ML20207R873
| ML20207R873 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/04/1987 |
| From: | Malina C AGRICULTURE, DEPT. OF |
| To: | |
| References | |
| CON-#187-2807 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8703180236 | |
| Download: ML20207R873 (121) | |
Text
- - - -
ORIGIN $
2104 TI M NS X H 00?fiE0 o
OF :?ROCEEDIXp$16 A856 UNITED STATES OF AMERICA 0FFICE OF ECMIM y 00CKETitiG A. Mnvici, NUCLEAR REGULATORY COMMISSION BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- - - - - - - - - - - - - - - - - - -x In the Matter of:
Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY (EP Exercise)
(Shoreham Nuclear Power Station, s
(ASLBP No. 86-533-01-OL)
Unit 1)
- - - - - - - - - - - - - - - - - - -x DEPOSITION OF CHERYL L. MALINA 4
I i
I l
Washington, D.
C.
Wednesday, February 4, 1987 ace-FEDERAL REPORTERS, INC.
Stenotyp Rep'rtm 444 North C.yitol Street Washington, D.C. 20001 (202)347-3 00 Nationwide Coverage 800-336 6646
%3teO @k 738$
2 pgg T
1 C:)
UNITED STATES OF AMERICA i
Joe Walsa NUCLEAR REGULATORY COMMISSION R/T 2
CR 29683.0 ATOMIC SAFETY AND LICENSING BOARD 3
-X 4
In the Matter of
- Docket No. 50-32 2-OL-5 5
LONG ISLAND LIGilTING COMPANY
- (ASLBP No. 86 -5 3 3-01-OL) 6 (Shoreham Nuclear Power Station,
7 Unit 1.
8 11
._______________x DEPOSITION OF Cl!ERYL L. MALINA to Washing ton,
D.
C.
gi Wednesday, February 4, 1987 12 Deposition of Ci!ERYL L. MALINA, called for examination 13 at the Law Of fices of Kirkpatrick and 14 pursuant to notice, N. W.,
South Lobby, 9th Floor,1800 M Street,
- Lockhart, 15 Washington, D.
C., 20036-5891, at 9:15 a.m., before Garrett 16 a Notary Public in and for the Commonwealth 17 J. Walsh, Jr.,
of Virginia at Large, when were present on behalf of the is respective parties:
to SUSAN M. CASEY, ESQ, and MICilACL S. MILLER, ESQ.,
20 South Lobby, 9th Floor, 1800 M Kirkpatrick and Lockhart, 21 22 Street, N. W., Washington, D.
C., 20036-5891, on behalf of 9
1 1
Joe Walsa UNITED STATES OF AMERICA R/T NUCLEAR REGULATORY COMMISSION CR 29683.0 ATOMIC SAFETY AND LICENSING BOARD 3
4
- - - - - - - - - - - - - - - - -x In the Matter of 5
- Docket No. 5 0 -32 2 -OL-5 (EP Exercise)
LONG ISLAND LIGIITING COMPANY 6
8(ASLDP No. 86-533-01-OL) 7 (Shoreham Nuclear Power Station, :
Unit 1.
8
__________x 9
to DEPOSITION OF CllERYL L. MALINA 11 Washington, D.
C.
kJ We dnesday, February 4, 1987 12 13 Deposition of CIIERYL L. MALINA, called for examination 14 pursuant to notico, at the Law Of ficos of Kirkpatrick and 15 Lockhart, South Lobby, 9th Floor, 1800 M Street, N. W.,
io Washington, D.
C.,
20036-5891, at 9 :15 a.m., before Garrett 17 J. Walsh, Jr., a Notary Public in and for the Commonwealth is of Virginia at Largo, when woro present on behalf of the 19 respectivo particu:
20 SUSAN M. CASEY, ESQ, and MICllAEL S. MILLER, ESQ.,
21 Kirkpatrick and Lockhart, South Lobby, 9th Floor, 1800 M 22 S tree t, N. W.,
Washington, D.
C.,
20036-5891, on behalf of
,7 i
3
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2 I
the Intervener, Suffolk County.
2 WILLIAM R. CUMMING, ESQ, 500 C Street, S. W.,
3 Washington, D.
C.,
204 72, on behalf of the Federal 4
Emergency Management Agency.
SCOTT D. MATCllETT, ESQ., Ilunton & Williams, 5
707 East Main Street, Richmond, Virginia, 23212, on 6
7 behalf of the Applicant, Long Island Lighting Company.
8 9
10 11
/^S k_./
12 13 14 15 16 17 18 19 20 21 22 4
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2-A l
1 CONTENTS
~#
2 WITNESS DIRECT 3
Cheryl L. Malina 3
4 5
6 7
E X 11 I B I T S PAGE INTRODUCED 8
g Malina Exhibit No. 1 31 Malina Exhibit No. 2& 3 49 to Malina Exhibit No. 4 65 11 Malina Exhibit No. 5 70
't >
12 Malina Exhibit No. 6 86 13 14 Malina Exhibit No. 7 86 15 16 17 18 i
10 20 21 22 O
3
.fbJ P R-O C E E D I~N G S 3
'M
,.2 (9 :15 a.m. )
~
3
. Whereupon, 4
CHERYL.L. MALINA, 5
was called'as a witness, and having firstL been duly sworn, testifie'd as follows:
6 7
DIRECT. EXAMINATION 8
.BY MS. CASEY:
f g
MR.'CUMMING :
In the deposition'o[ Paul 10 Giardina the week.before last, Counsel for Interveners 11 requested comments provided by Mr. Giardina's office which 12 is Region' II of the United States Environmental Protection 13 Agency concerning provisions' 7 and-8 of the LILCO' Emergency 14 Responso Plan.
15 I am today furnishing copies of the document 16 furnished to me by Mr. Myers Sku1 neck, Office of Regional 17 Counsel, to all the parties.
18 It includes a package of a letter to me from 19 Mr. Skulneck of January 30, 1987.
A memorandum to Mr.
20 Skulneck from Mr. Giardina dated January 27, 1987.
A 21 letter, concurrence copy, dated November 24, 1986 from Mr.
22 Paul Giardina to Mr. Ilusar of the Federal Emergency Management i
l
S 4
- io l
'4 1
Agency, and'an earlier letter dated December 8,.1986, from
.2 Mr. Giardina to Mr. Husar.
In furnishing this, I had-3 discussions with counsel and witness, counsel for. EPA, 4
witness, and I instructed them that they should tell me in 5
writing whether they, wished to assert any privilege with o
respect to this document they were furnishing to me, 7
No such instruction has been received, and we 8
are, in 'f act,' turning it over to the Intervenors.
9 I should also state for the record that while
-10 I represented Mr. Giardina in the deposition' at the request 11 of the Envirornmental Protection Agency, Mr. Chris Hermann,
~
12 of the Headquarters General Counsel operation of EPA 13 instructed me that any request for assertion of privilege 14 had to initiate with the Region, with.the Regional Adminis-l l-l 15 trator or the Regional General Counsel's Office, or r
l 16 Regional Counsel's Office.
17 Since no such request has been received, I as f
18 stated earlier, have in ' fact furnished this to all parties.
19 MS. CASEY:
Thank you, Mr. Cumming.
20 BY MS. CASEY:
21 Q
My name is Susan Casey, and I am an attorney
(
22 with Kirkpatrick and Lockhart.
We are representing suffolk
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5 1
County in this ' proceeding.
2 With me is Mr. Miller, also of Kirkpatrick and Lockhard.
Basically, what I am going to be doing today is 3
4 asking you what you know about the February 13, 1986 exercise at the Shoreham Nuclear Plant.
5 If at' any time you don' t understand any of my 6
7 questions, please ask me to clarify and I will be glad to a
do so, and similarly, if I don't understand your answers, I 9
will probably ask you to clarify.
Do you have. any questions?
10 A
Not at this time.
11 f) 12 Q
All right.
Will you state your name and address for the record, please?
13 14 A
My home address?
Q Whatever you are comfortable with?
15 A
My name is Cheryl L. Malina, I live at 1813 16
$ntjnBbr//
Saidwcil Road, Silver Spring, Maryland.
17 18 Q
And who is your present employer?
19 A
I am with the Office of Emergency Planning, Unite d States Department of Agriculture here in Washington.
20 21 Q
Wnat is your job title?
22 A
I am an emergency programs specialist.
O v
6 1
Q Are you the only person with that title in 2
yout office?
3 A
No, I am not.
4 Q
How many others are there?
5 A
There are four other than myself.
6 Q
Could you give me a general description of your 7
duties and responsibilities as an emergency program a
specialist?
9 A
Well, in our office we have two programs; e ev nw to have the radiological emergency planning progran, and -we-
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kw the - nahpi;a.CyLLMy' P"/ you will, where 11 h huve 1
c; --
F515 we develop P ans and procedures for TTSnA personnel o //o t.o l
12 g
,,, /r&Ah1liNulty f};q)cTtn'nwent, y
13 t-
- - - -- o for the bh Asanemergencyprogrampspecialist 14 15 radiological side o# the office, we act a little bit 16 differently than some of the other regions, sone of the 17 other "ederal agencies that you have talked to.
18 We serve all ten WFA regions, and serve on the 10 PAC of all ten UE"A regions, from our Pashington head-20 quarters.
21 We review plans from all o# the state and the 22 local governments and all o" the nuclear power plants, f3 N,_/
7 1
Following those plan reviews, we also attend 2
and evaluate -- act as evaluators during the exercise.
3 O
So, personnel are split, and would serve with i
4 just one program, is that correct?
5 A
No, we all work in both programs at this time.
6 Q
Other than reviewing plans and attending the 7
exercises, are there any other responsibilities that go with a
this position?
M N
c "
9 A
Yes.
We also have developed <r USDA radiological
.7 7
W 10 emergency response plan, which is part of the Federal 11 Radiological Emergency Response Plan, and that plan outlines
(T ii all the policies and procedures that USDA and its agencies 12 13 would follow in assisting state and local governments 14 should a radiological incident occur.
15 We also, in that same vein, participate in the 16 exercises where we are players, where we test the Federal 17 plan, like the FFE-1, St. Lucie, and the upcoming FFE-2, 18 Zion nuclear power plant in Illinois.
19 We also participate with FEMA and other Federal ct S tb agencies.iw blatj,f k Sy+my, nuclear weapon accident exercises, 4 ncL 81d 20 a l$ a p a r t iee h a k Q S p h u p r S S g,y 21 dontinuity of government exercises.
A 22 Q
Are USDA efforts in radiological emergency (3
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P 8
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planning geared toward any particular aspect?
i A
Well, we focus on protection of the food supply.
2 Q
Would you tell me, Ms. Malina, what you did to 3
. prepare for this deposition?
4 A
To prepare for the deposition, I went to-my-5 file on the LILCO exercise, and in that file I had two 6
7 letters received'from Roger Kowieski,.the'WLC Chairman for 8
Region II, that requested my presense at the exercise.
I reviewed the contents of the file, which had g
an itinerary for the Shoreham Exercise.
A chart as to 10 what my assignment would be.
It has the Post Exercise 11
,7
()
Assessment that was published.
And I also had some xeroxes 12 out of the LILCO Plan that I had used in preparing myself 13 14 for my assignment for the original Shoreham Exercise.
I reviewed the Post Exercise Assessment and 15 16 from that I have developed a talk paper on what my assignment 17 was and what I recalled.
18 It was taken directly out of this exercise 19 assessment.
I do not have any notes, I do not have my evaluation sheet that I had at the exercine.
What appears 20 21 in this statement has been taken out of the exercise 22 assessment.
O
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1 Q
Did you add to the statement at all from your 2
own memory?
A No.
3 4
Q Did you review the entire report?
W ll, I looked through the report, but I reviewed A
e 5
particularly the section that I was asked to respond to in 6
7 the deposition.
8
. EOC-2, - EOC-3, EOC-ll, EOC-16, EOC-18, EOC-2 0, 9
and Field 1.
10 0
You mentioned you have with you some xeroxes out 11 of the plan.
A Yes.
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12 13 0
Could you tell me which parts of the plan you 14 have there?
A Would you just like to see them?
15 16 Q
If you could just read the number off.
g7 A
Why don' t I just hand them to you?
There are 18 some from the basic plan, and there are some implementing 19 procedures.
20 0
Let the record reflect that Ms. Malina has just handed me OPIP 2.1.1, page 8 through 11 of 79.
This defines 21 22 positions.
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10 ET^$.
' 'r She lias also handed me OPIC 3.6.1, page 31-A' of f
-1 2
44, which describes protective ~ actions-.forEspecial facilities.
3 She~ has also handed me Section 2.1-2 through
+
4 3-A, which again defines the positions of certain emergency 5
responders.
Attached ' to that is a chart of the LERO 6
7 organization.
Follo' wing. that, 'are.pages 2.2-2Al.and 2.2-4F 8
i
.9
' of the plan, which n describes.. letters of agreement with
~
10
-certain support agencies.
11 Attached tol that'are.pagesf 3.'6,-7, 3.7-1,.4.1-1
- f 3
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12 of the plan.
She has also handed me OPIP 3.6.5, which 13 describes implementing procedures for protective actions 14 for special population.
15 She has also : handed me certain attachments to 16
-OPIP 3.6.5,. specifically the messages which LERO responders
- 17 are supposed to read over the phone to the home-bound, and to 18 health care facilities.
19 She has also handed me another attachment to 20
~OPIP 3.6.5, which specifies predetermined vehicle require-21 ments for special population evacuation.
-22 Attached to this is a copy of the ambulance /
1 11 i
ambulette dispatch.
2 Were all these forms in your evaluator packet?
A No.
They are ones that I xeroxed myself when 3
4 I knew what my assignment was going to be.
5 Q
Did you have a copy of the entire LILCO Plan and 6
OPIPs available to you?
7 A
Yes, I do.
8 Q
And had you received that in the capacity of 9
being a member of the RAC?
10 A
That is correct.
11 Q
You said that you now have no notes or logs.
Did J
you have any at any time?
12 13 A
Just during the exercise.
I was taking notes on 14 my evaluation form and wrote my evaluation after the exercise 15 was over.
My summary statement on the evaluation form.
16 I turned that in at the end of the exercise.
17 Q
So, you had no other notes that day?
18 A
No, I avu'L.([ed ADI-Cyn 19 Q
Did you turn in the form that you had actually 20 taken notes on, or did you --
21 A
Yes.
I turned in to FEMA everything that I had 22 written on.
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12
- f 3 1
Q Okay.-
2 I know it -is a. little diffi' cult when you know 3
- what question I am asking,~ but it 'would help the reporter and 4
'make the record a little clearer-if you do wait for me to 5'
finish.
6 Okay?
7 A
Sure.
l 8
Q Thank you.' ' You said thatjyou are a member of the 9
RAC.
When did y'ou b'ecome -a 'meEber of the RAC?
~
A'ctually,[Mr. George Bi,ckerton,; Director of.the 10 A
11 Office of Emergency Planning, is the official RAC member in
[ ^
s.
~
-12 all ten FEMA regions ~.
