18 Q And, you said that you drafted part of the FEMA 19 report; is that correct?
20 A Are you referring to the post-exercise --
21 Q Yes. I'm sorry. We call that the FEMA report.
22 A Yes, I drafted parts of that.
O n't
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vb 1- Q Which parts? ;
'2 MR. CUMMING: Objection as to this line of 4
i 3 questioning concerning the deliberative process. j 4 However, witness to the extent-he has some knowledge j t
5 may answer. ,!
i 6 THE WITNESS: The only.part that I recall drafting, j s
7 at this point is the section that dealt with the school 8 evacuation. 5 t
9 BY MS. CASEY: (Continuing) 1 10 Q So, in connection with drafting this report did :
b 11 you ever look at any of the other documents relating to b
_(~
12 school evacuation aside from those which you yourself had t
13 filled out at the exercise?
I l
14 MR. CUMMING: A continuing objection to this line 15 of questioning.
4 t
16 However, witness may answer this question. ;
17 THE WITNESS: I believe I did. That's usually 18 what happens in this evaluation process, the writing process, 19 to evaluate other forms.
I 20 BY MS. CASEY: (Continuing) 21 Q Now, I believe-there is a section in the FEMA 22 report about the request by the Longwood School District for
(
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62 [
() 1 a bus. ,
I 2 MS. CUMMING: Objection as to the form of question, [
3 if that was a question.
4 MS. CASEY: Well, I would like- for.Mr. Gasper to :
5 5 take a minute and look at his copy of the post-exercise .i 6 assessment report. .
f g MR. CUMMING: Any particular pages or sections, or 8 the report in its entirety? ,
g MS. CASEY: Just give me a moment. ;
10 (Pause.) ,
t I
11 BY MS. CASEY: (Continuing) l
(~)'
\- 12 Q If you will look on Page 38, the second to the last i
[
P 13 paragraph, is this part of the report that you-drafted, Mr. l
(
- r 14 Gasper? -
15 A No, it's not, t
16 Q Who did?
17 A I don't know.
18 Q Do you know if it was one of the other people who 19 had responsibility for evaluating school evacuation?
20 MR. CUMMING: Counsel objects to this line of '
21 questioning on a continuing basis.
22 Witness may answer to the extent he has knowledge.
O
\_/ +
63 -
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G' THE WITNESS:
1 I don' t know that either.
2 BY MS. CASEY: (Continuing)
- i
~
.3 Q Would you go through the report and' find out which j i
e4 sections you did draft? ;
5 MR. CUMMING: Objection as to form. l
?
6 MS. CASEY: I'm asking.the witness to. indicate to 7 me which sections of this report he drafted. He has been put l l
8 forth as the evaluator of the school evaluation exercise. I g And, so far all I've been able to' determine is that I i.
10 he went to one school and sat there for four hours and talked ;
11 to the bus dispatcher. He also told me that he drafted parts O 12 of the report and -- f 13 MR. CUMMING: Is counsel testifying?
MS. CASEY: I'm explaining what I want to know. I 14 MR.' CUMMING: Would counsel restate the question?
15 16 MS. CASEY: I would like the witness to tell me 17 which parts of this report he drafted.
18 MR. CUMMING: Witness may answer.
19 THE WITNESS: As I said earlier, the only part 20 that I can recall at this time that I actually draf ted was on 21 Page 43, the school evacuation section, the second paragraph 22 from the bottom.
_( ,
r if 64 l 1
.c N_ . . I 1 BY MS. CASEY: (Continuing) i 2 Q And that is all you had responsibility for draft- j l
3 ing? (
?
4 A No, that's not '-- that's all I recall drafting, .h h
5 and then on Page 44, last paragraph. Then, on Page 45, there 4 s.
. it 6 were areas requiring corrective actions that are associated ,3, x
r 7 with the description on Page 44. }
Q 8 Q How about on Page 38, the first complete paragraph ',-
E 9 on that page? '
1 I
10 A I did not draft that paragraph.
- i 11 Q Do you know who did?
.O) b# 12 A- No, I don't.
13 Q Could it have been Albert Smith? <
14 A It could have been. I i
i Q So, am I correct then that in draf ting the, what 15 ,'
16 was it, two paragraphs that you drafted in this report, you 17 had no occasion to look at any other documents concerning 18 school evacuation?
19 MS. MONAGHAN: Objection. It mischaracterizes the 20 witness' prior testimony.
21 BY MS. CASEY: (Continuing) l 22 Q Other than the documents you yourself had I
i 1
65 i 1
%s 1 generated during the' exercise?
- (
2 A I don't recall if I looked at specific documents. )
!i i
3 But, as I stated, generally other documents are reviewed in- j 4 the post-exercise evaluation process.
j 5
5 0 'By whom?
-:y 6 A By the writers. ,
7- Q But, in writing your sections you reviewed no _.
8 other documents other than the ones you yourself had written? ]
9 MR. CUMMING- Objection. Asked and answered. ;
i 10 MS. CASEY: This witness has a tendency to recall p' l
11 more if he is asked again.
O' 12 MR. CUMMING: Witness can supplement if he has a 13 desire to do so, his previous answer. [
14 THE WITNESS: I doh't recall reviewing any other 15 documents.
16 BY MS. CASEY: (Continuing) 17 Q Do you know how many school districts there are in 18 the 10-mile EPZ surrounding the Shoreham plant?
I 19 A No, I don't.
20 MS. MONAGHAN: Objection. Relevance.
21 BY MS. CASEY: (Continuing) 22 Q Did you ever know how many school districts there O
f e -
- . - - . . _ . _ , - - . . , - - . . . . . . - . . .,m_.._. , , ~ _ . . . - - . - . . .-. ..--., __, _ - - - _
h q
'p 66 >
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2 MS. MONAGHAN: Objection. Relevance. ;
il -
3 MS. CASEY: Ms. Monaghan, this'.is the evaluator for -,
y-
. ,4 school evacuat. ion at the exercise. It seems to me that a if i
5 knowledge of the~ number of school districts to be evacuated g 6 is directly relevant. 2 i
7 MS. MONAGIIAN: The objection sta'nds. , !
i i+
8 MR. CUMMING: FEMA counsel joins in the' objection 1 2
4 ,
9 on a continuing basis.
10 Witness may answer the question. i H
i THE WITNESS: - I was probably aware of how many '
11
/~N V 12 school districts there were, there are. '
e ,
13 BY MS. CASEY: IContinuing) <
et 14 Q You say you were probably aware? 7 15 A Right. , r 16 Q Can you be more specific than tha't? .
