ML20207A321
| ML20207A321 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/02/1986 |
| From: | Donovan R Federal Emergency Management Agency |
| To: | |
| References | |
| CON-#287-3224 86-533-01-OL, 86-533-1-OL, OL, NUDOCS 8704270103 | |
| Download: ML20207A321 (185) | |
Text
TRAN5COR!GKA; RII'1 sw/
e.astru m m m m o,
OF PRDCEEDIT/
All :05 UNITED STATES OF AMERICA 0FFICE.
. i.,
00CKfbn2 a, < t ou 65iANCH NUCLEAR REGULATORY COMMISSION BEFORE Ti!E ATOMIC SAFETY AND LICENSING BOARD
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the flatter of :
LONG ISLAND LIG!! TING COMPANY
- Docket No. 50-322-OL-5 (EP Exercise)
(Shoreham Nuclear Power Station, Unit 1)
- ASLDP No. 86-533-01-OL
- - - - - - - - - - - - - - - - - - - - - -x DEPOSITION OF RICIIARD W.
DONOVAN Washington, D.
C.
Tuesday, December 2, 1986 ACE-FEDElML REroR rERs, Ixc.
Shwtup.%n'stm hhington. b'ito! Street 444 North Ca I
.C. ItW1 (202) 347-3700 Nationwide Coverage 800-336-6646 0704270103 861202 PDR ADOCK 0300 2
T
1
)29069 12/2/86 1
UNITED STATES OF AMERICA JoeWalsh NUCLEAR REGULATORY COMMISSION 2
ATOMIC SAFETY AND LICENSING BOARD 3
__________________----------------X 4
In the Matter of
- Docket No. 50-322-OL-5 5
LONG ISLAND LIGilTING COMPANY (EP Exercise) c (St.oreham Nuclear Power Station,
- (ASLDP No. 86-5 3 3-01-OL)
Unit 1) 9
__________________________________x 8
9 10 DEPOSITION OF RICIIARD W. DONOVAN i
11 O
12 Washington, D. C.
I 13 Tuesday, Decemb'er 2, 1986 14 15 Deposition of RICIIARD W.
DONOVAN, called for examination 16 pursuant to notice, at the Law offices of Kirkpatrick &
37 Lockhart, 1900 M Street, N.W., Washington, D.C.
20036, at is 9:10 a.m.,
before GARRETT J. WALS!!, JR., a Notary Public in 19 and for the Commonwealth of Virginia at Largo, when were 20 present on behalf of the respective parties:
21 22 O
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J 2
i 1
MICIIAEL S. tiILLER, ESQ.'
i i
SUSAN M. CASEY, ESO.
l 2
Kirkpatrick & Lockhart i
1900 !! Street, N.W.
3 Washington, D.C.
20036 On behalf of the Intervenor, the County of Suffolk 4
j KATl!Y E. D. !!cCLESKEY, ESQ.
!!unton & Williams 2
707 East Main Street i
P. O. Box 1535 6
Richmond, Virginia 23212 l
7 On behalf of the Applicant, Long Island Lighting company l
8 RICilARD J.
Z AllNLEUTER, ESO.
j Deputy Special Counsel to the Governor e
i g
Capitol, Room 229 Albany, New York 12224
[
f 10 On behalf of the Intervenor, the State of New York 4
DERNARD !!. BORDENICK, ESO.
}
l 11 Office of General Counsel j
U. S. Nuclear Regulatory Commission l
12 l
Washington, D. C.
20555 i
)
On behalf of the NRC 13 j
34 WILLIAft R. CUtiMING, ESQ.
Federal Emergency Management Agency Washington, D. C.
i 15
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On behalf of FEMA 16 f
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18 19 i
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1 CO'NTENTS j
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Direct Cross
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Richard W. Donovan 4
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24 By Mr. Zahnleuter..........
136 I
By tis. ficCloskey..........
145
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By Mr. Bordenick..........
147 I
l By Mr. Cumming 151 6
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E X II I B I T S i
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I For Identification 4
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to Donovan Deposition Exhibit Number 1 Page 27
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11 Donovan Deposition Exhibit Number 2 Page 31 i O i
12 Donovan Deposition Exhibit Number 3 Page 57 i
j-13 Donovan Deposition Exhibit Number 4 Page 74 i
14 Donovan Deposition Exhibit Number 5 Page 82 b
15 Donovan Deposition Exhibit Number 6 Page 91 l
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16 Donovan Deposition Exhibit Number 7 Page 105 17 Donovan Deposition Exhibit Number 8 Page 112 l
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1 PROCE.EDINGS 2
Whereupon, 3
RICliARD W.
- DONOVAN,
.4 was called as a witness, and having first been duly 5
sworn, testified as follows:
6 EXAMINATION 7
BY MR. MILLER:
s Q
Mr. Donovan, will you please state your a
name and address for the record?
10 A
Richard W. Donovan, an employee of the RJD:
11 Federal Emergency Management Agency, ;Wf Region X, wh+eh i
Ser#tlL, l
O in invelicd i,n Washington.
12 13 Q
Mr. Donovan, my name is Michael Miller, and l
1 14 I am here as an Attorney for Suffolk County, and I am with the firm of Kirkpatrick & Lockhart.
We are taking your 15 I
i 16 deposition today for discovery purposes, and I will ask
{
l 37 you questions regarding events leading up to, the day of, i
a j
18 and subsequent to the exercise for the Shoreham Plan on i
39 February 13, 1986, i
If you have any questions during the course 20 l
21 of this deposition, please ask me, and I will be glad 22 to clarify any questions I am going to ask you, and we
i 5
4
)q O
1 are here today just to try to discover facts regarding the 2
Shoreham exercise.
l v
3 Would you tell me, Mr. Donovan, did you bring any i!
4 documents with you today to this deposition?
5 A
Yes, I did.
j t
6 Q
Would you tell me what documents?
,i 7
A I brought a copy of the Controller and Simulation a
plan, which was my responsibility to develop in this 9
exercise; an excerpt of that document, which was attached to 10 the evaluator training information, the Controller Organiza-i
,1 l
11 tion and Management Plan.
And, I brought a copy of the g.
12 free-play exercise messages that it was my responsibility 13 to see that they are inserted into the exercise, th'e FEMA
/
14 free-play exercise messages I should say.
I 15 Q
The first thing you mentioned, Mr. Donovan, the 16 Controller and Simulator plan, does that have a date?
17 A
February 13, 1986.
18 Q
Did you bring any drafts of that Simulator and 19 Controller plan with you today?
20 A
No, I did not.
21 Q
And., the excerpt that you mentioned from that 22 plan that is entitled, "The Controller organization 1
-.._,~.-.-, -..,,,
6 4
1 and Management Plan,." is that right?
2 A
That is correct.
3 Q
Is that a three page document?
,4 A
Well, there are two pages to the document, 3
and there is a separate document that we developed in 6
coordination with the Licensee, which is entitled, 7
"Information and Instructions for Exercise Players, 8
Visitors and Observers."
i 9
Q Is the management plan that you are referring 10 to pages 13, 14, and 15 in the Simulator and Controller 11 Plan that you first mentioned?
12 A
Yes.
Yes, it is.
And in that Plan, it was la entitled, Appendix A.
14 Q
And the other document you mentioned, would that be Appendix B to the Simulator Controller Plan?
15 i
A Ye s, it is.
16 i
17 Q
Now, the last document, the third document 18 that you mentioned, Mr. Donovan, can you tell me what 19 that is?
A It is my responsibility to see that certain 20 exercise messages developed' by FEMA were inserted into 21 l
22 the exercise play at appropriate times.
They were
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I titled, Free-Play Messages.
We gave a copy' to your 2
firm, representing Suffolk County, during the exercise IND j
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i as we input it.
j 3
i Q
Would an example of a free-play message be 4
a message that was used during the exercise regarding y
5 the simulated failure of Sirens 26, 45,'and 89?
6 7
A Yes.
P 8
Q Did you develop those free-play messages?
9 A
I was part of the team that developed those 10 ne ssage s.
11 Q
We will come back to that, Mr. Donovan.
Did l
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12 you bring any other documents with you today?
l 13 A
I have a copy of the Exercise Report.
14 Q
I may refer to that as the FEMA Report.
If there is any confusion on that, just let me know.
15 Anything else, Mr. Donovan?
16 17 A
No, I did not.
18 Q
Can you tell me what you did to prepare for l
19 this deposition?
20 A
Basically, just read throu h the ex rcise control plan that we had developed,p ntroller simulation-y or co 21 l
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Q Is that all you did to prepare for this deposi-i 2
tion?
f 3
A
.Yes, j
4 Q
Did you review the FEMA report?
5 A
No.
I was not part of the evaluation process.
t 6
That is a -- I had a separate assignment.
7 Q
Did you review, or have you reviewed at any time, 8
the contentions that havd been filed in this proceeding g
by the County, New York State, and the Town of Southampton?
10 A
No, I did not.
l 11 Q
Have you ever reviewed the contentions filed by 1
O 12 the Intervenors in this proceeding?
13 A
No, I have not.
14 Q
Mr. Donovan, are you aware that you have been 15 designated as a witness at the Shoreham exercise proceeding 16 by FEMA?
17 A
Yes, I have.
18 0
When were you first advised that you would be 19 a witness?
20 A
Approximately two months ago.
And, I was 21 advised that I may be a witness, not that I would be a 22 witness.
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_.. _ = _
9 1
Q So, approximately the beginning of October 2
of this year?
3 A
(Witness nods head af firmatively.)
i 5
4 Q
You will have to say yes or no for the f
record.
5 A
Yes.
6 7
Q Is it your understanding at this time that 8
you will be a witness on FEMA's behalf, or that you may be a witness on FEMA's behalf.
9 MR. CUMMING:
The witness may state his 10 unde rstanding.
1 11 THE WITNESS:
I may be a witness.
j 12 BY MR. MILLER:
(Continuing) 13 14 Q
Can you tell me, Mr. Donovan, what you were told with respect to the possibility that you may be a 15 witness --
16 MR. CUMMING:
Objection.
Attorney work 37 p roduct.
Privileged.
The witness may not answer the 18 question.
19 BY MR. MILLER:
(Continuing)
I 20 Q
Mr. Donovan, who advised you that you may i
21 be a witness at the Shoreham proceeding?
22
10 l
1 MR. CUMMING:
The witness may answer that 2
question to the extent of his knowledge.
3 THE WITNESS:
I had two phone calls; one
~
.4-with my Regional Director, who had advised-me that he 5
had been contacted by FEMA Headquarters as to the avail-6 ability of my time, and potential problems that request 7
for such duties may require, or present us in our Region; 8
and, two, I had a follow-up conversation with FEMA 9
Headquarters Personnel, where I was asked to submit 10 certain documentation on my background.
3 l
BY MR. MILLER:
(Continuing) 1 11
()
12 Q
The documentation to be submitted on your l
13 background was with respect to your identification as a 14 witness, or possible witness?
A Yes, that is correct.
15 0
Who is the Regional Director -- who was your i
16 17 Regional Director?
18 A
William Mayer, M-a-y-e-r.
39 Q
So, Mr. Mayer originally advised you that y u may be a witness in the Shoreham proceedings, is 20 that correct?
21 A
Yes.
I believe he was told by Richard Krimm, 22
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1 at FEMA Headquarters.
2 Q
What did Mr. Mayer say to you when he advi sed 3
you that you may be a witness in these proceedings?
4 MR. CUMMING:
You may answer the question.
5 THE WITNESS:
lie just asked if this would 6
create -- one, that I may be called upon to be a witness.
i 7
Two, the time was not certain, but it would be probably 8
during the winter months.
And would it create any problems g
for the Region if I was absent for a period of time, since 10 I am the only official assigned to radiological emergency h
11 preparedness duties in our region.
BY MR.11 ILLER:
(Continuing) 12 13 Q
Did Mr. Mayer say anything to you about why 14 you were being selected as a possible witness on FEMA's behalf?
15 MR. CUMMING:
The witness may answer to the 16 17 extent he has knowledge, Tile WITNESS:
No, he did not.
18 19 BY MR. MILLER:
(Continuing)
Q Did you ask Mr. Mayer that question?
20 A
No.
21 0
Y u were advised by Mr. Mayer that you may 22 O
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1 be a witness in the Shoreham proceedings, and you didn't 2
ask why you have been selected, and you didn 't make any 3
inquiry in that regard.
Is that your testimony?
4 A
No, I did not ask any questions.
5 Q
And Mr. Mayer did not state to you any reason 6
for your selection as a possible witness?
7 MR. CUMMING:
Asked and answered.
8 MR. MILLER:
I just find the answer hard to 9
believe.
10 MR. CUMMING:
I understand you do.
You find i
i 11 a lot of things hard to believe.
l 12 BY MR. MILLER:
(Continuing) i l
13 Q
Is that your testimony, Mr. Donovan?
l 14 A
What do you want to consider my testimony?
15 Q
Is it your testimony that at the time you Ic were advised by Mr. Mayer that you may be a witness in the 17 Shoreham proceedings, there were no statements made to 18 you regarding why you had been selected?
19 MR. CUMMING:
Objection.
Asked and answered.
20 MR. MILLER:
Your objection is noted.
Are 21 you instructing the witness not to answer?
22 MR. CUMMING:
The witness does not need to
13 O
1 answer this repetitive question.
2 MR. MILLER:
If you are instructing the 3
witness not to answer --
c4-MR. CUMMING:
I am instructing the witness 5
not to answer.
6 MR. MILLER:
Then he doesn't need to answer.
7 Your objection is noted.
It is inappropriate.
8 BY MR. MILLER:
(Continuing) l 9
Q Did you tell Mr. Mayer at the time you were 10 advised you might be a witness, Mr. Donovan, that there l'
11 would be no problems created for Region X if you were to j
12 be such a witness?
13 MR. CUMMING:
Objection to this line of g
14 questioning with respect to relevance.
The witness may 1
15 answer the question to the extent he has knowledge.
THE WITNESS:
At the time we were advised 16 17 I may be a witness, it was not specific as to what time 18 frames.
There may be a potential.
For example, I was 19 supposed to be somewhere else today making a presentation which I had to cancel.
There was no one to back me up.
20 21 BY MR. MILLER:
(Continuing) 22 Q
Well, with respect to your being present O
14
,OG) 1 at licensing hearings, and therefore being absent from 2
Region X, did you advise Mr. Mayer that that might cause 3
a problem?
4 A
I said there may be a potential, depending on what the time constraints were in request for my services.
5
~
0 Mr. Donovan, you mentioned two telephone 6
7 calls, and the second call you told me was a follow-up 8
conversation.
Do you recall that?
9 A
Yes, sir.
10 Q
The follow-up conversation was between whom?
A Margaret Lawless, who was an employee at i
11 FEMA National.
12 Q
And?
13 A
And myself.
14 0
Now, what did Mrs. Lawless tell you?
15 A
She didn't tell me anything.
She asked me 16 to provide certain information.
37 0
And that information would include, for 18 example, your biography?
19 A
Y 8*
20 21 Q
Any other information?
22 A
No.
O
-15 i
(
1 Q
Other than the telephone call between 2
FEMA X Regional Director and FEMA Headquarters, and the 3
subsequent follow-up call between yourself and Mrs. Lawless, 4
have you had any other conversations regarding the possibility 4
5 of you testifying on FEMA's behalf on these Shoreham 6
hearings?
7 MR. CUMMING:
Witness may answer to the extent 8
he has knowledge, s
THE WITNESS:
Had one conversation in a meeting 10 with FEMA Region II 's Staf f.
Basically there were no 11 specifics.
l 12 BY MR. MILLER:
(Continuing) 13 0
When was this conversation with FEMA's 4
14 Region II Staff?
A Early October.
15 16 Q
Who was present at that meeting?
j 17 A
It was a telephone call.
18 0
Who was involved --
19 A
Mr. McIntyre.
0 Just yourself and Mr. McIntyre?
20 A
That is correct.
21 22 0
Can you tell me, Mr. Donovan, what was
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discussed during that telephone call?
2 MR. CUMMING:
The witness may answer, but 3
counsel for FEMA objects to this line of questioning, and
.4 if we go on much longer I am just going to-instruct the 5
witness not to answer.
6 THE WITNESS:
Whether I should or should not 7
be a potential FEMA witness was the subject of the 8
conve rsation,
9 BY MR.,MILLDR:
(Continuing) 10 Q
Was that your question, Mr. Donovan, or was 11 that Mr. McIntyre 's question to you?
l 12 A
It wasn't a question at all.
It was a I
13 s tatement.
14 Q
Who was making that statement?
15 A
Mr. McIntyre.
16 Q
Do you know why Mr. McIntyre was wondering 17 as to whether you should or should not be a witness on 18 FEMA's behalf?
19 A
I believe the interrogatories had not been 20 filed at that time, and whether there would be a need for 21 me to be present to answer questions was the issue.
22 Q
Are you talking about whether there would be O
17 O
1 a need for you to be present at the hearings to answer 2
questions?
3 A
Yes.
4 Q
And could you tell me, Mr. Donovan, why it 5
was determined that there may be such a need for you to 6
be present at the hearings?
7 MR. CUMMING:
If the witness has knowledge, 8
he may answer, g
TiiE WITNESS:
I have no knowledge.
I was part of the management team that FEMA Region II utilized to 10 11 prepare for, and conduct the exercise.
l BY MR. MILLER:
(Continuing) 12 13 Q
Could you tell me, Mr. Donovan, what you would be testifying about on FEMA's behalf at these 14 hearings -- upcoming hearings --
15 MR. CUMMING:
Objection.
10 MR. MILLER:
-- upcoming hearings on the 17 Shoreham licensing proceedings, 18 MR. CUMMING:
Objection.
The witness is gg instructed not to answer.
20 BY MR. MILLER: (Continuing) 21 0
IIave you discunsed with anyone, Mr. Donovan, 22 O
18 i
O 1
what your testimony would involve at the hearings 2
regarding the Shoreham exercise?
3 MR. CUMMING:
Objection.
The witness is 4
instructed not to answer.
5 MR. MILLER:
What is the objection, Mr.
6 Cumming?
I asked if he had discussed with anyone 7
whether --
8 MR. CUMMING:
Attorney work product.
9 MR. MILLER:
What is the attorney work j
10 product?
I have asked --
11 MR. CUMMING:
Conversations with myself.
12 MR. MILLER:
IIe can state he had discussions 13 with you.
L 4
14 MR. CUMMING: Fine.
Let the witness so state.
MR. MILER:
Mr. Donovan, do you remember my 15 16 question?
17 T!!E WITNESS:
I had one discussion with Mr.
18 Cumming.
19 BY MR. MILLER:
(Continuing) 20 Q
llave you had discussions with anyone other I
l than the one discussion with Mr. Cumming?
21 I
l A
No, I have not.
22
!O 1
i l
, 19 O
1 Q
Are you able today, Mr. Donovan, to tell me 2
what it is that you will be testifying about at the hearings regarding the Shoreham exercise?
3
- 4 MR. CUMMING
Objection.
The. witness is instructed not to answer.
5 MR MILLER:
What is the basis of the objection ?
6 7
MR. CUMMING:
Attorney work product.
8 BY MR. MILLER:
(Continuing) g Q
Mr. Donovan, do you have any independent knowledge other than your conversation with Mr. Cumming, to
]
the one conversation with Mr. Cumming, regarding the
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scope of what your testimony might be at the Shoreham l
i 12 t
exercise hearings?
33 MR. CUMMING:
Witness may answer that 14 qu stion?
15 TIIE WITNESS:
No, I do not.
16 BY MR. MILLER:
(Continuing) 17 Q
Is it fair to say, Mr. Donovan, that at this 18 time you are not in a position to state whether you 19 agree or disagree with any of the contentions that have 20 been submitted by the Interveners in the licensing 21 Proceeding regarding the Shoreham exercise?
22 O
20 O
1 MR. CUMMING:
Witness may answer the question.
2 THE WITNESS:
Could you rephrase the question, 3
or restate it?
4 BY MR. MILLER:
(Continuing) 5 Q
Is it fair to state at this time that you are a
not in a position to state whether you agree or disagree 7
with any of the Contentions that have been filed by the a
Interveners in the Shoreham exercise proceedings?
9 A
Since I don't have a copy of the Contentions, 10 or had the opportunity to review them, I can't answer i
11 that question, j
12 Q
So, at this time you are not in a position 13 to have that discussion, is that correct?
A $ 'so s Position to discuss my responsibilitiesjas i
14 part of the management team,' documentation instructions,'
[dD 15 JG
{ oder M4dd +W conducted training classes',up to, and during the exercise.
16 17 0
So, you are here today to discuss with me 18 what you did at the day of the exercise as part of the gg management team?
A That is correct.
20 21 0
And you are not here today to discuss with 22 me what you may, or may not say as a witness on FEMA's O
21 i
O v
1 behalf at the hearings?
Is that correct?
2 MS. McCLESKEY:
I object to the question.
3 I think you can ask your questions of Mr. Donovan and 4
find out what he knows about any of those matters.
5 MR. MILLER:
Is that correct, Mr. Donovan?
6 MR. CUMMING:
Does the witness remember the 7
question?
8 Tile WITNESS:
Would you restate it?
9 BY MR. MILLER:
(Continuing) 10 Q
My question is:
Is it fair to say you are 11 not here today to discuss what you may or may not testify i
O 12 about at the hearings regarding the Shoreham exerciso?
i 13 MR. CUMMING:
Obje ction.
Counsel is 14 charactorizing what the witness has testified.
The 15 witness may answor to the extent he has knowledge.
T!!E WITNESS:
I am prepared to answer any 16 17 questions concerning my rouponsibilities before and during 18 the oxorciso.
19 BY MR. MILLER:
(Con tinuing) 20 0
As part of the FEMA Management Team, is that 21 correct?
l 22 I
22 f
1 A
Right.
[
2 MR. MILLER:
Mr. Cumming, I am going to note an 3
objection for the record.
We have a witness here today who has 24 been designated by FEf1A to be a witness, or a possible witness, 5
one of the five you have designated for the Shoreham hearings.
6 This witness is not being permitted to answer any 1
questions about what he may, or may not, know at this time 8
regarding the contentions at issue in this proceeding under 9
your instruction.
to The purpose of this deposition is twofoldt one, 11 to explore with !!r. Donovan what he did to prepare for and O
12 during the day of the FEMA exerciso at the Shoreham plant.
13 The second purpose of this deposition was to l
14 cxplore with Mr. Donovan his ability to testify as a 15 witness on FEttA's behalf.
You are precluding that second 16 explora tion.
17 MR. CUMMING:
I can't charactorize why you asked 1
18 for the deposition of fir. Donovan, but you have incorrectly 19 stated for the record what has happened here this morning.
20 And, until the contentions are resolved by the 21 Board and FE!!A knows what, in fact, is being litigated, no 22 witness will be in a position to testify.
I think wo havo
I l
23 l
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1 made that very clear in our filings.
1 2
MR. MILLER:
You are saying that until the Board j
s rules, no witness will be -- no FEMA witness will be in a 4
position to testify --
5 MR. CUMMING:
We don't know what is being litigated, J
s Mr. Miller.
4 7
MR. MILLER:
-- at the deposition about the 8
Intevonor's contentions?
j, 9
MR. CUMMING:
That's correct.
