ML20207A330
| ML20207A330 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/10/1987 |
| From: | Saegert S CITY COLLEGE OF NEW YORK, NEW YORK, NY, LONG ISLAND LIGHTING CO. |
| To: | |
| References | |
| CON-#287-3225 OL-3, NUDOCS 8704270136 | |
| Download: ML20207A330 (48) | |
Text
ws en,a-ogggg IIMN'SCluP1 O
C'F PROCEEDIN~GS APR24 A9:1 ffFiL
'N i
t UNITED STATES OF AMERICA 0CK
'b Biit NC>i NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
-- -------- - - - - - - - - -x In the Matter of:
Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY (Emergency Planning)
(Shoreham Nuclear Power Station, Unit 1)
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x OU DEPOSITION OF SUSAN SAEGERT Washington, D.
C.
Tuesday, March 10, 1987 ACE-FEDERAL REPORTERS, INC.
Stenotype &qvrters 444 North Capitol Street
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UNITED STATES OF AMERICA w
NUCLEAR REGULATORY COMMISSION 2;
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
I k - - - - - - - - - - - - - - - - -x i
4 i I
j In the Matter of:
I 1
Docket No. 50-322-OL-3 5"
LONG ISLAND LIGHTING COMPANY J
(Emergency Planning) j 6
(Shoreham Nuclear Power Station, Unit 1) 7
___ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 8
DEPOSITION OF SUSAN SAEGERT i
9 !
l Washington, D.
C.
10 Tuesday, March 10, 1987 11 l l
Deposition of SUSAN SAEGERT, called for examination 12 -
'/
pursuant to notice of deposition, at the law offices of 13 Kirkpatrick and Lockhart, 1800 M Street, N.W.,
Tenth Floor, 14 Conference Room A, at 1:30 p.m.
before KATHIE S.
WELLER, a Notary Public within and for the District of Columbia, when were present on behalf of the respective parties:
16 JAMES N.
CHRISTMAN, ESQ.
17 Hunton & Williams 707 East Main Street 1R P.
O.
Box 1535 Richmond, Virginia 23212 19,
On behalf of Long Island Lighting Company.
i 20 CHRIS McMURRAY, ESQ.
21 Kirkpatrick & Lockhart 1800 M Street, N.W.
Suite 900, South Lobby 77 Washington, D.
C.
20036
,s i j On behalf of Suffolk County.
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CONTENTS WITNESS EXAMINATION 2.
i 1
Susan Saegert 3
by Mr. Christman 3
4 j
j 5
SAEGERT DEPOSITION NUMBER IDENTIFIED 7 ' Exhibit 1 25 Exhibit 2 30 8
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10 11 i I
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13 14 15 16 17 18 19 i
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Whereupon, 3
SUSAN SAEGERT 4
was called as a witness and, having first been duly sworn, 5
was examined and testified as follows:
6 EXAMINATION 7
BY MR. CHRISTMAN:
8 Q
This is the deposition in the shoreham licensing 9
proceeding before the Nuclear Regulatory Commission Docket 10 No. 50-322-OL-3 and the subject is reception centers under 11 the LILCO off-site emergency plan for Shoreham.
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12 I will ask the witness to identify herself by name 13 and address.
14 A
Susan Saegert of the City University of New York 15 Graduate Center, 33 West 42nd Street, New York, New York.
16 Q
I'm James N. Christman.
I'm with the firm of 17 Hunton & Williams.
I represent the Applicant, the Long 18 Island Lighting company.
19 Dr. Saegert, just to set the stage, can you 20 describe for me what you understand to be the reception 21 centers for the shoreham emergency plan?
22 A
These are three locations that LILCO has O
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1 identified as sites for monitoring people for possible
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2 radioactive contamination.
3 Q
Do you have any opinions about whether those three l
4 reception centers are suitable or adequate for their purpose?
5 A
Yes, I do.
I think they are not adequate.
6 Q
In what respects do you think they are not l
7 adequate?
8 A
Well, first, they are not adequate to accommodate t
9 the size of the population that we expect will require
}
10 monitoring.
Secondly, it is possible that the configuration 11 of the sites, the actual layout and so on, particularly the
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12 things that are stored there, might present obstacles for i
13 organizing the monitoring function.
1 i
14 Q
Any other inadequacies you feel?
J 15 A
Not at the moment.
Today was the first time I j
16 have seen descriptions, well, photographs of the sites.
17 Q
Okay, what photographs did you see today?
i 18 A
I saw some apparently aerial view photographs, I
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19 suppose, that Mr. McMurray showed me.
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20 (Discussion off the record.)
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21 BY MR. CHRISTMAN:
1 i
j 22 Q
The area photographs, how many were there?
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A I believe there were six.
2 Q
Do,you know who took them?
j 3
A No, I don't.
4 Q
But they were showed to you by Mr. McMurray, 5
counsel for suffolk County?
6 A
That's correct.
7 Q
Were there they color or black and white or blue?
8 A
They were colored.
9 Q
Regular optical photos, glossy with a white 10 border?
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11 A
Yes.
i j
12 Q
Did you look at anything else today concerning the 1
13 reception centers?
14 A
I looked at the depositions that were taken from 15 Doctors Lindell and Mileti and also Dr. Cole's deposition.
I
,l 16 (Discussion off the record.)
i 17 BY MR. CHRISTMAN:
j 18 Q
Did you look at anything else?
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19 A
New today?
I reviewed some information that I 20 have on revisions in the LILCO plan with respect to the l
21 reception centers.
I 22 Q
What were those materials on revisions?
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A They were instructions to the various personnel i
2 about what their jobs would be and some description of the 3
equipment to be used in this situation.
4 Q
Do you know where those documents came from or who 5
wrote them, who created them?
6 A
It is my impression that they were written by 7
LILCo.
8 Q
Did you get those from Mr. McMurray also?
9 A
Yes, I did.
10 Q
And you got those just today?
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11 A
No, I received them perhaps a week ago.