13 I serve on Mr. Bickerton's staff, and was appointed i
14 the project person to review the LILCO Plan.
15 Q
And when did this appointment take place?
16 A
I don't recall exactly.- Whenever the~LILCO 17 plan was to be reviewed for the first time.
When plans 18 come into the office, one of the four project staff people 19 are assigned to review the plan.
I don ' t recall the date 20 when the plan was first submitted for review to the RAC.
21 Q
Does the fact that you were appointed project 22 person for Shoreham, mean that you were the only person who i
4
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was reviewing the LILOO plan?
g 2
1A That is correct.
3 Q
Did you discuss it at_ all with Mr. :Bickerton or 4
get>his input?
A Yes, I did.-
He signed all of the letters daat 5
have my review comments attached to them.
So, all of the 6
7.
letters going to Mr. Kowieski, orlIhor.Husar,jeho'was 6vw)
,oochd 0W 8
0CCivuca by our Director, Mr.. Bickerton.
9 Q
So, I : assume 'from what you. said that 'you were more or less. in charge of the Shoreham review in say 10 November and December ~of 1985', is that correct?
11
.f-N A
Yes.
12 13 Q
Do you recall receiving a copy of the objectives for the Shoreham exercise from.Mr.- Kowieski?. This would 34 probably have been in the beginning of December.
15 A
December of '85?
16 g7 Q
Right.
A I don ' t recall, 18 gg Q
Do you recall seeing the objectives for the Shoreham exercise at any time prior to the exercise?
20 A
Yes, I do remember seeing it.
I don' t recall 21 when.
-I can ' t say that it was December.
I did see the 22 Dt v
14 1
objectives prior to the exercise.
2 Q
Was it before you went down to Long Island for 3
the training session?
4 A
Yes.
5 Q
Did you comment on these objectives at all?
6 A
I believe I must have.
I would have to go back 7
through the records to see if there was an official letter, 8
or whether it was done by phone.
I don't know.
9 Q
How are such comments usually handled?
10 A
Usually the objectives are sent to the RAC prior 11 to an exercise.
They are asked to review them, and whether
(
)
12 they feel they are adequate or not, and it is usually 13 handled by phone.
Call them up and say: Yes, they are 14 adequate; or no, they are inadequate.
bc>llow af Comwen ts 15 And usually if they are inadequate, 4t would be 16 in writing.
17 Q
But you have no recollection at this time of 18 having written anything about the Shoreham objectives?
19 A
No, I did not feel that they were inadequate, 20 and I did not write any statements regarding the objectives.
21 Q
Did you see a copy of the Shoreham scenario prior 22 to the exercise?
/
/
i 15 i
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A I don' t believe I saw the scenario.
I.was not 1
2 involved in 'the development of the scenario.
3 0
In any other exercises, has-USDA become involved 4
in developing scenario?
5 A
No, we do not.
6 0
would -the Department usually review the scenario?
7 A
Not generally.
8 0
You mentioned before that you had two letters 9
from Roger Kowieski asking you to be an evaluator.
Can you
~
33 tell me when those 1etters were sent?
11 A
Yes.
I have copies of them.
The first one is
,f q k-)
a copy of one that was sent over telex, and it is dated 12 13 January 21, 1986, and the second one'is February the 3rd.
14 0
Was the January 24th letter the first time you 15 became aware that you would be an evaluator at - the exercise?
A Yes.
21st I believe.
The 21st.
16 17 0
So, prior to January 21st you had no idea that 18 you were going to be an evaluator?
19 A
As a member serving on the RAC, and I had served 20 on many plan evaluations, that is usually a step somewhere 21 in process, so one would not be shocked to learn that if 4
22
.an exercise cam? up, you would be part of the evaluation
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16
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.1 process ' if you ' are, indeed, serving on the RAC.
.2 Q
So, this was just an' of ficial notification of -what 3
you suspected would; happen, is that ' correct?
.4 MR. CUMMING.:
You may answer.
5 THE WITNESS:
Yes, ' this is an official notification 6
I hadnt heard rumors that I would be an evaluator.
I just
~
7 assumed,.as - the process proceeds 'along, eventually they.
8 do have an exercise, the RAC are evaluat' rs.
o 9
BY'MS. CASEY:
(Continuing) 10 Q
And what was your evaluatornassignment?
11 AL It was medical operations,at theyLERO EOC.
d I
12 Q
When did you learn that that would be your 13 assignment?
14 A
With the February 3rd letter.
15 Q
'Ib you know why you were chosen for this particular 16
' assignment?
17 A
Probably because, number one, the ingestion 18
' pathway was ' not going to be tested in this exercise, and UGr>R % Ctt'1A el t fgifl6 h e 19 that is whab-UCD?_ e'zaluato s Loku a icok-at.
We are usually
&no 20 at a State EOC looking at the decision-making process 21 involving ingestion pathway concerns.
22 However, since I have been in this program for f'%-
%)
17-
_,.3
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1
.almost six years, and have.been'all'overtthe country and had=many different assignments, I believe Roger felt that
^
2 3
I could handle being an evaluator of medical operations at
-4
.the EOC.
It ' was simply watching people perform what th'ey
-5
- had stated.in the plan that they could do -in ' carrying out 6
. their procedures.
7 And I have.done that for many years.
8 Q
Had you done it before specifically with reference 9
to medical operations at an EOC?
10 A
I have 'not done', specifically medical operations.
11 I have been involved in watching policy and-decision-making
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12 being done at an EOC, both at a State EOC:and a local EOC, 13 where social service activities and departments. that would-14' carry on this type of. activity, ' hich was going on at the -
w 15 LERO EOC.
I have seen that done.
16 Q
People who would be carrying on actual 17 evacuation of --
18 A
-- of home:, bound individuals. -The same type of 19 procedure that was being carried on at the LERO EOC, but 20 which had been carried on by State and Local personnel in 21 their capacity.
22 Q
You mentioned that usually USDA evaluates n
v 4
18 1
ingestion pathway.
2 A
And the decision-making process, and they also a cc onapa n' would go cut vit)a-any ingestion pathway sampling teams, 3
4 agricultural sampling teams that would be dispatched, as 5
well as watching the decision-making process at the EOC.
6 Q
Could you estimate how many times you have 7
evaluated ingestion pathway?
8 A
Well, I need to have the definition of whether 9
you are talking about a specific ingestion pathway exercise, 0 "^-
10 4er-separate and broken out; or are you just talking about 11 ingestion pathway activities which are a part of every
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12 exercise?
13 Q
Well, how about both, one at a time.
IIow many 14 times have you investigated. ingestion pathway when it was 15 part of an exercise?
16 A
I have evaluated approximately 4 3 exercises in the 17 las t five years, all of which have some food safety issues 18 concerned with it, either at a State or Local level.
19 I can't break out an exact number of how many 20 ingestion pathway separate type exercises.
I would say as 21 a guess seven maybe.
22 Ingestion pathway exercises are only required
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19 1
every six years.
2 Many. of the plants are now-j ust coming around-3 to 'the cycle where they have to do ingestion pathway 4
' exercises.
5 Q,
Is there some policy that th ngestion pathway
.6 can be exercised last?.
9 7
A
-I am not sure what you mean.
8 Q
You mentioned that some -plants are only now -
9 getting around to doing the ingestion pathway. exercises.
I 10 was just wondering if there i some-policy that permits that 11 to be tested last.
G.
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12 A
I don ' t know about last.
FEMA does have a 13 guidance that states when exercises have to be held.
I t'
~
14 has to be on a rotation-type basis.
15 FEMA is just, as I understand it, getting guidance, 16 out on the ingestion pathway.
It has not been officially 17 released, and I believe many state and local governments 18 have been waiting for this guidance to be released prior to
.19 having an official ingestion pathway exercise so they will know 20 what they will be evaluated on.
21 Q
Do you know if that was the situation with LILCo?
22 A
No, I don't.
O
t 20 7
I 1
Q Do you know, 'was there any -- were there any 2
ingestion pathway activities demonstrated at the Shoreham 3
exercise?
4 MR. CUMMING:
Asked and answered already.
To 5
the extent the witness has knowledge, she may answer.
6 TIIE WITNESS:
My assignment was only to evaluate 7
the medical operations of the LERO EOC.
If ingestion 8
pathway activities went on, or any decision-making regarding 9
food safety, I was not a part of it at that exercise.
10 BY MS. CASEY:
(Continuing) 11 Q
Do you recall at any of the post exercise
,e
(/
evaluator team meetings, time line'~ discussions -- there was 12 g3 a whole series of meetings held after the. exercise -- was 14 there any discussion at those meetings of ingestion pathway activities?
15 16 A
Not that I recall in the meeting that I 17 particularly was in.
l 18 Q
Did you attend only one meeting after the 19 exercise?
s 20 A
(Witness refers to papers. )
I attended the 21 meeting after the exercise to develop the emergency 22 classification and event time line, which was on February the
(~h V
1
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21 h
S.
- V 13th, from '6 : 30 to.7: 30 in the evening.
i 2
And then following that ~ meeting, I went to : a team Lmeeting, where we discussed highlights.
Each evaluator
.3 4
discussed' the highlights with-their team leader.
5' Those were the two meetings that I attended following the exercise.
6 7
0 Your. team was the EOC Team, is that correct?
8 A
Yes.
The LERO EOC Team.- Local EOC Team.
9 Q
And I assume there was somebody on that team who evaluated command and control and decision-making, is that io correct?-
11 12 There must have >been.
A Q
And. you don' t recall his. discussing any 13 14 activities dealing with ingestion pathway?
A I-don ' t recall 'that.
15 Q
Could you describe for me what you did on the day 16 of the exercise?-
17 18 A
On the day of the exercise?
19 Q
Yes.
Let the record reflect that the witness is once again referring to the Shoreham itinerary.
20 A
The exercise was scheduled from approximately 21 six a.m.
to five p.m.
And I recall that I arrived 22 O
22 1
approximately at 5 :40 a.m.
the LERO EOC.
85-2 And then I began my exercise evaluation watching 3
the medical operations begin.
4 Q
What do you consider, ' medical operations?'
A Well, I can tell you what medical operations is 5
that I would look at.
6 7
0 Could you tell me what medical operations you 8
saw, as opposed to what you were supposed to look at?
9 A
I have a statement of what I observed, and I would like to refer to that.
The exercise was a year ago.
10 11 Q
All right.
J A
(Witness reading document.)
Observations of 12 13 emergency medical operations was limited to LERO personnel 14 at the EOC.
The Hospital Coordinator and the Ambulance 15 Coordinator, and their interface with the Emergency Medical Public Services Coordinator.
16 17 Field observations of ambulances, ambule ttes 18 and special buses, their routes, drivers, KI procedures 19 and evacuation of the mobility impaired was the responsibility 20 of another evaluator.
B 21 The EOC-2 objective.
To demonstrate the ability 22 to mobilize staff and activate the Local Emergency Response Ov
23
)
' s' Organization, LERO EOC in a timely manner.
Emergency i
2 medical personnel at the LERO EOC were notified by pagers at about 6:29.
Responders called their automatic verifi-3 cation number and received instructions to report to the 4
LERO EOC.
The Staff activated in a timely fashion between 5
about 6:45 and 7: 30 and set up their command room.
6 7
Objective EOC-3 was to demonstrate through 8
ros te rs, the ability to maintain staffing in the LERO EOC on a 24-hour basis.
The Emergency Medical Public Services g
Communicator, Ambulance Coordinator, Health Services 10 Coordinator, and Hospital Coordinator presented rosters with 11
().
home and business telephone numbers showing sufficient staff
\\m 12 to support three shifts on.a 24-hour basis.
13 In anticipation of extended operations, the 34 Lead Communicator developed a roster of second shift personnel 15 which he presented to the Manager of Local Response, who 16 decided that a shift change would occur at 1600, after g7 replacements had arrived and been briefed.
A simulated is call-out of second shif t personnel was demonstrated by each 19 coordinator.
20 EOC-ll.
The objective was to demonstrate the 21 ability to communicate with all appropriate locations,
22
24 fO organizations, and ' field personnel.
g The Emergency Medical Public Services Coordinator, 2
the Ambulance' Coordinator, the Health Services Coordinator 3
and the Hospital Coordinator effectively demonstrated their 4
ability to contact affected hospitals and ambulance /ambulette 5
companies.
The available communication equipment is appro-6 priate for their emergency responsibilities, 7
EOC-16.
Demonstrate the organizational ability g
to manage an orderly evaluation of all or part of the ten 9
mile EPZ, including the water portion.
10 By 1023, telephone calls, simulated, were being 11
(_,)
made to homebound individuals.
These calls conveyed all 12 appropriate information and were made using the appropriate 33 message forms.
g The Home Coordinator maintains lists of g
individuals requiring curbside pick-up..Special buses were 16 assigned to pick up these individuals.
If the Home 37 Coordinator does not make telephene contact with a 18 particular individual, the bus driver, who has copies of the gg list, is told to check at the residence to see if the 20 individual is home.
The Special Facilities Evacuation 21 Coordinator directed this effort and was kept informed of 22 v
25
)
1 its progress.-
2 Listings of special facilities requiring ~ ambulance 3
services are maintained in OPIP 3.6.5, along.with lists of 4
ambulance companies under contract.
An evacuation of the 5
entire 10 mile EPZ would require that about eight hundred 6
eight individuals with speical needs to be picked up.
7 Fifty-seven ambulances and one hundred eighteen ambulette 8
vans with a total capacity to move five hundred and eighty-9 six people in approximately two hours are available under 10 the Plan.
The remaining people would be evacuated in a 11 second round of pickups requiring an additional one and a O
half hours.
12 13 According to exercise participants, additional 14 ambulances could be requested from volunteer fire companies 15 and volunteer ambulance companies in the area.
16 When the free play messages were injected at about 17 1030 requesting that an ambulance be sent to Our Lady of 18 Perpetual Help Convent, and that an ambulette be sent to the
-19 United Cerebral Palsy Residence, the messages were handled 20 expeditiously by the LERO EOC Staff.
Both messages had gone 21 from the Special Facilities Evacuation Coordinator to the 22 Health Facilities Coordinator, to the Ambulance Coordinator, in
26 I
I K'
i by 1055.
The ambulance had been dispatched by 1100, and g
2 the ambulette by 1114.
Field-1, the objective was to demonstrate the 3
ability to continuously monitor and control emergency 4
w rker exposure including proper use of personal 5
0 Y'
6 Field activities dispatched from the LERO EOC 7
were evacuation of special facilities by ambulance and 8
ambule tte, and school evacuation.
These activities were 9
m nitored by another evaluator.
10 With respect to the ambulance and ambulette g3 p
C/
demons trations, the objective to demonstrate the ability 12 to continuously monitor and control emergency worker exposure 13 including the proper use of ~ dosimetry was met.
14 Ambulance and ambulette personnel were issued 15 packets contaMng dosimeM eMpment consisdng of zero 16 to two hundred millerem and zero to 'five rem direct reading 17 dosimeters., a TLD, dose record forms, and simulated 18 potassium iodide tablets.
