ML20206Q894
| ML20206Q894 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/16/1986 |
| From: | Streeter J SUFFOLK COUNTY, NY |
| To: | |
| References | |
| CON-#287-3148 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8704220059 | |
| Download: ML20206Q894 (126) | |
Text
s#
omap TIM. bCRIF1 00LMETED 0
OF PRCCHKDINGS 17 APR 21 A9:08 UNITED STATES OF AMERICA 0FFICE GF SEGRti AhY 00CKET N.>.CE WICE NUCLEAR REGULATORY COMMISSION BRANCH ATOMIC SAFETY AND LICENSING BOARD
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the Matter of:
Docket No. 50-322-OL-5 (EP Exercise)
LONG ISLAND LIGHTING COMPANY (ASLBP No. 86-533-01-OL)
(Shoreham Nuclear Power Station, Unit 1)
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x A
DEPOSITION OF JOHN W.
STREETER, JR.
l Yaphank, New York l
Tuesday, December 16, 1986 l
ACE-FEDERAL REPORTERS, INC.
StenotypeILyrters 444 North Capitol Street
'h Washington, D.C. 20001 (202) 347-3700 Nationwide Coverage 800-336-6646 8704220059 861216 PDR ADOCK 05000322 PDR T
l
COFRECTIONS TO DEPOSITIO::
Pege Line Correction:
4 22
" Street" to "Streeter" 9-18
" resistent" to " resistor" 17 22 "two" to "to" 20 15' "is" to "as" 24 4
" curricular" to " curriculum" 32 10 "and* added 38 11 "Marger" to "Mager" MI 1
1 J
,l 1
c I
I d
- n s,
q
.g l
- 'l
' ~.;
J.
- ) '.,
4 f
e i;;
- 1 1
3, 1;
s
. /-
t 4
12/16/86
- 11 LUNITED STATES OF AMERICA
^ JbsWalsh NUCLEAR: REGULATORY COMMISSION LV00 0 31.'
.2-
- ATOMIC'. SAFETY'AND LICENSING-BOARD
~
3
X 4
.In'the Matter of.
=
LONG. ISLAND LIGHTINGECOMPANY.
- . Docket'No. 50-322-OL-5 5
'(EP' Exercise)
(Shore' ham N'uclear.P'ower Station, 86-533-01-OL).
~6 Unit 1)
(ASLBP No.
g.
g 8
^
g DEPOSITION OF JOHN.W.' STREETER,~JR..
Yaphank,.fNew York ~
10 Tuesday, December 16, 1986 11 12 Deposition of JOHN W. STREETER, JR.,fcalled for-examina-
' tion pursuant to notice of deposition at theIPolice Head-
'13
!4
= quarters, Yaphank, Long Island, New. York, at-9:18 a.m.,
~
16 before; GARRETT J. WALSH,'JR., a. Notary.Public-in and'for.the Commonwealth of Virginia at Large, when were present on 16 17 behalf of-the respective parties:
~
.18 MICHAEL MILLER, ESQ.
h P.
MATTHEW SUTKO, ESQ.
i 19
' Kirk patrick & Lockhart' I'
1800 M Street, N. W.
~
20 Washington, D. C. 20036-5891 On' behalf of the Intervenor, the County of Suffolk 21 l
l 22
- 1 r
'"h f.
p-4 x
r 2
- Qwl.
V
<*.;te 1"
' APPEARANCES::
(Continuing)'
s 2
JESSINE'A. MONAGHAN,:ESQ.
LLEE_B. ZEUGIN, ESQ.- -
3 Hunton & Williams
~
7071 East Main Street r;
4 P. O '. Box.-1535.
~
. Richmond, Virginia 23212 5 -
On behalf of the Applicant, Long Island Lighting-company l s
6 RICHARD J.
ZAHNLEUTER; ESQ.
7-Deputy Special Counsel toithe. Governor Capitol, Room 229 8
Albany, New YorkJ12224 On behalf of'the Intervenor, the: State of
~
9
-10 12 13 14 i
15 l
- 16 17 18 19 20 i
l' l-21
- 22 O
r i
i-
~
Sp..
j 3
s QL
~1
_C'.O N_ T_ _E N. T_.S_.
2 Dire'ct. Cro'ss. Redi're'ct j;
3
. John ~W.
Streeter,.Jr.-
4
'107
- 113-I
v:
4 5:
,6
/
7' L
8 9
.E X.H.I'.B.I T
.S.
10
.For-Identific'ation
'It'-
Streeter Deposition' Exhibit Number l' Page?6 -
Resume =~of' John W. Streeter, Jr.
12 1
13-14 41 15 16 17 18 19 20 21 22
~
'b
.p s,5 sg 1,
4
. )-
v P_ R_ O C E, E_ D, :I_INj G_i S_
I 1
2 Whereupon, 3
JOHN W..STREETER, JR.
4 was called as a: witness and, having first been duly' sworn,.
5 was examined and testified as follows:
6-DIRECT EXAMINATION' 7
BY MS. MONAGHAN:
.8 Q
Lt. Streeter,'my~name is Jessine Monaghan.
I am 9
with the-law firm of-Hunton &' Williams, and'we represent 10 Long Island Lighting Company.in this litigation.
11 I will be asking you a-number of questions this 7-
~
12 morning. 'Please understand that you should let me know if:
13 at any time you need to have a question clarified or if you 14 would like to expand upon an answer that you have given at 15 some earlier time in the deposition.
16 Now, would you please state your full name 17 and address.for the reporter?
18 A.
Okay.
Lt. John W.
Streeter, Suffolk County-Police 19 Department.
Do you want my home address?
20 Q
Yes.
21 A
5 Thornton Commons, Shirley, New York.
O Lt. Street, did you review any documents or other 22-
- a. '
- s. =
- l lj ? l [l ' ' -
t.
- ),,, i
_.- ( c ; A :.,
r.
s.,
e 5
^'
g
'f.
-f f1 cmaserialslin. preparation ~for youradeposition today?
2 iA.
.Yes.-
3
-Q.
Could you identify the documents that you review-4
'ed, please?
4
~5 A
The document that's entitled the'" FEMA Report"
.6' and photocopies'of several of the' contentions.and parts of 4
7 LILCO's' general-plan.
8' Q
Do you recall which of--the cont'entions you.re--
9
'viewdd?
10 A
I recall some;of them by number.
I:may not re--
11 call ~all of them by number.
'O 12 O
Which of.them do you: recall'by number?
13.
A1 Okay.- 22, 42, 45 and 50.
14 Q
Did you review any other documents besides-the-15 contentions, LILCO's plan and the FEMA post-exercise. assess-:-
l I..-
16
- ment in preparation for your deposition today?
17 A
Well,-there were other documents that I was given.
18 I may not recall them specifically by title.
19 Q
Do you recall generally.what they were about?
20 A
- Well, they were about the FEMA exercise.
- 21 Q
Anymore specifically than the FEMA exercise, do l
22 you recall what the contents of the documents were?
10 l
m
-r-4.-.;-.~..,
-._,_u,--..
..~
. ~.
3 T
,#-[
q ';.: ;
~, ;
~ Y w
p s.17, ;
V 6
c;:, ~
..n
.3,_
i - i_ i -
_ J k
~
,5)_,
li
. A No.
They are related: to '.that' matter.1 1
.Q.
~ Do you kilow who' h' aid prepared ithe(documents?-
~2' y -
.3
- Who hadnauth'oredi the-documents that you" reviewed?
4 A
.To the.best of$my. knowledge, FEMA was.the author-4 s
of one report; Eand, LILCO.._was:' the author ofc some of the 5
' t a
reports; and, the law firm -represented. by these gentlAmen' was
'7-the~auth'or I:believe of the contentions.- I.dod't:know for:
18
- sure, 9
- 0' Okay., In preparing for.th'is deposition, have4you-p 10 looked at any transcripts or. deposition testimonyLgiven.by 11; anybody else?
~
'- O E.
.12 i A No; i 13-
-Q Okay..Have -
I'm going to-show1youa copy of a
-- c.
l:
14 resume that'has'been provided by counsel.-
t:
. 15 A
Yes.
a 16 MS.~MONAGHAN:
I will~ask'that it be marked as 17 Streeter Deposition Exhibit Number 1.
k 18 (The document referred to was 1
19 marked as Streeter Deposition ~
i 20 Exhibit Number 1 for identifi-
,. indexxx 21-cation.)
22 s
4
- ~ -
-Y 4
e4e
- ,,v,
,.e e-,
r-,
..,-,-,e,>,wem,-,,-,,,,,..e
. e-eve
- e p.,,m,rw_,,_,._e.,,vi,,.-<,
,,,ym,----y,-moy,,-,..,,,,i-,.e7,,v-ww,---,,.9.-w,
,,--ve.-ve.
w p
- n.
.. 0 9,
,.E"*'
~
j gj -
t,
,i-i 4
' 1 i,
- 41 <
. l.
,7 ;
i: a,,b:
A
^
v:
o
-(Continuibg) l'
'BY'MS. MONAGHAN:,
. 2..
Q' Lt..Streeter, I wouldlask.that you: review-this i. '. ' 4
.. L.
-s resume.and ask'if;it accurately describes your. education and o
~
4' employment background?
5
'A.
'Okay.
6 (The' witness-is looking at.the document.)
T A
-Yes.
8 Q
Are there any statements on the resume that are 9
not' accurate.as of:the present-time?
-10'
-A No.
11 Q-Okay.
Are there any: recent' developments L that: are
'12 not-included?
13 A
No.
14 Q-Have you ever-testified before at a deposition, 15 in co'urt or in an administrative proceeding?
-16 A
No.
17 Q
Okay.
l8 A-Well, are you talking ab'outi civilly or criminally?
19 Q
Either one.
20 A
I've testified before in court for criminal mat-21 ters, yes.
22 MR. MILLER:
The question, Lieutenant, was at a
.g
,/
1 deposition.
2 THE WITNESS:
I'm not sure if the phrases are inter-3 changeable with regard to --
4 MS. MONAGHAN:
Let's go back and let me rephrase 5
the question.
6 BY MS. MONAGHAN:
(Continuing) 7 Q
Lt. Streeter, you have stated that you have testi-8 fied in criminal proceedings?
9 A
Yes.
10 Q
Have you testified at any other time besides 11 during criminal proceedings?
()
12 A
Only administrative hearings in regard to the-
' ^ ~
13 Department of Motor Vehicles.
14 Q
What was the nature of the testimony you gave 15 in those administrative hearings?
16 A
In regard to specific incidents of persons accused 17 of refusal to take a blood alcohol test.
18 Q
Okay.
When were you first employed by the Suffolk 19 County Police Department?
20 A
In 1968.
21 Q
Could you trace for me your employment history 22 from the time you completed high school until you first began r~s
9 x
1 working for the Suffolk County Police Department?
2 A
Okay.
When I completed high school, I went into a
the United States Marine Corps.
'okay.
In; the Marine Corps 4
I suffered a physical injury and was unable to complete my 5
enlistment and returned home and went to work in an electronics 6
factory.
Okay.
I then went to work at Hofstra University.
7 okay.
8 Q
Yes.
9 A
And my next employer was the Incorporated Village 10 of Huntington Bay Police Department.
And my next employer 11 after that was the Suffolk County Police Department.
t 12 0
okay.
Did you receive an honorable discharge from 13 the Marine Corps at the time that you left their service?
14 A
Yes, I did.
15 0
okay.
What was the electronics factory that you 16 worked for and what did you do for them?
17 A
It was the calibration of a device called the 18 potentiometer.
It's a variable resistent.
19 0
okay.
What did you do for Hofstra University?
20 A
I worked in the Security Department.
21 Q
okay.
When you were employed by the Incorporated 22 Village of Huntington Bay, what did you do for them?
/'s V
1
I
.e 10.
l
.b.m.
1 A
I was a police officer.
4
.2 0
What.were yourfduties~as a police officer for the 3
Incorporated Village of-Huntin ton-Bay?
4 A
General police service, working a rotating tour 5
on patrol.
6 Q
So, it was basically a patrol function; is that a 7
correct --
8 A
.Yes, it is.
9 0
Okay.
A n'd you began your employment with the 10 Suffolk County Police Department in 1966; is that correct?
11 A
No.
'68.
12 0
'68, okay.
What is your current job title ~ with the 13 Suffolk County Police Department?
14 A
I am a Lieutenant.
15 0
And, could you describe the-duties and responsibi-16 lities that you have as a Lieutenant for the Suffolk County.
17 Police Department?
18 A
My present duties and responsibilities are Execu-19 tive Officer of the Suffolk County Police Academy, and I 20 oversee specifically two units, the Recruit Training Unit and 21 the Audio-Visual Research Unit.
l t
22 0
Okay.
Who do you report to in your position as O
l l
I
=_
y
S 11
,y
(_J-1 the Executive Offic'er'in'the P'ol' ice'Acad$my?
2 A
~ To'the Commanding-Officer lof thelPolice: Academy.
3 lQ Okay.
In terms of the organizational structure of ntheSuffolkCountyPoliceD'epartmeNt,'h$w'doestheAcademy 4
'5 fit into that organizational structure?
6 lA Well, it's attached'to.the-Headquarters Division.
7 Q
How many divisions are there in the Suffolk. county-8 PD?
9 A
There are three= basic divisions.
10 Q
Okay.
What are those divisions?
11 A
The Investigative Division, the Patrol' Division 12 and the Headquarters Division.
13 Q
And the Academy is attached to the Headquarters 14 Division; is that correct?
15 A
Yes.
16 Q
Who is in charge of supervising the Academy?
17 A
You mean, the --
18 Q
Who would be the Commanding Officer of the 19 Academy, if that's the appropriate term to use?
20 A
Yes.
Captain Robert D' Muchowski, D-m-u-c-h-o-w-s-21 k-i.
22 Q
Aid, do pou report to Captain D'Muchowski?
O
m -
12
' _j 1
A Yes, I do.-
2 Q
Directly?
3 A
Yes.
4 Q
Can you explain for me what you do in your roll as 5
a Supervisor of Recruit Training for the Police Academy?
6 A
Well, I am the immediate Supervisor of its 7
Commanding Officer.
8 Q
What do you do on a daily basis as the immediate 9
Supervisor for the Commanding Officer of the Academy for 10 Recruit Training?
11 A
Okay.
I handle any problems that may arise,
( )
12 personnel type problems.
I make decisions in the day-to-day 13 operation of the Recruit Training program.
14 Q
Would you characterize your role as administra-15 tive?
16 A
Yes, I would.
17 Q
Would you characterize your role as being an 18 instructor?
19 A
On occasion, I'm an instructor, yes.
20 Q
Your primary role at the present time is that of 21 an administrator --
22 A
Yes, it is.
I la
(
4 x-I r
(
I
~,
s
,s y
f-13 7X
' V
. a
,;x 9
~
11
~.Q
.-- withdre'spect'.to Recruit Training?-
J c.
$=
2, A.
- Yes.-
~
3 Qj Could you xpla'inifor what y5u doin connectio'n.
4
!.with your responsibilities for audio visual work at!the n 1-1;
+
7
_,,2.,
5 Academy?'
f 6
'A-It's 'primarily-an ' administirative position, alSO',
7 dealing with planning of the: activities of the unit.
~
8 Q
~ What.do.you-do with : respect to ' tihe planning' of
~
9 ithe activities?.
10 LA Well, I designate the directions that we are going
[
'11
'to-take;in choosing _particular-training-subjects, and-I 3;
prioritize tlie training subjects as well.
i u
-12 How do you prioritize the training subjects?
13
'Q' Do-you:have certain criteria that you apply to that?'
1 l
-14 i'
15 A
Well,~it's based on~need.
.16
-Q Could-you explain for me a little further what P
- 17 you mean-by based on need?
$t 18 A
Sure.
As the training unit for the' department for.
i 19 in-service instructional television, the system has been in 10 existence for some t'ime, and we'get a lot of input from i
members of the Department and outside sources as perceived 21 training needs and we examine their perceptions in terms of 22 LD
.~
14 ri
- ,$.f 1
if_there is.an actual-training'need and,_if so,;to what:
J 2
degree.
3 Q
So,.in other words, you take-comments from. persons
'4 outside the Department -- outsidelthe Academy -- who might 5
make comments on the trainin'g program,tdnd'use that to. revise,
's modify or improve your training program; is that.right?
4 _
7 A
Uh-huh, also internally'as well.
8-
'O So that comments would.also come from persons 9'
within the Academy itself?
10 A
That's true; 11
-Q How do you go about choosing the subjects-that' 12 are going to be: taught in the Academy?-
13 A-That are taught in-the Academy itself?
~
4
-14 Q
Yes.
15 A
Are you talking about recruit-training or In-16 service training?
17 Q
Let's talk about recruit training.
Is this part 18 of what -- let me rephrase the question.
19 When we were talking about your administration of the audio visual program, you said that.one of the activities i~
20 you performed was choosing the subjects which were going to 21 i
22 be taught, and I want to investigate that a little further 7-.
k_ -
I
.. ~... - _ - -. - - -,,.. - -. -
15 g
1(_)
1 with you.
2 A
Okay.
3
'O When you talk about choosing the subjects that are q
e 4
. going to be taught, what do you mean'byuthat statement?.
S' A
Well, again we go back to training needs.
And 3
(
6 based on information that we receive, we look'at what are 7
perceived training needs from other' sources, and we look at 8
in terms of' actual need.
'9 Q
Do you charac'terize-need as being, for example, if 10 you'need more people in the Investigative Division as opposed 11 to the: Patrol Division; is' that how you characterize need?.
