ML20207T667
| ML20207T667 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/19/1987 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#187-2924 OL-5, NUDOCS 8703240229 | |
| Download: ML20207T667 (250) | |
Text
,
OR G2 UNITED STATES O
] NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO: 50-322-OL-5 SHOREHAM NUCLEAR POWER STATION, UNIT 1 (EP EXERCISE)
LOCATION:
HAUPPAUGE, NY PAGES: 1627 - 1807 1
DATE:
TIIURS DAY, MARCII 19, 1987 e\\
'k by l
ACE-FEDERAL REPORTERS, INC.
Official Peporters 444 North CapitolStreet 0703240P29 87031/
Washington, D.C. 20001 PDR ADOCK 0500 2
(202) 34~-3700 NATICNWIDE COVERACE
r 2110 01 01 1627.
llhysimons1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
X 5
In the Matter of:
6 LONG ISLAND LIGHTING COMPANY
- Docket No. 50-322-OL-5 7
(Shoreham Nuclear Power (EP Exercise) 8 Station, Unit 1) 9
X 10 Court of Claims 11 State of New York 12 State Office Building 13 Third Floor Courtroom 14 Veterans Memorial Highway 15 Hauppauge, New York 11788 16 Thursday, March 19, 1987 17 The hearing in the above-entitled matter 18 reconvened, pursuant to notice, at 9:00 o' clock a.m.
19 BEFORE:
20 JOHN H.
FRYE, III, Chairman 21 Atomic Safety and Licensing Board 22 U.S. Nuclear Regulatory Commission 23 Bethesda, Maryland 20555 24
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'3' 25 ACE-FEDERAL REPORTERS, INC.
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' OSCAR,H. PARIS, Member
.2 Atomic Safety and Licensing Board 3
U. S. Nuclear-Regulatory Commission 4
Bethesda, Maryland 20555 5
FREDERICK J. SHON,-Member 6
-Atomic Safety and Licensing Board
.7 U. S. Nuclear Regulatory Commission 8
Bethesda, Maryland 20555 9
APPEARANCES:
10 On Behalf of Long Island Lighting Company:
11 DONALD IRWIN, ESO.
12 LEE B.
ZEUGIN, ESO.
(
13 STEPHEN MILLER, ESO.
14 Hunton & Williams 15 707 East Main Street 16 P. O. Box 1535 17 Richmond, Virginia 23212 18 On Behalf of Suffolk County:
19 MICHAEL S. MILLER, ESO.
20 P. MATTHEW SUTKO, ESO.
21 Kirkpatrick & Lockhart 22 South Lobby, 9th Floor l
23 1800 M Street, N.W.
24 Washington, D.C.
20036-5891
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25 i
Ace-FEDERAL REPORTERS, INC.
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., 1629 hysimons1 On Behalf.of the' State of New Yorks
~
RICHARD'J.. ZAHNLEUTER, ESO.
2
'3-Specibl Counsel to the-Governor 4
' Executive Chamber 5
Room 229 6
State Capitol
'A 7
Albany, New York 12224 1
8 On Behalf of FEMA:
i 9
WILLIAM R. CUMMING, ESO.
v 10
' Federal Emergency Management Agency i
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)
11.
500 C Street, S. W.
y 12 Washington, D.C.
20472 il,
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AV 13 On Behalf of'the NRC:
14 ORESTE RUSS PIRFO, ESO.
' l; 15 U. S. Nuclear Regulaf.ory Commission 16 7735 Old Georgetown Road
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17 Bethesda, Mary. land 20814
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18 19 20 21 22 U
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25 ACE FEDERAL REvoRTERs, INC.
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- i..
ysimons 1 CONTENTS 2.
VOIR 3
DIRECT CROSS REDIRECT RECROSS DIRB BOARD 4'
JOHN A. WEISMANTLE 1648 5
EDWARD B. LIEBERMAN 6
EXHIBITS IDENTIFIED ADMITTED 7 s.,,
8 Suffolk County Exercise Exhibit 9
Number 23-A, B & C-1656 24 1674 10 i 25 1695 1723 11 26 12 13 27 1786 1793 14 FEMA Exercise Exhibit 1805 15 Number 2 16 LAY-IN DOCUMENTS 17 (None)
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RECESSES
.18 19 Mo rn i ng Re ce s s......................... Pa ge 16 81
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20 Lunch Recess........................... Page 1721 21 Af ternoon Recess....................... Page 177 3 s.
4 22 i
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ACE FEDERAL REPORTERS, INC.
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(9:10 a.m.)
3 JUDGE FRYE:
Good morning.
Did you-all have 4
some scheduling matters you wanted to bring up, Mr. Irwin?
5 MR. IRWIN:
Yes, sir.
Last evening and this 6
morning, Mr. Miller.and I, and indirectly colleagues back in 7
our home offices, have talked about the pace'at which we hope
_p 8
to get through the issues remaining before we get'to the ENC 9
testimony and the other large remaining pieces of testimony.
10-And, what I would like to do is outlin$ for the 11 Board an estimate of the schedule which we believe can be 12 followed with any luck for completion of Contention 40, l
- p)
(,_
13 LILCO's rebuttal on the fuel truck rerouting on Contention l
14 41, and then Contention 36, and then the group of 1
4 l
15 c'ontentions, 47, 22.A and 49.
I s
16 Mr. Miller has' told me that -- this is with
,/
l 17 respect to Contention 41st, Mr. Miller has told me that 18 Suffolk County expects to continue through the end of today l-
/_
19 and into Monday on its examination of LILCO's witnesses on
,S 20 Contention 40 but is hopeful of being able to be finished by 21 midday Monday and will make efforts to do so.
22 LILCO does not expect to have extensive 23 examination of Suffolk County's witnesses.
We believe it 24 will be on the order of a couple of hours.
We believe also
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25 that if Mr. Lieberman's rebuttal on Contention 41 remains as ACE-FEDERAL REPORTERS, INC.
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- (,uewalsh 1 now, as I presently expect it will be, that will not take 2
more than an hour or two.
3 Therefore, we hope to complete our cross 4
examination of Suffolk County and complete the rebuttal on 5
Contention 41 by the close of business next Monday, the 6
23rd.
We would hope --
7 JUDGE FRYE:
So, Monday the 23rd, we would have 8
completed 40 and 41?
9 MR. IRWIN:
Yes, sir.
10 JUDGE FRYE:
All right.
11 MR. IRWIN:
We would hope to move into 12 Contention 36 the first thing Tuesday morning, the 24th.
Mr.
-(
13 Miller understands from Ms. Letsche, who is in charge of that 14 contention, that her examination of LILCO's witnesses will 15 take on the order of three-quarters of a day to a day.
16 LILCO's examination of Suffolk County's 17 witnasses will be on the order of a half day or less.
So, at 18 the outside we expect to be through Contention 36 by midday 19 Wednesday, the 25th, and with any luck before then, although 20 I am hesitant to predict that.
21 We would then move straight into Contentions 47, 22 22.A and 49.
LILCO has two panels on them.
Suffolk County 23 has one.
24 We would propose to take LILCO's two panels in
()
25 order and then take Suffolk County's.
Ms. Letsche has ACE FEDERAL REPORTERS, INC.
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(()uewalsh1 indicated that she is not exactly certain how long she 2
expects her examination of LILCO's panels to take but that it 3
will be at least a day and probably longer.
4 On that assumption, I am guessing that.we will 5
probably get through Suffolk County's examination of LILCO's 6
witnesses by the close of business next Thursday, the 26th 7
but will probably not yet get to LILCO's examination of 8
Suffolk County's witnesses on 47, 22.A and 49.
And that 9
would have to be the first order of businese the following 10 week.
11 As always, I hope that things will move faster, 12 and LILCO will do whatever it can to expedite the process.
13 But, that's my understanding of where things stand right 14 now.
Maybe Mr. Miller wants to add something.
15 i
16 17 18 19 20 21 22 23 4
24
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MR. MILLER:
Very briefly, Judge Frye.
First, I 2
want to give all the appropriate caveats, as I think 3
Mr. Irwin has, that Ms. Letsche is in charge of the issues 4
after Contention 41 that are scheduled to be heard next by 5
the Board.
I talked to Ms. Letsche last night very. late.
6 She has been ill this week, but she is plowing ahead.
7 And, she has made a preliminary review of the-8 LILCO testimony.
The estimates Mr. Irwin has given to the 9
Board are her best guess at this point.
But, that's all 10 they are; they are just -- they are her best guess.
11 And, we would not want to be held in'any way-12 accountable for those estimates not being realized once the
{';
13 cross examination actually begins next week.
14 The other matter which is related, Judge Frye, is 15 this close-out of Contention 41 and Contention 40.
My first 16 position with the Board would be that I would like to see
'17 the. record stand as is on Contention 41.
I think we have 18 heard substantial testimony by the LILCO witnesses and the 19 County witnesses on that issue.
20 JUDGE FRYE:
We want to hear from, as we 21 indicated, Mr. Lieberman again.
And, of course, you have an 22 opportunity to cross on whatever he may say.
23 MR. MILLER:
Okay.
Judge Frye --
24 JUDGE FRYE:
We want your witnesses present when 25 he testifies.
l ACE FEDERAL REPORTERS, INC.
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MR. MILLER:
Judge Frye, there is a couple of i
2 understandings that I think we have to reach.
First of all, 3
for there to be any chance for the rebuttal on Contention 4
41 to go forward next week, especially next Monday, I think 5
the Board has got to define with as much precision as 6
possible what it wants to hear, what it will be permitted to 7
be heard, because my witnesses -- the Suffolk County police 8
who are very busy gentlemen -- have devoted most of this 9
week to this hearing.
I cannot expect to give them all the 10 transcripts for the time Mr. Lieberman was on the stand, 11 which is about four days.
That's a thousand pages of 12 transcripts.
O('^
13 They can't review that kind of material between 14 now and Monday plus prepare to testify on Contention 40.
I 15 understand that the Board originally wanted to hear just 16 about the fuel truck rerouting.
And --
17 JUDGE FRYE:
That's what we asked for.
That's 18 right.
19 MR. MILLER:
Is that the only issue the Board 20 then will permit to be presented, because that makes it an 21 easier matter for my witnesses to try to review the 22 transcripts.
We can obviously just look at those pages 23 pertinent to that issue.
24 JUDGE FRYE:
No.
LILCO has the burden of proof 25 and as such they are entitled to present limited rebuttal.
()s ACE FEDERAL REPORTERS, INC.
l 202-347-3700 Nationwide Courage 800-336-6646
-2110 02 03 163'6 1 -;W/sw 1-I don't_know whether you intend to go beyond the fuel 7L) 2 truck incident in rebuttal or not.
3 MR. IRWIN:
We haven't made any determination 4
that we will at this point, Judge Frye.
We just got the 5
transcript for that day yesterday evening,_and Mr.'Lieberman 6
for obvious reasons hasn't had a chance to review it either.
7 JUDGE FRYE:
Sure.
8 MR. IRUIN:
And he wasn't present when the police 9
were being examined the other day.
I told Mr. Miller when 10-we were talking a few minutes ago that we expected to review 11 the transcripts tomorrow.
12 And, if I felt we needed to go beyond the fuel 13 spill I would notify him of that tomorrow, and that I
(}
14 recognized that as to any matters beyond that LILCO had the 15 burden of showing good cause, to present rebuttal which I 16 think is the usual rule.
17 The fuel spill is testimony being delivered at 18 the Board's request, and I think that's a different matter.
19 JUDGE FRYE:
That is.
20 MR. IRWIN:
With respect to whether Mr. Lieberman 21 alone would address that or whether there may be 22 organizational aspects, as I indicated the other day, we 23 want to take a look at the transcript.
And, Mr. Lieberman's 24 views I think are entitled to some weight on that matter.
3 25 And, I told Mr. Miller that we would inform him (Q
ACE-FEDERAL REPORTERS, INC.
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if we needed to ask Mr. Weismantle or Mr. Daverio to be 2
present with respect to organizational ~-- or, Mr. Wilm, I'm 3
sorry -- with respect to organizational aspects.
At this 4
point, I don't really expect them to be, but we will keep 5
everybody apprised.
6 MR. MILLER:
Judge Frye, maybe we could' leave it 7
like this, because this sounds like this is the'only way 8
this-is going to work.
9 I will plan on'the rebuttal' going-forward Monday 10 afternoon.
I will search the transcripts, four days of 11 transcripts, for those matters relating - to the fuel truck 12 rerouting and I will get those materials out to the police 13 witnesses.
}
14 If --
15 JUDGE FRYE:
I guess I'm having trouble.
I don't 16 want to tell you how to proceed with your case obviously, 17 because you have to make those decisions.
But, what we are 18 interested in, I mean, is basically we've got a record at 19 this point where Mr. Lieberman and your witnesses have 20 contradicted themselves -- or contradicted each other, not 21 themselves.
22 And, we are interested in getting a little more 23 airing of that issue with regard to the rerouting around the 24 fuel truck.
So, it would seem to me that what your
)
witnesses are going to be most concerned with is what he 25 ACE FEDERAL REPORTERS, INC.
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may testify to when he comes back on that issue.
=L)
,R.
MILLER:
I agree completely, but I think also 2
M 3
I would'like my witnesses to see what Mr. Lieberman said 4
last week --
5 JUDGE FRYE:
Okay.
6.
MR. MILLER:
-- on that issue.
And, that's going 7
to require searching four days of transcripts.
And,. we will.
8 do that.
And, that's a lot less material than giving them 9
four days' worth of transcripts.
10 JUDGE FRYE:' All right.
11 MR. MILLER:
I -- let me just finish through on 12 this.
I will assume that the rebuttal being presented by f{ ';
13 LILCO will be limited to the fuel truck rerouting.
I will 14 prepare my witnesses accordingly.
And, I think that's 15 doable between now and Monday afternoon.
It's not great, 16 but it's doable.
17 If the issues are in any way broadened beyond d
18 that, Mr..Irwin will notify me, as he stated.
And then, 19 Judge Frye, I don't think we can count on it being done 20 Monday afternoon.
21 JUDGE FRYE:
Well, we will cross that bridge when 22 we get to it, if we get to it.
23 MR. MILLER:
If we get to it.
24 -
JUDGE FRYE:
Yes.
25 MR. MILLER:
But, if we go beyond the rerouting
}
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-1 of the fuel truck, I don't think my witnesses can be ready 2
by Monday afternoon.
3 JUDGE FRYE:
All right.
4 MR. PIRFO:
Judge Frye, if I may, this is 5
probably obvious but I assume that Mr. Lieberman's rebuttal 6
testimony will be oral, strictly oral?
7 JUDGE.FRYE:
Yes, that was my assumption.
Yes.
8 MR. MILLER: _ And the Board would like the police 9
witnesses here while Mr. Lieberman is on that. issue of 10 rerouting and then the police,- if necessary, will go back ty?
11 subject to questioning by the Board and other parties.
12 Is that the understanding?
("I 13 JUDGE FRYE:
Yes.
We might like to air the issue v
'14 if they --
15 MR. MILLER:
Okay.
16 JUDGE FRYE:
-- continue to have differing 17 opinions.
We might like to have them comment on each 18 other's opinions.
19 MR. MILLER:
Okay.
Fine.
And, I only have one 20 other caveat, which is none of this has been discussed with 21 the police witnesses because Mr. Irwin and I had these 22 discussions late last night.
I will endeavor to make the 23 contact during a break today and let people know where 24 things stand.
25 But, I have to clear all of this with the ACE FEDERAL REPORTERS, lNC.
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2-MR..IRWIN:
Ju'dge Frye, this is a almost top of I
3 the head-but not totally facetious thought.
If, in-fact, l
I 4
the Board is interested in the airing of experts' respective
]
5 views on this one matter, one possibility might be to'have l
6 Mr. Lieberman and the police on the stand at the same time 7
so that we could make sure that got everybody's views.
8 I've seen it work before, and it has worked quite 9
well on occasion.
10 JUDGE FRYE:
It works, what I thought, quite 11 well, too.
And I hadn't. suggested that yet, but why don't 12 you discuss it with Mr. Miller and see how he feels about 13 it?
}
14 MR. MILLER:
I'm always willing to discuss things 15 with Mr. Irwin,LJudge Frye.
I will say that I've seen it i
16 before in this case, and it was a complete free-for-all.
17 (Laughter.)
18 JUDGE FRYE:
It has that potential.
I --
19 MR. MILLER:
It did not work.
20 JUDGE FRYE:
-- agree with you.
It has that 21 potential.
Let me -- while we are on the subject of the 22 speed with which we are proceeding, let me make a couple of 23 suggestions.
I think last night we discussed the fact with 24 regard to the information that you are currently bringing 25 out now for the County.
It's apparently all contained in ACE FEDERAL REPORTERS, INC.
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'2110 02-08 1641 l'(~ ' W/sw 1-admissions'that you have gotten from~LILCO.
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-It would seem to me that it would speed up the I
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3 process'somewhat where you have admissions that you want to 4
.get into the record if you would just read those into the 5
record 1rather-than trying to get the witnesses to attest to 6
the information again.
It would go a good deal' faster.
7 Also, the questions ---I can appreciate your 8
concern about getting everything you think relevant in a 9
record but, I assure you, I think-everybody in this room is 10 capable of figuring out time differences and things:of that 11 nature.
So, I f rankly just don't see the need to take time 12 to ask a witness whether the difference between 1:30 and 12 13 is an hour and a half.
}
14 I think we can eliminate that sort of thing.
You 15 have got the times in the record, and we.can certainly make 16 the calculation.
17 MR. SUTKO:
Judge Frye, I think yesterday-18 afternoon you suggested that right now at the beginning of 19 the day I read into the record those admissions.
And, I'm 20 prepared to do so.
21 And then what I would like to do -- and I don't.
22 think it is going to take a lot of time, because there are 23 not that many charts I'm going to put up, I would like to 24 then go through -- I will simply put the numbers up for the
("1 25 witnesses to look at because --
ACE FEDERAL REPORTERS, INC.
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i JUDGE FRYE:
I think that would be helpful.
.V' 2
MR. SUTKO:
Okay.
3 JUDGE FRYE:
Yes.
So,.have we finished our 4
preliminary matters?
5 MR. IRWIN:
Two quick observations, Judge Frye.
'6
'I think Mr. Miller and I, we have seen free-for-all's I 7
suppose but I think also we've seen the development of 8
information in a fairly effective fashion on a couple of 9
times with simultaneous panels.
10 Secondly, the time estimates with respect to the 11 examination are obviously based on the parties 12 representations and the assumption of efficient-use of that 13'
-time.
d(~%_
14
'And, I will just stop there at this point.
So, I 15 think we are through.
In other words, we. agree with the 16 Board's suggestion that there are ways of expediting the 17~
pace of sor--? of the questioning.
And,~I will stop using 18 time.
19 JUDGE FRYE:
Fine.
Well, let's then proceed.
20 MR. SUTKO:
If it is of any help to the Board, I 21 am going to be referring to Pages 19 and 22 of the County's 22 testimony.
The first admission made by LILCO upon which we 23 rely is LILCO Admission Number 129.
And, we define what we 24 mean by LILCO admission in Footnote Number 2 of our rs 25 testimony.
d ACE FEDERAL REPORTERS, INC.
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4 2110L02 10, 1643 I ";W/sw 1-That admission asked LILCO to admit that during fV 2
the. exercise LERO traffic guides, other than Lead Traffic.
3 Guides, were not notified of the emergency or required'to 4
report to the staging areas until after 8:19 a.m. when a-l 5
site area emergency was declared.
LILCO's response was:
l 6
Admitted.
7 The next admission is LILCO Admission Number 123 8
in which we ask LILCO to admit that by 9 a.m. on the day of 9
.the exercise two traffic guides had reported to the 10 Riverhead staging area.
LILCO denied this.
It stated that 11 five traffic guides had reported to the Riverhead staging 12 area by 9 a.m.
And, then the five is the figure that we
('/
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13 have adopted in our testimony and which we will be using-in s.
14 this cross examination.
15 The next LILCO admission is LILCO Admission 124 16 in which we requested LILCO to admit that by 9 a.m. on the 17 day of the exercise one traffic guide had reported to the 18 Port Jefferson staging area.
LILCO admitted this.
19 The next LILCO admission upon which we rely is l
20 Admission Number 125 where we asked LILCO to admit that by 9 l
(.
21 a.m. on the day of the exercise one traffic guide had 22 reported to the Patchogue staging area.
LILCO admitted 23 this.
24 The next admission upon which we rely is Number
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126 in which we asked LILCO to admit that by 9:40 a.m. on 25 ace FEDERAL REPORTERS, INC.
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the day of~the exercise, 19 traffic guides had reported to N'
2-the Riverhead staging area.
LILCO denied this. admission and 3
stated by 9:40-a.m., 30 traffic guides had reported to the 4
Riverhead staging' area.
In our' testimony and.in our-cross
_5 examination we will rely upon the LILCO figure.
6 The next admission is Admission Number 127 which 7
we requested them to admit that by 9:40 a.m. on the day of 8
the exercise 10 traffic guides had reported to the Port 9
Jefferson staging area.
LILCO again denied this.
They 10 stated by 9:40 a.m. LILCO traffic guides had reported to the
~
11 Port Jefferson staging area.
We have adopted LILCO's 12 number.
13 The next admission --
{}
14 MR. ZEUGIN:
Just so the record is clear, I think 15-you said LILCO traffic guides.
I think you meant 15 traffic 16 guides.
I don't.think you got the number in.
17 MR. SUTKO:
Yeah.
I'm sorry, Judge Frye.
It's
-18 15 traffic guides.
19 The next admission i., Admission Number 128 where 20
'we asked them to admit that by 9:40 a.m. on the day of the
'21 exercise 37 traffic guides had reported to the Patchogue 22 staging area.
LILCO denied this number.
In turn, they 23 admitted that by 9:40 a.m.,
41 traf fic guides had reported 24 to the Patchogue staging area.
And, we again have adopted 25 LILCO's numbers.
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The next admission upon which we rely is LILCO O]
2 Admission Number 130 where we asked LILCO.to admit that 3
during the exercise no traffic guides were dispatched from 4
their respective staging areas until after the evacuation i
5 recommedation had been made to the public by a simulated EBS j
I 6
message.
LILCO admitted this.
l l
7 The next admission upon which we rely is l
l 8
Admission Number 136 where we asked LILCO to admit that 9
during the exercise, the dispatching of traffic guides from 10 the Riverhead staging area first began at 10:25 a.m. and was 11 completed shortly after 11 a.m.
LILCO admitted this 12 request.
13 MR. ZEUGIN:
Judge Frye, if I may simply ask so
( }
14 that -- I agree that this is the best process to go through 15 it.
I would merely ask that Mr. Sutko look at LILCO's 16 response to Suffolk County. Admission Number 131 where LILCO,-
l 17 in the admissions, attempted to define what it meant by the l
18 term " dispatch."
j 19 I think it will make it all a lot clearer when we 20 read these later admissions, that in answering these l
21 admissions LILCO had attempted to define that term which can i
22 sometimes -- the Board can probably appreciate -- have many 23 meanings.
24 JUDGE FRYE:
Yes.
I think we are aware that it
}
does have different meanings to different people.
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.MR. SUTKO:
Judge Frye,- the,next admission up'on
~ k).;
2 which we rely 11s. Number 137 where we asked LILCO to admit 3
that.during the exercise the dispatching 1of additional-
-4 traffic. guides. from the Riverhead staging area: began.at 5
approximately 12 noon, was completed at approximately 12:20:
1 6
p.m.
LILCO admits this.
7 The next admission that we asked LILCO to admit, 8
and upon which we rely, are Numbers 131 and 132.. And, 132
~
9
-- I'm sorry, 131, we-asked LILCO to admit that during the 10 exercise' traffic guides were dispatched from the Port 11
. Jefferson staging area beginning at 10:30 a.m.
LILCO denied 12 this request for admission and instead~ stated:
. Traffic g' ides were dispatched from the Port Jefferson staging area
(}
13 u
14 beginning at.10:50 a.m.,
where " dispatched"~means the 1
15
. traffic guides were sent to pick up' equipment and go to the' 16 field.
And, we have adopted both LILCO's time, and we will 17 be using their definition of " dispatch."
-18 In request for Admission Number 132, we asked 19 LILCO to admit that during the exercise the dispatching of 20 traffic guides from the Port Jefferson area was not 21 completed until 12:20 p.m.
LILCO's response was:
LILCO 22 admits that the last traffic guides ~were dispatched from the 23 Port Jefferson area at 12:20 p.m. and denies any implication 24 in the request that this time was inadequate.
25 I believe that the last two admissions upon which j
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'I am going.to. rely, at.least this_ morning, are Numbers'134
-- 2 and 135.
.3~
In_ request for Admission Number _134, Suffolk.
4' County requested that LILCO admit'that-during the. exercise-5 traffic. guides were dispatched fron the-Patchogue staging 6 '-
area _beginning at'10:30 a.m.
LILCO admitted-this. request 7
-for admission.
8 And.the final request is Number-135 where'Suffolk 9-County asked:LILCO to admit that during'the exercise, the.
10 dispatching of traffic-guides from.the'Patchogue staging 11 area was completed at:approximately 10:59.a.m.- ~ Again, LILCO l-12 admitted this request.
l
~
13 i
14 15 16 17 18 1 9 20 21 22 l
1 23 24 O
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JUDGE FRYE:
Do you want to add to the 2
admissions?-
3.
MR. ZEUGIN:
Not that I can see at this point.
4 Whereupon, 5
JOHN A. WEISMANTLE 6
and 7.
EDWARD B.
LIEBERMAN, 8
were called as witnesses, and having.previously been duly 9
sworn, resume the stand and further testify as follows:
10 CROSS EXAMINATION
'll BY MR. SUTKO:
(Continuing) 12 0
. Good. morning, Mr. Weismantle.
-13 A
(Witness Weismantle). Good morning.
{)
14 0
I think yesterday afternoon we left off that we 15.
had established that at 9:00 a.m.,
approximately four 16 percent of LILCO traffic guides were at the staging area, 17 and this is~ roughly twenty minutes before the PID estimate 18 of sixty minutes in which traffic guides would substantially 19 be in place.
20 I would now like to move beyond to later 21 estimates.
22 A
I don't agree with that statement insofar as when 23 the PID estimate -- twenty minutes before when the PID 24 estimate said they would be in place.
The PID estimate 25 dealt with travel times averaging about an hour.
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.1 JUDGE PARIS:
What is the PIT estimate?
^
..,)
2
= WITNESS WEISMANTLE:
I am sorry. -The Partial 3
Initial Decision estimate.
4-JUDGE PARIS:
Oh, PIDfyou are saying.
5 WITNESS WEISMANTLE:
PID.
6 BY MR. SUTKO:
(Continuing).
7 0
And, Mr. Weismantle, the time stated there is.60 8
minutes, is.that correct?
9 A
(Witness.Weismantle)
The travel time -- the 10 average travel time for field workers is indicated as about 11 60 minutes, yes.
12 0
Now Mr. Weismantle, it is correct, isn't it, that f]'
13 at'9:39 a.m.,
a general emergency was declared?
(s 14 A
Yeah, I believe that is correct.
15 0
And at 9:40, which is roughly an hour and sixteen 16
-minutes after a site area emergency was declared, LILCO's 17 mobilization rates were as follows, and now I am going tc 18 rely upon the admissions which we had previously entered-19 into the record, Judge Frye.
20 Mr. Weismantle, would you agree that at 9:40, 21 roughly, 58 percent of the traffic guides at Riverhead had 22 reported to their staging areas?