17 MR.'PIRFO: Objection.
18 THE WITNESS: I don'.t recall at this time how e 19 many schools -- how many school districts there are , involved 20 there. But at the time and day of the exercise, I was 21 Probably aware of that information.
22 s O
b ' ' y
%< ; t
y 1
.ll 67
<~~
'k_)
1 BY MS. CASEY: (Continuing) 2 Q Were you given this information by somebody?
3 MS. MONAGHAN: Objection. Rel.evance. i]
d 4 MR. PIRFO: Objection,-because it's obvious that d 5 he was given the information by somebody at some point. It j u
6 didn't spring from his mind.
]a q MS._CASEY: The witness has said he probably had 8 this information.
g MR. CUMMING: Witness may answer if he has 10 knowledge of how he acquired the information, l
11 THE WITNESS: I believe it's in the plans or the rs 12 OPIPs, the number of school districts.
13 BY MS. CASEY: (Continuing) 4 14 Q So, this would have been in the evaluator packet q 15 for the evaluator of school evacuation; is that correct?
16 A Correct. 1 17 Q Which you say you reviewed?
18 A Yes.
19 Q You say that on the day of the exercise you spoke 1
20 to the Superintendent and someone whom you believe was the 21 principal of the Shoreham Wading River School. Did you speak 22 to any other school officials that day?
O
68 i MS. MONAGRAN: Objection. The question mis-2 characterizes the witness' prior testimony.
i 3 MS. CASEY: I think the record will reflect that 4 that is what the witness testified to previously.
t 5 MR. CUMMING: Witness may answer the question if he 1
6 as knowledge. I 7 THE WITNESS: My recollection was I only spoke with !
l 8 those two officials. l 9 BY MS. CASEY: (Continuing) 10 Q Did you speak to any teachers that day?
l I
11 MS. MONAGHAN: Asked and answered. i r- {
k_T/ 12 THE WITNESS: I don't believe I did.
l 13 BY MS. CASEY: (Continuing) 14 Q You say you don't believe you did.
}
15 A I don't recall speaking to any teachers-that day.
16 Q Is it possible that you spoke with some teachers 17 that day?
18 MR. PIRFO: Objection. Relevance.
19 THE WITNESS: It's possible. There were many people 20 coming in and out of the administrative offices there at the 21 school.
22 I don't recall having any specific interviews with O
69
-3
,us$
1 any teachers there concerning the drill, the' exercise.
2 BY MS.-CASEY: (Continuing) 3 0 This is teachers at Shoreham Wading River?
I e4- A ~ Correct. ;
I 5 Q Did you go to any other schools that' day? !
6 A I did not.
7 Q You said earlier that you believed you had evaluated )
8 school evacuations in connection with other emergency exercises !
g fer. Gasper.
10 Can you recall more specifically whether you did? ,
11 MR. PIRFO:. Objection. ,
12 MR. CUMMING: Objection as to form, whether he did what? iJ 13 t
14 MR. PIRFO: Vague.
15 MS. CASEY: Evaluate a school evacuation in con-16 nection with other emergency exercises.
17 fir. CUMMING: Witness may answer.
18 THE'if6 FESS: Yes, I have.
19 BY fiS. CASEY: (Continuing) 20 0 At which exercises?
21 fir. CUlifiING : Objection as to relevance on a 22 continuing basis to this line of questioning. Witness may O,
s_
c .
9 70 [
t
\_)
1 answer to the extent-he has knowledge.
2 MS. CASEY: Mr. Cumming, I believe this..goes to ,
3 the~ witness' expertise to evaluate school evacuation. f 4 ;MR. CUMMING: It may go to the witness' expertise, i
.t 5 but my understanding is you are deposing this witness as a fi 6 fact witness. . I.
7 Witness, to the extent he has knowledge, may in fact j 8 answer to'the extent he has facts, f
t 9 MS. CASEY: I am deposing Mr. Gasper as the 10 evaluator of school evacuation at the Shoreham exercise. .f 11 MS. MONAGHAN: Is there a question pending?
m 12 MS. CASEY: Yes, there is.
13 THE WITNESS: You want to know what- otheIr. exercise ,
i 14 I have evaluated school evacuations; is that correct? s 15 BY MS. CASEY: (Continuing)- ,
16 0 Right.
17 A I don't recall which ones.
18 Q You were at the Indian Point exercise, weren't 19 you?
20 A I've been at several of them.
21 O Did you evaluate school evacuation at any of those f
l 22 exercises?
1 71
,s-1 A Not to my~ recollection.
2 Q Would you look at Page 45 of your copy of the 3 post-exercise assessment report? Did you write the second ,
4 paragraph on that page? ;
~
- cndT2A 5 (The witness is looking at the document.) .
~
+
6 A I believe I did.
7 0 What was the basis for the statement that school
{
8 bus drivers were not all trained regarding who can authorize g doses in excess of and what to do in the event of exposure i
10 beyond the general public PAG?
11 MR. CUMMING: Enter an objection to this line of &
<n '
\> 12 questioning.
la The witness may answer to the extent he has I
t 14 knowledge. '
i 15 THE WITNESS: That information was gained through 16 interviews with the bus dispatcher at the Seaman. Bus Company.
17 BY MS. CASEY: (Continuing) 18 0 I believe you testified that he told you that none l
19 of the school bus drivers had been trained in this?
20 A That's correct.
21 MR. PIRFO: I move to strike that answer. I'm not
- 22 sure that was his previous testimony. It was mischaracterized, O
o
?
I 72 I
\/ I 1- and I move to strike the answer. ,
2 MS. MONAGHAN: We should note for the record that' ti 3 the paragraph that is being discussed includes'both ambulette l 9
e4- drivers and school bus drivers in connection with whether all j i
5 were trained. F E
6 MR. PIRFO: The record, of course, will speak for r 7 itself. !!
O f
8 MS. CASEY: I think the transcript will straighten 9 that out.
10 BY MS. CASEY: (Continuing) l t
11 Q Well, you didn't have anything to do with evaluat-O\
(# 12 ing ambulette drivers; is that correct?
13 A On the day of the exercise, no, I did not. <
t 14 0 Were any school bus drivers trained regarding i 15 doses in excess -- regarding who could authorize doses in 16 excess of the general PAG?
17 MR. PIRFO: Objection.
18 MR. CUMMING: Witness may answer to the extent he ;
19 has knowledge.