L.)
12 Q
Let me see You mentioned two possible problems, 13 one, the size being adequate to accommodate the population 14 you expect will require monitoring and that the possible 15 configuration or layout might prove a problem.
Let me ask 16 the question a slightly different way.
Are there any 17 concerns about the adequacy tha: you have at this point in 18 time?
19 A
Yes.
With regard to the plan, I'm concerned about 20 its inadequacy in terms of dealing with the kinds of human 21 behavior that will actually occur in the situation.
22 Q
Let's go back to the first thing you mentioned, ace FEnEnAt REPORTERS, INC.
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1 the size of the population that might require monitoring.
2 How many people do you think might have to be handled at the 3
three reception centers?
4 A
Well, I would use Dr. Cole's survey as a ballpark 5
estimate.
He estimated that around I believe it was over a 6
million people, I think, 12 or 13.hundred thousand people, 7
would require monitoring.
He estimated that based on the 8
population projections of the survey that he conducted.
9 Q
So you accept his estimates of the number of 10 people who might show up or --
11 A
I said it would be a ballpark estimate.
The
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12 actual numbers would depend naturally on the conditions of 13 the accident.
I think in any condition serious enough that 14 LILCO would advise people to go to be monitored that you 15 could expect a number close to that that Dr. Cole reports, 16 because that's the sort of scenario that was being used in 17 the questioning.
If the accident were by some chance more 18 serious, more clearly dangerous and life-threatening, you 19 might even expect a larger number, and then of course there 20 would be some people who might already have evacuated prior 21 to that announcement, so therefore they would be subtracted 22 from the number, but I think that you could expect close to a ACE FEDERAL. REPORTERS, INC.
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1 million.
If even a third of those people who said that they 2
would evacuate failed to show up, you would still have, I 3
believe, 800,000 people, more than 800,000 people seeking 4
monitoring.
5 Q
Are there any other -- is there any other support, 6
evidence or basis for these estimates that you have given me 7
other than the Cole surveys?
8 A
For estimating the number of people who would 9
evacuate on Long Island I would rely on the Cole surveys.
10 I'm also responding to information I have gathered about 11 seeking of medical advice and help throughout Western Europe l' }
12 in the Chernobyl incident.
13 Q
And what does that information consist of?
14 A
I have obtained some documents from various 15 scientific organizations in Western Europe that released 16 reports about what occurred in Chernobyl as well as relying 17 on the New York Times coverage which has been cited by 18 numerous disaster experts as being the best source of 19 information about Chernobyl at this point.
20 Q
Starting at the end of that answer, who are the 21 experts you can recall who cited the New York Times coverage 22 as reliable?
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A Frankly, I cannot recall their names right now.
I 2
can tell you the procedure we -- I followed, which was to 3
telephone people at various university centers who have 4
consistently done research on disasters and to inquire who 5
there was conducting research on this topic, what was 6
available and what source they thought was most reliable at 7
this time.
8 Q
Do you remember any of the university centers that 9
you called?
10 A
Yes.
I called the one in Colorado at Boulder, and
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11 I called -- my research assistant rather called the one at 12 Clark, and I believe we called several other places, but I 13 don't recall right now which ones they were.
14 Q
You don't remember any of the people that you 15 talked to or that --
16 A
I don't.
That will be in my written testimony.
17 Q
I take it you must have a document somewhere that 18 has their names?
i l
l 19 A
Yes, I have a list of them;, I just don't recall 20 them.
21 Q
Now, do you recall the scientific organizations in i
22 Western Europe that produced the substantive documents about l
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2 A
No, I don't.
I also do have their names 3
available.
4 Q
And roughly how many documents in terms of pages 5
or thickness of pile or any other measure you want to use do 6
you have again on Chernobyl?
7 A
Not counting the New York Times material which we 8
didn't copy, maybe three or four documents, not terribly 9
thick.
10 Q
Can you describe any of the three or four
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11 documents by name, title or anything else about them you can
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12 remember?
13 A
All I can remember about -- I wish I could recall 14 the organization.
There was an organization in Western 15 Europe that attempted to bring together participants in the 16; evacuation and monitoring in Western Europe and the Soviet 17 Union, and they gathered reports from these various sources 18 about the technical aspects of the accidents including the 19 evacuation procedures.
What was available was a summary.
20 Some of the technical reports were not available.
Most of 21 the reports concerning evacuation were not, 22 Q
Are you going to be receiving any more documents U
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1 about Chernobyl?
2 A
Should any become available, yes.
3 Q
Will you have to make further inquiries or have 4
you already requested things that just have not become 5
available yet?
6 A
We would have to make further inquiries or new 7
material would have to be released from the sources we have j
8 already contacted.
9 Q
What was the substance of these various papers
]
10 from the European organizations that might bear on the use of
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11 the Shoreham reception centers in an emergency?
12 A
There are probably two points that are most 13 relevant.
One is that the need to monitor and decontaminate j
14 people in the area of Chernobyl slowed down significantly the i
}
15 evacuation in that situation because of lack of i
16 preparedness.
The other issue.has to do with spontaneous 17 evacuation, which supports our contention that people will l
i l
18 try to evacuate even if they are not advised to do so.
19 Q
How did the need to monitor and decontaminate slow l
l 20 down evacuation?
21 A
Well, the details are not very informative.
As 22 far as we could tell, it had to do with a lack of expectation l
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1 that the amount of people, the number of people who had to be i
2 decontaminated would have to be decontaminated, and also a j
3 lack of preparation for the scope of the emergency in 4
general.
t j
5 Q
Lack of preparation, and so it just took longer to 6
do than should have because they weren't ready to --
7 A
Yes.
I don't recall all of the details of their 8
lack of preparation and, as I said, very few details are j
9 available.
10 Q
What did you learn about spontaneous evacuation, i
11 people evacuating without being told to?