23 A
Yes.
24 0
At 9:40, roughly 21 percent of the traffic
}
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l areas?
().
2 0
And, at 9:40, 100 percent of the traffic guides 3
.had reported to bhe Patchogue staging area?
4 A
Yes.
5 0
So, at 9:40 roughly 52 percent percent of all' 6
traffic guides reported to their staging areas, is that 7
correct?
8 i;
That is correct.
9 0
Now, Mr. Weismantle, before you stated that you 10 had a little disagreement as to when the 60 minute estimate, 11 or the so-called one hour PID requirement would have begun 12 running, and I take it that it is your testimony,
{ };
13 Mr. Weismantle, that it would have begun running at roughly l
14 8:33, which is when you believe the call out first began, is 15 that correct?
16 MR. ZEUGIN:
I will object to the form of the 17 question.
I think it is a point that we covered yesterday.
18 What the PID means, whether it was a requirement or not a 19 requirement, is something I don't think these witnesses 20 agree with.
21 I don't want to keep going back over the same
.22 topic.
Mr. Weismantle can answer the question, but I have a 23 pro'olem with the way the question itself was formed, because 24 Mr. Sutko now apparently assumes that Mr. Weismantle agrees 4
25 with his characterization..
(~)T
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JUDGE FRYE:
I could tell Mr. Weismantle didn't 2
agree.
Why don't you rephrase the question, and let's stay 3
away from whether it is a requirement or not.
4 BY MR. SUTKO:
(Continuing) 5 Q
All right.
I will then refer to it as the PID 6
one hour estimate if that is okay with you, Judge Frye.
7 I take it you believe that the PID one hour 8
estimate roughly would have begun running at 8:33, isn't 9
that a fair statement, Mr. Weismantle?
10 A
(Witness Weismantle)
Roughly.
A little later 11 than 8:33 actually, but --
12 0
But not much later, isn't that correct?
/
13 A
No.
The time difference being the time it takes
)
14 the pager to be activated, through the point at which the 15 actual phone call is made to any individual traffic guide.
16 0
So, in fairness, at most we are talking about a 17 few minutes, isn't that correct?
18 A
We are talking about several minutes, depending 19 on the situation.
It can vary, depending on access to a 20 phone, and how long it takes for someone to pick up the 21 phone, et cetera.
22 O
So, roughly 9:40 would have been an hour.
23 A
I would agree to an hour after nofification as a 24 reasonable statement.
And I think this simply points out 25 that the PID estimate of 60 minutes to report as an
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1 average for.LERO. workers is borne out.
U 2
0 Mr. Weismantle, in your opinion, would you have 3
been able-to have manned all traffic control posts at 9:40?
4 A
No, of course not.
That was well before any sort
~
- 5 of protective action was declared.
6 O
Well, now, I wasn't asking you whether a 7
protectivew action had been declared.
8 JUDGE FRYE:
He said no, he couldn't.
9 BY MR. SUTKO:
(Continuing) 10 0
Mr. Weismantle, I would appreciate-it if we~are 11 going to attempt to expedite this proceeding, that you only 12 answer the question that is asked.
Otherwise, I have D]
/'
13 concerns that this proceeding-ic going to continue 11 4 significantly longer unan otherwise would be necessary.
15 Now, Mr. Weismantle, it is correct isn't it that 16 the order to evacuate was given at 10:24 a.m.?
17 A
(Witness Weismantle)
That is when it was 18 broadcast to the public, yes.
19 0
I take it you still have a copy of the partial i
20 decision before you?
21 A
'I have got some of the pages from it, yes.
22 Q
Do you have page 725?
23 A
Yes, I do.
E 24 0
Do you have page 723?
25 A
Yes.
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Now,-yesterday you were concerned,.were you not' 2
that the 60 minute estimate was not a holding of the PID, 3
but was rather just contained within LILCO's estimates, 4
which you say were set out in the PID.
5 A.
Well, 60 minute average simply was the data LILCO 6
presented that was not refuted at the previous hearing.
7 0
would you please read into the record the title 8
of the portion of the PID that begins on page 7237 9
A Conclusion on Mobilization.
10 0
Now, please turn to page 725, and in the first 11 paragraph, do you see the following sentences:
Clearly-12 workers must be briefed and issued equipment.
LILCO's
{}
13 estimate of 15 minutes to issue dosimetry equipment, 15 14~
minutes more to issue job-specific briefings, and five to 15 ten minutes to dispatch workers is reasonable.
16 Do you see that statement?
17 A
Yes, you are reading correctly.
18 0
Yesterday we agreed, did we not, that the 15
.19 minutes to distribute dosimetry under the LILCO Plan is to 20 be done before an order to evacuate is given?
21 A
If at all possible it is to be done before an 22 order is given.
23 0
I think we agree on this, but just to make sure, 24 that is the plan assumption, isn't that a fair statement, 25 Mr. Weismantle?
Would you like to review the plan?
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"1 A
No. - As we dis' cussed yesterday, depending on the-
-2 speed of the accidenti it'is possible to-do that.
3 It-is obviously a goal, but-it is out of your 4
control insofar as the accident might proceed'at a pace that 5-would prevent that'from happening.
l 6
JUDGE FRYE:
But the question is: -The plan 7
contemplates'that if.possible, it would happen that way.
8-WITNESS WEISMANTLE:
Yes.
l it JUDGE FRYE:
Okay.
10 BY MR. SUTKO:
(Continuing)-
11 Q
Now, the other two times that are-referred there, 12 15 minutesLto issue job-specific briefings and five to ten L{
minutes to dispatch as being reasonable, those are.two that' 13 14
~ occur after an order to evacuate is given, isn't that a fair l'
-15 sta'tement?
16 A
(Witness Weismantle)
Yes, under the plan as it 17 existed the day of the exercise.
-18 Q
So, the plan, therefore, concludes that 19 approximately 28 or 25 minutes after an order to evacuate is 20 given, dispatch should be completed, isn't that correct?-
21 A
Not for all traffic guides, no.
These are simply 22 times it would take for an individual guide to go through 23 that procedure, but briefings are done in groups.
4 24 O
So you think that a fairer time would be that we 25 should talk about 20 to 25 minutes after an order is given ACE FEDERAL REPORTERS, INC.
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tci a staging. area to deploy its people into the field, isn't 2
.that correct,.Mr.~Weismantle?
3 A
No.
Again, you are taking individual timess that 4
apply to an individual' traffic guide, and drawing a 5
conclusion about all traffic guides.
That is not right.
6 These people are briefed in groups, and it takes some time 7
for the sequence to go through, and all of the traffic 3
guides to get out.
9 And it depends on the number of traffic guides 10 that need to be mobilized, for instance, which depends on-11 the particular type of action recommendation.
12 O
Mr. Weismantle, I would like for you to show this
('}
13 Board where in the sentences we-have discussed it states 14 that it is talking about specific traffic guides.
15 In fact, doesn't it say, Mr. Weismantle, that it 16 is LILCO's estimates of the time it would take LILCO to 17 dispatch?
18 MR. ZEUGIN:
Judge Frye, I will object to the 19 question, I guess, because it is vague.
I am not really 20 sure what we are trying to accomplish with this.
The PID 21 says what it says.
It says LILCO's estimate, and I think as 22 Mr. Weismantle answered at the start of Contention 41 that 23 he represents LILCO.
24 So, I think he merely is interpreting the 25 statement as he understands it.
I don't see what we are ACE. FEDERAL REPORTERS, INC.
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1 accomplishing by this question.
2 JUDGE FRYE:
We can certainly read the initial
~
3
. decision.
4
-BY MR. SUTKO:
(Continuing) 5 0
Mr. Weismantle, I am going to hand to you what I 6
believe is to be marked as Suffolk County Exhibit 23, and it 7
will be three documents, which we will mark as 23-A, 23-B, 8
and 23-C.
9 (Above referenced documents are marked 10 Suffolk County Exercise Exhibits.23-A',
11 23-B, and 23-C, for identification.)
12 With the Board's permission, while the witnesses
' ("') -
-13 are reviewing these documents, I would-like to put a chart s-14 on the easel.
15 JUDGE FRYE:
All right.
16 BY MR. SUTKO:
(Continuing) 17 0
Mr. Weismantle, do you see a document pertaining 18 to an order to deploy or dispatch at the Riverhead staging 19 area?
.20 A
(Witness Weismantle)
Yes.
21 O
We are going to mark this as Exhibit 23-A, Judge 22 Frye.
Mr. Weismantle, does this document state that it is 23 from the traffic control point coordinator at the EOC to the 24 lead traffic guide at the Riverhead staging area?
r~s 25 A
Yes.
U ACE-FEDERAL REPORTERS, INC.
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'And doeg-it instrtl t the lead traffic ~ guide.that 2-2ones A through.M,:plus Q\\and'R, are to'be eva'cuated,'and' Y
1 s
- t
- -
3 then there'is an exclamationDpdint?
t y
14.
A
.Yes.
jg 'Q, v {
i b.
\\ s.
5 Of Is there.a time on'this document,'Mr.'Weismantie?
t 6'
'A.
The: document indicates it was transmitted at
' 7.
10:25.
7, t s.
1
\\
^g 8
0
'And that is reflected: in' the first : box'.on Q'fe'
- W3 l
90 chart that'we are using?
/"
4 s t
-x c
5;.
10 A
Yeah.
The time <is reflected there.
Whe ther '.
7 1,.
11 there might-have-been a previous verbal message that'wasn't t
.!~
12'
-recorded, or that disconfirmed, I.am not sure.
13 Q
Do' you have any basis' for your reason' to ithirik
.14L there would have been a verbal message?
i-
~15 A
I don't'knowS It is possiblA,f I am just e
\\'
\\
16 pointing that out.
J 17 MR. PIRFO:
Judge Frye, I hate to interrupt, but g
can we get these all identified at one; spot in the record as 18 f
19 opposed to going through y-t 20 JUDGE FRYE I think it would be a good idea.
t 4
21 Riverhead is 23-A, the one at Port Jefferson is --
f i
't t
,j' 22 MR. SUTKO:
23-B, yes, Judge Frye,kand the onc
'N i
23 for Patchogue would be 23-C.
I will stipulace for;the
]
% 3 24 record that the next two times on this document -- Qa the t.
25-chart that we are using -- what are 10: 25, dispatch.begins'-
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at Riverhead, and 11:00 is finished for Riverhead, are times
' a
'1
.n s
~
v2
-~ dmitted by LILCO.
a
[-
'3 JUDGE'FRYE:
That you previously put into the o
"Jb I
ll4 recard.
j
.I s
5 MR. SUTKO:
That is correct, Judge Frye.
+
3 A6 g BY MR. SUTKO:
(Continuing)'
s' 3 ' \\h y
s3 W 3
-7 0
Mr..Woismantle, for the Riverhead staging area, p
x 8
is my math on the chart correct?
It took 35 minutes from 1(
t 9
the order to deploy until dispatch was completed?
5 Y
't 10J' A
(Witness Weismantle)
Yes.
'\\ g
" 0, WouldYoupleasenowlookatthedocumentwhich' 12 is-marked 23-B7 Is it correct that that document is from 13
{}
the transportation' control point coordinator at the EOC to 14 the lead, traffic guide at Port Jefferson staging area?
15 A
I think it is traffic control point coordinator.
(%s,16 N
0 And then you would agree it is_to the lead l>
I 17 traffic guide at the Port' Jefferson staging area?
y r^
h.
l{\\
(
Y.
18 A
Yes.
t, a..
y..
19 O
Does that message state Zones A through M, plus 0 t
20 and R are to be eya,cuated?
21 A
Ybp.
x 22 O
What is the time on this document, t
23 Mr. Weismantle?
24 A
10:13.
25 0
Actual,1y, isn't it 10:43, I think?
(J s
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A It looks like the 1 is much mace distinct.
\\ +
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2
-JUDGE FRYE: -It appears to be 10:13'on my copy.
b "O
3 I,I[q MR. PIRFO:
Well, if we are voting, mine looks 4
like 10:13 also.
5 BY MR..SUTKO:
(Continuing) 6)
O Mr. Weismantle, you would not~have dispatched 3
7 traffic guides before in order'to evacuate on the day of the l
- n i
[-
8.
exercise, isn't that correct?.
I lU,{
'9 A
(Witness Weismantle)
I don't dispatch traffic j
'10 guides, but it is perfectly conceivable, as I testified --
11 well, it is perfectly conceivable this was.10:13.
12 As I testified the other day, at 10:10 the j
1
- {v"y 13 decision was made to evacuate, and I immedinately within a 14 minute or so announced it to the EOC, and told people to 15 start implementing their procedures.
f:
16 0
So you are unsure whether this is 10:13 or 10:437 f
17 A
It certainly looks like 10:13 from the copy of l
18 the message I got.
19 0
And you think that is a reasonable possibility, 1
20 is that correct?
21 A
I think that is a probability.
22 JUDGE PARIS:
Can I ask a question.
23 Mr. Weismantle, what time did you say you announced in the 24 EOC?
25 UITNESS WEISMANTLE:
Probably about 10:11.
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JUDGE PARIS: "Did the traffic' control point.
2
. coordinator know in advance which zones were going to be 3
evacuated?
4 WITNESS WEISMANTLE: 'Not the exact zones.
I 5
- think'he had'an' idea the evacuation' decision was being
{
6
' discussed.. We had already at 9:37 ordered the pre-staging
.ll l
7 of bus'es'for Zones A through G, which is basically as I l
8 recall a'two' mile semi-circle,and a key-hole downwind for.
9
'five miles.
10 He wouldn't have known the exact' zones thought, 11
.certainly, until I announced it.
12 JUDGE PARIS:
Well, would he have to know the t
13 exact zones before he selected all thoe traffic control
.14 points?.
~15' WITNESS WEISMANTLE:
Yeah.
Yes, he would.
16-JUDGE-PARIS:
Is it reasonable to believe that he I
17 in two minutes could determine -- write down that many?
18 WITNESS WEISMANTLE:
No, that is probably 19 stretching it a little, but you have to remember peoples 20 watches weren't synchronized.
We can only go by the times l
21 on an individual document, and recognize it is an 22 approximation; compare it to other times.
23 JUDGE SHON:
Yes, but his watch was synchronized 24-with his own watch, and he put the time on each of these 25 three documents, did he not?
It just seems much more ACE-FEDERAL REPORTERS, INC.
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reasonable that he would have -- what this says is that he 2
did Port Jefferson last, and got to it at 10:43..That is 3
taking a few minutes to do each one of them.
4 One at 10:25, one at 10:43, one at 10:30.
You 5
know, it took him ten minutes to do each one, or something.
6 WITNESS WEISMANTLE:
Well, we-just'can't be 7
sure.
All I can say is from the document I have, it does 8
appear as.though the 4 is overriden by a 1.
,9 There may be another document out there at_the 10 staging area that would indicate when they received the 11 message.
That is probably the only way we could attempt to 12 verify it.
(~%
13 JUDGE PARIS:
All of these, he had difficulty LJ 14 with the month, too.
January.
15 WITNESS WEISMANTLE:
Yes.
16 BY MR. SUTKO:
(Continuing) 17 Q
Mr. Weismantle, for now let's assume that it is 18 10:43, and then we will go back and recalculate it as though 19 it were 10:13.
So, the order to deploy at the Port 20 Jefferson staging area occurred, if you assume at 10:43, 21 LILCO has admitted that dispatch at Port Jefferson began at 22 10:50 and that dispatch was finished at 12:20, and therefore 23 my math on my chart is correct, isn't it, that if the order 24 to dispatch or to deploy occurred at 10:43, that is an hour r~'g 25 and thirty-seven minutes before 12:20, when dispatch was
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-finished?:
2
'A Your:-math _ is correct, given those. assumptions.-
3' O
Now, Mr. Weismantle let's look at it as.though.it 4
were 10:13. tit would be correctnthat the time ~it took at 5'
-Port 1 Jefferson from an order to deploy until dispatch ^was 6
finished, approximately two hours and-seven-minutes, isn't-7-
that correct?-
8 A
That is correct.
19 0
'Mr.-Weismantle, will you now please'look at the 10 document which has been marked as Exhibit 23-C', and I ask 11 you if you can identify that document?
12 A
Yes.
~
13 0'
Who is it from, and who is it to, Mr. Weismantle?
- w 14 A
The traffic control point coordinator to the lead 15 traffic guide at-Patchogue.
16 0
Okay.
And does that document also state Zones A i
17
.through M, plus 0, R are to be evacuated?
18 A
Yes.
4 k
19 0
And what is the time of that document, 20-Mr. Weismantle?
21 A
It appears to be 10:30.
c 22 0
Therefore, if the order to deploy began -- or l
23 came into Patchogue at 10:30, LILCO's admitted dispatch 24 began at 10:30, and dispatch at Patchogue was finished at 25 10:59, it took 29 minutes, isn't that correct,,from the ace FEDERAL REPORTERS, INC.
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order to dispatch.until dispatch was finished at the 2
Patchogue staging area?
3 A
Yes.
.4 0
Now, Mr. Weismantle,' assuming that the order to 5
deploy at Port Jefferson came in at 10:43-a.m., the average 6
time for the three staging areas to dispatch -- from the' 7
order to deploy until dispatch was finished, would:have been 8
roughly 53Lminutes, isn't that correct?
9 A
Well, what I think you have done is simply give 10 equal weight to each --
'f 11 0
Well, now, Mr. Weismantle, your counsel will have 12 an --
(~
13 A
Can I finish?
V}
14 0
Mr. Weismantle, your counsel will have an 15 opportunity to engage in redirect of.your testimony.
My 16' question to you is very narrow, and I would appreciate a 17 response.
18 MR. ZEUGIN:
Well, I think, Judge Frye, I would 19 like clarification.
I don't know if Mr. Sutko is asking 20 Mr. Weismantle to simply verify his mathematics; on the 21 other hand, agree with his formulation of an average.
22 I think Mr. Weismantle is trying to address the 23 latter point.
If Mr. Sutko simply wants verification of his 24 mathematics, Mr. Weismantle can do that.
-(N 25 JUDGE FRYE:
Mr. Weismantle, I take it you d
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'l-believe that the 53 minutes and the 64-minutes is an
.2' averaging of those figures?
3, WITNESS WEISMANTLE:: It is an averaging-of the
'4 times indicated.
5 BY MR.-SUTKO:
(Continuing) 6 Q.
And the 64 minutesd would be an average-for the 7'
three staging areas if the order to deploy at Port Jefferson 8
occurred at 10.13, is that correct?
9
-A (Witness Weismantle)
That is right.
10 11 12 13 14 15 16 17
.18 19 20 21 22 23 24 O
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Q Mr. Weismantle, would you-please turn to Page 6 2
of your testimony?- And, we are now going to focus on the 3-time it took the traffic guides to get to their stations in 4-the field rather than the time it took to dispatch traffic 5-guides.
6 Now, Mr. Weismantle, do you see the statement in 7
the answer to Question 7 that, "LILCO presented data 8-gathered during earlier drills on the time.necessary to 9
complete the mobilization process.
See PID at 719.
Based 10 upon these data, the Board held that LILCO could 11 substantially complete its mobilization in about three 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
PID at 723."
(~}
13 Do you see that statement?
v 14 A
(Witness Weismantle)
Yes.
15 O
Do you agree with that statement, Mr. Weismantle?
16 A
Yes, I elo.
17 O
Okay.
Now, I take it that previously in your 18 testimony there was a sentence following that statement 19 which you have now withdrawn from your testimony, is that 20 correct?
21 A
That's correct.
22 0
Mr. Weismantle, do you have an understanding of 23 how the PID defines mobilization?
24 (The witness is looking at a document.)
25 A
I think on Page 716 they define it in
~
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Paragraph'4.B.1.
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2.
0 And, what is your. understanding of that 3'
definition?
4-
'A I think it's self-explanatory when one reads it'.
~
5 Q
For'the benefit of those --
6 JUDGE FRYE:.For.the benefit:of the Board since-
-7 we don't have --
8 WITNESS'WEISMANTLE:
Oh, I'm sorry.
9 JUDGE FRYE:
-- that, wouldLyou read'that?-
10
. WITNESS WEISMANTLE:
I'm sorry.
Okay.
11-Mobilization is defined as the activities'that'take place 12 between the determination that particular off-site emergency
_tG 13 response _ personnel should be notified and the reporting of q,)
14' such personnel with necessary equipment to the locations 15 where emergency functions will be performed.
16-BY MR. SUTKO:
(Continuing) 17 0
And, I believe we have previously discussed that 18 on February 13 traffic guides, to use the PID's words, 19 should have been notified at the declaration of a site area 20 emergency; isn't that correct?
21 A
(Witness Weismantle)
No.
I can't agree that 22 anybody could reasonably expect a notification to traf fic 23 guides simultaneous with the decision in the EOF to declare 24 a site area emergency.
25 0
But, that's the triggering event; isn't that ACE FEDERAL REPORTERS, INC.
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correct?
2 A
That --
3 JUDGE FRYE:
It's what?
4 MR. SUTKO:
The triggering event.
5 WITNESS WEISMANTLE:
That triggers the 6
notification to the EOC which then triggers the setting off 7
of the pagers which triggers the call-out.
8 BY MR. SUTKO:
(Continuing) 9 0
Do you know when the EOC declared a site area 10 emergency on the day of the exercise?
11 A
The EOC doesn't declare a site area emergency.
12 That's declared at the EOF by the LILCO emergency response 13 organization.
14 0
Do you know when it was announced at the EOC, 15 Mr. Weismantle?
16 A
Well, at 8 -- I'm not sure when it was announced 17 or what you mean by announced, but at 8:24 a RECS message --
18 COURT REPORTER:
Excuse ma, Mr. Weismantle, what 19 message?
20 WITNESS WEISMANTLE:
RECS, Radiological Emergency 21 Communications System, message started to be transmitted to 22 the EOC and to the other points on the RECS system.
23 BY MR. SUTKO:
(Continuing) 24 0
Mr. Weismantle, what is your understanding based
(;
25 upon the definition of mobilization in the PID as to when N
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1 mobilizations-for traffic guides would be completed?
2 A.
When they are at their locations in the field, at 3
their traffic posts or traffic control points.
4 0
And, it's your-testimony on Page 6 that that 5
should have been substantially completed in three hours; is 6
that correct?
7 A
I'm quoting from the PID on Page 6.
8 0
But you agree with that conclusion?
9 A
I agree with that statement, that it could be 10 substantially complete in about three hours.
11 0
Okay.
Do you have a copy of the FEMA report, 12 Mr. Weismantle?
r 13 A
The post-exercise assessment?
-d"x 14 0
That's correct.
15 A
Is that what you are talking about?
16 0
That's what I'm talking about.
17 A
I believe so.
18 0
Would you please look at Page 25?
Do you see 19 there a table which is marked Table 1.1 and which is l
20 entitled " Emergency Classification Time Line?"
f l
21 A
Yes.
t 22 0
And, do you see an emergency classification 23 titled " Site Area Emergency Notification?"
24 A
Yes.
l l
25 0
Do you see another heading which is entitled l
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2 A' ~
Yes.
'3~
Q' And, isn't it FEMA'sEconclusion on Page 25 that!
J'
'4.
the LERO EOC1 received notification of a' site area emergency.
5 at 8:24?'
- 6 A'
.That's_ correct.
l 7-Q Okay'.
8 A.
-I think-though you have to look at the. footnote i
9
_ where it says times that events were observed at each-
~
10
-location to interpret these times.
11 Q
So, it's your testimony that --
I'm sorry, 12 Mr. Weismantle.
J 13~
A To interpret these times.
I simply note that
}
14-because that's what the footnote says, and that~ footnote f
15 covers all the times on the table.
16 Q
So, actually it.could have occurred prior to 17 8:24; is that correct?
r 18 A
One could say the footnote allows it but 6
19 certainly doesn't imply it in this case.
l' 1
20 Q
Now, Mr. Weismantle, I believe that you have I
21 three attachments to your testimony which are Attachments B, i
l.
22 C and D which set out the mobilization times for the 23 Patchogue, Port Jefferson and Riverhead staging areas as far l
24 as you have data for those staging areas; is that correct?
E 25 A
Yeah.
They are entitled " Mobilization Time" but
)
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'what they set forth is actually the time that the individual-traffic guides-called in to report their arrival at their 3
traffic control points.
4 0
And, that is your best estimate as to when they-
-5 arrived at the traffic control points;-isn't.that correct?
6 A
That's our best estimate.-
It assumes they called 7
in promptly.
8 0
And, in fact, that's what the plan and procedures 9
say, doesn't it?
10
-A Yes..
They are asked to call in as soon as they.
11 arrive.
12 0
And, you have no reason to think they deviated 13 from the plan and procedures on the day of the exercise; 14 isn't that correct?
15 A'
No, I have no evidence that they deviated.
16 0
Now, each of these attachments has three columns; 17 is that correct?
18 A
That's correct.
19 0
The first column is entitled "TCP" and I take it 20 that stands for traffic control post or point; is that 21-correct?
22 A
That's correct.
23 0
And, then you list each traffic control post for 24 that particular staging area; is that correct?
25 A
That's right.
,q
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0 And the next column is number of traffic guides, 2
and that's the number of traffic guides,.I take it, that on 3
the day of'the exercise staffed this particular traffic 4
control point; is that correct?
l 5
A That's correct.
{
6 0
And, then the last column is entitled " Time 7
Called In To Report Arrival at TCP."
Is that correct?
l 8
A That's correct for B and C.
Attachment B is a l
9 little bit different.
10 0
Okay.
And, you had'some problems with your data 11-at Riverhead; isn't that correct?
l 12 A
Well, as the testimony indicates, certain data p
13 was lost and has not been able to be found.
v 14 0
And --
15 A
So, what we did was try to indicate in Attachment-16 B the data that existed for when specific TCP assignments
(
17 were mader and, to the extent we had it from other sources, 18 the data or the approximate time the traffic guide -- in 19 seven specific instances indicated he had reported to his 20 traffic control post.
l 21 JUDGE PARIS:
Mr. Weismantle, were the data lost t
22 or were they simply not observed?
23 The footnote on this attachment seems to suggest 24 the observations simply were not made.
25 WITNESS WEISMANTLE:
Can you point me to the ACE-l#EDERAL REPORTERS, INC.
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[ ; 1-W/sw I l footnote?
Is.it the-two asterisks?
i 2
JUDGE PARIS:
The three asterisks. 'The actual 3
< reporting times were not observed, it says.
l
'4 WITNESS WEISMANTLE:
Okay. ~What that is 5
' referring to was the fact that this LILCO field observer-
}-
6 went.to the-field the. day of the exercise, while the traffic _
L 7
guides were still there, and asked them what time they 8
reported.
He wasn't actually there when they reported.
9 That's the only data we have.
The data that is-j.
10 missing that we know was recorded, but the data sheets are-11 missing for Riverhead, was the radio man's data in-the 12 Riverhead staging area as to when they called back.
l
} -
13 JUDGE PARIS:
They did call in but those data 14 were lost?
15 WITNESS WEISMANTLE:
That's right.
i 16 JUDGE PARIS:
All right.
17 WITNESS WEISMANTLE:
People observed them calling 18 in, filling out the sheet.
But, the sheet was lost some l
19 time between the end of the exercise -- or after the end of l
20 the exorcise.
21 BY MR. SUTKO:
(Continuing) 22 0
Now, so the record is clear, Mr. Weismantle, you 23 list 38 traffic control posts for the Riverhead staging r
l' 24 area; is that correct?
l l
25 A
Yes.