20 THE WITNESS: From the information that I got from 21 the dispatcher at the school bus garage, they had not been 22 trained. They were not aware of PAGs.
c- ;
+
73 i
/"T, 1
BY MS. CASEY: (Continuing) j i
2 0 .Now, you said that you did not speak to.any of the ;
i 3 individual bus drivers; is that correct?
l i
4 A That's correct. l l.
s 0 -Do you know how many actually went to the Shoreham j 1
6 Wading River School? -l i
7 A In response to this evacuation demonstration? !
8 0 Right.
g A .Through interviews with the dispatcher and with !
10 the school administrator, two-buses, one driver on each bus.
11 0 If you will look at Page 43 of the FEMA report, the f
\/ last paragraph in Section 2.1.2 states that drivers were given 12 13 detailed maps of the routes to follow and instructions to ;
i 14 report back to the hus depot upon completion of their routes. !
1 15 What is the basis for this observation? j 16 A I saw copies of the detailed maps that were given 1 17 to the drivers that depicted their routes.
18 0 When did you see this? l i
19 A The day of the exercise.
20 0 Was this part of your interview with the bus 21 dispatcher?
22 A Either the interview with the bus dispatcher or the O
.i 74 O
1 school administrator. I don't recall which. But,'one of 2 those -- at one of those locations, they had the maps that 4
3 would be given to the school bus drivers.
1 4 Q Well, does the Shoreham Wading-River Plan call for b 5 the bus dispatchers to distribute maps, or for the school to 6 distribute maps? -
7 A I don't recall. ,
8 Q But you did not actually see any bus drivers being !
9 handed these maps?
10 A I did not.
11 Q Did anybody accompany you on the day of the' o)
\-
12 exercise?
13 MS. MONAGHAN: Objection. Relevance.
14 THE WITNESS: Nobody accompanied me through the 15 whole day, but there was a controller at the school.
16 BY MS. CASEY: (Cor.tinuing) 17 O And, did somebody ride in your car with you to the 18 Shoreham Wading River School?
19 A No.
20 Q While you sat at the Shoreham Wading River School 21 and conducted your interview, was there another person with 22 you?
O
p--
75 .
i n
'Q 1 A The controller was present in the administrative
[
t 2 offices there. I believe I held some interviews with the }
3 administrator, just he and I. But, this controller was there 6
<4 for some of the interviews. I 1
5 Q. Aside from the controller, was there anybody else?
6 A No. There was some. clerical help that may have- -
7 been involved in some of the interviews, but there was nobody :
a j
8 there with me.
9 Q Do you know who the controller was?' j i ;
10 A No, I don't know her name. p Y
i 11 Q Were you introduced to her at any point?
(3 s~) 12 A Yes.
Q Was she a FEMA employee?
13 f
14 A No.
15 Q Was she an Argonne employee?
16 A No, she wasn't.
17 Q Nas she with the NRC?
18 A I don't think so.
19 Q Was she a LILCO employee?
20 A I don't recall.
21 Q Does the name Wiggins mean anything to you?
22 A That sounds familiar.
O
- .,.s .
~--
n I
.j
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i 76
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k.] i
.1 0 Does it. sound like it might be her name? .t
't i
2 A Jo Wiggins, that rings a bell. I don't know for j .-.
3 sure if that was her or not. h 3
4 Q But it is possible?
5 A It.is possible, yes. 3 6
6 O As the evaluator for the evacuation of schools, ,
q were you aware that the Shoreham Wading River School District
'f 8 was the only school district participating in this' exercise?
S g MS. MONAGHAN: Objection. Relevance.
i i 10 MR. PIRFO: Objection. Relevance. Not calculated ,,
il 11 to lead to discovery of admissible evidence.
O 12 MS. CASEY: You may answer.
13 MR. CUMMING: Go ahead. You may answer 'the 4 li 14 question.
- 15 THE WITNESS: Could you restate that, please?
i 16 BY MS. CASEY: (Continuing) 17 Q As the evaluator for school evacuations in this i
is exercise, or in any other capacity, were you aware that the 19 Shoreham Wading River School District was the only school 20 district participating in the Shoreham exercise?
21 MR. PIRFO: Objection. Relevance.
22 MS. MONAGIIAN: Same objection.
I c
77
- .-~ 1 s
~
1 MR. CUMMING: Objection. Relevance. Witness may 1
2 answer the question. j H
3 .THE WITNESS: No, I don't think I was aware of that. j 4 BY MS. CASEY: (Continuing) i p
5 Q Did you think that other evaluators would be
- i. '
6 evaluating the response of other schools? .
7 MS. MONAGHAN: Objection. Relevance. t 8 MR. PIRFO: Objection. It's not calculated to lead g to discovery of admissible evidence.
10 MR. CUMMING: FEMA counsel's objection is continuing
- t 11 to this line of questioning.
i '- To the extent the witness has knowledge, he nay 12 13 answer. .
14 THE WITNESS: I don't know if others -- I didn't !
15 know if others were evaluating other school activities.
16 BY MS. CASEY: (Continuing) 17 Q Did you ever see any correspondence between LILCO 18 and the school districts aside from the Shoreham Wading River 19 School District?
20 !!S. MONAGHAN: Objection. Relevance and not 21 calculated to lead to discovery of admissible evidence.
22 MR. PIRFO: Same objection.
[v
i i
i 78 4
N.
1 MR._CUMMING: Objection based,on deliberative l 2 process privilege. Witness may answer to the extent he has i'
3 knowledge.
1 4 MS. CASEY:' I don't see how whether he saw some-5 thing or not' implicates the deliberative process privilege.
6 MR. CUMMING: Counsel for FEMA doesn't need to 1
7 explain his objection. Objection is restated.
[
t 8 Witness may answer to the extent he has knowledge. i 9 THE WITNESS- I don't recall. I don't know that 10 I've seen other documents.
11 BY MS. CASEY: (Continuing) t 12 Q- Were you aware that LILCO had been asked by FEMA to 13 write to other school districts and ask them to par'ticipate j 14 in the exercise?
15 MS. MONAGHAN: Objection. Relevance and not cal-t 16 culated to lead to the discovery of admissible evidence.
- 17 MR. PIRFO: Same objection.
18 MR. CUMMING: Objection from FEMA. Not relevant.
19 Witness may answer to the extent he has knowledge.
20 THE WITNESS: I was not aware of that.
21 BY MS. CASEY: (Continuing) 22 Q You said that you returned to your hotel probablv O
l 79 i '~'s V
1 around 1 or 2 o' clock; is that right?
2 A No. I said I left the bus dispatch somewhere ;
3 around 2'and then re' turned, yes. !
e4- Q So, when approximately did you arrive back? !