19 That is what was observed during the exercise 20 as far as diedical operations.
That is what I saw.
21 Q
You know, as you were reading that, it sounded to 22 Ab
27 l
)
k' me as if it were taken exactly out of' the FEMA report i
discussion on these particular --
2 A
Right.
3 Q
You said that the ambulances in terms of the 4
drivers and emergency worker radiation control, was evaluated 5
by somebody else?
6 A
That is correct.
I evaluated only what went on 7
at the LERO EOC upstairs, Another evaluator was responsible 8
for going out on the routes with the drivers, watching any 9
decontamination efforts and so on.
How they used their 10 dosimetry.
I merely saw what was in the packet prior to 11
(__)
being distributed to drivers.
12 0
When did you see these packets?
Did you go 13 downstairs to see'those?
14 A
No.
They were in a box upstairs where I was.
15 And when the person showed them to me, I. looked in the packet 16 to see what was there.
He took them downstairs.
He was g7 followed by another FEMA evaluator, who took the process 18 from dbat point.
19 0
Who was the evaluator who actually observed the 20 briefing and the dispatch of the ambulance and ambulette 21 drive rs?
22
\\
o 28 g
1 MR. CUMMING:
To the extent that the witness has 2
memory or knowledge, she may answer.
3 THE WITNESS:
I am not sure.
I think it was 4
Mr. Hulet' from Argonne.-
5 BY MS. CASEY:
(Continuing) 6 Q
All right.
7
-A The post exercise assessment report shows an 8
evaluator D.
Ilule t, from Argonne, who had other field 9
activities, evacuation of mobility impaired ambulette, and to also Paul Lutz, from DOT, who had other field actitisies, 11 evacuation of mobility impaired, ambulan ce.
,\\/
12 Q-So Mr. Lutz and Mr. Hulet were the only evaluators 13 who had actual. contact with ambulance drivers?
14 A
I don',t know that.
I was not involved in that 15 activity.
Those two names appear in the report.
I don't 16 know.
17 0
Well, did you, yourself, have any actual contact la with ambulance or ambulette drivers?
19 A
None.
20 Q
So, I take it from what you said you never left 21 the EOC during the time of the exercise?
22 A
That is correct.
.p
n' 1
29 1
1 Q
Did you' ever go downstairs?
-2
-A-I did not.
i
~3 Q
Now, downstairs, is. that where the emergency -
l 4
worker > decontamination facility was?
5 A
I don ' t kn ow that.
6
.Q And one of the other things you read from -the 7
report is -- anc this is just' from my notes -- but you said 8
that the lead communicator developed a roster which was 9
presented to the. manager of Local Response, and at some.
10 point there was a simulated call out of the second shift.
11 Did you actually observe that?
f~T-kJ 12 A
What -I saw was the emergency medical public 13 service communicator, the ambulance coordinator, the 14 health services' coordinator,,and the hospital coordinator,
~
15 present rosters with home and business telephone numbers-16 showing sufficient staffs to support three' staffs on a 17 twenty-four hour basis, i
18 I saw them, yes, 'I did take a look at them.
They 19 presented them to this lead communicator.
Gave them to him.
20 That is what I recall.
21 O
other than what you just read from your statement, 22 do you have any independent recollection of events during the i
)
1
o.
30
'I
)
t exercise of things that you observed?
2 MR. CUMMING:
Objection.
Asked and answered.
But 3
the witness may answer to the extent she can answer more 4
fully.
5 THE WITNESS:
No.
I tried to put in my statement 6
everything that I re call.
When I wrote my evaluation form, 7
looked into the post exercise assessment, I have written down 8
everything that I saw.
9 BY MS. CASEY:
(Continuing) 10 0
So, when you were filling out these critique 11 forms on the day of the exercise, basically you wrote down 12 everything that you observed?
'/
13 A
Right.
14 MS. CASEY:
Let us take abaut a five minute break.
15 (Recess.)
16 17 BY MS. CASEY:
(Continuing) 18 Q
All right?
19 A
Yes.
MS. CASEY:
I would like to have marked as 20 Malina Exhibit 1 an eight page document, which contains 21 what we believe to be Ms. Malina's exercise evaluation 22
31
/ \\
U critique form for the Shoreham exercise.
g xx Index (The above referenced document is 2
marked Malina Exhibit No. 1, 3
for identification.)
4 BY MS, CASEY:
(Continuing) 5 you mind just tadng a minute and loodng 6
that over?
7 (Witness peruses document.)
8 MR. CUMMING:
At this time, pursuant to the g
Boards Order of January 9, these exercise evaluation critique 10 forms were released.
If there was more than one version of 11 c
the form, including a version of the form that had strike-12 overs or modifications, both versions of the form were 33 produced to all parties.
14 THE WITNESS:
Okay.
15 BY E. C E Y:
(Condnuing) 16 Q
Are these, in fact, your forms?
37 A
They certainly look like it, yes.
18 Q
And that is your handwriting?
19 A
Yes, it is.
20 Q
If y u look at the first page, which is your 21 evaluation of EOC 2, I have just a couple of questions 22
r V
~
32 (m.
,^,).
1
'aboutlthis one.
2 Did you actually see the-notification by pagers?.
3 A.
No.
4 Q~
So,. what is the basis of your comments?
5 A
When the medical personnel arrived at' the.EOC, 6
I asked them how they were notified, and they explained-the 7
sys tem to me.
8 0
. And, again, when you refer to, ' eme rge'n cy
~
9 medical personnel,' -- I am'sorry if I have already asked to this ---' but could you just; list the positions' dhat you.were 11 actually~ observing?
,r k/
.A The Emergency Medical Public Services Coordinator, 12 13 the Ambulance Coordinator, the Health Services Coordinator, 14 and the Hospital Coordinator.
15 Q.
And were all these. people ~ located in one 16 particular section.of the EOC?-
17 A
Yes.
.They each were assigned > a desk.
la Q
If you will look at'the next page, which is your 19 evaluation of EOC 3.
I believe you. already told me that 20 the rosters you actually checked were the ones for the 21.
positions which you just mentioned in your prior answer?
22 A
Yes.
Right.
O
r 33
(
I Q
Now, when you were shown these rosters with the 2
two alternates, ldid you call any of the numbers to verify?
3 A
No, I did not.
4 0
In the upper left of the critique form, there 5
is a little handwritten notation.
Look for lists with home 6
phones.
i 7
Did you write that?
8 A
Yes.
9 0
Was that an instruction you had received?
10 A
Well, I generally do that when I evaluate.
I 11 have evaluated this objective many times, in many different 12 situations.
We always look for that.
13 Sometimes I write notes on my evaluation forms 14 to make sure,
is Q
okay.
If you will look at the next page, which 16 is EOC 11.
You stated in the comments there that, quote:
17 The Emergency Medical Public Service Communicator, the 18 Ambulance Coordinator, the Health Services Coordinator, and 19 the Hospital Coordinator ef fectively demonstrated their 20 ability to contact affected hospitals and ambulance /ambulette 21 companies.
22 Could you tell me what you observed that warranted b,)
s_
34 1
the basis for that comment?
2 A
I sat in a chair from time to time next to each Eclc>R sm o
}htin du[I{S d#
3 of the desks as they were
,o standing next to A
4 them, and whenever the scenario suggested anything that would 5
affect these people, they immediately contacted the hospitals 6
that they were instructed to, or the ambulance companies, and 7
I overhead conversations.
8 Q
Well, just focusing on the phone calls to 9
hospitals, were these people in actual communication with to personnel at hospitals?
11 A
I believe they were, yes.
They were asking how l
12 many beds were available.
How many patients they would be 13 able to accept.
14 Q
Let me ask you a hypothetical question.
Assume 15 that the people who were making these phone calls to 16 hospitals were not actually talking to people at the hospitals 17 Would that affect your evaluation of this objective?
18 MR. CUMMING:
Objection.
Calls on the witness 19 to speculate.
To the extent she has an opinion, she may 20 so state.
21 THE WITNESS:
I don't have an opinion on that.
22 BY MS. CASEY:
(Continuing)
/^T V
.+
9 4
^
ci.
m f
e 35 p;
,s i
, bot to your knowledge,. they were actsally talking; l;
1
'O-i
- 2 to hospital ~ personnel?
-3
' ' A.-
That;is correct.
4 Q
Do you recall which hospitals. they communicated -
5 with?
~
6 A'
I do no't..
7 Q'
Do you know if these were hospitals.inside the 8'
ten mile EPZ?
.9
.A I don't recall.
10
-Q' fDo you know,whether any-hospitals outside the 1
' 1 1' ten mile ' EPZ. were called?
l i
~
A I-don't recall that.
I did not write them down.
12 13
.Q When the hospital coordinator-would call these -
L 14 hospitals, tell me if you can remember what he or she would l
15 say?
16 MR. CUMMING:
Objection as to form of the 17 ques tion.
To the extent the witness has memory,of specific 18 conversations, she may so testify.
I 19 MS. CASEY:
I'will try to' rephrase it.
20
'BY MS, CASEY:
-(Continuing) 21 Q
If you can recall, what did the Hospital L
22 Coordinator say to the hospitals?
LO l_
r 36 i
1 A
I don't recall the entire conversation.
It has 2
been a long time, but I do recall them having a need to 3
find hospitals that might be able to accept patients and 4
calling several hospitals to see how many beds were available 5
on that particular day, should their service be required.
2-A 6
Q On the day of the exercise, did you check to see 7
whether these reception hospitals were listed in the LERO 8
Plan?
9 A
I believe I did check there.
They had the LERO 10 Plan available at the EOC, and they did have procedures --
11 staff had procedures, and I did check those procedures.
(
)
12 Q
What was the communications equipment which was 13 being used?
14 A
Telephones.
15 Q
Was the communication both with hospitals and 16 with the ambulance and ambulettes by telephone?
17 A
Yes.
18 Q
Was the Ambulance Coordinator able to communicate 19 with the ambulances?
20 A
I don' t recall that.
That would have been the 21 other evaluator, who would be tracking the conversations 22 between any Ambulance Coordinator and the ambulance itself.
s
g-
=
n.
e J.
- t
'p' 7
37
,g V' :'.)'
I ' was. only watching 'the coordination of 'the -
1
~
2
.am ulance company, not with the individual driver...They o
3.
ywould; only' beItalking,by telephone with a company, not' with' u
y q
I the vehible itself.
.x.s y
, -f 5
10 ~ ep But if the Ambulance Coordinator;had communicated o
-s v
s,"
,a T
4.,
- 3. Y 6-with an ambulance, wouldn'.t'you have.seen.her sideLof the a
. I' 7
conversation?
~
> 8 A-Well, you have to. remember that I have several 1
.i 9 people to track.
I was not at each'! person's side every.
1
- 10 se cond of. the ' day : during the, exercise. : If. they did 'do -that, 11 I may.not'have seen it.
12 I do not at-this'. time recall seeing'that.
I only.
b4 b
13 rec 11 overhearing donversations Acr' telephone tsi-e) companies, A
'not ;to' an indivi' dual. driver.-.Although that does.;not mean that U
.14 t
s 15 that did not happen.
.I did not see it.
J k
16
',Q How many ambulance companies did the. Ambulance 17 Coordinator call?
18 A
I. don't rdcAll that".
t
-19 Q
Did she h' Eve a list of all the ambulance companies-
[in front of her?
20 2
A They were going by the procedures they had in the 22 LILCO Plan.
They followed those procedures.
0 i
[
.O i
a
\\,c 1
a f
- 6 '
.a
.-,c e
L r 4 38
. A; 1 -:
Q.
Going back to the phone conversations you overheard
~
2 to the hospital personnel, I believe you said you assumed 3
.that these were actual. phone calls to actual hospital 4
personnel, -is that correct?
A Yes.
I have to believe wh'at the people ' tell me r
.5 in any exercise.
6 Did the people at the EOC tell you that they were 7
Q
~
8 calling these hospitals?
00hln'e6 They had a procedure pierr fo%
"7 rghe d%
9 A
They did.
jncludiwg hospitals,gthe telephone numbers, an4They picked up a phone A
10 11 and they called, and.I assumed if they told me they were
.,9
k 12 calling a certain hospital and talking to that person, and 13 I sat next to them and listened to the conversation, that 14 they were indeed talking to whom they said they were.
Well, did anybody specifically state to you:
I am 15 Q
16 calling --
17 A
-- one of the hospitals, or whatever?
18 Q
Yes.
19 A
Yes.
20 0
Tell me what you recall about that.
Can you 21 tell me what hospital it was?
22 A
I cannot recall.
They have a list of hospitals.
O
V
- s 39
(
)
1
.IJcannoti recall which hospital.
I.did not 2
. write that down.
3 Q
Could.these calls have'been simulated calls to
.'4 other 'LERO personnel or players?
t Objection.. Asked and answered.' To 5
L MR.-CUMMING:
6
- the extent the witness has knowledge, she may answer.
7 TIIE WITNESS:
Will' you say that again?
8 BY.MS. CASEY:
(Continuing) 8 0
'Could these phone calls have.been simulated calls, 10 and I am using, ' simulated' in the' sense that rather than -
11 being to a real, hospital, they were made to other LERO i
. 12 players or personnel?
13 MR. MATCIIETT:
I object to that.
It1 calls for Id.
speculation.
15 MS. CASEY:
I am merely asking if based on what 16 you h'eard from your side of the calls, if there is a 17 possibility the calls could, in fact, not have been made to i
18 hospitals?
I MR. CUMMING:
Continuing objection.
The witness r
l 20 may answer to the extent she has knowledge.
21 TIIE WITNESS:
It is my feeling the calls were made 22 to hospital personnel.
O I
I
~
i --
40 7,
.i
)
~ %/ -
BY MS'.'CASEY:
(Continuing) 1 2'
Q.-
Did you'or.anyone.else from FEMA,':or the.other' Federal agencies involved, do anything toiverify the calls 3
were actually made to hospitals?
4
-L 5 A
I.can only speak 1for myself.-
I can' t speak for FEMA or, other Federal agencies.
Whether FEMA had someone 6
7
. verify, I don't know..
8 I personally did not.
l 9
0 Okay.
If you will-look at your-form for EOC 16.
This is going to bring back a lot of memories.
10 MR. CUMMING:
It shows the deliberative process 11-
/~y i
I at work.
s/
12 i
13 BY-MS.'CASEY:
(Continuing) 1-14 Q
First of all, Ms. Malinai is there anything on 15 this' page which you did not write?
i.
I 16 A
No.
These are my notes.
l 17 Q
Including what is written in the lower left hand l
18 corner?
19 A
I can barely read what it says.
Additional 20 resources from volunteer. fire department and volunteer i
21 ambulance services.
i 22 Yes, I wrote that.
i 4
w 41 s
1
-MR. CUMMING:
Counsel doesn' t wish to.. testify,-
~
2' but I believe it reads, ' Add,' rather than, ' Additional. '~
3 THE WITNESS:
Yes, but that is my abbreviation 4
4.
for it.
5 101. CUMMING:
Thank you for your explanation..