And, our position j
l 10 is very clear before the Board.
You are welcomed to go to 11 the Board and ask them for guidance.
l (
j 12 If you would like to racess the deposition, I i
i j
13 will send Mr. Donovan home, and I will be happy to 'do so.
I j
14 MR. MILLER:
Well, we will be recessing this 15 deposition but after I've asked somo questions.
i 16 MR. CUMMING:
Fino.
To the extent Mr. Donovan has i
17 knowledge, I hope he will be helpful in answering them.
1 18 BY MR. MILLER:
(Continuing) i
}
19 Q
Mr. Donovan, given the beginning of this deposi-l
}
20 tion and where we stand right now, and the representations i
j 21 made by your counsel, and given your answers to my questions 22 thus far, we will focus on your involvomont as part of the O
4 3
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24 i
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management team for FEMA at the Shoreham exercise.
2 Could you tell me, Mr. Donovan, what documents, if 3
any, did you generate during the day of the Shoreham exercise 4
on February 13?
5 A
I did not generate any documents during the day e
of the exercise.
7 Q
Now, prior to the exercise, you generated or helped a
to generate the simulator and controller plan, correct?
9 A
That's correct.
y to O
And the free-play FEMA messages, correct?
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11 A
That's correct.
O 12 O
Was there anything else prior to the exercise that 13 you generated or helped to generate in terms of the documents?
14 MR. CUMMING:
Asked and answered, but witness 15 may answer.
16 Tile WITNESS:
Part of the -- this plan was contained 17 in the documents that the Licensee prepared, specifically 18 the Information and Instructions for Exercise, Players, 19 Visitors and Observers.
It was a document that we proposed 20 and discussed and agreed upon with the Licensee.
21 Q
When you say this document, Mr. Donovan, are you 22 referring to the simulator and controller plan?
O
25 O
1 A
- Well, part that.
It had an appendix entitled, 2
"Information and Instructions for Exercise Players, Visitors 3
and observers."
In so many words, it was'to be considered 4-ground rules for the exercise and it's part of management i
5 approach to any exercise conducted by, or evaluated by, our a
agency.
It's just not particular. to this particular exercise.
7 Q
Can you recall any other documents, Mr. Donovan, a
that you would have generated or helped to generate prior 9
to the exercise?
10 A
No.
11 0
Did you keep a log during the exercise?
O 12 A
No, I did not.
1 13 Q
Any notes?
14 A
No, I did not.
15 0
Did you generate, or help to generate, any to documents regarding the Shoreham plant subsequent to the 17 exercise?
18 A
Following the exercise?
19 Q
Yes.
20 A
No, I did not.
21 Q
You had no responsibility for drafting any of the 22 PEMA report; is that correct?
O
26 i
O 1
A That's correct.
2 0
Is it correct that you did review drafts of the 3
FEMA report?
4 A
I reviewed one draft of the FEMA report.
5 0
What draft, do you recall?
6 MR. CUMMING:
Witness may answer.
7 Tile WITNESS:
The March 12th draft.
8 BY MR. MILLER:
(Continuing) 9 Q
Other than your review of the March 12th draft of 10 the FEMA report, did you have any other involvement in the 11 preparation or review of the FEMA report?
O i
12 A
No, I did not.
13 Q
Other than your review of the March 12th draft,
/
14 have you had any other involvement with the Shoreham plant 15 since the time of the February 13th exercise?
16 A
No, I have not.
17 MR. MILLER:
I'm going to have marked as Donovan 18 Exhibit 1 a two-page biography of Richard W. Donovan.
19 In the upper right-hand corner, there is some 20 printing which indicates the date of October 1986.
21 22 O
27 O
indexx 1
(The document referred to was marked 2
as Donovan Deposition Exhibit 1 3
for identification.)
4 4
BY MR. MILLER:
(Continuing) 5 Q
Mr. Donovan, did you prepare what has boon 8
identified as Donovan Exhibit l?
7 (The witness is looking at the document.)
8 A
Yes.
8 Q
Was this document prepared in response to your 10 tolophone conversation with Mrs. Lawless of FEMA headquarters?
11 A
It was updated.
O 12 0
Is this biography updated ossentially as of today?
13 Is there anything you would wish to add to this biography if 14 you were going to make it current?
15 Ti!E WITNESS:
You may answer.
16 Tile WITNESS:
No.
17 BY MR. MILLER:
(Continuing) 18 Q
Mr. Donovan, you are the RAC Chairman of the 19 Regional Assistanco Committoo, or RAC Chairman, for Dogion X, 20 correct?
21 A
Yes, I am.
22 O
Could you tell me just briefly what your dution as
28 O
1 RAC Chairman involve?
2 MR. CUMMING:
Witness may answer.
3 Tile WITNESS:
We have federal regulation publication 4
44 CFR end 351 that sets up the structure of the Regional,
Nd9 '
T" k d C(* ' o d *' A%istAA F W *IT7i' Assistance Committoo,and basically have throo primary rolosgt !
5 wmh e
one of which is to provido technical assistanco to stato and 7
local governmonts in developing preparodness for radiological a
omorgenciosi two, to perform assessments and ovaluations in i
9 accordanco with the agrooment with the Nuclear Regulatory t
to commission for commercial fixed facilitios.
And, throo is 11 to develop a responso capability betwoon and among the fodoral
[
()
12 field officos in my region for radiological omorgencies.
I 13 BY MR. MILLER:
(Continuing) 14 0
Mr. Donovan, is the composition of the various
}
15 Regional Assistanco Committoos around the country the samo in to terms of the agenclos represented?
17 A
Basically, yes.
4 18 0
Mr. Donovan, wo are going to talk about tho 19 simulator and controllor plan that you have already mentionod i
20 this morning.
21 Could you toll mo, other than yourself, who worked l
22 on preparing this simulator controller plan?
()
i i
i
29 i
n
(
I I
MR. CUMMING:
Witness may answer.
2 T!!E WITNESS:
It's basically my document.
I worked 3
with the RAC Chairman and lead person for FEMA Region II in 4
finalizing the document.
That is, I worked in draft with 5
him before I gavo instructions to have it finalized.
6 BY MR. MILLER:
(Continuing) 1 0
So, you worked with Mr. Kowieski; is that correct?
8 A
That's correct.
0 0
And, who oino did you mention you worked with?
10 A
That is all, 11 0
Just Mr. Kowlooki.
So, you basically drafted tho
(~)
\\'
12 document and then before it was put into final discussed it 13 with Mr. Kowleski, correct?
14 A
That la correct.
15 0
About when was it, Mr. Donovan, that you learned l
10 that you woro going to bo the nonior controllor at the 17 Shoreham exercino?
18 A
I can't remember the exact dato.
It would be l
to December of 1985.
I don't know if it'n fair to say that I l
20 know I wan going to bo the senior controllor at that timo.
21 I was requented to provido anniotanco to Region II, 22 and it wan not until my arrival at Region II in January of '86
30 O
t in a discussion of work to be done was I given this assign-2 mont.
3 0
Do you know, !!r. Donovan, if any person had boon 4
designated to be senior controller other than yournolf prior 5
to your designation?
1 6
MR. CUMMING:
Witness may answer to tho extent ho 7
has knowledgo.
8 T!!C WITNESS:
It's my understanding thoro was a o
contract with a consultant.
And, for a varioty of roanons tho 10 contract was terminated, and I was asked to develop the F
i 11 product that they had hoped the conouttant would develop for f
i CE) 12 the oxorcino.
l i
13 BY !!H. MILLER:
(Continuing)
[
14 0
Wan that consultant Thoodoro Barry & Associaton?
is A
I believe that was the consultant.
to 0
Wan Mr. Stoken, of Theodoro narry & Annociaton, 17 donignated an nonior controllor at any timo, to your knowledgo?
l to A
I have no knowledge.
to O
co, in it your tontimony that you onnontially camo 20 in in lieu of Theodoro 11arry & Associaton to nervo an 21 nonior contro11or at tho oxorcino?
22 A
I would rather nay that I wan anked to provido
l' 31 O
1 assistance to Region II.
And the assistance took the shape 2
of developing this plan and serving as senior controllor.
3 0
Just for purposes of clarification, Mr. Donovan, 4
I includo -- when I talk about the controller and simulator i
5 plan -- the Appendix A, " Control Organization and Management Plan."
Okay.
l 6
9 If you don' t want to -- if you war.t to tront that as l
8 a separato docen.ont, vould you lot mo know that?
But, othor-1 0
wino let's just considor that one docunont.
j go A
Okay.
I g
MR. ftILLER:
I'm going to mark as Donovan Exhibit l
l 12 2 some excorpts from the contro11or and Simulator Plan, J.
g3 specifically 14 pagos from that Controllor and Simalator y
34 Plan, the first pago which in dated Pobruary 3, 1986.
l And it is ossentially a covor lotter, a cover 15 l
10 memorandum, from Roger Kowloski and Richard Donovan to 39 PEMA Region II Controllers and Simulators.
l 38 (Tho document roforred to was niurked 39 as Donovan Doposition 1:xhibit 2 indoxx for identification.)
20 21 IlY MR. MILLER:
(Continuing) 22 0
Mr. Donovan, I will reprosent for you that thoso
32 O
xcrox copios from the final version of the Controller and 2
Simulator Plan, but if you want to look through them you 3
are froo to do so.
t
,4 MR. CUMMING:
I would just note for the record that 6
the document has not boon compared.
Proccod.
6 BY MR. MILLER:
(Continuing) 7 0
Givon my representation, Mr. Donovan, those aro 8
pages that you draf ted that lator were approved by Mr.
s Kowleski and became the final Simulator and controller Plan, I
10 correct?
tr b;
11 A
That's correct, h
O 12 Q
When Mr. Kowieski reviewod your draft of this la document, this controller and Simulator Plan -- I koop y
d 14 roversing rho terms, but it.'s the same plan -- do you recall 15 if there were any significant changes made by Mr. Kowieski?
i i
j 16 MR. CUMMING:
Hitnoss may answer to the extent ha l
i 17 haa knowledeo or memory.
18 TilU WITNESS:
What I roca11 is that there woro no l
f
{
18 nignificant changes.
i i
20 DY MR. MILLER:
(Continuing) t L
j 21 Q
Do you recall if thoro woro any changon mado?
l 22 A
Thoro woro somo minor that I would categorizo as i
O t
4 i
l i
4 I
33 O
i word engineering.
2 Q
Would you look please, Mr. Donovan, at Page 5 of 3
what has been marked as Donovan Exhibit 2?
It's actually I
4 Page 6 of the document that at the top is entitled " Purpose."
5 Do y u have that page?
l A
Yes, I do.
6 q
Q There is a paragraph that begins -- the second a
paragraph on that page, "To assist the normal FEMA evaluation g
of the objectives of the exercise, FEMA will execute certain go exerciso control functions through controllers..." and it goes 11 n from thoro.
12 Would you explain to me, Mr. Donovan, what you 13 meant when you wrote that, that the controllers at the i
14 Shoreham exercise were to assist the normal FEMA evaluation?
IS
?!R. CUMMING:
Witness may answer to the extent he 16 has knowledge, 17 TIIE WITNESS:
The purpose of the controller is to 18 cither intorject what we referred to in our documentation as 19 freo-play messages or to interjoct initiating events that 20 constituto part of the scenario to creato conditions for 21 respondors to respond to.
22 In this caso, there was a team of controllers that O
34 i
o-1 the Licensee had, and there was a team of controllers that 2
FEMA had.
3 Q
Eave you ever participated in other exercises, 4
FEMA exercises, Mr. Donovan?
5 A
Yes, I have.
j l
6 Q
In other exercises, does the utility typically have 7
a team of controllers?
8 A
Yes, they do.
9 0
So, was there any difference in the Shoreham 10 exercise and other exercises that you have been involved in 4
11 with respect to how controllers were structured and used f
12 during the Shoreham exercise?
13 MR. CUMMING:
Witness may answer.
14 TIIE WITNESS:
There was one difference in that, e g e,1 M so n T 6 * $
pb 15 that we had certain quccticar which have been referred to as 16 the FEMA free-play messages that we did not want to divulge 17 the contents of the messages; therefore, we developed this 18 controlled plan for our management approach to injecting 19 these messages into the exercises.
20 BY MR. MILLER:
(Continuing) i 21 Q
When you say these FEMA free-play messages you 22 did not want to divulge, are you saying that you did not want O
35 O
1 to divulge those messages to the utility?
2 MR. CUMMING:
Witness may answer.
3 THE WITNESS:
That's correct.
c4-BY MR. MILLER:
(Continuing) 5 Q
Now, in other exercises, does FEMA typically 6
divulage its free-play messages to the utility beforehand?
7 MR. CUMMING:
Witness may answer.
8 THE WITNESS:
In other exercises, we normally have I
9 the participation of state and local governments.
It is to usually designated a scenario development team which has 11 representation of state and local governments on it, and they O
i 12 develop the scenario which includes free-play messages.
l I
13 We review the appropriateness of the scenario to i
14 determine if sufficient conditions are contained therein to 15 allow the demonstration of the exercise objectives.
s 16 BY MR. MILLER:
(Continuing) 17 Q
So, what you are telling me, Mr. Donovan, is that 18 at other exercises FEMA would typically divulge to state and 19 local government officials its free-play messages beforehand; t
20 is that correct?
21 A
Mo, I'm not.
I'm saying the exercise control team, 22 the team that developed the scenario, would have access but O
i 1
~.
(
36 O
1 other officials that would be responders or' players, depending 2
on how you would prefer to refer to.them, during the exercise 3
would not have knowledge beforehand of those messages.
4 Q
I'm trying to understand the difference between i
5 the Shoreham exercise and other exercises with respect to i
e these controllers.
So, I'm going to ask again because I don't 7
understand your answer to me.
i 8
You told me that controllers, FEMA controllers, at I
9 the Shoreham exercise did not divulge the free-play messages 10 to LILCO personnel prior to the exercise, correct?
11 MR. CUMMING:
Asked and answered, but the witness O
12 may answer to the extent he wishes to elaborate.
13 TIIE WITNESS:
That's correct.
I' 14 BY MR. MILLER:
(Continuing) 15 0
And, I've asked if FEMA typically reveals its free-16 play messages to the utility controllers prior to the 17 exercise at other plants.
l l
18 MR. CUMMING:
The witness may answer to the extent i
l 19 he has knowledge.
20 THE WITNESS:
It would depend.
I wouldn't say 21 consistently that we do or we -- that we do not.
22 1
l 1
37 i
i V) f 1
BY MR. MILLER:
(Continuing) 2 Q
Why is it, in the case of the Shoreham exercise, it 3
was decided FEMA would not divulge beforehand its free-play 4
messages to the utility's personnel?
5 MR. CUMMING:
FEMA counsel objects to this line of 6
questioning, but to the extent the witness has knowledge you 7
may answer the question.
s3 THE WITNESS:
My recall of the discussions were i
9 that we wanted to preclude any supposition that Licensee's 10 organization or players had prior knowledge to the free-play i
11 messages.
Therefore, we made the determination to keep the t
(
12 content of the messages known only to FEMA controllers.
13 BY MR. MILLER:
(Continuing) 14 Q
And, those messages were not divulged to LERO 15 controllers prior to tne exercise, correct?
16 A
That's correct.
17 Q
Do you know Mr. Daverio of LILCO?
18 A
Yes, I know Mr. Daverio.
19 Q
Did Mr. Daverio know beforehand the content of the 20 FEMA free-play messages?
21 A
No, he did not.
22 Q
Whose decision was it, Mr. Donovan, to not reveal
l r
38 O
1 these messages prior to the time of the Shoreham exercise?
2 Wc 3 that Mr. Kowieski's decision?'
3 MR. CUMMING:
Counsel for FEMA' objects to this
..4-question based on relevancy, but witness to the extent he has 5
knowledge may answer.
6 MS. McCLESKEY:
LILCO also has a continuing ob-7 jection as to relevance.
8 MR. CUMMING:
Witness may answer to the extent he 9
has knowledge if you remember the question.
10 THE WITNESS:
I believe the question is, whose i
11 decision was it not to make these free-play messages, the
(
12 content therein, known to LILCO.
l 13 And I believe your supposition is correct; it was l
14 Mr. Kowieski's decision.
He was the lead person for the 15 exercise process, and he was the person I reported to.
16 BY MR. MILLER:
(Continuing) 17 Q
I assume, Mr. Donovan, that you yourself knew 18 prior to the Shoreham exercise the content of the free-play 19 messages, the FEMA free-play messages?
20 A
Your assumption is correct.
21 Q
In fact, you prepared those messages, correct?
22 A
I worked with two other people to prepare those O
m
39 1
messages, yes.
i 2
Q Who were those other people?
q 3
A Mr. Kowieski and Mr. Baldwin.
l endTlA 4
Q Looking again at what would be Page 6 of Donovan 4
l 5
Exhibit 2, it is a statement there that the FEMA Region II i
6 controller functions would be performed at various locations, 7
the EOC, the staging areas and with the radiation monitoring 8
teams.
1 9
MR. CUMMING:
Excuse me.
Could we find the correct 10 Page?
It's the sixth page of the exhibit, or it's marked 11 Page 6?
O 12 MR. MILLER:
No, it's the sixth page of the exhibit, j
i 13 the same page we were just looking at with " Purpose at the f
14 top.
15 THE WITNESS:
Would you restate your question?
IG BY MR. MILLER:
(Continuing) 17 Q
I'm just referring to the third paragraph on that 18 page which talks about the locations where the controller 19 functions were to be performed.
20 Do you see that paragraph?
21 A
Yes, I do.
22 Q
Could you tell me, Mr. Donovan, why these locations O
40
+
r r
(~))
I were chosen?
t 2
A Those locations would be the normal locations that 4
3 would be in FEMA's interest to evaluate in an exercise.
,f 4
That is, the LERO EOC is the location designated to coordinate i
5 off-site activities.
The staging areas were implementation 6
areas for off-site activities.
The field teams were part of 1
7 the off-site response.
l I
8 Q
And, is it fair to say that you decided that these 9
would be the locations to have the controllers?
l 10 MR. CUMMING:
Witness may answer to the extent t
11 he has knowledge.
O 12 THE WITNESS:
It was not necessarily a decision.
t 13 It was a condition of the exercise, that these were areas l
14 where exercise play was going to be evaluated; therefore, also 15 areas where there would be need to input scenario information l
16 and because of that we decided to obviously have controllers l
17 at those locations.
18 BY MR. MILLER:
(Continuing) 19 Q
Who decided that?
i
(
l 20 A
Myself and Mr. Kowieski.
l l
21 Q
Did Mr. Kowieski decide, or did Mr. Kowieski l
l 22 approve, the decision you had made regarding the locations?
(2) i
41 I
. c4 1
1 A
I would prefer to restate it.. Again, we have a i
scenario for the exercise) g A gatred It was-information to be inputted,'
2 3
here it was necessary for fella controllers to input that 4
information.
It was based on the way the off-site response was iu 5
to be initiated.
6 And those were the reasons and the rationale for 7
having controllers.
It wasn't a conscious decision to have 8
them in one place and not have them in another.
9 Q
Well, I understand that, Mr. Donovan.
But, someone 10 nevertheless had to decide where you would have FEMA control-a 11 lers.
And, I'm just asking --
O 12 A
The decision where we had to have a need for was i
13 based on -- where we had to have a need for, we mad ~e the 14 decision to have controllers.
15 0
And, did you make that decision, that initial decision?
16 17 A
Mr. Kowieski and myself.
18 Q
Together made that decision?
19 A
Right.
20 Q
So, I'm assuming from that answer, Mr. Donovan, 21 that when you showed Mr. Kowieski the draft that he approved 22 with minor changes, these areas, the LERO EOC, the staging O
42 I
U'\\
1 areas and the radiation monitoring teams, were not included 2
in your draft; is that what you are telling me?
3 A
No, they were included.
4 Q
They were included in your draft?
5 A
Yes.
J 6
Q So, then I'm assuming that you made the decision 7
and Mr. Kowleski approved that decision; is that correct?
8 MR. CUMMING:
To the extent the witness has 9
knowledge, he may answer.
10 THE WITNESS:
That's basically correct.
H 11 BY MR. MILLER:
(Continuing)
)
12 Q
And, is it fair to say, Mr. Donovan, that the i
13 criteria of why those locations were chosen were based upon l
14 the exercise scenario itself?
15 A
Yes.
16 Q
Who prepared the exercise scenario, to your 17 knowledge?
18 MR. CUMMING:
Objection to this line of question-19 ing on a continuing basis.
20 To the extent the witness has knowledge, he may 21 answer.
22 MR. MILLER:
Well, I'm not going to respond to all O
43 O
1 the objections I hear during these depositions but --
2 MR. CUMMING:
No response is required.
3 MR. MILLER:
-- I'm going to respond to this one.
.4-Basically, Mr. Cumming, we have a witness who.has told us 5
that his primary involvement was in preparing the Controller 6
and Simulator Plan and as being the senior controller at the 7
exercise.
8 I'n asking Mr. Donovan questions from the plan i
9 that he, this witness, developed.
They are relevant questions.
i(
10 MR. CUMMING:
We understand what your position is.
11 FEMA's position is that this whole line of questioning is 12 irrelevant.
i 13 Witness may answer to the extent he has knowledge
- +
14 if he remembers Intervenor counsel's question.
15
' MR. MILLER:
I'm counsel for Suffolk County, Mr.
16 Cumming.
17 MR. CUMMING:
Are you an Intervenor, Mr. Miller?
18 Are you not an Intervenor?
19 BY MR. MILLER:
(Continuing) 20 Q
Mr. Donovan, do you remember my question?
21 A
I believe your question is, who prepared the 22 scenario.
The scenario was prepared by LILCO and reviewed by O
x s.
44 i
s, J
1 FEMA and the NRC.
2 Q
Would you look please at the next page?
It would 3
be Page 7 of the document.
At the top it says " Controller i
4 and Simulator Organization."
5 The fourth line of the text, Mr. Donovan, refers
(
6 to control messages.
Just a point of clarification.
Is 7
control message the same as the free-play message?
8 A
Yes, it is.
9 Q
And that sentence also talks about -- well, it f
10 basically says that control messages will be input to 11 designated LERO exercise participants.
l' C:)
12 Do you see that?
l t
13 A
Yes.
14 0
I take it, Mr. Donovan, that these LERO exercise 15 participants would, therefore, have been known in advance by 16 certain persons; is that correct?
Known in advance of the 37 exercise?
18 MR. CUMMING:
Witness may answer to the extent he 19 has knowledge.
20 THE WITNESS:
The position was known, not the 21 person.
It was our intent to see that the exercise messages 22 which represented certain events would be input through normal O
l
i 45 i
/~3 i
kJ t
I channels as designated in the LILGO/LERO pl' n.
And, therefore, a
i 2
the messages contained input points designated by position.
i 3
BY MR. MILLER:
(Continuing) 5 i
c4-Q And, again the persons or the positions designated Y
'I 5
in advance would have been known only to FEMA prior to the j
6 6
exercise, correct?
7 A
That's correct.
J II 8
Q Could you tell me, Mr. Donovan, why it is that the i
9 input of these free-play messages went from the FEMA team
{
10 leaders to the controllers and then to the participants?