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0 Now, in fact there are 44 traffic control posts 2
for Riverhead; isn't that correct?
3 A
I think the difference is -- let me refer back to l
4 my testimony.
l l
5 (The witness is looking at a document.)
l 6
The difference is that what is listed in 7
Attachment B are simply the reporting times for the first 8
wave of traffic guides; that is, all those necessary for the 9
A through M and 0 and R evacuation.
10 JUDGE FRYE:
Are there 44 traffic control posts?
11 WITNESS WEISMANTLE:
I believe so, subject to a 12 quick check.
}
(The witness is looking at a document.)
13 14 BY MR. SUTKO:
(Continuing) 15 0
I'm not quite sure I understand your explanation, 16 Mr. Weismantle.
Why are there six that are not --
17 JUDGE FRYE:
Let him check.
18 WITNESS LIEBERMAN:
There are a total of 44 19 assigned in the event the entire EPZ is evacuated.
20 JUDGE FRYE To Riverhead?
l
[
21 WITNESS LIEBERMAN:
Assigned to Riverhead, yes.
I 22 JUDGE FRYE:
Okay.
23 BY MR. SUTKO:
(Continuing) 24 0
Mr. Weismantle, I would like to show you what is
(^)
25 going to be marked as Suffolk County Exhibit 24, which may
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shed some light on-this issue. ' I'first ask you to identify.
2 what this document is, who is it sent from, and who.is it 3
addressed to?
4 A
(Witness Weismantle)
It's a LERO message form 5
'sent from the Traffic Control Point Coordinator in the EOC 6
to the Lead Traffic Guide in Riverhead.
1 7
(The document referred to is marked as 8
Suf folk County Exercise Exhibit Number 9
24 for identification.)
10 BY MR. SUTRO:
(Continuing) 11 0
What is the time of that message?
12 A
It appears to be 12 noon.
[~)
13 0
What is the substance of that message?
N-14 A
It asks the Riverhead staging area to dispatch 15 the remaining six traffic guides because N, O, P and S --
16 Zones N, O, P and S -- ar,e to be evacuated in addition to 17 the first zones.
i 18 0
Okay.
So, I take it that the 10:25 order to 19 Riverhead to dispatch guides asked that only 38 traffic 20 guides be dispatched; is that correct?
21 A
I believe that's correct.
22 0
And, then later a decision was made to dispatch 23 six additional guides?
24 A
As a consequence of the change in protective 25 action or modification in the protective action to evacuate ACE FEDERAL REPORTERS, INC.
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2 0
Could you please explain what you mean-by that?
3 A
Well, our initial protective action 4
recommendation which was reached at 10:10 was to evacuate
\\
l 5
Zones A'through M, O and R.
That left.the four zones not-to i
1 6
be evacuated.
7 At 11:46, as a result of changing conditions, the
.8 decision was made to evacuate the full 10 miles; therefore, 9
the remaining four zones were to be-evacuated, and six more 10 traffic guides were needed to fulfill the traffic strategy 11 in the plan for a full 10-mile evacuation.
l' 12 0
Perhaps Mr..Lieberman can answer this question.
)
Mr. Lieberman, do you see on this' document that there are 13 14 six traffic control posts that.are referenced?
r l
l 15 A
(Witness Lieberman) 'Would you identify the i
16 document, please?
j 17 0
Suffolk County Exhibit 24.
l 18 A
Yes.
I see the six.
I 19 0
What are they?
20 A
20, 21, 22, 23, 25 and 112.
21 0
can you determine whether or not those would have 22 been guides which would not have been in areas on your 23 traffic control map that would have been needed for the 24 initial evacuation of Zones A through M, O and R?
25 A
Well, it would take me some time.
But, in the ace FEDERAL REPORTERS, INC.
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.OPIP these are.the -- according to the OPIP, these are.the 2
correct _six to be added.
In other words, they are-those 3
which are in-the O to 10 mile evacuation minus those which 4
were dispatched earlier for the regions which were 5
originally to be evacuated.
6 0
Now, Mr. Lieberman, the six traffic control posts 7
which are referenced in Suffolk County Exhibit'24, which are 8
20, 21, 22, 23, 25 and 112, do you see any of those guides 9
in Attachment D to your testimony?
10 A
No, those guides were not included:in this 11 listing.
12 0
Was that a conscious decision, Mr. Lieberman?
13 A
It wasn't a conscious decision of mine, no.
)
14 0
Mr. Weismantle, perhaps you -- can you shed some 15 light as to why these six were not included?
'16 A
(Witness Weismantle)
I think -- I have to look 17 at the exact places referenced in our testimony.
But, I 18 think that the clear issue is the mobilization and whether 19 or not the initial evacuation proceeded under controlled 20 conditions.
21 That was, you know, something like 95 percent of 22 the full EPZ.
As you can see by the numbers, 97 percent of 23 the traffic guides and so forth.
24 0
Just to make sure that I understand, you just 25 don't believe that these are necessarily relevant to your ACE FEDERAL REPORTERS, INC.
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testimony,~is.that a fair statement?
()
2 A
Not particularly relevant, no.
3 JUDGE PARIS:
I-didn't understand your 4
explanation lof that.
5 WITNESS WEISMANTLE:
Okay.
6
?4DGE PARIS:
Would you run through it again'in 7
different words?
8 WITNESS WEISMANTLE:
Okay.
Our-testimony focuses 9
on whether or not the controlled evacuation time would be 10 achieved, and if it can't be achieved what the deviation is 11 based on the initial protective action recommendations of A 12 through M, O and R.
That constituted the vast majority of.
] }.
13 the people who live in the zones, the zones that comprise 14 the 10-mile area.
And, it constituted the manning of 159 15 out of 165 of the traffic control points.
16 In essence, that's what we believe the issue of 17 this particular contention is.
And, that's'what we address, 18 the manning of the posts as a result of the initial 19 protective action recommendation.
20 WITNESS LIEBERMAN:
Perhaps I can --
21 JUDGE PARIS:
All right, go ahead.
22 WITNESS LIEBERMAN:
If I may, I think the term 23
" controlled evacuation" should be defined.
24 JUDGE PARIS:
Yes, I would appreciate that.
25 WITNESS LIEBERMAN:
We conducted two sets of p\\_/
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. studies for the original: litigation.
The first set was 2
based upon the assumption that all the traffic 1 guides and.
3-
.particularly those which were critical to preserving or to-4 minimizing the evacuation times were deployed at=the time i..
5_
that congestion arose within the EPZ.
6 That set of times, the ETEs, we have labeled 7
controlled evacuation.
That is, as the evacuation scenario 8
that takes place with the traffic guides controlling 9
' traffic.
10 We also conducted a second series of studies to 11
' determine what the effects would be if none of the' traffic 12 guides were out.
And, the reason we did that is because on
)
13 a very fast' escalating accident, we acknowledge it would be l
14 impossible to get many traffic guides out there by the time 15 the order to evacuate was given.
i 16 And, therefore, to provide a basis for 17 decision-making, it is necessary to predict what the 18 evacuation times would be under that set of circumstances.
f 19 And, the difference between the two sets of times for those i
20 studies is approximately an hour and a half; that is,
[
21 without traffic guidos available, particularly at what we 22 call critical TCPs, the evacuation time would be extended 23 from roughly five hours to about six hours and 30 minutes.
24 JUDGE PARIS:
That's the total evacuation time?
()
25 WITNESS LIEBERMAN:
That's the total evacuation ACE FEDERAL REPORTERS, INC.
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. time, g'iven.that the. entire EPZ were ordered'to evacuate.'-
2 I might add, justLto-complete the picture,:we had
- 3 also conducted other~ sensitivity tests to. examine.what would 4.
- happen if people departed from their recommended' routes and 5
'took oth'er routes.
We call this the comparison between 6
compliance-and non-compliance.
7 And, we ran actually two of those. 'We ran 25 8
percent.non-compliance and 50 percent non-compliance.
That-9 means that 50 percent of the people would select routes 10-other than those which were recommended to them.but.which:
11 were overall. sensible.
By sensible, I mean that in general 12 they would' move away from their points of origin towards the
().
EP2 boundary in'a direction away from the Shoreham Station
'13 14 but not along the recommended routes.
15 The results of those studies indicated that at 16 the 25 percent level, there was no significant difference 17 between the controlled evacuation under those circumstances 18 with compliance and the controlled evacution with 25 percent 19 non-ccmpliance.
20 With the 50 percent non-compliance case, the 21 difference, as I recall, is about a half hour longer.
- And, 22 what it shows is a relative insensitivity to non-compliance, 23 given that it's moderate.
24 It also demonstrates that the recommended routes
()
25 were not bettered by another selection of routing.
I hope
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that explains what you wanted.
2 JUDGE PARIS:
Yes, it does.
Thank you.
3 Mr. Weismantle, one question I would like to ask you.
Why 4
were Zones N, O, P and S ordered to evacuate at 12 o' clock?
5 Or -- yeah, is that right?
6 WITNESS WEISMANTLE:
About 11:46 the --
7 JUDGE PARIS:
Okay.
8 WITNESS WEISMANTLE:
-- decision was reached.
We 9
-- I believe that -- and I would have to refer to testimony 10
'that we haven't yet presented -- as a result of predictions 11 of wind shift later in the day and a long term release that 12 that decision was made.
()
13 JUDGE PARIS:
Okay.
Thank you.
14 JUDGE FRYE:
Are you moving to a new topic now, 15 Mr. Sutko?
Or is this --
16 MR. SUTKO This is a very convenient place to 17 break, Judge Frye.
But before the break --
18 JUDGE FRYE:
All right.
We will take a 15 minute 19 break, then.
20 MR. SUTKO With this Board's permission, before 21 the break, I would like to move that Suffolk County Exhibits 22 23-A, B, C, D and 24 be moved into evidence?
23 JUDGE FRYE Any objections?
24 MR. Z EU' I have no objections to A, B, C and
()
25 24.
I don't think we stave a 23-D, or else I haven't seen 26 ACE FEDERAL REPORTERS, INC.
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it.
l 1
- W
. R. SUTKO:
'I will withdraw the motion to --
2 M
3 JUDGE FRYE:
You will withdraw 23-D?
4
'MR. SUTKO:
Yes, sir.
I' 5
(Laughter.)
6 JUDGE FRYE So ordered.
7 (The documents previously marked as 8
Suffolk County Exercise Exhibit Numbers 9
23 A, B and C and 24 for identifica-10 tion are admitted into evidence.)
11 JUDGE FRYE:
Okay.
12 (Whereupon, a recess is taken at 10:30 a.m.,
to i
' ('s,
(/
13 reconvene at 10:45 a.m.,
this same day.)
14 l
l 15 16 l
17 18 19 l
20 l
21 l
22 23 24
()
25
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2 JUDGE FRYE Let's go back on the. record, 3
please.
4 BY MR. SUTKO:
(Continuing) 5 0
Mr. Weismantle, together we are going to put up a 6
chart.-
I am going to ask your help with this one.. What we 7-are going to do, Mr. Weismantle, is we are going to look at 8
how many traffic guides according to LILCO's own figures 9
were in the field three hours after a site area emergency l
10 was made known at the EOC.
And that was according to the l
11 FEMA Report, that was made known at 8:24, so we are going to 12 be talking about how many guides you had in the field at
()
13 11:24 a.m.,
three hours later.
14 What I would like you to do is please go to 15 Exhibit B to your testimony.
16 A
(Witness Weismantle)
I assume you mean 17 Attachment B?
18 0
That is fine.
Which staging area is that for, 19 Mr. Weismantle?
20 A
Patchogue.
21 0
And what is the total number of traffic control 22 posts to come out of Patchogue?
23 A
Twenty-eight.
24 0
Now, what I am going to ask you to do is to look
()
25 at it and tell me, isn't it correct at 11:24 a.m.,
ten of ACE. FEDERAL REPORTERS, INC.
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those 28 TCPs have reported in as having been manned?
2 It is a simple question.
As soon as you have an 3
answer, let me know.
4 A
I can't really say precisely, because it Is 5
obvious that these times are rounded off to the nearest'five 6
minutes.
7 O
That is fine.
My question is simply to look at 8
your view chart, and if you can't do that, then we will just 9
assume, therefore, that it is 10.
10 And what I am asking you now -- if it is.10, 11 then the percentage --
12 MR. ZEUGIN:
Judge Frye, it may be easier if
()
13 Mr. Weismantle just has a chance to answer the question, l
14 rather than just go on and assume a number and proceed on l
l' 15 with the chart.
16 JUDGE FRYE We can count them.
l 17 MR. SUTKO:
The attachment will speak for itself,
[
18 I think.
i 19 JUDGE FRYE:
I think it will.
It has been 20 introduced.
21 BY MR. SUTKO (Con t i ".u ing )
22 0
And I take it, then the percentage is 36 percent, 23 if you divided 10 by 28.
Maybe Mr. Lieberman --
24 A
(Witness Weismantle) 10 by 28 is about 36 25 ACE FEDERAL REPORTERS, INC.
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percent, yes.
7 0
What is_the next attachment in your testimony, 3
Mr. Weismantle?
E 4
A C.
5 0
And what does that talk about?
6 A
Port Jefferson times.
7 0
Okay.
Now, is it correct that there are 58 8
traffic control posts to come out of Port Jefferson?
9 A
That is right.
10 0
I take it then as of 11:24, which is an hour 11 after tbs order to evacuate, three hours after the site 12 area emergency was declared, you had zero in the field?
-(O.)
13 A
Well, the site area emergency wasn't declared at 14 8:24.
As I said before, it was declared earlier.
15 0
I will change my statement.
16 A
If I can answer your question.
There would 17 appear to be no traffic guides from Port Jefferson that 18 called in at 11:24 -- by 11:24, 19 O
As they were supposed to do immediately upon 20 getting to the field, according to the LILCO plan.
21 MR. PIRFO:
Is that a question?
22 MR. SUTKO:
Yes, it is.
23 WITNESS WEISMANTLE:
As I testified earlier, the 24 plan asks them to call in promptly upon getting to their
()
25 control points.
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1 O
Now, would you please-look at Attacfmen,t V
'2 your, testimony, Mr. Weismantle?
j t
3
~ A (Witness Weismantle)
Yes.
4j O
And that has 38 of'the 44 traffic control posts
(
w
.5 listed, is that correct?
p4
^
6 A
That is correct.
c; 7
0 But, in fact, according to the figures LILCO 8
relied'on in th'eir testimony, there.are only 7-that you know va s -
9 times for?
.gq
[
10 A
That is the correct.
Those are the only times 1
g 11 documented.
(
And of those 7 that you ha,ve ti3nes for,-is it 12 0
o i
ij 13 fair to say that either one or two, you are n6t,really s
14 certain, was manned as.of 11:24?
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\\
s t.
.15 A
That is correct.
16 0
Well, we will give you the benefit of the doubt 17 for purposes of cross examination.
We will call it two.
s 18 And that is roughly 29 percent of the known guides \\at /
19 Riverhead were manned, is that correct?
20 A
That is right.
\\
21 0
So, what we have then are known 93 guides at t
22 11:24, 12 are manned, and that is roughly 13 percent.
23 In fact, in my calculations I didn't give you the 24 benefit of the doubt on the two, I only made it one, so it'.
O 25 is roughly 13 percent, I think, is that correct?
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I think it is a little more than 13 percent, but
.,{
2 the numbers speak for themselves.
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'3 JUDGE PARIS:
12 of 937 l
l 4
MR. SUTKO:
Ye s, s i r.
I i
l
\\
1 5
JUDGE PARIS:
Do you want me to testify?
l 6>
MR. SUTKO:
Yes, sir, i
'7 JUDGE PARIS:
I got.129.
(
I BY MR. SUTKO:
(Continuing) 8 9
0 So, that is your known arrival at traffic control 10 posts, to the best of your knowledge, an hour after the 11 public was told to evacuate, correct, Mr. Weismantle?
12 A
(Witness Weismantle)
I don't -- well, repeat 13 that question.
We don't have the times for the rest of the 14 Riverhead guides, we can't conclude what I think you 15 concluded, but maybe if you restated the question, or it was 16 read back, I will see if I agree.
17 0
Tell you what I will do, Mr. Weismantle.
I will 18 ask a different question.
19 PEMA, on the day of the exercise, observed 8 20 traffic guides at the Riverhead staging area, isn't that 21 correct?
22 A
I will have to check that, I am not sure.
23 0
Feel free.
Do you have the FEMA Report?
24 A
Yes.
lh 25 0
Mr. Weismantle, will you please turn to page 74 ace-FEDERAL REPORTERS, INC.
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of the FEMA Report, and I ask you if you note two sentences; 2
the first is 8 TCPs were observed in the Riverhead staging 3
area's jurisdiction.
Do you see that?
4 JUDGE FRYE:
Where is that?
J l'
5 MR. SUTKO:
It is in the second full paragraph, 6
Judge Frye, second sentence.
8 TPCs were observed in the l
l 7
Riverhead staging area's jurisdiction.
Do you sea that I
l 8
statement?
l 9
WITNESS WEISMANTLE:
Yes, I do.
I
~ '
10 BY MR. SUTKO:
(Continuing) 7 t
11 0
Okay.
Let's move down two sentences, I believe, 12 maybe actually three sentences, and it says, does it its
()
13 They did not arrive at' their TCP assignments between --
14 until between 11:50 and 12:10.
)
l 15 Do you see that statement?
I 16 A
fWitness Weismantle)
That is what it says.
(
17 O
And that says that was about two hours after the 18 general emergency ECL was declared, isn't that correct?
19 A
That is what it says, yes.
40 O
So, in fact, the FEMA data actually observed on 21 the day of the exercise indicates that at least eight, 22 perhaps of those other traffic guides also weren't there 23 until at least thirty minutes after the time period we have 24 just been talking about, isn't that a fair statement,
()
25 Mr. Weismantle?
ACE-FEDERAL REPORTERS, INC.
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A I don't think so.
I couldn't draw that 2
conclusion.. I don't know which traffic guides FEMA 3
observed.
It might not be eight other traffic guides.
It 4
might have been some of the seven that our people observed.
5 0
Certainl'y, FEMA numbers are as late, or later, 6
than the numbers contained in Attachment D, isn't that a 7
fair statement, and we.can sit down and average it if you 8
like?
9 A
Yes.
11:50 to 12:10 is as late or later.
10 0
So, the FEMA data tends to corroborate, does it 11 not, in general terms, the known data that LILCO has chosen 12 to put in its testimony?
()
13 A
There is some coincidence.
Our data indicate 14 that at least three traffic guides arrived before 11:50, 15 three out of the seven that we have a documentation for.
16 0
Mr. Weismantle, do you know how LILCO got it's 17 documentation?
18 A
It was by an-observer, a LILCO observer the day 19 of the exercise.
20 0
And he went out in the field, I take it, and it 21 is your testimony observed when traffic guides arrived, is 22 that correct?
i 23 A
Among other things, yes.
Again, though, he 24 wasn't there when they arrived.
The times in Attachment D t">,
(_).
25 are based on what they told him.
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O Oh.
So,'he didn't see any of these people 2
arrive, is that correct?
i 3
A That is what I testified to earlier this 4
morning.
That is what the attachment says.
5 0
Let me make sure I understand your-testimony.
He 6
went out to these gentlemen, it appears, in the early 7
afternoon and said to them:
Gentlemen, what time did you 8
get here?
9 Is that a. fair statement?
10 A
I don't know what time he got there.
As the 11 testimony says, as the footnote clearly indicates on 12 Attachment D, the actual reporting times were not observed.
)
13
.Those reported here are based on responses to questions 14 asked by the observer.
15 VOICE:
Judge Frye, I am going to instill a 16 little humor into this.
17 JUDGE FRYE:
I am sorry, we don't have time for 18 that.
We have a lot of work to do.
Suffolk County is 19 trying to present a case here that I think is probably in 20 your interest, and I think it would be in your interest to 21 let them do it.
22 VOICE:
We have a story.
23 JUDGE FRYE:
I am sorry, not now.
24 VOICE:
Can I just start reading?
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25 JUDGE FRYE:
No, you may not.
Please continue, ACE FEDERAL REPORTERS, INC.
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Mr. Sutko'.
2
- VOICE:
I will start reading it.
3-JUDGE FRYE:
You may not start rea' ding it.
~
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4
'I am'sorry, I must ask you to sit.down'and be quiet, so we 5.
may-allow Suffolk County to continue presenting their" case.
6 You are interfering with.their case.
7 VOICE:
Well,'that is one of my. purposes here.
8 JUDGE FRYE:
You.have got to give them-an 9
opportunity to'present their case.
So, I must ask you to 10 sit-down.
11 VOICE:
Well, I will' sit-down but'I will start
~
12 reading.
k 13 JUDGE FRYE:
No, you may not; read it.
14 VOICE:
Once upon'a time there lived an Emperor 15 16 JUDGE FRYE:
No, you may not read it'.
17 We are adjourned.
18 (Whereupon, a recess was taken at 11:02 p.m, to 19 reconvene at 11:04 a.m.,
this same day.)
20 JUDGE FRYE:- Can we pick up?
Sorry for the 21 interruption.
We will pick up where you left off.
22 MR. SUTKO:
Thank you, Judge Frye.
23 BY MR. SUTKO:
(Continuing) 24 O
I believe before the break we were discussing the
)-
25 difference in the types of observations --
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VOICE:
We~are totally in support of Suffolk 2
County's case, and --
3 JUDGE FRYE:
We are sorry, madam.
You are 4
interfering with their opportunity-to present it.
5 VOICE:
This should'not be going on.
It is a 6
sham, and I think it is --
7 (Individual physically ejected from the hearing 8
room.)
9 VOICE:
This is not the way to do it.
(Referring 10 to physical ejection of previous individual.)
11 JUDGE FRYE:
Mr. Sutko.
12 MR. SUTKO:
Yes, sir.
(
13 BY MR. SUTKO:
(Continuing) 14 0
Mr. Weismantle, I believe we are discussing the 15 types of observations made by various individuals of arrival 16 of trffic guides at traffic control posts on the day of the 17 exercise, and I will now like to discuss with you on that 18 issue two documents, the first document is your attachment 19 E.7 to your Contention EX 40 testimony.
If you will review 20 that document, and please explain to this Board what that 21 document consists of?
22 A
(Witness Weismantle)
What that document consists 23 of are the observer notes from a --
24 VOICE:
Just a minute, Judge.
We don't want to
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25 listen to what he is about to say.
This here has as much ACE FEDERAI. REPORTERS, INC.
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' relevance.
2 JUDGE FRYE:
I'must ask that you sit down and be~
3-
- quiet.
.4 VOICE:
The.only ones thatLcount are the; people-of this county.
Not-LILCO"'s lawyers,:not even Suffolk-6 County's lawyers.
The people:of this county don't-want'it.
7
-The~~ operation of the power plant - -
8 JUDGE FRYE:
The people of this county are trying-
-9 to present a case which_you are not letting:them do.
~
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10 VOICE:
Nothing else is relevant here.
We have-11
.already decided.
I think you should either listen'to the 12
' people or shut the hearings off.- You are not.' going to 13-silence us by' removing us.
You realize.that.
14 (Individual removed from the hearing room.)
15 JUDGE.FRYE:- Mr. Sutko?
-16 BY MR. SUTKO:
(Continuing) 17 0
I believe, Mr. Weismantle, you were reviewing a 18 document'and you were describing to this Board what that 19 document consists of?
20 A-(Witness Weismantle)
The document is an observer 21 data form that was filled out the day of the exercise by a 22 LILCO observer who was assigned to the Riverhead Staging 23 Area to accompany the FEMA observer in reviewing the traffic 24 control function there.
.h 25 0
You say this individual was a LILCO observer.
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Was he a LILCO employee?
2 A
His name is not included on the document.
To the 3
best of my recollection he was a consultant, but I can't be 4
a'100 percent sure.
5 0
Would he have been a consultant for KDL, which is 6
Mr. Lieberman's firm?
7 A
No, I don't believe we had any KDL people as 8
observers that day.
9 A
(Witness Lieberman)
Or even any KLD observers.
10 A
(Witness Weismantle)
KLD.is the correct name of 11 the firm.
12 0
I am sorry, Mr. Lieberman.
KLD observers, (1
13 Mr. Weismantle.
14 A
Yen.
15 O
There were?
16 A
No, not a KLD observer.
17 0
would you please turn to Page 3 of your 18 attachment, and there you will ate that it state's:
1.
19 What traffic control post did you observe?
And he states he 20 observed seven traffic control posts, is that correct?
21 A
That is correct.
22 0
And then under 2, it says:
At what time did 23 emergency personnel arrive at the above location or 24 locations, and there is parenthesis:
Indicate whether
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25 arrival time was observed, or if you asked them, close ACE-FEDERAL REPORTERS, INC.
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2 underlined, is that correct?
3 A
Yes.
Let me just. correct something.
He actually 4
observed eight posts.
He only got times from seven of 5
them.
6 O
Do you know why he didn't ask the' eighth?
7 A
I don't know if he did or didn't ask.
But he 8
simply -- nothing was recorded for 'the eighth post, ' Post 95.
9 0
But under his istructions, Item No.
2, he should 10 have asked or observed and reported for all eight, isn't 11 that correct?
12 A
The intent -- that is right.
I can't explain why
- t']
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13 there is nothing recorded under 2 for 95.
14 0
Is it a fair statement that all we can say is he 15~
didn't follow procedures on the day of the exercise?
16 A
There was a lot of confusion by the FEMA 17 observer, who was sent to the field to observe traffic 18 control points the day of the exercise.
19 So, what happened, evidently, was he expected the 20 traffic guides to be dispatched at an earlier point, and 21 when they didn't arrive, my recollection and my 22 understanding is he went back to the staging area to find 23 out what happened, and as a result of the timing, was not 24 able to get out to the field to observe these traffic guides
()
25 when they were arriving.
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O-I want to make sure I understand your testimony,.
2 Mr. Weismantle.
Is it your statement that in your opinion 3
it was FEMA's fault that the LILCO observer did'not ask one 4
of'the traffic control posts what time they arrived?
5 A:
No, I am not saying that.
I am not ascribing 6
fault to anybody.
I am just trying to explain the probable 7
reason why people were asked after the fact rather than 8
observed times were reported.
9 0
Mr. Weismantle, I would now like to show you what 10 I am having marked as Suffolk County Exercise Exhibit 25, 11 which in the upper left hand corner is entitled:
Riverhead 12 Staging Area, and in the upper right hand corner it states:
()
13 Page A-66 of 219.
Evaluator's name:
J.
Levenson.
14 Do you see this document, Mr. Weismantle?
15 A
Ye s, I do.
16 (Above referenced document is marked 17 Suffolk County Exercise Exhibit No.
18 25, for identification.)
19 0
And do you see Field Objective 6 in the upper 20 left hand corner under Exercise Objective and Points of 21 Review?
22 A
Yes.
23 0
And that objective, which was to be tested of 24 LILCO was whether they had the ability to demonstrate that
()
25 access control points can be established and manned by ACE FEDERAL REPORTERS, INC.
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traffic guides in a timely manner, is.that correct?
2 A
That is correct-3 0~
Okay.
Do you see the comments made by 4
Mr._Levenson where he states:'
_A total of eight traffic 5
control points (TCPs) were observed in the Riverhead area?
6 JE That is correct.
7 ;-
0 And do you see further down in his handwritten.
8 comments:
They' arrived at their posts between 11:50 and 9'
12:107 10 A
That is correct.-
- ll-0 Which would have been over an hour and a half 12 after an order to evacuate the portions-of the EPZ in which
- (
13-they were supposed _to provide traffic assistance had been 14 issued, isn't that correct, Mr. Weismantle?-
~ 15 A
The order.to evacuate was 10:24 to the-general 16 public, if-that-is what you are referring-to.