'6' RBY MS. CASEY:
(Continuing) 7' Q
Now --
8 J'.".
CU:"I'ING s The !"alin a aqu valeu L vf the 9
RcsetL& C t c r.c.-
10 BY MS. CASEY:-
(Continuing) 11 Q'
Directing your attention to the second paragraph, O
'\\ 2 12 in' the comment section.
You state there that an evacuation 1
13 of ten miles, three hundred and sixty degrees, would consist 14 of approximately eight hundred and eight people.
15 A
Yes.
I see the line that you are talking about.
16 Q
Could you explain to me what you are referring 17 to there?
j 18 A
I am talking about eight hundred and eight people 19 with special needs; not eight hundred and eight people total.
20 Q
And how would you define people with special 21 needs?
l 22 A
people that would require ambulance, ambulette
-lO l
t
..42 l
l#?
\\
2"
- 1
. type service h 2
0 Where did you get the figure 808?
- A I.believe that is in~the Plan.
3 4
4 0
When-you wrote that figure.'down, did you. go toLthe Pldh and look it up?
5 4n 44teg'b YU W
A I had 4the Plan er a copy of *he Bing with.me,:
6:
g g
I 7
. ye s. -
A' copy of the page that we. are talking about, and I-l alsof talked with Jerry Connolly, my team leader on this 8
9 section.
10 Q
Was Mr. Connolly also evaluating this section? -
rnR.
A
. JQr Connolly was the team leader for the LERO EOC, 01%-
11
'f3
_hw Il responsible for C+ns
\\_/
so in the concept of team leader, thci are 12 k
.the teame LvoluabEn.
I 13 14 So, the team members can go and ask them for their 15 assistance or their guidance, in the understanding of certain i
16 aspects they might have a problem with or whatever.
They 17 are there to assist you.
18 Q
But, for instance, you didn't ask any of the LERO s
19 players?
20 A
Oh, yes.
I asked -- I talked to LERO players, oh, 21
- yes, j
t 22 O
And did you ask them?
n(_/
'4 'z
(.
43_
1 f.(
~ We Ediscussed this.. That is why.you see
'l A0
-Ye,s.
~
22 all these_ notes 1 all over the place.
These are my notes
( from.~ talking with the' LERO players. -They gaveime much of-3 q.
this information..
4
-Q Do: youl recall if"any of them told you there were-5 808 impaired people?
6 et
.7 A'
.Yes, I believe they did.
What exact' person,.I-8 don't know.-
9
. Q Now, you said earlier that' you reviewed OPIP 3.6.5, ~corre ct?
10 A
- I have a copy.of. portions of it.
I don't know 11
.if I have the whole thing.
12 13 The homebound evacuation message.
14 Q
Well, I am' just wondering where this 808 figure 15 came from?
16 A
I believe it came from the LERO people-that were 17
. working this problem.
They told me.
And I interviewed 18 them, and they gave me those figures.
19 Q
Did you or any other evaluator do anything to 20 independently veiify-these numbelrs?
21 A
I can' t speak for anyone other than myself.
I th cls cL '
22 don't know anyone else If Jerry Connolly took a look at my
$m,,
g g
r:-
Y 44 r~s
~~
1 evaluation form and verified it in some way. 'If he did, I 2
don't know about it.
I simply took this information from the 3
results of the exercise of what was going on, and what I saw.
4 0
In the lower lef t hand corner, you also noted that 5
there are 73 homebound persons.
Again, where did you get 6
this figure?
7 A
From the Home Coordinator.
He has a listing.
8 Q
Did you observe anybody calling the homebound 9
during the exercise?
10 A
I believe it was simulated.
They have a list of 11 the persons.
Their phone numbers, their addresses, and I
, -~s N ')
believe the calls were simulated, as I recall.
C 12 13 Q
And what did the simulation consist of?
14 A
As I recall, he would point to the name and say:
15 If required, I would call this person.
He would have their name, number and address.
He 16 17 did not pick up the phone and actually call that person.
18 Q
Did he do this for each name on the list?
19 A
I don't recall that.
I remember seeing the list.
20 MS. CASEY:
Off the record.
21 (Off the record discussion ensues.)
22 BY MS. CASEY:
(Continuing)
O) v
C t-45 1
Q Again, going back to your comment section? -
2 A
Yes.
3 0
You have written there, quote:
57 ambulances, and 4
118 ambulette vans, with a capacity to move 5 86 people in 5
approximately two hours, the remaining people would be evacuated in a second wave, requiring an additional one and 6
7 a half hours, end of quote.
8 Can you tell me the basis for those statements?
9 A
They came from one of the coordinators there.
ig The ambulance coordinator, probably.
11 Q
You know, there are sone calculations written
['b 12 across the bottom of the form, and again these appear to s-deal with the ambulances and the ambulette situation.
g3 14 Are those your calculations?
A Yes.
15 16 0
were these based on information given you by 17 the ambulance coordinator?
18 A
Yes, that is correct.
19 Q
Would your conclusion that the total evacuation time for the handicapped population is five and a half hours 20 21 depend upon assuming that each ambulance did, in fact, 22 carry two people, and that each ambulette or van did, in
(~w]
L-i i
1
47 A
1 A
This is the statement that I put together 4.heb-ts 2
.c.ama from the Post Exercise Assessment.
My evaluation as dPP/
g b.
e " hat I recall a I.rctc for thi-c.
dg.
3 4
Q I am sorry if I have already asked you, but 5
what was the specific purpose of your putting this document 6
toge the r?
% t_fEcAE e t%akuohe%c.t* N %
W'm &n 7
A Because I did not have bhie (pointing), and wh'n a
I received a subpoena that wanted information on the follow-9 ing objectives, the only way that I knew to do that was to go go to this book and recall -- I could pick out my own writing in the book, and to put it together in a few 11 12 pages so that I could talk to you today, because I did not www3 ht e o u_ %d utdm A e h uf% leevn.
(poin tin g. )
O d*
13 have a copy of this 34 0
It is fair to say because you didn't have a copy of the exercise evaluator critique forms, you went to 15 the FEMA Report and picked out the parts you can recognize, 16 and that h is --
17 18 A
That is right.
I contributed to the FEMA Report.,
hm e.,A. J w cre_&c A, cdud e A ex d qdt t. he'v-ww, Qn5bbb to What you see hew ( po ia4.4ng) 4s-t+re t ty "'neh whati-ycu ree "I-C M S t e 4 1.e hn' (PUintin;JrY -
O'#*
20 21 0
When you are re ferring to documents, just to make 22 it clear for the record.
s
e 46
' t'N,
i t
fact, carry four pcople?
2 A
I.can't recall'. These are numbers.I put down, and 3
7 attempted to work with, and it has 'been a long time.
4 0
. We ll, just looking at your calculation, 'it appears to me that you are indicating that during the first wave, 5
each vehicle would have to be filled 'to capacity, is that 6
^
7 correct?
8 A
IAt me put down what I wrote here, okay, because 9
I can read it better, and see if this comes out to be the 10 same.
Evacuation of the entire ten mile EPZ would 11 require that about 80 8 individuals with special needs be 12 13 picked up.
57 ambulances and 118 ambulette vans, with a 14 total capacity to move 586 people. in approximately two hours are available under.the plan.
The remaining people would 15 be evacuated in a second round of pick-ups, requiring an 16 17 additional one and a half hours.
According to exercise is participants, additional ambulances could be req msted from
-19 volunteer fire companies and volunteer ambulance companies in the area.
20 I have to stand by that.
21 22 Q
Could you state what you were reading from?
x
I k
48 n
C i
'l A
I am sorry.
What you see on the exercise
~'
2 evaluation critique form that I am responsible for, also 3
appears in the Post Exercise Assessment-Report.
4 Since I did not have copies of this at the office, 5
because I turned them all over to FEMA at the end of the 6
exercise, and I Was requested to comment on what I saw, I 7
went to the Post Exercise Assessment Report and developed a
some notes for myself to try to recall, because it has been 9
over a year.
10 0
Do you know where you got the time estimates for 11 the ambulance runs?
,a
(
i 12 A
I think from the Ambulance Coordinator.
A/
13 0
You didn't use the free play messages relating 14 to the ambulance and ambulette runs to get any of your 15 figures, is that correct?
16 A
I did not.
I was not out with the ambulance when 17 they made that run.
I did not time them.
That would have 18 been the other evaluator.
19 Q
But you handled the messages at the DOC, didn ' t 20 you?
21 A
I injected the free play message at the EOC, yes.
22 0
Did you see these messages after the exercise?
O
\\v/
m 49 t
A No, I injected them, and then I followed them 2
around to see who handed it to whom, and what they did with it.
3 4
I did not, as I recall, have them at the end of the exercise.
5 6
MS. CASEY:
I would like to have marked as 7
Malina Exhibit 2, a two page document which is the free.
8 play message dealing with the ambulette.
xx Index 9
( Above referenced document is to marked Malina Exhibit No. 2, for 11 iden tification. )
And I would like to mark as Malina Exhibit 3 12 13 another two page document which is also a free play message, 14 and this one deals with the ambulance, kotu ense nt xx Index 15
( Above referenced -ovument is Cnu 16 marked Malina E>tibit No.
3, for 17 iden tification. )
18 BY MS. CASEY:
(Continuing) 19 Q
Directing your attention to Malina Exhibit 3, the 20 first page there, this is the message dealing with the 21 ambulance.
22 Did you, in fact, fill out part of this page?
p
'wY
F 50
,Q D-1 A
~ I'did.
2-Q Okay. ' So, 'could you just tell me the part you cwrote?
3 A
Section 2.
I gave the message at.10: 30 to the 4
Special' Facilities ' Coordinator.
And then he did his. thing 5
with it, ' mud then it went - to 10 :40 to the Health Facilities 6
Coordinator.. And. then to 10:55 to the Ambulance Coordinator, 7
s and then someone else did the -11:00.
Dispatched.
I t ' mus t 8
g have gone on downstairs.
Q Now, is it your understanding that any request go for an ambulance would go through these four steps?
11 A
Yes.
I did not write the little notes on the 12 side.
13 14 0
Let the record reflect that the witness is referring to tiny notes. on the margin, which appear to say 15 i:
GJC, To Paul; Melino, misspelled; Field, Lutz.
16 A
Okay.
Very good.
17 MR. CUMMING:
On the far right hand side of the 18 i
19 form.-
BY MS. CASEY:
(Continuing) 20 21 0
So, now, if you will look at Malina Exhibit 2, and again, have you filled in.the process?
22 O
p.
'51
, -[f A
.Yes,. I have filled in the ' process under Item No. 2.
g 2
Q
.Okay.
Going back to Malina Exhibit No. 3, on the
.3 second page, 'if.. you will ~ notice, at. point ' 3a, it says:
4 Ambulance arrives. at EWDF/EOC,. and then somebody has filled 5
in the time there, 0950, 6
Now, I understand this is not your writing, :but 7
were you aware that ~ the ambulance would be at the EOC a
Prior to the time they 'were requested?
9 A
No, I wasn't involvad-in that aspect of'it.
10 Q
Did you see the parking lot at the EOC at all?
11 A
The parking lot?
There was a parking lot where 12 I parked my own car in.
And then I wont into the facility.
13 At 5: 30 in the morning there wasn't anything there but 34 regular-type vehicles.
15 Q
All right.
A And I didn't leave again until the exercise was 16 17 completod.
18 0
In your opinion, was thoro room in the lot for 19 118 ambulotto vans and 57 ambulances?
A It was a largo lot.
I am not qualified to mako 20 l
that kind of an ovaluation.
at 22 0
And you didn't make that kind of ovaluation?
O
52
~
l A
No.
2 Q
Do you know who actually dispatched the ambulances?
3 A
No, I don't.
That must have been -- well, the 4
Ambulance Coordinator was the person downstairs.
Who 5
actually was dispatching the ambulances, I don't know about a
th at.
I did not see ambulances dispatched.
7 Q
Were the drivers given their assignments by LERO 8
personnel?
bA 9
A I don't know that.
I have no interaction with A
b 10 the drivers, their instructions.
11 Q
Well, you said you saw maps and packets for the
'u- '
12 drivers.
Do you know who gave those packets to the drivers?
13 A
A gentleman took them downstairs.
I don't recall 14 which one of the coordinators did that.
They were in a an( -\\ob 15 large box /g Took them downstairs.
One of the other A
Ab c\\Mfdbht6, Fb h.. athh, 04 "
ovaluators tracked unb.
16 17 Q
Was it your understanding that af ter dropping a 18 patient off, the ambulance would return to the EOC7 to A
I did not participate in that part of it..
I don't know what their instructions were.
20 21 0
What I would like you to do, Ms. Malina, is to 22 take a look at the time shown on Malina Exhibit No. 2 and OU
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1 53' srm.
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1 Malina' Exhibit No. 3, and then tell me whether if. you had 2
this' information prior tof filling out your ' comment section 3
on EOC' 16, if your conclusion concerning the evacuation time.
1 4
for special populations. might have been different?
5 A
- (Pause. )
(Witness confers with her counsel)
That e
is calling for a conclusion that I can't draw.
7 0
Well, you state on your form, do.you not, that 8
586 people could be evacuated.in approximately two hours, 9
is that correct?
10 A
"h1L is wha L -- that i whoi -- yes, ong y
11 Q
Would it be fair to say that implicit in that J
12 statement is the assumption that an ambulance could be called, 13
' dispatched, pick up this passenger or' passengers, take them 14 to a reception - facility?
j 15 MR. CUMMING:
Objection as to form.
The question 16 as to what assumptions the witness made in writing that down, 17 she may so tes tify, if she remembers or recollects.
l 18 BY MS. CASEY:
(Continuing) 4 19 Q
Well, let's put it this way.
You state 586 people 20 could be evacuated in approximately two hours.
Would it be 1
21 fair to say that one person could be evacuated in approx-22 imately two hours?
(
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54 A.
1-
-A I don' t understand.
I don't follow you.
2 Q
Why.did you say 586 people could be evacuated.in approximately two hours?
3 A
In discussing the procedure with the medical' 4_
5' operations personnel for evacuation of homebound individuals,
- I this is the time frame that they-gave me.
.g 7
Q So, is it fair to say that you concluded 586
'8 people could be evacuated in approximately.two hours because 9
a LERO player told you that?
MR. MATCHETT:
I think this was already asked 10 and answered.
Ms. Malina said where she got the information 11 that was on this form.
It was quite a while ago.
12 l
MS. CASEY:
You can answer the question.
13 14 MR. CUMMING:
The witness can answer the question to the extent she has memory, or has an' opinion.
15 16
- THE WITNESS:
(Pause)
I still stand.by my evaluation form.
What went on at the LERO EOC that day.
17 BY MS. CASEY:
(Continuing) 18 19 Q
I appreciate that.
But what I am asking you is why you wrote that 586 people could be evacuated in 20 21 approximately two hours; from what you have told me already, 22 I understand that you wrote that because that is what a
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- 1' information was (given.to you by.'a :LERO player. -
2 I am asking youlis that the only basis for that 3
' s tatemen t?