I 11 Why was that the structure of the input of the 12 messages?
i 13 MR. CUMMING:
Witness may answer --
P P
14 THE WITNESS:
I believe that the --
15 MR. CUMMING:
-- to extent of his knowledge.
16 THE WITNESS:
I believe that the messages were multi-part(Oy*d 6
P dow t 5 f and from the purpasca that they were to create 17 conditionsthatweretobeevaluatedbytheteam[the 18 evaluationteam)-iftheevaluationteamwasnotinplace,it 2 }l) 19 20 made no sense to input messages to the players to respond to.
21 So, the team leaders of the evaluation teams were i
22 to acknowledge to the designated controllers that they were l
i eg.
e-,
- um-
-r
.-.,,7--
n-
46 O
1 ready to evaluate the initiating events.
The ground rules 2
that we developed with the Licensee.specified that only 3
controllers would input messages to players, not evaluators; 4
therefore, the nature of the text that you are referring to 5
is included in our plan.
6 BY MR. MILLER:
(Continuing) l 7
Q Towards the bottom of that page,'there is a 8
reference to progress reports that Mr. Weiss would make to 9
you during the course of the exercise.
10 Do you see that reference there?
i 11 A
Yes, I do.
I O
12 Q
Did Mr. Weiss make any such progress reports to i
13 you on the day of the exercise, do you recall?
j 14 A
Yes, he did.
15 Q
Do you recall generally the nature of those re-16 ports that were made to you?
17 MR. CUMMING:
Witness may answer.
18 THE WITNESS:
In general, if I may, I would like 19 to describe what we were trying to achieve and then I could 20 describe as my memory will allow me to recall the nature of 21 his progress reports.
22 One of the conditions I was asked to create was the O
p 47
}
t O
1 opportunity for the FEMA evaluators to determine whether the 2
LERO plan could accommodate interface between state and local r
3 government representatives.
Therefore, we created conditions
. 4-for telephone contact and telephone interface-, personal contact h
5 and personal interface.
6 Mr. Weiss was put in a position to be 'idua control-7 ler over the simulators who were establishing and maintaining
[
8 telephone contacts.
Due to the physical capabilities of the 9
buildings available to.us, we had to set this location up e
10 in a location other than where I was at during the exercise.
l l
11 So that the reports that he made to me during the l
12 day of the exercise were based on the nature of whether the I
13 phones were working, phone contact was made, and the nature i
14 of the discussions surrounding those phone contacts and inter-15 faces.
16 BY MR. MILLER:
(Continuing) 17 Q
And I assume, Mr. Donovan, that during the course 18 of the exercise you in turn provided reports to Mr. Kowieski; 19 is that right?
20 A
I only saw Mr. Kowieski once for a brief period of 21 time during the exercise.
He was in a roving mode of opera-22 tion where he attempted to visit the various locations and O
+m y
---=w.-p---,.
+v._
um_.
w
---g--.-
--r w-
m,-w
48 t
()
1 observe the exercise in different stages of~ response at these 2
locations.
3 So, no, I did not report to him continually during 4
the exercise.
I had a responsibility to see that certain 5
things were done, and I think he had the confidence that I 6
would see that those things were done.
7 Q
I was just referring to that last sentence of the 8
paragraph where it says that you would provide reports to the 9
FEMA RAC II Chairman on the actions of the controllers.
10 You are telling me you did not do that simply 11 because you did not see Mr. Kowieski during the course of the l
L.)
12 exercise, correct?
l 13 A
Correct.
14 Q
Mr. Donovan, you were at the LERO EOC, correct?
15 A
That's correct.
16 Q
Were you there all day?
17 A
Yes, I was.
18 Q
And, you were in the FEMA command cell, correct?
19 A
No, that is not correct.
20 Q
Where were you?
21 A
I was at the LERO EOC.
22 Q
Was there an area of the EOC designated for your f')!
49 9
s O
1 use, designated as the command cell?
2 Do you know?
3 A
No, that is not correct.
l 4
4 Q
Did you move about the entire EOC during the course i
5 of the day?
6 A
Yes, I did.
7 Q
There was also --
8 A
There was a desk with a telephone on it which was 9
manned by a FEMA person who took calls or paged me if it U
l l
10 was necessary to respond to telephone calls.
But, I was not f
11 normally at that position, at that desk I should say.
O 12 Q
There was a location that was designated as a 13 FEMA command post, I believe, on the day of the exercise; is
- t 14 that correct?
15 A
Yes, that is correct.
16 Q
Was that command post located at the Brookhaven 17 National Laboratory?
18 A
I believe it was.
I did not physically visit the 19 facility.
It was my understanding that that is where it was 20 located.
21 Q
Do you know, Mr. Donovan, what the function of the 22 FEMA command post was on the day of the exercise?
O
50 1
MR. CUMMING:
Witness may answer.
2 THE WITNESS:
It's my understanding that the pur-J 3
pose of the command post was to insure that the evaluators
.4-moved -- we had evaluators who were at fixed assignments and evaluatorswhowereatrovingassignments,ptwastocoordi-
/JP 5
r 6
nate the movement of the evaluators who had multiple assign-7 ments.
8 BY MR. MILLER:
(Continuing) 9 Q
Would you look please down at Page 9 of the 10 exhibit which is entitled at the top, " Controller Instruc-t 11 tions and Reponsibilities?"
l 12 Do you have that page, sir?
f l
13 A
Yes, I do.
l 14 Q
At the bottom, it talks about controller responsi-15 bilities and it says, " Prior to exercise commencement, all 16 Controller communications will be tested..."
17 Do you see, that sir?
18 A
Yes, I'do.
19 Q
Was this, in fact, done prior to the Shoreham 20 exercise?
21 A
Yes, it was.
22 O
When was that?
When were these tests conducted?
O
51 0
1 A
In two modes of communication, one of which failed 2
so we relied on the backup system..The backup system was 3
telephone lines that were in place.
The primary system was 4
to be a two-way radio system that was provided by FEMA which ti did not allow us to discuss with the locations we had pre-5 6
viously designated, so we established phone contact with the 7
controllers at the designated staging areas ~and at the LERO 8
EOF, excuse me, the LILCO EOF.
9 So, I established contact with all my controllers 10 prior to the start of the exercise, n
11 Q
On the day of the exercise?
l I
O' 12 A
On the day of the exercise.
13 0
When did you learn that the two-way radios were l
t 14 not going to work?
Was that the day of the exercise?
C 15 A
That's correct.
The radios were not given to us 16 until the night before the exercise.
17 At that time, all of us_were in one room.
We were 18 not in the locations from which we were to try to communicate 19 with each other until the day of the exercise.
20 Q
Was it ever determined why the radios failed?
21 A
It may have been, but I have never been given an 22 answer or an explanation.
O
52 I
Q At the bottom of this page, Mr. Donovan, it also i
2 states that controllers were to comply with instructions from 3
the LERO controllers as well as the FEML senior controller, 4
yourself.
5 Now, why is it that FEMA controllers were to comply 6
with instructions from LERO controllers?
7 A
The LERO controllers were inputting the major 8
exercise initiating events and other messages, and that was 9
basically to establish a harmonious working relationship with
.i' 10 the controller organization in place and under the control of 11 LERO or LILCO.
($)
12 Q
Are you telling me that you wanted to'make sure i
i i
13 that the free-play messages that were input did not intefere j
14 with the initiating events that were being input by LERO?
15 A
That's correct.
16 Q
If you would look at the next page of the exhibit, 17 Mr. Donovan, there is a reference towards the top of the page 18 to contingency messages.
19 Do you see that?
20 A
Yes, I do.
21 Q
could you just tell me what a contingency message 22 was, or is?
3 O
4
___---,._,m,
- r. _....
m..
.~._y
_~
_._m_.
53 0
1 A
A contingency message was -- an example of the 2
contingency message would be something that would be input 3
in the event the initial message did not cause the desired c 4 --
actions, response or occasioned to occur or to be perceived to i
5 occur.
6 Q
Do you know if any contingency messages were used 7
during the Shoreham exercise?
8 A
Yes, I do.
9 Q
Well, were any used?
10 A
One was used, li 11 Q
What was it?
12 A
It was the impediment to an evacuation route.
I i
13 was the official responsible for inputting that message.
[
14 Q
Is that the gravel truck impediment or the fuel 15 truck impediment?
16 A
The fuel truck impediment, I believe.
17 Q
Could you tell me why it was necessary to use a 18 contingency message in that event?
19 A
I can give you my recall of why I thought it was 20 necessary.
21 MR. CUMMING:
Witness may testify to the extent 22 he has recall.
O
i 54 i
i 1
THE WITNESS:
The initiating messages were input, 2
responding participants did not respond in the fashion that 3
we considered necessary to allow the conditions to be demon-4 strated.
We had evaluators in place, one of which had a 5
multiple assignment.
6 So, after a sufficient. time and discussion with 7
the LERO senior controller and the FEMA LERO EOC team leader, 8
we input the message a second time at a higher level within.the t
9 LERO response organization in order to see if it would be 10 a response to an initiating event.
/
11 BY MR. MILLER:
(Continuing) l 12 0
When the contingency message was input, did it 13 generate the appropriate response?
14 A
Yes, it did.
15 Q
Do you recall what level the contingency message 16 was input?
What was the position?
17 A
I would have to refer to the message myself, but my 18 recall is basically the evacuation coordinator level with 19 the information that he had impediments to two evacuation 20 routes and then to see what actions the organization would 21 take with regard to those impediments.
22 Q
Do you have the text of the contingency message?
O
l 55 i
o 1
A No, I do not.
It's the same messages that were 2
in the system.
3 0
It's the same free-play message regarding the fuel 4
truck but it was just given to a higher LERO position?
4 5
A That's correct.
i 6
Q Do you recall the initial position the message went 7
to?
8 A
I would have to refer to the message.
I don't 9
recall right now.
10 0
Could you do so relatively quickly?
f 11 A
Okay.
Fine.
S
(
12 (The witness is looking through documents.)
i 13 MR. MILLER:
Let's take a break, five or ten 14 minutes.
15 (Whereupon, a recess was taken at 10:10 a.m.,
16 to reconvene at 10:22 a.m.,
this same day.)
17 BY MR. MILLER:
(Continuing) 18 Q
Mr. Donovan, have you had a chance to find the 19 free-play message you were looking for?
20 A
Yes.
They were the two impediment messages, one 21 for traffic control point 41 and one for traffic control 22 point 124.
O
56 0
1 Q
And, at what level were those messages input, 2
do you know?
3 A
To the evacuation route coordinator in both cases, c4-That was the initial input.
5 Q
Can you think of any other contingency messages, o
Mr. Donovan, that were used during the course of the Shoreham 7
exercise?
8 A
No.
We had one for prepared but we did not have 9
to use it.
10 0
What did you have one prepared for?
?
I 11 A
That was on the eventuality of certain zones were C) 12 not included in the evacuation recommendation.
I 13 Q
I'm sorry, in the eventuality that certain zones 14 were not included?
Did you end up not having to use that 15 because LERO ended up advising all zones to evacuate?
10 A
Yes.
17 Q
Did FEMA input any verbal contingencies into the 18 exercise, verbal contingency messages?
19 A
No, other than the ones that were referred to.
20 When we referred to them as higher level, we referred to them 21 verbally.
We did not re-interject the written paper.
22 Q
So, you are saying that a FEMA controller would O
57 J
l
()
i i
simply go to a higher LERO position and verbalize the text of i
2 the initial free-play message?
3 A
No.
The two impediment messages that were initially 4
input were re-input verbally by myself at a higher level, and 1
5 those were the only contingency messages that were verbally 6
input to the exercise.
7 Q
Mr. Donovan, let me show you a two-page document 8
which we will mark as Donovan Exhibit 3.
9 A
Yes.
10 (The document referred to was marked
[
11 as Donovan Deposition Exhibit 3 O
inaaxx 12 for identification.)
13 DY MR. MILLER:
(Continuing) l 14 Q
On the first page at the top it says " Appendix E, 15 Controller Log, Assignment:
LERO-EOC."
16 At the bottom right-hand corner is the date of 17 12/13/86.
Have you ever seen this document before, sir?
18 (The witness is looking at the document.)
19 A
No, I have not.
20 Q
Do you know if this was the log for a FEMA control-21 ler?
22 A
It was probably a consolidated log among all the O
i
,E 58 1
i i
)
l 1
FEMA controllers.
But, all the individual logs were collected 2
and reviewed by myself and turned over.
So, someone recon-4 i
3 solidated all of them and put them under one.
4 Q
Who did that consolidation?
t 5
A I don't know.
I have no knowledge.
4
- )
s 0
If you look at the far. left column, Mr. Donovan, l
j 7
there are three instances where it's noted contingency message l
and on the second page there is one instance of a contingency 8
i g
message.
l l
t i
i go Does that indicate to you that there were four i
i
.I contingency messages used during the course of the Shoreham 11
()
exercise?
12 A
That's correct.
j.
i 13 I
0 Can you explain why this document indicates four 14 1,
and your testimony says there was only one such message?
l 15 A
It's incorrect.
Their summation is incorrect, I i
16 P
37 should say.
The first three contingency messages all --
l 3e listed on this document, they all refer to the traffic impe-19 diments.
The fourth contingency message was the message that I'm also familiar with and it was in response to a cuestion 20 i
generated by a player which came to myself.
I did not have l
21 1
22 the answer, so I turned to LERO's controller and he had the l
)
i
f l
59 I
O 1
answer and we just logged it on this log as a response to a 2
question.
i 3
That is also the purpose of a controller, to provide s
. 4 information if player's request it.
So, the first three on 5
Page 1 of 2 of Exhibit 3 are all relating to the impediment issue.
The item that you are referring to as a separate 6
7 contingency mescage on Page 2 has to deal with the response to a
a question asked by the response organization.
We did not g
have the answer.
We got the answer provided by LERO.
10 0
Well, let's start with the last one first.
Do you 11 recall which LERO player asked the question that you were C:)
i 12 not able to respond to?
13 A
No, I do not.
h 14 0
Do you recall the substance of the question that was asked?
15 A
After reviewing this summary, I do.
16 17 0
What was the question?
18 A
They wanted to know the status of the evacuation 19 and how many remaining persons may be within the plume EPZ p rtion that was recommended for evacuation.
20 21 Q
And the LERO controller was able to provide that 22 information; is that correct?
O
+h
60 i
i O
1 A
Right.
l 3
)
2 Q
Nou, looking at the first page of Donovan Exhibit j
3 3, I thought previously your testimony was that the impediment
)
4 that required the input of a contingency message involved the i
5 fuel truck; is that correct?
j l
I 6
A Yes, that's what I said.
7 0
Now, this Exhibit 3 would indicate that a contin-3 8
gency message was used with respect to the gravel truck 1
t 9
impediment; is that correct?
4 f
to A
I believe the first note at 12:14 says to blocked
[
6' 11 routes.
To me, it was both impediment messages.
O 12 The second reference on that page at 12:25 is to f
13 the actual location of the gravel truck.
In this case, it
[
14 was due'to the location of our evaluator who was in the field i
15 simulating the location of the gravel truck, so we did not l
f 16 actually move a gravel truck out and block the highway.
l 17 The LERO response organization was attempting to t
18 coordinate their response to this simulated incident and to i
19 direct their responders to the location where we had the 20 evaluator located.
And, we could not get the two to meet in 21 the field.
22 And that was the reason for the input in the 12:25 O
62 0
1 Q
Okay.
Now, the second, contingency message noted 2
on this exhibit refers just to the gravel truck.
And, is it 3
your testimony that that really involved trying to coordinate c4 the coming together of the FEMA evaluator and the LERO j
5 response?
6 A
Ye8-7 Q
What is the last contingency message there, Verbal 8
Times of Accidents?"
What does that refer to?
s A
I think they wanted to know the initial time of the accident.
10 11 Q
Who wanted to know that?
{
(
A The evacuation coordinator.
12 13 Q
Is it fair to say that a contingency message is a 14 prompt?
A No.
15 16 Q
How would you distinguish a contingency message 17 from a prompt?
18 MR. CUMMING:
Objection as to witness' understanding I
19 of the word " prompt."
20 But witness may answer to the extent he has 21 understanding.
22 MR. MILLER:
Well, let's make sure we have an O
--T
--e i--
r-e---wy-c=
p-vr-y=-----
-w m--er--
-*m
--v--
-'-r-
-w c---
g-
63 O
1 understanding, Mr. Donovan.
2 BY MR. MILLER:
(Continuing) 3 Q
Is the term " prompt" a term that is f amiliar to you 4
in the context of FEMA-graded exercises?
5 A
I would prefer to define what I understand " prompt" 6
to be.
7 0
Okay.
Why don't you tell me what that understand-J 8
ing is?
j 9
A We would instruct evaluators not to ask leading to questions which would -- could be or should be interpreted.
I 11 That is, they should not ask responders what you would do or
()
12 why haven't you done something in response to the initiating I'
13 event.
That is what I would call a prompt.
[
14 A contingency message is, in this case, the re-input 15 of an initiating event at a point other than it was initially 16 inputted to see what response the organization would do to that 17 initiating event.
18 Q
Is it fair to say that a contingency message has 19 as its goal to provoke the action that would be appropriate 4
20 and desired by the FEMA -- by FEMA during the exercise?
21 A
I wouldn't use those words, but I would agree that 22 you are basically defining what we had in mind.
We wanted to
64 i
O 1
create the conditions through these free-play messages that 2
would, therefore, stimulate situations, therefore causing the 3
LERO response organization to respond in a fashion that our C
4 evaluators could e aluate.
4 5
Q And, in your mind, a prompt is a term restricted to F
6 FEMA evaluators themselves; is that correct?
s
[
7 A
One which we caution or -- at least, I did not have 8
anything to do with the training of evaluators, but if it were 9
my region we would caution and instruct our evaluators not to 10 ask leading questions or prompts.
i 11 Q
Mr. Donovan, were any free-play messages prepared
?
(
12 for the Shoreham exercise but not used?
l l
13 A
Yes, the one I previously referred to.
i 14 Q
I'm sorry.
Which one was that?
15 A
The one on evacuation zone.
I 16 Q
Other than that free-play message, any other FEMA 17 free-play messages that were not used?
18 A
No.
endTl 19 Q
Mr. Donovan, if you would go to the numbered Page 7 20 of Donovan Exhibit 27 Do you have that in front of you, sir?
21 A
Yes, I do.
22 Q
All right.
Paragraph Number 9, "Some exercise O
r I
65 l
t I
participants may insist that certain parts of the scenario are 2
unrealistic."
I 3
Do you see that statement, sir?
, A Yes, I do.
I 5
Q Do you know if that happened during the Shoreham I
6 exercise?
I 7
A Not to my knowledge.
8 Q
Now, Mr. Donovan, if you look at the next to the l
'i 9
last page of the exhibi,t which is numbered Page 14 at the top,
}
10 midway down there is discussion about potential conflicts of
,fi 11 interest between FEMA's efforts and LERO's efforts at the fi l
12 Shoreham exercise.
l I'
13 Do'you see that discussion?
14 A
Uh-huh.
15 COURT REPORTER:
Your answer was yes?
16 THE WITNESS:
Yes, assuming he is referring to the 17 second and third sentences of that full paragraph on Page 14.
18 BY MR. MILLER:
(Continuing) 19 Q
Were there any such conflicts that actuallysdeveloped 20 during the course of the exercise, to your knowledge?
21 A
To my knowledge, there were no conflicts that i
22 developed during the course of the exercise with regard to our
!b
)
I s
I 4
.--c--,'7v..,y,
,.,_m
.,n---
,,.,%_.,y,,,.,,,3 o
y
,,-,__m-_
w y
.-.s_--
,,w.,
66 O
1 free-play messages and scenario messages.
2 Q
Were there any conflicts that developed in any 3
other context during the exercise, to your knowledge?
4 A
Not to my knowledge.
5 0
And I gather, Mr. Donovan, that the next to the t
6 last sentence of the paragraph -- actually the last two
-l 7
sentences, where it basically defines LERO's responsibilities 8
with respect to the exercise scenario and FEMA's responsi-9 bilities with respect to the input of exercise messages and 10 data, is that a fair characterization of how the exercise 0
11 was conducted, in your opinion?
A Yes, it is.
12 t
13 0
And so, therefore, LERO itself was in charge of
[
the extent of the exercise play and demonstration; is that 14 correct?
i 15 16 A
I believe my answer would be yes.
They created 17 it, the LERO control organization created initiating events; 18 FEMA's free-play messages created initiating events.
How 19 they were responded to was the responsibility of the players 20 and, to my knowledge, from our perspective it was no prompt-21 ing to cause players to proceed any farther than they wished 22 other than the contingency message which we have already O
67 i
O 1
discussed.
I wouldn't categorize that as prompting; I would 2
just categorize that as a re-input of a free-play message.
3 Q
Mr. Donovan, you stated earlier that Mr. Kowieski, 4
Mr. Baldwin and yourself prepared the free-play messages for
?
5 the exercise, correct?
6 A
That's correct.
7 Q
Did anyone of the three of you have the responsi-8 bility for the initial drafting of those free-play messages?
9 A
I b e l i-e v e I r e c a l l Baldwin drafted the first 10 draft.
t l
11 Q
And, after Mr. Baldwin drafted the first draft did O
12 you then review those drafts?
13 A
That's correct.
i 14 O
And, was Mr. Kowieski the last link then in the 15 scheme of things, in terms of approval of these free-play 16 messages?
17 A
That's correct.
18 Q
Do you recall if you made any significant changes 19 to the messages draf ted by Mr. Baldwin?
20 A
It's my belief that we changed the designated input 21 Point for several of the messages to correctly reflect the 22 point that they should be inputted into the response O
v
i e
68
(
1 organization.
They may have changed some of the text, too, 2
based on our observations of, I believe, the January 30th 3
drill.
24-Q Is it fair to say that essentially though the 5
messages as drafted by Mr. Baldwin were used by FEMA during 6
the course of the exercise?
?
I 7
A Yes.
8 Q
Do you know what criteria Mr. Baldwin used in 9
preparing these free-play messages?
10 A
Other than addressing the objectives and creating 11 conditions for the objectives to be evaluated and his review C:)
i 12 of the LERO response organization, I know of no criteria.
J l
13 The format of the messages, that is the form that
'l 14 they were used is a work product of FEMA Region II.
15 Q
I don't understand.
Is the work product of FEMA 16 Region II?
17 A
They have a form that you already have examples 18 of which calls for evaluator sign-offs, comments.
That's the 19 work product of FEMA Region II.
20 The message itself, the text of the message, I 21 believe was a joint effort.
My input was on the text of the 22 message and on the "To" aspect of the message; to whom the O
r-f 69 I
- (
()
i 1
message was to be inputted to.
[]
2 Q
Do you know for example, Mr. Donovan, why it is 3
that -- the basis for Mr. Baldwin's deciding to simulate
.I h
4 three siren failures?
5 Why three?
Why not two, why not ten?
6 A
No, I have no knowledge.
[
t 7
Q Do you know why it is that Mr. Baldwin decided l
8 that two simulated traffic impediments was a sufficient number 9
to input into the exercise?
(
10 MR. CUMMING:
FEMA counsel objects to this line
]
11 of questioning.
But, witness may answer the question to the O
12 extent he has knowledge.