(}
12 A
Particularly, in Kiev, large numbers of people 13 attempted to evacuate, and especially to evacuate their l
14 children during the incident, and many were successful 15 despite the fact that travel is very difficult in the Soviet i
16 Union.
17 Q
Do you remember numbers?
I i
18 A
No, I don't know that there are any reliable 19 estimates.
There were reports that there were virtually no i
j 20 young people on the scene in Kiev after the accident, and I
j 21 there were reports of crowding and near riot conditions at i
22 the railroad stations.
I ACE. FEDERAL. REI'ORTERS, INC.
202 347 370)
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Q Apart from spontaneous evacuation, do you conclude 2
anything from these materials about human behavior, other 3
aspects of human behavior in an emergency?
4 A
Well, I think that they add to the growing and 5
consistent picture of the public's extreme fear of 6
radioactive contamination.
I think they also suggest that 7
people will act on these fears, and that as an accident 8
develops, the size of the response may be very great.
9 Q
Were there cases of -- you said "near riot 10 conditions."
Were there cases of irrational or panicky 11 behavior at Chernobyl, do you know?
}
12 A
Yes, there were a number of instances of that.
13 Q
Do you remember any of them?
14 A
Well, there were reports that some of the workers 15 in the plant refused to participate in the evacuation and in 16 the work of getting the emergency under control because of 17 their fears, and there were also reports of stressed, le demanding, panicky behavior at railroad stations in the 19 Soviet Union, in Kiev.
20 Q
Some of those workers at the plant behaved 21 heroicly, didn't they?
22 A
That's also true.
Some did and some showed high O
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1 levels of fear and inability to perform.
2 Q
I believe on the question of the size of the 3
population who might use reception centers, we've mentioned 4
the Cole surveys and the documents you have gathered about S
Anything else you can think of that might support 6
your thesis that there would be.a large number of people 7
using the reception centers?
8 A
I believe the work by Lindell and Barnes would 9
support that in substance.
10 Q
How does that support your thesis?
11 A
Well, it shows the high levels of fear that people l (}
12 have concerning radiation from the nuclear power plant l
13 accident, and it shows that it is specifically related to I
14 fears of contamination.
15 Q
How does it show the latter specifically related?
16 A
There is information in the study -- the 17 researchers asked specific questions concerning beliefs about 18 the effects of such an accident.
Some of those had to do 19 with expectations that a person could be exposed to 20 radiation.
21 Q
We probably ought to try to specify which study by 22 Lindell and Barnes that you are talking about.
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A Yes, it has " behavioral intentions" in the title.
2 It is a rather long title.
A 1986 study, and they are the 3
only authors.
4 Q
Have you looked at other work by Lindell or S
Barnes, either one?
6 A
Primarily by Lindell.
7 Q
What were the other things that you looked at?
8 A
I looked at some of the work he has.done with i
9 Perry on guidelines for evacuation planning and for hazard 10 response and disaster response.
11 Q
And what in that work,.if anything, supports your
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12 testimony?
13 A
I haven't examined that work carefully with regard 14 to this issue.
15 Q
Did you examine it with regard to other issues?
16 A
Yes, with respect to the evacuation shadow and the t
17 accuracy of the -- efficacy of the EBS messages.
10 Q
And how did the -- what did the paper tell you 19 about the shadow phenomenon and the efficacy of EBS messages?
20 A
Well, it told me that those authors, as others who 21 work on the topic, look to TMI as a precedent and are 22 interested in and concerned by the large number of people who ace FEDEltM. Riti>oitTnits, INC.
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spontaneously evacuated in that situation and attempted to 2
look at that as a situation from which to understand how an 3
evacuation in the case of a nuclear incident could be i
4 handled.
They also developed some criteria for effective i
5 messages.
6 Q
You said that Chernobyl experience was consistent 7
with the growing body of information that people fear 8
radiation -- radioactive contamination and that people will 4
9 act on their fears.
In addition to the coal survey or i
10 surveys and the Chernobyl documents we've talked about, what I
11 other documents or papers or studies are in that body of
- (}
)
12 information?
i i
13 A
Well, there's the large body of research that came i
14 out of TMI, ranging from the Rogovin & Frampton report i
15 through the studies by individuals and groups that are
{
16 frequently cited in this area, Houts and his colleagues, 17 Bromet's work.
The work of Baum and his colleagues looking 18 at stress caused by living with the aftermath of the 19 accident.
I think Lindell's work fits in here.
There's the 20 work of Slovic, Fishhoff and Lichtenstein and then other work l
l 21 by that group with different orders of names, i
i 22 Q
Anything else?
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1 A
Those are all that come to mind now.
There might 2
be others.
3 Q
Tell me about the concerns you have about the 4
layout of the configuration of the reception centers 5
themselves and how that might cause difficulties.
6 A
Well, I just began to look at this today, so I 7
have not completed my analysis, but there are quite a few 8
barriers to freedom of movement here, and it seemed to me 9
that the instructions for moving people around were somewhat 10 complicated and that the spatial configuration was fairly 11 tight.
If the numbers of people in that space far exceeded
(~ }
12 the estimates, you can have an extremely crowded situation in 13 which people I think would find it very difficult to follow 14 instructions, very confusing, and would probably be subject 4
15 to long waits prior to being contaminated and possibly even 16 long waits prior to being decontaminated -- I mean monitored 17 and decontaminated.
18 Q
You mentioned problems of human behavior and I i
19 sense that -- well, I sense you are not talking about people 20 evacuating who had been advised to, but rather people 21 behaving in ways that are counterproductive to getting the 22 monitoring and decontamination done; is that right?
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1 A
Yes.
2 Q
And what do you think might occur in terms of that 3
behavior?
4 A
The first, most obvious thing would be in the case 5
of a real accident, people would have large numbers of very 6
urgent questions to ask and, given the information provided 7
by LILCO from other sources, those questions would be for the 8
most part still unanswered.
This would be people's first 4
9 encounter with a living LILCO-LERO representative, and those 10 personnel would be subject to barrages of questions, many of 11 which they would be probably unprepared to answer, which
(}
12 would further aggravate the frustration and sense of being 13 evaded that many members of the public will have in the case 14 of an evacuation.