4 A
And it-is'also.in the Plan, and they are follow-
'5 ing their Plan, which is what the exercise is supposed to
- 6 test.
7 Did they follow their Plan?
This is a: statement 8
that'was given to me.
That is where the statement came 9
. from, from the - players.
2-B 10 MR. CUMMING:
Off the record.
. 11 (Off 'the record discussion.)
]' ' '.
12 MR. CUMMING:
Back on-the record.
13 MS. CASEY:
Okay.
Going to the next page.
- 14
' MR. CUMMING:
This is Malina Exhibit No. l?
15 MS.'CASEY:
Yes, thank you.
16 BY MS. CASEY:
(Continuing) 17 Q
I believe this is a continuation of your 18 comments on EOC 16, is that correct?
l
- 19 A
Yes.
20 0
Okay.
On this page, you state -- I am sorry, 21 this may be a continuation from the prior page, but you r
~
22 appear to indicate that additional resources from volunteer i
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I fire; departments and volunteer ambulance services could 2.
be requested from volunteer fire companies '..and. volunteer :
3
' ambulance companies in the area.
4 A
Right;.
.5 Q
Again, could you just tell me the basis for that 6
statement?
7
.A That statement was given.to me by a LERO 8
. coordinator.
An' agreement that they had.
9 Q
They said they have an agreement with these 10 volunteer companies?
11
- A' I believe ' that is what they said.
They had O
additional ambulances that could-be requested from volunteer
. 12 13
' fire companies, and volunteer ambulance companies.
14 Q
Did they specifically mention that they had
. 15 agreements with these companies?
MR. CUMMING:
Objection.
Asked and answered.
16 17 If the witness has an opinion, she may answer.
18 THE WITNESS:
I don't recall they said the word, 19
' agreement.'
BY MS, CASEY:
(Continuing) 20 21 Q
Did they tell you how many fire companies and 22 ambulance companies there were in the area?
i-
1 a
l 70, a
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-I don't recall.that.
12 Q
Did you ask whether any of these volunteer fire 3
company personnel had been trained for a radiological 4
emergency?
5 A
I did not.-
6 Q
Your comments on that page continue thati quote:
7 Additionally, mobility impaired population that'have been a
evacuated to hospitals and special facilities would be i
9 monitored for contamination.
Monitoring teams would be 10 dispatched to these facilities, close quoto, it' What was the basis for these two sentences?
l 12 A
I don't recall.
I sco that I have them crossed 13
'out, and everybody can read through the crossed out lines.
14 0
Those are your cross outs?
i
(
15 A
Yes.
I don't recall the situation of why I 16 crossed them out.
I don' t recall why I crossed them out, t
i 17 Q
Do you recall why you wrote them initially?
18 A
No, I don't.
19 Q
Okay, the second paragraph on that page, you 20 state:
The llomo Coordinator maintains a listing of homebound 21 Individuals requiring curbsido pickup.
Special buses are 22 assigned to pick up these individuals.
O
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58 1
Now, you have already told me about the listing 2
of the homebound.
What were the special busos that woro 3
assigned to pick up thoso,poople?
4 A
You mean a description of them?
I don't follow.
5 0
You never saw them?
6 A
I never saw any vehicles.
I was insido the EOC
-\\he tv 7
all day.
I guess eef are buses that can accommodato A
8 whoolchairs.
Not the typical type bus.
9 0
So, you believe those woro what are commonly to referred to as knocling buson, is diat correct?
11 A
I don't recall that phraso, but as I remember they 12 told me it was not typical typo buses, but busos that could i3 accommodata homebound type people which I would assumo would 14 be whoolchair individuals.
15 0
Who told you about those special type busos?
10 A
The llomo Coordinator.
17 Q
Did she toll you how those people would got to the is curb?
19 A
I don' t recall that.
20 0
Do you know if there was a system in place so 21 that those homebound people would have buddles who would 22 assist them?
7
.c 59 1
A I believe there is a system in place, but I 2
can't repeat that to you.
I believe that'-- I don't know 3
if it is the bus driver that goes up -- they are registered, 4
they have a list of those people, phono numbers and addressos 5
-- if the bus drivnr assists them, I don't know.
6 Possibly the other ovaluator on the bus who 7
actu sily went to the places would have had that type of 8
in fo rmation.
9 Q
Going back for a moment to your comments about to thu availability of ambulancos from voluntoor companies, 11 did your -- any other Fodoral ovaluator do anything to O
\\)
12 verify that thoso ambulancos would, in fact, be availablo?
13 A
I did not.
I can't speak for other ovaluators.
J 14 0
You may have already answorod this, and if you 15 havo I apologizo.
Whoro you say that monitoring teams would to bo dispatchod to those facilition, again, did you do anything it to verify that?
18 A
I crossed that statomont out, and I can't spunk to to that.
Noxt timo I will have to uso a thick point pon.
20 MR. CUMMING:
It shows the chilling of fect.
21 Tile WITNESS:
You, the chilling offect.
22 MR. CUMMING:
The ruthlons discovery conducted by
l J
60 g-1 In te rvonors.
2 (Laugh te r. )
3 BY MS. CASEY:
(Continuing) 4 Q
From a review of the -- from your review of the 5
ambulanco and ambulotto proceduros prior to, or during, the o
exerciso, woro you aware that certain handicapped facilitics 7
had informod LILCO that they had their own transportation?
8 A
No.
0 0
Okay.
If you will look at EOC No.18, you havo 10 put in your comment section that this objective was not 11 played, is that correct?
tx/
12 A
That is correct.
13 Q
That is your handwriting?
14 A
No, it is not.
15 Q
So you didn't put, 'Not Played?'
16 A
1 didn't put, 'Not Played.'
I don't think I had 17 anything thora, is o
Did you writo the two comments on the loft hand to sido of the pago?
20 A
You, I did.
21 Q
Now you havo writton:
Schooln for tho handicappod.
l 22 A
Right.
O
61 m
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Q Am I correct in assuming that your assignment 1
2 was to analyzo this objectivo in terms of specifically I
if any schools for the handicapped --
3 4
A Yos.
If any schools for the handicapped were to b e involved.
5 Q
Okay.
Do you know if there are any schools for 6
7 the handicapped in the EPZ?
8 A
I don't.
g Q
Do you know if you had this information on the day of the exorciso?
to A
I don' t recall that.
11 (3
(_,!
Q Do you recall if thoro woro any phone calls 12 informing --
13 A
I was not involved in the school situation at 34 all.
is Q
Do you recall any phone calls alerting schools for 16 tho handicappod, and telling them to stay clonod?
37 A
I did not obnorvo that.
18 is Q
- Okay, If you look at the next page, this han to do with 1:0C 20.
Thin was an objectivo annigned to you?
20 21 A
It was not.
It wan in my packot, but -- I soo 22 my namo in on it, but I wan atrictly to do medical oporations.
~3-j' s
t e
62 1.
(~)
L^'
t Q
So, for 'instan'ce,if' there were schools for t
2 the handicapped in. the EPZ, you were not to evaluate whether l.
L 3
they could effect an early dismissal of those schools?
c 4
'A I. don' t recall that as part of this EOC. evaluation.
l s
was discussed.
l l
8 0
If you will look at the next, and you.will be l
7 glad to hear, final.
You said earlier that you didn' t l
8 ovaluate any of the a.nbulance and ambulette drivers.
l 9
A That is right.
I did not have any interaction to with any drivers of vehicles.
All the information came from l
11 the Ambulance Coordinator on the main floor of the EOC..
l
\\
12
-Q So, you were actually assigned this objective is though, is that right?
14 A
Yes, but from a perspective of coordinator at is tha upstairs level, but not any intorface with the drivors le and how they used the dosimetry.
17 I was not to loave the EOC, or go on any of the is routos.
to Q
So, is it fair to say that the comments you havo 20 recorded on hero all camo from your discussions with the 21 Ambulanco Coordinator?
22 A
True.
O I
,7,
?!
F 63 7s 1
1 0
'All right..-
2 A
Plus actually sooing the packet /thit held the a
dosimetry, and what was in;. the packet. --
4 Q
You mentioned these packets before.
Can you toll
~
5 me what was in them?
f f cf
~
6 A
We had doaimetry equipttent cobsisting ot':oro>to i
7 two hundred millorem, and zore to five.:'ren direct reading; 8
dcsimators, TLD, doso record forms, and'sinulated potassium
/
9 lodido tablots.
10 0
Did those packets have the routo~msps?
'~
~
11 A
I'do not recall.
(~)
i
'i 12 Q
So, you don't recall see.ing the actual maps.that 13 the drivers woro to uso?
14 A
No.
They may have boon in the pt6kot.
I was 15 looking at the dosinotry.
I don' t recall wnother there woro 16 or not.
17 0
Is it fair to say that what is writton on your 18 critique forms is based on what you woro told by LERO
]
19 players, or what is in t ho ?lan itself?
20 MR. MATelt! TT:
Asked and.answorod.
21 Tile WITNPR1:
!!ased upon the c:torciso, and what 22 I saw at thu exorcisu on tho oxorciso day.
What the nodical O
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personnel'~ at the.LERO -
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2
.LERG EOC did. ; How ~ they ' followed' thbir! proce'd'ures in -
(ty f' :')
.3 accordance with the Plan.
4
.Q But'what you saw was LERO players, is that 5
correct?.
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- f pa A
That is correct.
'd Y
0
. And the people you talked to were LERO players, L'
8 Lis:that' correct?
J 9
A That-is correct.
.to
'10
' And you did not independently verify the I
11
- information' which was presented to you other than, perhaps, D'd checking it in the Plan, is that-correct?-
12 13 A
That is correct.
I talked with my team leader.
14 We discussed the items that I have written here, but I did 15 not ca)1 outside people or consult with anyone, outside 16 experts of any kind.
17 0
You didn't talk to any ambulance drivers?
5
(
18 A
No.
I had no interaction at all with the ambulance 19 drivers themselves.
That was another evaluator.
2a O
And you didn' t talk to any hospitals, or any et hospital personnel?
22 A
No.
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- Q And you didn' t ' talk to any riursing home officials?
-2 x
A c No.-
There would;be people who. are 'out on the 3
routes as they went.to those places who may have, but. I.
~
4
- personally was at the. EOC. the who1e' time. - I did:not go to p.
5 another-f acility to talk with other people.
(s
- f a
Q And you didn' t check with'any - of the volunteer iY they;
.7 companies who would ~b'e available to see, if in f act, 6
8 Would be available? i 3
_s -
I' 9
A I did not call them, n'o.
\\
T 10 MS. CASEY:
I would like to have marked as, 11 Malinal Exhibit-No. ' 4', -a one page document entitled, Emergency.
Y-
}
t-12 Classification Tifneline.
y xx Index 13 (The' above referenced document is 14 marked Malin'a Exhibit No.
4, for
,t.
15 i' den ti'fication. )..
16 BY MS. CASEY:
(Continuing) 17 O
Did'you fill out thic form,.Ms..'Malina?
t.
18 A
I filled out a portion of it.
~
19
'Q Which portion did you fill out?
J 20' A
Under LERO EOC.
21 Q
Okay.
You filled out the times in the column
'22 marked, LERO EOC, is that correct?
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., Howe'verk,the, last entry, 8: 30 a.mJ, under
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-2 Release' Started-Notification, does:not look like my. hand-
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?
4
- s writing.-;
~-I'_can say de finitely I filled-out Alert. -
'4; 15 '.
Notification, 6 :28'!a.m. ;. Facility; Declare'd Operatio' al, -
n 8:10 ; a.m. ; Site - Area Emergency Notification,. 8:24 Ia.m'. ;.
6
.7 and ' General. Emergency, ' 9 :4 8 a1m.
8 0-When:did-you fill in these' times?
I 9'
A'-
Youihave' this form as the exe'rcise is-progressing,.
~
i 10
'and 'as each notification is received at.- the facility -that
[
11 you are.at, _you mark'down:the time.
' r
~
~12.
And the time.the-facility is - declared operational 713
- would be when' the head' of the facility declare's his facility 14
_ operational.
15=
Q So, to your knowledge did every; evaluator have
~.
'one:of these forms to. fill out?.
16 A
Well,.not every evaluator, because certainly 17 18
. people on routes outside of.the facility wouldn' t have them,
'.19
.but pecple at a facility would have them.
o l
20 Q
So, did each other member of the EOC team have 21 one of-these?
'22 A
I can' t say that definitely, because I didn't go r
T' EO I.
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67 i
i through each individual evaluator's packet.
2 O
How did you know that tne alert notification was 3
received?
4 A
Because I was at the LERO EOC and was listening 5
to the briefings that were being given, the status board 6
entries that were being put up.
I was aware through 7
briefings as to when various classification models changed.
8 Q
Let me see if I understand this.
So, for instance, 9
somebody at the EOC gave a briefing and stated the alert 10 notification was at 6:28?
11 A
That is right.
They had received notification
(
's 12 that the alert was at 6 :28.
23 Q
So there wasn't any particular action or message 14 that you observed, is that correct?
4k g
15 A
I did not monitor Like-a hot line % c unng, b_ cuAk w
where J heargthe actual message from the utility e.
I 16 g
17 was simply in the EOC and heard it when other people heard 18 it.
It was not my assignment to track the exact moment the 19 utility would have declared the classification.
20 Q
For instance, the next one, where it says the 21 facility declared operational, 8:10.
Am I correct that 22 that was written based on your own direct knowledge?
I
~.,/
68 8~'
-1 A
I believe, in trying to -recall, - that the hea'd 2
of the LERO EOC would stan'd 'up and say:
The facility is 3
now operational, and we are ltaking responsibility.
4 That is done in every exercise that I have ever 5
been at in any facility across the country.
When the EOC 6
Manager feels that his response personnel have arrived on the 7
scene, his facility is fully operational, he would stand 8
up and state this, and the time is written down.
9 Q
Is it fair to state that other than being the 10 notation, Facility Declared Operational, that the basis for 11 the notation in this column were either information you
\\_)-
obtained from briefings, or information obtained from the 12 13 status boards?
14 MR. CUMMING:
Objection.
Asked and answered. -
15 To the extent the witness has an opinion, she may answer.
h 16 THE WITNESS:
As I recall, these times were 17 written when the briefings were held, and when the manager 18 Said:
We are now at alert.
19 We were informed by the utility that we are now I
20 at alert.
3-A 21 BY MS. CASEY:
(Continuing) 22 Q
I am just trying to get this straight.
So, I am (3
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going to'ack-youJa hypothetical.
~
Suppose there were; a b iefing{ h' eld at 6 :40, an d.-
J 2-
~3 the : Manager 'said : an calert was ' declared.at - 6 : 2 8.
Wouldsyou -
,,f,n-
.t
,r r
r
~
'4 write. down 6 :2 8.~ or would lyou write down? 6 :40? =
5_
'A You usually write down' both. times:,. if: you are
{
6
! going to a hypothetical situation, _because. you would want
~
7 lto 'know how long it took-from when.the declaration was made -
8 to when the facility' received the declaration, if. it is
)
9 an ' hour ~ and a half, or. two' minutes.