13 MR. MILLER:
What's the basis for the objection?
[
a 14 MR. CUMMING:
Relevancy.
l 15 MR. MILLER:
Well, it's relevant because our 16 contentions directly deal with such issues as the scope of the 17 exercise.
18 MR. CUMMING:
We discussed it previously this 19 morning, but FEMA counsel does not believe it's relevant.
20 That's the basis for its objection.
21 MR. MILLER:
Based upon your motion for reconsidera-22 tion with the Board?
i 70 1
(:)
1 MR. CUMMING:
That's correct.
2 THE WITNESS:
Could you. rephrase or restate your i
3 question?
4 MR. MILLER:
I will try to present examples of 5
various aspects of the exercise that were looked at during l
6 the Shoreham exercise.
l 7
5 1
8 BY MR. MILLER:
(Continuing) 9 Q
I have asked you about the failed sirens, and now 10 I'm asking about traffic impediments.
i I
l 11 And, my question I think is, do you know why it is l
)
12 that Mr. Baldwin determined that two traffic impediments were 13 sufficient for purposes of the Shoreham exercise?
14 A
No, I do not.
15 0
would you answer me the same with respect to the 16 number of buses that were observed by FEMA during the exer-17 cise?
18 MR. CUMMING:
Same objection.
Witness may answer 19 to the e:: tent he has knowledge.
(
4 20 THE WITNESS:
I prefer to say that the objectives 21 were agreed upon before I was given this assignment.
I was 22 asked to review and input into these exercise messages to see C) 1 1
1
71 Ov 1
that they were appropriate.
Why.certain bus routes were t
2 picked, we attempted I believe to make a rational selection
]
3 to give opportunities to be observed in each area where we
.4 had evaluators.
5 BY MR. MILLER:
(Continuing) 6 Q
Well, with respect to the number of buses and the 7
number of bus routes and the number of ambulances and the s
8 number of ambulance routes that were looked at during the 9
course of the Shoreham exercise, is it fair to say that you
)
10 have no knowledge regarding the criteria used by Mr. Baldwin 11 in making those judgments?
f
[
\\
12 A
I don't know if Mr. Baldwin made the judgment.
l h
13 Mr. Baldwin had the assignment to write the text to the 14 messages.
15 0
Is it fair to say that you do not know why Mr.
16 Baldwin, or whomever did it, chose the numbers of buses and 17 ambulances and routes that were actually observed during the 18 Shoreham exercise?
19 A
Yes, that's fair to say, I didn't have knowledge.
I 20 I think I would like to add that there was an operational 21 requirement from the Licensee's aspect, depending on what we 22 asked te be demonstrated during free-play that they had a O
V
72 i
O 1
fiscal responsibility to pay for the actual movement of.
2 buses and the actual movement of ambulances.
So,.those 3
discussions and agreements on requirements were the condi-4 tions that then set the outside parameters fo.r what aspects were asked to be demonstrated.
5 6
Q Who had discussions with LILCO regarding the cost 7
parameters of the exercise, to your knowledge?
8 A
To my knowledge, it was Mr. Kowieski.
I don't l
l 9
believe it was cost parameters.
It was more referred as to to the number of buses that would have to be hired for the given i
11 day, et cetera.
(:)
12 O
And, Mr. Kowieski had this discussion with LILCO, l
13 to your knowledge?
i 14 A
Yes.
,l 15 0
Who at LILCO was involved in those discussions; 16 do you know?
17 A
It would be either Mr. Daverio or Mr. Daverio's 18 staff.
They were given the responsibility to develop the 19 scenario.
20 0
Can you recall approximately when it was that you 21 worked on the free-play messages, Mr. Donovan, in terms of 22 your review of those messages?
O 4
)
73 O
1 A
Approximately, it was between January 13th and 2
January 31st of 1986.
I was in Region II's offices, and in 3
the vicinity of Region II's offices, for.those three weeks.
4 Q
During those three weeks, you reviewed the free-5 play messages prepared by Mr. Baldwin, correct?
6 A
That's correct.
7 Q
I assume that you worked on the controller and 8
Simulator Plan, correct?
9 A
That's correct.
10 0
What else did you do during that three week period L
11 regarding the Shoreham exercise?
f
()
12 A
Those were basically my duties.
I I
i 13 Q
Can you recall anything else?
14 A
As I've already mentioned, we attended a drill, 15 I believe, January 30th.
We participated with -- I participated 16 with Region II at several meetings with LILCO's team that was 17 developing the scenario to become more familiar with their 18 plan and procedures and method and style of conducting 19 OXercises.
20 And I worked with Mr. Kowieski and Mr. Baldwin and 21 staff in developing the Controller and Simulator Plan.
22 0
Was there a draft Controller and Simulator Plan O
74 i
prepared prior to your becoming involved in the Shoreham 2
exercise?
3 MR. CUMMING:
FEMA counsel objects to the line
<4 of questioning.
But witness may answer to the extent he has 5
knowledge.
6 THE WITNESS:
I have no memory of a specific plan.
7 That was the assignment I was given to develop.
8 BY MR. MILLER:
(Continuing) 9 Q
So, to your knowledge, Theodore Barry & Associates 10 had not prepared any draft Controller and Simulator Plan; 1
l 11 is that correct?
()
12 A
To my knowledge and recall.
13 0
They had not?
14 A
Right.
15 MR. MILLER:
We will mark as Donovan Exhibit 4 a 16 three-page document dated 1/15/86.
It appears to be a 17 memorandum from Roger Kowieski for the record, subject:
18 Shoreham Exercise Planning Meeting.
19 (The document referred to was marked 20 as Donovan Deposition Exhibit 4 indexxx 21 for identification.)
22 i
w
75 O
1 BY MR. MILLER:
(Continuing) 2 Q
Mr. Donovan, have you ever seen this memorandum 3
before?
4 (The witness is looking at the document.)
4 5
A I don't recall receiving it.
That's not to say tha1.
6 I haven' t seer. it.
I'm not an addressee.
7 O
This memorandum does reference, however, your 8
attendance at meetings on January the 14th and 15th in New l
9 York City, doesn't it?
10 A
Yes, it does.
l 11 Q
Do you recall attending those meetings?
f O
12 A
Yes, I do.
~
I 13 Q
It says,in this memorandum that the purpose of 14 the meeting was to review the progress made in exercise 15 Preparation.
16 Is that a fair characterization of the meeting's 17 purpose?
18 A
Yes.
19 Q
This apparently was at the time that you were 20 announced to be the lead controller for the Shoreham 21 exercise.
Do you agree with that?
22 A
Yes.
O
1 i
76 3
i 1
Q Now, it says at the bottom, Mr. Donovan, that the 2
draft control plan and simulator plan prepared by TBA -- and f
I believe that's Theodore Barry & Associates -- were reviewed f
3 i
i 4
and modified by Mr. Donovan, Bernie Weiss and.Cheryl Sakenas.
l l
?
5 Do you see that statement?
l 6
A Yes, I do.
i r
i i
7 Q
That would indicate that there was a draft plan
[
i 8
prepared by Theordore Barry.
Does that refresh your recol-l J
l 9
lection in this regard?
[
l i
l 10 A
That's what the sentence says, yes.
1:
11 Q
Does that refresh your recollection, though, as l
O l
12 to whether or not there was such a draft plan prepared by i
13 Theodore Barry & Associates?
14 A
I did not consider it a draft plan.
There was f
i f
15 documentation of which I was only able to utlize one page.
i 16 So, I would say that the sentence is not a correct t
I 17 summation.
I reviewed documentation and did not consider it i
18 to be adequate and had to start from scratch.
i 19 Q
Do you recall what documentation that you reviewed i
20 that had been prepared by Theodore Barry & Associates?
l 21 A
I recall briefly that it was a package of paper 22 that was presented to me when I arrived in Region II on
(:)
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77 p
h 1
(.
January 14th.
I 1
2 Q
Yes, but do you recall ' tMe contents of that 3
package of paper?
.- 4 A
It had the exercise objectives and documentation
[
5 on the State of New York and other counties, response organiza-6 tions for radiological emergencies.
l 7
Q Do you recall anything about the documentation about 8
the State of New York that you were just referring to?
9 A
No, I don't recall any specifics.
10 Q
And, with respect to this draft control plan and 1
t 11 simulator plan prepared by Theodore Barry & Associates as l
(
i 12 referenced by Donovan Exhibit 4, do you recall anything about I
13 that draft Controller and Simulator Plan, other than the fact 14 that you were only able to use one page of it?
A The only thing I recall, it was my opinion and 15 recommendation -- and I made a recommendation that I start 16 I
l 17 over from scratch, that it was not a document that could be revised and be workable with the time constraints remaining.
18 19 Q
And, why is that you concluded that you needed to 1
start from scratch and the document prepared by Theordore i
20 i
21 Barry was not workable?
l I
MR. CUMMING:
FEMA counsel objects to this line 22 m
I 78 l
i 1
of questioning based on its relevance.
2 But witness, to the extent he has memory and 3
knowledge, may testify.
]
4 THE WITNESS:
Given the assignment to be the senior
(
5 controller, I considered the document did not address what was a
\\SSwCha95tGr4omErd N
6 necessary to be, in my understanding of the issues Therefore, 7
it was my opinion and recommendation that I' start anew rather l
8 than to extensively revise the existing document.
9 BY MR. MILLER:
(Continuing) 10 0
What was your understanding of the issue?
a I
11 A
The issue was that I was to be a senior controller, O
12 and I was to be responsible for the input of free-play li 13 messages and for the conduct and activity of the simulators.
14 Q
And what did the Theodore Barry document state with 15 respect to any of those areas?
16 A
I can't recall any specifics other than the fact 17 that it was my opinion that it did not address the issues, 18 and it would be prudent with the time remaining to start anew.
19 Q
So, your only recollection is that the document 20 prepared by Theodore Barry would not be helpful to you, given 21 your assignment as the senior controller for the exercise, 22 correct?
O
l 79 j
i i
O 1
A That's correct.
2 Q
Do you recall why it is, Mr. Donovan, that you --
3 let me just back up.
I think we've reached an understanding j
4 that Theodore Barry & Associates was, prior.to.your involvement 5
in the Shoreham plan, going to conduct the role of senior 6
controller at the Shoreham exercise; is that correct?
7 A
That's my understanding of the situation.
8 Q
And, it was Mr. Bill Stokes at Theodore Barry that 9
was going to, in fact, serve as the senior controller at the j
10 exercise; is that correct?
i 11 A
My recall is not that specific as to what official l
(
12 at Theodore Barry was to serve as senior controller.
l 13 Q
Well, what is your recall with respect to why it 14 is that you were asked to serve as senior controller in lieu 15 of Theodore Barry & Associates?
16 A
I was asked to assist Region II.
When I arrived 17 at Region II, I was asked to assume these responsibilities.
l 18 I don't know the reasons why.
19 Q
Did you know that you were, in fact, replacing 20 Theodore Barry & Associates?
21 A
Not until I arrived there.
22 0
Well, when you found that out when you arrived
()
i
61 i
I iO I
message.
I 2
Q Well, let me make sure I understand, Mr. Donovan.
3 These three contingency messages noted on Page 1 of Donovan
{
4 Exhibit 3, did they all relate to both of the traffic impedi-3 5
ments used during the Shoreham exercise?
6 A
That's correct.
i 7
Q Are they separate from the contingency message you 8
previously testified about regarding the fuel truck impediment?
9 A
No.
They are similar.
They are the same, i
10 0
They are similar or the same?
I 11 A
They are the same.
(
12 O
Now, the first one says, " Verbal message, re:
i l.
)
13 Blocked Routes to Evacuation Coordinator."
That, I assume, is F
I 14 the one that you previously mentioned to me, the one that you i
15 input verbally to the evacuation coordinator because the 16 evacuation route coordinator did not respond as he should have.
17 A
That was both, that was for both messages.
18 0
That was for both traffic impediments?
19 A
That's correct.
20 Q
Okay.
i l
21 A
The one I remembered most was the fuel truck 22 because that's the one that they played most.
I
d h
41 80 l
Il T
b 1
there, were you told at any time why it is'that you were 2
replacing Theodore Barry & Associates?
p 3
A No, I was not.
1 A
c4-Q Did you ever ask?
h t
5 A
No, I did not.
,F 6
Q Is it fair to say, Mr. Donovan, that it's your j
7 testimony today that you have no understanding whatsoever as a
8 to why you became the senior controller for the Shoreham t
i 9
exercise rather than Theodore Barry & Associates?
i
(
10 Is that your testimony?
l 11 A
That's correct.
I might add that there were g
12 numerous press stories at that time in the media which I had 13 access to.
i I
14 I reviewed the correspondence file maintained by s
15 Region II which did not go into the reasons why, since it was 16 not a Region II contract.
It was a FEMA headquarters contract.
17 I did not have access, nor have I ever reviewed any corres-18 pondence files from FEMA headqua-ters relating to this contract, 19 Q
So, you are telling me that you read in the papers 20 when the papers were talking about the Theodore Barry contract; 21 is that what you are saying?
I 22 A
Yes.
- O 1
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1 Q
And you looked at press releases on that subject; 1
2 is that right?
[
3 A
That's correct.
)
4 f
4 Q
But, you didn't bother to even ask.anyone why it 9
5 is that you were being brought in and Theodore Barry was 6
going out?
i{
7 A
I didn't consider it relevant to my assignment.
8 I was there to help, to be part of the management team.
And f
1 g
that was it.
10 0
On Page 3 of this exhibit, Mr. Donovan, there is
[y I
11 reference to a conference call on January the 23rd, 1986.
All O
12 controllers and simulators were to participate in this 13 conference call, I take it; is that correct?
i e
14 A
That's correct.
5 15 0
Did you participate in that conference call?
1 A
Yes, I did.
16 17 MR. MILLER:
Now, I want to mark as Donovan Exhibit 18 5 a one-page document which is dated 1/23/86.
Again, it's a 19 memorandum from Roger Kowieski to the file,
Subject:
Confe-i 1
rence Call with Controllers and Simulators.
l 20 I
l 21 22 O
s t
l 82 1
i
(
I 1
(The document referred to was marked 2
as Donovan Deposition Exhibit 5 indexx 3
for identification.)
4 BY MR. MILLER:
(Continuing) 5 Q
Have you ever seen this document before, Mr.
6 Donovan?
7 (The witness is looking at the document.)
8 A
I believe I may have seen it, given I am not an 9
addressee.
10 0
But you are referenced as a participant in the 1
11 conference call, correct?
O 12 A
That's correct.
I 13 0
Do you recall what was discussed in that conference
[
14 call on January 23rd?
15 A
Yes, I do, in a general nature.
16 Q
Well, could you tell me in general terms what it is 17 that you recall?
18 A
The purpose of the conference call was to discuss dott withthethendesignatedcontrollersandsimulators,(s4cco) 19 20 after this conference call we had some substitutions on the 21 concept for the FEMA controller and simulator plan and the 22 nature of the work assignments and schedule of training
(
=
~
r i
83 I
1 activities during the exercise week, and the commitment that l
2 we made to them that we would provide them a copy of the j
s 3
Controller and Simulator Plan the week prior to the exercise.
l' c4-Q A commitment made to whom?
l i
i 5
A The participants at the conference call that were l
6 going -- that were designated as either a controller or a f
t 7
Simulator.
4 a
Q So, as of January 23rd I assume then that the l
I o
final version of the Controller and Simulator Plan had not 10 been completed?
I 11 A
That's correct.
12 Q
And you made a commitment to these various persons 13 who were to serve as simulators and controllers that you 17 i
14 would be getting the plan to them?
15 A
That's correct.
16 0
You said there were some substitutions made i
17 following the January 23rd conference call.
What substitu-18 tions were made?
19 A
I couldn't be specific, but I believe if you i
20 compared the names to this phone call to the names listed in i
21 the report that you will see that there are some differences.
l l
I 22 Q
Do you recall why there were substitutions made in
(}
i I
l
84 O
1 the personnel that were going to serve as controllers or 2
simulators?
3 A
No, I do not.
4 Q
Were you involved in that decision?
5 A
No, I was not.
6 Q
Do you recall if, during the conference call, on 7
January 23rd that it was concluded tha? there would be any a
substitutions made?
9 A
No, I do not.
I don't believe it was discussed.
10 0
At the bottom of Exhibit 5, Mr. Donovan, there is i
11 a reference that says, " Issues Discussed:
Background - Ilow
(:)
12 Did We Get liere."
1 13 WhaEdo'~yB'u recall a out that issue?
f 14 A
I believe Mr. Weiss is an NRC National Office G*
15 employee, designated as being the main facilitator in the 16 discussion, and I believe he covered the correspondence be-17 tween FEMA headquarters and NRC headquarters on the scope of 18 the exercise and the rationalo for simulators representing 19 state and local government as being part of this exercise.
20 0
So, the "llow Did We Get I!cre" refers at least in 21 part to how it is that FEMA found itself in a position to be 22 evaluating the Shoreham exercise on February 13th, 1986; is O
85 i
i 1
that correct?
i 2
A That's partially correct, yes.
3 Q
And the rest of the conversation in that regard i
4 I
i l
4 dealt with Mr. Weiss' discussion about the role simulators?
i t
l 5
A That's correct.
l l
6 Q
Now, underneath that --
i 4
7 A
I'm sorry.
The need for simulators, not the role 1
8 of simulators.
This would be considered an unusual assign-i 9
ment for any of the par,ticipants of this conference call.
i i
)
10 Q
What would be considered an unusual assignment?
1 j
11 A
To be a simulator or to be a controller.
C) j 12 0
Why would that be an unusual assignment?
i 1
13 A
Most of these parties, as you can tell, obviously 3
14 are NRC employees; they normally deal with on-site issues if 1
i i
15 they are assigned to an NBC evaluation team.
They do not 16 normally deal with off-site issues.
l 17 0
So, what you are saying is that the personnel 18 involved as simulators and controllers typically would not l
lo serve in such capacities at other exercises?
20 A
The bulk of these people and that's the rationale l
i 21 for part of the discuscions that Mr. Weiss discussed.
i l
22 Q
Did you feel, Mr. Donovan, that because of this O
.- - - - - _. -. - _ __=_ -.
l I
86 2
t
(
l 1
lack of familiarity at other exercises, there was a need for t
fl 2
some training for the simulators and the controllers at the l
l j
3 exercise?
4 l
c4 MR. CUMMING:
Objection as to form,. how the 5
witness feels.
1
)
6 MR. MILLER:
I will rephrase.
i 7
BY MR. MILLER:
(Continuing)
.t.
a Q
Mr. Donovan, did you believe there was a need to f
l s
have training sessions for the controllers and simulators at f
i 10 the Shoreham exercise?
Y 11 A
Yes, I did.
12 Q
Why did you think that there was such a need?
i 13 A
I would say that it would be standard practice to e
14 conduct training at any exercise for controllers and simula-1 15 tors and evaluators.
i j
16 So, we scheduled a training session for controllers i
l 17 and simulators as part of this exercise.
I i
la 0
Was there any greater need for training the simula-l 19 tors and controllers at the Shoreham exercise than at other i
I l
20 exercises, in your opinion?
21 MR. CUMMING:
Witness can answer to the extent he 22 understands the term " greater."
O
87 O
1 Tile WITNESS:
I would say there is a need for 2
training, whether --
J 3
BY.MR. MILLER:
(Continuing) 4 Q
But that's not my question, Mr. Donovan.
Was there, j
5 in your opinion, a greater need at the Shoreham exercise for
{
6 these people who were serving as simulators and c'ontrollers 7
than at other exercises you were involved in?
i 8
A I wouldn't say in reference to other exercises that 9
I've been involved with -- in other exercises that I've been 10 involved with, we have had lotr. of other exercises that I've i'
11 personally been involved in where we have had people simulating O
of ficials that they would not normally simulate and cen+tr ilers w v
12 13 who were asked to be a controller in an exercise, i
14 So, I would say there is no greater need.
15 0
So, what you are telling me is.that you have seen 16 and been involved W2th other exercises where the same scrts 17 of personnel with no background were brought in to serve as 18 controllers and simulators?
19 A
Tnat's correct.
20 Q
So, there is always a need for training because of 21 the lack of familiarity and the lack of background?
22 A
That's correct.
I would say, it's my position that O
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1 for every exercise there should be a training session for i
2 people involved in the exercise as a controller, simulator or 2
j 3
evaluator, whether we are testing an earthquake. response or a f
l 4
nuclear war response or a radiological emergency response.
i 5
Q Well, Mr. Donovan, it is referenced at the bottom
+
L
.l 6
of Exhibit 5, it says, Normal Exercise Functions, Differences 7
for Shoreham Exercise. "
.l 8
What was that discussion about?
r
.i I
9 MR. CUMMING:
FEMA counsel objects to this line of 1
i 10 questioning, but witness to the extent he has memory or recall i,
i i
j 11 may testify.
(:)
12 MS. McCLESKEY:
LILCO has a standing relevance I
13 objection and it continues.
I 14 THE WITNESS:
The issue was that there was going to 15 be two control organizations, the LILCO controller crganiza-16 tion and the FEMA controller organization.
j i
l 17 BY MR. MILLER:
(Continuing) 9 i
18 0
And, you are saying that at other exercises there
}
19 would not be but ono controller organization?
1 20 A
Normally there is just one, in the exercises that l
21 I'm familiar with.
l 22 Q
And, normally is that one controller organization i
e
]
i
i 1
I 89 q
i 1
1 the FEMA organization?
2 A
Not necessarily.
It varies.
l l
3 0
Well, what else could it be?
1
~4 A
Again, usually there is an exercise control group 5
that develops a scenario, trains the controllers and trains 6
the simulators.
Usually there is a joint group.
It varies on i
7 the type of the exercise and who is being evaluated during 8
the exercise.
9 Q
Normally, is a joint group a joint group comprised 10 of FEMA, state and local government officials?
1 l
11 A
That would be a fair approximation.
O 12 O
Would you tell me, Mr. Donovan, again -- I apologize j
i 13 if this is repetitive but I'm trying to keep it all straight
[
14 in my mind -- why it is that there were two controller organizations for the Shoreham exercise?
15
{
16 A
The desire to maintain the confidentiality of the i
17 FEMA free-play messages from the overall controller group, 18 and a desire and a need to maintain control over the simula-19 tors.
20 Q
Other than the desire to maintain confidentiality 21 of the free-play messages and the desire to control the 1
4
{
22 simulators, were there any other reasons, to your knowledge,
(
f 90 l
i O
s./
t I
why there were two control organizations for the Shoreham 2
exercise?
l 3
A No, not to my knowledge.
i 4
Q You spoke during the conference call, Mr. Donovan, 5
about message injects, simulation of state and local officials; v.
6 is that correct?
7 A
That's correct.
l 8
0 I assume that your part of that discussion was S
r 9
based upon the Controller and Simulator Plan that you were 10 then preparing; is that correct?
i 11 A
That's correct.
O 12 O
Message injects, does that refer to the free-play 13 messages?
t 14 A
Yes, it does.
f 15 0
And, do you recall essentially,what was discussed 16 during this conference call by you regarding the free-play 17 messages?
18 A
Basically, we were developing free-play messages 19 to be interjected, and it would be the responsibility of the 20 controllers to interject those messages at the appropriate 21 times.