5 A Three o' clock. !
6 Q Did ycu do anything between speaking to the bus
'l 7 dispatcher and returning to your hotel? ,
l
'8 MR. PIRFO: Objection. Relevance, i l
9 MS. CASEY: I'm merely trying to gain an understand-10 ing of Mr. Gasper's activities on the day of the exercise. j 11 MR. PIRFO: I think it's the problem I have with
<, i
\/ '
12 the question. You are not tying it to the exercise. He's S 13 not my witness.
14 t1R. CUMMING: Witness may answer to the extent he 15 has knowledge.
16 TIIE WITNESS: I believe I stopped for some lunch, 17 but nothing else that had to do with the exercise.
18 BY MS. CASEY: (Continuing) 19 O And, at what point did you call back in to find 20 out what you should do next?
21 A Before I left the administrative offices of the
- 22 school. Yeah, before I left, before I went over to the bus O)
\_
80 a
(rf t dispatcher.
2 Q Did someone tell you to go to the bus dispatch 3 . garage, or did you do that on your own initiative?
4 A I indicated that I was going to do.that, and that 5 was received affirmatively with the FEMA person that answered i'
6 the phone.
7 Q Returning to Lane Exhibit Number 2, did --
8 Ma. CUMMING: Is that the itinerary?
9 MS. CASEY: Yes.
'10 BY MS. CASEY: (Continuing)
- 1 11 Q Well, first of all, could.you tell me what you did 12 between the time you left your exercise location and 7:30 13 that evening?
14 MR. PIRFO: Objection. That has been asked and I 15 answered three times.
16 BY MS. CASEY: (Continuing) 17 0 Well, you told me you made a phone call, you then i
18 left the bus dispatch place, returned to the school --
19 A No.
20 0 Why don't you just go through chronologically 21 what you did.that afternoon?
22 A I was at the school and I made the telephone call
- - - - - - _ - - - _ - - - - -- a
1.
h 81 1
t t 1- back 'to the FEMA control cell and told them' that I was' com-yNb 2 Pletedgmy evaluation at the school district and I was going ~-to 3 go over to the bus dispatch and then I asked.what I should do j i.
4 from there. I was told I could just -- I.was, released, I could ,
t 5 g back to.the motel. ;
6 O So, then you got lunch?
7 A I had lunch, I believe, on my way from the bus 8 garage to'the motel. I got back to the motel'and I Wrote j
.t g up my exercise critique forms.
10 0 Okay. And hat took you approximately how long?
11 A A couple hours to write the critique forms up. i' O s~' 12 _ Q And, then what did you do?
13 A I don't recall.
14 Q Did you attend the one hour meeting that evening? ;
15 If you will look at Page 5, please? That is on Exhibit 2, 16 and maybe that will refresh your recollection.
17 A I attended the timeline meeting that was scheduled i 18 to last one hour.
19 Q Okay. And, how long did it last?
20 A More than one hour. In the neighborhood of two, 21 two and a half I would guers.
22 O And what were your contributions to the timeline?
O
o-1 82 ii p
V 1 A I don't recell that I had any, contributions to the 2 timeline.
3 Q Would it be fair to say that aside from arriving at b N
e4- the Shoreham Wading River School at 8 o' clock.that you did 0 5 not do any of the other activities which are referenced on H 6 Gasper Exhibit 1, which is the " Evaluator Assignment / Location.
7 Instructions?"
8 A Attachment 4? ,
y g Q Right.
i t to (The witness is looking at the document.)
i 11 A No. There are other items on here that I did do.
O V 12 Q Would you tell me which ones?
13 A I evaluated some of the contact between the <
14 Superintendent -- not the high school principal, but the 15 Superintendent with EOC.
16 Q I'm confused. I thought you testified earlier 17 that the phone call had occurred prior to your arrival?
r 18 MR. PIRFO: Objection. Can the witness finish his 19 answer to the question? You asked him what did he do on this 20 list, and he was in the process of that when he was interrupt-21 ed and you stated you were confused.
22 Can we get a complete answer to the previous O.
g m.
'.y
3 i
I 83 f3 b
\_)
1 question? ,
.c 2 BY MS.. CASEY: (Continuing)
~ !:
3 0 Okay. Which contacts between.the Superintendent and if il 4 EOC did you evaluate?
is 5 MR. PIRFO: I object. I believe counsel'has a h lt 6
right to get'an answer to a quest. ion withou't deposing' counsel j 1
7 interrupting the answer.
]
1 8 I must insist. Mr. Gasper was in the process of !j g describing what activities he did complete on this. His 4 10 answer was interrupted. He is not being allowed to go back .
I, t
13 to give a complete answer.
12 I must insist Mr. Cumming direc t the witness to g3 answer the previous question, y g4 MR. CUMMING: Witness should answer the previous l!
i!
15 question. In deference to NRC counsel, witness is instructed [
16 to answer the previous question. ;!
17 MR. PIRFO: Does counsel for Suffolk County want I
t 18 to restate the previous question to the witness? We have a 1g right to the answer. h 20 MS. CASEY: I have absolutely no recollection of 21 what the previous question was, but --
22 MR. PIRFO: The question was, if counsel will O
i
~
i 84 i
'fs ?
! l >
\.J ;
1 indulge me, Mr. Gasper was asked what -- Mr. Gasper testified j f
2 that he performed other activities .that are listed on Gasper j f
3 Exhibit 1. He proceeded to describe those activities. I 1
4 believe he said he evaluated the extent of the contact between, ij 5 .not the high' school' principal,-but the Superintendent with j 6
the EOC at which point he was interrupted.' .
9 If that refreshes the witness as-to what the a
a question was, he can continue With his answer. If not, he 4 g can go back and the Reporter can read the question.
10 MS. CASEY: I'm going to withdraw the previous 11 question.
~'
12 MR. PIRFO: I believe it's a little l' ate for that,
[
13 but if you want to do that -- I'm confused by what you mean i
14 as the previous question. ;
15 MR. CUMMING: FEMA counsel objects to the with-16 drawal of the question.
17 MS. CASEY: I would like to go through this list i
18 one by one. Mr. Gasper testified that he evaluated the 19 extent of the contact between the high school principal or 20 designee with the EOC. And, I would like to inquire into 21 that.
- 22 MR. PIRFO
- Well, you have every right to do that,
)d
)
85 -
4 )
s_/ ,
1 ma'am, but after he answers ~the question. -Can he just give 2 simply an answer.to the question?' He was going!to laundry list ,
.i 3 presumably for us, what he did on this activity.
e4- You are free to go back once he answers the ques- e 5 tion. And, because -- U 6 MS. CASEY: I just want --
MR. PIRFO: -- you gave him -- if I may. Becauss 8 you gave him an open-ended question, he has the right to o answer that question. We have a right to hear his answer.