12 A
No.
Basically we are talking about p'rformance, e
13 job performance.
14 Q
So, you choose the subjects that are going to be 15 taught in the audio visual part of the1 training program 16 based on what the perceived need is for job performance?
17 A
Uh-huh.
For example, if there is-a law changed 18 that would impact the Patrol Division having to do, for 19 example, with search and seizure it would be imperative that 20 that information get out to the personnel as quickly as 21 possible.
22 O
Is the audio visual portion of the training program O
16
..n.
Am) 1
. used primarily1for recruit trainingj or primarily for-in-2 service. training?.
, i!
3 A-Primarily-for in-service training.
4 Q
Is it used at all 1n. recruit tra1ning?
5
. A' Yes, it is.
~
L 6
Q-
.Lt..Streeter, your resume lists a third, as I 7
. understand it, category of things-thatiyou do:in connection 8
with'your duties as Executive Officer of the Policy Academy.-
9
.When I look at'your resume, it says that.you are.the primary.
10 instructor for' police-response to critical incidents.for
~
11 recruit, in-service and supervisors training needs.
~
h' 12
- A Yes..
13 Q
What does that mean that you do?
14 A
. Well, it's responding to -- responding to critical 15 incidents is kind of a broad subject that touches on all 16 levels of police officers.
And, I'm the primary instructor 17 in that~particular subject matter.
18 Q
How would you define a critical incident?
19 A
Well, a critical incident is an incident that 20
-requires immediate response, what the layman would term an 21 emergency.
And it usually involves quick planning and deploy-22 ment of emergency personnel.
And there is some degree of
- ~
. -. ~ =. - -. -
2 17-
.mP P
.s I
danger;to bothithoserpersonnel.and the;public.;
Do you have - ;what,do.you. teach, recruits-in the L2 Q.
, a :
n...
r; critical:; incidents't'rainingprogramJthatyou}.are.the.in'
!~,
3
~
4' structor?
i n
^
+.
~
_,s 5
A-Could you clarify *thatm ad lititle; bit?.
.6
- Q~
Sure, I would be. glad:,to'.
Are.there'particular i:
7
-topics that'are covered in-the critical-incidents training 8
program?
9
-A-Yes, there'are.
' ~
~
1
. 10' Q
What!are those: topics?
1 11 A
First reponder procedures for incidents' involving p
i -
hazardous' materials, and first responder.to c' rimes.in: progress, 1
12.
and.first reponders to' incidents invol'ving domestic' violence.'
- 13 14 Q
Ok'ay.
With respect to the. topic of first-
~
V 15 respon' der procedures, let me'just clarify this.
Are-those b
j.
- 16 all the topics that you cover, or are:there others?-
L
- 17 A
Generally speaking, those are all the topics ~for j-18 recruits.
i 19 Q
Okay.
Are there different topics that are i
l" 20 covered for in-service training officers?
l 1.
21 A
The topics are generally the same.
However, if 22 we get two in-service personnel with supervisory positions VO:
L L
4 I-t e
r
--:,,--+-g..'
w
,m y.-py,.y-.,-. - -,, -, - -,
,,#n
,,,,,,.--,,-w,,_y,ym,,,,m,3.,,,,,,www.,-.
,.y..,.,y y-,-~ w,,,,,,,,
%,yn y-,.my,,,,,y
.,,,n,w,.-
18 A.,f I
the problems are more complex, the same topic.
2 0
Okay.
With respect to the topic of hazardous 3
materials,.first responder procedures to hazardous materials, 4
what -- if you were' going to describe for me what the training 5
program consisted of, how would you describe it, the first 6
responders to hazardous materials?
7 A
Okay.
We use a training device called the 8
critical incidents response board, and what this is is a scale 9
model miniature community.
And, we pick -- the whole class 10 views this device -- they stand around it, and particular 11 members of the class are assigned as active participants.
b) 12 The active participants are assigned a miniature 13 police vehicle with specific numeric designations.
And 14 they are then given information, the same type of informa-15 tion that they would be given by a police dispatchen and 16 told to respond to a certain intersection as indicated on the 17 critical incidents board, and they then position their vehicle.
18 develop a plan while they are responding and coordinate with 19 back-up units who are other participants in the class who 20 are also given miniature vehicles, and they respond to the 21 incident and deploy themselves as if it were a real-life 22 incident.
,r m j
19 4 wy_
V 1
Q When they respond to ' that, is their primary 2
function a patrol function, in= essence, to direct people
's around'this particular incident or awap from the incident?
4 A.
No.
5_
Q What would their primary,. function be in' the case':
6 of a critical incident'where hazardo'us materials were present?
7 What would you expect them to do in response?
8 A
Okay.
Well, first they have to'be very cognizant 9
of their environment, in that the incident that is commonly 10 depicted is a motor vehicle-accident involving an overturned 11 tanker.. And we expect them to recognize the fact that a
)
12 hazardous material may.be involved in'any motor vehicle is accident, especially~those involving larger transport vehicles.
14 Q
Other than recognizing that there might be 15 hazardous materials present at'the site of an accident with 16 an overturned tanker, what actions would you expect them to 17 take in responding'to that type of incident?
18 A
Okay.
If they suspect that it is an incident in-19 volving hazardous materials we expect them to take certain 20 actions in regard to their own safety, the safety of their 21 fellow officers and the safety of the general public, and also 22 to comply _with certain procedures.
O
20-What would those' actions be that you would expect
-1 Q
2
-them to take, _for example, to protect their own safety?-
3
'A Okay.
To advise the other units responding that' they have a suspected. incident invol'ving h'azardous materials,
~
4 to be cognizant of the' wind. direction aild whether:they are up-5
'6 hill or downhill from'this-incident, and to deploy their-7 back-up units with tnis particular --- these particular factors 8
in mind, also to request a' supervisor and to request'a
'9 response from the Emergency Services Unit of the Department.
10 Q
How would you expect them.to protect the safety 11 of the public in the event of this type of critical incident?
12 What would their. response be to.that?
13 A
Well,.one thing-that we have to make them-aware of 14 is that this is almost contrary to many of the things that 15 police officers have been traditionally taught, and that is 16 a -first responder, many police officers, move righti into the 17 scene without stopping to assess the danger that they might 18 be exposed _to.
19 Every year, probably on the average of two or three, 20 police officers are killed by hazardous materials simply be-21 cause they act more in the traditional form in that they.go 22 in to get the job done and do so with an exposure to their O
.;- j 7 5
I f
p 21-s fi--
M 4
'1' own safety, and theseitwo'or three.o'fficers'Lwind up~ succumb <
r-J 1,
2 Ling ~to the'same. hazards:of the-people they are trying to.res-i cue simply because'they 'didn't:use proper procedures and.they.
s
- 4
'weren't equi.pped.to go;in.'
J LLet's assuine' that th'ere are[two'! ways; of: protecting i
5
- Q I
6
-the public, one would:b'e the public tha't was actually involved
- a
~
t
...4-l 7
in -the ' incident itself but there might be public. in.the sur-f rounding -areas that inight bk 'affected by'[the incident, how-i 8
would the officers-go about -- or, howiwould you^ expect $ hem
~9 2
to goLabout(protecting the public!in.She surrounding area?
.10
, ell, they would-have to' assess certain~ factors 11 A
W h
12 such as' wind direction, uphill or: downhill,- the nature'of the.
4 t
i "
. 13 hazardous material itself.
And what they would'normally do-
~14 would be to refer to a document contained.in most police F
15 vehicles or_ gain access to the information?in it via radio.
16 And the document 'is the "IIazardous Material: Emergency Response f
l 17 Guidebook," which is prepared by the United States Department l
(
18 of Transportation.
!l' 19 0
In training your officers, your recruits, to 20 respond to critical incidents, what else do you use besides
[,
21 this critical incidents response program?
22 A
We also use video tapes and any other information O
.a._,
- -..._..... _,,.__ _ m._,.. _ n _.-
-.-___._.,._..-._,m,
,.g a
v -
- g.,
.F m: w;-
- a-s
-- 2 2.
M s',
+
oE V,'
?
.e s.
c ;,
'M y
[V y that?we have access to.viadother sources in t$he. Department.
.1
^2 Q-
. Do - youi conduct exercises :or drills 1with :your.
s
~s
-officerslatia" field-location;to practice _their response to 3
c a l c r i t i c a l*s i n c i d e n t.T s u c h a s.h a z a r d o,u s ' rt a t e r i a l ? '
.4 t
4 3 +y,,.., p -
7 q
- - g
.s ' '
'5
-'A',, JCould yoti clarifyjthat, please?.9
~
6L TQ~
- Do :you engage in a~ role playing l exercise-with thel
- o u - : ' >
-: officers.' to train them 'to respond lto critic'al. ' incidents at
~
8 field' location'snas opposedi'to;just:with the critical. exercise 3
t
,v n
9 board??
s a
'.10 -
A'
'With the-recruits?'
- k.. a l'1 :
Q Yes'.
y E ': U.:i 12 A
.No.
.,s
,,e
- Q
,Do you do.that with~ people who' are in.in-service' ' '
13
- i-l'.
training?
~
4 t,-
1-
~
Certainla'spects, yes;-
~
15
-A
+
J j
. 16 Q
What aspects are those?.
~
17 A
Well,-fof example, the Emergency ~ Services Unit'.is' i*
18 c o n s t a n t l y t r a i n i n g a n d,~ y e s,- t h'e y d o M : ole play-involving
~
19 hazardous materials.
i-20 Q
In field role?
in 21 A
Yes.
22 0.
But, for the majority of the recruits who are
~
7 v _-
- ( -. ~
= - -
3 s
~
23
[.
1 being~ trained,fyou would use video tapes and_ critical inci-2 dents -- the critical incidents reponse board to. train-them
~
-3 to respond to critical incidents :such _as hazardous materials?
- 4 A
Yes.
5.
.Q.
LOkay.
..I just.wante'd to'be.sure;Ifgot it clear.
6 What.~ texts or other> resources do you use to train recruits; 7:
-forJeriticalvincidents1 response??
8
-'A.
Well, J the materials that'.are 'codsained in their'
'9 notebooksthataresupplied.toithemlbytheBureau'for to:
Municipal Police.
11 O'
And'those materials are developed by.the Bureau 12 for. Municipal: Police?
-13 A-Uh-huh.-
14 Q
What-is that agency, the Bureau for Municipal-15 Police?
16 A
Well,'it's part of State government, and they are 17 responsible for setting the standards for police training 18 throughout the State, and also they develop training materials i:
119 that are disseminated throughout the State.
J: -
20 Q
Can you 6xplain to me what responsibilities you 21 had as Commaddins~dificer of In-Service Training?
l 22 A
Ckay.
Primarily I was responsible again for L-l-
s
[.-:
I,.'
24
'. I 1
~ assessing training needs geared to~in-service personnel, 2
the construction of curriculum for in-service training 3
personnel, the evaluation of the effectiveness of-that.
4 curricular.
And, also specifically I was training coordina-5 tor for the emergency services team of the Department and 6
the hostage ns'gotistion team.
7 Q
What did you do-as training coordinator for the 8
emergency services team?
9 A
I arranged and coordinated.the. training of all 10 their exercises when they would come to the Police Academy.
11 Q
Can you describe'for me what that entailed?
/m
's 3
12 A
Okay.
Well, it might be arranging role play,.for la example, in dealing with hazardous materials or arranging for 14 role play involving a sniper exercise or-hostage scene or 15 having use of the range for the specialized weapons.
16 Q
Did you detually participate with the emergency 17 services team in their training, or did you just make arrange-18 ments for the training to take place at the Academy?
19 A
I was not an active participant.
I was a partici-20 pant as far as an administrator was concerned.
I was to 21 monitor their training and to make sure that everything went 22 as planned.
/'N L.)
= -...
?
25
~
s p/
%.,) l
.1-
~Q
, When you say monitor their training, what dolyou
- 2 mean.by that?
Did you 'just make sure everyone : took all 3
the. appropriate classes and attended and completed the course?
4' Or, were-you=in the position of evaluating what 5
they were'doing?!
6 A
On ocdasion bdth.;,
7 0
When you evaluated the emergency services team in 8
the course of their't' raining, how did you)go about-doing'that?
9 A
Observation and by talking with the supervisors.
- 10 Q
Did you h' ave any criteria against which-you 11 evaluated the-emergency services team when you were' observing?
12 A-Well, my own knowledge and experience as a 13-police officer.
14 Q
Did you use any kind of --
15 A
And --
16 Q
I'm sorry.
Complete your~ answer.
17 A
And my training as well.
18 Q.
Did you use any kind of critique form or rating 19 form when you observed the emergency services team?
20 A
No.
21 Q-So, you relied solely on your training as a police 22 officer and your experience when you observed and rated those
, \\
m --
- ..,0
~
261 F.
';/^y 11
- people?
"2 A
-And the input from;theirlown ' supervisors.
3 Q'
)Did their.own; supervisors employ some kind of=
4 critique or-rating form?
5 AI Not:that'I'm aware of.
6 Q-
"So'they, too, relied on their. training and ex-s 1
..=
-7 perience in evaluating thefemergency services teamrinLtheir t
8 ability to performftheir services?
.g,
- ,~
9 A
I'm not ' aware of everything that they. used to 10 evaluate'theirJown personnel with,lso I!really'couldn't say.
~
~
~
11 Q-Okay.
But, when you evaluated them you relied on 12 lyour discussions with'the people who were training them-and 13 your own observations?
14 A-Yes.
15 0-Okay.
One-of the-other things that you indicated 16 that:you had-done in~ connection with your~ position as-
]
17
' Commanding Officer of In-Service Training was to evaluate the
[
I 18 effectiveness of the training program.
t i,
19 How did you go about doing that?-
t 20 A
Well, the first thing we did was perform a front-r
. 21 end analysis to detect training needs.
E'
(
22 Q
How did you do that?
i
t 27 7-
'f w;
1 lA' Okay.
This.was done by'the construction of a 2
questionnaire and a survey.-:The material that we..got'for 3
.the questionnaire was obtained from interviews of a broad 4
spectrum of~personneliat the Police Department.
5 Q
Whatfwere the~ kinds of questions that were asked-6 in.the questionnaire,11n'a general' sense?
~
7' A
Okay. 'In'a; general sense,Fthey w.ere~given specific.
- 8-topics and' asked'to-rate them in terms of importance of the 9
perceived trainingineed based on thei'r experience and also i
10 it was multi-level in that the' supervisors wereLbased to-
-t 11 perceive their own training needs and:the training needs of
.m k
12'
'the'ir superiors and'their subordinates.
13 The subordinates-being the patrol officers or'the 14 first line' investigators were asked to -- a perception of 15 their own training needs, their peers and their immediate 16 supervisors.
c17 Q
So, in fact, in conducting this front-end analysis
?-
- 18 you essentially asked the officers to self-evaluate what they l
19 needed in terms of draining, what their fellow officers need-i 20 ed in terms of training?
21 A
That's only part of it.
We also asked our people l
22 assigned to the Internal Affairs Division, because they were r
1 -,,,--
,4,,
~, -.., -,
.,p,..,,.-,
,,..,,,.,,,,..r_,
28 J
1 aware of the high liability incidents,.and training needs that 2
they may have detected in regard to these.
3 And, we also asked the District Attorney personnel, 4
because they would be aware of training needs that-may arise 5
out of police officers' testimony and legal actions.
6 Q
After you conducted the front-end analysis, what 7
else did you do to evaluate the effectiveness of training?
8 A
Okay.
We compiled the data gained from this 9
particular survey and then we constructed a curriculum based
\\
10 on this data.
11 Q
Did you attempt to evaluate the effectiveness of I'_ \\
\\' ' '
12 that curriculum?
13 A
Yes, we did.
14 Q
How did you go about doing that?.
15 A
Well, the first thing we did was to conduct a pre-16 test of the students that attended the in-service classes.
17 The pre-test showed us that the data that we had was extremely 18 accurate and that for the most part we had at least'a 50 19 percent failure rate of the pre-test dealing with the subject 20 matter that we had inserted into the curricular.
21 Q
And these were officers who were in the field and 22 had already been trained, in-service training; is that q
N.)
N
'29
~h.
(O,
1 correct?
2
'A Tha't's correct.
3 Q
And there wasta 50 percent failure rate on the pre-4 test?~
5 A
Yes.
6-Q The-pre-test tested areas-which, in the Academy's 7
opinion, the officers sho~uld:have been knowledgeable about 8
but wer'e noti 9
A Well, there'was a' training need there for those-10 subjects, yes.
Q And that1was the'-- the pur' pose of that in-service 11 12 training program was to, if you will, provide remedial train-13 ing on topics that you felt needed training, needed additional 14 training?
15 A
_Well, some was not strictly remedial, in that some 16 of it was new information also that they had not been exposed 17 to.
18 Q
So, Part of it was new information and part of it 19 was remedial training?
20 A
Yes.
21 Q
After you conducted the pre-test, what did you do?
22 A
Okay.
Then, they were exposed to their curriculum,
, ()
I
~
30 gy -
o l
.1-and at'the'end of the five days of.. training they:had to take 2
a final' examination.
. as-there a 100 percent pass' rate on the final W
3 Q
4 examination?
5 A
No, there was not.
6 0~
What was the_ percentage of the' pass rate on the 7
final examination?
8 A
I~ don't.have the exact figures.: ;It was extremely I
9
-high in the ' time that' I supervised the program.