10 0
But you'only wrote'down the one time.
i I' l-A That is right.
. 12 Q
~ Does that= mean that-the minute the Manager got
- 13 the notification, he held the briefing, is that.it?
!f 14 A
I am trying to recall.
It has been.a long_ time.'
..l:
t
-15 They did have status boards. - I don't recall that this was i-f ;.
16 a" problem area.
They were notified in a timely fashion. -
~
t L
17-Usually, the procedure is that as soon as they
[
^ 18 are notified,b they stand up and say:
We have'been notified 19 of the alert.
20 It is in a very timely fashion.
I don't think any l
?-
21 EOC Manager would wait an extended period of' time to allow i
22 his response personnel to know the classification change.
O
o=
I 70 T, '~X
-.,, c.
~
1 0-
~ I justfwant to show :the bitness a' blank form-c
-2 entitled, Protective. Action and 'EBS: Time; Line.;
i:
3 Can.youltell'me, Ms. Malina, if you filled.out 4
a form like~ this during ~ thel exercise?.
5 A
Let me have a minute.
We'have these forms at 6
every exercise.
-I don't recall whether-I filled'one out.ht 7
the LILCO Exercise or not.
I don ' t believe I did, but I
-l 8
don ' t recall.
i II
-9 Q
You said you have them at-every exercise.
Did
~
i 10 that mean thati the evaluators have them with.them during the -
11 exercise?
-12 A
-Yes.
13
-MR. CUMMING:
Is this being entered as an 14 exhibit, or do you want to just describe it, and you don't 15 want to enter it?
16 MS. CASEY:
I think I am going to enter it as-17 an exhibit.
Let's take a five minute break.
18 MR. CUMMING:
What will this be, Malina Exhibit-19 No. 5?
20 MS. CASEY:
This will.be Malina Exhibit No.
5..
xx Index 21 (The above referenced document is 22 marked Malina Exhibit No. 5, for
- (
identification.)
l
~
j 71 THE WITNESS:' Khy is it Malina Exhibit No. 5 1
2 if I didn't fill it out?
3 MS._CASEY:
Because-Iiwant-to ask you some
~
1 4
questions about it,,and the record will _be clearer if people '
i-5 can see what' we are referring to.
l l
6-MR. CUMMING:
Let the record notei that they can l
7 ask you about things even if they are completely irrelevant.
8 to what you did on the day of the exercise.
9 (Recess.)
BY MS. CASEY:
(Continuing) l 10 1
11 0
Before the break, we were discussing Exhibit No. 5, l' ',
(/
which is a blank form entitled, Protective Action and EBS 12 Time Line.
13 14 You said, Ms. Malina, that usually at exercises some evaluators, at least, would have these forms with them.
15 Do you recall now whether you had such a form at the 16 Shoreham exercise?
g7 18 A
APParently not.
19 Q
Okay.
But you have seen this form?
A Yes.
This type of form is used in some of the 20 21 FEMA regions, not all of the FEMA regions use it.
Some 22 just rely upon putting it in notes, and some actually have n
\\j
72 a form.
They allIdon't'look exactly like~this one.
1
.2 But it basically would state as to what protective 3
actions were taken, 'and at what: time EBS messages were sent 4
out, and that sort of thing.
5 Q
Have you ever filled out forms like this?
6 A
Yes, I have.
Usually at a State EOC.
7 Q
When you would fill out a form like this, if you 8
will notice there, there is a column - for the time the 9
decision was made.
How would you get that time?
10 A
Well, first of all, each evaluator wouldn't fill 11 out each blank, okay?
It is like a puzzle.
12 Somebody might have one time over here, and 13 another person would have another time in another blank.
One 14 evaluator would not turn in a full sheet.
Only the evaluator 15 that was assigned to the decision-maker, and following him 16 around at that particular time could fill in that blank.
17 Q
I believe you said you have fulfilled that 18 evaluator role at other exercises, is that correct?
19 A
What, being with the decision-maker?
20 Q
Right.
21 A
Well, I have followed EOC operations that ~ included 22 decision-making.
That was not my assignment here.
O)
N l
\\.s'
ec --
=
3 c
73 I i
~
1 Q
So, havelyou ever,been in a position where you 2
would be responsible-for determining at what time the person 3
who makes protective action recommendations made the decision 4
to make those recommendations?
5 MR. CUMMING:
If-the~ witness understands the 6
ques tion, she may answer?
7 THE WITNESS:
I don ' t understand the question.
8 It seems to me we are getting into a hypothetical area that 9
is not relevant to my evaluation of what went on at LERO.
10 I am not here to talk about what I have done at 11 other evaluations.
I don't feel comfortable talking about g
'wi 12 that.
13 MR. CUMMING:
To the extent the witness does 14 have knowledge, she may answer the question.
I think she 15 has answered the question.
16 MS. CASEY:
I am not sure she has.
17 BY MS. CASEY:
(Continuing) 18 Q
You told me that you have been at other exercises 19 where as an evaluator you would evaluate decision-making 20 objectives, isn't that correct?
21 A
Yes.
22 Q
In the course of evaluating these objectives at f~)h
~-
I s
74~
>!m h):--
1 any exercise, have you been responsible for reporting.the
~
'j
.2 time at'which a particular protective action recommendation
~ :3 decision was made?
4
-A-Yes, I'I h ave. c 4
5 0-And-.how did you do that?
? ';
6 A
Well, I would be nexN to the decision-maker.-
He.
sat down with h'is4 group of people to make a decision.. They
~
y
-8 say:
We are not going.to make this protective-action.
9 recommendation; and go' carry it out.
We will note the time--
10
.that th'at decision was made, andlwe would -put that on the
.f o rm.
11 12'
- 0 Okay.
Have you ever been ' responsible for 13 recording the time at which an EBS message was issued? '
14 MR. CUMMING:
Objection, based on i-- continuing.
15 objection to this line of questioning based on relevancy.
16 To the extent _ that the witness ' has memory, 'she may answer.
17 THE WITNESS:
No,.I amsnot generally involved in 18 evaluation of EBS messages, or operations of JPIC or any of
_19 that type of operation.
20 BY MS. CASEY:
(Continuing) 21 0
You say you are not generally involved in it.
Have 22 you ever --
t 75 i
1 A
I have not ever evaluated a JPIC -,.2md their 2
. release of EBS messages,to the public.
3 Q
What is a JPIC?
4 A
A Joint Public Information Center, where the 5
information is released to the public..The State has a 6
representative there, -the utilit'y, the NRC.
It is where 7
the information is released on the incident.
8 Q
Do you know who on your team at the Shoreham 9
exercise evaluated the time that EBS messages were issued 10 from the EOC?
11 A
No, I don't.
k/
12
-Q Did the subject of EBS messages ever come up 13 in any of the post exercise evaluation team meetings?
14 A
Not in the meeting that I was a participant in.
15 Q
You participated in the meeting of everybody to 16 generate the time line of the exercise, is that correct?
17 A
That is correct.
18 Q
Did the subject of EBS messages come up at this 19 meeting?
20 A
Is that on the time line?
If it is on the time 21 line, people would just call out the time.
I have to look 22 at the time line.
p, N,)
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e 76~
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~
This-is a group meeting :now' ofl all'the -
1 2
evaluators.
You are ' talking; about-what,, forty evaluators or 3
so?
4'
'O Righth Let the. record -- I'didn't mean'to. cut 5
you off.
Let the record f reflect that l thS witness is referring 6
to the Post Exercisej Assessment,Repor.t'. '
7 MR. CUMMING:
Well, counsel. objects to the line 8
of questioning, because the witness' has already stated that 9
she was not responsible for either observing or evaluating 10 the; EBS message, but to the extent that the witness can
' research: the. post exercise assessment and answer counsel for-11 p/.
.\\-
'12 Intervener's questions, she is instructed to do so.
13 THE WITNESS:
On Page 26 of the Post Exercise 14 Assessment Report, there is a column marked ENC.
It-should be Emergency News Center, but I don't see anything on.this 15 chart that has anything to do with EBS messages per se.
16 17 It is only emergency classifications.
18' BY:MS. CASEY:
(Continuing) 19 Q
So, is it fair to say that you have absolutely no independent recollection of any discussions of the 20 21 issuance' of EBS messages at the Shoreham exercise?
22 A
That is correct.
N-
77
~'
1 Q
Going back for a minute to Exhibit No.
4, and 2
this is the emergency classification time line you filled 3
out, I am just not sure ' I got.an answer to ' this, and if I 4
did, I apologize.
5 The times that are actually written there, are 6
those the times when you heard about the emergency classifi-7 cation, or are those the times when those classifications 8
actually took place?
9 Let the record reflect the witness is once again 10 referring to the FEMA Report.
11 A
These are the times that the emergency classifi-e 12 cation was declared and received at the LERO EOC.
During the 13 break, I was trying to recall how that procedure went.
14 As I recall, the head of the EOC would stand up n os.o 15 in a very timely fashion and say:
We are made at the alert.
0 +~,
16 We have received alert as of 6:28, 17 He probably did that within several minutes after 18 receiving the alert notification.
19 Q
And you would write down the time he reported, 20 is that correct?
21 A
I wrote down the time that he said we were at the 22 alert.
We received the alert at 6:28.
Now, if it was a long v
A 78-7 -
- t V
^^#
1-period of time - 'if I looked at my watch and it was 7: 30,.
.2 then 'there would:be a problem; but if it was 6:30_or 6 :31,
~
.an'd 'he is ideclarin'g Ithat' th'ey} receivedL the falert, that. is 3-
~
4' only three: minutes difference.
~
5 0
And onnthis' partibularl chart you-didn't write down the time that he actually made the stA'tement?.
6 s.
7
~A No, I did.not.' ;Because I 1 feel it was in a - timely 8
. fashion.
9 O'
Do you have any' idea of.who. filled 'in the columns 10 on the far right'.of-Exhibit 4?'
11 A~
-No, I don't.
' - (~h
(/
- 12 Q'
You said there was no problem during the Shoreham 13 exercise in terms of the time notification ~ was received and 14 the time when the Director 'would announce it.
What is your criteria for timeliness?
15 16 A
In most. exercises that I have evaluated, I would 17 say within ten minutes.
L' 18
-Q Did you apply the same criteria during the 19 Shoreham exercise?
20 A
Yes.
21 Q
You are aware that there were certain deficiencies 22 found during the Shoreham exercise, aren't you?
A
. O
(~~~'t y
i.-.,
l 79
- .; y.
b'
.-A.
In-reading the exercise reports, I was not
~
t 2
involved in.those. decisions.
3
. Q ~
You mentioned you had:been an evaluator at a li e,,
c 4
number of exercises. ~ In :- any of :the: other exercises you have evaluated, have there been deficiencies found?-
5 MR. CUMMING: L Objection y as Lto ' the relevancy of.
~
6 7
- this line of questioning. : If the witness has-an opinion, t.
l
^
she may answer.
Or. if she has knowledge, she may answer.
8 g
THE WITNESS:
Yes.
Exercise evaluations, there i
- to
.have been other deficiencies in other exercises.
l '.f[
BY MS. CASEY:
(Continuing) 11
(,
0-In other exercises you have evaluated?.
12 A
Yes.
13
- 14 0
In those cases, was a remedial. exercise always I
required?
l 15 MR. CUMMING:
Objection as to the relevancy of 16 g7 this line of questioning.
To the extent that the witness 18 has -- this is a continuing objection with respect to other exercises.
19 To the extent that the witness has an opinion, 20 21 she may answer.
Or has knowledge.
l TIIE WITNESS:
Some exercises have required 22 l
I tz
p
~
r
+
t s
80 m
-t
)
Ettre tbES -
^"M t'
' remediag some haveL not.
~2 BYJMS. CASEY:
(Continuing) 3 Q
Which ones haven't?
m
-4 A
I don ' t irecall.-
~
5
-Q Do you ' have. knowle'dge of' any criteria which were used to determine..whether. or' not.a remedial. exercise should 6
7 be held?
8 A
USDA does' 'not get involved in ~that. - FEMA P MS O'
- 9 C.dc rO tr.d -
thcrc 15 published criteria when -a remedial E'*
10 exercise is required, and when 2 e is not.
11 USDA doesn't get involved -in that decision.
12 Q
Even as a member of the RAC, the USDA would not 13 be involved, is that correct?
14 A
Well, we have not been involved in setting up the criteria for remedial exercises, if that is what you 15 16 mean.
17 Q
So, you are saying that you have knowledge of la exercises where deficiencies were found, and no remedial 19 exercise was required, is that correct?
20 A
There is, I believe, a published criteria whether<t. 6W 21 remedial exercise is required or not.
22 Q
Notwithstanding the fact that there are published O
i
.?
s 81 p.
1_
y h /i 1
criteria, arelyou personally aware of any exercise where 2 2
. de'ficiencies were found,. and no remedial ~ exercise wa's t.
3 required?
'4~
- MR. - CUMMING:
Continuing [ objection.. Asked and q
e
. answered.. To the 'ex,te'nt ' the. witness iknows s from.. memory, she 5
r,
~
6 may so ' s tate.
3 s
4 7
THE WITNESS:. I. don'tfrecalli
~8
.BY MS. CASEY:._ (Con tinuing) 9 Q
_ So, your earlier, answer wherelyou said you knew
- of exercises-where there were deficiencies and some had' to 11 remedials, and some had not. --
i >
12 A
.I will. withdraw that.., because I ;can ' t recall' of 13 a specific instance.
14
-Q You have been referring throughout this deposition to a statement you prepared ahead of time.
I was wondering
. 15 16
~ if. you would be willing to produce that to us.
17 A
- Sure, f
18 (Witness hands document to Ms. Casey.)
19 Q
You mentioned that you are a member of the 20 Regional Assistance Committee.
IIave you had any involvement in the review -- the consolidated RAC Review, Revs 6, 7, and 21 i
I.
22 87 i O.
,,...., -.,,,,,. _, - - ~.... -
,. - -,..,.,. - ~
'l
.r' s
e 82
..;;3
'~'
1 lMR.-CUMMING:
Objection t'o'this[line of
~
L2 questioning based on relevancy.. ' Counsel for the witness as
~
3 Lwell as representations : on - the. record, going back. to 4-conference of counsel on December the' 4th, FEMA Jdoes.not s;
5
' understand the relevancy ofl the ' review of '6, ; 7, 8 to this i'
6
-proceeding.
g.
7 However, on Januaryf14th :19 87, Jthe OL-3. Board
-8 did open discovery concerning reopened Contention =24.
Since r
7 i' 9
counsel does not wish to have witnesses put in - the' position 10 of giving repeated testimony, the counsel for Interveners -
11~
may question the witness concerning - the : review - of Revisions
. - 5 (V --
i 12
' 6, 7, and 8 and her RAC participation.
13 However, the continuing objection.of counsel is 14 note d.
So that we won' t waste further time, there is.a 15 continuing objection.
To the extent the witness has knowledge 16
- she may answer -- is instructed to answer the questions.