10 Then, you can go back and pick up part of the ,
e 11 pieces of that question. But, you cannot stop him in the !
(~%
l 12 middle of his answer to talk about various parts of his It i
13 answer. f 14 BY MS. CASEY: (Continuing) 15 Q Mr. Gasper, I would like to go through the laundry 16 list one item at a time.
17 MR. CUMMING: . Objection --
18 MR. PIRFO: Are you directing the witness to 19 answer the question you asked him about eight questions ago?
20 I'm not trying to make this difficult for you. Just 21 let him answer the question, then go back. With all due 22 respect, I'm not sure you have a choice at this point <of what A
U y.,
n- ,
86 ,
L. 5
} 73 i s
- he can or cannot do. There was a question asked, and~the 7 3 2 answer was started. I think I have a right, as does other 3
counsel, just in -simply getting an answer to that question.
4 MS CASEY: Mr. Pirfo, I have withdrawn my 5 opening question. I --
6 MR. PIRFO: With all due respect', you.do not have y a right to withdraw the question after an answer has been 8 started.
9 I demand the. answer to the question. A question 10 was asked. IIe started to answer. He was interrupted. I h
11 believe I have restated what the question was, t
)
/ 12 MS. CASEY: Off the record.
13 (Off'the record.) ,
14 MS. MONAGHAN: For the record, let the record ,
15 reflect that there was a colloquy prior to a break concerning 16 the fact that counsel for Suffolk County interjected a 17 grastion in the middle of the witness' answer to a prior 18 question, and that Suffolk County is taking the position that 19 they are not obligated to permit the witness to finish his .;
20 answer.
21 It's your witness, Ms. Casey.
22 MS. CASEY: Before the break, as Ms. Monaghan has O
U
i k
87 i
[ t
~' ~
1 referenced, I had asked the witness a question and I assumed 2 het had completed his answer and I was going into a follow-up question. I 3
i s4 And, at this point the record is so confused as to 5 what that question was, whether I cut him off, whether he had i 1
6 .more to say, that I think at this. point it would be better to 7 just start anew. i a If anybody has any objections to that, would they i i
g state it for the recor now?
10 MR. PIRFO: No objection.
11 BY MS. CASEY: (Continuing)
. (~ .
\- 12 Q Okay, Mr. Gasper, returning to Gasper Exhibit 1, 13 will you tell me what you did in connection with the <
14 activity numbered Number 1 on that sheet? l 15 A I evaluated on the grounds of some contact that I ,
16 had between the school district administrator, the Superin-17 tendent, and myself. I witnessed a call from the EOC -- or to 18 the EOC from the administrator that they had completed their 19 evacuation at 8:15.
20 Q So, you witnessed one call; is that correct, to the 21 EOC?
22 A That I recollect at this point, there was one call l O
m
- 7. e.
r 88 ,
1 f
( )
1 that I had witnessed.
2 O And, what did you do in connection with Number 2?
3 A In regards to interviews with the school bus 4 dispatcher, I gained some knowledge into the dosimetry and
- )
5 some of the emergency procedures that the bus drivers were-r 6 instructed. . ;;
7 Q But you did not, in fact, board the bus, did you?
8 A No, I did not.
L I
g Q Did you note whether the bus drove a designated 10 route? .
I
- n 11 A No, I did not. l I
(~
k' ) 12 Q Did you personally examine the driver of the bus as la to his knowledge of emergency procedures, dosimetry?. ,
14 A No. j; o
15 0 And, if you will direct your attention to point i
16 Number 3, what did you do in connection with that?
17 A Nothing.
18 Q So, you did not go to the reception center?
19 A Yes, I did not go.
20 0 Why did you stay at the school from 8 o' clock 21 until noon? ,
22 A Well, part of my assignnent was to stay there to O(_,
89 i
g
-ij 1 evaluate that. I didn't know if any other activities would ,
2 happen at the school. So, until I was released from staying i
3 there, I stayed there.
4 Q And, what finally promptedyou to make the call and 5 to suggest that.you go to talk to the bus dispatcher?
6 A Well, it became apparent that no' thing.else would 4 7 happen there. I believe, in conversations with the controller, 8 she indicated that nothing else would probably haopan. t a
g And, I decided it would be a waste of time to stay '
. i 10 any longer.
E 11 Q Why did you think that something was going to I A 12 happen?
13 A Well, I was still -- I was waiting for the 14 possibility to board a bus and do some of that as is outlined $
here. When it became apparent that that wouldn't happen, 15 f
16 then like I said, in conversations with the controller, I J 17 decided I should make the call and find out. ;
18 0 At what point did you realize that you had missed 19 the bus?
20 A I realized that early on. I didn't know if they ,
21 would reenact some demonstration where I could do that or 22 quite what would happen. And, I didn't know what further i
i
~ -
- . , - - , - - - . - ,,-,,---.c ,..e,,, .,n.~, - , . -~m-- ~m- - , - - - - - - . ,. --..-n-.---,.--
90 *
,r) 1 things would happen at the school, so I waited around~to see 2 what might happen.
~
h 3 Q Did you ask the controller if .there'would be a i
f.q - reenactment? i 5 A I don't recall.
6 Q Do you recall any discussions you had.with the ,
y controller?
8 A No.
g Q Did you talk to her at all?
10 A Sure, yes.
11 Q Y u are unable to recall any conversations you k 12 had with her; is that correct?
13 A I can't recall any specifics of the conversations j 14 that I had with her.
15 Q Do you~ recall any general topics?
16 A Well, we talked about some of the items on the 17 exercise obviously.
18 0 So, you did discuss the exercise; is that right?
19 A Yes.
20 Q Did you discuss school evacuation with her?
21 A Yes.
22 O Did you discuss early dismissal with her?
()
2.
i 91 :,
en T2 1 A I don't recall. .
2 Q Did you discuss sheltering as a protective action 3 with anybody that day?
4 A I don't believe so.
5 Q Did the Superintendent indicate that there were 6 any plans for sheltering _ children?
7 A No.
8 Q Did you observe the controller input any messages?
9 A I don't recall. I don't believe I did.
10 Q Did she do anything to further the exercise?
i 11 MS. MONAGHAN: Objection. Vague.
( 12 MR. PIRFO: The same objection.
13 MR. CUMMING: Witness can answer the que'stion. r i
14 THE WITNESS: I don't believe she did. .
15 BY MS. CASEY: (Continuing) 16 0 Is it possible that she was there merely as an 17 observer?
18 A I don't know.
19 Q Did you see her take any notes?
20 A I believe she took some notes.
21 Q Why do you refer to her as a controller?
22 MR. PIRFO: Objection. Ile did not refer to her as
92 .
f'v) 1 a controller. He said she may have-been.a controller.