I'm only to aware of a few officers that failed to. achieve a passing cnd T1' 11
- grade'on the final' exam.
U Was there anything else that you did to. evaluate 12 0-13 the in-servic'e Fr' dining program other than the front-end analysis questionnai're that you did, the pre-test'and the 14 15 test after the officers had completed ~the training?
16 A
At the end of each five day period, we have both 17 a written and an oral critique of the curriculum by the 18 students.
19 Q
Can you recall anything else that was done in 20 connection wfth"the"in-service training program to evaluate 21 the effectiveness of that program?
22 A
At courses for supervisors, we would specifically
.f s
e
31 q
v 1
ask in.the oral critique sessions if they_had noticed changes-
'2 in.the personnel that had attended -- the subordinate person -
nel that had attended -- the in-service training program..
3 4
Q' Changes in what' sense?
5 A
In'their job performance,'in'their knowledge.
~
6:
0 And, do you recall what the response was?
7
_A Generally speaking', they were always, positive.
8 Q
So that.they had noted positive changes,.that 9
there had been an' improvement-in~ performance?.
(
10 A
Yes.
3 cil Q
'Has'the Suffolk County Police Department ever 12 instituted'a disciplinary proceeding-against you?-
13 A
No.
14' Q
When you attended. the. Suffolk County Community 15 College, were you employed by the Suffolk County PD?
16 A
Ye's, I wds.
17 Q
What was your area-of concentration at the 18 Community College?
19 A
Criminal justice.
20 0
Okay.
Were all of the other students in your 21 criminal justice class members of the suffolk County Police 22 Force?
O
32 m
1 A
No.
2 Q
Was the majority Suffolk County police officers?
A I would say the majority were police officers.
Not 3
4 knowing everyone in the Department, I would only be' guessing.
5 It was a mix of civilian.and police officers.
6 Q
What did the criminal justice curriculum entail?
7 What topic areas did it cover generally?
Gener'lly speaking, it was kind of broad-based.
8 A
a 9
It dealt with certain aspects,of the law, both legal -- both to specific in general with police administration and management.
11 It also entailed other basic curriculums that are
(.
\\'
required by the college such as English, history, psychology, 12 13 sociology, science.
14 Q
So you took the, if you will, a basic core curri-15 culum required by the college for your A.A.
degree and then 16 with a concentration in criminal justice; is that correct?
17 A
Yes, that would be accurate.
18 Q
And the criminal justice aspects of that, that 19 was your concentration, primarily dealt with aspects of the 20 law, administration and management?
21 A
Yes.
22 MS. MONAGHAN:
Off the record for a minute.
(-
33 j
w 1
(Off-the-record.)
2 BY MS. MONAGHAN:
-(Continuing) 3 Q
After you completed your A.A.
degree at Suffolk 4
County Community College, did you then attend the New York 5
Institute of Technology?
6 A
Yes, I did.
7 Q
Did you go directly from Suffolk County to NIT?
8 A
I believe so.
It would be rough for me without 9
looking at the specific records somewhere, because I inter-10 rupted my academic activities for -- to study for promotional 11 exams and due to a'ssignments and things like that.
There
\\qi 12 were a lot of interruptions.
13 Q
You are welcome to refer to your resume at any 14 time, Lt. Streeter.
It's here for you to use.
If that 15 prompts your memory in any way, please do.look at it.
16 A
Okay.
17 0
What was the course work that you undertook at 18 the New York Institute of Technology?
19 A
Basically it was behavioral science.
20 0
And what do you mean by the term behavioral science?
21 A
Well, it was the examination of human behavior.
22 Q
Sociology, would that be a topic area that would O
34
~-
.s 1
be covered?.
2 A
Sociology and psychology.
-3 Q
How many years did you spend at the New York 4
Institute of Technology.in the behavioral science program?
5 A
-Approximately two years.
o Q
At.the end of that two years, did you complete a 7
Bachelor of Science in behavioral science?
8 A
Yes, I did.
9 Q
Okay.
Did you take any education courses in 10 connection with your studies at the New York LInstitute of 11 Technology?
O
\\
12 A
Well, it all depends on what you mean by education la courses.
Some of the courses dealt-with various aspects of 14 development, and we did touch on, you know, cognitive develop-15 ment.
16 Q
Okay.
When you say you touched on cognitive 17 development, can you expand for me a little more what you mean 18 by that?
19 A
Well, the stages of development that people 20 normally go through through infancy, adolescence and so on, 21 and how this relates to their behavior.
22 Q
After you completed your Bachelor of Science degree n
v
35 n,!
1 at the New York Institute of Technology, did you then go 2
directly to Stony Brook for your Master's work or did you 3
take some' time off?
4 A
Lst's ses.
I believe I took some time off.
I 5
also continued at New York Tech, and I took two graduate 6
courses there in behavioral science.
7 Q
What were the titles of -- the course descriptions 8
of those courses, if you recall?
9 A
I don't recall specifically.
10 Q
Do you recall at all what the subject matter was 11 generally?
('~h
\\l 12 A
Generally, they were' behavior, human behavior.
13 Q
Okay.
What course of study did you pursue at 14 Stony Brook?
15 A
Okay.
I pursued a graduate program in political 16 Science and it specifically dealt with what was called the 17 public affairs program.
It dealt with policy analysis.
18 Q
What do you mean by policy analysis?
19 A
Well, basically it was a broad-based view of 20 aspects of public policy.
For example, we would look at 21 legislation; we would look at the beginnings of the legisla-22 tion, what people had to say about this subject, before the o
N_
36 7,
I legislation was drafted, and then we would look at the 2
original drafts of the legislation and kind of follow it 3
through the political process, take a look at its final 4
construction and then see what impact it had on its implementa-5 tion and make comparisons throughout.
6 Q
Would your example of following the legislation 7
through its draft. stages and commentary on that legislation 8
through its final passage, if in fact it did pass, be indica-9 tive of the types of things that you did in connection with to your political science degree at S6ony Brook, or are there 11 other topic areas or examples which would highlight other
[D U
12 areas?
13 Or, was that the only thing that you studied 14 there?
15 A
Well, it was generally my main course of study but 16 we also looked at government programs, for example.
17 Q
IIaVe you taken any continuing education courses 18 or on-the-job vocational training?
19 A
Yes.
20 Q
Could you tell me what those are?
21 A
Well, I attended the Federal Bureau of Investiga-22 tion National Academy in 1985.
-s
/
37 no
- t 0
What did you study-there?
2 A
Okay.
There were five main areas of study.
One 3'
was education, one was' management, one was law, one was 4
human behavior, and one was forensic science.
Those were 5
all accredited courses, the education courses, the. graduate.
6 course, affiliated with the University of Virginia.
And I-
[
7 also took non-credit. courses at the F.B.I. Academy.
8 Q
Okay.
How long is that course of study at the g
F.B.I. Academy?
(
10 A
Eleven weeks.'
~
=
11 Q
In'the education' portion of that 11-week program, which I understand was a UVA!coursef'is:that correct?
12
.13 A
Yes.
14 0
What was-the course of study'for that, do you 15 recall?
16 A
Primarily it was dealing with' education from the 17 administrative perspective, in that you are an active 18 participant in the planning, implementation, development and 19 evaluation.
20 0
What did they discuss concerning evaluation, how 21 one should evaluate education programs?
22 A
Well, the various types of evaluation dealing with O
38
\\m/
t construction of survey materials, interviews, other sources 2
of information, looking at student-generated data.
3 0
Were there any particular texts that you used 4
that you recall?
5 A
We used a multitude of sources.
e 0
Have you had occasion to refer to those since you 7
took the F.B.I. program?
8 A
Yes.
9 0
But, you don't recall what they are?
10 A
There were a number of publications authored by 11 Robert Marger.
(3
\\/
0 Okay.
Other than the F.B.I. Academy, have you 12 13 taken other vocational training courses or continuing educa-14 tion courses?
15 A
I've taken the in-service training course itself to at the Police Academy.
I've taken a course in hostage negotia-17 tion which was conducted by Mr. Frank Boltz.
He is a retired 18 Captain from the New York City Police Department and has 19 lectured at the F.B.I. National Academy.
20 0
How do you spell Mr. Boltz's name, if you know?
21 A
I believe it's B-o-1-t-z.
22 0
Okay.
/~l u
I
39 q;
-1 A
And there was the normal routine training that 2
every member of the Department undergoes having to do with 3
certification for various time periods, annual firearms
-4 qualification, CPR, first aid.
And, I'm currently enrolled 5
taking a course as an emergency medical technician.
6 0
Is that EMT course being taken through the Suffolk 7
County Police Academy, or is that a separate --
8 A
No, it's on my own.
9 Q
Okay.
Are there'any other continuing education 10 courses that you have taken?
4 11 A
Not that I can recall.
(-)
\\>
12 0
All right.
Your resume on Page 3 lists a number 13 of professional activities.
Does that describe all of your 14 professional affiliations?
15 A
To the best of my knowledge, yes.
16 Q
llave you authored or co-authored any articles, f
17 books, papers or reports?
18 A
I have authored a segment in a manual for the 19 Bureau for Municipal Police dealing with a police supervision 20 course on evaluation of training.
21 MS. MONAGilAN:
I would like to request that we 22 be provided with a copy of that segment that Lt. Streeter has O
l
r 40.
_]
1 authored.
2 MR. MILLER:
We will take your request under 3
advisement, but I would assume that you will be provided that 4
report.
5 MS. MONAGHAN: Okay.
6 BY MS. MONAGHAN:
(Continuing) 7 Q
Are there any other articles, papers or books, 8
parts of books, that you have authored other than this segment 9
of the manual that deals with evaluation of training?
10 A
No.
11 0
Did you observe the FEMA exercise?
V 12 A
No.
13 Q
Did you undertake any activities in connection 14 with the FEMA exercise at the time it was conducted?
15 A
No.
16 0
Who engaged you to testify in this proceeding?
17 A
The Suffolk County Police Department.
18 Q
What are the terms of this engagement?
19 Is this part of your normal job as a member of the police 20 force?
Is this a special assignment?
21 A
Wdll, to me, it's just part of my job.
22 O
Are you being paid any additional monies in O
t/
i
-1 q
4
- /~8:
'b 1
. connection with.your testimony?
-1 2
A-No.
i 3
10 Are you e'xpecting to testify as'an expert witness-
~
1 4'
in this proceeding?-
5 A
Well, I believe so.
6-Q Okay.
What.is the subject matter on which-you 7
expect to. testify?
8 A
. Training, in general.
9 Q
Can you be anymore specific about what.you 10 expect your testimony to entail?
11 A
Well, to look at examples of behavior, of job LO V
performance, as relates tio the FEMA exercise, and to evaluate; 12 13 it in terms.of my knowledge, skills and experience.
14 0
What'is the substance of the' facts and opinions 15 to which you expect to testify in this proceeding?
16 A
Could you'be more specific?
17 Q
Sure.
As an expert witness in this proceeding, 18 do you expect to give certain opinions?
19 A
Yes', I expect to be asked my opinion.
20 0
Do you know at this time what opinions you have 21 about the FEMA exercise?
22 MR. MILLER:
Well, I object to the form of that O
"t 42-
'n f 1.
-question.
You-asked if he knows what opinion that he has.4 c
2
.I-think.you'should first establish ~whe~ther he.has'any opinions
=- 3 at this time.
4 BY'MS..MONAGHAN:
(Continuing).
F
~5 Q
Let me rephrase thefquestion,oLt.-Streeter.
Do 6
you have'any opinions about.the FEMA exercise at this time?-
7 A.
Yes.
8 0
What are'those opinions?
9 A
Well, based on the documentation that I've seen, 10 there seems to be'a lot of flaws and weaknesses in LILCO's 11 training.
O
. k )'
. hat documents-have,you: reviewed that leads you W
12 0
13 to that opinion?
14 A
Well, the primary document is the FEMA report.
15 Q
Are there any secondary documents that you have 16 reviewed that lead you to that opinion?
17 A
I would continue -- in my own opinion, I would rate 18 it as primary also, is an outline of LILCO's training which I 19 believe was generated by LILCO itself.
20 Q
Was that outline of LILCO's training part of the 21 emergency plan and procedures?
i 22 A
I believe so.
I'm not that familiar with the i
/~T V
i I
43
\\,,
1 correct terminology of the segments of the documents.
2 Q
Was the outline --
3 A
If' 96u could show it to me, I would be glad to 4
identify it.
5 Q
The outline of LILCO's training program that you 6
reviewed, do you know whether it was part of a approximately 7
five-volume set of binders?
s-A I don't know for sure.
9 Q
Does the term "OPIP" mean anything to you?
10 A
Well, it's one of the many acronyms and abbrevia-11 tions that I've run across in reading the documents.-
i' >
12 0
Do you know whether you reviewed any OPIPs or 13 procedures?
14 A
I think, but I'm not sure because, as I've said, there were so many documents, but I believe the training 15 16 outline was part of that program.
Again, if I saw it, I could 17 tell you for sure.
18 Q
So, you believe that you have reviewed some of 19 the OPIPs and that the outline of the training program was.
20 part of that?
21 A
Uh-huh.
22 Q
Other than the FEMA report and the outline of the
(~\\
Q 7'
44 E
1 LILCO training program, what other documents do you base 2
your opinion on?
3 A
Well, the contentions that I've read, I agree 4
with.
5 Q
Did you participate in the drafting of those 6
contentions in any fashion?
7 A
No.
8 Q
So, you have just reviewed the contentions; is 9
that correct?
10 A
Yes.
11 Q
Now, Lt. Streeter, you did not see any of the
/~T 12 events that occurred on the -- at the~ FEMA exercise; is 13 that correct?
14 A
No.
15 O
So that your --
16 A
It is correct.
17 0
Okay.
Your opinion is based solely on the docu-18 ments that you have reviewed; is that correct?
19 A
- yes, 20 0
And, the documents that you have reviewed are the 21 FEMA report, an outline of LILCO's training program, the 22 contentions that have been drafted by the Intervenors.
- Now, (3
l
45
~
t are there any other documents that you have reviewed that you 2
recall?
3 A
Well, there may be in the documentation that I was 4
given.
As I said, I'm not that familiar with it to be able 5
to specifically identify each individual piece of documenta-tion.
e 7
0 So that to the best of your knowledge, these are 8
the primary documents -- there are the documents that you have 9
reviewed; there may be a few others?
10 MR. MILLER:
That's not his testimony, Ms.
11 Monaghan.
IIis testimony is that he can't recall everything
[ )
.12 exactly.
'v' 13 What I object to is your statement at the end that 14 there may be a few others.
I don't think you have established 15 that there are only a few others.
But, you can ask the witness.
16 17 BY MS. !!ONAG!!AN:
(Continuing) 18 Q
Lt. Streeter, we have this morning tried to list 19 the documents that you have reviewed and on which you base 20 your opinion.
The documents that we have listed are the 21 FEMA report.
You told me that that was the primary document 22 on which you relied; is that a correct characterization of O
\\_/
46
/8 Q,l '
I what you have'said this-morning?
2 A
Yes.
3 Q
And that you also reviewed an outline of LILCO's 4
training program which you believe may have been part of 5
the procedures but you are not certain; is that correct?
6 A
Yes.
7 Q
And that you also reviewed the contentions that 8
were prepared by the Intervenors; is that correct?
9 A
Yes.
10 Q
And that there are some other -- there may be 11 other documents which you have reviewed; is that correct?
- f. O) 12 A
Yes.
13 Q
Now, the other documents that may be out there 14 which you may have reviewed, do you have any idea whether 15 they are few or many in number?
16 A
I would say a few.
17 0
Thdre are a few other documents?
And, you do not 18 recall what those documents were?
l 19 A
No, not really.
They all related to --
20 Q
Can you describe those other documents in any way I
l 21 oven if you can't give the titles?
22 A
one might have been a list of the contention by s_)
I l
t
r--
47
(/
1 I believe the Town of Southampton.
2 Q
Could you repeat that, please?
3 A
one might have been a contention wherein I 4
remember the Town of Southampton was involved.
5 0
All right.
Any other document that you recall e
that you could describe?
7 A
Not that I can recall.
8 0
All right.
Do you recall whether you reviewed any 9
documents that were generated by the LERO players during the 10 FEMA exercise?
11 A
Cobld you be more specific?
The actual documents O
themselves or something that might have been in the FEMA 12 13 report?
14 0
I understand that you reviewed the FEMA report --
15 A
Uh-huh.
la 0
-- and that the FEMA report may have made some 17 reference to documents.
What I want to know is whether you 18 yourself reviewed documents that would have been generated 19 by LERO players during the exercise?
20 For example, message forms that they may have 21 generated?
22 A
No.
O v
n,.
48 7'
'v' 1
Q Player logs that would have been' generated?
2 A
No.
3 Q
So, to your recollection, you did not review any 4
materials that were generated by LERO players during the 5
exercise; is that correct?
6 A
That's correct.
7 0
Have you reviewed any post-exercise training docu-8 ments that were authored by LILCO?
9 A
Well, I'm not sure of the date of -- authorizing to the document that I read that dealt with training which you 11 infer that may be part of the OPIP plan.
12 Q
So, other than the outline of LILCO's training 13 program, which we referred to earlier, you don't recall 14 the -- perhaps that might be a post-exercise training docu-15 ment, but you don't recall reviewing any other post-exercise 16 training docdment'?
s 17 A
Not as I recall.
18 0
Okay.
Post-exercise training documents, for 19 example, that might -- do you recall reviewing any post-20 exercise drill scenarios, for example?
21 A
Not that I recall.