17 0
I did have an outstanding question, 18 Mr. Weismantle.
19 A
If you take 10:24, which I assume is what_you are 20 basing it, an hour and a half after that would be 11:54.
21 So, this time frame would bracket that.
22 0
Thank you, Mr. Weismantle.
Mr. Lieberman,-I have i
23 a few brief questions which I would like to pose to you, if 24 that is all right.
Please look at Page 7 of your
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testimony.
Isn't it correct, Mr. Lieberman, that on-Page 7 2
of your testimony you state:
To fully meet the control 3
evacuation time estimates for the Shoreham EPZ,.
4 capacity-enhancing traffic control posts need to be in place 5
when demand exceeds highway capacity aru3 congestion begins?
6 In substance, is that your statement?-
7 A
(Witness Lieberman)
Yes, what I have written 8
here..
9 0
Mr. Lieberman, will you now please turn to the 10 bottom of Page 11 of your testimony, and you state, do you 11 not, that given these evacuation recommendations, meaning 12 the ones given the day of the exercise, congestion would g)
-(
13 have been predicted to begin about 11:24, one hour after the s
14 initial evacuation recommendation was given.
15 Do you see that statement?
16 A
I am sorry.
What page are you on?
17-0 I am on two pages, Mr. Lieberman.
As I said, 18 please look at the bottom of Page 11 of your testimony.
19 okay?
i 20 A
Right.
At some locations, that is true.
21 O
I am not asking you now for your opinion.
We are 22 going to talk about your opinions in great detail later on 23 during this cross examination.
24 A
That was not an opinion; that was a statement of
(
)_
25 fact.
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Mr. Lieberman, do you see at the bottom of Page 2
-11_and the top of Page 12 of your testimony:
Given these 3
evacuation recommendations, congestion would have been 4
predicted to begin about 11:247 5
A That is correct.
'6 O
And you still believe that to'be'true, is that 7 -.
correct?
8 A
Yes, at~some locations.
9
-10 11 12 13 14 15 16 17 18 i
19 20 21 22 23 4
24 25 ACE FEDERAL REPORTERS, INC.
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0 Thirteen percent of the traffic control posts 2
were manned at 11:24 when congestion was going _to begin; is 3
that correct?
4 A_
(Witness Lieberman)
No.
I will take issue with 5
that.
There are quite a few that came in at 11:25.
- And, 6
I'm not going to banter over one minute.
7 0_
That's right.
There were -- you are correct, 8
Mr. Lieberman.
There were two or three, and that might 9
actually rsise it as high as 15 or maybe 16 percent.
10 But, I want to ask Mr. Weismantle a question at 11 this point.
12
-MR.
ZEUGIN:
Judge Frye, I would onlyfsuggest
()
13 that I'think cross examination would be advanced if it was 14 simply in a question and answer form rather than Mr. Sutko 15 arguing with the witnesses about facts.
16 If he would like to have the numbers for 11:25,-
17 I'm sure the witnesses could provide him with that and they 18 could have real numbers if he feels it is important.
19 JUDGE FRYE:
I think the record is clear.
I'm 20 not too concerned about that particular remark.
- And, 21 Mr. Weismantle did testify earlier that the figures were 22 rounded to the nearest five rinutes.
23 So, that's in the record.
24 BY MR. SUTKO:
(Continuing)
()
25 O
Mr. Weismantle, in your Contention EX-40 ACE FEDERAL REPORTERS, INC.
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,2110-10 102 1700 Elf W/sw I1 testimony,'you; assert that'certain.TCPs are " critical TCPs,"
2l
. don't.you?
3 A
(Witness Weismantle)
Yeah,.I believe.so. Land, 4;
Mr. Lieberman' explains.what that-means in:his portions of 5-the. testimony.
6 0.
We are going to discuss that later:this-
-7
. afternoon,1but right now I want simply to-see what type of-8 mobilization we had of so-calle'd critical TCPs at'll:24, 9
which was an hour af ter the order tx) evacuate and the time
~
10
. mobilization was. predicted 'tx) substantially be' completed _on 11 1 "
the' day of the-exercise.
12 And perhaps if you could return again,
)f 13 Mr. Weismartle,- to Attachment B' to your testimony, weL will/
14-try and do this as quickly as possible.
So the record is 15' clear, what does Attachment B refer to?
~
4 16-A.
It defines'the Patchogue-traffic guides called in 17 to report arrival at their control point.
i
=18 (Mr. Sutko is at the-easel.)
19-O okay.
-And, I've written Patchogue and I'm now j
20 going to write Total TCPs which means-total number of TCPs i
21 at Patchogue that are marked as critical.
22 Now, would you please explain on Attachment B how you marked.certain traffic control posts as critical?
23' l:
24 A
Well, they are indicated by the asterisks and on
()
25 Page 11 in the testimony all the critical posts are listed.
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'And, at 10:24 you had 10 - ~as you did all' day,.
J 2
as a matter of fact -- critical TCPs as you define that 3
termr'is:that correct?.
4 A.
-That's correct.
5' O
Okay.
And at 11:24 the data on-the sheet states,.
6.
does it not, that seven were manned?
7 --
A It could have been all of them.
The other three 8
were manned at 11:25, and then these are rounded numbers.
9 Q.
But, you have no personal knowledge to say that's 10 the case, correct, Mr..Weismantle?
11 A
Given the approximate nature of-these times, no, 12 I have no personal knowledge.
(
-13 0
So, LILCO's figures established as best.they can.
14 is that seven were manned and that would be roughly -- is 15 that correct, Mr. Weismantle?
16 A
The figures show seven were manned, and the other.
.17 three a minute later.
18 O
And,'that would be roughly 70 percent; is that 19 correct?
20 A
If you are asking me if seven divided by 10 is 70 21 percent, it's exactly 70 percent.
22 O
Okay.
Now, let's look at the Port Jefferson i
23 staging area, please, which I believe is Attachment C to 24 your testimony.
()
25 How many so-called critical TCPs do you and Mr.
P
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Lieberman believe there are in the Port Jefferson staging 2
area?
3
.A Seventeen.
4 0
And, I take it that on the day of the. exercise at 5
11:24 you had not yet manned any of those?
6 A
That's correct.
7 0
And, I now please ask you to refer to Exhibit D 8
of your testimony; Attachment D, I'm sorry, Mr. Weismantle.
i 9
And, is it a fair statement that of those 10 critical TCPs for which the LILCO observer asked LILCO 11 traffic guides what time they got to the staging area, that 12 we know that-seven of them gave him an answer?
/'_)
(
13 A
That's correct.
14 0
So, we know about seven, according to LILCO, the 15 critical TCPs were at Riverhead?
16 A
Seven out of the 20, yes.
17 0
And, again there is confusion as to whether one 18 or two, according to your data, which is manned as of 11:24?
19 A
Well, there is uncertainty.
20 0
Let's again give you the benefit of the doubt, 21 and we will say that it is two.
That would be roughly 29 22 percent?
23 A-Fine.
24 0
And, it would be 34 total known, so-called
.( )
25 critical traffic control points?
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'A That's right.
%./
2 0
'And,;nine were. manned.
3 14 Yeah, the arithemetic is-correct.
4 O
And the percentage comes out to roughly 26 5
percentLof the: critical oeing manned?
6 14 That-looks. correct.
7 O
Mr. Lieberman, do you have Appendix A to the 8
LILCO plan?
9 A.
(Witness Lieberman) 'Yes, I do.
10 0
-In terms of background, yesterday we discussed a 11 number of traffic control strategies such as concurrent 12 continuous' flow, and you were kind enough to define those
).
13-for myself and the Board.
l 14 Do you remember those discussions?
15 A
Yes.
16 0
I would now like to discuss with you, 17 Mr. Lieberman, the times that those traffic control points
-18 which were supposed to perform the strategies we discussed 19 yesterday were manned.
20 And, if you will excuse me for just a moment, I'
21 will get my data.
22 (Pause.)
23 Mr. Lieberman, will you please turn to Page IV-9 24 of Appendix A?
And, we are going to be discussing from
()
25 Roman Numeral IV-9 through -51, and we are going to just
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I take a few of the various types of traffic functions that 2
you performed -- that were performed on the day of the 3
exercise and see what-time the people that were supposed to 4
perform those functions arrived at the field.
5 I would first like to ask you, did you or KLD 6
Associates draft the portion of the LILCO appendix that we 7
are going to be discussing?
8 A
That's right.
9 MR. ZEUGIN:
Judge Frye, if I could just ask the 10 Board's indulgence, we have extra copies of Appendix A other 11 than the one Mr. Lieberman is looking at, behind him.
If I i
12 could just get one of them, I could follow along with
,s
(
13 Mr. Sutko's questions.
14 JUDGE FRYE:
Yes.
This is Appendix A to the 15-plan.
16 BY MR. SUTKO:
(Continuing) 17 0
And, I think before we discuss this, 18 Mr. Lieberman, I would like to ask Mr. Weismantle a 19 question.
20 On the day of the exercise, LILCO did not 21 actually perform the functions that Mr. Lieberman and I are 22 going to be discussing; isn't that correct?
23 A
(Witness Weismantle)
No.
We did not have 24 traffic guides in the actual streets performing the
()
25 functions.
ACE-FEDERAL REPORTERS, INC.
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0 Did traffic guides drive to their traffic control 2
posts?
3 A
Yes.
But, they didn't set up their posts in the 4
streets, that's all I'm saying.
5 0
So, for example, if they.had cones they would not 6
actually place the cones in the street; is that correct?
.7 A
That's correct.
8 0
And, if they were to, for example, block certain 9
lanes they didn't actually block the lanes?
10-A No, they didn't.
11 0
Is that also your understanding, Mr. Lieberman?
12 A
(Witness Lieberman)
That's my understanding.
()
13 0
Okay.
I would now ask you to turn to Table 5 of 14 Appendix A which is entitled " Concurrent Continuous Flow 15 Treatment," is it not?
16 A
Yes, it is.
17 0
And, there there is a chart showing an 18 intersection of two roads, North Rocky Point Landing Road 19 and Route 25-A; is that correct?
20 A
That's one of them.
21 0
And, that would be manned by Traffic Control Post 22 927 23 (The witness is looking at a document.)
24 Now, Mr. Lieberman, this is the first example of
()
25 concurrent continuous flow on Table 5; is that correct?
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'A That's correct..
2 MR. ZEUGIN:
Judge Frye, I think there is a 3
.pending question before this one, which-~is that --
4 MR. SUTKO:
There is, Judge Frye.
5 MR. ZEUGIN:
And, I think Mr..Lieberman'is'trying 6
to. confirm that_right now.
7 MR. SUTKO:
He is, and I thought perhaps as he
~
8_
was trying to confirm this.was Traffic Control Post 92 we-9 could.do-some other preparatory things and maybe speed'this 10 up.
11 Or, if you prefer, I could ask-Mr. Weismantle 12
'until Mr. Lieberman --
)
13f WITNESS LIEBERMAN:
Let's cut it short.. It's TCP.
14 92, yes.
15 BY MR. SUTKO:
(Continuing) 16 O
And, the diagram charting ~the concurrent 17 continuous flow treatment to be done by TCP 92 is the.first 18 one on Table 5; is that correct?
19 A
(Witness Lieberman)
That is correct.
20 0
And, TCP 92 comes out of the Port Jefferson 21 staging area, Mr. Lieberman?
J 22 A
That is correct.
23 O
And, his responsibilities in a real emergency 24 would be to have vehicles moving south on North Rocky Point fl
)
25 Road Landing to be routed west onto Route 25-A; is that i
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2 A
Well, he would encourage that movement, yes, 3
although.in that particular case I think there would be 4
little need to encourage it since any other movement would 5
-move them, the evacuee, toward the Shoreham Station.
6 0
So, in other words, it's your opinion that the 7
traffic control posts which you spent so much time setting 8
up has no practical value.
9 Is that your testimony, Mr. Lieberman?
10 A
No.
Those are your words.
11 0
I'm asking you if you agree with my words, 12 Mr. Lieberman?
()
13 A
No, I don't.
14 0
You think it does have some value, don't you?
15 MR. PIRFO:
Argumentative.
It has been asked and 16 answered.
17 JUDGE FRYE:
Yes.
Let's don't argue.
18 MR. SUTKO:
Okay.
19 BY MR. SUTKO:
(Continuing) 20 0
Apparently, you are having some problems with the 21 words, Mr. Lieberman.
Would you please look at Table 5 in 22 the first example we are discussing?
23 A
I am looking at it.
24 0
Thank you, sir.
And, do you see where it states
()
25 there that he -- he, being Traffic Control Post 92 -- is ACE FEDERAL REPORTERS, INC.
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going to have vehicles moving south on North Rocky Point 2
- Landing Road and will be routed west onto Route 25-A?
3 A
(Witness Lieberman)
Yes, that's what it says.
4-O would you please tell this Board what time that 5
traffic control post who was to perform this 6
concurrent continuous flow treatment arrived at his post on 7
the day of the exercise?
8 A
That is not a concurrent continuous flow 9
treatment.
10 0
All right.
11 A
It is labeled as such, but actually it isn't.
12 O
All right.
Let me make sure I understand your
/~'
(_)s 13 testimony..You drafted this; is that correct?
14 A
That's right.
15 0
You drafted it so that the title is incorrect as 16 to this particular treatment ac this particular 17 intersection?
18 A
Well, we have a number of treatments in that 19 section which guide movements.
And, I assigned that title 20 to all of them just as a means of grouping them all.
21 They are not all, as I consider them, to be 22 concurrent continuous flow treatments.
23 JUDGE PARIS:
You said just as a means of 24 something, and I didn't get the words.
()
25 WITNESS LIEBERMAN:
It's just a means of ACE FEDERAL REPORTERS, INC.
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. documenting'~ specific locations. indicating'where the traffic-2.
flows are.in'dicated.
My definition-of'a concurrent 3
' continuous' flow treatment is best.shown on the following
~
<4 page which is 4-11.
I
-5 On the top ~of that page you will notice: thati h
. j 6
there are two traffic streams approaching.that i
l l 7.
intersection.
The' role of the traffic guide there is to l
8 guide these movements so that each movement'can continue 9
without~ conflicting with the-other.
10 And,-that's what I call a concurrent continuous i
ill-flow treatment.
I. guess it was a poor choice of' title in 12 the table, because not all of them -- in fact,-relatively I
l
.13 few of them actually perform that kind of function.
14 BY MR. SUTKO:
(Continuing) 15 Q
Mr. Lieberman, you-I believe in Table 5'show 10-l 16 intersections.
How many of those are actually not 17' intersections at which concurrent continuous flow treatments
(
-18 take place?
t l'
19 A
I would say seven out of the 10 are not.
~
20 0
Thank you, Mr. Lieberman.
21 A
As I said, it was a poor choice of title.
22-0 And, I believe that previously I asked you what 23 time did Traffic Control Post 92 report as having arrived at
'24 the intersection, which is the first example on Table 5, on 25 the day of the exercise?
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1 A-Indicated here in Attachment C, it's 12:12.
2 0
Mr. Lieberman, let's.please move onto your next
.3 treatment that we discussed yesterday which I believe is 4
channelization treatments.
5 And I ask you to look at Table 9 which is on Page 6
Roman. Numeral IV-20, and again let's take the first example
.7 that you give.
I believe that there are two traffic control' 8
posts that would be in the vicinity of this channelization 9-treatment, _and that they are Traffic Control Posts 57 and 10 56.
11 Would you please confirm that?
12 (The witness is looking at a document.)
(~'s 13 A
Well, 57 and 56 are represented here.
\\/
14 0
would it be a fair statement they are in the 15 general vicinity; is that correct, Mr. Lieberman?
16 A
Okay.
The first one which is identified as a 17 Link 7,30 is the three-way-treatment -- I'm sorry, 18 three-lane treatment on the westbound approach to CR-83 19 along Route 25-A.
And that's shown a's Traffic Control Point 20 56.
21 0
Now, would you please look at Traffic Control 22 Post 57 as well, Mr. Lieberman?
And, I think you have a 23 book that sets out, in front of you, every traffic control 24 post; is that correct?
25 A
That's correct.
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0 And, essentially it's'a little map of each'of the-
. )
2 130 traffic control posts.
.Is that.a fair statement ofythe.
3;
' book?
A~ schematic drawing,'if you will?
'4 A
-That's correct.
i 5
0 Was this drafted-by you.or-by,KLD.and Associates,
~
6 Mr. Lieberman?
7 A
No.
8 0
Do you know who did draft-this?
9 A
I believe it.was drafted by consultants to LILCO' 10 using a CAD computer.
11 0
And, who would those consultants be?
12 A-I don't'know who --
(
13 (Witness Weismantle)
I think it was Stone &-
14-Webster at the time.
15 0
And, I take it that you have relied upon these 16 130. drawings in preparing your testimony; is that correct?'
17
-A (Witness Lieberman)' No, I don't think that-is 18-true.
19-JUDGE FRYE:
You don't think that's true?
Is 20 that what you said?
21 WITNESS LIEBERMAN:
Yeah.
The question was 22 whether I relied on all 130.
And, no, that's not true.
I 23 really focused on those I felt the most important.
24 MR. SUTKO:
Okay.
25 BY MR. SUTKO:
(Continuing)
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0 Mr. Lieberman, you have the preciseness of an 2
engineer,- and my question was badly framed.
And, I 3
apologize.
4 Did.you rely on any of the 130 schematics that 5
are -- that detail the traffic control posts in preparing 6
your testimony?
7-A (Witness Lieberman)I Yeah.
I reference ( this
-8 document in the course of preparing testimony.
9 0
And, now I think I had asked you previously to 10 look at Traffic Control Point 57 and tell me,'is that also 11 involved in the channelization treatment?
12 A
That is correct, r').
13 0
And, the channelization treatment which is
.(m-14 contained in the first example on Table 9 requires those 15 traffic guides or those traffic control posts to establish 16 two lanes; the inside lane is reserved for left turning 17 traffic onto link, and here you use what's a traffic note I 18-believe, which Judge Shon would be familiar with, Patchogue/
19 Mt. Sinal Road; is that correct?
20 A
That's correct.
21 0
Okay.
And that's a technical explanation.
Can 22 you give a layman's explanation for what these gentlemen are 23 doing out in the field when they are setting up this 24 channelization treatment?
25 A
Well, what you wanted to do is maintain two lanes 14CE FEDERAL REPORTERS, INC.
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of through movement in this section.
It's about 2,000' feet 2
long, along Route 25-A'from Echo Avenue on east to the T 3
intersection which is the northern terminus of County Road 4
83.
5 There isn't all that much traffic there.
What 6
you wanted to do was' assist in the movement of traffic so 7
that we could eliminate some merging.
8 O
And, what is some merging, Mr. Lieberman?
9 A
Merging is a situation where, for-example, two.
10 lanes of traffic merge into one lane of traffic.
- And, 11 depending upon the relative volumes, you might encounter 12 some delay and a lowering of speed as a consequence of this
/~
13 merging.
\\._)/
14 It's also a lower capacity.
15 0
And, in order to attempt to mitigate this 16 lowering of speed and lowering of capacity, you have chosen 17 to adopt a channelization treatment in this area.
18 Is that a fair statement, Mr. Lieberman?
19 A
Right.
You are trying to be helpful to the 20 evacuees, since we had a section here where there were two 21 traffic streams entering at the eastern end, two traffic 22 streams entering at the western enci, and an existing 23 one-lane configuration between theri.
So, we thought it 24 would be helpful to do this.
r's 25 0
Okay.
And, again I'm a layman.
But, to make b
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sure I understand, you just thought you would get people-in 2
.there -- speed them up-apd get them.in there more quickly by 3
establishing this procedure, correct?
4 A
I wouldn't use the phrase " speed them up."
5 0
I know you wouldn't.
I just asked you if you 6
would agree with me, not whether you would use it.
7 A
I think I've already described it.
I don't know '
8 how to do it better.
9 0
Okay.
That's fine, Mr. Lieberman.
I just have 10 one further question on this'particular channelization 11 treatment.
It's the only channelization treatment I am 12 going to discuss.
13 Would you please tell me what time Traffic
{
14 Control Post 56 and 57 arrived at their posts or reported in 15 as having arrived at their posts on the day of the exercise?
16 (The witness is looking at a document.)
17 A
56 arrived at 11:42, and, 57 arrived at-noon.
18 0
And that would be after congestion would begin'to 19 develop within the EPZ.
20 Is that a fair statement, Mr. Lieberman?
21 A
At some points within the EPZ.
I'm not -- I 22 don't know if it developed at this point at that time.
I 23 would have to check into that.
24 JUDGE FRYE:
I'm having trouble hearing you, 25 Mr. Lieberman.
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' JUDGE PARIS:- Mr. Sutko, could I get in a fast.
2
' question?
3
'MR.'SUTKO:
Yes, sir.
4 JUDGE FRYE:
Let him' finish first.
l~
5 WITNESS LIEBERMAN:
Let me just repeat.the 6
answer.
I have -- I can:look it up, but I don't know 7
whether there is congestion.at that. point at roughly noon p.
8 without looking-it'up.
9 When we'say that congestion starts to appear, we 10 mean just that, that there are I think.about a half'a dozen 11-points out of perhaps 280 links which are undergoing.
12 congested: conditions one hour after the order to evacuate.
13 14 15 16 17 18 19
)
20 1
21 l
l 22 1
23 24 25 ACE FEDERAL REPORTERS, INC.
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WITNESS LIEBERMAN:
I can't tell you at this time
~2 whether this point was congested at that~ time, at noon.
3 JUDGE PARIS:
Is Route 83 the same as Patchogue -
4 Mt. Sinai. Road?
5 UITNESS LIEBERMAN:
Yes, sir.
Suffolk County is 6
notorious for hyphenated names.
7 JUDGE PARIS:
Yes.
I. gathered that.
8 BY MR. SUTKO:
(Continuing) 9 0
Mr. Lieberman, I ask you now to please turn to 10 Page Roman Numeral IV-29 of Appendix A of the LILCO Plan.
11 Here, I want to briefly ask you about the first-four 12 examples that you provide in Appendix A, and first it is 13 correct, is it not, that page Roman Number IV-29 of Appendix
(~)S m
14 A is entitled:
Table 13, Recommended Turn Movements?
15 A
(Witness Lieberman)
Ne I believe that is Table 16 12 with that title.
17 0
That is right.
Now, Mr. Lieberman, will you 18 please explain for me and for the Board quickly what a 19 recommended turn movement is under your traffic strategy?
20 And again, I personally would appreciate it if 21 you could do it as close to layman's terms as is possible.
22 A
Right.
The -- as part of the implementing 23 procedures, information is given to the public identifying 24 the routes that are recommended to them, and by routes I 25 mean evacuation routes.
That is one way of representing
{-)g n
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the pattern of traffic flow over the-spacial domain of the 2
EPZ, and these routes are shown~in a exhibit of evacuation 3
routes.
4 And it might be useful if I can hang that up and 5
talk about it.
6 0
My_ question is' direct.-
I don't object to you 7
doing that, Mr. Lieberman.
I just want to make sure we have
~
8 an understanding.
You are going to do that to explain what-9 a recommended turn movement is.
10 A
Yes,'I will 11 (Witness puts map on easel) 12 I am using some terms here which I guess I should
/~N 13 define to ease the burden on the Board.
V' 14 When you model a physical highway system, we 15 represent that as a network, which is comprised of links and 16 nodes.
17 A link is a section of highway which extends 18 between two nodes.
19 We identify a link by the upstream node, that is 20 the place where traffic is moving from, and by the down 21 stream node, which is the location where the traffic is 22 moving toward.
So, in the first link here, we have link 23 102,1, which implies that traffic is moving from node 102 24 towards node 1.
I believe that the link 102,1 -- let me 25 check that before I indicate it -- is the link which C_);
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~ approaches along North Country Road to the. fork ~in the road,-
7
-t t
'~'
2 the left fork being North Countr'y Road, which proceeds west.
3 from that point.
The right fork being Shore Road, which 4
takes the right fork,-and then eventually becomes Broadway, 5-or Old Post Road, into Port Jefferson.
6
-Now, you will notice that at that point the flow-7 of traffic along North Country Road branches both lef t and 8
right, and what-this-table does is identify on the basis of 9
the analysis that we did, using the model, what we expect 10-the turn movements to be based on the instructions that we 11 give to.the people who will be using that route to evacuate.
12 O
Thank you, Mr. Lieberman.
I take it then that
-(a"i 13 that section we are talking about is the intersection where 14 traffic control post 81 would make the recommended turn 15 movement?
16 A
Yes, that is correct.
17 0
Do you know if that traffic control post was in 18 the field by the time the congestion began to develop in the 19 EPZ on the day of the exercise?
20 A
I believe it was, yes.
According to the table.
21 0
It was there before 11:24, Mr. Lieberman?
22 A
Okay.
I would have t6 check that.
Here it is 23 11:40 when that post was manned.
I would have to check the 24 listing to answer the question, if you would like me to.
()
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A I would like to go just through a few more-
\\s' ^
2 examples of recommended turn movements briefly, and then 3
perhaps'have lunch, if that is okay with the Board.
4-But it won't take more than a few minutes, I 5
don't'believo.
Mr. Lieberman, would~you look at the bottom 0
of Page Roman Numeral IV-29.
I believe that is entitled:
7 Node 4, is that correct?
8 A
That is right.
9 0
And could you please tell me if that is traf fic 10 control post 1007 11 A
That is right.
12' JUDGE PARIS:
Could you point to it, 13 Mr. Lieberman, so we can locate it on our maps.
}
14 (Witness points to place on map.)
15 JUDGE PARIS:
Thank you.
16 BY MR. SUTKO:
(Continuing) 17 O
And that control post is located at an 18 intersection along North County Road, which is the road we 19 have discussed a lot in this litigation to this extent, 20 Mr. Lieberman?
21 A
(Witness Lieberman)
That is right; it is the 22 intersection of North County Road with Echo Avenue.
23 0
Could you please tell me what time that traf fic 24 control post arrived in the field on the day of the
)
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exercise?:
2
.A That was at 12:17.
3
-0 And let's just take a final. example.
Would you 4
please go to the next example, Mr. Lieberman, which I think' 5
is on Page Roman Number IV-30, and you see where it states:
6 Node 57 7
A-Lyes.
8' O
II believe that that-is Traffic Control Post 118, 9
is that correct?
10 A
(Witness peruses document.)
I believe it is.
11 0
And will you please.tell me what time-the traffic 12 guide that was supposed to perform the recommended turn O
13 movements.at that intersection arrived on the day of the U
14 exercise?
15 A
I am going to take issue with the word, 16
" perform."
He doesn't perform.
He expedites the moveme'nt 17 with hand actions.
He doesn't -- I think the word, 18
" perform" is incorrect.
I can give you the time anyway.
It 19 is 12:15.
20 0
So, prior to 12:15, obviously, he could not 21 expedite with hand movements, isn't that a fair statement?
- 22 A
Unless he had very long arms.
23 MR. SUTKO:
Thank you, Mr. Lieberman.
24 JUDGE FRYE:
Is this a good breaking point?
25 MR. SUTKO:
Yes, sir.
p a
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.1 JUDGE FRYE:
All'right.' Well, why. don't we ib1 2
adjourn until about'l:25, for lunch.
3 (Whereupon, luncheon recess was-taken at 12:00 4
noon,--to. reconvene at 1:25 p.m.,-this same day.)