L 2 BY MS. CASEY: (Continuing) 3 0 .Mr. Gasper? ,
4 A I think she identified herself as such. +
5 Q But, you didn't actually see her perform any of ;
6 the activities which are generally assigned to controllers in 7 emergency exercises, did you? ,
8 MS. MONAGHAN: Objection. The question is vague.
9 THE WITNESS: I don't know.
10 BY MS. CASEY: (Continuing) 11 Q Well, aside from her self-representation as a n
kl 12 controller, was there anything else that led you' to believe i
13 that she was a controller?
f 14 A I was -briefed that I should expect a controller to I 15 be there at the school. I believe I was given her name, too.
16 So, I knew to expect that someone would be there.
17 But, I don't know that she did anything play-wise 18 that would have indicated that she was a controller.
19 Q Who told you to expect her presence there?
20 A I can't recall the individual. It was brought out 21 in one of our pre-exercise meetings.
22 Q Was this a FEMA person who told you she would be A
U
1 1
93 j l
f)
(d 1 there? - j]
i 2 A Probably. :i 3 Q You have no recollection as to'who it might have :l J
l
.4-
' been? [
'I 5 A No.
6 Q I would like to direct.your attention once again to i 7 Page 43 of the post-exercise assessment report. Looking again ,
)
8 at the last paragraph of Section 2.1.2, I believe you identi- i:
g fled that as a paragraph that you drafted; is that correct? l
\
10 A That's correct. . ,.
r I
11 Q If you will look at the last sentence of that O)
\
paragraph, it states:
12 "A sufficient number of buses and 13 drivers are available for the transportation responsibilities f
r 14 required during an evacuation of schools."
15 What is the basis for that statement, Mr. Gasper?
16 MR. CUMMING: Objection as to this line of question-17 ing based on deliberative process.
18 Witness, to the extent he has knowledge, may 19 answer.
20 TIIE WITNESS: Knowledge for that statement came 21 through interviews with the Superintendent of the School 22 District and the bus driver, the dispatcher of the bus O
1 94
/'T
% k 1 drivers. ,
2 BY MS. CASEY: (Continuing) ,
d 3 Q So, what are the schools you refer to in that y j
4 statement? $
e 5 MR. CUMMING: Objection based on deliberative f?
process.
6 To the extent witness has knowledge, he may )
y answer. h
$h 8 THE WITNESS: I think the schools I was referring j 9 to are the ones that are in the Shoreham Wading River School 1
- t 10 District.
e 11 BY MS. CASEY: (Continuing)
O 12 Q Okay. As the evaluator of schools, Mr. Gasper, 13 I am going to ask you a hypothetical question. Ass'ume that 5 14 there are 10 school districts in the Shoreham EPZ, and then
[
h 15 assume, if you would, that only one school district had said ;
16 that it would be willing to implement protection actions in 17 the event of a Shoreham emergency, with those assumptions in 18 mind would you still conclude that field objective number 16 19 had been met?
20 MR. MONAGIIAN: I'm going to object to this line 21 of questioning to the extent that it deals with issues that 22 are not relevant to the scope of this proceeding in terms of CE)
95 i
()
1 which schools have stated that they will,or will not partici-2 pate in the Shoreham emergency plan.
3 o In additi~n, I question the witness' competence to 4 answer this question. ,
5 MR. CUMMING: FEMA counsel objects to the question 6
based on relevancy and based on the witness competence to y answer.
8 However, the witness may answer the question to the o extent he has an opinion.
10 MR. PIRFO: NRC staff also objects to the i
11 relevance, since the answer to this question cannot possibly i l
('-
12 lead to the discovery of any admissible evidence in the f 13 proceeding.
I 14 MS. CASEY: I'm merely asking the witness who 15 observed school evacuation a hypothetical question. As to 16 relevance, I believe it is directly relevant to Contention 17 15 and 16.
18 TIIE WITNESS: I don't believe I can answer that.
19 BY MS. CASEY: (Continuing) 20 0 Why are you unable to answer it?
21 A I would -- I guess I would need more information.
22 0 Such as?
O
i 96
- 1 A Resources that might be available to the school 2 district, the one that has agreed to play.
l 9
3 Q Then, are you saying that one school district, if !
u
.4 it has sufficient resources, could take the responsibility , l 5 f r evacuating the entire EPZ?
6 fir . PIRFO: Objection., .
7 MR. CUMMING: FEMA counsel objects to this line 8 of questioning as going into the deliberative process.
g Witness is instructed not to answe'r. '
10 MS. MONAGIIAN: LILCO objects on the grounds that 11 it calls for a speculative answer on the part of the witness.
12 MR. CUMMING: Let the record show that witness did answer the hypothetical question. ij 13 i
14 BY MS. CASEY: (Continuing) 15 Q Did you ever discuss this situation with anybody 16 before?
17 MR. PIRFO: Objection. What situation?
[
18 MR. CUMMING: Objection as to form.
MS. CASEY: As to whether -- if it is assumed that
( 19 20 only one school district participates.
21 MR. PIRFO: Objection. Did he ever discuss the 22 hypokhetical you have asked with anybody else? Obviously he O
+,
t
97 th
( f 1 hasn't. What is the ' question?
2 MS. CASEY: Whether he has ever discussed the 3 situation posed as a hypothetical with anybody else before.
4 MR. PIRFO: Okay. Can we have -the . question directed i 1
5 to the witness, then?
6 .
BY MS. CASEY: (Continuing) .
7 0 Have you ever discussed with anyone the lack of 8 participation in the exercise of any of the school districts I
9 besides Shoreham Wading River?
10 MR. CUMMING: Objection as to relevancy. Witness, l l
11 to the extent he has knowledge, may answer. l O -/ 12 THE WITNESS: I don't recall.
f 13 BY MS. CASEY: (Continuing) 14 0 Mr. Gasper, if you would assume then that there are !
15 10 school districts in the Shoreham EPZ and also assume only 16 one school district has said that it's willing to participate 17 in the emergency plan, would you be able to draw from that 18 any conclusion as to the ability to protect the health and 19 safety of school children in the EPZ in the event of a 20 radiological accident?
21 MR. PIRFO: Objection.
22 MS. MONAGHAN: Objection. Relevance.
O
r 98 :
i (3
V 1 MR. CUMMING: Objection. It requires the witness 2 to speculate. If it's a restatement of a hypothetical, then i
3 the counsel should so state. I 4 It sounds to counsel for FEMA as if it's the same i 5 hypothetical which witness has been asked and answered. j i
6 MR. PIRFO: The NRC staff has the same objection.
i 7 That question was asked and answered. The witness said'he 8 needed some other information, that he had problems with the i
9 hypothetical.