22 Q
Do you recall over reviewing anything that might O
\\j
49
\\_
be characterized as a player log, no matter what' time it was 1
2 generated?
A No.
3
~
4 Q
Or message form?
A No.
5 Q
Did you speak with anyone, either in person or 6
by telephone, regarding the testimony that you expect to give 7
s in this proceeding?
9 A
Yes,'I did.
10 Q
And, who was that person?
A The two gentlemen that are present here.
11 O
\\l Q
Is that Mr. Miller and Mr. Sutko?
12 A
Yes, it is.
13 14 Q
Was anyone else present during those conversa-tions?
15 A
Inspector Peter Cosgrove.
16 17 Q
Anyone else?
18 A
No.
19 Q
Were there any notes taken during those discus-f 20 sions?
21 A
Not by myself, no.
(t ' R By anyone else that you recall?
22 b) x_/
50 l
1 A
Not that I recall, no.
2 Q
Were any memoranda prepared of those discussions?
3 A
Not that I'm aware of.
4 Q
Have you begun to draft the prefiled testimony 5
that will be filed in this proceeding yet?
6 A
No.
7 0
Okay.
Now, you stated that you have reviewed the 8
contentions t' hat have been submitted by the Intervenors in 9
this proceeding; is that correct?
10 A
Yes.
Q Which are the contentions are you to provide 11 12 testimony on?
13 A
Well, I'm not sure what I will be asked to' testify 14 specifically on.
The contentions I reviewed were 22, 42 15 and 45 and 50, 16 Q
So, you reviewed Contentions'22, 42, 45 and 50, but 17 you are uncertain as to which of.those'you will-be asked to 18 provide testimony on; is that correct?
19 A
Uh-huh.
20 R5 PORTER:
Could you say yes'or no, please?
21 THE WITNESS:
Yes, I'm sorry.
I 22
("'\\
\\_/'
51
\\
i:
1
- BY MS.'MONAGHAN:
- (Continuing) 2 Q
Do you know what draft of'the contentions you 3
reviewed?..Let-me explain to you that there have'been multiple 4
drafts of the contentions.
5-Do you know which of the drafts that you reviewed?
6 A
No.
7 0-okay.
Do you --
- 8 MR. MILLER
I will represent that,Lt. Streeter 8
has reviewed the Government's August 1, 1986 version o'f the 10 contentions.
11 liS. MONAGRAN:
All right.
Thank you, Mr. Miller.
b 12
- BY MS. MONAGIIAN:
(Continuing) 13 Q
Lt. Streeter, is-it'your opinion thatEthe 14 exercise scenario and activities and events which' occurred 15 during the ex*erciseare premised on certain assumpti~ns which o
16 conflict with establi'shed: facts,;uncontroverted evidence and.
17 ASLB fin'ings?
d 18 A
C6uld' yod clarify'that, please?' 'That's kind of --
18 Q
All right.
Let's break:it up:a little bit.
Is 20 it your opinion that the exercise scenarios and the activities
- 21 which occurred during the exercise conflict =with the findings 22 by the Licensing B6Ard in the plan proceeding?
O
52 1
A
.I'm not sure that I'm that familiar'with the find-2 ings of the Licensing Board.
I'm basing my. opinion on the r 3
exercise and what was indicated-in the~ FEMA report,'.or their -
4-observations.
5
- Q Lt. Streeter, is it your opinion:that exercise e'
players should not assume that members of the public'would 7
follow.the protective action recommendations made'by the.LERO-8 organization?
9 A
Well, I have an topinion based on that, but I don' t. - --
10
-I wouldn't base that~ opinion on being an expert in that 11' particular mdtter.
I looked at it in terms of LILCO's:
I ')
12 employees andithe training needs.that I would.certainly<be concerned about'if I:had bee'n' involved:in the' exercise.
13
-14 Q-I'm aflittle unclear about your answer.
Did you 15 say that you are not offering-an expert opinion-about whether-16 or not the publiclwould have : fdllowed ;the protective action 17 recommendations that would have been made by. the LERO organiza-18 tion?
19
'A Yeah.
I. don't feel I can raake an expert opinion
~-
20 based on that.
21 Q
Okay.
But, you do have an opinion about the 22 training program; is that right?
i p' o
l l
53 V
1 A
Uh-huh, yes, I do.
' 2 Q_
Okay.
Do you have an' opinion about the' training 3
program as it relates to whether' the' public would follow 4
' protective' action recommendations made by LERO?
5 A
Yes, I do.
6 Q
What is that opinion?
7 A
LILCO's training -- that LILCO's training based-on, 8
what was shown in the exercise was inadequate.
9 Q
Okay.
What facts do you rely on for your 10 opinion?
11 A
Well, they don't seem to have dealt with'a lot I_ i
/
s 12 of possibilities.
13 Q
For example, what possibilities didn't they deal 14 with?
15 A
Well, for example, if the public did not follow 16 their instructions how are they going to deal with it.
17 Q
What facts which ~ occurred during tlua exercise do 18 you rely on for the statement that you just made, that the
~
19 public might not follow -- that if they didn't make provisions, 20 what would have happened if the 'public didn' t follow LERO 21 recommendations?
22 A
Well, everything that I've read indicated to me
/~T U
s y
. 54 and'
$.)
1 that it was, assumed by LILCO that' people would do exactly'as 2-they.were. told and that there would not'be~'any type of panic
-3 reaction and people would sit ~at home'and calmly. wait'to be 4
told what to'do.
~
Is it your opinion'that people would not. sit at 5
- Q-6-
'home and calmly wait and be told what to'do?
7 A
That's-my opinion, yes'.-
8 0
What-do you base that opinion on?
9 A-Well, in emergency situations that I've' dealt to with and the public in1my 21 years as a police officer and L
11 my experiened.
O' 12 Q.
What kind of emergency situations were those?=
~
13 A
Well,'they range'anywhere from two people fighting 14 in a crowded bar'to firearms being fired in a crowded premise 15 to a burning-oil tanker at a major intersection during rush-l-
16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> to large motor vehicle ~ accidents during rush ho'ur on the Long Island Expressway and a-myriad of other types of inci-17 18 dents.
19 Q
With the example of the burning. oil tanker, did you find that the public flocked to the burning oil tanker 20 i
L 21 to view it?
I 22 A
There was some'of that, and there was also a panic r
O T
w e r t'
-nP-m-
e
9
-4 W -- r
- 'r**-
- *~=
--W-*&
s
?'----T
---ve - e m-mm-m*e-
4 55
(-.
.'v i
fleeing:of the~ area where"the fire was.
't 2
Q.
How do -- ~can you char'acterize for 'me what.you 3
mean - by the - term " panic ' fleeing?"
4 A
People leaving their businesses and dwellings,-
5
-leaving the doors open',<not being: concerned.about the~ security
.e of L the.. facility they were leaving, running,- yelling at ' each 7
- other, Let's,get'out of here,"'and things like:tha~t.
8 Q
Did'those members of the public r~eceive any-9 instruction from the'Suffolk County police officers who~were-
-10 at the scene?
11 A
Yes, they did.
. O'
\\~#
12
-Q-What'were those instructions?.
13 A
To seek safety, to calm down, that-the police were 14 there and that help was on the way and other. emergency ser -
15 vices.
16 Q
Was the ' public in the ' vicinity of that burning 17 oil tanker told to evacuate'their premises?
18 A
Yes, they were.
19 Q
And they did so at the instruction of the~-Suffolk 20 County Police Department?.
21 A
At the Police Department; yes.
22 Q
Have you conducted any research' studies or
.1 4
.r
' 56 -
r
\\_/
l' analyses.other than your personal experience'with the Suffolk 2
County Police Departmen't: th'at would -; lead.you sto' believe that- ~
3 the public.would not' follow LERO'.s protec'tiveactionxrecom' -
{
4 mendations?
~
5
.A-Have I conducted any studies in regard.tohthat, 6
no.
7 0
'Have'you done'any resea'rch ofrany kind' or any kind' 8
of analyses?~
,9 A
Not specifically.
10 Q
.What generally?
11 A
Well, I'm thi'nking in' terms of incidents 'I've:
?
12 re'ad involving disasters whereithe're'has; bee'n11arge panics; L
-13 10 What have you read regarding. disasters?-
14 A
' Newspaper accounts, magazines, things like that.
I 15
'O Have you. read any research' paper'sJthat deal with c
16 disaster?-
.17 A
No.
18 Q
Do you' rely on any discussions with other persons 19 for your' opinion thatFthe:publiclwould'not follow LERO's C
20 Protective action recommendations?
21 A
No.
22 MR. MILLER:
Can we go off the record for a second?
l c
1 -
o
~
s s
e 5
M W
.1 (Of f-the-record. )
~
x 2'
MS." MONAGHAN::
(Continuing)-
3 0-
. Lt.! Streeter,!I'm; going'to-show;youIthe" text of1 y
4
- 4'
' Contention 22x-- unfortunately I, don'tchave extra-copiestfort 5
everyone 'else-here.'.
Would you review-the' text'of thatfcontention and-c
_g
~ 7 :. itiell me.wh' ether ~ youfare. going to offer any testimony 'on that
~
-end~T2 8
isubpart 22.F? '
^
-(The witness'.is look ng'at the' document. )l.
.9 i
MS'.'MO'N'AdHAN:
For your information,IMr. Miller,.
^
10
'11 these-are-'thellatest revisions of the~Jconte'ntions'as9 supplied;
'O-by Suffolk Cdunty.
12 13
. MR. MILLER:- Just.to make'it. clear,.Lt.--Streeter,;
- 14~
- for' legal reasons this'is"a different version but'the'substanco 15' of this particular contention is'the~ same as;the?shbstance ofi 16 the contention previously supplied to you.
'17 THE WITNESS:
Okay.
18 (The withes's' is--'looking at.the document.)
. Continuing)
(
19 BY MS.~MONAGHAN:
20
.Q Lt'. Streeter,.have yonicompleted reading
~
21' Contention 22.F?
'22 A
Yes, I have.
H
58
[V g
1 Q.
Do you know whether you will be offering testimony.
2
.on this' contention?
3 A
I believe'I will befasked to.
I don't know for:
?
4 sure.
5 Q
Okay.
Do you have any opinion with' respect to the-6 substance of-that contention?
7 A
Yes,-I do..
8 Q
What is;that opinion?
9 A
That based on ths FEMA report and what LILCO has to to say about their training and ths exercise, I.dod'to believe 11 that the LILCO people were' trained to-deal with the'public.if r~.
. t it did not go as they had anticipated.
By'they, meaning 12 13 LILCO.
14 Q
Do you intend to offer any expert opinion on 15 whether or not it would be likely - that the' public would not.
16 follow LILCO's protective' action recommendations?
I 17 A
No, I don't believe^so.
p L
18 Q
Do you inte'nd'to offer an opinion 1about whether l
(
19 the training program trained LERO personnel to deal with 20 the public if the'public did not follow-LILCO's protective 21 action recommendations?
I' 22 A
- Yes, f
s 3
59 R9
- ='
(_)-
_.What would your opinion be on that topic?
1 Q
2 A
.That the training, apparently from what.I.can see, 3
was either. nonexistent or'cer'tainly inadequate.
4 Q-What' facts do you rely-on for th'atiopinion that 5
the training'was' nonexistent or inadequate?
~
6 A
Well, based on.what-I've read so far.I don't even see that is was dealt with.
7 8
Q What documents do you rely on'for your statement 9
that.you-don't even see tha't it was dealt with?.
10
..A None.of the~ documentation thatiI have read, as I have said before, : indicated-to me that: it was dealt with.
11 s
12 Q
And the documentation that you are-referring to-is the documentation that we've' discussed earlier in this 13 14 deposition; is that correct?
15 A
That's correct.
16 Q
Do you have any other opinions with respect to 17 Contention 22.F?
1 18 MR. MILLER:'
Let me just clarify.
That question would include any opinion'he'may'have, or are you looking for -
i?
19 OP nions he may offer at trial as an expert. witness?
i 20 21 MR. MONAGHAN:' I'm looking for-the opinion that 22 you are going to offer at trial as-an expert witness with
s K+
g
,y ' : : -,
_'J-s a fys,
f: Q.b 1:
. respect to Contention.22.F.;
2 THE WITNESS;'
No..
e
-3 BY MS. MONAGHAN:/.(Continuing)
~
~
~
~
14 Q:
Looking'at Contention'50,'Lt..'Streeter, do'you plan.to' offer.; testimony on Contention-50?
- 5
~6
.A-
-If-asked.to, yes.'
6.
-7 Q.
Do you,know whether,you'will be asked:to offer 8
. testimony on~ Contention'507 1
A I believe'so..
9l 10
.. Q.
Okay.
Please identify.for me'all events'that I
occurred duringfthe-exercise which<you would. classify /as 11 m:D.
.12 unanticipated and unrehearsed situations?
2 13 MR. MILLER:
Are you asking thelbieutenant to-Jdo 14 this from his memory?
15 MS.'MONAGHAN:
Yes.-
-16
.MR. MILLER:. To the_best of your memory, Lieutenant,:
17 you can answer. that qu.estion.
18 THE WITN$SS:
Can you repeat the question?
./
19 MS. MONAGHAN:
-(Continuing) s 20 Q
Yes.
Plea'se identify all' events that occurred
+
during the exercise which you wouldEclassify as unanticipated 21
~
.22 and unrehearsed situations?
t h
7.
= = -
_7 m
4
~
{
61
~;
1
,d1
~
.c c
<1=
fA ~
Okay.
I willLidentify:some.to the-best of my1 s
22
~ memory,~however,.it may not include?the'm all-because there}
~
.3
.;were so many.
4 The' motor vehicle' accidents,that wer'e:' injected into
~ ~
-5 the' scenarios'.thattwere-inadequately responded.to which was a
. indicated by the FEMA ~ reports,K th'e' " inability of. LILCO. person-- -
7 nel to effectively a'nd. properly communicateiwithin the'ir own-8 organization, people ' unfamiliar _ and.-unable to perform Lthe' -
9 functidns I tha't' the'y ' were ' delegated and assign'ed to, p'eople :
f
~
?
I'0' kind!of3: locked into certain modes ~ of' behavior and unable:to-aL
_11-
. deal with things that they were'not trainedcin.
~
y -
~
f
~ 12
-:Q Okay.
And these are, to,the~best~of your.recol--
13 lection,-all 6f the unanticipated and unrehearsed situation's'-
J
~
s 14 on'--
Well, with~ut referring.to the documents,.that's-15-A o
16 the best of.my recollection,.yes.-
c17 0
What documents would you refer.to in-order to re
-18 call more'specifically?'
19
.A The FEMA report.
'20 Q
Any othe~r' document?
- 21 A
That's all'.I need right now.
22 Q
Do you expect to review other documents prior to
- J%
15 2; fsg
~ M drafting'youri. testimony?
~
~
- 2 A
Yes.'-
3 Q'
Do you know what those' documents wou'ld bh?.
~
4 A
Well,ithe' outline of thelLILCO training.
~
15 Q
Anything. else?.
}
.6 A
E And the contentions that.we have discussed.
7 O
Anything else?.
8 A
I don't -- I'm not sure'specifically if there-9 may be a need to.
.If there's a need, certainly, if I'm
~
. to supplied with something.else.
~
~ 11 Q
But at the present time, you are notfaware of::any-other document which you might-wantitoireview prior.:.to draft-12 13 ing'your testimony;'is that correct?
14
' A That's c6rrect.'
is Q
Would you please identify fo'r me all events that i-occurred during.the exercise which you believe demonstrated-.
16 17 that LILCO's training program has been ineffective ~in. instruct--
~
18 ing its. personnel to follow and implement the~ plan and pro-L 19 cedures?
20 A
Okay.-
Do you want me to do thattfrom~ memory?
i 21 Q
Yes, unless you wish _to review some document'that
- 22 you have available to:you-that will.hel'p you refresh your LO.
i
^
/
63
(
.1 recollection.
2.
MR. MILLER:
Ms. Monaghan, I have to object here.
3 I've let.this go on.long enough.
~
4 tit seems to me that we 'should try to' expedite this 5
deposition when we'can.
.Your.last series of questions,fwhich.
.6 I ' do not object to, ' clearly went ' to ' the' ' statements made in 7
Con'tention 42.
You have'those contentions.- Why don't you
~
8 show them to the Lieutenant rather than asking.him to testify 9
from his memory?
10 Now, you are" clearly asking.on Contention ~45.
-Why
~
11 don't you show-the Lieutenant Contention'45Erather tha'n asking
~
p 12 him,to testify from his memory?
You can;ask him to lookiat la the. contention.and then state whether he' agrees'or. disagrees t
14 with the contention.
15 But, to test his memory.is--just not a fruitful use
-16 of the time here at this table.
It's your deposition, you do i
17 what you want to do.
I 18 MS. MONAGHAN:
Mr.-Miller,-I'm attempting.to I
l 19 ascertain what Lt. Streeter is basing his opinion on, whht I:
20 facts specifically he' is! basing his, opinion on.
l 21 If he would like to have access to contentions 42 22 and 45 to help him refresh his recollection, I'm delighted to O
l l
l'
[
64 N-]
1 let him have that.
2 MR. MILLER:
Well, then do that.
But you have 3
just instructed him to testify from his memory.
And we have i
4 spent 10 minutes having him do that.
I don't think that is 5
a useful way to spend the time here today.