This will increase this, plus waiting, 15 plus a general stress of the accident will tend to increase 16 hostile and aggressive feelings and probably actions.
I 4
17 think it is quite safe to predict that there would be large 18 numbers of aggressive exchangen between people waiting to be 19 monitored or waiting _to be decontaminated and LILCO personnel 20 around these issues and around the wait.
21 Q
Arguments or fistfights?
22 A
Possibly it might even go to fistfights.
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Q Is that what happened.at the train station in 2
Kiev?
3 3
A The reports are not really clear on exactly what 4
happened.
I will be attempting to find more information out S
about that, however.
I think that this is not too 6
farfetched.
Many,of us who have been caught in -- I'm 7
relying primarily on research in psychology linking 8
frustration and stress to aggressive behavior.
Some of my 9
own research is on people's feelings and reactions to 10 crowding in public places with strangers, so I think there's
('}
11 a scientific body of evidence behind this, but I also think 12 if you think about the experiences one observes, for example, 13 in crowds at airports during, say, a snowstorm at Christmas, 14 that sort of thing is not at all farfetched.
15 Q
When you talk about your research, are you talking 16 about the work you did at Ann Arbor, I think it was -- with 17 was it a simulated shopping situation?
18 A
That was my dissertation, was a laboratory study, 19 but I then conducted research in train stations and 20 department stores in New York City, and supermarkets.
21 Q
Train stations, department stores and 22 supermarkets?
(
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1 A
Yes.
2 Q
And where were those references published?
3 A
Well, one was published in " Environment and 4
Behavior."
One was published in the " Journal of Personality 5
and Social Psychology," and another paper I did with a 6
student we presented at the American Psychological 7
Association.. We never finished working it up for 8
publication, but it is available from the Center for Human 9
Environments.
10 Q
And those references, from those references you 11 concluded what about the connection between stress and
(~'}
12 aggressive behavior?
13 A
Well, in those studies, we found that people 14 reported feeling -- particularly men, more hostile and 15 negative and more anxious just by being in a crowd.
This is 16 without any negative encounters or frustrating encounters by 4
17 personnel in the situations.
We also found that they were 18 less able to find things in the environment, less-able to l
19 follow instructions and less able to complete simple tasks, 20 all issues, I think, in this situation.
21 Q
How does the body of evidence on this subject 22 differ from the body of supporting evidence when you ace FEDERAL REPORTERS, INC.
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1 testified in 1984 in the Shoreham proceeding?
2 A
I'm not clear on what you are asking me.
3 Q
You testified on similar subjects, for instance, 4
inability of drivers to process information, and possible 5
aggressive behavior back in 1984 in the Shoreham proceedings.
6 A
There have been no contradictory findings.
There 7
have been new studies carried out on things like behavior in 8
fires and so on.
9 Q
Can you tell me what those new studies that are in 10 your judgment consistent have been, behavior in fires, for 11 instance, what has been done since, say, '84?
(}
12 A
Well, there's some research that Beth Loftus and 13 her colleague have done on fires that I'm taking into account 14 now.
15 Q
Is that published work?
16 A
Yes, it is published.
I believe it is published.
l l
17 Q
Do you know where, when or the title of the l
l 18 publication?
l l
19 A
No, I don't.
You would have to consult 20 Dr. Loftus.
l 21 Q
But you have seen it and are going to use it?
l l
22 A
I have seen some excerpts from it and I intend to ACE FEDERAL REPORTERS, INC.
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1 see more of it.
2 Q
What else do you plan to use or look at in writing 3
your testimony?
4 A
Well, I review articles on this topic for
.5
" Environment and Behavior" and I believe that I have reviewed 6
some new material in the last few years.
I will check back 7
over that and see what's come out.
8 Q
I take it you have a file of the articles that you 9
have reviewed in the last couple of years?
10 A
No, that's not allowable but I will check what's 11 come out in the journal.
(}
12 Q
That's the journal of " Environment and Behavior"?
i 13 A
Right.
And also the other new journal, the 14
" Journal of Environmental Psychology."
I might check other 15 psychology journals that would have such information.
i 16 Q
Such information, are you talking about papers 17 that might bear on behavior under stress?
18 A
Yes.
19 Q
Do you have in mind any other possibilities other 20 than fires or of course anything about radiological 21 emergency; do you know of any other situations that might i
22 have been treated in the literature that might be relevant?
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A Well, I'm not sure the extent to which I will 2
testify on the topic of worker behavior, but there's quite a 3
large research on the effects of stress and fatigue on 4
workers' performance.
5 Q
And I suppose they show that stress impairs worker
)
6 performance?
7 A
Under certain conditions and over certain periods 8
of time.
Depends on the person on the job and the knowledge
~
(
9 of the person.
10 Q
Can you remember any of those specific standards
}
11 that bear on worker behavior or the researchers?
12 A
I was reviewing one this week in a book called --
13 by Warburton, I believe was the editor.
I referred to that 14 source in my previous testimony.
I have seen new things on 15 that in the last few years in connection with my teaching and 16 I probably reviewed them, but I don't recall now the sources.
17 Q
I guess that's why I'm curious.
Do you have to 18 research through the abstracts from scratch or have you kept 19 a file of those that you can just go back and pull out?
20 A
I have bought books on the topic.
That's probably 21 where I will start.
l 22 Q
Go to your personal library?
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(~')
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1 A
Yes, and I will probably ask my research assistant 2
to look through some of the abstracts if there's time.
3 Q
Doctor Johnson and Dr. Cole have both been 4
designated as witnesses for Suffolk County on reception 5
centers as well.
Do you anticipate you will be testifying in 6
a panel with them or separately?
7 A
Probably a panel.
We haven't decided.
8 Q
How is your testimony likely to differ from 9
Dr. Johnson's or Dr. Cole's?