10 The question has simply been restated.
t 11 MS. CASEY: It's not the same question.
12 MR. PIRFO: Well, the record will soeak for itself.
13 But, I object on the grounds that it's the same question that j 14 the witness had problems with.
15 MR. CUMMING: Witness may answer to the extent he 16 has knowledge.
17 TiiE WITNESS: I would not be able to answer that 18 question.
19 BY MS. CASEY: (Continuing) 20 0 That it would not lead you to draw any conclusions; 21 is that correct?
22 MR. PIRFO: Objection.
O
99
<x b 1 MR. COMMING: Objection. The prior objection is ;
2 restated. Witness may answer to the extent he has. knowledge.
d 3 MS. CASEY: He already has. Just give me a minute.
]
I
,. 4 I don't think I have anymore questions.
5 BY MS. CASEY: (Continuing) i 6 Q S t4 v it>5 Who is T. Seyrels?- Qh l 7 A He is the Deputy Associate Director of the Energy )
l 8 Environmental Systems at Argonne National Laboratory.
9 Q And, what is his involvement in the Shoreham exer-10 cise? i i
11 MR. CUMMING: Objection based on relevancy. Witness f
(~)
\/ 12 may answer to the extent he has knowledge. -
13 THE WITNESS: I don't know that he is directly i
14 involved with the exercise at all, except being in charge of j 15 the division -- part of the division that some of the work 16 force came out, the evaluators from Argonne.
17 BY MS. CASEY: (Continuing) 18 Q Did he review draft reports?
19 A I don't know.
20 MS. CASEY: I am showing the witness a letter dated 21 March 12th, 1986 from Edward Tanzman to Roger Kowieski.
22 O
E% *%
100 g
V 1 BY MS. CASEY: (Continuing) l s'
2 0 hat I would like to ask, Mr. Gasper, is why 3 would Mr. S'eyrels have been copied on a letter such as that? };
4 fir. CUMMING: To the extent the witness has know- )
5 ledge, he may answer. ;
v 6 TIIE WITNESS: It is internal procedures at Argonne 7 to copy Mr. s on any correspondence in regards to the h 8 FEMA program. l ll 9 BY MS. CASEY: (Continuing) 10 0 And, what's the reason for that?'
11 A It's requested by him. !!e keeps an ongoing file 0,
'V 12 of documents in and out, particular this is a copy of --
i la copies were included of the post-exercise assessmerit. And, !
14 he has a full file of all those reports.
15 0 You said you filled out your critique forms on the I 16 day of the exercise; is that correct?
17 A That's correct.
18 !!S . CASEY: fir. Cumming, I would ask you again why 19 we haven't received those previously when --
20 11R. CUM! TING: Counsel's request is noted.
21 MS. CASEY: Previously whenever a witness has 22 filled out his critique forms on the day of the exercise, full O
t 101 i
(
V copies were turned.over to us.
1 2 MS. MONAGIIAN: Let the record reflect that FEMA has J
3 previously turned over the copy of the evaluator critique form 4
of only one of the witnesses. That critique form, as the :
i 5 witness testified, was filled out during the course of the
~
e exercise. .
7 MR. CUMMING: For the record, I will say the a specific exercise critique form turned over was that of 9 Edward Tanzman who left the exercise early.
10 MR. PIRFO: My recollection conforms with LILCO l d
11 and FEMA's recollection. I 12 MS. CASEY: My questioning of this witness is 13 completed at this time. So, as far as I'm concerned I will p 14 adjourn this deposition with the understanding that when we 15 receive more documents fron Mr. Cumming that it may be neces-to sary to call Mr. Gasper back.
17 MR. CUtiMING: FEMA counsel has only one question.
Indexx is CROSS EXAMINATION 19 BY MR. CUMMING:
20 Q You stated for the record that you filled out your 21 exercise evaluation critique form the day of the exercise.
22 Was it during the exercise hours or post-exercise?
O 6
102
'E)
C A It was after my involvement in the exercise. I l
1 2 believe that the exercise was still ongoing, but I was back 3
in the motel and had no further activity or input into the i v
e4 exercise. So, it was post-exercise as far as,I personally was ;I i
5 involved. a i
> 6 MR. CUMMING: No further questions. . i q MS. MONAGi!AN: I have some questions for the i i
j g witness. .
1 p CROSS EXAMINATION 10 BY MS. MONAGIIAN:
i e ind:xx 11 Q Mr. Gasper, how mdny FEMA exercises have you (2) -
12 evaluated?
13 A Somewhere over 60. I don't know exactly.
f 14 0 Itave you evaluated -- have some of those exercises 15 that you have evaluated been since the time of the Shoreham
- 16 exercise on February 13th, 1986?
17 MS. CASEY: Objection on the grounds of relevance.
j If MR. CUMMING: Witness may answer the question.
19 TIIC WITNESS: Yes. I have participated in other 20 exercises since then.
21 BY MS. MONAGIIAN: (Continuing) 22 0 Do you know how many exercises?
L l'
103 g MS. CASEY: Objection. Relevance. ;-
1 2 MR. CUMMING: Mitness may answer the question to i 3 the extent he has recollection.
b t 4 Tile WITNESS: Somewhere around eight or ten. j 5 BY MS. MONAGHAN: (Continuing) f s O Mr. Gasper, I would ask you to turn to Gasper
}
1 Exhibit Ex 1. Previously, you were asked a question which
- l 8 activities listed on Gasper Ex 1 you evaluated, e could you give us a listing of those activities p
10 that you ovaluated? i 4
11 MS. CASEY: Asked and answered.
12 f1R. CUMf1ING: Witness may answer the question to 13 the extent he has knowledge.
14 Ti!E WITNESS: Part of !! umber 1, part of Number 2, 15 Number 5.
i 16 BY MS. MONAGilAN: (Continuing) 17 0 Could you describe for us what you ovaluated in is connection with Number 17 19 MS. CASEY: Asked and answorod.
20 MR. CUMMING: Witnoss is instructed to answer the 21 question.
22 T!!E WITNESS: I ovaluated discussions, phono calls, O
I 104 '
~
i i
N}_) between the EOC, LERO EOC, and the Superintendent of the
. i 1
]
2 School District, noted the time of the phone call. .
3 .BY MS. MONAGIIAN: (Continuing). ,
4 0 Is that all that you ovaluated in connection with ij 5 Number 1, with Item Number 1, or is there anything else? ;
6 A I believe that's it. -
7 Q Would you go to Item Number 2 and describe what l a parts of Number 2 you ovaluated?
- 9 MS. CASEY: Asked and answered.