5 6
7
~
8 9
10 11 12 13
-14 15 16 17 18 19 l
20
~21 22 23 I,.
24 25 ACE FEDERAL REPORTERS, INC.
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i 121T0.03 03 1722 Lnr.rysimons 1' AFTERNOON. SESSION
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3
.Whereupon, 4
JOHN A. WEISMANTLE 5
and 6'
EDWARD B.'LIEBERMAN 7
a panel of witnesses called on behalf of Long Island Light 8
. Company, having been previously duly sworn by Judge Frye,-
9 resumed their places at the witnesses table and were 10 further examined and' testified further as follows:
.q; 11-JUDGE FRYE:
Let's'go back on the record.
b 12 Are you ready to continue, Mr. Sutko?.
~
13 MR. SUTKO:
Yes, sir..
14 First, Judge Frye, there are two preliminary 15 matters.
16 First,'I would like to move into evidence 17 Suffolk County Exercise Exhibit 25, which was the FEMA 18 evaluator form that we discussed prior to the break.
19 JUDGE FRYE:
Any objections to that?
20 MR. ZEUGIN:
No objection.
21 MR. ZAHNLEUTER:
No objection.
22 MR. PIRFO:
No objection.
p 23 JUDGE FRYE:
So ordered.
24 25 ACE FEDERAL REPORTERS, INC.
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^
b
,12110L01"Ol;
- 1723-3
- r^Tysimons l' ik )
(Suffolk Cou'nty Exercise
^_~
.2 Exhibit No.;25, previously 3
fortidentification', wasi 4
- admitted into evidence.)
15 sMR. SUTKO:
Second, Judge Frye,'during the break 6'
Mr.~2eugin and I discussed'the various flow treatments'and 7
other.traf fic~ treatments which I-discussed Iwith Mr. :
8 Lieberman' prior to_ lunch,'and Suffolk County isigoing to 9
want to use those perhaps as potential findings in this 10 case.
11 JUDGE FRYE:
Those being the diagrams I take it?
~
12 MR. SUTKO:
Yes, sir.
Many.of the-diagrams do
};
-not reference traffic control-posts.. Rather they discuss 13 14-the nodes that Mr. Lieberman referred to prior to lunch.-
f
~
15
.Certainly.we feel that it is necessary to have someone with 1-4-
16 expertise in converting nodes at traffic control points do f
17 that' exercise.
18 I've done it, but the agreement that counsel I l
19
-believe have worked out is that'I'm simply going to ask Mr.
~
20 Lieberman an open question which he can wrap on Monday as 21 to these various intersections and whether the traffic 22 control posts I believe them to be are correct.
That way 23 the record would be full for findings, and I would like the l
24 Court's permission to do that.
C:)
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2110 01 01-1724
{^7ycimons 1 JUDGE FRYE:
I take it you are just going to
~
2 give him that document, he will review it, you will then 3
.ask him whether you've done it correctly, he will say 4
presumably yes and then you will introduce it as.an 5
exhibit.
Is that the idea?
6
-MR. SUTKO:' That's correct, and this document 7
obviously the document I used to prepare for trial.
It has 8
some notes. 'The only question I would be asking him about 9
would be whether the traffic control post-listed by each of 10-these is correct or incorrect and I can give that to Mr.
11 Lieberman on a break.
12 JUDGE FRYE:
It sounds fine to me.
13 MR. ZEUGIN:
It's fine with me, Judge Frye.
I 14 think it will save time.
15 JUDGE FRYE:
Good.
16 MR. SUTKO:
Judge Frye, I guess I envision a l
l 17 problem with giving this to Mr. Lieberman in that this 18 document being the section of Appendix A, Roman numeral IV-
{
19 9 through 51 has my handwritten notes on it.
So I don't 20 believe it could become an exhibit properly.
21 JUDGE FRYE:
It sounds like you got to get a 22 clean copy to give to Mr. Lieberman.
23 MR. SUTKO:
We will do that.
24 Judge Frye, I would now like to introduce for 25 purposes of identification Suffolk County Exercise Exhibit ACE FEDERAL REPORTERS, INC.
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. _ =.
2110-'01L01 1725 r"}ysimons 1 26-which are the traffic control point schematics that Mr.
.f
~
2 Lieberman and I discussed prior to lunch this morning.
3 (The document was distributed to the Board and 4
parties.)
5 CROSS-EXAMINATION (Resumed) 6 BY MR. SUTKO:
7 0
Mr. Lieberman, do you have a copy of this before 8
you?
9 A
(Witness Lieberman)
Yes.
10 0
What I would like to do, Mr. Lieberman, is for.
11 you and I to discuss the schematic,- and you will note that 12 in the bottom left-hand corner of traffic control point No.
13 1,'for example, the e is a legend with various (J
14 explanations, and then I would like to discuss with you 15 just some. selected traffic control points and how traffic 16 guides are expected to implement the strategies that would 17 be necessary in a Shoreham evacuation.
18 So the first question I would like to ask you is 19 to please look at traffic control point No. 1.
20 Mr. Lieberman, do you see the first thing under 21 the legend are a white circle and a dark circle and the 22 word cones.
Would you please explain why you have two i
23 colors on this schematic for cones.
24 (Pause while the witness reviews the document.)
25 A
It doesn't come to mind at the moment.
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2110H01 Ol' 1726 r~;ysimons 1 0
So toLthe best of your knowledge as you sit.here 3-Qf-2 today there is.no significance whether a cone is a white 3
cone or a black cone; is that correct?
4 A-Well,'there may be, but.as I say it doesn't come 5
to mind.
6.
Q.
You will notice in the next line in the' legend 7
there :again are two types of cones both of which.are 8
flashing light cones, and I take it that you also hadE no 9
reason to believe that the triangle with the white circle 10 is any different than the triangle with the black circle; 11 is that a fair statement?
l 12 l
A Well, until I have time to refresh my memory, I i
13 can't say otherwise.
'}
14 O
Mr. Lieberman, if you would like to take a few 15 minutes and review this document, I certainly have no.
16 objection.
17 (Pause while the witness reviews the document.)
18 JUDGE FRYE:
While he's doing that, Mr. Sutko, I 19 take it that this exhibit that you've identified is 20 diagrams of all of the traffic control points 1 through 21 1307 22 MR. SUTKO:
Yes, sir.
Judge Frye, so the record 23 is clear, it's my understanding that those were prepared by 24 LILCO to be given to their traffic guides for use in the 25 field and that they do not necessarily in all instances
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2110 01 01 1727 ysimons 1 accurately depict side roads, for example, but do show the 2
evacuation routes and the routes of other traffic which 3
would come through the various intersections.
4 JUDGE FRYE:
Well I'm sure that the witnesses 5
will describe it.
6 BY MR. SUTKO:
7 0
Mr. Weismantle, would you generally agree with 8
those statements?
9 A
(Witness Weismantle)
No, I can't comment on the 10 accuracy of the side road treatment.
11 JUDGE PARIS:
I would lika to ask a couple of 12 questions to clarify the origin of these diagrams.
13 You testified earlier, did you not, Mr.
14 Lieberman, that they were drafted by Stone and Webster you 15 thought?
16 WITNESS LIEBERMAN:
Well, the final product was 17 drafted by Stone and Webster.
The actual presentation of 18 these sketches was done by Stone and Webster.
- However, 19 they all involved field trips at which time I with the 20 assistance of another person working for LERO would stand 21 out there and sketch the geometrics of the intersection and 22 from those sketches these drawings were made and then they 23 were returned to me for approval and any revision that I 24 thought was worthwhile and finally they became part of the
's 25 training material.
7 1'
ACE FEDERAL REPORTERS, INC.
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2110 01 01 1728 jr~rycimons 1 JUDGE PARIS:
I see.
So they represent your
~
2 traffic work.
3 WITNESS LIEBERMAN:
Oh, yes.
4 JUDGE PARIS:
And Stone and Webster were-just
'S draftsmen, so to speak?
)
l 6
WITNESS LIEBERMAN:
That's correct.
l l
7 JUDGE PARIS:
All right,-thank you.
8 WITNESS LIEBERMAN:
I might add that these are 9
sketches of schematics, and the purpose was to provide the 10 guide with sufficient information so that he could do his 11 work.
We don't represent that they are photographic 12 representations of the area.
13 JUDGE FRYE Did you have an opportunity, Mr.
14 Lieberman, to refresh your recollection on why there are 15 two depictions of cones?
16 WITNESS LIEDERMAN:
I recall that there is a 17 reason, but I just can't dredge it up from memory.
18 JUDGE FRYE:
All right.
19 BY MR. SUTKO:
20 0
Mr. Lieberman, you'll note in the third line of 21 the legend there is a circle with an "x" through it and a p
22 statement " traffic guide."
I take it it's a fair statement 23 that on the schematic where the circle with the "x" is 24 depicted is roughly where the traffic guide is expected to 25 stand in order to route traffic?
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'A
.(Witness Lieberman)
It's very, very rough.. By T*);ysimuns'l
. Q,.
2
'no means should you imply that the' traffic guides should be 3
immobile and restricted just to that. location.
He1can move
-4.
around.inLaccord with what he perceives in the field.
We 5
'had to show the general area wherefthe traffic. guide is-
- 6 located;and how many there were... We'can very well depict 7
real world movement on a piece of paper.
8 Q
"Now,~Mr. Lieberman, when-you say.he can move 9-around,-I take it you mean that he can move around the 10 traffic control points is that correct?
11 A
That would be generally true, but again'there 12 are no restrictions in terms of'his movement.
'{
.Would you expect in a nuclear emergency for a 13 0
l'4 traffic guide.on his own to leave a traffic control point
-15 and travel to another intersection?
16 A
No, not without first radioing in to the-Chief 17 Traffic Guide or perhaps even -- let me check on the 18 communication end.
19 Pause while the witnesses confer.)
y i
20 Yes, he can radio back to the Chief Traffic 1
i 21 Guide and inform him that he has such and such reasons for 22 leaving his post, and then he would get instructions from I
23 the Lead Traffic Guide.
24 0
But that would be a staging area rather than a
)
/
25 traffic control point decision; is that a fair statement?
i
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("7ysimons 1 A
Usually, yes.-
I mean there could be some-(,f 2
circumstances where he would act on his own volition and 3
inform the Chief Traffic Guide why he was doing it.
4
'O Mr. Lieberman, what would those circumstances 5
be?
6 A
Well, there might be an impediment in which case 7
he would call in to the EOC, inform them that there is an 8
impediment and that he's going to the site of the 9
impediment to direct traffic.
10 A
There may be a situation where the traffic drys 11' up at the location and he may perceive that there is no 12 need for his-services there any more.
So he will ask for 13 permission to leave the area.
There could be events of j (}
14 that nature.
15 0
So it's your testimony that it is acceptable for l
16 a traffic guide when he determines that flow is dried up to 17 on his own as a traffic control point decision to leave the 18 area; is that correct?
19 A
No.
I said just the opposite.
He has to call 20 in and inform the EOC or the Lead Traffic Guide as to the 21 situation.
He might make some recommendations, but that 22 decision has to upwards.
23 0
Mr. Weismantle, you're the ex-head of LERIO; is i
24 that correct?
25 A
(Witness Weismantle)
That's right.
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Is it your. understand that without staging area
():
2 approval a traffic should ever leave his traffic control 3
' point?
4 A
I just to check the precise procedure on one 1
5 matter.
6 (Pause while the witness reviews documents.)
7 If his dosimetry reading exceeds 5 rem, for 8
instance, and he is not authorized to stay, he can leave on 9
his own.
10 0
But that is the only instance of which you are-11 aware, isn't it?
12 A
That is the only instance that is covered in our
(~']
13 plan.
14 JUDGE PARIS:
He'll be wearing a self-reading
'15 dosimeter?
16 WITNESS WEISHANTLE:
Yes.
He has a couple of 17 direct reading dosimeters.
One of them is a low range, 18 zero to 200 millirem, and the other is a zero to 5 rem.
19 BY MR. SUTKO:
20 0
Mr. Lieberman, you will note the next item under 21 the legend is a square with an "x" drawn through it and 22 that's just meant to depict traffic signals; is that 23 correct?
24 A
(Witness Lieberman)
That's correct.
25 0
would you please now turn to the next to last ACE FEDERAL REPORTERS, INC.
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.2110.01 01 1732 i ;
ysimons 1 legend item' going from the bottom, which is a straight
~
2 black line and bears the legend " evacuation route."
Would l
3 you please describe what this'is to depict on the 4
. schematics?
l-i 5
A Well, I think I earlier described what an i
-l 6-evacuation route was.
What the arrow does is to depict I
7 schematically the main evacuation route or routes that move 8
through the traffic control point.
l
(
9 0
For example, Mr. Lieberman, isn't it true that j
l 10 hypothetically evacuation traffic coming down Lower Rocky 11 Point Road could make either a left onto Sound Beach 12 Boulevard or what I will call a right-hand turn onto Lower 13 Rocky Point Boulevard if'there were no direction?
14 A
That's correct..
15 0
But.under the plan that you have developed you 16 would prefer that the traffic would make the right onto 17 Lower Rocky Point Boulevard; is that correct?
18 A
That's the plan that is consistent with our ETE 19 calculations; that's right.
20 0
And is it fair to say that one of the functions 21 of the traffic guide at traffic control point No. 1 is to 22 assist that traffic by helping it make the decision to make 23 the right-hand turn onto Lower Rocky Point Road?
24 A
That is one of his functions, yes.
25 0
In addition, you will note that you have two ACE FEDERAL REPORTERS, INC.
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I "2110 01101 1733 r Tysimons 1.
broken lines on the schematic for traffic control point No.
.i
%.)
2 1, and at the bottom of the legend it defines it I believe 3
as movements to be accommodated; is that correct?
4 A
That is correct.
5 0
.Is it a fair-statement to say that this is other 6
traffic which may arrive at that intersection and which the 7
traffic guide is also supposed to assist in routing?
8 A
That is correct.
The implication is that for-9 the most part these movements would be characterized by 10 much lighter volumes of traffic than the evacuation route.
11 In a location such as this where we have a road which is 12 embedded within a residential area the differences may not
(-)
13 be all that pronounced.
t) 14 0
And is it also a fair statement, Mr. Lieberman, 15 that at least in some instances where you have what I will 16 call I guess accommodated traffic -- and I take it you 17 understand what I mean when I use that term?
18 A
I think so.
19 0
--- merging with evacuation route traffic, what 20 you may have is traffic from residential areas joining an 21 evacuation route.
Is that a fair statement?
22 A
Yes.
23 0
Now I also note on traffic control point No. 1 24 that one of the accommodated traffic streams, the one that
}
25 would be moving east on Lower Rocky Point Road and making a
{~J
~
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~-2110.01 Oli 1734
,,r'7ysimons 1L right or. southward' turn onto Sound Beach. Boulevard has the
'V
~
- 2' notation " expect'no or'11ght traffic."
Is1that correct?:
3 A
-That is. correct.
-4 O
Could'you please explain what you mean in these 5
schematics when you use the term "no-or light-traffic"?
6 A
Well, we're: talking about directions of flow 7
which we expect-to be very light.
In this-particular case 8
we have flow which is moving eastbound and therefore at 9
this location closer to'Seabrook Station.
It is contrary 10 to the instructions which are furnished to the public, or 11-would be furnished to the public, and therefore we expect 12' that this traffic would be light over the extent of-the
(~\\
13 evacuation.
%)
14 0
Mr. Lieberman, would you briefly look at traffic 15
-control point No. 5.
16 JUDGE PARIS:
Could I ask a quick question 17 before we go on?
18 MR. SUTKO:
Yes, sir.
19 JUDGE PARIS:
Mr. Lieberman, will movements 20 other than the evacuation route movements and the movements 21 to be accommodated be prohibited?
22 HITNESS LIEBERMAN:
We never use the word 23
" prohibited."
They would be discouraged.
The reason we l-24 don't prohibit movements, and I don't think they should 25 over be prohibited, is because people may have good reason I
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,r 7ysimons 1 for taking routes other than those which move them out of 2
the EPZ.
For example, they may be commuters who are coming 3
home from work if the accident happens midweek /mid-day to 4
gather up their family and then to evacuate as a unit.
We 5
expect that to happen.
6 There may be situations where somebody in one 7
household has arranged to pick up a member of another 8
household for ride sharing purposes, and that, too, would 9
be an example.
10 The third example would be a parent who decides 11 to go to school, the school that his or her children are 12 at, or child, and decides to pick them up from school in 13 the event that their action precedes the evacuation of the
}
14 schools.
15 JUDGE PARIS:
Well if I'm a commuter driving 16 north on Sound Beach Boulevard and I want to turn right on 17 Lower Rocky Point Road what would I encounter as far as the 18 traffic guide is concerned?
19 WITNESS LIEBERMAN:
What you would encounter 20 there is a traffic guide which would point towards 21 westbound Lower Rocky Point Road and indicate through is 22 hand movements that that is the recommended route.
23 JUDGE PARIS:
Do they have any instructions as 24 to action to be taken if a vehicle does not obey their hand 25 signals?
(-]
\\_ /
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2110 01 01 1736-r,2ycimons 1 WITNESS WEISMANTLE:
They are instructed to take
(
)
~'
2 no action.. They are not to prohibit or in any way 3
interfere with someone who wants to take a different route.
4 JUDGE PARIS:.That clears up what I was 1
5 interested.in.
)
6 BY MR. SUTKO:
7 0
Mr. Lieberman, in talking with Judge Paris you l
8 mentioned that the traffic guide at traffic control point l
9 would point westbound, and I take it that you believe that 10 that would provide some potential advantage to the 11 evacuating populace.
Is that a fair statement?
12 A
(Witness Lieberman)
Well, it certainly wouldn't 13 hurt.
It would serve to reinforce the information which
)
14 has been provided to the driver beforehand.
Essentially it r
15 goes back to the use of our word facilitate.
It's i
16 essentially a facilitating, visual, advice giving.
17 0
In your opinion, does having a traffic guide at 18 that intersection help people make that right-hand turn 19 more quickly than they might if there were no traffic guide 20 at that intersection?
l.
21 A
I don't believe that the action of the traffic 22 guide serves to increase capacity.
I think what it does at 23 this point is more an advisory function and one which, as I 24 said before, reinforces the information provided by the 25 public information literature.
ACE FEDERAL REPORTERS, INC, 202 347-3700 Nationwide Coverage 800-336-(M6
I 12110 01 01 1737 J*gysimonsl-JUDGE PARIS:
Mr. Lieberman, in'your prepared
~
2 testimony on page'7, the paragraph beginning at the bottom f
3 of;the page you say " Traffic guides implementing special 4
traffic control' treatments are able to' decrease the 5
evacuation times by increasing the capacity.on individual 6
highway segments."~
i 7
So maybe you had'better explain the apparent 8
discrepancy in that and what you just said.
H
.-9 WITNESS LIEBERMAN:
The key word there is-i
' 10 individua'l. highway segments.
We don't assume traffic l
11 guides to perform that function everywhere.
There are a L
12 number of functions, one of which is to increase the 13 capacity at'specified locations.
{}
14 The answer to question 8 is ---
15 JUDGE PARIS:
What page?
16-WITNESS LIEBERMAN:
I'm sorry.
That's page 10.
i 17 We define what we call critical TCPs.
The previous Board 18 in the PID calls them key posts.
Regardless of the 19 semantics, these are the TCPs which we consider to be most 20 important for.the reasons given there.
21 The TCPs which do not lie within the realm of 22
" critical" are essentially there to perform the kind of 23 advisory and guidance function which I described for TCP 24 No. 1.
There are a number of TCPs which are designed 25 expressly f r the purpose of increasing capacity.
The most ace. FEDERAL REPORTERS, INC.
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" ysimons 1 notable of these are the TCPs which lie alcng that stretch 2
of Lower Rocky Point Road and North Country Road which is 3
converted to one-way flow.
When you do that you 4
effectively double the capacity of that section of roadway.
5 JUDGE PARIS:
The statement on page 7 refers to 6
things like changing a two-way road to a one-way raad?
7 WITNESS LIEBERMAN:
To a major extent.
There is 8
also a section on Route 25A which we talked about earlier 9
which is west of Echo Avenue and east of County Road 83 10 where we establish a two-lane outbound flow in order to 11 maintain the continuity flows I described earlier.
As a 12 consequence of that action, the capacity is increased, but
(~')
13 that's not the major motivating factor for doing that.
v 14 The major motivating factor is to maintain 15 continuity of flow.
The reason I make that statement is 16 that the demand through that section, even in the presence 17 of a single lane, would not be a bottleneck in the sense of 18 extending the evacuation travel time.
But as part of the 19 channelization treatment given there, the outcome is to 20 increase capacity.
21 JUDGE PARIS:
What do you mean by " continuity of 22 flow"?
23 WITNESS LIEBERMAN:
If the Board has been served 24 with a copy of these sketches ---
r 25 JUDGE PARIS:
We have them.
(
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92110'01 01 1739' WITNESS.LIEBERMAN:
'You have not?
b.c^7ysimonsl~
-2 JUDGE PARIS:: LWe have them, yes.
3' WITNESS LIEBERMAN:
I would like to point your 4'
attention ~to TCP 56-and-57.
5-If you-look at 57 first,2which isithe entrance-f:
6 to the outbound flow in that' area, you'will notice that you.
7-have a converging.of two traffic streams, one from Echo t.
8
. Avenue and the other westbound along Route 25A..-Under 9
normal-conditions these two traffic streams.would merge 10 onto-a single lane.
E 11.
Then if you go back to traffic point 56, that-12 single lane of westbound movement would approach the "T"'
13 intersection to the left of that sketch and there would be'
{}
4
- 14 some vehicles who.want a left turn and would slip.into an F
15:
existing left-turn bay and the others would~ continue: moving
-16
. west.
17 What.we've done with this treatment'is to i
L-18 preserve.the separate-streams.
Instead of having a merging 19 or converging of two traffic streams justLdownstream of 20 Echo Avenue and then a subsequent diverging of those i
21 traffic streams at the "T"
intersections, you would L
22 preserve a continuing flow of two parallel traffic streams i.
23 which tends.to smooth out the traffic, maintain the 24 continuity of movement and otherwise expedites traffic 4
25 movement.
1 ace FEDERAL REPORTERS, INC.
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.2110 01 01 1740 r~;ysimons l'
. JUDGE PARIS:
So keeping those-streams separated fV 2
.is maintaining continuity of flow; is that right?-
'3 WITNESS LIEBERMAN:
Right.
4 JUDGE PARIS:
Okay.
Thank you.
5 JUDGE FRYE:
This example of traffic control 6
point 57 I take it is one in which the traffic guides would 7-be expected to increase the capacity of the roadway?
8 WITNESS LIEBERMAN:
The consequence of adding 9
the second lane effectively does that.
It's not the 10 primary motivation in this particular case as it is in the 11 one-way treatment on North Country Road, but it is an 12 outcome.
'{S) 13 BY MR. SUTKO:
v 14 0
Mr. Lieberman, I want to make sure I 15 understand.
Is what happens here is that you're converting 16-two lanes into three lanes?
17 A
(Witness Lieberman)
I guess by "here" you're 18 referring to traffic control point 56; is that right?
19 0
I believe you're talking about 57.
20 A
Well, they both deal with the same section.
21 Okay, let's go to 57.
22 0
Let's look at 57.
Would you look at the portion 23 of Route 25A that is west of the intersection with Echo 24 Avenue.
25 A
Right.
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I take it~that under normal conditions that 2
roadway is a two-lane road?
3 A
That's correct.
It's quite wide there, but it's 4
a two-lane road.
1 5
O But during an evacuation'that through traffic l
1 6
guides would become a three-lane road; is that a fair i
7 statement?
8 A
That's correct.
After the traffic guides get to 9-the area and establish the cones as indicated, it would act 10 as a three-lane section.
11 Q
And there are not more than a few places where 12 you convert two lanes to three lanes; is that correct?-
(^%
13 A
This is the only section, to my knowledge.
I w/
14 have to be careful when I say that.
There are some 15 channelization treatments on the immediate approaches to 16 some intersections, but I would not consider that a three-l 17 lane treatment.
18 0
And the reason that you convert two to three is l
t 19 because the amount of traffic at this intersection is so i
l 20 heavy that you feel it's appropriate to have three lanes 1
i j
21 rather than two; is that correct?
I-22 A
No, it isn't.
I think I've said several times i
23
,that capacity was not the motivating factor for 24 establishing the three lanes.
If you look at the volumes 25 you'll find that they are not all that high in this area.
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What then is the motivating factor?
k j-
~
2 A
Well,-I think I've said it several times.
It's
-3 to ---
4 0
Bear with me, Mr. Lieberman, because I'm trying 5
to get it.
6 A
Well,.it's to maintain the continuity of 7
movement for two traffic streams which otherwise would 8
converge to form one traffic stream, and then diverge a 9
couple of thousand feet later to once again form two 10 traffic streams.
11 O
Would you please define for me the rate of flow?
12 A
Well, definitionally the rate of flow has the
}
units vehicles per hour and it describes the number of 13 14 vehicles that pass a point or travel along a homogeneous 15 section of highway in a given unit of time under the-16 prevailing conditions.
It represents demand so long as 17 that demand is less than capacity.
Otherwise it represents 18 capacity.
19 0
And I take it that there are a number of things 20 that can influence rate of flow; isn't that correct?
For 21 example, a speed limit would influence rate of flow; isn't 22 that a fair statement?
23 A
No.
24 0
So, in other words, if you had a 55 mile-an-hour 25 speed limit on a completely empty roadway and a 35 mile-an-ACE FEDERAL REPORTERS, INC.
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~ ysimons 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> speed limit the same number of vehicles could pass 2
along that roadway.
Is that a fair statement, Mr.
3 Lieberman?
4 A
Yes.
I would say, putting it another way, that 5
the capacity of that roadway having only the speed limit 6
sign as a difference would be about the same.
7 0
Sir, my question though was not about capacity.
8 I know that's a differently defined term, as I'm sure you 9
do.
My question goes to rate of flow, and I would 10 appreciate, if you could, if you can answer that question.
11 A
I've already defined rate of flow, and I'll say 12 it again.
()
13 0
That's not necessary, sir.
My question is if v
14 you had a 55 mile-an-hour speed limit sign and a 35 mile-an-15 hour speed limit sign, are you telling me that the number 16 of vehicles that can pass that point in a given amount of 17 time would be the same?
18 A
That's right.
19 JUDGE FRYE:
So you're saying in essence that 20 administration restrictions such as speed limits do not 21 determine rate of flow or capacity.
22 WITNESS LIEBERMAN:
That's correct.
23 JUDGE SHON:
I think, Mr. Sutko, you're tossing 24 the witness a kind of a curve.
You asked him the number of rs 25 vehicles that can pass a point in a given time, and his L]
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- ysimons 1-Lmind, and stop me if I'm wrong,1 Mr. Lieberman, that's
~
2 capacity.
That isn't necessarily rate of1 flow.
3 How many cars go by a given point, the rate of 4
flow might have nothing to do with the capacity lof a 5
~ highway.
Maybe only one uses it every day..That's not a 6-function of anything, size.or speed limit.
Isn't'this
.7 correct?
8 WITNESS LIEBERMAN:
Well, it's a function of-9-
some thing, yes.- The speed advisory is not a determinant 10 of capacity,'and given that the demand is less than 11 capacity, it has no effect on'that.
Speed advisory is for 12 safety purposes.