6 MS. MONAGHAN:
Excuse me, Mr. Miller.-
7 BY MS. MONAGHAN:
(Continuing) 8 Q
Lt. Streeter, would you like to refer to Contentions 9
42 and 45 to help you refresh your recollection about the facts 10 on which you tely for your opinion?
t f
11 A
Yes, I would.
(
's N
'\\ >'
(The witness is provided with documents.)
{
12 13 MR. MILLER:
Let's go off the record for a second.
t i
14 (Of f-the-record. )
MT. 'ff0'NAdHAN:
Let the record reflect that Lt.
15 16 Streeter has been provided with a copy of the August 1, 1986 17 version of the contentions to help him refresh his recollectior.
18 with respects to the specific facts on which he relies for his 19 opinion.
20 (The witness is looking at'tMe documents.-)
21 BY MS. MONAGHAN:
(Continuing) 22 Q
Lt. Streeter, let's go back to some questions that r)
'v'
F 1
i s s
~
65 Y
e"y i
us! -
t' I know-I: asked you previously but you wer'e not provided with
.2 the assistance 'of the-contentions at 'the time.
3 Could youtlist.for'me the'cVents that'you:would l
4 clsssify as' unanticipated and unrehearsed situations?-' And, 5-
-for your. reference, that term.is used 16 Contention 50.'A..
6
- You havean extra copy of 5'0.A right here.
~
7 A.
Okay.
Which one would you prefer me'to'use?
.8 MR.'MONAGHAN:.Let the' record reflect that Lt.
9 Streeter has -in front of him the parts of ' Contention' 50 which l{
10 are part of the December 9, 1986 version that is-to reflect it the Board Ordet of' December 4 tha't was.provided-by.Suffolk; f'y
\\'
County to-the parties.
He'also has in front of him Contention 12 13 42, which:is part of. the August 1,1986 version of the' 14 contentions as submitted by the Intervenors to the' Licensing.
15 Board.
16 BY MS. MONAGIIAN:
(Continuing)~
17 Q
I'm asking you, Lieutenant,1 to refer to Contention is 42 to help you refresh your recollection with respect to the 19 facts on which you rely for the opinion, your opinion, that 20 there'are unanticipated and unrehearsed situations during 21 the exercise to which you believe LERO personnel may have 22 responded inappropriately.
What I would like for you to do O
y
.66 7~.3 V'
t.
for me right now'is'to list.those-events which'you would 2
classify as unanticipated and unrehearsed ' situations.-
Do you understand what I am asking you?
3 The te'm'that they[use'" road impedi-A.
Yes.-.Okay.
r 4-ment" which, to me, I would call'a' motor vehicle accident,'they 5
use the term also " free play" which~1eads me to.believe.or 6
7 to under~ stand'that they were not expecting this, that this was 8
thrust:upon them by'the FEMA people.
9 Okay.
Do.you want me.to just --
Q Just list for me --
10 A
-- talk about the~' incident?.
11 f
Q No..
Just list-for.me the events which you would
~
12 classify as unanticipated or unrehearsed situations.-
I want 33 g4 essentially a laundry list of-what you think they are, okay?
A Okay.
All right.
~The'= incident where.they were 15 requested to evacuate 40 children from the' Ridge ~ Elementary ^
16 17 School.
is.
Q.
Okay.
19 A
Okay.-
The. dealing wi:th simulated rumorLmessages.
~
l 20 Okay.
Can we continue?'
21 Q
Yes.
Goias quickly as you;like.
i 22 A
Okay.
The behavior of their traffic guides.
("3
\\./
l L
67
. \\,,)
1 Q
Which particular-behavior of the traffic guides, 2
Lt. Streeter?
3 A
Well, their response'to inquiries.
4 Q
What kind of inquiries?
5 A
People seeking directions.-
6 Q
Anything else?
Any other kinds of inquiries?
7 A
We'll, the behavior.in regards to their own knowledge 8
about their exposure to radiation; their inability to respond 9
to inquiries'in general from people that may have been 10 evacuating the area.
11 Okay.
The bus drivers' inability to carry out gs a
12 their assignments.
13 Q
How is that an unanticipated and unrehearsed 14 situation?
15 A
Well, in that they were expected to perform in a 16 certain way and they didn't.
I'm sure the people in LILCO 17 expected their buses to go where they were supposed to go 18 in a timely fashion and an effective fashion, and if they 19 don't that certainly impacts on the' entire exercise.
20 Q
Does the failure of a bus to timely arrive at a 21 location constitute, in your opinion, an unanticipated and 22 unrehearsed situation such as is referred to in Contention 50.A?
/~l u
68 jg._
Q),
1 A
Yes, it does. _The inability.'of certain_ personnel 2
to han'dle thdir assignmentsDin a timely fashion.-
3 Q
Any particular.per'sonnel?-
4 A
Traffic-guides,~Lfor example. ' Bus drivers.
The' 5
Per'sonnel' involved, dealing with 'the' ~ road ' impediments.-
6 Q
What ab'out the personnel dealing with the road 7
. impediments?
Are you referring to the manner in which they 8
dealt with them, the timeliness?
9 A
Well, their generally ineffectiveness.-
10 Q
An'd, you'would' classify tha~t'as an_ unanticipated 11 and unrehearsed situation, their ineffectiveness?
( ~.
12 A
Yes.-
I would certainly ho'pe that'their ineffective-13 ness would be unanticipated.
14 Q
Is there'anything else that you would classify'as 15 an unanticipated or unrehearsed situation?
16 A
Well, the ineffectiveness of the' people ~to deal-17 with rumors and the media.
18 Q
Are there any other' events or facts on which you 19 rely for the statement in Contention 50.A that the LERO 20 personnel were unable to deal with unanticipated and un-21 rehearsed situations?
'22 A
I'm not sure we are talking about the~ -- all the O(~s
t 69-k;,uvI 1
material ---
- 2
-Q-Let:me rephrase'the~ question.
'A-
-- that is'in ths' contention.
3
- 4 sQ Let me withdraw the' question and let me restat'e
'it.
5 s
.A Okay.-
7 Q
Are there any othe~r ev'ents on which.'you rely --
8' which you would classify as unanticipated or unrehe~arsed 9
situations?
10=
A-I remember rea' ding -- I'm not sure exactly where 11 now -- about.certain personnel were unable to useitheir (3-
/
equipment that'they'had to~ measure the' dose-of radiation 12 13 with, and there were othe'r personnel that were supposed to be 14 monitoring radiation drove into'the threat instead.of away, from it.
15 And I remember reading also somewhere'-- I'm not 16 17 sure it's in this -- that some people were not trained at-
- 18 all in regard to what to do with 'the indications that were on 19 their radiation monitoring equipment.-
20 Q
Is there anything else tha~t you would characterize 21 as unanticipated or unrehearsed situations, any other-event 22 or fact?
O
e- -,,,...
..g.
3,. Y(
^
~
~
~
....c 70-
,lr m U
. %):
-Not:that I'can recall'at._this time.
11 A
/
'Is cthere ~any document whi~ch you would wishto look 2
Q-Lat.to refresh'.your recollec' tion?
~
3 4
A' Okay..Nowi this conten' tion.we have'. looked.at,
/~would liketto'takeJ'a look~at 45 and 5'0.
.this --4 2.
I
~
-5 r-
.Q Plea ~se do'so.,
6 7
A Okay.
8 (The witness. is :looking at the documents. )
9 0
I think you will' find tha't Contention ~45-is more.
30
~ descriptive'~than Contention.50 of the~ events which 6ccurred..
at the' exercise.
11
- {"i,
A Wsl'1,'aga'in you would like~me~to supply you with 12 a' list?
13 14 Q.
Yes.
A Okay.
We have~the two road impediments.-
i.4 15-i.
Q Okay..
16 i.
~
'17 A
The late' notification of-the evacuation coordina-l_.
[.
18 tor.
19 Q
And you would characterize that.as an unanticipated or unrehearsed situation; is that correct?
20 21 A
Yes.
The other. people that were involved, I'm not I
22 sure to what degree eachJone contributed to their ineffectiveness,
- O r
k
....a. -. _ -.- ~,. ___.., _ _. _ _, n a,.... _ _., _ _ _, _.. _ _. _ -. _..,.,,,. _
F
- u m ', < s q>
7 n ' L ;4 L, "*
3-s r
~*
e+e 71 fR M:
F
~1f it was one.:individualEoriall? individuals' collectively, i
2 f but pthe. traf'fic control' coordinator,, the Jroad, logistics?
- coordinat!or, ;the~ transportation -' support -coordinator,ilead -
1-3
.v J
4 (traffich; guides,4the road crews,;ev'acuation route" spotters',(
ovacuation' support communicators,.I'm not'sure exactlI-how!
5 they interface with ~each' ~other,.where'i specifically K the -
6 7
' weaknesses are.
8 MR.JMILLER:
Can-we go off the record 'fori a' second?
c
~
9 MS. MONAGHAN:- Yes.
-(Off-the-record. )
to BYLMS. MONAGHAN:
'(Continuing) s.
11 12
- Q LtJ Streeter,Ilet's try-.to1 speed
- this--up.a little bit..
13.
14 A
Sure.'
.15 0
- Maybe we can save both
- of ours' elves a'little bit!
of time. -Contention 50.~A, which you~have a' copy of"in-front 16
- of you,--- uses the term ", unanticipated and unrehearsed situa-17 18 tions likely.to'arise in an emergency."
What'is your understanding of that term?'
19 20
.A
.My understanding of that term is an even~t that 21 could occur or be' injected into the exercise that was not 22 expected and also it's a breakdown or ineffectiveness somewherm h
if.,T%+ n. c :M g: (3
.i 4'
g
- 3. +
-.-.s s
n
~
-72 E
f
,~
+
s 11.inithe'exerciseithat may have been unexpe'cted.
A's.
So, L yourcinterpretation ; of-the Eterm ;"unanticipa'ted 1 Q-
-land rehearsed situations"--inclu'desJalltbrehkdownsithat occur-'
)
~
3
?
~
~
4
. red during.the;ex'ercise?f t
~
5 A
' Yes.-
. i 1
4 s-QL All' mistakes'that wer'e'made.during the' exercise?.
~
7
'A' 1Yes, and also the'inabilityIto remedyfthose 8
mistakes.
9 Q1 Okay.: - Limiting your list of unanticipated ahd
.unreh'e'arsed! situations only to-those' situations wheNe'therei ~
to was free play message-interjected or something1unant'icipated 11 occurred!'in the scenarioi notlaibfeakdown or a" mistake but an 12 Levent which. occurred which.you would not.have been expectingi.
la
' 14 can you list for me'thei events'on'which you rely'for your; OP nion?
~
i 15 A
The two road impediments.'
g
- 16 17 Q
Lt. Streeter, we have'previously been through 18
. Contention 42.
Youihave~reviewe.d that.and listed a' number.of-
~
h
^
. things in connection.with that contention.
~
19
'2 0 -
Is it a correct' characterization of your. testimony I
employing the definition of unanticipated and : unrehearsed 21 22 situations that limits it to events that were'not expected and
!O t.
73 does not include mistakes and breakdowns, would you characteri2 e I
all of the incidents that are listed in. Contention 42 as 2
unanticipated and unrehea'rsed situations?
3 If you would like to, you can review that.
4 Ofhe witness is looking at the document.)-
5 Q
I can review it for you briefly.
42, I believe, 6
7 and you can follow along.
8 A
Okay.
9 Q
The road impediments, do you agree that those are unanticipated?
10 A
Yes.
11
\\_/
Q The Ridge Elementary School?
12 A
Yes.
13 14 Q
Rumor control messages?
A Uh-huh.
I'm sorry, yes.-
15 Q
Okay.
Behavior of the traffic guides?
16 A
Yes.
17 18 O
The ability of the bus drivers to locate bus 19 yards and drive their routes?
A Yes.
20 21 Q
Okay.
The ability of players to respond to 22 escalating situations?
'J
u 74 I
1 A
Yes.
2 Q
The ' ability of persons at the ENC to respond to 3
media questions?
4 A
.Yes.-
5 0
Is there anything el'se'that you would characterize as an unanticipated and unrehearsed situation using the 6
7 definition'that we have been employing most.recently; that is, 8
unanticipated events and does not include breakdowns or g
mistakes in the term of unanticipated or unrehe'arsed situations A
I'm not sure'if I understand your question.
10
~
11 Q
Ar'e there any other events or facts which you believe constitute unanticipated'or:unrehe~arsed situations?
12 13 A
Other than what is in Contention 427 14 Q
Other than what you have just listed in Contention 42?
15 A
That are not listed in Contention 50?
16 17 Q
That are not listed in Contention 42, any unanti-18 cipated or unrehearsed situations which we have not just run 19 through in connection with Contention 42?
20 A
I'm not trying to give you a hard time.
I'm a 21 little confused.
22 Q
If you don't understand the question, let me
(^T
(.),
l t
s 75
)
t/
rephrase it.
1 2
A-Okay.
Q We have just gone'through a list of events in 3
connection with reviewing Contention 42.
Contention 42 4
summarizes a number of events.which~ occurred on the day of 5
- C 6
A Right.
7 8
Q And, you have characterized those as unanticipated g
and unrehearsed situations.'
Is that a correct characteriza-tion of your testimony?
10 A
Yes, it'is.
11
\\>
Q N w, are there any other events which you would 12 also characterize as unanticipated and unrehearsed situations 13 but do not include within the definition of the term "unanti-14 cipated and unrehearsed situations" any mistake or breakdown?
15 I'm looking for --
16 g7 A
Things that were just. inserted by PEMA?
18 Q
Inserted unexpected events.
19 A
I'm not quite sure.
I remember there was a communications problem, and I'm not sure if that was due to 20 21 an inserted event or as part of the normal exercise.
22 O
l.11 right.
Anything further?
V
ot
~ i!
- .iL 76 l
m r
u A
Noh.that I can recall at.this time.:
1
~
2 Q
Now,.if we' employed the'more expansive: definition
'of the' term " unanticipated and unrehe'a~rsed situations" which
^
3 you have'used, would there be~other events other than what.we.
4 have listed in Conten' tion 42 which you would. characterize as-5 unanticipated and unrehe~arsed situations?.
6 A
Yes.-
7
.g Q
What would those be?
A You will have'to bea'r with'me.
I don't'know g
exactly where to go.to start with.
to (The witness is looking through' documents.')
it OV A
In --
12 Q
Lt. Streeter, if you want.to just refer.to the' -
13 14 particular subsections of Contention 45 and use that as a shorthand reference, that would be fine with-me.
15 MR. MILLER:
Let me~try something.
Ms.-Monaghan, 16 17 the problem I think the Lieutenant is having.is that given his background as a trainer, given your question which is-any-18 breakdown would be included as an unanticipated event,-
19 essentially the Lieutenant would say that any deficiency 20 noted during the exercise'is unanticipated.
21 22 So, you are asking for quite a list.
If that's O
~
f s
'O
'. i.
s i
g
[*;
5+4 77 v
- U-
~
what you want himito do --
t a
MS.-MONAGHAN: "Let me'rephr'ase the-question.
2 BY MS. MONAGHAN:
'(Continuing )
s 3
4 O
_ :What would you rely on to.identifyfany deficiencies which' occurred.during the'ex~ercise?
5 A
I w uld rel~y on the' : rep' ort - that something was e
incorrectly'hindled or inadequately dealt.with'and-parti-7 8
cularly from my point of. View as a trainer..
9
()
Okhy.
When you refer to the report,~~are you refer-ring.to the FEMA post-exercise' assessment?-
~
10 A
Yes, I'am.
11
['T
~
4~/
O Okay.
Are you referring-to-any other.' document 12 when you use that' term?
13
.A Also the contentions.
~
14 Q
So, you are looking to the -FEMA post-exercise 15
. assessment and to what has been listed in the~ contentions to 16
'I identify the deficiencies on which you rely for your opinion; 17 18 is that right?'
gg A
That's. correct..
Q Okay.
Is 'it also true, Lt. Streeter, that to 20 2i identify events that you believe demonstrated that LILCO's 22 training program was ineffective'in instructing LILCO O
a:-
- x c
,k' A
78
,s M
x-i
)
i' i
2 m'i fpersonnelito follow;and implement,the-plan and procedures,-
i
~
.-you would also look to that;same. FEMA report-and th'e'1
~
~
2 contentions?-
3 A'1 That'.s; correct..
^4 5
(Q
'Would.youlook~to'any"othdr-) document?
- 6
- A Well,ftheir training outline.~
y-7
..Q
__0kay,.~which you' identified earlier as;you-bel'ieve
' was in'the plan and procedures of the-LI'LCO: plan?
8 9
A' Yes.-
1
- go O
- And, L those' would be,ths three ' documents that you would.1,ookLto'to determine'whethsrithe' LILCO program had been.
it n
"JV-12-
. effective in instructing its personnel to. follow'the' plan:
- 13 and. procedures?.
i-
- 14 A
.Yes.
5
[
- 15' O.
okay.
Would you.look:to any of the' training materials that LILCO program uses?-
- 16
'A Well, I would be interested.in looking.at them-17 but 'I believe the results ' of the behavior of the job 'per-18 19 formance of-the individuals involved can speakEfor themself.
('
20 Q
So, in order to ascertain that job. performance, i
21' what would you-look to?.
22 A
The observations by FEMA.
LO:
,,seg
-.e g.
v ewy-+,a p.-w-.
w.-4
.,..,-w r,,,-cy
,,,.,.-w-em-
,,----,----.m.e.
,,,--e, v
--e,-.--<--,-,
e-.., ~. +,. -.
,w-w..