And by " differ" I don't mean 10 that you will disagree with them, but what unique perspective 11 do you bring to this testimony that they might not have?
}
12 A
Well, a greater familiarity with the psychological 13 literature of human information processing and behavior under 14 stress, particularly under crowded conditions.
15 Q
What have you done of a professional nature, by 16 which I mean teaching, papers or original research or 17 addresses since you last testified in this case in 1984, 18 starting chronologically in
'84.
19 A
That information with regard to publications is on 20 my vitae, so I think it is.available to you.
21 Q
We haven't received an updated copy of your vitae, l
l 22 so if you don't mind going into what you have done --
1
('N l
\\_
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MR. MC MURRAY:
Let me state I believe we did send 2
one late last week.
If you have not received it, I think I 3
can try to dig out a more recent copy of it.
4 MR. CHRISTMAN:
I have not received it.
It may 5
have gone to someone else at the firm.
6 MR. MC MURRAY:
Why don't we take a break and I 7
will dig it out and see.if, in fact, we sent it, and then you 8
can look at it.to -see if you have any questions on it.
9 MR. CHRISTMAN:
Let's take a break then.
10 (Recess.)
11 BY MR. CHRISTMAN:
{}
12 Q
Let me show you a document called curriculum vitae 13 dated February 1987, and I will ask first that it be marked 14 as Saegert Exhibit 1.
15 (Saegert Exhibit 1 identified.)
16 BY MR. CHRISTMAN:
17 Q
Let me show you this document and ask you if that 18 is your current resume?
19 A
Yes, it is.
20 Q
I will ask the reporter to bind this into the back 21 end of the transcript.
22 Is there anything of a professional nature that (O
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1 you have done since '84 that's not reflected on this current 2
curriculum vitae?
3 A
No publications or anything like that.
4 Q
Or major addresses?
5 A
No.
6 Q
It would not show, of course, ongoing research, I 7
suppose.
Do you have any research ongoing of your own?
8 A
I'm trying to finish a book right now on housing.
9 Q
I notice that most or many of your recent 10 publications involve housing or feminist issues.
Do those 11 offer any insights that would be useful in judging reception
{}
12 centers in the Shoreham plant?
13 A
I don't think so.
14 Q
How about the housing; is there anything about 15 crowding?
4 16 A.
I did some early work on crowding in residential 17 environments.
I would tend to draw more on my work in 18 crowding in public spaces, though.
19 Q
I seem to recall a few years ago you testified you 20 were doing some analysis of the Yankelovich, Skelly & White 21 survey that was done in this proceeding.
Do you recall 22 saying that?
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1 A
Right.
2 Q
What was that in connection with?
3 A
Well, Jim Johnson and I did run a reanalysis of 4
that, but we didn't publish it; both of us were too busy and 5
too far apart to finish doing the paper.
6 Q
What was the purpose of the paper?
7 A
We wanted to look at the impact of trust in LILCO 8
on compliance with evacuation requests in the Yankelovich 9
study.
10 Q
What did you conclude?
11 A
We found that the people -- it was a study that
{}
12 Yankelovich did when they introduced a second message; would 13 you change your behavior.if LILCo added this information --
14 and we found that the people who were -- the major changes 15 were simply that people in the evacuation area who trusted 16 LILCO, not a very large number, said that they would not 17 evacuate if they heard that even if ordered to do so.
That 18 was one of the main findings, and that other people would not 19 change in the direction of complying with LILCO.
20 Q
In preparing your testimony on reception centers, 21 do you expect that you will do any research of your own as 22 opposed to reviewing literature?
i I'i G
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A I doubt that time would permit that.
2 Q
If you had more time, what might you do?
3 A
I'm not sure, but I might do something.
i 4
Q When were you asked to be a witness on reception 5
centers?
6 A
About a month ago.
7 Q
And have you attended any meetings at which the 8
reception centers were discussed?
9 A
Well, we met in November with -- I met with 10 Mr. McMurray and Ms. Letsche, and Steve Cole and Beth 11 Loftus.
We discussed very briefly that this issue would come
(
12 up, and a suggestion was made that it be included in the 13 survey.
14 Q
Was that in Washington, D.C.
or in New York?
15 A
It was,in New York at Laguardia.
l 16 Q
You had a meeting in Washington, D.C.
too, didn't 17 you?
18 A
I did not attend that meeting.
19 Q
So that's the only meeting you have been at?
20 A
Right.
21 Q
Have you discussed the adequacy of reception 22 centers with other technical experts like Dr. Cole, ACE FEDERAL REPORTERS, INC.
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1 Dr. Johnson or others?
2 A
No, I have not.
3 Q
I take it you have not started drafting your 4
testimony yet?
5 A
No, not for these proceedings.
6 Q
For reception centers?
7 A
Right.
8 Q
You are appearing in the exercise litigation also, 9
aren't you?
10 A
Yes, I am.
(~}
11 Q.
Have you committed your opinions on reception 12 centers to writing in any form?
13 A
There will be some -- I have sent some materials 14 in for these contentions that are being filed at the end of 15 the week.
However, those were based on the old plans, not on 16 the new ones.
17 (Discussion off the record.)
18
.BY MR. CHRISTMAN:
19 Q
Are you talking about testimony on contentions 20 that will be filed shortly?
21 A
Right.
22 Q
And the contentions you are talking about are in ACE FEDERAL REPORTERS, INC.
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the exercise litigation?
2 A
That's correct.
3 (Discussion off the record.)
4 THE WITNESS:
Not contentions, testimony that's 5
being filed on the contentions.
6 BY MR. CHRISTMAN:
7 Q
I take it reception centers are involved in that 8
testimony as well, or.not?
9
. A There's one point that I'm testifying on.
10 Q
All right, but as to the present proceeding, not 1
11
.about the exercise, but about the reception centers
{'}
12 themselves, you have not written anything?
13
, A No, I haven't.