11 3 JUDGE PARIS:
Well, if I have two stretches of
{[
14 road, one with a 35 mile-an-hour speed limit and one.with 15 an 50 mile-an-hour speed limit and I put 10 cars on each 16 road and they drive at the speed limit and I'm standing 17 down watching them go by, the ones on the 50 mile-an-hour 18 road will have a higher rate of flow, will they not?
19 WITNESS LIEBERMAN:
No, sir.
I kr.ow it's 20 intuitively satisfying to think so, but they are different 21 entities.
22 JUDGE PARIS:
They will go out the other end 23 before the others get out, won't they?
24 WITNESS LIEBERMAN:
Now you're talking about 25 speed, sir.
Speed is a measure which extends over a
\\_
I i
ACE-FEDERAL REPORTERS, INC.
l 202-347 3700 Nationwide Coserage 80)-33MM6
1.2110 01 01 1745-F^7ysimons l
' distance.
In other words, you travel a:'certain distance-
\\v' 2
and divide it by a certain and you have speed.
3 JUDGE PARIS:
Miles per hour.
4 WITNESS LIEBERMAN:l Right.
-A_ capacity is a 5
measure which is taken at a point or.at points along a 6
homogeneous section of highway, and if I could put it 7
another way, capacity is the inverse of headways.
A t
8 headway is the ---
9 JUDGE PARIS:
I'm not talking about capacity, I 10 don't think.
ill WITNESS LIEBERMAN:
I'm sorry, flow is the same 12 thing.
Capacity is a certain value of flow.
They both 13 have the same units of vehicles per hour.
}
14 WITNESS LIEBERMAN:
It's a limiting value, isn't 15 it, a flow?
16 WITNESS LIEBERMAN:
That's correct.
But the 17-flow rate can be expressed as the number of vehicles over a 18 given time.
So if you have your 10 vehicles and they pass 19 a point in say 25 seconds, they can do that both traveling 20 at 35 miles-an-hour and at 55 miles-an-hour.
They can pass 21 a point, the same number of cars can pass the same point at i
22 the same flow rate, but at different speeds.
23 What is different is the distance between the 24 cars on average.
At the higher speeds, because of the need 25 for safety, you will have a greater distance between the
}
ACE. FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800 336-6646
-'2110 01 01"
'1746 r^
cars than you will at 35 miles-an-hou'r, but the average Q 'qysimons 1
):
a 2
time between cars crossing a line, say, drawn laterally 3
across the highway would be about the same.
4 JUDGE PARIS:
Okay, because the driver's 5
allowable distance between theirivehicles at higher speeds.
6 WITNESS LIEEERMAN:
That is correct.
7 JUDGE PARIS:
All right.
Thank you.
8 BY MR. SUTKO 9
0 Let's return to traffic control point 57, Mr.
10 Lieberman, and I want to ask you a few questions about it.
11 First, I would like to ask you whether two 12 evacuation routes merge at this intersection.
(}
13 A
(Witness Lieberman)
Yes, that is correct.
14 0
And, second, I would like to ask you, in your 15' opinion, do you consider this to be a so-called critical 16 intersection?
17 A
I would not deem it to be critical.
You see, 18 the reason we have a prioritization system is because there 19 are gradations of importance from one TCP to another.
We 20 have chosen for the sake of classifying a dichotomy of 21 critical and non-critical to group a number of 22 intersections as critical and everything else is non-23 critical.
But within each group there is a gradation of 24 importance.
25 0
So is it your testimony that this is not, in
)
ace FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage mk33MM6 u.
2110 01 01 1747
,r~}ysimons 1 your opinion, a critical intersection.
2 I think Mr. Weismantle is trying to help you by 3
turning to page 11 of your testimony.
4 A
Oh, I can do it myself.
5 0
Please do that.
6 A
Right.
These two TCPs come out of the Port 7
Jefferson staging area and you will notice they are at the 8
bottom of the list.
9 0
So they are critical, Mr. Lieberman?
10 A
They way we have classified it, yes.
11 0
"We" or you, Mr. Lieberman.
I believe this is 12 only your testimony, sir.
13 A
I said "we."
I didn't say you.
I said "we."
b'~i
/
14 0
Is that the royal "we," or is that "we,"
Mr.
15 Lieberman, plus another individual?
I'm confused, sir, 16 because I thought this was solely your classification based 17 upon the answer on page 10 of your testimony.
18 A
Well, I don't use the royal "we."
19 (Laughter.)
20 When I say "we,"
I'm referring to the 21 organization KLD Associates.
22 0
Thank you.
So it's critical.
23 Do you know how long after the order to evacuate 24 went out, and assume that's 10:24, that this critical r^')
25 intersection was manned?
\\J ace-FEDERAL. REPORTERS, INC.
202 347 3700 Nationwide Cmerage 800-336 6646
-2110 01 01 1748-g ysimons 1 A
Yes, it's' noon.-
2 0
I'm sorry?
I 3
,A 56 was manned at 11:42, according to.my notes, 4
and 57.at noon.
5 0
So that.would be an hour and 36 minutes after 1
6 the. order to evacuater is that correct?
7 A
It would be completed at that' time, right.
I
(
8 Actually the folks at 56 would have set up their cones and 9
it's reasonable to expect that channelization treatment 10 would take place shortly thereafter.
11 O
Now I only have one other question about this 12 intersection which is one that you've chosen to point to, 13 Mr. Lieberman.
In fact, this is an intersection through i
14 which LILCO on the day of the exercise rerouted traffic r
15 around the fuel truck impediment; isn't that true?
16 A
No, that's not true.
I don't know how you mean l
17 routed, but the fuel truck impediment is to the east of l
18 Echo Avenue.
l l
19 0
That's correct, and is it not correct that you 20 sent traffic down Echo Avenue, sir, in the LILCO rerouting 21 to Route 25A from whence it traveled westward?
l 22 Perhaps Mr. Weismantle can help you.
l l
23 A
That's true.
l l
24 0
So, in fact, this was the method through this 25 critical intersection that LILCO chose to use to reroute O
Ace FnDERAL REronTens, INC.
202 347 37(X)
Nationwide Cmcrage lux).3364M6 i-
2110.01 01 1749 ysimons 1 traffic around the fuel truck; isn't that a fair statement?
2 A
I don't know what you mean by "this method."
3 Why don't you rephrase it.
4
.0 It was part of the rerouting scheme, isn't that 5
correct?
6 A
No.
7 0
The. traffic that was rerouted, Mr. Lieberman, 8
was rerouted from Route 25A.
That was the normal 9
evacuation route they would travel; isn't that correct?
10 A
That is correct.
11 0
And the traffic that was rerouted around the 12 fuel truck impediment rejoined Route 25A at the l
(L /~)
13 intersection represented by TCP 57; isn't that correct?
1 14 A
That is quite right.
15 0
And I take it what they would have done, just so 16 we can close out on this quickly, is they would have come l
l 17 in a southwesterly direction down Echo Avenue and made a i
l 18 right-hand turn onto Route 25A; is that right?
19 A
They would have borno right on Route 25A; that 20 is correct and probably would have used both lanes since 21 thoro is no through traffic from Route 25A itself.
l l
22 0
That's correct.
Now if they had followod their 23 original evacuation route would they have boon traffic that l
24 would have boon directed into the left-hand lano looking at 25 the intersoction of Echo and Route 25A in a wasterly Aci Fiti>tinal. RileonTitus, INC.
202 347 3700 Nationwide Coserage m)-33MM6 i
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'2110101 Ol' 1750
- r^jysimons 1-direction.
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'2 Place yourself where the most westerly traffic
~
3 guide is.
Do you see the point I'm referring to?
4 A
Yes.
5 Q
Looking westward, would they have wanted to be 6
in the left-hand lane under the normal evacuation route or 7
in the right-hand lane?
8 A
No, they would have been channelized into the 9
left-hand lane.
10 0
Now, Mr. Lieberman, I take it then if LILCO had 11-wanted to establish a rerouting scheme in a real emergency 12 like the one they established on the day of the exercise 13 around the fuel truck impediment, there would have been no 14 traffic guide at traffic control point 57 until 12 o' clock 15 to facilitate that rerouting; isn't that a true statement?
16 A
It's conjectural.
It might have been true, but 17 it might not have been.
I assume that you're making a 18 hypothesis here that the impediment would have been 19 detected at a time earlier than it was during the exercises 20 is that correct?
21 Q
Now lot me make sure I understand what your 22 belief on that is.
Do you think that the impediment 23 actually wouldn't havo boon discovorod until perhaps ono 24 o' clock which is when LILCO discovered it on tho day of the 25 oxorciso?
O Acit Fl!DERAI. RimonTrins, INC.
202 347 37tX)
Nationwide Canetage N(Xb31MM6
2110 01 01 1751 r~;ysimons 1 MR. ZEUGIN:
Objection, asked and answorod.
Wo 2
went over this all on Contention 40.
3 JUDGE FRYE I think we have boon over this one
'4 to some degroo and I also think it's in the record quite 5
clearly that this traffic control point 57 was not manned 6
until 12 o' clock, and we cortainly have it in the record 7
when the impediment was intorjected into the oxerciso.
8 MR. SUTKO:
Thank you, Judge Frye.
9 BY MR. SUTKO:
10 0
Mr. Lieberman, let's turn back to traffic 11 control point No. 1 briefly, and I would like to discuss 12 with you some decisions, at least in terms of common senso, 13 it scoms that the traffic guido could help facilitate.
14 Do you soo traffic control point No. 1, sir?
15 A
Yes, I do.
16 0
And you're looking at the schomatic?
17 A
Right.
18 0
That ovacuation route traffic would be coming 19 down in a southwesterly direction along Lower Rocky Point 20 Road toward the intersection initially; is that correct?
21 A
I would expect some traffjc would be coming from 22 thoro, right.
(
23 0
And a driver in a car that would bo making a 24 decision as to what to do with that intersoction would havo 25 a number of choicos, wouldn't ho?
And the first choico Aci! 17 ntinai. Rimoniitas, INC.
ti
(
202.mmm N.uion*Ide Cmcrag km-U6 u,46 L - - -- -- - - -
2110 01 01 1752 ysimons 1 that he could choose, isn't it correct, is to make a right 2
onto Sound Beach Boulevard?
3
.MR. ZEUGIN:
Judge Frye, I'm going to object to 4
that question, and the reason is I think we are now 5
straying from what happened on the day of the exercise to 6
perhaps revisit a lot of the earlier planning litigation.
7 It would seem to me that at the outset of his 8
question Mr. Sutko basically said that for the purposes of 9
the questioning we would assume that the treatments were in 10 place and doing what they wore supposed to do.
11 Behind all of this basically are the evacuation 12 routes that I believe Mr. Lieberman has explained.
So to 7'5 13 talk about peoplo's options at givo intersections strikes V
14 me as revising whether people will follow their assigned 15 evacuation routes, which is a subject we have litigated 16 previously in the plan litigation.
17 MR. SUTK0:
Judge Fryo, may I speak briefly?
18 This goes to the heart of the dispute betwoon Suffolk 19 County and Mr. Linborman.
Nowhere in LILCO's plan does it 20 stato that there are so-called critical and non-critical 21 traffic control points.
They list thom in a spectrum, but 22 they don't have a magical cut-off rato, which is the basis 23 for ---
24 JUDGE FRYE:
I'm sorry, they don't have a what?
I 25 MR. SUTK0:
A cut-off rato at nomo point in tho r
i i
Acit FritninAL Riti>onTitns, INC.
202.m&W Nadonwide Cmerage Mm 34&#i
2110 01 01 1753 r gyoimons 1 plan which says you now stop having critical TCPs and you V
2 are now into non-critical TCPs.
And it's those non-3 critical TCPs which Mr. Lieberman attempts to discount in 4
his testimony, the lato arrival at the intersection, and 5
this is one of them.
At this one, for example, the man did 6
not arrivo until 12:30.
7 I'm attempting to demonstrate through cross-8 examination that overy TCP is important, and in fact this 9
traffic guido at this intersection is going to help pooplo 10 move more quickly potentially through this intersection 11 through hand and arm movomonta and letting them know which 12 direction they have to go so that they don't have to mako
(}
13 decisions and they don't havo to slow down to think.
You 14 minimizo blockagos at this intersoction and you can 15 increaso the rato that ovory singl.o person gets out of the 16 EP2, which la the crux I think of public hoalth and safoty.
17 JUDGE FRYE Aro you going to do that with all 18 of the non-critical TCPs or just this ono?
19 MR. SUTKO No, sir.
This is a very simplo TCP 20 and I think that I can ask Mr. Lioborman that question.
21 It's as simplo as any of tho 130 TCPs.
It has no conos; it 22 has nothing.
I want to discuss this one in como detail and 23 briofly look at a few others just to establish what timo 24 they arrived.
l 25 JUDOC PRYC:
Holl, wo'vo got the timos they l
s-i l
Aci!.I l!DiiRAI, IlliPORTI!RS, INC.
l t
202.,147 37(o Nationwide Coscrage Mu t 316 (M6
l 2110 01 01 1754 ysimons 1 arrived.
There's no question about that.
I think that's a 2
reasonable inquiry, but I think if you're taking this one 1
3 as a simple one, it would seem to me that you could
'4 probably make your point without having to go through a 5
lengthy examination involving a lot of TCPs.
6 BY MR. SUTKO:
7 Q
Mr. Lieberman, I believe you have a pending 1
8 question which is traffic which is traveling ---
9 JUDGE FRYE Let me interject myself.
10 MR. SUTKO:
Yes, sir.
11 JUDGE FRYE Could you just summarize, and if 12 you don't like this question I'll entertain an objection, 13 could you summarize the options that traffic coming down
\\
14 Lower Rocky Point Road in a southwesterly direction would 15 have as they approached this traffic control point?
16 Is that all right?
i 17 MR. SUTKO:
Yes, sir.
18 WITNESS LIEBERMAN:
Well, Judge Fryo, I think 19 when one talks about options, I think we have to 20 intersection the qualifior "roasonable options."
21 MR. SUTKO:
Can I objection, Judge Fryo?
22 JUDGE FRYE Let's do it this way.
Why don't 23 you just indicato the options and tho onon that you 24 considor unroanonablo.
Would you identify thono and why 25 they aro unroanonablo?
i Aci!.FlinitRAi. Riii>onTitas, INC.
I 202J47 3700 Nationwide Cmcrage
- n))6(M6 t
2110 01 01 1755 T"gysimons 1 WITNESS LIEBERMAN:
Certainly.
The movoment of (v) 2 traveling north on Sound Beach Boulovard is unroasonable, 3
and the reason is that Sound Beach Boulevard, as the samo 4
implies, takes you to Sound Beach.
It is not an evacuation 5
routo.
A movement onto that boulovard is contrary to tho 6
instructions which are given to the peoplo in this aroa, 7
and unless they are going up there to pick up a relativo or 8
some other rido sharing activity or going home to join 9
their family, there is no early rational and roanonablo 10 reason for them to make that right turn onto Sound Beach 11 Boulovard.
12 So the only two options which aro "roasonablo" 13 are the one that is consistent with the instructions to
(}
14 thoso peoplo to procood west along Lower Rocky Point Road 15 arid because of the fact that this is a "Y"
intersection, 16 which moans it's a non-standard geometry, thoro may be an 17 inclination for somo to go south to Sound Beach Boulovard.
18 If they do that, they will como south to Routo 25A and at 19 that point travel west on Routo 25A oventually.
20 The purposo of the guido thoro, or one of tho 21 roasons we put a guido thoro is because of the goomotry.
22 It's not a through movemont.
Somo action has to bo takon, 23 and the purpose of the guido thoro is to indicato which is 24 the action which is consistont with their instructions or 25 recommendations.
Acl 17sti) tina 1.111:1>oR rtins. INC.
l 20244Wm Nationwide Omcrayc xml% uat,
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2110 01 01 1756 r");ysimons 1 BY MR. SUTKO:
(
2 0
I have a number of questions to follow up on tho 3
specific statomonts you just mado, Mr. Lieberman.
If you 4
would like to look at the flagstrom first, that's fine, and 5
then when you've done that perhaps we can discuss this.
6 A
(Witness Lloborman)
Well, why don't you go 7
ahead.
8 0
Tno first question, Mr. Lioborman, is you have 9
just thought out for mo and for tho Board why you don't 10 want to go up Sound Beach Boulevard, isn't that correct, 11 and you havo explained it?
12 MR. ZEUGIN:
Objection to the form of tho 13 question.
I think basically "just thought out," it
(~}/
s_
14 auggests that Mr. Lioborman just thought of it this 15 moment.
I would suggest to the Board that the fact that 16 all thoso drawings woro mado and all the dotalled plan in l'7 place suggests that this was well thought out long ago.
18 That's why I object to the form of tho question.
19 MR. SUTKO I'll withdraw the question, Judge 20 Fryo.
21 JUDGE FRYE All right.
22 BY MR. SUTKO 23 Q
Mr. Lioborman, somoono who in coming from the 24 north and cast up Lower Rocky Point Road travoling south 25 and wont toward tho intorsoction whoro traffic control O
ACli Fl!Dl!RAl. Riii>ontains, INC.
202.u7 3?oo Nanonmac rmerage m im ua6 w
2110 01 01 1757 r~7ysimons 1 point No. 1 is arriving must make certain decisions,
(
)
2 mustn't he.
The first decision he must make is whether or 3
not to travel up Sound Beach Boulevard, and ho must think 4
in his mind whether or not to do that; isn't that true?
5 A
No, that's not true.
6 0
Mr. Lioborman ---
7 A
Thoso are local people.
They know the stroot 8
system, and to arguo that ovary sido stroot offers an 9
option and a major decision simply isn't truo.
10 0
If you could cito mo a treatino that you rely 11 upon, or if that's your own personal opinion, I just would 12 like to know so the record is clear.
13 MR. ZEUGIN:
Judge Frye, I'll again object.
{}
14 This is getting into tho whole question of route complianco 15 which was a planning issuo as to what routes peoplo would 16 follow while evacuating.
This was litigated in groat i
17 detail in the earlior 03 litigation as to how the pooplo 18 would solect routos and follow them.
19 JUDGE FRYE:
It sooms to mo what wo are ronlly t
20 getting into is psychology and local knowlodgo.
It's an 21 option cortainly to do that.
I guous I have probloms of l
22 whoro wo're going with that kind of a question.
I guous I i
l 23 don't nuo the rolovanco of it ron11y to this inquiry.
24 MR. SUTKO:
I boliovo that Mr. Lioborman will 25 agroo with mo that thoro are olomonts of psychology in tho l
ACli.FitniinAi. Ili i>onTrins, INC.
202.m Moo Nanonwkfe Gna.we W Ut> (Mi
2110 01 01 1758 r^7ysimons 1 implomentation of traffic control strategies.
There are
(
i
~
2 many assumptions about human nature that Mr. Lieberman has 3
made in sotting up his ovacuation time estimatos and his 4
ovacuation routes.
5 When ho set up thoso he said 130 TCPs wore 6
important.
Ile's now really trying to back off of that and 7
I'm trying to show that that is simply for purposos of 8
justifying a poor performance, and I'm trying to walk 9
through each option individuals horo havo.
10 Now having a person within clear lino of sight 11 who can direct pooplo how to go, that minimizos the 12 consciouc docicions they have to make and thorofore 13 increasing the rato of spood that thoso individuals can 14 travorno the ovacuation routes minimizing tho amount of 15 timo they are going to spond in the EPZ.
16 JUDGE FRYE Would you agroo with that 17 statomont, Mr. Lloborman, that having the traffic control 10 guido thoro minimizos the number of decisions that must bo 19 mado by a drivor?
20 JUDGE PARIS:
It would cortainly koop him from 21 having to road a map, wouldn't it?
22 UITNESS LIEUERMAN:
It's holpful, yes.
I 23 wouldn't use the torm "minimizo" bocause the driving task 24 involvos many, many decisions othor than guidanco.
25 JUDGE FRYE 11 0 has to decido ultimatoly that 1
ACit.Fitniinai. Riii>onnas, INC.
20214747m Nationwide Cmcrage No 06 (M6
e 2110 01 01 1759 ysimons 1 he's going to go or is not going to go the way the traffic 2
guido indicates for him to go, but if you have a traffic 3
guide there isn't it true that the fact that an individual 4
is there indicating that this is an appropriato way to go 5
casos the burdon on the driver of that vehicles in the 6
senso that there is someono pointing the way to him rather 7
than for him to have to say now what is the best way to go?
8 WITNESS LIEBERMAN:
I think it's hypothotical as 9
to whether it "casos the burdon."
Thoro may be no burdon 10 for most drivers in the first placo.
If they havo reviewod 11 the information which has boon provided to them, than thoso 12 drivers are confident.
13 JUDGE FRYE Let's assumo they havon't.
)
14 WITNESS LICBERMAN:
If thoro is uncertainty on 15 the part of somo drivers, than cortainly the traffic guido 16 thoro is holpful in that respect.
17 MR. SUTKO:
Judge Fryo, if I might, lot mo as a 18 real basic question.
19 BY MR. SUTKO:
20 0
Why in thoro a traffic guido hero, Mr.
21 Lloborman?
22 A
(Witnoss Lloborman)
I think I havo already 23 indicated that.
It is a goomotry which is non-standard and 24 it in a location whoro a decision has to bo mado whethor to
(~')
25 boar right on Lower Rocky Point Road or boar loft.
Wo i
Acit l'i:i)itari. Riti>ou riins. INC.
- o:w17m N.uionmae cmer.we xm wite, m
I l' 2110 01 01 1760 l
k._)iysimons 1 r~
would prefer that that traffic stream bear right.
If the l
2 guide is not there, we think the vast majority of evacuees l
3 would do so because they are familiar with the roadway
[
4 system and hopefully they would have reviewed the i
l 5
instructipns which are provided to them.
l 6
There may be some exceptions to that rule who l
l 7
will go down Sound Beach Boulevard in the absence of a l
l 8
traffic guide.
9 0
And that's your assumption, isn't that correct, 10 Mr. Lieberman, as to how individuals would go, for example,
[
i 11 on February 13th, 19867 12 A
I think it's a reasonable expectation rather 13 than an assumption.
14 I have to tell you that in many areas of the 15 country which are frequented by hurricanos, instructions l
l 16 such as those are issued and it has been found that they l
I 17 are generally well followed.
So there is some procedence 18 in the empirical world that this is the caso.
19 0
Mr. Weismantle, I would now like to return to 20 your testimony for the present at least for a differont 21 line of questions.
(
22 Would you please turn to pago 3.
Do you see the 23 statomont in your testimony, Mr. Woinmant10, whero it is l
24 nald, "unlike any other nuctoar power station omorgoney 25 oxerciso whoro partial namplos of field personnol are i
ACit.Fiiutinai. Ritvointins, INC.
20244747(o Nation 4Je Cmcrase moU6(M6 L
! 2110 01'01 1761 L)Jysimons1
(
mobilized and evaluated by FEMA, the February 13th exercise 2
involved the mobilization of all LERO field personnel."
k 3
Do you see that statement, sir?
f 4
A (Witness Weismantle)
That is correct.
l l
l 5
0 Whose decision was it to mobilize all LERO field 6
personnel?
7 A
I think LILCO decided to do that.
I think d
that's a fair statement.
I think FEMA was aware of what we I
9 were going to do, and I'm not sure of what reaction they l
10 may have had had we decided to do it differently.
11 0
In fact, Mr. Weismantle, that was solely a LILCO 12 decision, wasn't it, and it was not a FEMA decision?
O l
l 13 A
I think that's what I said, yes.
14 0
Will you now turn, please, to your next sentence j
15 of testimony where you state "Approximately a thousand 16 field workers reported to the three staging areas."
[
1 17 I take it that you have modified your testimony l
l 18 in the next two sentence in two respects.
You changed the 19 number of bus drivers to 386 and the number of ovacuation 20 route spotters to 9: is that correct?
21 A
That's correct.
22 0
When I add up all those numbers and add in a 150 l
23 percent factor, I still wind up with about 75 or 80 field 24 workors short.
Do you understand why that is?
O 25 A
I don't know why you're using a 150 percent.
Wo f
Acit.Fitniinai. Ri:Pon nins, INC.
202 uf 37m Nation *ide Cmcrave s m 336IM 6
M i
2110 01 01 1762 O
L_;ysimons 1 said 150 percent were called, not reported.
1 2
O Well, bear with me then.
When you talk about 3
1,000 field workers, you're talking only about people that 4
actually went out into the field; isn't that correct?
5 A
Well, in the sentence we say "approximately 6
1,000 field workers reported to the three staging areas.
7 We're talking about bus drivers, traffic guides, road 8
crews, route alert drivers and evacuation route spotters 9
who actually reported.
Not all of them were sent out to 10 the field.
l 11 The following sentence indicates the numbers 12 that were sent out into the field to perform evacuation i
13 related tasks.
Some of them were retained in the staging 14 area, in other wordo.
15 0
And it would be the numbers that actually went j
16 out into the field that were actually needed, or would have l
17 beon actually needed if there had been a radiological i
18 emergency; is that correct?
19 A
Given the scenario on the day of the exercise, 20 yes.
l 1
i j
21 0
so that would be the 165 traffic guides, 300 bus 22 drivers, 38 road crews, 19 route alert drivers and 9 23 ovacuation route spotterst is that correct?
4 24 A
Yes.
(
l j
25 0
Now if you'll look up at your testimony to the i
Acti Fiiniinai. Riironriins, INC.
l 202 34mm woonw6de rmerne m ur, tu, i
I
i'2110 01 01 1763 ysimons 1 clause where you state "approximately 150 percent of the J
l 2
workers actually needed were called out."
I take it that 3
those wars-the. individuals who were called out to the i
)
4 staging areas. The difference between 100 percent and 150 F
j 5
percent were the ones that were called out and reported to j
6 the staging area, but did not actually go to the field is i
7 that correct?
8 A
No.
What this means is they were called.
Now i
i 9
some calls were made and the person was ill or the person i
10 was not there or on vacation. The 150 percent does not mean j
11 that they actually reported to the staging area.
l j
12 JUDGE FRYE:
How many were called, do you f
O l
13 recall?
f 14 WITNESS WEISMANTLE:
How many were called?
Let
}
15 me see if I did that calculation.
Well, let me put it this
[
l 16 way.
How many fis1d workers were called?
I 4
t l
17 JUDGE FRYE:
Yes.
When you say "Approximately 18 150 percent of the number of workers actually needed in the 4
j 19 event of a radiological emergency were called out."
i i
l i
20 WITNESS WEISMANTLE:
Okay.
That references 1
j 21 fiold personnel, and by fis1d workers, it's those job l
l 22 classifications in the sense that start with these 165 t
23 traffic guidos, et cotera.
So the approximate number of
(
i 24 field workers who woro called is something more than a
'O 25 1,000 and probably loss than 1,100.
t 2
i i
l Acit Fl!!)l!nAl Ri!Ponri!ns, INC.
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- ommm Nanon*Me emerage m)m,u6 r
1 2110 01-01 1764 i
O l
L jysimons l' JUDGE FRYE So it's more than a thousand.
l 2
WITNESS WEISMANTLE:
As I recall, when you add 3
the numbers up, something like 140 percent of the field l
4' workers actually sent out reported.
It might be a little l
5 less than 140 percent.
l.
l 6
JUDGE FRYE:
140 percent of the ones sent out-l l
7 reported?
i l
8 WITNESS WEISMANTLE:
That's right.
9 JUDGE FRYE:
And 150 percent of the.ones sent 10 out were called?
11 WITNESS WEISMANTLE:
Approximately, yes.
12 JUDGE FRYE Okay.
Now I think I understand.