17 MS. CASEY:
Let me make it perfectly clear that 18 what I am 'conduc' ting here is OL-3 discovery.
I am sorry, 19 I; misspoke.
20 What I am conducting here is OL-5 discovery, and 21 my asking questions about Revs. 7 and 8, which have been 22 put in issue in this proceeding as responses to the FEMA O
83 1
Exercise, and as fixes for what occurred at the FEMA 2
exercise --
MR. CUMMING:
You mean the FEMA-evaluated 3
4 exercise.
MS. CASEY:
Right.
5 MR. CUMMING:
Or graded, as LILCO has always 6
7 stated.
8 MS. CASEY:
And it is for that reason that I am 9
inquiring into the reviews of - Revs. 7 and 8, and this should be in no way construed as a waiver of any discovery rights to under the OL-3 litigation.
11
'~'
12 Now, having said that --
13 MR. CUMMING:
I think our positions are clear 14 on the record.
Continuing objection to this line of 15 questioning.
To the extent that the witness has an opinion 16 or knowledge, she may answer.
17 BY MS. CASEY:
(Continuing) 18 Q
Ms. Malina, did you participate in the consoli-19 dated RAC review of Revs.
6, 7,
and 8?
r.2Vt<c.us b e
b"'#
20 A
Yes.
I received the revised Plan, and reviewed-
$4 W and submitted a letter of my review to the RAC Chairman,
(@
21 22 Ihor ilusar.
\\,,,.
84
(
1 Q
Did you review the whole plan, or just specific 2
. parts of it?
3 A
USDA only has specific elements that they are 4
responsible for in.>any plan review,. in all plan reviews.
5 Q
So, did you just review these specific ' elements 6
of the plan?
7 A
That is correct.
8 Q
Which elements ' are these?'
9 A
A.2-A, A-3,.E-1,.F-3, G-1, J-ll, M-1, N.
10 Q
In respect to your review of Rev. 7 and 8, did 11 you comment on all of these elements?
,~
\\~
12 A
USDA has been-involved in the review process of 13 the LILCO Plan since the beginning.
We made specific
~
14 comments up until Rev. 5.
At the Revision 5 level, USDA 15 concerns had been incorporated into the Plan at Revision 5.
4 16 Since that revision, we have had no further 17 explicit comment on further revisions.
USDA is not involved 18 in the new revisions that have come out.
Our concerns have 19 already been addressed.
20 Q
Is that the substance of the letter that was 21 submitted to Mr. Husar?
22 A
That is correct.
,~
4
=
E s
"3 85
~
~
1 MS..CASEY:
Mr.- Cumming, 'if you1have not already 2
done so, we would request production of that letter.
3 MR..CUMMING: - After consultation.with the office 4
of George Bickerton, and counsel's office of the Department 5
. of Agriculture. concerning the Department.of Agriculture 's.
rights to asserg privilege, with -respect? to this document, 6
they have indicated. th'at they' do not wise to assert
~
7
~
deliberative process and the letter whic{ I will ask Ms.
8 a
l 9
Malina to identify is being produ'ced to all parties at 1
10 this time.-
t 11 It 'should be noted that it isLalso currently the
- (~%
D 12 subject of' a' discovery request through the -Federal Emergency 13 Management Agency, based on our request from. Interveners 14 filed within the last ten days, and by> producing this 15 document FEMA and the Department of ~ Agriculture don' t waive 16 any other rights with respect to its use.
17 With respect to its production at this time, its 18 intent is that it will expedite the proceeding, and avoid 19 further harassment of the Department of Agriculture's
'20 witness on the Shoreham matter.
21 MS. CASEY:
I object to your characterization of 22 this deposition as harassment.
/~
(_}/
86
(
1 I don't think I am going to have any questions 2
about either of these, but I would just like to have marked 3-
' as exhibits Exhibit No. 6, Ms. Malina's statement.
(Sic.)
xx Index 4
(The above referenced document is marked Malina Exhibit No. 6, 5
for identification.).
6 7
Exhibit No. 6 is' the Department of Agriculture's 8
comments on Revs. 7 and 8.
9 I would like to have marked 'as Exhibit No.
7, 10 a nine page sta'tement.by Ms. Malina. :
(The above-referenced document xx Index 11 I~
)
is marked Malina Exhibit No.
7, 12 for identification.)
13 14 BY MS. CASEY:
(Continuing) 15 0
You said earlier that you have been involved in reviews of the LILCO Plan, quote, 'since the beginning,'
16 17 is that correct?
l 18 A
Yes.
19 Q
llave you also been involved in the review of i
20 Plans for other utilities?
21 A
By other utilities, there are no other utility I
22 plans dhat I am aware of.
LILCO is unique unto itself --
A, t
l s/
l I
(7-i
~87 1
-- or I should say Shoreham is unique unto itself.
It is the first utility plan that has been reviewed by us that 2
hasn't involved State and Local participation.
3 Q
Have you been involved in the emergency response 4
plans for other commercial nuclear facilities?
5 A
Yes.
We have in our office plans from all over 6
7 the country.
SomeL eighty some _ plants, state and local 8
plans.
Site-specific plans, 9
0 How would you characterize the. number and extent of the changes in the revisions you reviewed of the LILCO to Plan compared to the number of changes in revisions you have 11
/~,
(-)
reviewed to other plans?
12 MR. MATCHETT:
I object to the relevance of that.
13 That is not relevant to this at all.
g4 MR. CUMMING:
Objection, based on relevancy.
The 15 wi tness, if she has an understanding of the question, to 16 the extent she has an opinion, may answer.
17 THE WITNESS:
I don't have an opinion on that.
18 BY MS. CASEY:
(Continuing) 19 0
You said you reviewed the LILCO Plan, right?
20 A
Yes.
21 22 0
And you said you reviewed emergency plans for (v
t
I 88 F
i other nuclear plants, correct?
2 A
That is correct.
3 Q
And there have been numerous revisions of the 4
LILCO Plan, right?
5 A
I have received eight revisions.
6 0
Over what period of time?
7 A
I don't! recall what the time frame is.
That must 8
be a matter of record.
9 Q
I will represent to you that Rev. O through 8 to have been promulgated over a period of something like three it and a half years.
x/
12 First of all, have you reviewed a similar number 13 of revisions for any other emergency plan?
14 A
I don't keep track of the number of revisions for 15 every plan that we get into the office.
As a matter of 16 course, all plans when they are first developed require 17 revisions according to RAC review.
18 Following that, all plans -- I shouldn't say all 19
-- but most States and Local Governments have a procedure 20 where they update and revise their plans annually.
21 So, it is a continuing, revolving document.
It 22 is always going to be changed and revised.
O V
m 89 1
Q So, is it fair to say then that you have no 2
sense whether eight revisions in three and a half years represent an average number?
3 4
A No, I don't.
I have never averaged them out.
We get boxes of plans in our office from all over the country 5
on a daily basis.
I would have to sit down and. figure that 6
7 out myself.
8 Q
Do you know how many emergency exercises you have evaluated since the Shoreham exercise?
g A
only evaluated, or also been a player in as well.
go Q
Well, let's first of all ask how many you have 11
(-)
been an evaluator in?
12 A
I don't know.
I don't have my schedule with me.
13 14 I would say four or five.
That was what, a year ago, right?
MR. CUMMING:
Almost one year ago, assuming 15 Interveners are going to have an appropriate celebration, to 16 which all counsel are invited.
17 BY MS. CASEY:
(Continuing) 18 19 0
Ilow many have you participated in as a player?
A Without going back ti. tough my records, I would 20 21 say three or four.
22 Q
So, as near as you can tell now you have probably O
,v
r 90
'1.
at like,seven to nine -exercises since the Shoreham exercise?
2 A
Or ~ had some ' role as.a player, ' a planner - - I aise d*'
)
dw M'-u a p aunc--r, ---
or as an evaluator.
3
.4
'In those'three capacities.
I left 'out the first, 5
originally.
Player, planner,. evaluator.
O Are you aware from any source of any. ingestion 6
7 pathway - a'ctivities that took place at -the February 13th ~
8 exercise ' of the Shoreham plant?
e.
9 A
No.
10
'J1 MR. CUMMING:
Is f counsel almosi done with. this witness?
11 MS. CASEY:
hes,-one more question.
12 BY MS. CASEY:
(Continuing) 13 14 Q
Now, I hope you won't consider this harassment, Mr. Cumming, but I would just like to --
15 MR. CUMMING:
I do, whatever representation you 16 i7 make.
18 MS. CASEY:
-- go back to the hospital question.
19 I am asking you just to assume that those phone calls were 20 not, in fact, to hospitals.
That no hospitals, and no l'
hospital official was contacted on the day of the exercise, 21 i
Would that in any way change your conclusion about objectives 22
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(Continuing) 7-Q It is ~ just ' a' hypothetical / question, and,I am y" Y '_'I #,
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Sh'e n.ay 'Ntate her opinion?!
Idon'tcaretoabsweEhypothetical 10 THE WITNESS:
11 que.stions or to' assume thing's.
.n 12 MS. CASEY:
We11~, you!still have to answer.the a
13 question, if you can.
14 THE. WITNESS:- I have no opin1@n on a hypothetica?.
15 question.
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BY MG. CASEY:
(Continuing) 16.
17 Q
You are unable to give an opinion?
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18 A
I have no opinion on a hypothetical question.-
I am '; ~ '
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.not going to exchange hypothetical' ideas.
20 MR. CUMMING:
The witness has stated she has no 21 opinion.
22 BY MS. CASEY:
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. Q; You mentioned - that you were an emergency. planner.
2 Scme times you planned for these exercises, is that correct?-
3 A
That -is right.
I plan exercises that involve t
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For instance, Federal field exercises, 5
where -the' Federal Government assists State and Local 6
governments during a radiological emergency.
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Would you consider an exercise where the players 8
3 retended to make calls to, real facilities, to be a good i
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10 MR. MATCHETT:
May-I have a clarification on 11 that?
Would be a' good plan, is that the question?
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(Continuing) 13 Q
Would that be a good plan for an exercise?
f; 14 MR. CUMMING:
Objection as to the use of the r.
15 word, 'protend.'
You are referring to simulation of phone is calls, and the witness has an opinion as to whether simula-17 tions are an e f fective representation of knowledge or la training, or whatever, and witness has an opinion, she may I
19 answer.
20.
MS. CASEY:
Ms. Malina has obviously -- :Us
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21 23 She han had some' involvement in planning for exercises.
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m fat.. Y - '18 9 MR. CUMMING:' If the wi.tness has.-an opinion, e k (.7 19 she may answer. I instruct her-to answer. ^' 20 THE WITNESS: (Pause. ) I have' no opinion. .21 MS. CASEY: Thank you'very_much. Of f the record. - I. 2'2 (Off the record discussion ensues.-) 4 r l y + a=
+.A,- s a '( ~ s 94-f'y> ~ : - t -- MS. CASEY: I am sorry. Does. anybody else have f2 any questions?- '3 - MR. CUMMING:' I have no questions. 4 MR. MATCHETT: I have no questions. 5 - (Whereupon, the taking of the deposition concluded - at 12 : 30 p.m., ~ this -same day. ) ~ 6 ' W .q 8 b M < -<t_W g 'CHEkYL L. ' MAL'INA - ;; ' '[$, - ~ ' ' 10 s 11 D + '12 before mt 13- , j 14 ~ .- gng ublic p _a gy Commission %# pires Dec8M 16 17 18 19 20 I' 21 !'~ 22
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J; c y- ) 95 .., = fy - O .' 1 CERTIFICATE OF NOTARY' PUBLIC ,2 '3
- I',JGarrett J. Walsh, DJr.,: the of ficer before ' whom 4
'the foregoing deposit' ion was taken', pages 1L through"94, 1 5 do hereby certify that' the witness whose testimony appear :' s s in the foregoingideposition was dulyLsworn by,me; that the 7 testimony of said witness was taken : by me and. thereafter. a reduced to type' writing by me or under my direction;; that. b ,9 ' said deposition. is;a true record of the testimony:lgiven by 3-to-the witness;'that I am,neither counsel for,-related to nor employed by-any oE the parties to the action.in which this ' 12 ' deposition was taken; and further,- tihat-I am not a relative 13 or employee of any;' attorney or counsel employed'by the 14 Parties -hereto, nor financially or otherwise interested -in ' 4 the outcome of the action. 15 i . 17 d## O GARRET'T WALSH, JR. [ 18 Notary Public. in and for the -19 Commonwealth of Virginia at Large. f 20 My Commission Expires: January 9, 1989. 21 22 4 LO f 9 t f-G7e pt Ttg--9T--M-gr-wt-yr q irrpp4syeyem yp.g y--eey-pw-._-W& qwyp y -s 9+4 gye ip.9w--r,wv-.mye,- -y.gp.- ,.g-my-yee--y9-mp-.-yy9ymp y,- g p e -w. C4'"T#P'F*FIW@'
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TH13 IS AN EY.ERCl2E 1 4W/ V4 & U., I SHORERAM EXERCISE QC, j SPECIAL FACILITT EVACUATION NESSACE Ambulette Suffolk County, New York Date. February 13, 1986 g Message: Ambulette i From: C. Connolly, EOC Team Leader i 3 i To Special Facil!ty Coordleator at LER040C .l via Eserclee Controller Initiatlag Event Decleloe to evacuate Zones A-E, F, C. Message SEND A REAL AMBULETTE TO UNITED CEREBRAL PAL 8Y RESIDENCE AT 442 EANDAL ROAD, RIDCE, NEW YORE. i ONE FATIENT REQUIRES AN AM80LETTE BECAUSE THAT FACILITY'S TRANSPORTATION RESOURCES ARL UNAVAILABLE, AND THEY HAVE REQUESTED LERO ASSISTANCE. WBEN SIMULATID FICKUF OF DDIVIDUAL MAS BEEN CONFLETED AT THIS ADDRESS, THE VEHICLE IS 10 CO 10 THE UNITED CERE8RAL PAIJY RESIDENCE AT 4 MEDIA' LANE, STONY BR005, NEW YORE RECEPTION CENTER. Evaluator Slanoff Time Comments 1. Message glven to controller by team 4 leader at LERO E0C M ( eam Leader / a 12R0 EOC) N' 2. Message dispatched to l Ambulance /Ambulette 50Ae as gL.,,q.,eaza3 wa$ s0*,fv32 E *..t d f_M_ighe g Company fron the // jyg 'g IIRO EOC (Evac. Evaluator g/ W g at LERO EOC) 3. Fleto Evaluation of Ambulance /Ambulette l Company /(s. (Field Evaluator) y a. Vehicle arrives at EWDF/EOC J l l b. Vehicle dispatched from EWDF/EOC l c. Evacuation route completed g d. Vehicle arrived at reception center