-,-*-.--+-e-re--t
79 Q
That are contained'in the FEMA exercise?
1 A
In the FEMA exercise, yes.
2 cnd T3 Q
Io it your opinion that the LERO training program 3
has not effectively trained personnel to communicate neces-4
~
sary-and sufficient data and information?
3 A
Yes, it is.
-6 Q
What do you base that opinion on?
7 A
Well, based on failures to communicate in terms 8
of timeliness and effectiveness.
9 Q
Can you identify for me the specific incidents 10 on which you rely for that epinion?
11
~
/ 's
(./
Again, let me just try to shorten the process.
12 A
Okay.
13 Q
But, if you have something else to add please 14 supplemenc what I'm going to say.
Would you rely on any-15 thing other than the FEMA exercise report and the contentions 16 for the facts on which you are going to rely for your opinion 17 l
that they were unable to effectively communicate --
gg A
No.
19 Q
Just the FEMA exercise report and the contentions; 20 is that right?
21 A
And their training outline.
22
- 1. (Q
_/
n 1
80 1
Q-And their,traini,ng outline?-
2 A
Uh-huh.
3 MS. MONAGHAN:
Mr. Miller, may I ask~you to 4
identify for us the specific. training outline to which Lt.
5
-Streeter'was referring so th'at.we are all dealing with the 6
same set of information?
7 MR. MILLER:
If I could, I would.
The Lieutenant 8
has been sent the pertinent training materials'.from the LILCO.
9 plan ~and the LILCO OPIPs, the procedures.
And he is to obviously referring -to materials he'.saw in either the plan
~
11 or in the OPIPs or both.
(
12 But, I frankly -
'I could try to ascertain that.
13 if I'went back and reviewed his materials that he was sent.
14 But right now I can't do that.
15 MS. MONAGHAN:
So, you believe it's.either the 16 Plan or the OPIPs?
17 MR. MILLER:
I believe so.
The Lieutenant has been 18 sent some other materials,'but I believe that is what he is 19 referring to.
I think that's the case.
20 MS. MONAGHAN:
Would you endeavor to ascertain 21 with the Lieutenant after the fact of the deposition speci-22' fically what he's referring to when he refers to the LILCO (v~T
81
(.
A,
1 training outline?
2 MR. MILLER:
Yes, we-will do that.
3 MS. MONAGHAN:
Thank_you.
4 BY MS. MONAGHAN:
(Continuing) 5 0
Is it your' opinion that the training proaram has 6
not effectively trained LERO personnel to follow directions 7
given by superiors during an emergency?
8 A
Yes, it is.
9 Q
Okay.
What do you rely on for that' opinion?
10 A
Their performances indicated in the FEMA report.
11 0
Do you rely on anything else?
/x
)
(
12 A
No.
13 Q
Just the FEMA report; is that correct?
14 A
Uh-huh.
15 Q
Okay.
Are there any specific facts in the FEMA 16 report that you believe~ illustrates that they have not been 17 effectively trained to follow directions giver. by superiors 18 during an emergency?
19 A
Well, their response to the road impediments, 20 their inability to communicate within their own structure, 21 the inability of the individuals to effectively use the 22 equipment that they were issued.
V)
/'
82 x,
1 Q
Okay.
Do you rely on any discussions with other 2
Persons for the opinions thdt you'have given?
A No.
3 4
Q Is it your opinion that the LERO training program-
'has not effectively trained LERO_ personnel to exercise 5
independent judgment in dealing with situations presented 6
7 during an emergency?
8 A
Yes, it is.
9 Q
What do you base your opinion on?
A Their. inability to deal with the situations that 10 they were confronted with during the exercise.
11
('
Q What facts do you rely on for your opinion?
12 A
The observations as reported in the FEMA report.
13 14 Q
Anything else?
A No.
15 Q
So, there are no other documents or analyses 16 other than the FEMA report on which you rely?
17 A
No, I believe their behavior speaks for itself.
18 ig Q
Is it your opinion that the LILCO training program has not effectively trained LERO personnel to use common 20 sense in dealing with situations presented during an emergency 21 22 A
Yes, it is.
'^S
,/ ;
i f
I
7 s
83 w-1 Q
could you identify all the facts on which you 2
rely for your opinion?
3 A
The observations as indicated in the FEMA report.
4 Q
Anything else?~
5'
-A No.
6 Q
Just what's in the FEMA report; is that correct?
7 A.
Uh-huh.
8 O'
Is it your opinion that LILCO's training program 9
has not effectively trained LERO personnel to. exercise in-to dependent judgment in implementing the LILCO plan and 11 procedures?
(
')
12 A
Yes, it is.
13 Q
What do you rely on for that opinion?
14 A
The observations of their behavior ~in the FEMA 15 report.
16 Q
Do you rely on anything else for that opinion?
17 A
No.
18 Q
Lt. Streeter, you yourself did not observe the 19 FEMA-graded exercise, but did you discuss that exercise with 20 any of the Suffolk County Police Department officers who did 21 observe the exercise?
22 A
Just with Inspector Cosgrove.
l'h '
V
j. '
s.- f
~
~
~
V.;.
t O J c;
. p3 n g --
n E84-
'et l i.r
,e.
r
. yp ; -
. (
K
.T
?
-o,
_m/
1
!Q
- . What.was the?substancet.of?vouridiscussions with--
~ ~
~2-
.' Inspector Cosgrove?._
y
- i. ;
t o< c.
. MR'.: MILLER:
Before yo'uia,nswer that" question, 3
~~L -were those(discussions'where:.I:was'in attendanceJ.or Mr.
u 4
2 551 Sutko was in attendance?
- 6'-
THE' WITNESS:-
Yes.-
2 s
P ' MR.~ MILLER:
Then, you cannot answer-that-question..
8
- THE WITNESS:: Okay.
E
- 9 BY'MS.-MONAGHAN
- - < (Continuing)
-,f -
fio Q:
Was.canyone el'se other than Mr...Millerior'Mr.
~
~
~
_11
- Sutko present during.those' discussions!with Inspector c16
- j. "
12 Cosgrov.e?f 7
13 A
- No..
14 Q.
_Just.the'four of you?
+
15 A
-Yes.
-18 Q
Did you. discuss - -during your dis'cussions with h.
17 Inspector Cosgrove, did you discuss his observations that he f
"18 made~during the FEMA exercise?
I
~ '19
'A No.
. 20 Q
Have you at any time _ discussed with any of the I'
21 Suffolk County officers who observed the exercise their 22 observations of the exercise?
I;O; i-l-!r i
I.
'H F'um
.<--.se
%3-7 r-m
--e 9p-yy 9 m y-g* y-g og p g m. * -. g9-%
y ep g+
t. yg y u 7 e-egg ryy t pq m T-pre wy eg g -W q 9 e rge w ip g ge rst-r**prr py= y p= f g g--gigm w-f9-M -g zupe -ym p-1Wg'ayM up M- @ w--m M 1P g
w Ttf q 9
rw--
^
,}
p w., -
75
~
- c g
.,7,
.,3 85'<
~
.q N a
,,0,
< x '
j I
No r-
'1 1A c
'3 L w..
.t t
g m
r.
2
.Q-Is'your. knowledge =of-what(occurred:the day of-the-a;,s,.,-
13' -e'xercise based on the' FEMA 1.',exercisetrecort?
t
~.:.
.L 4 A
- Yes, it is.-
'5 Q
Is T it ' based.at all' on vour:: di'scussions. with--
-6 Inspe'ctor-Cosgrove?
7 AJ
- No..
8
.Q
-So,}your.-soleJsource of.information about whati occurred-.the dayf of the FEMA ehcercise fis.' the FEMA' exercise-9
~
10 report; is that correct?.
11
-A TYes,':it-is.1
^O
.12 Q-Is it your opinion that LILCO's? training program:
13 has not effectively trdined1LERO' personnel to exercise in--
14'.dependentijudgment in implementing.the, plan and procedures?'
15 A-Yes,'it is.
16 Q
What do you rely on for that opinion?.
{
17 A
Their reported behavior in the FEMA report.
(" -
18 Q
Anything else?
7 l
l
)
19 A
No.
i I:
20 Q
Is it-your opinion-that LILCO's training program l
21 has not effectively trained LERO personnel to use common i
l 22 sense in implementing the LILCO plan and procedures?-
O
, ;g:
- 3...
l
- ,-l
' r-
-86.
m.
jM b-
' ~ ~
~<
^
1:
..AU
-You ' have c asked, that.'
S f.i
.- i ;
,2
' Q..
'I-thinkwe";alreddhask'edthNt'.1 Strike 1that.
i 3'
LIscit-your? opinion that LI,LCO,fs. training program 4
hassnot-effectively trained its personnel =to-deal with?the-
'5 media?1 4
6 A
Yes..-
7 i Q What do'you, base your opinion on?.
8-
.A' On what was indicated in th'e FEMA repor.t.
9
-Q' Are'there any.other-facts'or documents on which 10.
you. base'.your. opinion other'tha'n; wha ~t is in the' FEMA repor't?
11 A
'No.
(
12 Q
shave you had any discussions with'anyone~on.which
'~
r l
- 13
' you' base that opinion?
s 4-4
' 14 A
No.
15 Q
J Is it your opinion. that LILCO's training program t
- has not effectively trained LERO personnel to: provide. timely, 16-17 accurate, consistent and non-conflicting.information'to the-P 18 public?
is t'
- 19
- A Yes, it is.
I.
20 Q
What do you base that opinion on?
3 21 A
Based on the' indicated behavior in the FEMA i
s 22 report.
!O i
v.- m
--o e w w azw,-
y--.se,a. - - -.
,,---e**3.-,,c.sw,,
v.~
m.
w..r,---
-,-o-ww
.-r
+-
es-,e---
- ry m -
-v. e-e
,+ '-- w re v - r y-e Tw ev -
y--,g.a
---v e n
- m an' g - r -w v m e w,w - w -- e v ewee n ---
e-e r s--
-t"w-'w-
v yy.,3
\\
L
~
3 87.
1
~
1 0
f,
..g
~,
w L)G
~
' ' ~ '
.'1 O
JArefthere'any other doouments on which you rely-s
? #
1' for-tliat' opinion? d
l' 4
2-3
' A No.
3
- (.:.
I 1
i ).1
.\\'
? I 4
-Q' Discussions with 'any'one.else. ~on. which -'you : rely
~
.Ui=
5 for th'at opinion?j-
^
6 Al No.
L
~
M 1
Q-Your opinion is based solely on.the, facts and.
8
. observations containedlin the FEMA report;1is-;.that correct?-
9 An That's correct.;
10
!Q Is it'your opinion;that LILCO has failed to 11.
provide. training'-to persons:and' organizations relied on:for-
' R
~V
'12
. implementation of this plan?
13
-A Yes, it is.
14 Q
What do you base tha t opinion on?
A Again, on information and observations.as indicated 15 16 in the-FEMA report.
17 Q
And, your opinion is based solely on the FEMA 18 report; is that correct?-
f, 19 A
That's correct.
'0 Q
Is it your opinion that the LERO training program 2
[^
21 is deficient in the area of dosimetry?
b 22 A
Do you mean trainirg in the use of that device?
! 'O f
b vsw=.-
sm.-
=w+r wr
.-, ---,c,,,,
,w--
,-w,-w,,-
-,--w-
,n---*-w
-ww.,y=t--,s-v,r---
..ww--n--w.-ww.,,ww.-,, -,,,,,
88
'g f LJ l-Q Yes.
1 A
If.tha~t,is-wha't you mean, the answer is yes.
2 n
3 Q.
Okay~
What dh Lyou' bas'e your ' opinion on?
~
-4
'A
- Again, the' -info'rmation: and. indications of the.
behavior via the FEMA report.
5 6
.Q Is.your opinion based solely on the facts and 7
opinions contained in. the FEMA report?
8 A
Yes, and the' facts indicated in the FEMA report.-
9 Yes.
~
10 Q
Is it your opinion tha~t LERO training is deficient in the' area of exposure control?
11
-v'
. ' 12 A
Yes,.it is.'
J 13 Q
What do you base your opinion on?
14 A.
The behavior.and information as indicated in the 15 FEMA report.
-16 Q
Do you base your opinion on anything else?
i 17 A
No.
18 Q
Do you agree with the assessments in the FEMA 19 report?
i' 20 A
To a certain degree, yes.
21 Q
What do you disagree with in the FEMA report?
22 MR. MILLElt:
Do you want to see the FEMA report?
O
\\i
(
I I'
[
~
89 J
v
^I
+
y.
' THE WITNESS:
I"think'I.can answer in; general.
~
1-
.2 terms.'
I think that certain.. things are' extremely important 3
from'the: training perspective that.perhaps:they:didn't attach 4
the same degree'of importance that I do.
j
. Continuing)
(
,5 BY MS. MONAGHAN:
6 Q
What thingsfdo you feel that you attach a. greater 7
degree'of_importance to than'was-attached by the FEMA report?
Training in, general.
8 A
9 Q
Can you be more' spec'ific tha~n that?
10 A
Just the overall. training.
it Q
Can you be more specific about what you disagree
,m-
=()
12 with in the FEMA report?.
~-
13 A
No.
It's just my. general feeling.
14 Q
Would you characterize the FEMA report as'a 15 comprehensive evaluation of the exercise?
16 MR. MILLER:
Please define what'you'mean by 17 comprehensive.
18 BY MS. MONAGIIAN:
(Continuing) 19 Q
Do you understand the question?
20 A
It depends on what you mean Inr comprehensive.
21 And if I wasn't there, I don't know if they omitted data.
22 0
To the best of your knowledge, did the FEMA report O
v
90 s
cover all of the laspects of the exercise _ that were demon-I
-2 strated?
._3 MR. MILLER:
I don't1 understand that question at 4
all.
5 BY MS. MONAGHAN:
(Continuing')
6 Q
Do you understand the' question,.Lt. Streeter?
7 A
I understand the question, and the answer is I 8
don't know because I wasn't there.
9 Q
Do you have any idea how FEMA went about evaluating 10 the performance of the LERO players?
11 A
As was indicated in the report, that's the degree
/~
\\'
12 of my understanding.
13 Q
Do you have any reason to disagree with their 14 methodology based on what you have read in the report?
15 A
No.
16 0
Would you modify the methodology in any way based 17 on what you have read in the report?
18 MR. MILLER:
Do you understand what the FEMA 19 methodology is, Lieutenant?
20 THE WITNESS:
It's my understanding that they had 21 observers at certain locations that made observations of 22 the performance and behavior of the personnel ~ involved in the
/~'T
(_/
91 N._ /
1 exercise..
t 2
BY MS. MONAGHAN:
(Continuing) 3 Q
And you feel that that is an appropriate way to 4
evaluate an exercise, by having observers at various locations 5
to observe'the performance.of the~ players; is that correct?
6 A
No.
I would qualify that in that I don't know how 7
long they olserved, I don't know the qualifications of the a
observers, I don't know the degree of freedom that they had 9
to~ observe and so on.
10 It's a method, and it can be used effectively.
11 Q
Do you agree or disagree with the overall conclu-(3 i
sions in the FEMA report?
12 13 MR. MILLER:
Are you talking about all of the 14~
conclusions in the FEMA report?
15 MS. MONAGHAN:
Yes.
16 THE WITNESS:
I only examined the report in terms 17 of the training perspective, and it's my opinion that the la training was overall inadequate.
19 BY MS. MONAGHAN:
(Continuing) 20 0
Do you disagree or agree with the conclusions that 21 PEMA reached with. respect to training in the FEMA report?
22 A
Well, I need to take a look at them.
rs
,_/
, ~
92 p( >
1 Q
Do you have an overall impression about wh'at :your 2
feeling was'about.theEconclusionsDthat FEMA reached about 3
training in.the FEMA report?
4 A
No.
I,wasn't. concerned withl agreeing or disagree-5 ing with anyone, only.on the: observations and conclusions and ns g.
-opinions-that I made myself based on what I read.
7 Q
Did you have any reasons to disagree'withJobserva-8
.tions made by the FEMA evaluators and contained in the FEMA 9
report?
10 MR. MILLER:
With respect to training?
11 MS. MONAGHAN:
With respect ~to training.
I
.rm k-)
believe that.is all Lt. Streeter is testifying about.
12 13 MR. MILLER:
That-is-.the case, but your questions 14 sometimes are broader.
That's why I wanted to clarify that.
15 MS. MONAGHAN:
Let.me clarify the question, then.
16 THE WITNESS:
Okay.
17 BY MS. MONAGHAN:
(Continuing).
18 0
With respect to -- let's take it very specifically.
19 With respect to the dosimetry, do you have any reason to dis-20 agree with the conclusions reached by FEMA in the FEMA report 21 about dosimetry training?
22 A
I'm not sure if I recall exactly what their O
I e
93 3e
- r%
~
n 1
~ conclusions were.
IJremember the observations,.the fact
.that the" people.werein6t t$ rained lodihow t6Lusetheidevices.
'2 3'
Q
-Do you-recall anything'else about what FEMA said1 l
,1.
.4 about. dosimetry?
0 5
A No,-I. don't" recall what thby'said about.;it.
~!
'6 0
What do you1' recall? '
7
<A.
.I1 recall that upon.rea~ ding it,.I thought [that this 8
seemed to be very. significantly important and iti could be
-9 life-threatening to.the individuals.who were involved'who.
10 were there.with good' intentions.of doing their job.
11 Q
Did'you form.any opinion based on.that?
O 12 A
Yes.
13 Q
What was that opinion?