14 MR. CHRISTMAN:
Let me give the reporter a 15 document, it is a FEMA guidance document on the subject of 16
" Guidance on NUREG-0654/ FEMA-REP-1 Evaluation Criterion J.12" 17 and ask that the court reporter label it Saegert Exhibit 2..
18 (Saegert Exhibit 2 identified. )
19 MR. CHRISTMAN:
I will ask that it be bound into 20 the transcript at the end of the proceeding.
21 BY MR. CHRISTMAN:
22 Q
Let me show you this, Dr. Saegert, and see if you ACE FEDERAL REPORTERS, INC.
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1 have ever seen this before.
2 A
No.
3 Q
Would you take as long as you need and read the 4
thing?
It is only two pages long.
5 A
Okay.
6 Q
Recognizing you haven't had a hole lot of time to 7
think about it, do you have any top-of-your-head opinions 8
about that document and whether you agree or disagree with 9
it?
10 A
20 percent seems like a very low estimate, and I 11 also think that basing the numbers on the use of emergency
(
12 shelters and other disasters is not a supportable procedure.
13 Q
Anything else that comes to mind?
14 A
I think the point that many people will go to 15 relocation centers whether or not they have been exposed to 16 radiation is well-taken, and would suggest that the numbers CoJL D 17 in this situation be very large.
18 Q
Would you mind handing that to the reporter so she 19 can put it into the transcript?
20 Do you have any opinions or concerns about the 21 process LILCO plans to follow for monitoring or 22 decontaminating people after they get to the reception 1
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center?
2 A
I think the idea that you will only be able to 3
monitor the driver is not implementable and that people will 4
be very concerned, particularly about their children, and 5
want them to be monitored, too, and that the effort to impose
)
6 such a guideline will create additional hostility and 7
aggressive behavior and stress for people who are attempting 8
to be monitored.
s 9
Q Suppose LILCO proposed to change that instead to 10 monitoring everyone in every car, all passengers as well as
{}
11 the driver?
12 A
Then what is the question?
13 Q
Do you have any concerns about that?
14 A
About monitoring everyone?
15 Q
Yes.
16 A
I have a concern about the whole situation.
I 17 think LILCO is not set.up to handle the numbers of people 18 that it has to handle in order to be sure that everyone who 19 needs to be monitored in a timely fashion is monitored in a 20 timely fashion.
21 Q
In addition to the obstacles or barriers you 22 perceive may exist at the sites, do you mean LILCO doesn't
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I have enough people and equipment?
l 2
A Yes, I think that's probably one of the problems.
3 Q
Do you know how many people or how much equipment 4
they have dedicated to this purpose?
5 A
I can't recall exactly.
There were -- I have 1
6 reviewed, however, those numbers and I think there were about 7
three monitoring teams per site, something in that order.
8 Q
Are you aware that LILCO at one point designated 9
the Nassau Coliseum as a reception center?
10 A
Yes, I am.
{
11 Q
You were not asked to present evidence on that 12 proposal, though, were you, for anyone?
13 A
On a proposal?
No.
14 Q
You have never been asked to give an opinion on l
l 15 the previous proposal to use the Nassau Coliseum?
16 A
No, not on a proposal to use the coliseum.
17 Q
Are you aware that other suffolk County witnesses 18 did present written testimony, though not oral, on the Nassau 19 Coliseum?
20 A
No, I was not aware of that.
21 Q
Do you have any opinion about the transportation 22 or traffic problems that might be caused by the either O_
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'q 1
location or the distance of the reception centers from the 2
EPZ?
3 A
Yes, I think it is going.to be extremely difficult 4
if not impossible for people who were in the EPZ during the 5
release of radiation to make their way to these sites, due to 6
the high levels _of spontaneous evacuation in the area of the 7
monitoring locations.
That's one very major concern.
8 Q
Do you mean there will be so many people on the 9
roads they will cause congestion?
10 A
Right.
11 Q
And where do you -- the last phrase you used was
{}
12 in the vicinity or.in the." area.of the monitoring stations."
13 Where do you anticipate that the congestion might arise or 14 cause problems?
15 A
Well,.in the major roads adjacent to the 16 monitoring sites, I believe each of them is located on a 17 major highway, and the road networks in those areas I 18 understand are not nearly extensive enough to carry the 19 volume of traffic predicted.
20 Q
Where did you get that information?
21 A
Some from reading Dr. Cole's testimony on the 22 issue, and others from information that I have gathered in ACE FEDERAL REPORTERS, INC.
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1 previous proceedings.in the earlier hearings, in which I 2
testified on driver behavior and went with the Suffolk County 3
police around some of the roadways and looked at maps of Long 4
Island and had them explain to me with their traffic experts 5
what the problems were.
6 Q
Those roadways would have been closer to the EPZ, 7
though, than.40 miles away, wouldn't they have been?
8 A
We looked at maps of the entire island.
9 Q
Could you tell from those maps how congested the 10 roads might be in an emergency?
11 A
. I saw that there were very few roads leading in
{}
12 the directions that people wanted to go in and judging from j
13 the comments.of the traffic experts and the police, I was 14 persuaded that they would be inadequate for the situation.
15 Q
And do you think that the location of these 16 reception centers -- and let me ask you first, do you 17 understand what the location of the reception centers are?
18 A
I understand they are all 30 or 40 miles west of-19 the EPZ in Nassau County.
20 Q
Have you looked at them on a map or seen on a map 21 where they are?
i 22 A
No, I haven't.
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Q Do you think the locations might create problems s
2 in regard to the shadow phenomenon?
3 A
I think it will create _two kinds of problems.
One 4
is that by being located so~far from the EPZ, it may give 5
people the impression that all of the area up to the 6
monitoring sites has been exposed to radiation.
It is also 7
the case that this would be in a heavily congested area 8
because this would be a very large proportion of the 9
population of Long Island's evacuation routes.
10 Q
So you mean being west rather than east puts it in
{~ }
11 the path of lots of people?
m 12 A
Right.
13 Q
Hence there would be more congestion in those 14 areas?