22 O
And, you talked in terms of how that would be O
s i
91 j
4 i
1 accomplished?
t 2
A Right.
a 3
MR. MILLER:
Let me introduce as Donovan Exhibit 6 4
a two-page document dated 1/24/86.
Once again, it is a j
5 memorandum to the file from Roger Kowieski.
indexx 6
(The document referred' to was marked I
7 as Donovan Deposition Exhibit 6 8
for identification.)
9 BY MR. MILLER:
(Continuing) 10 Q
Mr. Donovan, have you ever seen what has now been j
I l
11 marked for identification as Donovan Exhibit 6?
O 12 (The witness is looking at the document.)
13 A
I don't recall seeing it.
Again, it was not 1
14 addressed to me.
15 Q
This memorandum refers to a January 24th meeting 16 between representatives of LILCO, FEMA and Argonne National 17 Laboratory, correct?
18 A
Yes, it does.
19 Q
And, you were in attendance at that meeting, 20 correct?
21 A
Yes, I was.
22 Q
Could you tell me the purpose of that meeting?
92 O
1 A
I believe the purpose is described in the 2
content of this two-page memo to the file.
3 0
Well, would you just tell me what you recall as
.4 being the purpose of the meeting?
5 A
We had a desire to know how the LERO response 6
organization was going to respond, to get an understanding of 7
the status of procedure revisions, to request the most recent 8
copies or the copies that would be used during the exercise, g
and to discuss our observation of the January 30th drill.
t 10 0
You mean to discuss the observation that you were 11 going to be conducting in the future at the January 30th drill?
12 13 A
(No response.)
l 14 0
Now, you say you had a desire to know how LERO was 15 going to respond.
What do you mean by that?
16 A
We wanted to get a better understanding other than 17 one that could be derived from reading their plan, of how 18 they would respond to an emergency.
I 19 It's my understanding that neither Mr. Kowieski or 20 Baldwin and certainly myself had not participated either as 21 an observer or an evaluator at any other LERO drill, and since 22 we had the need to have intimate knowledge of how the response
(
4
- n.. -
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y w+--
93 AU 1
organization worked, we had some questions and that's one 2
of the reasons for holding the meeting.
3 Q
So, you are telling me that you didn't think you 4
could accurately understand how the LERO response organization 5
was to work simply by reading the plan itself?
6 A
To say couldn't accurately is not the correct 7
phrase.
We just had some questions that couldn't be readily a
derived -- answers could not be readily derived by a mere 9
reading of the plan.
10 Q
So, is it fair to say that FEMA requested LILCO/LERO 11 to hold this January 30th drill?
{
12 A
No.
l l-13 Q
No?
Whose idea was it to hold that drill?
i 14 A
It's my understanding that the drill had already 15 been scheduled by LILCO.
16 Q
Had already been scheduled?
Had FEliA been invited 17 to attend that drill prior to January 24th?
l 18 A
I do not have any knowledge of that.
I i
19 Q
Do you know why, or what the purpose was, for the 20 January 30th drill?
l 21 A
I can assume that the purpose of the January 30th
(
22 drill was to shake out the revisions to procedures that they O
94 i
C)
I had promulgated since their last drill.
I end2A 2
Q Have you ever heard of the January 30th drill 3
characterized as a dry run, Mr. Donovan?
1 4
A Have I ever heard of it?
5 Q
Have you ever heard the January 30th LERO drill 6
characterized as a dry run for the February 13th exercise?
7 A
Characterized by whom?
8 Q
Characterized by anyone.
9 MS. McCLESKEY:
Objection to the question on 10 relevance.
i 11 THE WITNESS:
Not in an active meeting situation, (1) i 12 no.
i 13 BY MR. MILLER:
(Continuing)
[
14 Q
I don't understand.
Not in an active --
[
V 15 A
I had never heard describe this dril s a dry 16 run drill in a meeting that I attended.
17 Q
Well, that implies that you have heard the term 18 used, " dry run" for that drill?
19 A
Yes.
I heard that this morning from Mr. Cumming.
20 MR. CUMMING:
Counsel will state for the record 21 that the term used this morning previously by counsel for 22 Intervenors was not dry run but rather dress rehearsal.
If O
95
~'T (V
1 counsel would care to restate the question -- although FEMA 2
counsel has objection to it based on relevancy -- as dress 3
rehearsal, he is welcomed to do so.
e4-MS. McCLESKEY:
Mr. Miller, dry run, dress rehearsal, 5
it's all irrelevant.
6 MR. MILLER:
Well, that's your opinion, Ms.
7 McCleskey.
8 MS. McCLESKEY:
It's my objection.
9 MR. MILLER:
It's noted.
10 BY MR. MILLER:
(Continuing) i 11 Q
Mr. Donovan, I assume that you did actually attend i
(
12 the January 30th drill, correct?
l i
13 A
Yes, I did attend the January 30th drill.
l 14 Q
There was a training session prior to that drill on 15 January the 29th; is that correct?
16 A
That's correct.
17 Q
Did you attend that training session?
18 A
I attended portions of that session.
19 Q
What did the January 29th training session involve?
20 A
The portions that I attended involved the orienta-21 tion of the controllers for the January 30th drill by the 22 LERO/LILCO staff.
96
(~h i
\\-)
1 Q
And the controllers for the January 30th drill F
2 were LERO controllers?
if i
3 A
That's correct.
j 4
O Did you attend any other meetings regarding the i;
5 January 30th drill on January 29th or at any other time?
6 A
That was the only meeting that I atten'ded.
7 Q
Okay.
The drill on January the 30th, was that 8
an all day drill?
4 5
9 A
Yes, it was.
t 10 Q
Were you there all day?
te 11 A
Yes, I was.
O 12 O
Were you at the EOC all day?
13 A
No, I was not.
j n
14 Q
Where were you?
15 A
I was -- I visited staging areas, the EOF and the l
16 EOC.
17 Q
Did you take any notes during the day of that 18 drill?
19 A
No, I did not.
20 Q
Do you know if anyone did?
21 A
No, I do not.
22 Q
You kept no log or anything of that sort?
O
97 0
1 A
No, I did not keep a log.
2 Q
Do you recall the scenario used for the January 3
30th drill?.
4 A
No, I do not, not specifically.
5 Q
Well, what recollection do you have of that scenario?
6 A
My recollection was that it required the activation l
7 of the LILCO and the LERO response organizations.
8 Q
Well, do you recall anything more specific than 9
that, Mr. Donovan?
10 A
No, I do not, because I basically was escorted by 11 LERO controllers and staff to different facilities so I could O
12 get a working knowledge of how the response organization was 13 responding to the exercise.
i I
14 And, I was not interested in specifics of their 15 response, nor specific issues within the scenario.
16 Q
You essentially wanted to see how LERO worked; is 17 that correct?
18 A
That's basically correct.
Again, the purpose of rN
\\
h 19 my visit my upcoming assignment on February 13th/was to 20 ensure that our free-play messages were properly formatted 21 insofar as to input points to not contemplate but to supplement 22 and provide a proper mechanism for LERO to respond to.
O
i 98 i
1 Q
Mr. Donovan, as senior. controller for the Shereham 2
exercise, is it fair to say that your primary duty responsi-3 bility was the input of the free-play messages?
P c4-A I would say that was one of my primary duties.
5 0
And, what would you say were your other primary 6
duties as the senior controller?
7 A
To train controllers and simulators and supervise 8
controllers and simulators on the exercise day.
9 Q
So, in terms of your responsibilities and duties 10 on the day of the exercise, they were twofold, to supervise i
11 the controllers and the simulators and to assure the input of j
o 12 the free-play messages at the appropriate times; is that f
13 correct?
14 A
That's true, and inject contingency messages if 15 necessary.
16 Q
Do you know, Mr. Donovan, if you were ever shown or i
17 given a copy of the January 30th drill scenario?
18 A
At the-training session, we were issued a copy, i
19 yes.
20 Q
Do you still have it in your possession?
21 A
I don't believe so.
I believe we were asked by 22 Region II to return them to Region II.
,ga.,
i i
1 Q
At what point was that that you were asked to l
l 2
return them?
{j 3
A The evening of that drill.
i 4
MR. MILLER:
Mr. Cumming, I think we have an out-5 standing request for the January 30th drill scenario, but I 6
will renew that request at this time.
7 MR. CUMMING:
To my knowledge, it was produced 8
on the index to all Region II documents and there are no 9
copies within FEMA.
t i
10 So, you may direct your request to other appropriate f
11 persons or parties.
O 12 MR. MILLER:
Well, my request is outstanding with 13 FEMA now also.
14 BY MR. MILLER:
(Continuing)
+
15 Q
Mr. Donovan, on Page 2 of the document marked as 16 Exhibit 6, that refers to, "LILCO will provide copies of 17 procedures by 1/30/86."
l l
18 Are those the LILCO OPIPs that is referring to?
19 A
LILCO and LERO.
We needed both, if you understand 20 that.
EOF procedures were under LILCO; and the EOC and 21 the staging area procedures were in the LERO organization.
22 Q
I just have trouble distinguishing the two O
i s
i 100 i
()
1 organizations in my mind sometimes, i
2 MS. McCLESKEY:
You had better work on that, Mr.
3 Miller.
4 MR. MILLER:
I'm trying hard.
5 MR. CUMMING:
FEMA counsel believes that the depo-l 6
sition would be expedited if counsel would cease ^ testifying.
7 MR. MILLER:
Counsel is not testifying, Mr. Cumming.
8 But, if you care not to testify we will all --
9 MR. CUMMING:
Counsel for Intervenors, if he l
10 could refrain from testifying we could expedite this deposi-g i
11 tion.
i'
(~/
s_
i 12 MR. MILLER:
Counsel for Intervenors is not i
i 13 testifying, Mr. Cumming.
!~
14 MR. ZAHNLEUTER:
Counsel for one of the Inter-15 venors.
16 BY MR. MILLER:
(Continuing) 17 Q
Mr. Donovan, do you recall if you got the proce-t 18 dures on or about the 30th of January?
19 A
It's my understanding that we received some of l
20 them, and I left on the 31st.
But I believe we received all 21 that was necessary.
22 Q
You believe you received all of the LERO and LILCO OO
,a
101 O
1 procedures that were necessary?.
il 2
A I cannot say whether we received all of them by 3
i 3
the 30th.
But we received all that were necessary.
j i
i
,4-Q How did you discern which ones were.necessary and 5
not necessary?
6 A
The procedures I was interested in were relevant to I
7 the staging area and the LERO EOC.
Mr. Kowieski also requested
'I 8
procedures addressing LILCO's emergency news center and LILCO's
{
i 9
EOF h order to go into his evaluator packages.
10 I cannot attest to whether all procedures were i
11 received by 1/30.
But the procedures that were necessary for l
(
f 12 me to see that my job was to be accomplished had been received i
13 by.1/30.
14 This request here -- there is a request here that 15 addresses procedures in general and not procedures in specific.
16 Q
Mr. Donovan, were people instructed not to take 17 notes at the January 30th LERO drill?
I 18 MR. CUMMING:
Witness may answer the question to 19 the extent that he has knowledge.
20 THE WITNESS:
To my knowledge -- I was not 21 instructed to or to not take notes, i
22 O
102 i
O 1
BY MR. MILLER:
(Continuing) 2 O
But, it was your understanding prior to-that drill 3
that there would be no evaluation of that. drill made by FEMA; 4
is that correct?
5 A
That's correct.
At the meeting on the 24th we 1
6 addressed the desire to attend a drill to become familiar with q
the response organization.
8 Our purpose in attending that drill was not to
,i g
evaluate that drill.
l 10 Q
And to your knowledge, the January 30th drill had E
11 been scheduled by LERO prior to any expression of FEMA's i
desire to attend it; is that correct?
12 A
That's correct.
As I say, in my region, similar 13 j
14 dress rehearsals or dry runs are conducted by licensees.
In 15 my case, I usually try to attend those as well.
And, I do not evaluate it or participate in the evaluation of those 16 17 drills or dry runs or dress rehearsals.
I would say the practice of sending key people to 18 observe them is common throughout the FEMA regions.
It's 19 n t something that was done extraordinary in this case.
20 Q
Do you recall, Mr. Donovan, if any of the free-play 21 messages were modified in any way following the January 30th 22 D
1 103 O
1 LERO drill?
2 A
I cannot recall.
3 Q
Do you recall if any of the free-play messages 4
were scrapped following the January 30th LERO drill?
5 A
I cannot recall whether we scrapped any messages.
4 6
Q Do you recall if you prepared additional messages 7
following the January 30th drill?
8 A
No, I cannot.
9 Q
Mr. Donovan, I assume from the previous testimony 10 today that you do indeed know Mr. Weiss of the NRC?
i.
11 A
Yes, I do.
l 12 Q
What is your understanding of Mr. Weiss' involve-13 ment in the shoreham exercise?
l t
14 A
He was assigned to the controller and simulator 15 group to work for me.
16 Q
In what capacity did he work for you?
17 A
He served as the controller over what I refer to 18 as the control cell.
19 Q
Is that the location where various simulators were located?
20 21 A
That's correct.
22 Q
Did Mr. Weiss work with you in preparing the O
+
104 i
i O
1 Controller and Simulator Plan for the Shoreham exercise?
2 A
He was at the additional meeting which you l
3 referenced in your Exhibit 4.
He participated in the i
1 4
telephone conference that you referenced in your Exhibit 5.
5 And we had some phone conversations during those i
6 three weeks following an initial meeting.
7 Q
Did he help draft any of the sections of the I
8 Controller and Simulator Plan?
l g
A Yes, he did.
)
10 Q
Do you recall which sections?
Are they the sections
[
n dealing with simulators?
l 11 A
Yes.
12 Q
Any other sections?
13 A
I am not -- my recall is not that clear as to what 14 he proposed and what he didn't propose.
15 Q
I assume, Mr. Donovan, that you had authority to 16 accept or reject whatever Mr. Weiss drafted; is that correct?
17 A
That is correct.
18 Q
And, over you there was Mr. Kowieski.
He had the 19 i
authority to accept or reject what you drafted?
20 A
Correct.
21 Q
Mr. Donovan, let me show you what we will mark as 22
)
105 O
1 Donovan Exhibit 7.
It's a one-page document entitled at f
2 the top, " FEMA Region II, Controller and Simulator Organiza-i 3
tion."
r 1
,4-A Yes.
5 (The document referred to was marked 6
as Donovan Deposition Exhibit 7 indexx 7
for identification.)
8 BY MR. MILLER:
(Continuing) 9 Q
Did you prepare this document, Mr. Donovan?
A Yes, I did.
I caused this particular document to 10 i
11 be prepared.
I wrote it in longhand and someone else put it 8
in --
12 l
13 Q
This is, in fact, part of the Controller and i
14 Simulator Plan, is it not?
A Yes, it is.
i 15 Q
Are the names reflected on this document, Mr.
16 17 Donovan, accurate with respect to the persons who actually served as controllers and simulators on the day of the 18 Shoreham exercise?
f 19 i
A No, there are some changes.
20 Q
W uld you tell me the changes?
21 A
Well, I would have to go back to the exercise report 22 t
.c
+
.y-
c, w-
106 i
r~(,))
1 to do so, but I do know that some of the individuals, for f
r 2
reasons not made known to me, were not available on February j
3 13th so we had some last minute replacements.
4 Q
You can't tell me, though, which people changed by j
5 looking at this chart at this point in time?
5 6
A I would have to pull out the other report to answer 7
you.
8 0
What other report?
9 A
The exercise report.
10 0
When you say you had last minute changes, are you f
talking about last minute on February the 13th you found out 11 you couldn't have certain people?
12 A
No.
We had a training day, and when the people 13 l
showed up on the training day -- I left the Controller and 14 Simulator Plan to be finalized on January 31st.
It was 15 mailed out the following week to the recipients of the docu-16 ments, and I did not return until the night of the 10th of 17 18 February.
And on the lith when the controllers and simulators 19 convened, I was made aware that there had been some replace-20 ments.
21 22 Q
Those replacements then were approved by someone
(
-,w
-m
i.
.c 107 Y
O 1
other than yourself; is that correct?
2 A
That's correct.
I 3
0
.Was it Mr. Kowieski that made that decision?
4 A
I don't know if he made the decision.
I don't i.
5 know -- some people who were initially designated could not 6
be there.
I believe that the agreement between the NRC and 7
FEMA was that FEMA would provide X number of positions and 8
NRC would provide X number of positions.
I 9
And, there was no discussion as to selection by 10 name.
It was just providing a person.
11 Q
Earlier, Mr. Donovan, I showed you a controller C:)
t 12 log.
It was identified as Exhibit 3.
l 1
You told me this was a compilation, and I think h
13 i
14 you -- I think I'm repeating myself, but did you also tell me that you did not know who had made this compilation?
15 A
That's correct.
16 17 Q
Do you know if the FEMA controllers at the Shoreham exercise kept logs during the exercise?
18 19 A
Yes, because I designated this form for them to keep the log on.
20 21 Q
To your knowledge, did all FEMA controllers at 22 the exercise keep such logs?
1
i 108 n
1 0
1 A
To my knowledge, they did.
We had a post-exercise 2
meeting where the paperwork was collected.
I reviewed it il 3
and turned it over to Region II.
z4-Q Turned it over to Mr. Kowieski?
5 A
Yes.
6 Q
Is there a reason, Mr.. Donovan, that you did not 4
F 7
keep a log but the other controllers did keep such logs?
.I 8
A There was no reason to duplicate their efforts.
]
9 Q
Well, they had responsibilities and duties somewhat to different from your responsibilities and duties; isn' t that 11 correct?
12 A
That's correct.
13 Q
So, why would that have been a duplication of 14 their efforts?
15 A
The purpose of their logs was to indicate when 16 they input certain messages.
17 Q
Was that the only purpose of their logs, to your 18 knowledge?
g4,,
19 A
Yes.
The Controller Plan said'if' there were other 3mOta.no W occasions ar.d reason 7 but the2 purpose of their log was to log (s 20 w,a r 21 the times that they ++R input free-play messages into the 22 system.
4
=
r 7-..
i L
109 i
O 1
Q Do you know if any FEMA controllers at the 1
2 exercise kept or. prepared any written documents during the 3
day of the exercise other than their logs?
4 A
No, I do not personally know.
5 MR. MILLER:
Mr. Cumming, I believe that the only 6
controller logs that have been produced were the controller 7
logs from the staging areas.
8 And I think we've made this request, I will renew s
9 the request, that we be provided copies of the controller logs 10 at other locations, the EOC and the radiation field monitoring I
11 teams, to be exact.
l (1) 12 MR. CUMMING:
Counsel for FEMA will diligently l
13 search for such forms.
Radiation field monitoring' teams?
l 14 MR. MILLER:
Well, let me just --
15 MR. CUMMING:
All documents remaining in the 16 region have been indexed.
And I'm not sure if that index 17 includes these documents.
(
18 But, if they exist we will search for them.
As 19 you know, we have been basically producing documents generated the day of the exercise with one exception.
That exception is 20 that certain handwritten notes which have been produced by 21 witnesses prior to their testimony the date of depositions are 22
i a
110
.{
I O
1 being reviewed by me as expeditiously as possible to determine 2
whether there is factual information on them which may be i
j
'l 3
released or whether there is anything that would implicate 4
deliberative process and, therefore, should be objected to.
5 We have also -- although the initial request i
6 clearly contemplated that all individual notes would be pro-7 duced, for whatever reason, and counsel can't state whether 8
it was misunderstanding or whatever because the document g
production request was given and ordered to be circulated to 1
10 all people who appeared.
t li We are again going back to request if, in fact, 11 O
i individual notes were produced the day of the exercise that 12 they be produced to counsel.
13 14 BY MR. MILLER:
(Continuing) 15 Q
Mr. Donovan, am I correct that FEMA controllers 16 Jere located at the EOC, the staging areas and with the 17 radiation monitoring teams?
18 A
There was one other location where we had the 19 simulators representing --
20 Q
So that was the FEMA control cell.
21 A
Correct.
22 Q
Other than those locations, were there any other O
111 OV 1
locations where there were FEMA controllers?
2 A
Did you mention the EOF?
0 No, I didn't.
3 c4 A
There were some at the EOF.
Q Is that everything?
5 A
Yes, sir.
6 MR. MILLER.
So, Mr. Cumming, my. request actually 7
w uld go to the EOF and also the FEMA control cell as well.
8 MR. CUMMING:
Fous categories.
9 MR. MILLER: Of f the record for a moment.
10
}
e record.)
l 11 MR. MILLER:
Okay.
Back on the record.
12 I
ILL
( ontinuing) q 13 14 Q
Mr. Donovan, do you recall who was the FEMA controller at the Patchogue staging area?
15 A
Well, according to your Exhibit 7 it was Mr.
16 17 Hawkins.
But, I don't believe that was the name.
I would 18 have to consult the report.
19 MR. MILLER:
Let me mark as Donovan Exhibit 8 a f ur-page document, the first page of which just says 20 "Patchogue Controller Logs;" the second page of which has at 21 22 the top, "Eric Weinstein, Patchogue Staging Area Controller."
?
s I
--,my.-_
7--,_---.,__-m,
112
/~')
V indexx 1
(The document referred to was marked 2
as Donovan Deposition Exhibit 8 3
for identification.)
4 BY MR. MILLER:
(Continuing) 1 5
Q Have you ever seen this document before, Mr.
6 Donovan?
7 (The witness is looking at the document.)
8 A
I believe I have.
I just said I collected from 9
all controllers and simulators information that represented to a pile approximately an inch or an inch and a half thick of D
11 Paper.
And, I reviewed them before I turned them over to Mr.
l
(
12 Kowieski.
l I
13 Q
Does this refresh your recollection as tb where 1
I 14 Mr. Weinstein was stationed the day of the exercise?
15 A
Uh-huh.
16 Q
And, was he stationed at the Patchogue staging 17 area?
18 A
I believe he was.
19 Q
Would you say, Mr. Donovan, that the log presented here and marked as Donovan Exhibit 8 is typical of the logs 20 that were generated the day of the exercise by the FEMA 21 controllers?
22 O
113 l
O
~
It 1
A I would say it was probably the more complete.
2 is beyond what he was requested to do.
3
.The purpose of his log was only to acknowledge by 4
a time record the times that he, or any controller, input 5
messages.
6 Q
Was that an instruction that you gave to the 7
FEMA controllers?
8 A
Yes.
I can refer you to it in the control plan, 9
if you wish.
I 10 0
Would you look at the third page of the exhibit, d
11 Mr. Donovan, where it states overall impression and there O
-I 12 is redacted information?
13 Do you see that?
i 14 A
Yes.
j 15 0
Do you recall if any controller other than Mr.
16 Weinstein set forth their impressions about the Shoreham 17 exercise?
18 A
No, I do not.
19 0
Do you recall whether any other FEMA controllers 20 summarized in any format what had been observed by those controllers during the exercise?
21 22 A
I do not recall.
It was not their assignment to O
114
(~
1 record impressions.
It was their. assignment to input messages 5o yhd gould obh b) v-2 Cr M GhhE44VO evaluators 1' thOir interface /wa+h LERo and 3
LILCO responders.
c4-Q Do you recall what was written by Mr. Weinstein r
5 in this space regarding overall impressions?