' 14 A
Those' people should have-been' trained..
15 Q
So,:you.were concerned about'a lack'of training-16 rather than an inadequacy of the training; is thatla correct 17 characterization of what you just said?
18 A
Concerned with both.
19 Q
What facts do you rely on for an opinion that-20 the dosimetry training was inadequate?
21 MR. MILLER:
I want it noted for the record that 22 the Lieutenant is not being sho'wn the FEMA report and, O
J-94 j~>(
.\\,,/-
1 therefore, he is testifying from his memory.. With that; 2'
notation,-we may,goiforward.}';;
+
3 "THE WITNESS:
Its based;on'the' fact ~.that certain-4
- personnel were not '-t'rainedl and I. believe others were 'in-5 adequately trained on how to.use those devices'.-
1 : -
6-BY.MS. MONAGHAN: ' (Continuing) -
17 Q
Is it your opinion _that the exercise.: demonstrated 8
that the:LERO training program is deficient in the~ area of
~
9 providing an-understanding of radiation-terminology?.
10 A
I'm.not sure.
11 Q~
You don'.t know; is that correct?.
(')
\\
12 A
I don't.
13 Q
Is the question _ unclear,.Lt..Streeter?
14 A
Yes, it is.
15 Q
Is it your opinion that the LERO training program 16 is deficient in training personnel to understand radiation 17 terminology?
i 18 A
If that was one-of the factors in their inability 19 to use their equipment, then the answer has to be yes.
20 Q
What is your opinion based on?
21 A
Well, based on the inability of personnel to have i
22 been trained in the~ equipment, or to have the equipment, or
(
i i
i.
95
'J 1
to use the equipment, or to -- I remember one reading about 2
the one team of people that were supposed to take measurements 3
and they drove into the~ radiation L plume as opposed to driving 4
away from it or staying in a safe area.
5 If their understanding.of the terminology and the 6
principles dealing with radiation led to all those inade-7 quacies, then the answer. to the question has to be yes.
8 I'm not sure ex'actly what role unless I looked at 9
their specific lesson plans or their test devices or whatever 10 if there are, indeed, such materials.-
I would have to look 11 at those in order to completely answer your question without O'-
12 any qualification.
13 Q
Lt. Streeter, to your knowledge, might there be 14 circumstances under which it would be appropriate for 15 Personnel to drive into the radiation plume?
16 A
There might be, I suppose.
I'm not an expert on 17 radiation monitoring.
18 O
Do you know whether, under the circumstances of 19 the FEMA exercise, it was appropriate for those personnel 20 to drive into the radiation plume?
21 A
To the best of my recollection, that was indicated 22 as one of the inadequacies, that they were unaware of the r
~' '
96 J
1 danger involved to themself.
2 Q
Is your understanding that it was an inadequacy 3
based on FEMA's assessment contained in'the FEMA exercise 4
report?
5 A
Yes.
6 Q
Is it based on any other document?
7 A
No.
-8 Q
Or any other independent knowledge that you may 9
have?
10 A
No.
11 Q
Is it based on any discussions with anyone else?
(~h C/
A No.
12 13-Q Is it your opinion that LILCO's' proposals to 14 modify the training material or to modify the procedures 15 would not correct the flaws revealed by the exercise?
16 MR. MILLER:
What procedures are you referring 17 to?
18 BY MS. MONAGHAN:
(Continuing) 19 Q
Do you understand the question, Lt. Streeter?
20 A
Uh-huh.
21 Q
Would you answer the question, please?
22 A
Okay.
I'm not sure what you mean by modifications.
9(a
y*'.
~
p 97-
, _ ('T Af
- .1 1.'
.Q We discussed earlier in connection witih 'the 2
.Suffolk' County' Police Department training program'that-
- 3 comments'were made(about,theftraining. program andLafter that
-i, 3
'the training; materials ~wer~e somet'imeh' modified.to, reflect 4-
-5 the. comments-that were made'and thereby,to(try to improve 6
the'trai'ning program.'
~
^.
- . 4 7
A-
'Uh-huh.
(
8 Q
'After the FEMA exercise, LILCO ha's made' proposals 9
to modify its Uraining materialsJin order to correct'some 10 of.the problems'.that were noted during the: FEMA-graded 11-exercise.
^
O 12 In your opinion, can LILCO modify its materials.
13 to correct'the flaws revealed by the exercise?.
14 MR. MILLER:. I've,got to' object to that' question.
15 The form'of the question is outrageous, but if.you think you 16 can answer that question,: Lieutenant,,go ahead.
17 TIIE WITNESS:
Well, my answer would have:to be 18 no.
19 BY tis. MONAGHAN:
(Continuing) 20 Q
Can you elaborate on'that answer?
21 A
Well, looking at the training outlines I don't 22 see any of the other things that we have talked about as
.O
98.
(,)
1
'the components of a training system, front-end analysis,-
2
. pre-testing, testing after they were instructed, any type 3
of evaluation or indication of individual's performance of 4
the effectiveness of theiritraining.
5 Can you make something bad better?
Possibly.
6 Can you make it worse?
Possibly.
~
7 Q
Have you reviewed.the LILCO training materials?
8 A
I've reviewed an outline.
I didn't see any
~
9 indication of lesson plans or instructional objectives for 10 individual behavior or any data that was generated for testing 11 of the effectiveness of their training.
,o
)#
12 Q
Do you know whether or not LILCO tests its la personnel for the effectiveness of the training program?
14 A
No, I don't.
15 Q
Do you know whether they engage in any pre-testing 16 of personnel?
17 A
No, I don't know.
18 Q
Do you know whether there are any lesson plans 19 that exist as part of the LILCO training program?
20 A
No, I don't know.
21 Q
Do you know whether there are any other kinds of 22 instructional materials that exist as part of a LILCO training a
99 l
g 1
program?
2 A-No,. other than the're were things that were 3
mentioned in their outline.
4 Q
So, your< sole; source of information about the 5
contents of the LILCO training pbogram is the_ outline that 6
you have reviewed?-
7 A
Yes.
8 Q.
And based on' th'a't, you have formed the opinion 9
that you do not believe they: can modify the training program to to correct the flaws revealed in the' exercise?
11 Is that a correct cha'racterization of what you
^
\\ ')
12 have said?
13 A
Based on the information'I have, yes.-
14 Q
Would you want to look at any other information 15 before providing testimony in which you would state your 16 opinion that they could not modify their training program 17 to correct the flaws in the exercise?
18 A
Yes.
19 Q
What would that be?
What other materials would 20 you want to review or information which you wish to have?
21 A
Lessons plans, results of their testing, pre-22 testing and post-testing, and any -- their recommendations for r~
t\\v
g-h
^
^
J100
~
g
')_ K
- 1;
- remedial' training;.~and_also.the' testing,> posting and; pre,
.2
- on their-remedial' training 3
Q
.Is it"your opinion'that it would theoretically ~be
_4' possible for.LILCO to-modify its-training program.to corrects n
the flaws revealed 2intheTexercise?.
5 6
~A.
Anything-isspossible.h If"the'y-took the components fi
~
7 to make an effective trai~ning system, whichthey.~ don't have,.
8
'and inserted it-.11nto their: systeni it"may.be possible..
But,.
~
A 9
I woul'd have to look at it.
10
.Q And your understanding of the componentsLof.the
.s-
' 11_
'LILCO training program is based. solely.onlyour. review'of N
.12 the outline--'of.the training programs.is.that correct?
13 A
That's correct.-
14 Q
Have you had any discussions with anyone'concerning 15 the'LILCO training program?~
16 A~
No.
17 Q
I just have'a couple of wrap-up questions, Lt.
18 Streeter.
Did you bring any documents with you today?
19 A
No.
20 Q
Okay.
Did you meet with Mr. Miller or anyone else-21 in preparation for your deposition?
22 A
Yes.
O
p I:
101
):
_ ')
1 Q
Who did you meet with?
2 A
These two gentlemen.-
3 Q
Mr. Miller and Mr. Sutko?
4 A
Yes, and Inspector Cosgrove.
5 Q
Did they provide'you withany instructions about e
what to expect during your deposition?
I 7
A Well, in. general; terms they described to me what 8
it was going to be.
I was not familiar with this type of 9
procedure only having dealt with criminal matters primarily 10 before.
11 y
What did they say to you?
(3
(
12 MR. MILLER:
Objection.
You can't ask that ques-13 tion and he can't answer that question.
r 14 You can't ask him what we told him.
I object.
15 You can't answer the question, Lieutenant.
16 MS. MONAGHAN:
Are you instructing the witness 17 not to answer?
18 MR. MILLER:
I'm instructing the witness not to 19 answer a question which --
20 MS. MONAGIIAN:
On the grounds of attorney-client 21 privilego?
22 MR. MILLER:
Yes, on the grounds of attorney-client eQ I
C/
l
102 1
privilege.
2 BY MS. MONAGHAN:
(Continuing) 3 Q
Were you shown any documents during your discussion 4
with Mr. Miller?
5 A
No.
6 Q
Did anybody refer to or mention any documents 7
during that discussion?
8 A
I asked if I would have access --
9 MR. MILLER:
Excuse me.
Just answer the question, 10 because I'm going to object to the next question.
11 THE WITNESS:
Okay.
r~N 12 MR. MILLER:
The question is, were you shown any 13 documents by anybody?
14 THE NITNESS:
No.
15 MR. MILLER:
I'm sorry.
Was that your question, 16 Ms. Monaghan?
17 MS. MONAGHAN:
No.
The previous question was, were is you shown any documents and I believe your answer was no.
19 THE WITNESS:
No.
20 BY MS. MONAGHAN:
(Continuing) 21 0
My question was, were you -- did anyone refer to 22 or mention any documents during that discussion?
/G V
L..
f 103 1
1 MR. MILLER:
Well, I will object to this question, 2
then.
That's also privileged communication.
I instruct the witness not to answer.
3 4
MS. MONAGHAN:
Just so I'm sure I understand your 5
objection, Mr. Miller, you are' instructing the witness not to answer the question-on the-grounds of attorney-client a
7 privilege?
8 MR. MILLER:
An'd work product.
9 MS. MONAGHAN:
And, you are instructing him not to tell me whether or not anyone made any mention or referred to 10 11 documents during the discussion?
\\'
MR. MILLER:
That's right.
He's not going to 12 discuss the substance in any way of discussions we had with 13 14 him prior to this deposition.
He has told you that he had a meeting with us.
15 BY MS. MONAGHAN:
(Continuing) 16 17 Q
Did you have any telephone conversations with any-18 one in preparation for your deposition?
19 A
Other than scheduling, no.
20 Q
How many times did you meet with Mr. Miller prior 21 to this deposition?
22 A
Twice.
O k._
104 J
1 Q
On what occasions did you meet with Mr. Miller 2
in preparation for this dep~osition?
3 A
Last Wednesday and thi~s morning.
4 Q
okay.
When were you first notified that you were 5
going to testify in this proceeding?
6 A
I'm not familiar with :the. exact date.
I believe 7
it was the early part of last week.
8 Q
When were you.first shown the~ contentions?
9 A
Last Wednesday.
10 0
When were you first shown the FEMA exercise 11 report?
12 A
Last Wednesday.
13 0
Was last Wednesday the~ first time that you saw any 14 documents concerning the FEMA exercise?
15 A
Uh-huh, yes.
16 Q
Was your meeting with Mr. Miller last Wednesday 17 an all day meeting?
18 A
No.
10 Q
llow long did you meet with Mr. Miller?
20 A
Approximately two hours.
21 Q
llow long did you meet with Mr. Miller this morning?
22 A
Approximately an hour and a half.
m x,
r
? - ?
3 -:
s f ;f '-
e 3-
'~
105 m
v:
1
.Q
..Did-you meet with anyone'fother. than Mr.: Miller
~
-2 in preparation for-your; testimony today?
~
4
- 3
- A' Inspector.~Cosgrove-was at these-meetings.:
^4'
-Q.
- Were'there-any other me'etingsiwhich occurred to
~
-s
. Prepare you for your deposition ~.today?.
^
6 A
= No..
's '
m.
a.
l7 Q
Did. yo'u review.the' ' materials provided. to.you outside ofIthe. meetings that,you'had'with Mr. Miller'-last L
L 2
8 U
9
-: Wednesday - and thi's.mprning? '
if-$
.[
to A
'Yes.
~
11
'Q
-Heu much time'did you~ spend reviewing those
~ O 12 materials approximately?
13 A'
.I would say approximately six. hours.;
14 Q
Does.that'six hours include the two' hours you.
15 spent'with Mr._ Miller last Wednesday?-
16 A
No.
17 Q
That's six hours 'in addition to the' 'two hours la spent last Wednesday and the hour and a half this morning; 19 is that. correct?
20 A
That's correct.
21 MR. MILLER:
It was approximately two hours last 22 Wednesday.
For the record, I will state that it was at least 10
106
%_f 1
three hours.
2 MR. SUTKO:
And I'will state for the record it 3
was more like four.
4 MS. MONAGHAN:
Off,the record for a minute.
5 (Off-the-record. )
MS. MONAGHAN:
Back on the record.
I have no 6
i 7
further questions for Lt. Streeter.
8 MS. ZAHNLEUTER:
I~have no questions.
9 MR. MILLER:
We will take just;a short. break and to then we will have a few wrap-up questions, I think.
i (Whereupon, a recess'was baken at 11:52 %.m.,
11
(\\
k' to reconvene at 12:08 p.m.,
this same day.)
12 i'
13 MR. MILLER:
Let me represent [for the record, first 14 of all, that during the break Lt. Street r and I were able to verify that his references to the LILCO training outline is 15 essentially he is referring to Cha~pter.5 of the LILCO plan 16 17 and OPIP 5.1.1.
Those'are the' materials.
There could be additional materials, because he was 18 4
19 sent additional materials.
But, those are the primary docu-20 ments he was referring
~o.
c 21 MS. MONAGHAN:
Okay.
Thank you.
(/
)
22 v
i 107 k._
1 CROSS EXAMINATION 2
BY MR. MILLER:
indexx 3
Q Lieutenant, I have just a few questions.following 4-up from Ms. Monaghan.
Early on today, you talked about the 5
critical incidents response board.
6 Do.you recall tho'se~ questions from Ms. Monaghan?
7 A
Yes.
8 Q
And, is it -- let me 'just ask you', is it ' fair to 9
say that critical response is equivalent to-emergency response 10 in laymen's terms?
~
11 A
Yes.
/ ~1 A/
12 O
Ms. Monaghan has asked you some questions regarding 13 your meetings and discussions with var.ious persons in pre-14 paring for this deposition and in reaching the' conclusions 15 you have talked about today.
16 For purposes of clarification, do you recall meet-17 ing with Ms. Letsche of my law firm and myself during November?
18 A
Yes.
19 Q
And, why is-it-that you did not mention that meet-20 ing to Ms. Monaghan in response to her questions?
21 A
At that meeting, it was just --
22 O
I don't want you to talk about the substance of the
[h
.J
108 TxD
~
I;just want you to answer my question.
1 meeting.
-2 A'
Okay.
3 -
0 Why is_it you did not mention-that meetin.g to Ms.
~
.4 Monaghan. in response -to her question?
5 A
It was my opinion that theimeeting was very pre-6 liminary in nature.
7 Q
Was the meeting in November with Ms. Letsche to 8
Prepare you for your'de' position?
9 A
.No.
10 0
.Ms. Monaghan asked a series:of[ questions, Lieute-11 nant, about the conclusions that.you presently hold regarding
.s
-12 the LERO training program and the source of your-information
.13 for reaching those conclusions.
. 14 Do you recall all of those-questions?
15 A'
Uh-huh.
Yes, I do.
16 Q
I thi~nk that a number of times you told Ms.-
17 Monaghan that the sole ~ source of information regarding your 18 Present conclusions is the' FEMA report; is that correct?
19 A
That's correct.
20 0
Is, indeed, the sole source of information regard-21 ing the' conclusions of the. FEMA report?
22 A
We'll --
O
109 x_-i 1
Q Let me rephr'ase that.
You have had meetings with 2
Mr. Sutko and myself and Ms. Let' sche ~, correct?
3 A
That's correct..
4 Q
And, Inspector Cosgrove has participated in those 5
meetings, correct?
6 A
That's correct.
7 Q
And, you have reviewed the contentions.
You have 8
reviewed portions of..the LILCO' plan,.theLILCO implementing 9
procedures, other training materials in addition to the FEMA 10 report; is that correct?
11-A That's correct, p +.
12 O
Now, is it correct that that's the sole source of 13 information that you relied upon~in reaching your conclusion, 14 is the. FEMA report?
15 A
The sole sourch~of reaching a conclusion would be 16 no.
There were the other factors involved.
17 Q
Okay.
Could you explain that answer?
18 A
Okay.
What I did, I looked at the contentions, 19 I looked at the planning outline, and I used those kind ofcas 20
. guides and indexes in going into the FEMA report.
I then 21 would look at the observations of the behavior on the FEMA 22 report and base my opinion as to the behavior that was r~s
\\
110
?"r
'ij 1-indicated in1the FEMA repor.t.
=2 10
'TheLopinions thatLyou' expressed.to Ms.-Monaghan 3
today, those~are your. opinions:as~of today,;I. assume?
4 A
As of t!oday, as of the'information that'I have been exposed to'at th'is. point'in time.
5
.6 Q
Is it -your understanding. that you may be,' exposed
to' additional information.in the' future?.
7 8
A Yes, it is.
9 10 And, do you-have:any understanding.as to what that additional information'may consist of?:
.go 3
'A No,cI don't.