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TH13 IS AN EXERCISE SHOREHAN EXERCISE SPECIAL FACILITT EVACUATION MESSACE f. Ambulette f Suffolk County, New York Dates February 13, 1986 Message: Ambulette From: C. Connolly, EOC Tese Leader To Special Facility coordinator at LERO EOC via Exe*rcise controller Initiating Event Decision to evacuate Zones A-E, F, C. i j. Messaget SEND A REAL AMBULETTE TO UNITED CEREBRAL FALST RESIDENCE AT i j 442 RANDAL ROAD, RIDGE, NEW YORK. ONE PATIENT REQUIRES AN ANBULETTE BECAUSE THAT FACILITT'S TRANSPORTATION RESOURCES ARE UNAVAILABLE, AND THEY HAVE REQUESTED LERO ASSISTANCE. WHEN SIMULATED PICKUP OF INDIVIDUAL HAS BEEN COMPLETED AT THIS ADDRESS. THE VEHICLE IS TO CO TO THE UNITED CEREBRAL FALST RESIDENCE AT 4 MEDIA'IANE, STONY BROOK, NEW YORK RECEPTION CENTER. Evaluator i Signoff Time Comen t s 1. Message given to j ; controller by team l, leader at LERO EOC (Team Leader at LERO EOC) 2. Message dispatched to h 4 L L. ks() Ambulance /Ambulette NWi f if /4.or W, } Company from the A rv D 12-ro ne' r' tr LERO EOC OlM2 I (Eva'c.Evalua t or at LERO EOC) 3. Field Evaluation of a 1 Ambulance /Ambulette ( Company /1 (Field Evaluator) (' a. Vehicle arrives at EWDF/EOC ~
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T HIS Ib AN t: A t: M b s t e 'l $8$-WA h SHOREHAM EXERCISE SPECIAL FACILITT EVACUATION MESSACE s Ambulance 'uffolk County, New York Date: February 13, 1986 .:essage: Aebulance trous C. Connolly, EOC Tese Leader To: Special Facility Coordinator at IARO E0C via Exarclae Controller f f four g3 Initiating Event: Decision to evacuate Zones A-E, F, C.( # pielf' p+ p* '*e s s age SEND A RZAL ANBULANCE TO OUR LADT OF PERFETUAL BELP CONVENT ON HILLTor DRIVE, SOUND BEACE, NEW TORE. ONE PATIENT REQUIRES AN AMBULANCE. WHEN SIMULATED PICKUP OF INDIVIDUAL HAS BEEN COMPLETED AT THIS ADDRESS, THE VERICLE IS TO CO TO THE RECEPTION CENTER ASSIGNED BT THE APPROPRIATE LERO OFFICIAL (SINCE I THE PLAN SPECIFIES RECEPTION CENTER IS TO BE ARRANCED). Evaluator Sinnoff M Commen ta I 1. Message given to controller by team leader at LERO EOC g (fess Leader 6 84
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THIS IS AN t-A t:rtta c c , [/4 t L J-v i *= ,j / SHOREHAM EXERCISE SPECIAL FACILITT EVACUATION MESSAGE Ambulance Suffolk County, New York Dater February 13, 1986 Messaget Ambulance 4 From: C. Connolly, E0C Tese Leader To: Special Facility Coordinator at 1.ERO EOC via Exercise Controller Initiating Event Decision to evacuate Zones A-E, F. C. Messaget SEND A REAL ANBULANCE 10 OUR LADY OF PERFETUAL RELF CONVENT ON HILLTOP DRIVE, SOUND BEACH, NEW YORE. ONE PATIENT REQUIRES AN AMBULANCE. WHEN SIMULATED FICEUF 0F INDIVIDUAL HAS BEEN COMPLETED AT THIS ADDRESS, THE VEHICLE IS TO CO TO THE RECEPTION CENTER ASSIGNED BY THE APPROPRIATE LERO OFFICIAL (SINCE THE PLAN SPECIFIES RECEPTION CENTER IS TO BE ARRANCED). Evaluator 5ignoff Time Commenta 1. Message given to controller by team leader at LERO EOC (Team Leader at LERO EOC) 2. Message dispatched to Ambulance /Ambulette l Company from the LERO EOC (Evac. Evaluator at LERO EOC) 3. Field Evaluation of Ambulance /Ambulette h l-L u 7 'E-Company (Field Evaluator) An>benn44 a. Veh ele arrives at EWDF/EOC d7 I _hd f U/41-Bi aQG-b. Vehicle dis tched from EWDF/E0c i gxpp l'ok W W /Nteties Ho** _ ffo5 f ~_ pqu eg g.4 L o uggp va w,x nr mme.v o niw .,,,,,w,a ~ c. Evacuation route completed 8/- d tanat r M i 6' d " AKidffD l i d. Vehicle arrived at i .g... ...ui /3.3[, f l Wd h).s. ' ^ THIS IS AN EXERCISE . e 4t ? ...u't ,.c nt ) .p . :' ;G479 I' e.. ; ) j, <.g.3 t l80bi.n.y;.khid, l u-g
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(( s _ ~ y, 1 . \\, s' 4 , J ;r '! Mr. Ihor W. Husar ~ l Chairman. Regional-Assistance' Committee. ' ~ ~~ e l Federal Emergency Management A~ ency,. Region 'II g ~ 26 Federal Plaza - Room 1319 ' - L '. T, '[ ~ L, W.e,.
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Dear'Mr. Husar:
E i.. :;',- a, .~;~ e . f, ~ i e As requested,c i n your memorandum of-October.22,1986.' we 4 have reviewed the Radiological Emergency Preparedness 3, Transit' ion. Plan.(Revisions:7 and 8). developed by the i ~'l Long. Island" Lighting Company (LILCO) for, the'.Shoreham ^ ~ u Nuc.l ea r ' Power ' St at. ion.,New York.'.-
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.s t ~,, e ~ u 'r , 'g, i We have. evaluated tho' changes to the plan' addressed in' l . ' ~ t Revision's 7 s and,8.andifeel thef are-acceptable. However. /.~ j these changes do not.directly relate.to.the NUREG l elements assignedito.USDA.USDA.is. charged.with;l i reviewing. plans regarding.their adequacy. in protecting. i the food supply.- Previous = revisions (of the LILC0 plan
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s. l 3_ l If.you have any ' questions..p1~ ease feellfree-to contact. i Cheryl Malina of my' staff _on FTS 47543683.. Mrs. Malina- ~ will be available. to atten'd' the : proposed'. November RAC, .' ^ ~, ~ j ' meeting to discuss thef L!LC0 plan., z. s . t. l Sincerely. ,i 7 _ f u-g - .s - 'l, y,; 1 f l l ' George E.. Bickerton, Director -Office of. Emergency Planning 5[. FSIS:PP': EP:CLMa M :igw: 10-30-86,. ,f -s i s }* s', i i lO i 4 ,t -e 1 l
kkUNb h $l SHOREHAM NUCLEAR POWER STATION EXERCISE EVALUATIO STATEMENT OF DEPOSITION Cheryl L. Malina v_ USDA My name is Cheryl L. Malina. I am currently an Emergency Programs Specialist with the Of fice of Emergency Planning, USDA, in Washington, D.C. I have worked with the Of fice of Emergency Planning and the Federal Radiological Emergency Response Program since 1981. Since that time I have evaluated hundreds of State and local radiological emergency response plans and participated as a Federal Evaluator in over 40 exercises throughout the country. I serve as the designated project of ficer for USDA on the FEMA Region II RAC and have been involved in the review and evaluation of the Long Island Lighting Company's (LILC0) '~ Transition Plan for the Shoreham Nuclear Power Station in New York. On February 13, 1986, an exercise of the LILCO Plan was held. I was requested by FEMA Region II RAC Chairman to evaluate the medical operations of the LILC0 Emergency Response Organization (LER0) at LILC0's Emergency Operations Center (E0C) in Brentwood, N.Y. Following the exercise, all of my notes, exercise evaluation forms and exercise summaries were turned over to FEMA. The following statements regarding my exercise evaluation have () been reconstructed from the Shoreham Post Exercise Assessment published on April 17, 1986. I have retained nothing that is unique to the exercise evaluation.
mt ' Eval uator Assignment i . Medical-Operations .'S.. LER0-Organization (m)l. LILC0 E0C u Brentwood, N.Y. j ' Observations of emergency-medical operations was limited to LER0 ~ personnel'at the E,0C'. (The. Hospital Coordinator and the Ambulance Coordina' tor-and their. interface with the Emergency ~ Medical /Pdbl'ic Services Coordinator.) Field observations of ~ ambulances, ambulettes'.and special buses, their routes, drivers, KI procedures and~ evacuation of the mobility impaired was the responsibility of another evaluator. - The following exercise objectives were assigned to me: E0C 2 E0C 3. E0C 11, E0C 16, E0C 18 EOC 20 and-Field 1. My reconstructed evaluation is as follows: EOC 2 - LERO Emergency Operations Center Objective: Demonstrate the ability to mobilize staff and activate the Local Emergency Response Orgnization (LERO) E0C in a timely manner. FEMA General Evaluation: This exercise objective was met by demonstrating the ability to mobilize sta f f.and activate the LER0 E0C in a timely manner. 2 -w+ .,,_,7 y-.,-..,,,,,,, - -. _. -,, -. ...,,,y .e, ,, _,, -.--,mm.-,.yyy mm--._,y. ,r..----
1 . Medical Operations (Specific evaluator comments) ) LJ ~ ~ Emergency medical'~ personnel at the LER0 E0C were notified by . pagers at'about 0629.- Responders called their automatic verification inumber and. received instructions to report to-the LER0 E0C. .The, staff activated in a timely fashi'on between about 0645 and 0730.and set up thei r command room. o EOC 3 - LERO Emergency Operations Center Objective: Demonstrate through rosters, the ability to maintain staffing in the LER0 E0C on a 24-hour basis. r\\ l (f FEMA General Evaluation: This exercise objective was met by demonstrating the ability to mobilize staff and activate the LER0 E0C in a timely manner. Medical Operations (Specific evaluator comments) The Emergency Medical /Public Service Communicator, Ambulance Coordinator. Health Services Coordinator, and Hospital b Coordinator presented rosters with home and business telephone numbers showing su f ficient staf f to support three shif ts on a 24-hour. basis. (~1 s-3
I In anticipation of extended operations, the Lead Communicator ('s-developed a roster of second shift personnel which he presented (_) to the Manager of Local Response who decided that a shift change would occur at 1600 after replacements had arrived and been briefed. A simulated call-out of second shif t personnel was demonstrated by each coordinator. EQ$_JJ_ _ LQQ_ Eggggg3Sy_Qgg$a t 1gg s_S$3 tg5 Objective: Demonstrate.the ability to communicate with all appropriate locations, organizations, and field pcenonnel. (q / FEMA General Evaluation: The exercise objective was met by demonstrating the' ability to communicate with all appropriate locations, organizations and field personnel. Medical Operations (Speci fic evaluator commer.ta) The Emergency Medical /Public Services Coordinator, the Ambulance Coordinator, the Health Services Coordinator, and the Hospital Coordinator ef fectively demonstrated their ability to contact af fected hospitals and ambulance /ambulette companies. The -) available communication equipment is appropriate for their emergency responsibilities. 4
c .w EOC 16 - LER0 Emergency Operations Center ,y (f ' Objective: Demonstrate the organizational ability to manage an orderly evacuation'of all or part of the 10-mile EPZ including the water' portion. FEMA General Evaluation: The LER0 E0C. met the exercise objective of demonstrating the organizational ability to manage an orderly evacuation of all or part of the 10-mile EPZ including the water portion. ~ (3 ()' Medical Operations ~(Speci fic evaluator comments) By'1023, telephone calls (simulated) were being made to homebound individuals. These calls conveyed all appropriate information and were made using the appropriate message forms. The Home Coordinator maintains lists of individuals requiring curbside pickup. Special buses were assigned to pick up these individuals. If the Home Coordinator does not make telephone contact with a particular individual, the Bus Driver, who has copies of the list, is told to check at the residence to see if the individual is home. The Special Facilities Evacuation Coordinator directed this effort and was kept informed of its 3 progress. G .d 5
p-ty Listings of special facilities requiring ambulance services are - . maintained i n OPIP 3.6.5, along wi th lists. of ambulance companies under contract. An evacuation of the entire 10-mile EPZ would require that about eight hundred eight (808) individuals with special needs be picked up. Fif ty-seven (57) ambulances and one ~hundred eighteen-(118) ambulette vans with a total capacity to move five hundred _ eighty six (586) people in approximately two (2) hours' are' available under the Plan. The remaining people would be " evacuated in' a second round of pickups requiring an additional, one 'and 'one-hal f (1.5) hours. According to exercise participants, additional ambulances could be requested from volu.nteer. fire companies and volunteer ambulance companies in the area. When the free play messages were injected at about 1030 requesting that an ambulance be sent to Our Lady o f Perpetual Help Convent and that an ambulette be sent to the United Cerebral Palsy Residence, the messages were handled expeditiously by the LER0 E0C staff. Both messages had gone from the Special Facilities Evacuation Coordinator to the Health Facilities Coordinator, to the Ambulance Coordinator, by 1055. The ambulance had been dispatched by 1100 and the ambulette by 1114. O 6
~. E0C 18 - LERO Emergency Operations Center ,x Objective: Demonstrate the organizational ability necessary to effect an early dismissal of schools within the 10-mile EPZ. t. FEMA General Evaluation: A demonstration of the organizational ability necessary to ef fect an early dismissal of schools within the 10-mile EPZ could not be observed. Both public and private schools were simulated to have been contacted prior to 0845. O 1x / Medical Operations (Specific evaluator comments) No medical operations were observed. E0C 20 - LERO Emergency Operations Center Objective: l Demonstrate the organizational ability necessary to effect an orderly evacuation of schools within the 10-mile EPZ. If this protective action is not recommended by the decision-makers, e.g. Schools were dismissed early, a free play controller's message may be inserted to demonstrate this activity. l
y ' FEMA General Evaluation: \\_j: Since schools would have alread.y closed, an actual demonstration of the organizational ability necessary to effect an orderly evacuation of. schools within the 10-mile EPZ could not be observed at the LER0 EOC. A free play message was inserted to demonstrate this activity. However. I did not observe the flow of information or emergency response activity concerned with this objective. Medical Operations (Specific evaluator comments) No medical operations were observed. () Field 1 - Field Activities Objective: Demonstrate the ability to continuously monitor and control emergency worker exposure including proper use of personal dosimetry. FEHA General Evaluation: Field activities dispatched from the LERO EOC were evacuation of special facilities by ambulance and ambulette and school evacuation. These activities were monitored by another O evaluator. 8
r t' With respect to the ambulance and ambulette demonstrations, the r~% objective to demonstrate the ability to continuously monitor and U control emergency worker _ exposure including the proper use of dosimetry was met. Medical Operations (Specific evaluator comments) Ambulance and ambulette personnel were issued packets containing dosimetry equipment consisting of 0-200 mrem and 0-5 Rem direct reading dosimeters (DRDs), a thermoluminescent dosimeter (TLD), dose record forms, and simulated potassium iodide tablets (KI). Activities following the issuance of the dosimetry packets were monitored by another evaluator. O I hereby declare under penalty of perjury that the foregoing is true and correct.
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