! O 13 BY MR. SUTK0:
14 0
When I add up the number of field workers which i
15 were sent out, which are the traffic guides, bus drivers, 16 road crew members, route alert drivers and the evacuation l
l 17 route spotters, I get 617.
Would you please explain to me l
18 who the other 383 field workers are that are within the l
19 1,000 figure that you cite in your testimony as reporting 20 to the three staging areas?
i 21 A
Who the others are, the difference between 617 22 and approximately 1,0007 23 0
That's correct.
24 A
I think wo did this calculation the other day, t
- O l
25 and I think the number of ffold workers who actually Acn.FnonnAi. ReconTuns, INC, 202 347 3700 Nanonwide cmcrage m)weM6
I 2110 01 01 1765 O
.L ;ysimons 1 reported was really like 968.
So the difference between 2
968, and I was conservative in the 140 percent, the 3
difference in the 968 and the 617 are those that reported 4
but were not sent out into the field.
5 0
Now your testimony, to be accurate, this 6
statement should read 968 field workers?
7 A
Doing a quick calculation the other day that's 8
what I came up with.
9 0
What documents did you use to make this quick 10 calculation, Mr. Weismantle?
11 A
The manning lists at the staging areas, the 12 lists that show who reported and when.
An example of one 13 of them would be, for instance, Attachment E-5 shows the 14 number of traf fic guides, or you can get the number of 15 traffic guides by adding the number of people who signed in 16 and so forth.
17 MR. SUTKO Judge Frye, would this be a good i
18 time for a 10-minute break or some sort of a break?
I 19 JUDGE FRYE:
Wo would liko to go for a little 20 bit longer if possible, say for about 10 minutes.
21 MR. SUTKO Yes, sir.
22 BY MR. SUTKO 1
23 0
Would you look at the last sontonco on the 24 bottom of pago 3 of your testimony, and thoro you stato, do i
25 you not, Mr. Weismantlo, that "The oxorciso provided a Am Fl!DIiRAl. RimonTiins, INC.
l 202a47 37m Naikinwide Cmcrage m MtefMi
2110 01 01 1766 L_lysimons I literal and accurate picture of the mobilization of LERO 2
field workers."
Do you see that statement?
3 A
Yes.
4 0
Isn't it true, Mr. Weismantle, that LERO field 5
workers were notified as much as five weeks in advance of 6
the exercise that there would be an exercise?
7 A
Yes, subject to check on the five weeks.
They 8
know there was going to be an exercise that day, but they 9
didn't know when they were going to be called out.
10 0
But they knew they were going to be called out; 11 isn't that correct?
12 A
Just like every other exercise.
(~T 13 0
And in fact wasn't a form sont out to every 14 potential field worker asking them to fill in a box, are 15 you going to be able to make the exercise or are you not 16 going to be able to make the exercise?
17 A
I believe prior to some of our practice drills 18 we sent out that form.
19 0
And they were asked to return that, isn't that 20 correct?
21 A
I think so, yes.
22 0
So you made sure on the day of the exercise that 23 you had field workers who know they were going to be called 24 and you knew they were available; isn't that correct, Mr.
25 Weismantle?
Acit l? nititri. Iliti>oitritits, INC.
ti 202 147 3700 Nahonwnlc Cmcrage Mut 31MM6
l2110 01 01 1767 p)
L Jysimona 1 A
I wouldn't put it that way.
We had done a 2
survey that I think, and I would have to look at the survey 3
to refresh my memory, but I think we-asked them if they 4
were going to be available for the dress rehearsals as well 5
as the day of the exercise and so forth.
That's the only 6
comment I would make on it.
7 JUDGE PARIS:
How many dress rehearsals?
8 WITNESS WEISMANTLE:
Well, there were a couple 9
of practice drills that were held and we did term them 10 dress rehearsals with the Shift 1 personnel plus field 11
. workers who would participate in the graded exercise.
12 I think, as I indicated in the previous O
V 13 contention, a group of our workers are on three shifts. So 14 those are the people whom man their posts where the posts 15 have to be manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, such as the EOC and the 16 supervision in the staging area.
Then the rest of them, 17 the field workers, are just one group of about 150 percent 18 of what is needed to service a full 10-mile evacuation.
19 JUDGE FRYE:
Mr. Weismantle, if I were one of 20 your traffic guides and I got your questionnaire and I said 21 I wouldn't be available on February the 13th, what would 22 happen?
23 WITNESS WEISMANTLE:
I'm not sure. I would have 24 to refresh my memory about the documents that were sent
'l 25 out.
Well, I'm going to have to refresh my memory about ACE FEDERAL REPORTERS, INC.
202-34L3700 Nationwide Coverage 800-336-6646
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)
11 L;)ysimons 1 these.
2 JUDGE FRYE:
Isn't it true that the organization
- 3' LERO would have put an awful lot of pressure on these 4
people to be available?
5 WITNESS WEISMANTLE:
No, not at all.
6 JUDGE FRYE:
'I mean here is the FEMA exercise of 7
your plan and if they decide not to show up you're not 8
going to do too well.
9 WITNESS WEISMANTLE:
No, I don't think so.
I.
10 think that questionnaire sent out to all workers and not 11 just field workers,-for instance, and if somebody, as in a 12 couple of cases I think had a long-planned vacation for 7_
U 13.
that period, and as a matter of fact, I-think there are a 14 couple that I can recall, we just wanted to know about it 15 ahead of time.
16 JUDGE FRYE:
So if someone said they were not 17 going to be available, you would want to know why?
18' WITNESS WEISMANTLE:
I don't think we wanted to 19 know why.
I don't think we asked why.
Frankly, I'm going 20 to have to review the documents to refresh my memory as to 21 the context of those questions we asked.
22 JUDGE PARIS:
We have seen copies of that 23 document.
I don't know who gave it to us, but it's in some 24 of the big ones we collected.
I remember it.
25 MR. SUTKO:
Judge Paris, they are in the ACE FEDERAL REPORTERS, INC.
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2110101 01 1769
('
. L_.tysimons I record.
Suffolk County entered them so that the record-2 will be clear as to what was asked and the lines to fill in 3
'why you're not available and so forth.
4 MR. ZEUGIN:
Maybe I can clear up what is in or 5
out of the record.
If I recall correctly,.they were marked 6
as exhibits in Contention 41, but that particular subpart 7
of a three-part exhibit was not admitted into the record as 8
I recall, if my recollection is correct on that particular 9
document.
10 JUDGE PARIS:
The subject that we are on right 11 now is a good point for me to ask a couple of questions 12 that I would like to ask, if I may.
13 Can you tell us how traffic guides are assigned 14 to their posts?
15 WITNESS WEISMANTLE:
They are assigned to their 16 posts in order of which they are dispatched to the field.
17 In other words, if you've got a group that is given a job 18 briefing, a group of 15 people, the packets are handed out, 19 the first packet for the first assignment is given to the 20 first person and the second packet for the second person.
21 This is all done in order of manning priority as set forth 22 in the plan and procedures.
23 JUDGE PARIS:
So the first guy who shows up gets 24 your top priority?
( )
25 WITNESS WEISMANTLE:
That's right.
ACE FEDERAL REPORTERS, INC.
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'2110 01-01 1770 L_)ysimons 1
' JUDGE PARIS:
Then I take it that a given 2
. traffic guide is not always assigned to the same post.
3 WITNESS WEISMANTLE:. Not at all, and it's at 4
random.
5 JUDGE PARIS:
And you make no attempt to assign 6
them to areas that th-ey are familiar with?
7 WITNESS WEISMANTLE:
No.
A given traffic guide 8
could be assigned to any post, depending on where he is in 9
the briefing order.
10 JUDGE PARIS:
Okay.
Thank you.
11 JUDGE FRYE:
You have, I gather, these same 12 individuals as a group who are traffic guides that would be 7
k 13 assigned to Port Jefferson, Riverhead, et cetera?
14 WITNESS WEISMANTLE:
That's right.
They are 15 broken down by staging area, but that's as far as it goes.
16 JUDGE FRYE:
By staging area.
17 WITNESS WEISMANTLE:
Yes.
18 JUDGE FRYE:
So that they have within their 19 respective areas some continuity?
20 WITNESS WEISMANTLE:
Yes.
21 JUDGE FRYE:
But they do not have any continuity 22 with respect to their particular assignments?
23 WITNESS WEISMANTLE:
That's right.
24 JUDGE FRYE:
Now are the people who serve in O
25 these positions people who work in those areas?
ACE FEDERAL REPORTERS, INC.
i 202-347-3700 Nationwide Coverage 800-336-6646
1 1
L 2116$51 '01::
1771 L 1("y L_jysimons 1 WITNESS WEISMANTLE:
Generally theylare assigned 2'
to staging l areas by proximity to'home' address.
3 JUDGE FRYE:
Rather than.to company assignment.-.-
'4
' WITNESS WEISMANTLE:
Rather than work location, 5
yes.
6 MR. SUTKO:
Judge Frye, if I may ask one follow--
7 up question on the last one.
8 BY MR. SUTKO:
9 0
In. fact, Mr. Weismantle, you have people that-10 live in the City of New York that act as field personnel,-
11 don't you?
12 A
(Witness Weismantle). There are some, I believe,
.O
. 13 yes.
14
-0 And there.are substantial numbers that don't t
I 15 live.in Suffolk County as well?
1-16 A
A lot of workers live in Nassau.
I don't recall
- 17
-the breakdown any more.
I think that was done over in the 18 first set of hearings.
I 19 0
Just one final question, Judge Frye.
20 And, in fact, some of those people not only 21 don't live in Suffolk County, but they don't even work in
[
22 Suffolk County, do they?
23 A'
That's right.
Some of them work in Nassau 24 County.
(
j 25 0
So they are not necessarily familiar with the 1
}
14CE FEDERAL REPORTERS, lNC.
202-347-3700 Nationwide Coverage 800-336-6646
2110 01.01-1772 L.jysimons 1 roadways in the 10-mile EPZ;.isn't that true, Mr.
2
.Weismantle?
3 A
Well, I would say they certainly gained a 4
familiarity through participation in LERO drills.
5 O
For example, let's look at Port Jefferson.
I 6
think that's Attachment C, is that correct, to your 7
testimony?
8 A
Yes.
9 O
There are 58 traffic control posts in the Port 10 Jefferson staging area, correct?
11 A
I think that's right, yes.
12 O
Prior to an order to evacuate the best any 7_
13 individual traffic guide in Port Jefferson could know is
~
14 that he might be assigned to one of those 58 traffic
'15 control points; isn't that true?
16 A
That's right.
17 O
Are you trying to suggest to this Board that 18 each of the traffic guides in the Port Jefferson staging 19 area is familiar with the roadways of each of these 58 20 traffic control points?
21 A
No, I'didn't say that.
22 O
In fact, for those individuals who live outside 23 of Suffolk County, which you testified is a large group, 24 they may be aware of a few or none, to your knowledge, e
O-25 isn't that correct, Mr. Weismantle?
ace FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800-336-6686
2110:01 01 1773 py 9t_}ysimons 1 MR. ZEUGIN:
Objection, Judge Frye.
It'seems to 2
me we are now getting into the whole area of training and 3
training related issues.
I mean the packets that these 4
drivers are provided when they are dispatched were all-5-
litigated previously ---
6 JUDGE FRYE:
I 'think we have got the picture on 7
this one.
8 Do you want to break at this point?
9 MR. SUTKO:
If that's fine-with the Board.
10 JUDGE FRYE:
Why don't we break for 15 minutes.
11 (Recess taken.)
12 JUDGE FRYE:
Are you ready to begin?
13 MR. SUTKO:-
Yes, sir.
14 MR. MILLER:
Judge Frye, if I might just very 15 briefly.
I told the Board this morning I would try to make 16 contact with the Stuffolk County Police Witnesses regarding i
17 the rebuttal on Cchtention 41 which we discussed possibly 18 doing on Monday af ernoon.
19 I maybe have used up my good will with the 20 Suffolk County Police Department, but it looks like the 21 four members of that Department can rearrange some 22 schedyles and activities and be available for Monday 23 aftefnoon.
e 24 JUDGE FRYE:
Are those four officers going to be p[
t 25 back on another panel?
ACE-FEDERAL REPORTERS, INC.
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21.10'01 01-1774 L lysimons 1 MR. MILLER:
The plan right now, Judge Frye, is 2
it looks as though Mr. Sutko would finish hopefully by the
~3 lunch break or so. Monday and the-then the same four members
~4 of the Suffolk County Police would be up on Contention 40..
5 JUDGE FRYE:
That's what I thought.
6 MR. MILLER:
I guess what we are going to do is 7
instead of them being around for a couple of hours or 8
whatever Mr. Zeugin's cross takes, they will stay around 9
and be available to hear Mr. Lieberman on the questioning 10 regarding the rerouting of the fuel truck impediment and 11 also be available to go back up to rebut Mr. Lieberman-if
~
12 that's necessary.
'~#
13 So they will rearrange schedules to be available 14 Monday afternoon.
So I think we can close out the issue 15 that day.
That's all premised on the limitations of the 16 rerouting-around the fuel truck impediment because that is 17 what I'm going to prepare those witnesses to discuss.
18 JUDGE FRYE:
Surely.
19 MR. SUTKO:
Judge Frye, I would first like to 20 move into evidence Suffolk County Exercise Exhibit 26 which 21 we referred to prior to the break.
22 JUDGE FRYE:
26 being the traffic control point 23 diagrams?
24 MR. SUTKO:
Yes.
O 25 JUDGE FRYE:
Mr. Pirfo is not here.
Why don't ACE FEDERAL REPORTERS, INC.
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2110 01-01 1775
[)
L_ ysimons 1 you just hold it until he comes back.
2 MR. SUTKO:
The second thing I would like to do 3
is that previously we discussed that I was to have a 4
pending question to Mr. Lieberman to identify traffic 5
control. points on page IV-9 through 21 and IV-29 through 51 6
of LILCO Appendix A by Monday to make sure that he and I 7
had an understanding of which particular nodes.or which 8
traffic control points so that we then could write 9
findings.
10 JUDGE FRYE:
Right.
l 11 CROSS-EXAMINATION (Resuming) 12 BY MR. SUTKO:
O 13 O
Mr. Weismantle, I think at the break you and I 14 were discussing whether or not the exercise provided a 15 literal and accurate picture of the mobilization of LERO 1
16 field workers.
Do you remember that discussion?
17 A
(Witness Weismantle)
Yes.
18 0
I take it here by " mobilization" you mean the 19 same definition that we have used throughout the Contention 20 40 discussion which would be the mobilization process 21 ending as of the time they reach the traffic control 22 points; is that correct?
23 A
Yes.
24 0
Now, Mr. Weismantle, it's correct, isn't it, 25 that no LILCO traffic guide would be deployed into the ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6M6
1776 2110 01 01 7-x
~
-field until after.an order to' evacuate is given; isn't that-m 2ysimons l 2
correct? A Yes.
4 O
And in fact on the day of the exercise'I believe 5
it was as' late as 10:59 b'efore any traffic guides were 6
deployed from Patchogue; is that correct?
7 A
I would have to refresh my memory on that.-
8 0
-I stand corrected.
Dispatch began as early as 9
10:25.
f 10 A.
That's right, if that's what you mean by deploy.
11 O
And it continued as late-as 12:20;.is that t'
12 correct?
~ C:)
13 A
I think that's correct, yes, at Port Jefferson.
14 O
Now on.the day of the exercise on February 13th, 15 1986, we have'previously had testimony which you have 16 discussed with Mr. Miller concerning the fact that real 17 traffic conditions had a light traffic flow.
Do you recall 18 those discussions?
19 A
I don't specifically recall those discussions.
20 There may have been a statement made by Mr. Wilm.
21 O
I take it it's your understanding that traffic 22 that day was light; is that correct?
23 A
Well, I wasn't out in the field that day.
I 24 think we can indicate that probably it was normal.
At
()
I l
25 times it might be light, depending on what road you're on e
i.
ACE FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800 336-6M6
-, - - -.,,. -, -,,..,... -. ~., -... -
l:
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2110 01 01
.1777
()
'L.,lysimons 1 and so forth.
I think maybe.one of the traffic guides 2
radioed back at one point that traffic was light and I 3
think that's what you're recalling and that was in one of 4
the messages either attached to 41 or made part of the 5-record by Mr. Miller.
6 JUDGE FRYE:
The police have also testified, as 7:
I recall, that weather conditions were good and the 8
pavements were dry.
9 BY MR. SUTKO:
10 0
So in fact you have no reason to doubt that 11 there were not congested conditions on the roadways during 12 the February 13th, 1986 exercise; isn't that correct?
.O 13 A
(Witness Weismantle)
Could you repeat that?
14 Did you give me a double negative?
15 MR. SUTKO:
I did, and I'll withdraw the P
16
. question.
17 BY MR. SUTKO:
18 O
Just to summarize our discussion, is it a fair 19 statement to say that we assumed that it's your 20 understanding that traffic in the real world on February 21 13, 1986 during the exercise was approximately normal and 22 what it would be for that time of day?
23 A
(Witness Weismantle)
That's my understanding 24 given the weather conditions and the day of the week.
O 25 O
Now, Mr. Lieberman, I have a question for you, ACE FEDERAL REPORTERS, lNC.
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2110 01 01 1778
'q L_)ysimons 1 sir.
I believe it is your testimony, is it not, that 2
congestion in a real emergency will begin as early as an 3
hour after an order to evacuate; isn't that correct?
4 A
(Witness Lieberman)
That is correct at some 5
locations.
6 0
Mr. Weismantle, this type of congestion was not 7
faced by LILCO traffic guides in arriving at their posts on 8
the day of the exercise, was it?
9 A
(Witness Weismantle)
Since there was no 10 evacuation, there was no congestion, but traffic guides 11 would go countercurrent to evacuation traffic anyway. So I 12 don't see how that is relevant.
13 MR. SUTKO:
Just one second, please, Mr.
14 Weismantle.
15 (Pause while counsel confer.)
16 BY MR. SUTKO:
17 0
Mr. Weismantle, I would now like to turn to your 18 testimony on the first full paragraph of page 4, and there 19 you state there is no basis for an assertion in Contention 20 Ex-40 that "The mobilization of traffic guides during the 21 February 13th exercise established a defect in the plant" 22 is that correct?
23 A
(Witness Weismantle)
That's correct.
24 0
I take it that is still your testimony, Mr.
O
\\-
25 Weismantle?
ace FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Cmcrage 800-3366M6
22110 0l 01 1779 L_Jysimons 1 A:
Yes.
2 O
It's.true, isn't it, Mr. Weismantle, that the 3
FEMA post-exercise assessment, which'was submitted by FEMA 4
on April 17, 1986 found that the mobilization times for the 5
traffic guides at the Riverhead staging area were 6-deficient?
7 A
Yes, I believe so.
That was one of the 8
-deficiencies in their report.
9 O
Mr. Weismantle, it's true, isn't it, that the 10 mobilization times known for the Riverhead stage area are 11 even better than the mobilization times that we know for 12 the Port Jefferson staging area?
V 1.3 A
That's correct.
14 O
Anc to make sure we understand each other, on 15 average the Port Jefferson traffic guides got there later 16 than the Riverhead guides we know about?
17 A
Yes.
18 O
To the extent that FEMA was correct in 19 concluding that the Riverhead mobilization of traffic 20 guides constituted a deficiency, wouldn't you therefore 21 agree that the Port Jef ferson guides under the same 22 criteria should also have been found to be deficient in 23 mobilization?
24 MR. ZEUGIN:
I'll object to the question.
25 Counsel has not established a basis for that.
In fact, if ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coserage 800-334 6/ 4
2110~01 01 1780 L_jysimons 1 I recall the testimony at the end of Contention 41, Mr.
2 Miller. asked Mr. Weismantle with regard to each and every 3
one of the deficiencies found by FEMA on the day of the 4
exercise whether he agreed that those were deficiencies, 5
and if I recall Mr. Weismantle's response correctly, he 6
disagreed with all of them.
7 MR. SUTKC:
Actually, Judge Frye, Mr. Zeugin, 8
interposed a timely objection I believe which was 9
sustained.
10 JUDGE FRYE Well, I think it's fairly safe to 11 assume that Mr. Weismantle is not going to agree with 12 that.
Are you?
13 WITNESS WEISMANTLE:
No, I'm not going to agree.
14 BY MR. SUTKO:
15 0
Let me make sure that you understand my
('
16 question, Mr. Weismantle.
To the extent that FEMA was 17 correct, and I want you to assume they were correct in 18 making Riverhead a deficiency, please assume that, then 19 isn't it true that Port Jefferson should also have been 20 found to have been deficient?
21 A
(Witness Weismantle)
I don't agree with the 22 premise that FEMA was correct.
23 0
Mr. Weismantle, do you know why FEMA did not 24 find that the mobilization of traffic guides at Port O
25 Jefferson was a deficiency?
ACE FEDERAL REPORTERS, INC.
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2110.01 01 1781
.g
-L_Jysimons 1
'A I can't read FEMA's mind on how they did not 2
' reach a particular decision.
3 0
You've-never had any discussions with anyone 4
regarding that issue; is that correct?
5 A
No, I've never had any discussions.
As our 6
testimony indicates, we think overall our mobilization 7
times were good and met a good standard, the proper 8
standard being the one of a controlled evacuation.
9 0
Mr. Weismantle, will you-please turn to page 8 10 of the FEMA report where I believe~ FEMA defines a 11 deficiency, and under that definition isn't it true that 12 for FEMA to find a deficiency they must establish both O
13 demonstrated and observed inadequacies?
14 A
In part that's what it reads, yes.
15 0
That is one of the conditions prerequisite to a 16 deficiency according to the FEMA definition; isn't that 17 correct, Mr. Weismantle?
18 A
Well, I think you have to read the whole 19 sentence.
I think the sentence speaks for itself.
20 JUDGE FRYE:
Is that one of the prerequisites 21 for a deficiency?
22 WITNESS WEISMANTLE:
I guess you could term it 23 as a prerequisite for them to find reasonable assurance of 24 health and safety was not adequate.
25 MR. SUTKO:
For public health and safety.
ACE-FEDERAL REPORTERS, INC, 202-347 3700 Nationwide Coserage 800-336-6 4 6
2110 01 01 1782
/
T
.~jysimons 1 WITNESS WEISMANTLE:
Public health and safety.
2 BY MR. SUTKO:
3 0
Now, Mr. Weismantle, at the beginning of our 4
discussions yesterday you mentioned that you had discussed 5
with staging area coordinators I believe some of the 6
results of the February 13th exercise?
Do you recall those 7
discussions?
8 A
I had some general discussions with them.
9 0
Did you ever inquire of them what FEMA did and 10 did not observe in terms of mobilization of traffic guides 11 on the day of the exercise?
12 A
No, they wouldn't have known.
I wouldn't have-(
13 had any reason to ask them.
14 O
Have you ever discussed it with Mr. Daverio?
15 A
We have had some general discussions about what 16 FEMA observed and didn't observe, but I think all those 17 documents are part of or available to you as well as to us.
18 0
Actually, Mr. Weismantle, your discussions with 19 Mr. Daverio are not available to us and I would appreciate 20 it if you would please tell me what those discussions were 21 as they relate to FEMA's observations of mobilization of 22 the Port Jefferson staging area traffic guides on the day 23 of the exercise.
24 A
I don't think my discussions with Mr. Daverio
- / \\
\\
l 25 went into that detail.
We talked in general about how FEMA ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coserage 800-336-6M6
.2110 01 01 1783' r's LdysimonsI controllers and evaluators' operated, bu't that's about the 2
extent of it.
3 O
Let me ask you a real simple question.
Do you 4
know whether FEMA observed the mobilization of traffic 5
guides in the Port-Jefferson staging area on the day of the' 6
exercise?
7 A.
When you say observed the mobilization, do you 8
mean accompanying traffic guides or waited in the field for 9
them to observe them arriving?
What part of the 10 mobilization are you talking about?
11 O
I think we have a common understanding, but 12 let's explore it to make sure.
]
13 Do you recall the portion of the FEMA report' 14 that discusses FEMA's observations of the arrival of 15 traffic guides at Riverhead?
I believe it's page 74 of the 16 FEMA report.
17 A
I have a general recollection of that.
18 0
There they stated that they observed traffic 19 guides arriving at their posts at specific times; isn't 20 that correct?
21 A
Well, not at Riverhead.
I don't think they said 22 they observed them actually arriving.
I think that was the 23 area where there was the mixup or the logistics problem I 24 described this morning.
25 JUDGE PARIS:
Are you referring to the loss of ACE FEDERAL REPORTERS, INC 202-347-3700 Nationwide Coverage 800-336-6M6
/
2110 01 01 1784
,c\\
L.dysimons1 the communicator's notes or log?
2 WITNESS WEISMANTLE:
No.
What I'm referring to 3
or as I recollect, the FEMA observer thought the traffic 4
guides should have been in the field earl'ier than they 5
were.
Whe'n they didn't arrive by the time he expected them 6
to he went back to the staging area to find out what 7
happened, and I think as a result didn't get back into the 8
field until the traffic guides that he had intended to 9
observe had actually arrived at their posts.
10 Our best information as to when they arrived at 11' their posts was the results of the LILCO observer's notes, 12 and I think it's E-7, which were based on discussions with g
13 the traffic guides in the field after they had arrived, 14 discussions that went to their recollection as to what time 15 they arrived.
16 JUDGE PARIS:
I thought you testified this
~
17 morning that the reason the arrival times were based on the 18 discussions of the observer with the TCPs was that the log 19 of the communicator who received their radio calls was 20 lost.
21 WITNESS WEISMANTLE:
Well, that's right.
If 22 that log had been available we would have used that to 23 establish when they arrived at their posts.
But since it 24 was lost, we had to use the notes of the LILCO who O
25 accompanied the FEMA evaluator that day.
ace. FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-(M6
2110 01 01 1785 e
m_iysimons 1 JUDGE PARIS:
Okay.
2 BY MR. SUTKO:
3 O
Mr. Weismantle, I believe you have before you 4
Suffolk County Exercise 25 which has been moved into 5
evidence in this proceeding, and what that is is it's the 6
FEMA evaluator form from a Mr. Levinson of the Riverhead 7
staging area.
8 A
(Witness Weismantle)
I don't know if we have 9
that here now.
I think we probably left that back in the 10 room.
11 MR. SUTKO:
I believe Mr. Zeugin may have a copy 12 he can provide to you.
I,s\\
'~'
13 BY MR. SUTKO:
14 O
Now I'll ask you, doesn't Mr. Levinson under 15 Comments and Recommendations state "they" meaning traffic 16 guides " arrived at their post between 11:50 and 12:10"?
17 A
(Witness Weismantle)
Ye s.
That was covered 18 this morning.
That's right.
Just to draw a distinction, 19 it's my understanding that this was drawn up after the 20 fact, that is, he didn't write this in the field.
It's not 21 his field notes.
It's a form that used as part of the 22 process of developing the post-exercise assessment.
I just 23 don't know when he wrote this down.
24 O
Mr. Levinson had some instructions on the form O
25 as to what he should put down under comments and ACE FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coserage 800-336-(646
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2110 01 01 1786 L_lysimons 1 recommendations; isn't that correct?
In parentheses it 2
states " Factually describe your observations."
3 A-Yes.
4 0
And then he states in the very first sentence of 5
his form, does he not, that he observed eight traffic 6
control posts or points in the Riverhead staging area?
7 A
That's right.
I'm sure this is Mr. Levinson's 8
best record of his observations.