6 A
No, I do not.
When I reviewed it, I was not interested in their impressions.
I was interested in the 8
times that they inputted their messages.
9 0
So, are you saying that if you saw it you wouldn't even have read it?
10 i
A Probably not.
That evening, the evening of j
11 February 13th, we attempted to put together a report 1:hich is 12 thi in thc scport of the critical timeline events.
i 13 i
14 Again, the instructions to the controllers was merely to report the times they inputted exercise messages.
l 15 And my concern was to get those times put in the timeline 16 and make the evaluator or the evaluator teams aware of those g7 times so that they could then evaluate the issue or objectives.
18 MR. MILLER:
Mr. Cumming, we have made this request gg before and I will renew it again.
The emergence of these 20 controller logs that have been produced have some pieces 21 f
redacted.
We would ask for the unredacted versions.
22 1
.g-
,~
115 Y
1 MR. CUMMING:
That's fine.
I think I should 2
state for the record that for the day of the exercise materials, 3
except for LERO/LILCO employee names, we intend to produce 4
those, are going to produce those, or have produced, with no other redactions.
5 6
MR. MILLER:
So you intend to pr'oduce Mr. Weinstein's 7
log unredacted?
i 8
MR. CUMMING:
That's correct, if it was produced the g
day of the exercise.
BY MR. MILLER:
(Continuing) 10 i
11 Q
Well, Mr. Donovan, the logs generated by the FEMA h
l O
12 controllers, to your knowledge, isn't it correct that they were 13 all generated during the day of the exercise?
14 A
That's correct.
15 Q
We have previously in another deposition, Mr.
16 Donovan, marked for identification as an exhibit the itinerary 17 of the Shoreham exercise.
We have called that Lane Exhibit 2.
18 And I will now refer to that exhibit.
It is 4
19 hopeful that the other parties brought their Lane Exhibit 2 20 with them.
21 MR. CUMMING:
You asked us to, but we never took 22 that Lane Exhibit 2.
In other words, we never removed the 4
r e
116 i
[N
(_)
I copies of the exhibits.
2 MR. MILLER:
Off the record.
3
.(Off the record.)
4 BY MR. MILLER:
(Continuing) 5 Q
Mr. Donovan, I'm showing you what is Lane Exhibit 6
2 from a previous deposition.
This is the itinerary for the 7
Shoreham exercise.
8 Have you seen this document before?
endT2 g
A Yes, I have.
10 Q
I take it, Mr. Donovan, from your statements i
11 earlier today that you actually travelled to the area of the
(
Shoreham plane on February the 10th; is that correct?
l 12 1
13 A
That's correct.
[
14 Q
Is it fair to say your first pre-exercise involvemen in terms of preparing for the exercise began on February the 15 lith once you had travelled to the Shoreham plant?
16 Did you do anything on February the 3 0th other than 17 travel to Long Island?
18 19 A
Just travelled.
Q Okay.
Beginning on February the lith, did you 20 attend this 8:30 to 12 noon meeting, this joint training 21 session with the FEMA evaluators, the controllers and the 22 O
I
117
(
?
9 1
simulators?
f 2
A Yes, I did.
I 3
Q Did you have any responsibility for presenting 4
any information to attendees at that meeting?.
l, 5
A I believe I addressed what is referred to on Page 2
]
6 of 8, subpart C.
)
7 0
Exercise control plan overview?
j 1
8 A
That's correct.
a g
Q Could you tell me generally, Mr. Donovan, what i
10 was stated by you at this meeting with respect to the exercise i'
11 control plan?
(
l 12 A
The concept of FEMA's exercise control plan, 13 LILCO/LERO's exercise control plan and the acknowledgment to 14 the FEMA evaluation teams, of who the FEMA controllers were, 15 since the process for input of free-play messages was from 16 the team leader to the FEMA controller to appropriate inputs.
17 Q
Other than your presentation of remarks regarding 18 the control plan at this meeting, were you otherwise merely 19 an attendee at the meeting?
i 20 A
Yes.
21 Q
Did you take any notes at the meeting?
A No, I did not.
22 O
1
-1
,+--..__.._,_,__y-._,.w-
r i
118
(_T
/
1 Q
Did you attend the 1:15 to 3 o' clock p.m.
2 training session.later that day?
3 A
Portions of it.
4 Q
Did you have a responsibility for presenting 5
information to the attendees?
6 A
No, I don't believe so.
7 Q
So, you were there as an attendee only; is that 8
correct?
d g
A Portions of, and I also attended the concurrent j
l 10 meeting.
I 11 Q
For the simulators?
i I
(~N
\\~
A
- Correct, 12 i
Q In both cases, were you there merely as'an 13 attendee?
14 A
No.
I was a presenter in the concurrent meeting 15 for simulators.
16 O
So, you are talking about the meeting referenced 37 n Page 3 of the exhibit which is the training session with 18 the simulators?
19 A
That's correct.
I believe Mr. Kowieski did not 20 give a presentation.
I gave the presentation.
21 Q
Did Mr. Weiss also give a presentation?
22
-O
1 4
1 119 1
A Yes.
.,r i
2 Q
Do you recall the substance of your presentation i
3 at that meeting on the simulators, Mr. Donovan?
4 A
Basically, it was to go over the Controller and 4
5 Simulator Plan with specific emphasis on those portions of
~
6 the plan that addressed the roles.that we expected of the 7
simulators.
8 Q
Again, was it based upon the Controller and 9
Simulator Plan that you had prepared?
10 A
That's correct.
t 11 Q
Basically a summary of what that plan contained; i
('\\
is that --
12 13 A
Well, when I train people I take the assumption f
14 that they perhaps have not read the documents I prepared.
15 So, to ensure that everyone is familiar with the key points 16 of the documents, I go over the documents in detail.
I do not 17 necessarily read the document to them, but I make sure that 18 all the key aspects are pointed out to them and make reference 19 to them.
20 Q
Do you recall, Mr. Donovan, if you were, in fact, 21 involved in these two meetings up until about 5 o' clock that 22 day?
OV i
41 l'
120 ll t
O 1
A I believe I was.
[
2 O
Did you attend this 3 to.5 o' clock meeting, training 3
session for all FEMA controllers?
.4-A Uh-huh.
'f e
5 Q
Did you go there from your presentation to the
{
6 simulators?
7 A
Right.
8 Q
Did you make a presentation at the 3 to 5 o' clock 9
meeting for all FEMA controllers?
10 A
Yes, I did.
[
11 Q
Is it true that, in fact, your presentation re-t 12 garded the controller assignment, and the responsibilities 13 and authorities of a controller?
l
+
14 A
Right.
4 15 Q
Is that the first time FEMA controllers were given 16 specific assignments?
17 A
No.
When they were mailed the Controller and 18 Simulator Plan the preceding week, this sheet which you have t
19 as Exhibit Number 7 was in that plan.
20 As I said, there were some last minute substitutions.
I 21 In some cases, there were some new persons.
So, this session f
22 would be similar to the session we just discussed that occurred i
1 l
l
_.l i
y a,
e--
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--r--,
n n~
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121 1
0 1
between 1:15 and 5, though I didn't attend the whole session 2
of simulators I attended portions of the session.
3 Q
Do you know, Mr. Donovan, on Page 2 of this exhibit 4
there is reference to the training session with the evaluators 5
and controllers, and on Page 3 there is a training session 6
for just the controllers.
7 What was the difference in those two meetings?
8 MR. CUMMING:
FEMA counsel has objection to this 9
line of questioning bas,ed on relevancy.
10 But witness is instructed to answer it to the
\\
11 extent he has knowledge or memory.
12 THE WITNESS:
The 1:15 to 3 o' clock meeting re-13 ferenced on the bottom of Page 2 for evaluators and control-
}
14 lers discussed the exercise scenario among other topics.
15 As stated in our Controller and Simulator Plan, we 16 took as a premise that we did not want the simulators to be 17 aware of the scenario for the exercise.
So, a separate 18 concurrent meeting was set for them.
19 Since I was aware of the scenario, I did not have a 20 need to attend this 1:15 to 3 o' clock meeting.
And I, in 21 turn, attended the other concurrent meeting for the simulators i
i 22 only to make sure that they understood the aspects of the plan O
122 1
and my expectations for them as simulators.
That was the 2
main reason for holding two separate meetings.
3 BY MR. MILLER:
(Continuing) c.4 -
Q Maybe I'm confused, Mr. Donovan.
I'm not sure.
5 My question is, Page 2 of the exhibit references a meeting, 6
training session for evaluators and controllers.
7 A
Right.
8 Q
Page 3 of the exhibit reflects a later training 9
session just for the controllers.
10 A
That's right.
I 11 Q
Why is it that -- what were the differences at l
O
'/
12 the two meetings in terms of the discussions held?
13 A
The 1:15 to 3 o' clock meeting discussed the 14 exercise scenario, the objectives and the assignments for the 15 collateral group of evaluators and controllers.
16 The 3 to 5 o' clock meeting specifically addressed 17 only the assignments for controllers insofar as free-play 18 message input.
19 Q
And, to your knowledge, the simulators did not 20 attend either of those two meetings?
21 A
That's correct.
22 Q
Now, on February the 12th, Mr. Donovan, this O
..g-.
123 (O
v 1
exhibit references that that morning the evaluators and 2
controllers drove to their locations in the field.
3 Did you drive about the locations of the Shoreham --
4 around the Shoreham plant?
5 A
No, I did not.
~
6 0
Is that because you were already familiar with those 7
locations?
8 A
Partially, plus I was requested to attend a meeting g
with representatives of the State of New York and Suffolk County 10 and FEMA Region II, that was chaired by Mr. Brown of your i
11 organization I believe.
I I
O' I
12 0
So, you were in New York City at that meeting?
N-A No.
The meeting was held at Medford Inn on 13 14 Long Island.
15 Q
Actually, I think I was at that meeting, too.
A It was a big meeting.
I didn't necessarily meet 16 17 everyone.
l 18 MR. CUMMING:
FEMA counsel again requests that l
l 19 counsel for Intervenors cease testifying so we can expedite f
the deposition.
20 I
MR. MILLER:
I'll try not to be too jcvial here, 21 22 Mr. Cumming, about these things.
I
124 i
O 1
(Laughter.)
2 MR. CUMMING:
FEMA counsel renews its request.
3 BY MR. MILLER:
(Continuing) 4 Q
Mr. Donovan, on Page 4 of the exhibit, did you 5
attend this 1 to 4 o' clock p.m. training session for control-6 lers and simulators?
i 7
A Yes, I did.
8 Q
Up until the time of that meeting, were you involved 8
in this meeting with the County and State representatives?
10 A
Yes.
i f
11 Q
What was involved essentially, Mr. Donovan, at
(
12 dhis training session on February the 12th?
13 A
Well, several things.
One, to insure that the 14 controllers and simulators knew where they were expected to be 15 the following day; and, the second purpose was to address 16 their activities, to see if there were any questions.
- And, 17 third, was to prescribe their actions following the exercise.
18 0
What actions were prescribed following the 10 exercise?
20 A
Basically, I believe the agenda on Page 5 that l
21 references a meeting from 7:30 to 8:30 on February 13th.
- And, l
22 following that meeting there were follow-on meetings to be
}
e T
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t 125 i
?
.i Cl) 1 completed that evening or early the following morning.
I i
2 Q
Did you attend the 4 to 5 o' clock meeting on
[
3 February 12th, the general meeting for all the evaluators and controllers and simulators?
j
...4 i'
A Yes, I did.
5 Q
It states in this exhibit that the purpose of that j
6 7
meeting was to resolve problems.
Do you recall any problems?
8 A
I don't recall any problems.
l i
g Q
What was done at that meeting?
I A
It was just a last opportunity for people to 10 express any concerns and for Mr. Kowieski and myself, dealing l
11 i
O with our respective audiences, to remind the persons that were 12 assigned to us what was expected of them the following day.
13 14 Q
Do you recall any concerns being expressed at that meeting?
15 A
o, I do not.
16 Q
You have already mentioned the meeting in the 37 l
evening of the day of the exercise, Mr. Donovan, the 7:30 to ig 8:30 p.m. meeting.
It states that the purpose of that meeting 19 f
was to develop the timeline and a brief discussion was held 20 of major exercise events.
21 Is that a fair characterization of that meeting?
22 O
h 1
.-_v-----
.-_._-_r
.__,...y, y
.____,_.7
126 O
1 A
No, it's not.
The meeting basically became h u n.t e h
2 strictly an event timeline meeting. -ft ' ear reclLy no discus-3 sion of major exercise events.
f 4
Q So, the meeting on the evening of the exercise was 5
essentially to put together the timing of the events as they 6
occurred on the day of the exercise?
7 A
Right.
8 0
Is that a meeting where someone stood a big black-9 board in front of the room and actually you sat there and 10 Put together the timeline?
A That someone was me.
11 O
0 You are the one who put together the timeline?
l 12 A
Yes.
13 I
14 Q
I take it that it was more than a one-hour meeting?
A That's correct.
15 0
What did you do, if anything, Mr. Donovan, in 16 17 addition to developing a timeline on the evening of the exercise related to the Shoreham exercise?
18 Go Doc nC s
WeM-r-tn the timeline meeting) controllers and 19 A
simulators remained.
We collected their logs.
Mr. Weiss 20 w nted to review them one more time.
We jointly reviewed them.
21 N \\ t'()
I left themYwith him on or about 12:30 or 1 o' clock in the 22 O
~
li
?
ij 127
.{
i 1
morning, and picked them up from him the following morning l
i 2
and returned them to Mr. Kowieski the morning of the 14th.
j 1
3
.In that session, I asked the simulators -- I had 4
made reference in the exercise control plan that the control-5 lers and the simulators were to endeavor to ensure that the 6
evaluators were presen f there were situations' involving any by 7
interfaces that would be of interest to the evaluators.
So, J
8 in that followup meeting, I tried to endeavor and ensure that 9
simulators did have, and the controllers for the simulators, 10 did have evaluators present.
i a
i 11 I then met separately with each of the team leaders l
O 12 to see if there was anything that they desired in terms of an 13 interface with the simulators before we released them.
- And, f
14 I advised them that if I did not contact them by the following
+o M bS
} M
/
15 morning that they were released and free to returng p
16 Q
So, all of this was done the evening of February the 17 13th?
18 A
That's correct, and the morning of the 14th and 19 for me until about 3 o' clock in the morning.
20 Q
Did you, at any time, review the FEMA controller 21 logs after your reading of them with Mr. Weiss the evening of 22 the 13th and before they were turned in to Mr. Kowieski the O
1-l 128 i
+
i 1
morning of the 14th?
2 A
Just our joint review.
+
3 Q
Have you seen those logs since the morning of the e4 14th of February?
N l
i 1
5 A
No, I have not.
- t i
6 0
What else did you do on February the 14th, Mr.
1 7
Donovan, related to the Shoreham exercise?
l 8
A I collected all of the controller plans and j
9 information that we distributed and boxed it up and turned it i
10 over to Mr. Glass who was then counsel for FEMA Region II.
i t
i 11 Q
Did you attend the X meeting that morning of the Cl) f 12 14th for the controllers and the simulators referenced on Page l.
i 13 6 of the exhibit?
[
14 (The witness is looking at the document.)
15 A
Yes, I did.
i is Q
Do you recall what took place during that four l.
17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />, approximately four hour meeting?
l j'
18 A
Well, the meeting did not occur as scheduled on 19 this itinerary.
The meeting took place at a later time, at 20 11 to 12.
As I just mentioned a few minutes ago, the 8 a.m.
I 21 to 12 a.m. or p.m. meeting did not take place.
l l
22 Q
Did not take place at all?
J
r
'l I
i 129 r
9 f
1 A
Right.
j J
2 O
Why is that?
3 A
Because, as I mentioned just a_few minutes ago, l
4 when I touched base with each of the team leaders Thursday l
5 evening I asked them to let me know by 8 o' clock Friday morning t
6 if there was a need for them to meet with the simulators or
'i 7
controllers.
If there was not a need, then I was going to 8
dismiss them as of that time.
9 Q
You were going to dismiss the simulators, not 10 controllers?
j Y
11 A
And controllers.
4 O
8 12 Q
Were the simulators and controllers, in fact, 13 dismissed about 8 o' clock in the morning on the 14th?
14 A
Right.
i; Q
What else did you do on the day of February the 15 14th, Mr. Donovan, if anything?
16 17 A
I insured that Mr. Kowieski had all of his inputs 18 that he needed from me and the team leaders had all that they 19 needed, packed my bags and left.
Q Were you involved in any way with the evaluation 20 21 of the exercise by the FEMA evaluators?
22 A
No, I was not, other than to insure that if they
(^)\\
1 i
I
i 130 l
I
]
had any questions relative to the simulators that they were 2
answered before I left.
3 Q
So, you left some time early afternoon on the 14th c4 of February?
5 A
That's correct.
6 Q
Did you conduct a debriefing, Mr. Donovan, of the 7
controllers and simulators for the Shoreham exercise?
~
8 A
Yes.
I mentioned I did.
8 Q
Is that where you -- well, tell me about that de-10 briefing.
What was that debriefing?
I 11 A
Following the construction of the timeline, we O
12 held a separate meeting.
We collected their logs.
Mr. Weiss 13 and I jointly reviewed them.
He asked to have one more chance 14 to review them himself.
And, I let him take the logs with him.
15 That was the extent of our debriefing.
16 Q
That was a debriefing of the simulators and 17 controllers?
18 A
And controllers.
19 Q
So, you did not actually meet with the simulators 20 and controllers.
You were reviewing their logs.
21 A
No, both.
22 O
When did you actually meet with them, with the i
t
131 f
O I
simulators and controllers?
13i 2
A The night of February 15th (sic) following the 3
timeline construction.
4 MR. CUMMING:
Excuse me, the night of February the r
5 13th?
l l
6 THE WITNESS:
The night of the exercise.
The time-I 7
line session which is indicated here did not get over in an 8
hour.
My memory is a little faulty as to when it did get over, i
i g
because that was a 22-hour work day for me.
So, times become 10 irrelevant when you are up 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> straight.
I 11 But, following that session we met with them, and it h
[
O' seems to me that we dismissed them some time between 11 and 12 11:30.
13 i
14 BY MR. MILLER:
(Continuing) 0 What exactly was the purpose of the meeting with l
15 the simulators and controllers, the meeting after the 16 17 development of the timeline on February the 13th?
18 A
To make sure that they completed their logs.
We did not want them to depart without capturing their logs and gg insuring that their job was done.
20 MR. MILLER:
Just give me a minute, please.
I'm 21 22 trying to see if I'm through.
l i
132 i
O 1
(Pause.)
2 MR. MILLER:
I'm almost through.
3 BY MR. MILLER:
(Continuing) 1 4
Q Mr. Donovan, you mentioned to me earlier today l
i 5
that you reviewed the March 12th draf t of that FEMA report; is that correct?
6 7
A That's correct.
8
!!R. CUMMING:
FEMA counsel objects to the line of 9
questioning dealing with post-exercise review, but has no 10 objection to witness answering to the extent he has know-j 11 led e.
9 O
l 12 BY MR. MILLER:
(Continuing) 13 O
Do you recall, Mr. Donovan, making any changes 14 to the draft of the FEMA report that you reviewed?
I l
15 A
I had one phone conversation with Mr. Kowieski.
16 The purpose of my review was to review those portions of the 17 exercise summary and introductory portions of the report 18 that dealt with the Controller and Simulator Plan and the 19 assignments therein.
20 0
And, after you had conducted your review you had 21 a telephone conversation with Mr. Kowieski?
22 A
That's correct.
O
133 O
1 Q
And, what was the substance of that telephone 2
conversation?
MR. CUMMING:
FEMA counsel objects to this line 3
- 4 of questioning, but to the extent the witness.has a recol-lection he may answer.
5 6
THE WITNESS:
I basically told him that I had 7
reviewed the report and felt they had captured everything 8
pertaining to my assignment in a factual and correct manner.
9 BY MR. MILLER:
(Continuing) to O
So, you had no changes to make to that draft?
11 A
No.
O 12 Q
Who do you understand actually drafted the FEMA 13 report, Mr. Donovan?
E i
14 MR. CUMMING:
Witness may answer to the extent 15 he has knowledge.
16 THE WITNESS:
It's my understanding that Region 17 II's exercise evaluation process is very similar to what we 18 use in Region X.
19 We have exercise evaluation teams, composed of team members and team leaders.
In some cases, it's a compo-20 21 site report, that each person on the team has a portion to 22 develop.
In some cases, the team -- depending on the size of O
?
134 6
i i
the team -- designates a reporting secretary and they jointly I
2 dictate.
One person writes the report out.
3 It's ny understanding that both methods were used, j
4 were utilized, by the evaluation teams and that all evaluation 5
inputs were translated into typewritten pages by a FEMA con-t 6
tractor.
7 BY MR. MILLER:
(Continuing) 8 Q
Is that FEMA contractor Argonne National Labora-j 9
tory?
i I
to A
Yes.
i.
i 11 Q
What is your understanding as to who wrote the l
12 draf t of the sections of the FEMA report dealing with the i
I 13 controllers and simulators?
y 14 A
It would be my understanding that either FEMA
[
15 Region II or Argonne rephrased those portions of the report that addressed controllers and simulators from the exercise 16 17 control plan that I had previously prepared.
18 Q
So, it's your understanding that essentially the 19 Controller and Simulator Plan was the basis for the FEMA report sections regarding controllers and simulators?
20 21 A
Right.
22 0
And someone just simply rephrased that?
()
i
t l
f 135 i
O i
i 1
A That's correct.
i r
2 0
Have you had any involvement with -- well, let me
[j 3
back up.
[
i 4
Do you recall what revision of-the.LILCO plan was f
5 exercised on February the 13th?
6 A
It's my -- as you can see from r'eviewi.ng the 3
I Simulator and Controller Plan that we had portions of 7
8 Revisions 4, 5 and 6 referenced in this document.
I believe o
the procedure revisions were Revision 6.
[
10 The documents that I provided as part of this plan u
11 were from up to Revision 6.
O U
12 Q
Have you had any involvement with subsequent re-l 13 visions of the LILCO plan since the February 13th exercise?
14 A
No, I have not.
15 0
Mr. Donovan, you told me that no one at LILCO or 16 LERO knew about the free-play, the FEMA free-play messages l
17 in advance of the exercise, correct?
l 18 A
That's correct.
l 13 Q
Did anyone at LILCO or LERO, including Mr. Daverio, i
20 know what aspects of the LILCO plan were to be tested by the 21 free-play messages?
22 A
I do not have direct knowledge.
I can assume that lO t
e 136
(
1 one could read the objectives and deduce what areas we were t
2 going to test with free-play messages and what. areas we were i
5 3
going to actually expect to be demonstrated.
j i
e4 0
Is it your opinion that if you read the exercise 5
scenario and read the exercise objectives that you could then k
?
6 deduce where free-play messages would need to be' input during 7
the exercise to accomplish the objectives?
8 A
Not necessarily.
I don't think you could deduce 1
)
9 when we would input them and what areas we would request 10 free-play activity to be demonstrated.