10 MR. CUMMING: Witness aay answer to the extent he ,,
11 has recollection.
12 Ti!E WITNESS: Through interviews that' I conducted 13 that day, I gained knowledge on dosimetry, some of the g I
14 omorgency proceduros the drivers know or were instructed of.
- 15 And, I bellove that's it for Number 2.
t 16 BY MS. MONAGilAN: (Continuing) 17 0 In connection with Number 2, did you examino any la maps concerning the route which the drivers would go? ,
to MS. CASEY: Asked and answorod.
20 Tile WITNESS: Yes, I did.
21 BY MS. MONAGIIAN: (Continuing) 22 0 Is thoro anything further that you did in connection *
( ,
4 i
105 *-
(D 1 with evaluating Number 2 on the day of the exercise?
2 A No.
3 0 Mr. Gasper, would you look at Item Number 3? Was y c4 it your task to evaluate any of the activities at the 5
reception center on the day of the exercise?
8 A No, it was not. -
7 MS. MONAGilAN: I have no further questions.
8 MR. PIRFO: Staff has no questions.
9 MR. CUMMING: Counsel for FEMA has no questions.
10 MS. CASEY: Okay. This deposition is adjourned. !
4 11 AND FURTilER Tl!E DEPONENT SAITl! NOT. !
12 (Whereupon, the deposition is concluded at 12:08 13 p.m., Monday, December 1, 1986.) j 14 15 (() M ,
- A.
" WILLIAM R. CASPEIY 16 17 18 Om to DetoM M 19 ej oi ;C' 2i
_p.Adad M gy Comas. con wa 22 O
5.
106 l 1 CERTIFICATE OF NOTARY PUBLIC 2
3 I, GARRETT J. WALSH, JR., the officer before whom 4 the forogoing deposition was taken, pages 1 through 105, do i s hereby certify that the witness whose testimony appears in the 6 forogoing deposition was duly sworn by me; that the testimony 7 of said witness was taken by ma and thoroafter reduced to s typewriting by me or under my direction; that said deposition 9 is a true record of the testimony given by the witness; that to I am noither counsel for, related to nor employed by any of i
11 the parties to the action in which this deposition was taken; 12 and, further that I am not a relative or employoo of any 13 attorney or counsel employed by the parties horoto,' nor l
. I 14 financially or othorwise intorestod in the outcomo of tho ,
15 action.
j t / e v f f 18 GARRETT J. WALSil, JR.
19 Notary Public in and for the commonwealth of Virginia at Largo
- 20 21 My Commission Expiros
- January 9, 1989
! 22 i
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~~AstrA, [y #l str. cme n sumamest samC!ss - spaLeases assicammut/tacaTies InstesCTieus page 26 of 23 3.arties Teek Time predesig-Ember af This Free meted Oteerwer Perferund assi&' h arlem play location Beecripties of Activity II 1 of 1 8:00 sharehem-Wedlag River . I ammeest seest classificaties declared appresteetely 5:30 h eistaat Teen sigh Schest alert classificaties declared approeiantely het '
w eers Scheat St. 25A site Asee amargency classification declared apprealastely este a .ac .e t ies) Shorehen, WE 11784 Generet hergency classification declared appraelastely 9:30 (516)929-8500 l '
- 1) Evaluate the esteet of contact between the sigh Scheel principal (or designee) with the EDC, noting all appropriate tiar e ,- e especially the time estimated for ewecasting the scheel into ite
- huese. *
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- 2) Board the hue which will se to the Recepties Center (or to l
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asether location that the Scheel District decideo - either a C host scheel or another locaties pureuset to the Nigh Scheel's [4 precedere), noting whether it folloue the designated route, the
- haeuledge of the driver of emergency procedures, declastry, and att appropriate times.
- 3) Af ter arriving at the Recepties Center er other location, stay sheerd the hise as it sees tu the Emergency Worker Decentaminaties Facility.
- 4) Cet off the hue at the guergency Werher Decentamination Facility, and locate the LERO Centre 11er. Be/she will arrange for transportation heck to the Nigh Scheel yes departed free, and where yee car is. The hue yee rede en will he driven heck by its driver to the hoe garage ednere it origlasted.
- 5) Upon completing this assisement, advise year Teem leader through the FDet haicator that your seeig1 meet is complete.
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OPIP 4.1.2 Page 6 of 7 (f)m Attachment 1 Page 1 of 1 LERO MESSAGE FORM No '
- t.rau tIcle t.ocacton name Trom: fu8/rt $clost $e p E O C- M Tr S i p t Q, To: l$M 0'e n D FC C. Nos & .t Date/ Time: I//4(([ ~ /6 Yb '
Hesaage: N M M9.e ctesO/
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+b twa~%u , vd M . V <
O Routing for: l%l Action l[lInformation Response Required: l[l In Response to Massage No. i
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O White copy - Addressee (signature)
Yellow copy - Originator Rev. 5 Pink copy - Lead dor =unicator 721889
THIS IS AN EXERCISE SHOREHAM EXERCISE
,s SCHOOL EVACUATION MESSAGE (j LERO EOC - Part 1 Suffolk County, New York Date: February 13, 1986 Hessage LERO School Bus - EOC Trom: C. Connolly, EOC Team Leader Tot Public Schools Coordinator / Bus Coordinator at LERO EOC via Exercise Controller Initiating Event: Decision to close or evacuate schools. 4, l .
Message LONGWOOD CENTRAL SCHOOL DISTRICT HAS REQUESTED SCHOOL BUS RESOURCES TO ASSIST IN TRANSPORTING 40 CHILDREN TROM RIDGE ELEMENTARY SCHOOL ON RIDGE ROAD, RIDGE, NEW YORK 11961'.
A REAL BUS IS TO BE USED TOR THIS DEMONSTRATION; ALTHOUGH ~No CHILDREN ARE TO BE ACTUALLY LOADED ON THE BUS.
THE SCHOOL DISTRICT HAS REQUESTED THAT 'IEE CHILDRf.N BE SEN RECEPTION CENTER AT NASSAU VETERANS Mr.MORIAL COLISEUM.
! A TEACHER WILL BE AVAILABLE AT THE SCHOOL TO RIDE THE BUS AND ACCOMPANY '1HE CHILDREN TO THE RECEPTION CENTER.
THIS IS AN EXERCISE l
l l
l 721000 I
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