9 MR. SUTKO:
I would now like to show you Suffolk 10 County Exercise Exhibit 27 which I would like to have 11 marked for purposes of identification, which is another 12 FEMA evaluator form, this one from a Mr. K. Bertram, who V
13 was located at the Port Jefferson staging area, and I would 14 ask you to please review this document.
15 (The document referred to ias 16-marked for identification as 17 Suffolk County Exercise 18 Exhibit No. 27.)
19 (Pause while the exhibit was distributed to the 20 Board and parties and the witness reviews the document.)
21 MR. SUTKO:
Judge Frye, perhaps while the 22 witness is reviewing this document it might be possible for 23 me to renew my motion to move Exhibit 26 into evidence.
4 24 JUDGE FRYE:
Exhibit 26 is the traffic control O
25 point diagrams.
ACE FEDERAL REPORTERS, INC.
l 202-347-3700 Nationwide Coserage 800-336-6M6 l
2110 01 01 1787 L jysimons 1.
Any objection to those?
2 MR. ZEUGIN:
Judge Frye, I think before I.
3 respond I would like to ask Mr.'Sutko to explain for what 4
purposes he would like to have that particular exhibit 5
admitted.
6 JUDGE FRYE:
All right.
7 Your purpose?
8 MR. SUTKO:
It would be to use it as a basis for 9
findings, Judge Frye.
10 MR. ZEUGIN:
If that's the purpose, then I have 11 an objection.
I would not object to the fact that these --
12 well, let me add a beginning caveat, and this is something
[].
13 I think we can clear up without getting into the objection 14 as such.
15 I would only note for all parties that the 16 traffic control point drawings that make up Exercise 17 Exhibit EX-26 are not controlled in the same sense that the 18 plan and procedures are controlled, that is they are 19 periodically revised.
1 20 What I would suggest, and LILCO will take it 21 upon itself in this respect, is to look at Exercise EX-26 22 and if it is not the most current set or the set that 23 basically were in place on the day of the exercise, and I 24 frankly don't know at what point in time Suffolk County got 25 this particular copy.
It may be that there are some slight ACE FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800-336-6M6
.2110 01 01 1788 L.Jysimons 1 changes in some of the traffic treatment.
2 What I am offering to do is make available, if 3
there are changes, the correct maps for the day of the 4
exercise.
4 5
JUDGE FRYE For the day of the exercise.
6 MR. ZEUGIN:
That's correct.
7 MR. SUTKO:
And my suggestion, Judge Frye, would 8
be to move this document into evidence, and then if-it 9
becomes necessary to substitute, I would be willing to do 10 that.
Mr. Zeugin is correct, we don't know precisely when 11 this document was offered.
12 JUDGE FRYE:
I would rather not, frankly, put O
13 this in and then have to change it.
I would rather get the l
14 document that is going to go in and then we'll put that 15 document in.
You are through with it for today anyway, 16 aren't you?
17 MR. SUTKO:
Yes, sir.
I may briefly use it on 18 Monday, but it wouldn't be for any extended use.
19 JUDGE FRYE:
Or you could still use it I would 20 think.
The only problem that could arise that I could 21 foresee is if you relied on a particular point in your 22 cross-examination that happened to have been changed.
23 MR. SUTKO:
I certainly would like to know 24 that.
This was not a discovery provided pursuant to
'(
25 discovery requests although, frankly, Suffolk County thinks ACE FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage M)-336-6646
'2110 01 01-1789
( --
L_Jysimons 1 it-should have been.
We think it was responsive to a 2
number of discovery requests.
But I would like the 3
opportunity to conduct cross-examination with the relevant 4
traffic control points so that two weeks from now we don't 5
discovery that in fact this is incorrect and requires a 6
motion to bring a witness back.
7 So I would ask Mr. Zeugin if it would be 8
possible in the next three days if Mr. Lieberman could make 9
that determination.
10 MR. ZEUGIN:
I have no problem with that, Judge 11 Frye.
12 JUDGE FRYE:
So on Monday morning we'll have 13 that.
14 MR. ZEUGIN:
That's right.
Do you want to hear 15 my real objection to the admission of this at this point or 16 would you rather wait until Monday morning?
As I say, that i
17 was merely, in my view, an administrative point.
18 JUDGE FRYE:
I see.
What's your real objection?
19 MR. ZEUGIN:
Judge Frye, I don't object to the 20 admission of this exhibit for the purposes of describing 21 the various traffic treatments that occur at given traffic 22 control points as a result of the LILCO plan.
23 What I do object to is if this document is going 24 to be used in " findings" to argue that given traffic 25 control points within this document are "important" or "not ACE-FEDERAL REPORTERS, INC.
1 202 347 3700 Nationwide Cmerage 800-336-6M6
2110 01 01 1790 I
L ;ysimons 1 important," particularly if witnesses have not been 2
questioned on them.
I have no problem with admitting 3
specific traffic control points that we have discussed 4
here.
5 My concern is if we admit this and all it's 6
parts, then there may be a number of issues raised in 7
" findings" that will not have been fully aired by all 8
parties and people given reasons to explain why given 9
points were important or not important.
10 MR. SUTKO:
Judge Frye, I guess the only 11 alternative to the one that Mr. Zeugin implicitly is 12 suggesting is that I ask Mr. Lieberman about each of the
,,)
13 130 documents and, frankly, I think that would be 14 advantageous to the County's position, but I'm willing to 15 forego that if Mr. Zeugin is willing to have these 16 introduced into evidence.
I think that will prove to be an 17 extremely time-consuming effort.
18 JUDGE FRYE:
I think it would prove to be 19 extremely time consuming, and I'm not sure how beneficial 20 it would be in the long run either.
You are not likely to 21 rely on 130 of them, or are you?
22 MR. SUTKO There are so many.
Judge Frye, I 23 would say that I can't say definitely one way or the 24 other.
I certainly think there is a distinct possibility O
25 that we might and that we may very well rely upon ACE FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Canerage 8m346M6
l.
l 2110 01 01 1791 gs, sL Jysimons 1 substantial number of these.
l
-2 JUDGE FRYE:
Let me suggest this.
Why don't you 3
two confer and see if there is some way you can work this l
l 4
out and we'll take it up again first thing Monday morning.
l 5
MR. ZEUGIN:
That's fine, Judge Frye.
6 BY MR. SUTKO l
l I
7 0
Mr. Weismantle, you've had an opportunity to 8
review and I think do some figuring there.
Let' me ask you, l
9 it was Mr. Bertram's responsibility on the day of the 10 exercise, was it not, under Field Objective 6 to determine i
11 whether access control points for the Port Jefferson l
i 12 staging area were established and manned by traffic guides O
13 in a timely manner?
l l
14 A
(Witness Weismantle)
Yes, that's what this 15 document indicates.
16 0
Looking at Suffolk County Exercise Exhibit.27, l
17 Mr. Weismantle, do you note that under the Comment Section j
18 where Mr. Bertram is supposed to have actually described 19 his observations that he states "Due to a two and one-half 20 delay at the evacuation impediment location (see Field j
i 21 Objective 10) the timeliness of establishment of traffic l
22 control points (TCP) could not be observed and evaluated"?
l r
23 A
That's what it says, yes.
i 24 0
As a result it was impossible for FEMA under its O
25 definition of deficiency to rate the Port Jef ferson staging
{
{
l ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Cmcrase 800 33MM6 l
2110 01 01 1792
(~h area mobilization of traffic guides as deficient on the day L lysimons 1 2
of the exercise.
Isn't that a fair statement?
3 A
They didn't evaluate it because they didn't 4
observe it, yes, that's correct.
5 0
Mr. Lieberman, the reference there to an 6
impediment would be to the fuel truck impediment; isn't 7
that correct?
8 A
(Witness Lieberman)
When you say "there," where 9
are you referring to?
On this exhibit?
Given that he's 10 assigned to the Port Jefferson staging area, that would 11 follow.
12 JUDGE PARIS:
Could I ask, why was he delayed 0
13 for two and half hours at the evacuation impediment 14 location?
15 JUDGE FRYE Do you know?
16 WITNESS LIEBERMAN:
I don't know.
17 JUDGE PARIS:
It wasn't because there was a real 18 impediment, was it?
Was he assigned some other duty at 19 that point or some other observation to make at that point?
20 WITNESS WEISMANTLE:
I presume he was involved 21 in the fuel truck impediment and waited until we got route 22 alert drivers there and so forth and, as you'll recall, our 23 response was delayed because of the communication problem i
24 in the EOC.
So I assume he just waited there and observed i
25 the responders when they finally arrived.
j ace. FEDERAL REPORTERS INC.
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[ 'L_.jysimons~1 JUDGE PARIS:
Okay.
Thank.you.
2 BY MR. SUTKO 3
0' Mr. Weismantle, so the record is clear, when you 4
talk about communication problems at the EOC you're 7 -
5 speaking about LILCO communication problems and not FEMA 6
. communication problems; is that correct?
l 7
MR. ZEUGIN: -Objection.
It's really Contention l
l 8
41 material that we have already covered.
9' JUDGE FRYE Yes, I think we've covered those l
10 problems thoroughly.
l l
11 MR. SUTKO At this time, Judge Frye, I would l
12 like to move Suffolk County Exercise Exhibit 27.into 13 evidence.
14 JUDGE FRYE Any objection?
P l
15 MR. ZEUGIN:
No objection.
16 MR. ZAHNLEUTER:
No objection.
l l
17 MR. PIRFO No objection.
i 18 JUDGE FRYE So ordered.
i i
e j
19 (Suffolk County Exercise 20 Exhibit No. 27, previ'ously 21 marked for identification, I
22 was admitted into evidence.)
i 23 BY MR. SUTKO:
I 24 0
Mr. Weismantle, would you please look at the O
25 last sentence of the first full paragraph of your testimony l
/\\CE. FEDERAL REPonTERs, INC.
202 347 3700 Nationwide Cmcrage M43%M46
2110 01 01 1794 L Jysimons 1 on page 4.
And there it states, does it not, "Thus, the i
2 critical focus, a focus missed by the contention, should be 3
on the time needed to complete the entire mobilization 4
process"?
5 A
(Witness Weismantle)
That's correct.
6 O
And I take it that your conclusion that Suffolk 7
County has not focused on the entire mobilization process 8
at the time you wrote this was based solely upon our 9
Contention 40; is that correct?
10 A
Yes, I think that's fair.
11 0
Have you read Suffolk County's testimony on 12 Contention 40, Mr. Weismantle?
k 13 A
No, I haven't read any Suffolk County testimony.
14 0
So, in fact, you don't know whether that 15 testimony does focus on the entire mobilization process; is
^
16 that correct?
17 A
No, I don't.
18 O
So as we sit here today, at least as f ar as you 19 know, it may be that the County has now spent pages and 20 pages focusing on the entire mobilization process; isn't 21 that correct?
22 A
Again, I didn't read your testimony.
When this 23 testimony was prepared, obviously all we had to go on ---
24 JUDGE FRYE:
You're asking him to speculate
( ]^ '
25 basically.
He doesn't know.
t
(
ACE. FEDERAL REPORTERS, INC.
1, 202-347-3700 Nationwide Coverage 800-336-6M6
y
- p..
t 2110'01 OS 1795
- L iysimons 1 BY MR. SUTKO:
s 1
2.
O Now, Mr. Weismantle/ I would like to ask you a 3
question regarding a question in the last paragraph 1of your testimokyonpage4., There I believe_you admit that l - 4.
I
)
mobilization of 6raffic guides. assigned to the RiverheadL 5
6, staging area may not have proceeded at an optimal level.
7 Do you see that statement?
8-A (Witness Weismantle)
That's right.
1 9
0 What do you mean when you use the word'" optimal
- id level"?
1 11 A
It could have been faster, and later on we 12
. indicate'a couple of changes and, in addition, explain at.
)-
13 least one factor at Riverhead that delayed people, or a 14 couple of factors actually.
15 0
So would you agree, Mr. Weismantle, that the 16 mobilization times of traffic guides at Riverhead on 17 February 13th, 1986 are unacceptable to the LERO 18 organization?
19 A
I wouldn't day'they were unacceptable.
I'm 20 saying that they could be improved, and we explain that 21 later in our testimony.
22 T)
Well, are they or are they not acceptable to the
. :'["
23 LERO organization?
24 A
I think I just answered that.
.m
,i h(">\\'
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~
25 0
With all due respect, Mr. Weismantle, I don't ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 800-336-6646
2 1 1 0 D0 1-.0 1 -
1796
- p:
L_.lysimons 1
- think.you did.
2 JUDGE FRYE:
I don't think you did, Mr.
3 Weismantle.
4 Do you consider them acceptable or not?
5 WITNESS WEISMANTLE:
They are acceptable within 6
the context that this contention covers, that is the 7
adequacy of the mobilization time compared to the times O
necessary to get a controlled evacuation.
9 BY MR. SUTKO:
10 0
So to make sure that I understand, you would 11 find it acceptable for the mobilization times that occurred 12' at the Riverhead staging area on February 13th, 1986 to 13 take place in a real emergency at the Shoreham Nuclear 14 Power Plant; is that correct?
15 A
(Witness Weismantle)
If it was a real 16 emergency, those mobilization times would have been 17 acceptable, but what I'm saying is we can do better.
There
-18 are a couple of things we learned and a couple of things we 19 changed to do better in the future.
20 0
Would you agree with me that the word " optimal" 21 is a word that connotes a valuativq judgment, Mr.
22 Weismantle, and I'm trying to determine what the valuative 23 judgment is that you seem to think was not optimal.
24 MR. PIRFO:
I'm going to object.
It's
\\
25 argumentative.
He asked him for his definition and now ACE FEDERAL REPORTERS, INC.
202 347 37(o Nationwi<fe Coverage 804336-6646
.2110 01 01 1797 L_Jysimons I he's quarreling with the definition.
2 MR. ZEUGIN:
I think it's argumentative, and I 3
also think any further discussion of this line is all asked 4
and answered.
I think Mr. Weismantle explained what he 5
meant by the term and answered it.
6 JUDGE FRYE:
Would you repeat your question for
.7 me.
8 MR. SUTKO:
May I withdraw my question and state 9
anoth'er question.
10 JUDGE FRYE:
You may if you wish.
11 MR. SUTKO:
That may be easier.
12 BY MR. SUTKO:
O
\\#
13 0
We determined, Mr. Weismantle, that you think 14 Riverhead's mobilization was acceptable to LERO, but you 15 say.that it may not have been optimal.
16 What is the distinction between acceptable and 17 optimal?
18 A
(Witness Weismantle)
Well, optimal to me 19 denotes a higher standard along the lines of the best you 20 could reasonably do within certain restrictions I mean 21 without going to an impractical or infeasible standard.
22 0
On the day of the exercise, do you think the 23 Port Jefferson mobilization times were optimal?
24 A
No, they weren't optimal.
25 0
Were they acceptable to the LERO organization?
ACE FEDERAL REPORTERS, INC.
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~
2110.01-01. -
1798 LL_Jysimons l' A
.Well,-we'think they.wera acceptable again within-2
~the context.of achieving something close to a controlled
~
3 Levacuation, but again there both-because of.the'way people 4
parked and had to walk down the hill and walk'back up the 51
. hill and some other factors we could do better in the
.6 future.
7 0
If a real emergency occurred at the Shoreham.
L8 Nuclear Power Plant involving a release of radiation and 9
potential. health threatening risks to the public, would you.
10 find the mobilization rates in that instance of traffic 11
' guides'at the Port 1 Jefferson' staging' area as demonstrated 12 on February 13, 1986 to be acceptable in that real
.O 13 emergency?
14~
A-I would consider them acceptable, but in'real 15 emergency, for. instance, the traffic guides and other field 16 workers wouldn't have parked in the parking lot at the 17 north end of'our property and we would have saved as much 18 as 20 to 30 minutes on these mobilization times.
19 0
Putting that assumption aside though, Mr.
20 Weismantle ---
21 A
I can't put that aside.
You asking me ---
22 JUDGE FRYE:
I interpret what you're saying, Mr.
23 Weismantle, as really saying they are not acceptable and 24 that they would be made acceptable by this change in O
25 parking arrangements.
Ace FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 800-336-6646
e 2110 01'01 1799 1
D' L.Jysimons l-JWITNESS WEISMANTLE:
Well, it wouldn't be a.
.2 change.
In a real emergency they would park down by the 3
plant.
On the day of the exercise, consistent with' FEMA 4
practice not to disrupt operations, they parked up in the 5
' north lot and walked down and then had to walk back.
6 JUDGE FRYE:
We are aware of that, but even if 7
that the time that it took.them to make the trip you
~
8 consider the times 1were acceptable?
9 WITNESS WEISMANTLE:
It's acceptable if I define 10 acceptable, as I thought I had, but the ability to achieve
-11' something close to a controlled evacuation.
As our 12 testimony indicates, given the manning times of those O
13 critical locations, the impact on the total evacuation time 14 was within 19 minutes using a conservative method of 15-calculation of the controlled evacuation.
That's within 16 the error band and the uncertainty band of the times 17' estimates to begin with.
i-18 BY MR. SUTKO:
i-19 0
Mr. Weismantle, we are going to take those 20 numbers head on on Monday, but please turn to Attachment =
21 C.
I want to make sure the record is very clear on this 22 because I think it's very important.
23 Are you saying that the arrival times which are l
24 set forth in Attachment C for Port Jefferson would be t-25 acceptable to LILCO, and by LILCO I mean you feel would b
/\\CE FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 804336-6M6 r
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2110 01 01 1800
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L_;ysimons 1 adequately. protect the public health and safety in a real 2
emergency, assuming that an order to evacuate and all other 3
conditions-that occurred on the day of the exercise were as 4
they were on February 137 5
MR. ZEUGIN:
Judge Frye, I'll object to the form 6
of the question.
On the one hand, Mr. Sutko-is asking Mr.
7 Weismantle to look at a set of numbers that include the 8
time necessary to walk up and down that hill.
.9 The question then went on, Judge, to talk about 10 in a real emergency.
I think these times Mr. Weismantle 11 would basically say would not occur in a real emergency 12 because of the fact that people didn't have to walk up and
('
13 down the hill.
14 JUDGE FRYE:
Well, I thought he testified that 15 the times were acceptable, that if you included the time 16 necessary to walk up and down the hill that they regard as 17
' acceptable.
That's the way I understood it.
18 Did I understand you correctly, Mr. Weismantle?
i 19 WITNESS WEISMANTLE:
I'm sorry.
20 JUDGE FRYE:
That the times set forth in 21 Appendix C, am I correct, Attachment C ---
22 WITNESS WEISMANTLE:
Yes.
23 JUDGE FRYE:
--- are acceptable times?
24 WITNESS WEISMANTLE:
Yes, I think they are 25 acceptable times.
ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800-336-6M6
E-
.211 01 01-1801 L lysimons 1 BY MR. SUTKO:
2 O
To make sure that I have a proper definition ---
3 1 01. ZEUGIN:
Judge Frye, where I think the 4
confusion and the purpose of my objection was I'm not sure 5
whether Mr. Weismantle is answering a question about 6
acceptable in the context of the facts as they existed on 7
February 13 or whether he would view that as an indication 8
that acceptable mobilization could occur on the day of a 9
real emergency ---
10 MR. SUTKO:
Judge Frye, I think that is ---
11 JUDGE FRYE:
I pursued that with him, Mr.
12 Zeugin.
I pursued that with him, that very point and he,_
O' 13 as I understood it, said that they were acceptable, 14 including the amount of time necessary to go up and down 15 the hill.
So I think that's the way the record stands.
16 After the weekend and after you have reviewed 17 the record if there is some question about it you can go 18 into it on redirect, but I think that's the way it stands 19 right now.
20 I think also that probably we should be winding 21 up at this point.
22 Mr. Cumming, thank you for coming, and thank you 23 for your telephone message that you were coming.
I hope 24 you didn't make a special trip.
25 MR. CUMMING:
Well, Judge Frye, I had hoped to ace. FEDERAL REPORTERS, INC.
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- 2110-01 01 1802 p
.L_;ysimons 1 be able to informally serve on everybody today FEMA's-2 written testimony.
Unfortunately, due to two things, it's 3
not going to be available until tomorrow, but I will serve 4
it by. hand on all the_ parties and Judges tomorrow-in
_ ashington.
5 W
6-FEMA was involved with a1special request dating 7
back_some period of time with respect to another power 8
plant in the State of New York and my witnesses were 9
-involved heavily with negotiations with the State this week-10 and that also caused some delay.
11 But it will be available tomorrow and will in 12 fact be served on all the parties.
13 I do understand that yesterday morning in the 14 course of the proceeding an issue cane up with respect to 15 FEMA's guidance, AN-1.
16 Counsel doesn't wish to testify.
However, I 17 have brought and I can serve informally or whatever the 18 Board would request the most recent draft of AN-1.
It is 19 expected to be finalized and issued to all regions I would 20 think essentially in the form of a draft within the next 30 21 days and certainly before the FEMA witnesses testify.
22 While in general FEMA's testimony is draf ted 23 with respect to the guidance memorandum that was in effect 24 on the day of the exercise, FEMA does understand the i
25 Board's special concerns with this guidance and our ACE FEDERAL REPORTERS, INC.
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~
2110 01 01 1803 i
L_Jysimons 1 witnesses will in fact testify, and because we think that 2
the guidance will be final before that testimony, we will 3
in fact take it upon ourselves to introduce it as an 4
exhibit.
5 It's clear, and I think I stated last week, that 6
FEMA has a great deal of concern about how the Board deals 7
with post-exercise materials or guidance and whether it's 8
going to be the general standard of relevancy or whatever 9
the standard for admission.
Basically FEMA has drafted its 10 pre-filed testimony based on what was in effect as of the 11 time of that exercise.
12 I should state that one of the concerns and the 7-
!'~'!
13 reason it's been in draft for the last six months, as I 14 understand it, is that there is a time frame in the 15 attachment which indicates a suggested compliance time 16 frame for utilities, and that has been part of the 17 discussion with the Nuclear Regulatory Commission.
18 But I have full copies, and if you would like me 19 to mark it as a FEMA exhibit and then have it authenticated 20 later, I'll defer to the Board and whatever you ---
21 JUDGE FRYE:
Why don't you informally give the 22 copies to the parties here if you have them with you.
23 MR. CUMMING:
All right.
When we're off the 24 record, then what I'll do is just provide them copies.
\\
]
25 JUDGE FRYE:
Will you be here next week or not?
ACE FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6M6
~ - _.. -
7 4
f S:
- 2110.Ol'01.
1804 n
' b)ysimons-1.
MR. CUMMING:
My intention is to be here next 4
2 week, but I'm uncertain as to exactly _the availability of my witnesses to complete the OL-3 prefiled. -We're working
~
3 4
on that-right now and if there is no conflict, I will"in 5
fact be.here.
)
6 JUDGE FRYE:
Is there any' objection from any of 7
the parties to marking this' document that Mr. Cumming is
(
,8
. going to give:you on Monday as the next FEMA exhibit for 9
identification?
{
4 t10 MR. MILLER:
No objection at'.all by Suffolk
]
11 County.
We will welcome the opportunity to explore the i
12 --
document with the FEMA witnesses.
- Q-13 JUDGE FRYE I thought we could mark it for 14 identification on' Monday morning and then when they come whoever wishes to explore it will be free to do so.
15 a
1
-16 MR. COMMING:
Judge Frye, in case I'm not here, l_
17 would it be possible to mark it this afternoon as FEMA 18 Exercise Exhibit 27 19 JUDGE FRYE Okay.
20 MR. PIRFO:
Judge Frye, if I may, Mr. Cumming is l
21 going to serve it informally ---
7 22 JUDGE FRYE:
Well he's going to mark it right 23 now.
p I
i 24 MR. PIRFO:
It might be more efficient to simply
!o 25 give it to the parties now and let them review it, and j
)
i l
ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Cmerage 800-336-6646
t
'2110 01 01 1805 ycimons 1 then, as'he said, possibly by the time the FEMA witnesses 2
appear it will be w final -- it seems to me that if it 3
becomes final between now and when the FEMA witnesses appear, you're going to have to put in the. final version 4
L 5
anyway, in which the draft goes the way of the doe-doe I 6
would presume.
7 JUDGE FRYE:
Well, he would have another 8
exhibit.
9-MR. CUMMING:
That's correct.
We have no 10 objection to placing the draft and whatever is finalized 11 our witnesses will be prepared to discuss if there are i
12 differences between the two versions.
O 13 MR. PIRFO:
Well, see that's the problem I 14 have.
I'm not sure of the effect of a draft once the final 15 is ---
16 JUDGE FRYE:
We are not admitting it. All we're 17 doing is identifying it.
18 MR. PIRFO:
Okay, fine.
P 19 JUDGE FRYEt We are not admitting it.
We are 20 just identifying it.
l 21 MR. PIRFO It's been a long week. I understand.
22 (The document referred to was l
l 23 marked for identification as l
24 FEMA Exercise Exhibit No. 2.)
O l
l 25 MR. MILLER:
Judge Frye, I know everyone wants i
i I
l ACE FEDERAL REPORTERS, INC.
.02 347-3700 Nationwide Coverage mk336 6646 I
2110 01 01 1806
,\\
/
(
)
L_mysimons 1 to go, but one last quick point.
2 I want to give to everyone Suffolk County's 3
motions to strike that came to me late yesterday from Ms.
4 Letsche on Contention 47.
I apologize.
In the crunch of S
business here these have been sitting in our work room.
I 6
should have brought them yesterday.
The certificate of 7
service say yesterday and LILCO was served yesterday and I 8
was supposed to give them to everyone else.
I'm sorry.
I 9
overlooked it and I have them now and I'll give them to 10 everyone.
11 JUDGE FRYE All right.
12 MR. CUMMING:
Judge Frye, before we go off the 13 record, I have one other minor point.
Contention Ex-40E 14 was not listed in the Order of the Board of February 13th.
15 FEMA is assuming that that in fact is going to be litigated 16 as part of the 40A and B Contention which was listed under 17 the fiell worker contention.
18 JUDGE FRYE Somebody is going to have to 19 refresh my recollection because I don't recall.
20 MR. ZEUGIN:
I think, Judge Frye, there was a 21 little bit of confusion in an earlier order because of the 22 movement of part 40C I believe back to the parts of the 23 contention, both 38 and 39.
I think both the Suffolk 24 County testimony and I know the LILCO testimony covers 40E O
l 25 in our testimony on Contention 40.
We only intend to cover ace FEDERAL REvonTuns, INC.
202 347 3700 Nationwide Coserage HO)-33MM6
2110 01 01 1807
-i
\\
L_jysimons 1 40C and Contentions 38 and 39.
2 JUDGE FRYE Does that answer it?
3 MR. CUMMING:
That contention definitely was 4
admitted and we would assume that the Board wants to hear 5
it.
It just was not listed in the order of the 13th.
6 MR. SUTKO:
Judge Frye, I think 40E goes to the 7
changes in the LILCO plan regarding traffic guides 8
subsequent to the exercise, and I believe it's in our 9
Contention 40 testimony and is what is currently the 10 subject of cross-examination.
11 JUDGE FRYE:
Good.
12 We will see you all at 9 o' clock on Monday
,,1 i' ' '
13 morning.
14 (Whereupon, at 4:03 p.m.,
the hearing in the 15 above entitled matter recessed, to reconvene at 9:00 a.m.,
16 Monday, March 23, 1987.)
17 18 19 20 21 22 23 24 (3
( _)
25 ACE FEDERAL REPORTERS, INC.
202 347 37(0 Nationwide Coserage 8(U-3346646
~ l0
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