9 l
11 Q
Not necessarily the when, but what about the 12 actual aspects of the plan that would be input with free-play 13 messages, do 'you think that that could be deduced?
l t
14 A
Basically, I would say one could approximate a 1
15 good guess.
i 16 MR. MILLER:
I have no further questions.
i 17 MR. ZAllNLEUTER:
I have several questions.
indexxx 18 CROSS EXAMINATION 19 BY MR. ZAlINLEUTER:
i 20 Q
My name is Richard Zahnleuter.
I represent the i
21 State of New York which is one of the intervening governments 1
22 in this proceeding.
We have already established that there 3
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= _ _.
1 137
?
- i i
1 were no FEMA controllers at the customer. service office in I
2 Hicksville, t
i 3
Do_you know if there were any LILCO controllers 4
at that office?
A I do not personally know or recall whether there 5
6 were.
i y
Q Why was there no FEMA controller at that office?
i 8
A I do not have a ready answer for you.
We only had h
f 9
controllers where we felt they were essential to input free-play messages or to control simulators.
10 l:,
e 11 We did not have or prepare messages to be input
, ()
12 at that location.
Therefore, we did not have a controller 13 there.
i Il Did FEMA believe that the customer service office 14 Q
15 was not a place where it was essential that free-play messages i
16 be inserted?
i 17 MR. CUMMING:
Objection as to the line of question-I 18 ing.
To the extent, the witness -- based on relevancy.
l 19 To the extent the witness has knowledge, he may i
l 20 answer.
J 21 THE WITNESS:
Our comnitment to the Nuclear Regula-22 tory Commission was to evaluate the aspect of the plan known
()
i
.n___--,,--,---------
.,, -,.. ~ -. -, _ - - -... - -. - - - - - _. - -. - _ - _ _ _..
I 138 i
e 45 1
for the LERO organization.
I believe the office that you are
[^U 2
directing me to respond to is a LILCO organization and not i
'l 3
normally part of an organization that FEMA would evaluate at 4
any site anywhere in the United States that involves a portion y
5 of the power plant.
I s
The Licensee's customer service office, if it is 7
involved in the emergency response effort, normally would a
probably be evaluated by the Nuclear Regulatory Commission and 1
9 not be evaluated by FEMA.
10 BY fir. ZA!!NLEUTER:
(Continuing) i 11 Q
Do you know if there was a FEMA evaluator at that j
O 12 office?
13 A
No, I do not, without referring to the report.
It i
14 was not my assignment to address the evaluation of the exer-15 cise.
16 Q
To your knowledge, were any proposed free-play 17 messages rejected before they became final?
18 A
No.
19 0
With respect to the drill and the training session 20 on either January 29th or 30th, do you remember which came 21 first?
22 A
The training session came on the 29th, of which I O
i I
l 139 i
4 C:)
1 only, as I previously mentioned, attended a' portion because i
r 2
in conjunction with the training session the LILCO staff gave i
3 us a separate briefing.
j t
.4-The drill came on the 30th.
5 Q
FEMA's answer to Interrogatory 20 states that the f
6 drill occurred on January 29th.
Is that incorrect?
i 7
A May I refer to a calendar?
i 8
Q Sure.
l f
9 (The witness is looking at a calendar.)
10 A
The drill occurred on the 30th.
e 11 Q
Is the answer to FEMA's -- is FEMA's answer to the I.
12 Interrogatory incorrect?
i i
13 A
I'm not familiar with the answer you are referring I
i 2
14 to.
I 15 Q
During'the drill which was on January 30th, then, to did anyone from FEMA, including Mr. Weiss, insert any free-j 17 play message?
I 18 A
Mr. Weiss is an NRC employee.
Mr. Kowieski and l
l I
l 19 myself and FEMA contractors support were escorted by various
'1 I.
20 LERO controllers.
We did not have an active part in any 21 aspect of the drill.
I 22 We did not input any messages.
To my knowledge, i
140 0
1 none of us took notes.
And, we were not there -- again I 2
repeat -- to evaluate the drill.
We were there to familiarize 3
ourselves with the way the response organization set up and 4
operated.
5 Q
Did anyone from LERO input any free-play messages?
6 A
I could not answer that question.
7 0
Why not?
8 A
As I mentioned earlier, I was mobile during the day.
9 I did not stay at any one location for any period of time, and I was there to see how the organization set up, not to track 10 Plca
't how the scenario was hde$ad l
11 O
12 Q
So, is it fair to say that you are telling me that, i
13 to your knowledge, you did not observe anyone from 'LERO insert 14 any free-play messages into that drill?
15 A
Would you care to define a LERO free-play message?
16 Q
Well, it's true, isn't it, that changes were made 17 in the FEMA procedures to insert free-play messages based on 18 what happened at the drill?
19 A
Changes were made in the addressees on our free-play 20 messages, the addressees to whom the messages would be input-21 ted at.
22 Q
Imat occurred at the drill that generated those O
141 0
1 changes?
2 A
We observed that our perception of the plan and 3
procedures called for the messages to be input, in some cases, c4 at different levels.
5 Q
Did you or anyone associated with FEMA observe 6
LILCO or LERO personnel insert any free-play mess-ages?
7 A
- Again, I ask you to define what you mean by free-eh 8
play message.
If you mead 91nitiating an event, they had a 9
controller team that ran that drill and they interjected s
10 initiating events or atypical to what FEMA calls a free-play l
11 message.
12 So, they had controllers that interjected initiat-i 13 ing events during the drill.
14 Did I personally observe anyone interject those 15 messages, the answer is no.
16 Q
Did you know of the substance of those messages?
17 MR. CUMMING:
Asked and answered.
The witness has 18 testified that he did not observe anyone initiating any 19 messages, and now counsel is asking if he observed or knew 20 what the text of those messages were.
21 To the extent witness has knowledge, he can repeat 22 his answer.
O
142 1
().
1 THE WITNESS:
No, I do not.
2 BY MR. ZAHNLEUTER:
(Continuing) 3 Q
At that drill, was there anyone who simulated state l
i 4
or local government officials?
I l
5 A
Yes, there was.
l l
I 6
Q Which organization were they associated with?
@\\b I
7 A
I do not know the individuals.
I was introduced to 8
them, pe'I could not answer your question.
k 9
Q Can you say that they were not associated with 10 FEMA?
i l
11 A
Yes, I can, from the perspective that they were l
12 not there at our invitation.
Whether they are currently or 13 have been a member of an organization that has dealt or been 14 associated with FEMA in the past, or the present or the future, I
i 4
t 15 I could not answer that.
i 16 Q
Were the simulators that you knew of at the drill 17 the same simulators who were at the exercise?
l 18 A
No, they were not.
19 Q
Were they associated with LILCO?
20 A
Since I don't recall their names, I cannot answer 21 that question.
22 Q
Could you look at Donovan Exhibit 7 and also Page 5 1
I
143 i
O 1
of the FEMA report?
2 A
Okay.
Is that the page you are referring to?
3 Q
Yes, that's right.
I've compared the two.
Is 4
J. Brown who is on the list on Page 5 a person who does not 5
appear on Exhibit 77 6
(The witness is looking at the documents.)
7 A
It could be the same Brown as listed as G.
Brown.
8 I can't tell you for sure.
9 0
You are the lead controller; isn't that correct?
10 A
That's right.
11 Q
Are these two people or are these the same people?
i i
O' f
12 A
They are separate people, because there is a 13 G. Brown shown on Page 7.
f 14 Q
Now, when did J.
Brown become a controller?
15 A
When he arrived on February lith, as all the other 16 controllers who arrived on February lith.
17 Q
Do you know whether J. Brown had the same docu-18 ments and information that the other controllers had when he 19 arrived on February lith?
20 A
Yes.
21 O
Ilow do you know?
22 A
Because I asked.
I took the roll to determine who O
~
144 C:)
I was replacing who and asked if everyone had the Controller and 2
Simulator Plan and our letter.
They all answered yes.
3 O
Is it correct that J.
Brown was the only controller t
.4 at the Port Jefferson staging area?
3 A
Yes.
6 Q
And --
7 A
To my knowledge.
8 Q
Where did Mr. Weinstein go to?
s g
A Patchogue.
10 0
What was the reason for that?
s>
l 11 A
I don't know.
I don't know there is a valid reason.
l 12 We just noved people.
I did not slot the individuals; all I l
13 had were positions.
i 14 O
Do you know who J. Brown is?
A No, I do not other than obviously he is, or was, 15 I
I 16 an NRC employee.
g7 MR. ZAHNLEUTER:
I have no other questions.
18 MR. CUMMING:
I have a few questions.
i MS. McCLESKEY:
Mr. Cumming, I have a couple of gg questions for Mr. Donovan first.
20 MR. CUMMING:
Okay.
21 5
22
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,i 145 0
indexx 1
CROSS EXAMINATION 2
BY MS. McCLESKEY:
3 Q
I would like to talk about this meeting you had 4
with Mr. Brown.
Who called the meeting?
!)
5 A
What meeting with Mr. Brown?
6 Q
The one that you identified that you went to that, 7
I believe, you said Mr. Miller was there also and many other i
a people from the state and the county at the hotel the night 9
before the exercise.
a 10 A
Okay.
It was the day before the exercise.
My 11 recall is that FEMA Region II asked me to attend a meeting O
l 12 that had been requested by the representatives of Suffolk i
13 County and the State of New York.
14 Q
Do you recall who particularly attended the meet-15 ing?
16 A
Mr. Petrone, Mr. Glass, Mr. Kowieski, myself, 17 representing FEMA Region II.
We had a number of representa-I i
18 tives of Suffolk County and the State of New York.
I don't i
l 19 want to mispronounce it, but Palomino is what I want to say 20 but it's not the right pronunciation.
And, a representative, 21 Mr. Brown of this law firm here and other parties from this l
22 law firm.
And, there were some representatives from LILCO, I lO i
l l
i 146 Ir 1
believe, and a number of media.
P 2
Q Do you recall what the purpose of the meeting was?
s 3
A
. Well, they had several purposes.
My understanding,
)
4 when 1 was asked to attend the meeting, was just to be j
5 responsive to any questions they may have had about control-6 lers and simulators.
7 0
Who spoke at the meeting?
8 A
Mr. Petrone and Mr. Kowieski did most of the speak-9 ing for FEMA, and Mr. Brown and an individual from the town-10 ship, Suffolk County and the State spoke for the other i
i 11 parties, did most of the speaking for the other parties.
(
12 Q
Did -- was it a question and answer format, or were 13 there speeches, or how was it handled?
f 14 A
There were statements and questions and discussions.
Q Nhat was the tenor of the remarks?
15 A
Well, they were varied.
The State and the County 16 asked for certain information, asked for access to certain 17 facilities.
We did agree to -- and LILCO did agree -- give 18 19 them copies of the scenario inputs as they were interjected into the exercise.
And, we agreed that we would transfer those 20 documents to their possession at the time that they were 21 22 interjected at the LERO EOC.
O
i i
i 147
(
1 They made other requests which I felt we couldn't 2
honor, because we had already negotiated exercise ground rules 3
with LILCO and LERO and had already instructed our evaluators, f
c4 simulators and controllers in other issues.
ij 5
They made a lot of statements that -- which I was 6
not directly involved with because I didn't have a role to 7
play in responding to those questions.
t-l 8
MS. McCLESKEY:
Thank you, Mr. Donovan.
I don't l
9 have any further questions.
10 MR. BORDENICK:
I have some questions.
indexx 11 CROSS EXAMINATION 12 BY MR. BORDENICK:
i 13 0
With regard to the meeting that Ms. McCleskey just 14 questioned you about, do you have any recollection as to 15 whether or not there were any representatives of the NRC in 16 attendance?
17 A
I really don' t recall if there were or there were 18 not.
19 Q
In answering one of her questions, you mentioned --
20 let me rephrase that question.
21 Were there any representatives of LILCO present at 22 that meeting?
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148 j
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1 A
I believe there were.
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2 0
Do you recall who they were?
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A I believe it was Mr. Daverio, and I believe there G
4 was a representative of LILCO's counsel.
ij 5
0 were they at the meeting as participants or 1
observers?
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6 t
?
7 A
I believe FEMA requested their attendance not n
8 knowing the agenda of the meeting that had been requested by
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Suffolk County and the State of New York.
j i
10 0
Your answer is that they were requested to attend Y
gg the meeting by FEMA.
But, did they participate in the meeting i!
in any way, to your recollection?
12 13 A
I just mentioned that they did agree, as' FEMA pr 14 14 agreed, to give copies of the scenario injects to representa-15 tives of Suffolk County and the State as they were interjected 16 in the exercise play, and that we would give those copies.
17 They also agreed to allow limited access to certain 18 of LERO's facilities for the point of observing.
And, there i
19 again it was not our prerogative to make those concessions or 20 agreements.
l l
That was one of the reasons they were asked to 21 l
22 attend.
l l
i
i I
149 i
i 1
Q All right.
Going back to one.of'Mr. Miller's i
2 questions, I wasn't sure whether your answer got on the i
e:
3 record or not.
My recollection is that you shook your head 4
in the negative.
Rather than to take up the time to have the 5
Court Reporter go back and see whether you gave a verbal answer r
6 or not, I think he asked you whether or not you had any 7
changes or you made any changes to the draft FEMA report when j
8 you held a conversation with Mr. Kowieski, and my recollection i
,i 9
is that you shook your head in the negative.
t 10 So, I take it that your answer was no?
11 A
That's correct.
I made no -- recommended no 12 changes to the draft.
I 13 0
One other area I would like to explore with you j
14 very briefly.
There was a little confusion, or I was a little 15 confused when you were answering questions having to do with, 16 for example, the number of buses that LERO or LILCO -- I guess 17 it's LERO -- was going to use in the exercise.
18 And, you were talking about cost.
I wonder if you 19 could clarify your answer as to -- to your knowledge, was 20 cost a consideration involved in what LILCO did or didn't 21 provide as requested by FEMA for the purposes of the exercises?
i 22 MR. MILLER:
Objection.
That calls for speculation O
150 1
by this witness.
[
2 BY MR. BORDENICK:
(Continuing) 3 Q
You can answer it.
c4' A
If I implied that, I'm sorry. 'The cost was not a D
5 consideration.
The discussion was around the fact that if 6
buses or ambulances or ambulettes.-- if our free-play messages r
y were to call for demonstration in those areas 7 hat they would r
7 t
8 like advance knowledge only from the perspective of writing
.7 9
purchase orders in order to actually pay the vendors who would to provide those vehicles.
11 We indicated that, yes, they should prepare some f
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12 draft purchase orders.
But we didn't specify what bus companien 13 or what ambulance companies or what ambulette companies, i
i 14 There was no cost -- their cost was not a considera-15 tion.
The only issue was the people were to follow up 16 insofar as seeing that these vendors and providers of services 17 would be reimbursed.
18 Q
And, to your knowledge, was all the necessary paper-19 work completed?
20 A
Yes.
21 MR. BORDENICK:
I have no further questions.
22 MR. CUMMING:
FEMA counsel has several questions.
O
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,ev,_
-er,
151 0
1 CROSS EXAMINATION indexxx 2
BY MR. CUMMING:
3 Q
Could you recover the exhibit marked Donovan 2?
4 On several pages of the exhibit marked Donovan 2, there are 5
handwritten annotations.
6 If'th'e witness would review the document briefly.
7 (The witness is looking at the document.)
8 A
- yes, o
9 Q
Are any of those annotations ~yours?
10 A
No, these annotations are not mine.
n i
11 Q
Would you briefly describe the function of O
12 controllers in exercises that you have been involved with in 13 the past?
f 14 A
In the exercises I have been involved with over the i
15 last 12 or so years, we have always had controllers.
Control-16 lers are there to.. input scenario initiating events, referred 17 to in this particular exercise as far as FEI1A's controllers, i
A$
[d 18 were free-play messages; and controllers can serve another 19 function as woll, and that is to rule out of bounds or to 20 limit the direction of a plan in response to the responders.
21 In this case, our controllers for the simulators 22 were directed to insure that the simulators adhered to the
152 i
.aanagement policy and principles outlined in the Controller and 2
Simulator Plan.
3 Q
Is it accurate to state that a. controller does have 4
a role in the evaluation process, in that it is the control-i 5
ler's primary function to insure that events transpire so that 6
the evaluation may, in fact, occur?
7 A
Yes, that's an accurate statement.
We trained, and 8
we encouraged, our controllers to insure that evaluators were 9
present when they interjected their message inputs in order 10 to allow the maximum opportunity for evaluation to take place.
i 11 Q
If you would recover Donovan Exhibit Number 3.
It 12 appears to be a handwritten document.
I 13 Is that your handwriting?
l 14 A
No, it is not my handwriting.
I 15 Q
Do you have any explanation why in the lower right-16 hand corner of the two pages there is the date marked 12/13/86, 17 which has not yet occurred, in my judgment?
18 A
No, I do not.
19 MR. CUMMING:
No further questions.
00 MR. MILLER:
I want this on the record, but I'm 21 through with my questioning of the witness.
22 Mr. Cumming, we have scheduled on Thursday Mr. Husar
i t
153
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1 and on Friday Mr. McIntyre, both of whom have been designated
.:i 2
to be witnesses at the Shoreham proceeding.
I would ask you i
3 now, on the record, if it is your intent to not permit those e4-Witnesses to answer questions going to the scope of the 3
J 5
testimony that they may provide at the hearing?
j 6
MR. CUMMING:
That is correct.
7 MR. MILLER:
And, I gather from that answer that 8
you also then would object and instruct those witnesses not to 1
9 answer questions going to the contentions that have been
'I i
10 submitted by the Intervenors in this proceeding?
l 11 MR. CUMMING:
That is correct.
i
\\
MR. MILLER:
Given that representation, we will 12 13 seriously consider postponing the depositions of Mr.-Husar 14 and Mr. McIntyre, and we will advise the parties either this
?
15 afte; noon or tomorrow morning what we are going to do in that i
16 regarl.
17 MR. CUMMING:
Thank you.
18 MR. MILLER:
This deposition is over, as far as 19 I'm concerned, with the statement that I will make that, Mr.
20 Donovan, we appreci.ite your time and your coming in today.
I 21 I also note for the record that this deposition 22 is adjourned and there may be further need for Mr. Donovan to O
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come back once we have been given documents'that we have 2
requested of FEMA's counsel.
We will have to make-that 3
determination once the documents are received.
i 4
AND FURTHER THE DEPONENT SAITH NOT.
j 5
(Whereupon, the taking of the deposition was l
i 6
concluded at-1:00 o' clock p.m., Tuesday, December 2, l
1 7
1986.)
l 8
G4w1Alb.
9 wW RICHARD W.
DONOVAN 10 i
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17 18 19 20 21 22
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1 CERTIFICATE OF NOTARY PUBLIC I
t 2
3 I, Garrett J. Walsh, Jr., the officer befo're whom the 4
foregoing deposition was taken, pages 1 through 154, do 5
herphy certify that the witness whose testimony appears in 6
the foregoing deposition was duly. sworn by me; that the 7
testimony of said witness was taken by me and thereafter 8
reduced to typewriting by me or under my direction; that 9
said deposition is a true record of the testin.ony given by the 10 witness; that I am neither counsel for, related to nor
):
1 11 employed by any of the parties to the action in which this i
O 12 deposition was taken; and further, that I am not'a relative l
l l
13 or employee of any attorney or counsel employed by the l
14 parties hereto, nor financially or otherwise interested in 15 the outcome of the action.
16 17
/M
/-
GARRETT J/ WALSH, JR.[
j Notary Public in and for the 19 Commonwealth of Virginia 20 21 My Commission Expires:
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(,)
BIOGRAPHY Richard W.
Donovan Radiological Emergency Preparedness Program Officer and Regional Assistance Committee Chairman FEMA RE0 ION X Richard W. Donovan is the Radiological Emergency Preparedness Program Officer and Regional Assistance Committee Chairman for the Federal Emergency Management Agency (known as FEMA) in Region X.
His office is located in the Federal Regional Center. Bothell Washington.
Richard Donovan has been:
o involved in Radiological Emergency Planning (REP) since 1975: and o Regional Assistance Committee (RAC) Chairman longer than anyone in the (V'
10 Federal Regions.
As Program Officer, his Regional role and responsibilities include:
Coordination and guidance of Federal Radiological Emergency Preparedness o
activities to ensure adequate assistance to State and local governments in REP planning.
coordination and guidance of Field Office activities of Federal Agencies o
to ensure a coordinated response to radiological events.
Serves as Federal Interagency Focal Point of Of'fsite Preparedness and o
Operational Focal Point for the "350" Process required for approval cf Commercial Nuclear Power Plant licensees, which necessitates the following:
I
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750177
I l
Chairmq,nship of the RAC (composed of Feder'al Agencies includi_nE_ DOT.
o EPA. DOE. HHS /PHS 'FDA. NRC, USDA).
With regard to the 350 process.
the RAC follows FEMA's rule and established procedures for review and 7-k-
approval by FEMA of State and local emergency plans and preparedness for coping with offsite effects of radiological emergencies which may occur at nuclear power facilities.
FEMA has established criteria which is used in the RAC's review, assessment, and evaluation of plans and preparedness, and in making any findings and determinations with respect to the adequacy of the plans and the capabilities of State and local governments to implement them.
Implementation includes the conduct of regular exercises that are evaluated by the FEMA RX/RAC.
o Transportation.
FEMA has prepared a document entitled " Guidance for Developing State and Local Radiologica'l Emergency Response Plans and Preparedness for Transportation Accidents." FEMA RX has encouraged the States in our Region over the last several years to develop appropriate response plans and preparedness capabilities. FEMA has facilitated and sponsored various training sessions, seminars, and drills' exercises to address subjects and issues related to the
\\' l trantportation aspects of preparedness, o Response The Federal Radiological Emergency Response Plan (FRERP) applies to emergencies resulting from incidents at fixed nuclear sites and to incidents involving the transportation of radioactive materials.
The FRERP primarily concerns the offsite Federal response to, peacetime radiological emergencies, in support of State and local governments.
FEMA defines offsite support to be Federal assistance in mitigating the hazards beyond the immediate area associated with the emergency. and in determining and implementing means to protect the public.
o
- U 750178 t
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/T Federal Emergency Managerhent Agency 1
m Region 11 26 Federal Plaza New York, New York 10278 e
N.]
February 3,1986 TO:
FEMA Region !! Controllers and Simulators WpW3. h)ca/8Sbf (See Distribution List a
FROM:
Rog/r Bt Kowleski, Chairman Regional Assistance Committee AD W
Richard W. Donovan, Senior Controller
SUBJECT:
Shoreham Exercise -- February 13,1986 This memo confirms the discussions and referrals that have been held over the last few weeks concerning your partici stion as a FEMA Region !! controller and/or t
simulator for the upcoming Shoreham Exercise to be held on February 13,1986..
Attached is a memorandum referring to logistical arrangements; and a schedule of. events. Please confirm your reservations and arrange your travel plans so that you are
- with us Tuesday morning (2/11) at 8:30 a.m. through Friday (2/14) at noon (12:00 p.m.).
It Enclosed is a copy of the FEMA Region !! Controller and Simulator Plan.
contains:
Our management plan' for the exercise.
e Concept of operation.
e Controller and simulator assignments / responsibilities / instructions /
o logs,etc.
Summary of the LERO plan.
e o Exercise objectives.