15 A
Right.
There's something to be said for putting 16 it in a place that people are likely to be going, but i
17 nonetheless it will mean that they are in highly congested 18 areas.
19 Q
Do.you have any opinion or any information about 20 the need to have these reception centers get permits under 21 state laws or local laws?
22 A
I have no opinion on that.
l ACE FEDERAL REPORTERS, INC.
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Q You don't expect --
2 A
I'm not familiar with the issue.
3 Q
You don't expect to look at that issue before you 4
file testimony?
5 MR. MC MURRAY:
She is not being offered on that 6
issue.
7 BY MR. CHRISTMAN:
8 Q
How about the same answer for the effect of the 9
reception centers on the ground water or water supply of Long 10 Island?
11 A
Yes, those are not areas of my expertise.
12 Q
I guess if I would ask your opinion whether the 13 distance of the reception centers from the EPZ might cause a 14 problem because.of the distance from the exposure area, do l
15 you have any additional opinions on that that you have not j
16 already mentioned?
You have already mentioned the difficulty 17 of getting to them.
18 A
I haven't thought of any other reasons that come 19 to mind.
20 Q
You have already told me about the adequacy of 21 evacuation routes.
Do you have any additional opinions or 22 concerns about the adequacy of the evacuation routes other ACE FEDERAL REPORTERS, INC.
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than the ones you have told me already?
We just went through 2
some concerns about a minute ago.
3 A
There seems to be no convincing way in which these 4
evacuation routes can be adequate to the population that they 5
are expected to carry.
That's my major concern, and that 6
because of the geography of Long Island, this is not a simple 7
matter that can be resolved.
8 Q
Do you feel confident testifying about traffic 9
congestion when you are not a traffic engineer and you have 10 no background that I can see in it?
11 A
I doubt that very much of my testimony will be (v~)
12 directed toward that.
As someone who has been caught in 13 traffic leaving Jones Beach in the summer, I have an opinion 14 about it.
15 Q
You have mentioned you don't think there are if enough staff or equipment to handle the numbers that might be 17 coming.
Do you have any other concerns or questions or 18 opinions about staffing requirements of the reception 19 centers?
20 A
Based on LILCO's performance in the drill, I have 21 serious doubts that people will be well enough trained to 22 handle the enormous stress that will be put upon them in this
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kind of a situation, stresses arising from the large numbers 2
of people that they have to monitor, the wide range of 3
questions, the hostility and uncooperativeness of the public 4
and so on.
5 Q
And how did the drill show in your mind that they 6
won't be well enough trained?
7 A
Well, neither the personnel at the ENC nor the 8
personnel in charge of rumor control were able to 9
spontaneously and convincingly answer a wide number of 10 questions raised for them.
I would suspect the same problems 11 would exist for the personnel at the monitoring sites.
}
12 Q
There's a proposal that people evacuating from the 13 EPZ on buses, that is, people who need transportation to be 14 provided for them, will be taken.to the Hicksville reception 15 center of the three.
Do you have any opinions or concerns 16 about that proposal?
17 A
I have not looked into that yet.
18 Q
Do you have any concerns or opinions or questions l
19 about the uses of buses in the evacuation as it might bear on 20 going to reception centers?
21 A
The only concern I have about the use of buses 22 would be whether LILCO will in fact be able to produce the im\\)
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1 required number of buses and drivers in this situation, that 2
this is not a matter that I have been asked to testify.
3 (Discussion off the record.)
4 MR. CHRISTMAN:
Back on the record.
5 BY MR. CHRISTMAN:
6 Q
There's an issue about whether the proposal by 7
LILCO to send the evacuees to parking lots for the monitoring 8
and for decontamination in the trailers is acceptable.
Do 9
you have any opinion on that, concerns other than those you 10 have already voiced?
11 A
I need to further study exactly what the physical 12 layout of that situation would be, 13 Q
Do you know anything about the decontamination 14 trailers that have been ordered?
15 A
I have seen the diagrams of them.
16 Q
Do those diagrams raise any concerns in your mind?
17 A
I have not studied them carefully yet.
18 Q
How about preliminary concerns?
19 A
Well, the size, given the volume of people, is a 20 concern.
Other than that, the whole situation with the 21 waiting area and the trailers and trying to control people's 22 behavior when they are already told that they have been t
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contaminated and are waiting to be decontaminated seems 2
problematic to me.
3 Q
The work you mentioned for me earlier that was on i
4 behavior in crowded public places, that work was done roughly 5
when?
6 A
In the early to mid-70s.
7 Q
Are there other parts of your own professional 8
research that bears on the reception center issues in this 9
proceeding other than work done as a consultant to suffolk 10 County in this proceeding?
()
11 A
I haven't done any direct empirical studies of 12 this beyond the crowding work that I think is relevant.
13 Q
But I gather you will be reviewing a lot of the 14 literature between now and the time of your testimony?
15 A
I have done that; some of the addresses and papers 16 that I have written since 1984 have concerned human responses 17 to nuclear power and decisions involved in nuclear power.
18 Q
Can you list those for me or point them out on 19 your resume?
I 20 A
The one on environmental psychology and social l
21 change has a section on nuclear power, and then there's a f
22 small amount of discussion of issues related to environmental O
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hazards in my G.
Stanley Hall lecture which has also come out 2
in a book since then.
They are both on my vitae.
3 Q
What will you be doing between now and the time 4
you file your testimony that might be called further analyses 5
or research aimed at your testimony?
6 A
Well, I will be attempting to find out whether 7
there was any information about monitoring or health increase 8
beyond what I know about at TMI, be checking back with my 9
sources on Chernobyl.
I may look into more general 10 epidemiological research on people's use of testing and 11 monitoring facilities in emergencies.or in any kind of health
'{ }
12 crisis.
13 Q
What do you know about the research literature on 14 the use of either testing in the monitoring facilities or 15 other health care facilities that would bear on the issues i
16 we're talking about?