~
11 N ' -
12 Q
Is-it possible:that-you',mayTbefgiven someJof the documents referred to;by Ms. Monaghan,. documents generated 13 14 by LERO during.the exercise?
15-A It's possible, yes'.-
16 Q
And, have'you heard the term " player. logs" before?
17 A-
.Yes, I have..
18 O.
Have you heard.the term "LERO message forms" before?
19 A
Yes, I have.
20 0
Is it possible that you may be,given.some:of that 21 information by us?
l 22 A
Yes, it is possible.
LO l
111 JG 1
Q~
Is it,:therefore, possible that,the opinions you
~
~
have stated 'today may be- ' changed or.. be ' modified in some 2
. ay?
w 3
4 A
'Yes, they may change.
5 Q
' Do you have any reason to expect that theytwill 6
change based upon'your information and knowledge that you have 7
today?
8 A
Only that in that they may indicate greater needs' 9
for training.
i 10 Q
Greater needs for training by LERO?
11 A
By LERO.
12 Q
Do you recall ever having discussions.with InspectorCosgroveSboutthe'LERObrainingprogram?
~
13 14
- A Yes'. -
.15 Q
Do you recall generally the natureTof those discus-
'sions?'
16 17 A
Yes.
18 Q
Could you tell me what those discussions.were?
19 Let me ask, first of all,'were those discussions discussions
-20 where anyone from my law firm was present?
21 A
Yes.
22 Q
Then, forget my question.
You can't answer it.
l i
l' t.
i
.--,-..-e,.4,-.
-,,,y_
, _ ~,., _. _ -,. - -. - _
..,.-..,.-,_e
.m
..---r,
]
2
~
M, j
- .c3
^
t p
g
}
112 s,
..e
,,.,9,.'
4 1
l_(
~
11 -
y
.. (Laughter.)
- 2
' BY: MR.' MILLER:
(Continuing):
3-Q '.
.DidLyou have'any discussions with Inspector 4'
~
. Cosgrove with' members of.my law: firm :-not present? :
A No..
~
5 6
MR.-MILLER: LI have_no.further questions.' -1.et me 7
just state..for the record-.again~:---I'm just trying:.to clarify things for pe'plei horaren't'on'the'same' wavelength ~of under-8
~
o w
8 standing -- thatiLt. St'redter s recollection'is~a..little
~
faulty -as to when he 'wasi firsti senti.some' of.thes'e materials.
10
~
- u
.I can represent \\to: y~ou it,was prior.to last-y 11 T~ OL It's not important,- but~I-: state th'atDform the.
^
12 Wednesday.
~
]
N '4 13
'r'ecord.
N " ' '
14 MS.'MONAGHAN:..~I have a.few clarifying questions.-
~
Mr) Miller, do you rec'all when' Lt. Streeter,,wasi se'ntithose
'indexx-15 16 materials-and/or does Mr. Sutko?=
17 MR. SUTKO:
No.
MR. MILLER:
No, we don';t recall but wefknowiit,was 18 i"
19 prior to last. Wednesday.
It was prior.to last Wednesday.
i; L
20 That's what I was just discussing with'Mr. Sutko.
21-MS. MONAGHAN:
Was :it substantially prior to last 22 Wednesday or --
[O R
6 i
- sr
,,,-=,-m,
.c. -,.,,
,,,w..
p
- y.,_.,..,-,_,__,mem.w,w.p..%.,,,_97.-
.,,.,.._.,._,,,,wy7.
m.,,w
- y.,..,-4
_,w
,_.,,,,.-.y,.
,...m.,.
113
'Y
,h
.('
1-1 MR. MILLER:
We'can.look and get back to you 2
with a date.
3 MS.'MONAGHAN; All right.
4.
MR. MILLER:
We'will have a correspondence-on all 5
.of this.
.c 6
MS. MONAGHAN:
Okay..
I' appreciate it if you
~
7 would get back to'me with that.
indexx 8
REDIRECT EXAMINATION' 9
BY(MS.;MONAGHAN:.
10 Q
- Lt'. Street'er',: you stated earlier that youblearned' t
11 that_you'would be'a witness early last-; week.
Is that O
12 correct, or has your recollectionIbeen refreshed since your 13 prior statement?
s 14 A
No.
I learned I was be'ing~ considered to be a 15 witness earlier on.
16 Q
Mr. Miller referred to a meeting.that.was held 17 between you, he and Ms. Letsche in November.
Is that-the 18 time at.which'you learned that you were being considered to-19 be a witness?
20 A
Yes.
21 Q
When was it confirmed that you would, in fact, be 22 end T4 a witness in-thi's procee~ ding?
~
~
,,7
114
- ~j-
- 1--
A To my knowledge, it was absolutely confirmediat
~
2 the mee' ting we had last' Wednes' day. 1: was not told specifi-3 cally-whatcrole~I would play before.then'other.than in terms 4
of Possibilities.
A lot'of it had to do with my own work' schedule and 5
6 availability.
~
-7
.Q Did you begin -- when did you begin to prepare to 8
be a witness?
9 A
After the meeting on Wednesday.
10 Q
Now, atJthepresent,timejyou have' reviewed, in 11 Preparation for your deposition, the' contentions,-.the OPIPs, and plan which is[the';LEROjtraining outline.that we have-
~
12 13 referred to previously;and confirmed that that's-probably what 14 it was, and.the FEMA' report.
4 15 A
Uh-huh.
16 Q
And, I think you characterized earlier a few other 17 training documents.. Is that a correct-characterization of 18
-what you said?
19 Please correct me'in any respect that --
20 A
I -- other documents, I don't --
21 Q
-- my characterization is not true.
22 A
-- know if it's just limited to training documents.
O' y
4 L
-,-s.-y,r, n-e r
r---s
t-
<115
&;V.-
1 Q
All right.
And you have. based.your opinion on 2
those' documents?
3 A
Uhihuh.
Yes.-
4 Q.
You have indicated.tha~t you may-review additional-
~
5 documents; is that correc't?
-6 A
.Yes, that's correct.'
7 Q.
Will it[beLyour idea about what additional docu-8 ments you will review?
9 A
Some may be and some not.
10 0
Is-it yourLunder's'tanding tha't;you will.have'~ access
~
.11 to any documents'that you would like-to review?
)
But,. I have - been 12 A
-I don'ttknow about.any. document.
13 told I will have' access to documents.
I don't know if-I have:
'a' clear understanding of how;your processIis. going-to operate 14
-15 if we have free access.to everything.
16 Q
Is it your under' standing that you will be-'provided-
-17 with documents by the' attorneys-for Suffolk County to review?
18 A
Yes.
19 MR. MILLER:
But, as you know, Ms. Monaghan, 20 LILCO is not providing Suffolk County or.any of.the[ govern-21 ments~some of the. training documents that we have requested 22 in discovery.
So, with res~pect'to your question about access O..
e 116
_ q)..
I to documents,' if we ' don' t have. them we can!t. give : them to 2
the-Lieutenant..
3 MS.'MONAGHAN:
A s you know, Mr.. Miller, the Board 14 ha's determined'that the' pre-exercise ~ training documents are-5 not. relevant to this procee~ ding.
6
'And you are' correct, we have not-provided those 7
non-relevant documents to you.
8 MR. MILLER:.
I wasn't' aware that the Board had 9
decided that.
10 MS._MONAGHAN:., I believe the:Orderithat came out
-11 on Friday indicates;tha~tfspecifically.--
~
g 12 MR. MILLER:
With res'pectto the' training documents
~
13 MS.- MONAGHAN:
.Yes.'
14 MR. MILLER:
We-may.be -- -
15 MS.'MONAGHAN:- Off the' record for a minute.
. Off-the'-record.1
(
16
- 17 BY MS. MONAGHAN:
(Continuing)-
18 Q
Lt..Streeter,.in my_ prior questions.I was asking 19 you whether it was your understanding that you~would have 20 total access to the documents in the possession of the-'
attorneys for.Suffolk County concerningfthe LERO' training 21 22 program, and that you would be'able to select from those O
(.
r i
,r--
4 a_,,
w,____m,
f
'E 117
. f s-(_)
1 documents what.you wish to-. review?
t
'2 A-Well, it-was not'that' clear.to me, no,-that I 3
would have' access to everything.1.As I-understand, you are 4
involved' tin litigating this matter.
~ 5
'Q Lt..'Streeter, LILCO ha's provided.to:the attorneys 6-for Suffolk County documents relating'to the: training program 7
that"they have' requested in the conrse of what we term' dis -
8 covery.
9:
Is it your understanding that you will have access I
10 to those documents?
11
-A Yes.'
. p.,
V 12-
'Q-Is '-it your understan' ding that you will choose' what-additional documents you'wishCto.re' view in(order-to prepare 13 14 your testimon~y?
15 A
Yes. -.
16'
'Q, You have indicated that you had some discussions l '
with Inspector.Cosgrove concerning the EIna exercise; ~ is.
17 18 that' correct?
l 19 A'
Yes.
- 20 Q
Did you talk during those discussions about what
' 21 Inspector Cosgrove saw?
22 MR. MILLER:
Again, was any member-from my law h
a l
I t.-
W d
-118 1(j; -
1 firm present at these~ discussions?'
2 THE WITNESS: ' Ye,s.
3
- MR.EMILLER:
Then~,.you'cannot answer the' question.
4 MS.-MONAGHAN:
I.'am not inquiring'into thesub-si stance'of hi~s conver'sations with hi's attorneys.
'I'm only
~
6 -
asking him whether he~ discussed with Inspector Cosgrove what 7-Inspector Cosgrove saw.
8 It's.a very limited inquiry, Michael,Eand.I don't-9 think'it's covered by attorney-client work product.
~
10 MR.. MILLER:
Go ahead and. answer'the question.
. 11 THE WITNESS:. Canlyou P
MS. MONAGHAN:
I wiS1 b'e: glad'to repeat the
" b '
12.
13 question.
14 BY MS. MONAGHAN:
(Continuing)
During your;dihcus'io'n's.with Inspector Cosgrove, 15 Q.
s 16 did you discuss with him what his observations.were during 17 the FEMA exercise?
18
.A Yes.
'+
19 Q
Do you recall what he told you about what he saw 20 during the FEMA. exercise?
21 A
Only in generalEterms.
22 O
Can you tel'1 me'what you recall about what he told O
+..
- y_
3:
E 4
w I.4 -
s-r.
119 '
r
+. >
,- 1 C (l(~y
- u-1l
- you.about --
[2' A'
Ye s. '.
~
31 0.
'-- what'he,'saw duringL.the FEMA exercise?
~
~ I'm-4 MR.: MILLER:.iJes' sine, I'm going'to obj'ect.e bothered'.by the' fact that I.wasipre's'entsat'tho'se.' meetings:
3 5
6 whenithese~ discussions' occurred..'I1 don't want any claim:that.
7 we Lha've; waived o some privileg'e.-
~
Inspector Cosgrove 'is(the1.next: witnes's - that.'is a
f
.. 8 9
. g o i n g t o -; b'e ; h h r e. ! Iou are 'more 'tha'n free to :ask ~ Inspectorg
- 10 ~
Cosgrove:what he~saw.during.the exercise, independent of his:
11 ~-
discussions with.the ~ Lieutenant or with me. or with!Mr. - Sutko.:
4
,. n But I don 't.:want' to proceedIhere,kgiveri the. fact 12 a
5 tha't-we were 'present at'.tho'se discusisions,-' an'd I'mJsure dthe -
13..
_ 14 discussions involvtid myself, Mr. Sutko,: Inspector Cosgrove
.~
It's:a' murky: issue, and we'are'^not going-
.and Lt. Streeter.3 3
15.
8:
a E
16 to get into 'iti. _
< MS..MONAGHAN:
Areyou instructing the' witne'ss not 18 to answer?
19 MR. MILLER:
I'm instructing the-witness not to 20
~ answer ~especially;given the' fact that Inspector-Cosgrove is-21 the next witness.that you'are, going to' dispose today.
- 22 If you want to talk to him about what he' saw on 1
s
..3,
120:
.:fh
.k 1-the day of.thel exercise, you can,get it through Insp'ector-2
_Cosgrove.
3 BY MS. MONAGHAN:
(Continuing)
-4 0
-Lt.;Streeter, are any of the~ opinions.you have 5
had today. based onyour discussions with Inspector.Cosgrove?..
6
- A-No.
7 1MS. MONAGHAN:- I ha've-'no further questions.-
8 MR. ZAHNLEUTER:
No questions.
9 MR. MILLER:
I have~no questions.
10 MS. MONAGHAN:.Thank'you very much','Lt. Streeter.
11' AND FURTHER THE. DEPONENT SAITH NOT.
12 (Whereupon, ' the' ~taking of the' dep'osition' _was 13 concluded at 12:25 p.m., Tuesd'ay,.' December 16, 1986.)
14 15 16
<17 18 OH 1 'W.
STREETER, JRK 19 Subscribed and swam to before me thisOday of -
I - 19O
'20-
, b ALLAN R. STERNBERG Notary bublic 22 NOTARY PUBLIC, State of New Yott f~
No. 52-4626197 Qualised in Sutioth County My Commission Expires _
. O)
\\
Comme,aan Expires Wrch aik
_________m___-_
121 CERTIFICATE OF NOTARY PUBLIC & REPORTER hd/72 M,
the officer before whom I,
the foregoing deposition was taken, do hereby certify that the witness whose testimony appears in the foregoing deposition was duly sworn by me; that the testimony of said witness was taken in shorthand and thereafter reduced to typewriting by me or under my direction; that said deposition is a true record of the testimony given by said witness; that I am neither counsel
- for, related to, nor employed by any of the parties to the action in which this I
deposition was taken;
- and, further, that I am not O
e re1aeive or emg1ovee or any attorner or coun e1 financialiy employed by the parties ' hereto, nor or otherwise interested in the outcome of this action.
Notary Public in and for the Commonwealth of Virginia My Commission Expires [/g
~
O
$WS b
RESUME i-e.
7
('
John W.
Streeter Jr.
l(~)
Lieutenant
\\/
Command $124 3
Suffolk County Police Department EXPERIENCE 1986 - Present:
Suffolk County Police Department 1986 Present:
Executive Officer of Police Academy (Lieutenant)
Direct the research, development, production, administration and evaluation of instructional television programs for county, federal, state and local law enforcement agencies within the county.
Oversee and direct entry level (re-cruit) training for county, state and local en-forcement agencies within the county.
Primary instructor for police response to critical in-cidents for recruit, in-service and supervisors; training needs assessment, and evaluation of training for new instructors:
Instructor-evalu-ator and critical incidents response instructor-for Bureau for Municipal Police.
Meritorious Award for development of critical incidents response instruction methodology.
1986:
Commanding Officer In-Service Training (Lieutenant) 1984 Direct the research, development, administration, and evaluation of in-service training for county, federal, s ta te and local law enforcement agencies.
Primary instructor for critical incidents response, training needs assessment, evaluation of training, training coordinator for hostage negotiations and emergency service units.
Instructor - evaluator for Bureau for Municipal Police.
Curriculum development, administrator and l
evaluation of Career Development Course lor in-service patrol. personnel.
Curricu' lum development, administration and evaluation of Career Development Course for in-service investigative personnel, Outstanding Achievement Award for 198S by j
the Federal Bureau of Inves tiga tion Na tional Academy Association of Nassau and Suffolk Counties.
Bureau for Municipal Police (N.Y.S.) commit-cee member - developed new curriculum and O.
standards for state mandated Police Super-vision Course.
l n
F h
o' 2-
.'e,
Bureau for Municipal Police (N. Y.S. ) com-mittee member - for development of mandated in-service training standards.
1978 - 1984: - Commanding Officer Decentralized Individualized In-Service. Training (Sergeant)
Developed, administered and evaluated training needs analysis and evaluation instruments.
Administered and evaluated instructional television programs for county, federal, s tate and local law enforcement agencies within the county.
Indepth evaluation and analysis of the use of ins t ruc tion a.'
television on a ttitude, know-ledge and recention.
1978:
Patrol Supervision (Sergeant) 1977 Generalist police service first line supervisor for police officers at precinct level.
1977.
Police Officer 1968 Police service generalist with specialization in Vehicle and Traffic Law enforcement and rescue
- work, f3 Professionalization Award Mul tiple Depa rtmen t commendations 1965 - 1968.
Police OfficerInc. Village of Huntington Bay Police service generalist 1963 - 1965.
Securitu Officer Security Officer generalist for Hofstra University 1961 - 1963.
Electronic Productive Technician Potentio" meter calibration technician for Computer Instrume... Corp.
- 1961, United States Marine Corps 1960 Infantryman O
PROFESSIONAL ACTIVITIES
- (m '
F.B.I.
National Academy Associates, Member.
International Association of Chiefs of Police, Associate Member.
Law Enforcement Training Director Association of New. York State, Member.
Suffolk County Police Conference, Member.
Suffolk County Police Association, Member.
Suffolk County Police Superior Officers Association, Member.
Suffolk County Police Patrolmen's Benevolent Association, Member.
Suffolk County Police Steuben Association, Financial Secretary.
Suffolk County Police Columbian Association, Member.
EDUCATION F.B.I.
National Academy, (University of Virginia),
Diploma, 1985 State University of New York at Stony Brook, M.A.,
Political Science, 1981 New York Institute of Technology,_B.S. Behav-ioral Science, 1976 Suffolk County Community College, A.A.S.,
Criminal Justice, 197S O
O n
O
'*