Specific message and data inputs for controllers and other prompts for simulators will be provided at the February 11 training session.
Please take the time to review this plan and if you have questions, hold them and we will address them at the controller / simulator training session (s) on February 11 and 12.
O
6 2-The upcoming Shoreham Exercise will attract additional interest and inquiries O
rre= ta 9=ette. - =6 r=
r t"
=edi
=e=ders ' co"sress *ad vario"s i c i st te-and federal government offices.
We would like to take this occasion to remind all controller and simulator team members that we expect you to perform your assigned duties and tasks in a highly professional manner. You should avoid subjective comment and critique in your discussions and interfaces with the exercise participants.
No member of any team should give any comment to members of the media and public regardless of reason! All inquiries should be directed to the RAC Chairman or Public Information Officer. The statement, "we are not at liberty to comment on the evaluation until a total analysis of.all the events'and exercise play are made," should be offered in a courteous and direct manner.
Any conflicts arising with exercise participants, members of the media and public should be referred to the RAC Chairman or Public Information Officer.
The RAC Chairman and the Public Information Officer will arrange for a briefing after we have completed our evaluation process. We appreciate your cooperation in this important matter of preserving the Integrity of our evaluation process. We are looking forward to seeing you.
~
RBK and RWD: bis Attachments (2)
Region 11 memo - Shoreham Exercise (hotel arrangements)
O Itinerary for the Shoreham Exercise Enclosure (1)
FEMA Region 11 Shoreham Exercise - Controller and Simulator Plan Distribution List:
NRC Headquarters:
NRC, Region 11:
FEM A, Headquarters:
- L. Bolling
- J. Gilliland
- J. Thomas
- M. Hawkins
- A. Gooden
- V. Wingert
- J. Himes
- J. Kreh FEMA, Region II:
- M. Landau
- R. Meck NRC, Region III:
- R. Kowieski
- K. Perkins
- L. Kers
- E. Podolak
- W. Sriell FEM A, Region IX:
- J. Sucich
- C. Sakenas
- B. Weiss NRC, Region V:
- E. Weinstein
- G. Brown FEMA, Region X:
- R. Donovan
- E. Williams
- B. Zaleman O
..r
3 SHOREHAM E,XERCISE FEMA REGION !!
February 13, 1986 k
CONTROLLER AND SIMULATOR PLAN O
4 SHOREHAM EXERCISE CONTROLLER AND SIMULATOR PLAN CONTENTS 1
1 I N T R O D U CTI O N.........................................................
2 2
PURPOSE...............................................................
3 CONTROLLER' AND SIMULATOR ORG ANIZATION........................... 3 CONTROLLER INSTRUCT! ohs AND RESPONSIBILITIES.....................
5 4
5 SIMULATO R INSTRUCTIONS AND RESPONSIBILITIES........................ 8 APPENDIX A: FEMA Region !! Control Organization and Management Plan.......
13 APPENDIX B: Information/ Instructions for Exercise Players / Visitors / Observers....................................
16 APPENDIX C: Simulator Inform ation........................................ 20 AFPENDIX D: Controller' and Simulator Assignment........................... 30 C o ntro lle r Log............................................... 31 0
~
APPENDIX 5:
APPENDIX F: Si m ula t o r Log................................................ 3 2 APPENDIX G: Ex e rcise Obj ec tives.......................................... 3 3 APPENDIX H: Su m m ary o f LERO Plan....................................... 42 O
iii e
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4 1
1 INTRODUCTION A unique situation has evolved at the Shoreham Nuclear Power Station, where the State of New York and Suffolk County governments have declined to participate in emergency planning for the Station. In response to this dilemma, the utility has prepared its own off-site emergency plan which utilizes utility resources in the place of those normally provided by the State or local governments. The utility has titled the off-site plan the Local Emergency Response Organization (LERO).
Although the Licensing Boards and the New York courts have found that LILCO lacks the legal authority to implement key aspects of the LERO plan, the NRC in June of 1985, requested FEMA to evaluate a full scale exercise of the LERO plan. FEMA, the NRC, and LILCO have scheduled an integrated emergency preparedness exercise for February 13, 1986 at the Shoreham Nuclear Power Station.
Piemoe see Appendix A, FEMA Region II Control Organization and Management Plan.
I e
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2 2 PURPOSE V
This EEMA Region II document establishes the policy, procedures, and management structure for the use of FEMA controllers and simulators during the integrated emergency preparedness exercise scheduled for February 13, 1986 at Shoreham. The February 13 exercise is being conducted to test the capability of the LILCO " Local Emergency Response Organization" (LERO) plan:
e.g., off-site activities associated with the implemehtation of the LERO plan (activation of LERO facilities, support equipment, personnel, etc.).
To assist the normal' FEMA evaluation of the objectives of the exercise, FEMA will execute certain exercise control functions through controllers and will designate individuals to simulate the interface of key State and County officia.ls with LERO and LILCO.
FEMA Region 11 controller functions will be performed at the LERO EOC,
. A n /b r a b -
/ %,;j Sta ng Areas, and with the Radiation Monitoring Teams dispatched by Brookhaven g/ j we /
f
\\ Wational Laboratory (BNL).
wJr sq J-FEMA Region II simulator functions will be performed at the LILCO EOF, LERO
/ g [/8 he x@*'
EOC, and a control cell representing the local and state EOCs. The purpose of the J & <<W simulation effort (s) will be to provide an opportunity for the FEMA Region !! evaluation teams to determine if the ~LILCO' and LERO ' plans, procedures, facilities, and preparedness can:
accommodate and support State and local personnel; and provide information to State and local personnel so that they (S/L) can carry out their 8
responsibilities.
i For the purpose of this exercise, simulators re[iresenting state and local personnel willy assume a response posture. They will ask and request information, briefings, etc., in order to be informed, but will, at all times, allow the LERO staff to direct all response efforts. In order to ensure this policy is implemented, certain FEM A c,ontrollers will monitor the-interactions between FEMA simulators and the LILCO/LERO
/hAS(
exercise participants.
Ida.fhrs Y W ' ffd'S 5
3 3 CONTROLLER AND SIMULATOR ORGANIZATION The FEMA Region !! controller and simulator efforts will be directed by a senior
"'N !M 64 t yks b 4.Q $rf/or y t h l fin a pel FEMA controller who will be located at the LERO EOC.
/
j Controllers at the LERO EOC, staging areas, and with the two field radiological monitoring teams will Iriout control messages and exercise data with designated LERO exercise particip. ants. Control messages will be provided to controllers at appropriate times by the FEMA exercise team leaders. The Controller will then input the control messages to the appropriate LERO exercise participants.
Simulators will establish telephone contact _from a control cell and person to person contact with LILCO and LERO exercise participants at the EOF and LERO EOC.
_ Their interaction (s) and interfaces will be monitored by' specific designated controllers at the EOF, LERO EOC, and at the FEMA control cell.
DUTIES AND RESPONSIBILITIES o-Richard Donovan, the FEMA Senior Controller, will supervise and monitor the actions of the controller at the LERO EOC and Staging Areas (Port Jefferson, Patchogue, and Riverhead). Mr. Bernard Weiss will monitor and supervise the interaction of the simulators at the control cell. Mr./Ms. K. Perkins and C. Sakenas, the designated controllers for the simulation at the EOF and LERO EOC, will monitor and supervise the interaction of the simulators at these locations. They will provide progress reports to Mr. Weiss.
If necessary or if they are unable to contact Mr. Weiss, the designated controller for the simulator (s) at these locations will report events to Mr. Donovan. Mr.
Weiss will provide progress reports to Mr. Donovan on the interaction / interface of all simulators. Mr. Donovan will provide reports to the FEMA Region !! RAC Chairman on the actions of the controllers and the interface of the simulators.
t Please see Appendix B, Information/ Instruction for Exercise Players / Visitors /
O observers-
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4 FEMA REGION 11 Controller and Simulator Organization R.W. Donovan S'enior FEHA Controller Location:
LERO EOC Simulator Function Control Function I
l l
l E. WEINSTEIN H. IIAWKINS J. IIIHES 8..
KENS B. ZALCHAN l.oc:
PORT JEFFERSON LOC:
PATCIIOCUE LOC: RIVERilEAD I
I if E. WILLIAMS E. PODOLAK
[
l 1
1.OC :
FIELD TEAM LOC:
FIELD TEAM C. SAKENAS - Cont.
K. PERKINS
- Cont.
B. WEISS
- Cont.
J. KREll
- Sim.
J. Til0HAS
- Sim J. SUCICil - Sim W. SHELL
- Sim.
L. BOLLING
- Sim V. WINGERT - Sim LOC:
LILCO EOF A. COODEN
- Sim C. BROWN
- Sim J. CtLLILAND - Sim H. LANDAU - Sim LOC:
LERO EOC R. HECK
- Sim 1.OC :
FEMA Cont rnt Cell
~~
5 4 CONTROLLER INSTRUCTIONS AND RESPONSBILITIES CENERAL INSTRUCTIONS Controllers are responsible for inputting exercise messages and exercise data to
[ d
[ specific designated exercise participants. Controller assignments are as follows:
,,af/
a LERO EOC and Staging Area Controllers At specific times during the exercise play, FEMA team leaders for these designated areas will provide exercise messages for input. The controller will present the message to the designed player, log the time on tneir personal log, and inform Mr.
Donovan (by message number) of the event.
Field Team Controllers Field team controllers will provide radiological monitoring data (simulated gamma / gamma beta measurement, and radiolodine concentration (s)) to the field team players as conditions require:
e.g., dependent upon direction of field teams by Brookhaven Area Office and their location of the simulated plume boundaries, centerline, etc. Note: Field team evaluators will evaluate the exercise participants.
CONTROLLER RESPONSE!LITIES 1.
All Controllers shall be pre-positioned at least 15 minutes prior to the start of the exercise 2.
Prior to exercise commencement, all Controller communications will be tested to ensure satisfactory exercise control.
3.
All Controllers will compl'y with instructions from the LERO Controllers, and FEMA Region !! Lead and Senior Controller.
6 4.
Each Controller will have copies of the FEMA Region !! messages. Evaluators will O
vrovide messares at 99eenri te times to co#troiter fee i=90t-xessares shati ee delivered by the Controllers at the appropriate times, to the designated individual (s). If the response of exercise participants necessitates the use of a contingency meuage, the situation, if possible. should be discussed with the Lead Controller or Senior Controller prior to issuance of the message.
Controllers will use the following techniques to input messages and data into the exercise play in accordance with the scenario:
Control Messages - Control messages provide information to the participants a.
and/or cause the participants to take action needed to keep the exercise moving smoothly. The Controller will give a hard copy of the control message to the designated puticipant at the specified time.
Simultaneously, the Controller will provide he essential information verbally. The Controller will follow through and clarit7 the message by answering questions to ensure that O~
the participants do not read extraneous meaning into the message. Controllers will not tell participants what action they are expected to take.
b.
Contingency Messages - Contingency messages will be used only if participants fall to take the major actions expected from the control messages by the time designated. Controllers will give the contingency message to the designated participant and explain in as much detail as necessary what actions the participant is expected to perform. Contingency messages are used to keep the exercise on schedule, though, their use may indicate inadequate plan implementation.
I Control Information - Controllers for Health Physics and Environs Field Teams c.
1 will provide instrument readings and other information to team members j
verbally. Controllers will refer to their current location on De maps and the 0
99 e eie time 9ertee to eet i reaeestee e t -
ti
l 5.
All ' Controllers shall synchronize their watches to ensure that messages are O
delivered at the proper time. Times on messages given in clock time and time relative to the start of the scenario, i.e., 00:00 (07:00) indicates time zero (start) and 7:00 AM.
6.
Each Field Team Controller will have copies of radiological parameters (data) corresponding to the development of the exercise scenario. This information should be issued, when required, to the appropriate exercise participants.
7.
Controllers shall not provide information to the exercise participants regarding scenario development or resolution of problem areas encountered. The exercise participants are expected to obtain information through their own organizations or control cell and exercise their own judgments in determining response actions and resolving problems.
8.
Any inquiries originating from the general public, as a result of exercise activities, will be referred to either the LERO Master Controller or Senior FEMA Controller.
An explanation will consist only of stating that a practice drill is underway at the plant and all events are simulated (i.e., not real).
9.
Some exercise participants may insist that certain parts of the scenario are unrealistic. The LERO Master Controller has the sole authority to clarify any questions regarding scenario content.
10.
Each FEMA Region II Controller, with the exception of the two (2) Field Team Controllers, is expected to log the time (s) that he/she inputs FEMA Region !!
control messages. If other controller / player discussions / interactions occur, these times with appropriate comment (s) should be logged as well(see Appendix _).
11.
The exercise is tentatively scheduled to end at approximately 5:30 PM.
NOTE: In the event of a real emergency during the exercise, the exercise may be immediately terminated by the LERO Master Controller, if deemed appropriate.
1 1
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7-13 APPENDIX A:
f-f FEMA REGION II CONTROL ORGANIZATION AND MANAGEMENT PLAN The Shoreham exercise, scheduled for February 13, 1986, will be a unique Radiological Emergency Preparedness (REP) Exercise.
This situation has evolved because the State of New York and the Suffolk County government have declined to participate in the emergency preparedness efforts for this site. In response to this dilemma, the licensee (LILCO) has prepared its own offsite emergency plan which utilizes utility resources in lieu of the normal state / county resources. The offsite plan and response organization is referred to as "the Local Emergency Response Organization (LE RO)."
In this exercis2, as in other REP exercises, the NRC Region I evaluation team will evaluate the onsite efforts of LILCO. The FEMA Region 11 evaluation team will evaluate the offsite effo::ts of LERO and support agencies. Due to the uniqueness of the
~
Shoreham situation, NRC and FEMA have requested LILCO and LERO to demonstrate that they can accommodate State and local personnel with regard to information and coordination.
Because of the State / local government's refusal to participate in the normal radiological emergency preparedness efforts, this exercise will assume that the State / local government will not activate their emergency powers and authorities:
e.g.,
at no time will the State / local government assume responsibility for protective action decisions, or take actions to effect/ implement these decisions.
The State / local government can be expected to maintain their normal (day-to-day) activities and responsibilities (e.g., traffic control, snow removal, response to traffic accidents, etc.).
In order to provide the opportunity for LILCO and LERO to demonstrate that they can accommodate State / local government representatives and requirements for information, FEMA' Headquarters will provide simulators to LILCO and LERO facilities (EOF & EOC)
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and will provide a control cell to simulate State / local government EOCs and normal work v
locations. The FEMA simulators will be under the management control of the Chief FEMA Region II Controller, who will report to the FEMA Region II Senior Controller.
The FEMA Region II Senior Controller will also manage FEMA controllers. The overall management responsibility for FEM A's evaluator's, simulators, and controllers will rest with the FEMA. Region II RAC Chairman. The controllers will input FEMA Region II control messages and exercise data at various times to various LERO exercise participants. The purpose of the FEMA Region II controllers and simulators will be to provide an opportunity for the FEMA Region II evaluation teams to determine whether the predetermined exercise objectives have been satisfactorily demonstrated. Note: The one unique aspect of this exercise in terms of FEMA's evaluation efforts is the use of simulators for State / local government, due to the lack of State / local participants.
As in other REP exercises, LERO has designated a Master Controller and a
(~i control organization (e.g., designated controller, control cell, etc.). The FEMA Senior v
Controller has coordinated FEMA's efforts with LERO's efforts in order to minimize the potential for conflict. They will be co-located during the exercise in order to provide a point of control / interface in the event an issue / conflict needs to be resolved, or if certain limiting conditions need to be placed upon exercise play. At all times, the LERO Master Controller and control organization will be in charge of the exercise scenario (time line/ initiating events and extent of exercise play / demonstration). FEMA Region !!
controllers will input certain exercise messages and exercise data at various times during the exercise. FEMA r,imulators will seek (telephonically and in person) information (e.g.,
plant status, information on release, 'agie/ rationale of decision, etc.) from various LILCO/LERO exercise participants.
NOTE: Controllers and Evaluators should review:
,U Information (instruction for exercise players / visitors / observers) e
~
15 NOTE: FEMA Region II Controllers should review FEMA Region 11 exercise control instruction and FEMA Region II Controller /Simutuator Plan.
[
NOTE: FEMA Region II Simulators should review FEMA Region II Simulator Handbook.
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CONTROLLER LOG Assignment: LEEO-Ecc Message #
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31 APPENDIX E:
O CONTROLLER LOG 4
Assignment: Leto-Eoc-Message f Input Point Time lfl
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/'m6' T Federal Emergency Management Agency e
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Region 11 26 Federal Plaza New York, New York 10278 v
,w 1/IS/86 Mrorandtra for: Pecord My 3. $wW' Fran:
Poger B. Ibaieski, PIC Chaiman
Subject:
Shoreham Exercise Plann.ing Meeting On January 14 and 15, 1986, representatives of FD%, NFC, Argonne National Laboratory (FDR's contractors) and Idaho Nuclear Engineering Iaboratory (FD%'s contractor) met at 26 Federal Plaza, New York City to discuss the upcaning Shoreham exercise.
In attendance:
o Bernie Weiss, NBC Headquarters o Cheryl Sakenas, NFC Headquarters o Thcmas.Baldwin, Argonne National Laboratory o Fdaard Tanzman, Argonne National laboratory o Joseph Keller, Odaho Nuclear Engineering Laboratory
,q o Richard Donovan, FD m, Pegion 10 Roger B. Kowieski, FDR,' Pagion 2 V
o The purpose of this meeting was to review the progress made in exercise preparation.
Issues discussed:
Roger Kawieski announced that Richard Donovan, PIC Cha.iman, Pegion 10 o
has replaced Bill Stokes of TBA as FDR's Lead Controller for the Shoreham exercise.
i Kowieski explained to all attendees as to how T.TTm plan is structured o
l and how LERO organization','inteMed to operate.
l l
o Kawieski and Baldwin explained the obserwr assigments and free play concept.
Draft observer packet has been reviewed and coments trade by all represent-o atives.
[
Draft control plan and simulator plan prepared by TBA were reviewed aM l
o nodified by Richard Donovan, Bernie Weiss aM Cheryl Sakenas. The revised control /siin.tlator packet has bee.n extensively discussed and concurred by all parties on January 15, 1986.
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Controllers /Si:nilators Assienments jIncation Controllers w _3, m _,,,
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LEPO ECC e 1 Senior FEMA e Controller for o County Dc. Pep.
Controller EXI Sinulators e County Health Pep.
e 1 Controller e County PIO e State Health Pep.
-e-Stato l'W LIICO EOF e Controller for s State Health Pep.
Sinulators e County Health Pep.
Patchogue e 1 Controllers Staging Area Port Jefferson e 1 Controller Staging Area Riverhead e 1 Controller D
Staging Q
i Area 2 Field e 2 controllers tenitoring Tea:rs FD% Control e State Health Cell / State Camissioner EDC e Health Pep.
FDR Control e 1 Controller o Cottty Exec.
Cell / County e Health Pep.
E:OC e Others a
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o Conference call for all controllers and sinulators has been scheduled for January 23, 1966. By that time, FD4A Headquarters will provide to mC Poger Kowieski three na:nes of FDR simulators.
o It was agreed that the Team leaders of Federal evaluation team, sane key observers and controllers will attend the January 30, 1986 drill.
Tne main purpose of this observation is to familiarize ourselves with the layout of each facility and concept of operation, o A target date for mailing the observer and controllers packages was established for February 3, 1986.
o It was reccmended that FDR should contact the Brookhaven Area Office and investigate the availability of telephones for FFNs Ccmnand Posts (6 instruments and 18 lines). Ibger Kcwieski agreed to follcu-up on this suggestion.
State Sinulators @ Ccmnand Post o 2 players (2 instruments with 3 lines each)
County Simulator @ Ccmnand Post o 3 players (3 instrumnts with 3 lines each) o 1 Controller (1 instrumnt with 3 lines).
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731261 l
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Federal Emergency Management Agency 1
l Region II 26 Federal Plaza New York, New York 10278 pd d23/er Memorandum For:
The File 8
From:
Ro e B.
Kowieski Chairman Regional Assistance Committee
Subject:
Conference Call with Controllers and Simulators On January 23, 1986, a conference call was held among the exercise controllers, simulators, FEMA and NRC staffs.
Participants:
E.
Jordan, NRC L.
Bolling, NRC E.
Chrisenbury, NRC A.
Gooden, NRC K.
Perkins, NRC G.
Brown, NRC Schwartz, NRC M.
Landau, NRC B. Weiss, NRC B.
Zalcman, NRC M.
Blume, NRC R. Donovan, FEMA L.
Kers, NRC Y. Thomas, FEMA E. Williams, NRC R.
Kowieski, FEMA E.
Podolak, NRC E. Weinstein, NRC M.
Hawkins, NRC Y.
Himes, NRC R.
Melk, NRC Y.
Kreh, NRC W.
Snell, NRC Issues Discussed:
Background - How Did We Get Here B. Weiss MEC y
Normad Exercise Functions R.
Kowieski, FEMA Differences for Shoreham Exercise R.
Kowieski, FEMA LERO Plan R.
Kowieski, FEMA Control Plan:
Message Injects R.
Donovan, FEMA Simulation of State &
Local Officials R. Weiss, NRC Legal Concerns:
Suffolk County Legislation E. Christenbury, NRC Participant Sensitivities Further Training B. Weiss, NRC Logistics R.
Kowieski, FEMA 1
731588
y lcanuly f r # h
/Wi Federal Emergency Management Agency i
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~S Region II 26 Federal Plaza New York, New York 10278 (G
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Memorandum For:
The Fil
?
From:
B.
Kowieski Chairman Regional Assistance Committee
Subject:
Shoreham Exercise Planning Meeting On January 24, 1986, a meeting was held with the representatives of LILCO, FEMA and Argonne National Laboratory.
In attendance:
D.
Behr, Impell/LILCC B. Aidikoff, Aidikoff Assoc.
R.
Donovan, FEMA R.
Kowieski, FEMA T.
Baldwin, Argonne National Lab.
(3 Issues discussed:
V 1.
January 30, 1986 drill a.
Drill Time line UE 0810 Alert 0900 SA 1000 6E 1130 Exercise 1500 Termination b.
Training session prior to drill - January 29, 1986 Training session for LERO participante and FEMA representatives will be held between 1:30 pm and 5:00 pm.
l 1
1 Location:
225 Broad Hollow Rd.
(Rte. 110) l Exit 49 North of LIE 3rd Office Building on right, 3rd floor 731788
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2.
Medical Drill Medical drill is scheduled on February 9, 1986.
LILCO will advise FEMA about time and location (by Monday, 1/27/86).
3.
Procedures 1
LILCO will provide copies of procedures by 1/30/86.
4.
Congregate Care Centers LILCO will provide FEMA with names of facilities to be used as congregate care centers.
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u 731799 1
f)l}84 FEMA REGION 11 Controller and Simulator Organization R.W. Donovan Senior FEMA Controller Location:
LERO EOC Simulator Function Cont rol Function
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PORT JEFFERSON LOC:
PATC110 CUE LOC: RIVERilEAD I
I if E. WILI. LAMS E. PODOLAK I
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FIELD TEAM LOC:
FIELD TEAM C. SAKENAS - Cont, K. PERKINS
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