17 A
Not very much.
18 Q
It won't take long?
19 A
All I know is that in discussions with Tip Letsche 20 about what health experts that the county has retained have 21 to say about it, she reported that when there is a new test I
22 that comes out for a disease that the public is fearful of i
i i
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U 1
and that does not involve a social stigma, it is widely used.
2 Q
So you expect you will be looking into the 3
literature to see if you can nail down the facts on that?
4 A
Possibly, although that may be the domain of other 5
health experts or more directly relevant.
There may be other 6
lines of inquiry that I pursue that I have not yet figured 7
out.
8 MR. CHRISTMAN:
I have no questions.
I want to 9
make a request at this time that the list of names 10 Dr. Saegert called of university centers be provided to us,
(~'S 11 plus any notes taken on those conversations, plus any written
\\_]
12 information that might have been sent to her by any of those 13 sources, plus the documents regarding Chernobyl that she 14 mentioned, being approximately three or four in number and 15 having been provided most likely by organizations in Europe 16 be provided, and that the unpublished analysis of the 17 Yankelovich, Skelly & White be provided us as well.
18 THE WITNESS:
I'm not sure I have that.
That was 19 sometime ago and when I cleaned out my desk about two years TH R & al 20 ago I'm pretty sure I through that away.
21 MR. CHRISTMAN:
If it still exists in 22 Dr. Saegert's, Dr. Johnson's or anybody else's custody and OG ACE FEDERAL REPORTERS, INC.
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1 control --
zu 2
MR. MC MURRAY:
Please put your request in writing 3
and we will respond in due course.
4 MR. CHRISTMAN:
As I say, I have no questions.
5 MR. MC MURRAY:
I have no questions.
6 MR. CHRISTMAN:
With that, this deposition is 7
adjourned.
Thank you very much for coming.
8 (Whereupon, at 2: 40 p.m., the deposition was 9
concluded.)
Subsenbed and sworn to before me 57 thisD ay c/ N /L
, 19 l
/"
11 L
AF Not[ Public 12 SUSAN SAEGERT My Commission Exp:res /
j 13 F
DONALD AREY
' ' Notary Public. state of New YorR g
po, 31 4515161 Quantled in New York County 15 commiwon M' "^" "'
16 f
17 18 19 20 21 22 O
I ACE-FEDERAL REPORTERS, INC.
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CERTIFICATE OF NOTARY PUBLIC & REPORTER 45 I, KATHIE S. WELLER the officer before whom the foregoing deposition was taken, do hereby certify
- that, the witness whose testimony appears in the foregoing deposition was duly sworn by me; that the testimony of said witness was taken in shorthand and thereafter reduced to typewriting by me or under l.
my direction; that said deposition is a true record of the testimony given by said witness; that I am neither counsel
- for, related to, nor employed by any of the parties to the action in which this deposition was taken;
- and, further, that I am not a relative or employee of any attorney or counsel O
employed by the parties
- hereto, nor financially I
or otherwise interested in the outcome of this action.
i d bilh a
Notary Public in and for the District of Columbia My Commission Expires NOVEMBER 14, 1989 e
f f
O a
1
,c5lg/ #f i
Attachment E i
,3fc3 to:30 Pa2 xw m a m 33' 525-3 m t
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@ Federal Emergency Manag Washlagtee D.C. 20472
~
M t tisst d
someWttet rats amt' Division ottets 3
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riot:
Etonen w. sr
'i assistant Assostate 01 rester staes aM tonal Progrees AM 4 pert SUWWts atidance on ICMEM454/FDtHa>1 paluation Criterian J.12 protestive nopense waluation eriteriet J.13e1his esserende A-ag>1 and sanitoring et eveeuses at relocatics osetsfl L areas. the personnel trd epiment wallable ehen14 he espeals of monitoring within about a 13-tour period all O
residents a i <>=
m transienta in the plms espesure EPS s.
2 tta aaly be cupseted to arrive at a relocation sentar(s).the pae seen,
gathersi en weeustian responses to a variety si natural and teameistica IItelocation sentere er sheltese.
tes is not sonoluetve.
tevealed that anywhere fras 3 to 20 percent of sne evaeuse,s arriv dRe Per radiol e at cenable to assues that additional wacuses,ogical seesgensiase it is rota have been eRpened to radiation. fear over radiation, will go to rolesa to alley their eenoema aM g to 2M range, ogical amorgenstes any be eleser to the p end of tne 3T n se for radtel e
the esse issue is reviewed as a part of all Atauis safety and 1.ieene seest hearirge, although it hem never been fonnelly litteeted at fueh a ing lanta to usually ethe sangregata eare fast 11ty capsoity in the vicinit nuclear power p.
the tetlasted taaeer of evsouses.itad as being betwen 5 AM 13 percent of With these percentages in a1M, it ta spearent that there is atentfisant diversity in the frees of reference eur.
Ithruling this taeus.
O sgec/T 2.
33 =WINCO ICPP
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1/C3 10:30 525-349;
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9 the guldense peerided beler is based on the tallertrg feeterus rieres wie erecuatians regard 1ees of the nature W tas (3 tralustan W fear AM urmettainty fasters aseestated with (1) g ames9erstes and (31 geesentage of fesulties attad in A813 hearirgo. potential weeuses for conpegate %
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ne mate ans toes restatosted amtveney preparedness alare of trained pereennel aMshould ineluse provistare at relacetion cent tien to be evaeussed.nt to senatee a minima pensent of the eettmated
- For highly trerobable radiolostaal releases involvitg high levels et raslation enourgaastrg a rotatively lange tres may be necessary to nonitor a greater raaber W evemaees, it beyond 30 pereent d the papalation.
State ard local gwerrtents wmid be empoete6 to develap a.
In such a situatten t.M ad hoe toepense anuusse supp rd j
by Fedessi and private sector ressu, roes.lemented, if noeces, I
W quaetiens or conesme about this guidance shsuid to direstad stetts at 648-2497 j
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