ML20209G608
| ML20209G608 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/07/1987 |
| From: | Edward Robinson SUFFOLK COUNTY, NY |
| To: | |
| References | |
| CON-#287-3293 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8705010023 | |
| Download: ML20209G608 (140) | |
Text
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- F:<v!ct NUCLEAR REGULATORY COMMISSION BR A NC'i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the Matter of:
Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY (EP Exercise)
(Shoreham Nuclear Power Station, (ASLBP No. 86-533-01-OL)
Unit 1)
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x l'y DEPOSITION OF ELAINE D.
ROBINSON Hauppauge, New York Wednesday, January 7, 1987 ACE-FEDERAL REPORTERS, INC.
Stenotyp Rep,rters 444 North Capitol Street e
Washington, D.C. 20001 (202) 347-3700 Nationwide Coverage 800-336-6646
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UNITED STATES OF AMERICA
,JotWalsh,Rptd NUCLEAR REGULATORY COMMISSION
- Su Walsh, Typed E2355a.r ATOMIC SAFETY AND LICENSING BOARD V2956J,0 3
4 In the Matter of 5
LONG ISLAND LIGHTING COMPANY
- Docket No. 50-322-OL-5 (EP Exercise) 6 (shoreham Nuclear Power Station, :
Unit 1)
- (ASLBP No. 86-533-01-OL) y
?
8 DEPOSITION OF ELAINE D.
ROBINSON 1
9 County Attorney's Office Building 158, North County Comple:c 4
to Hauppauge, New York 11 Wednesday, January 7, 1987
'A l
12 Deposition of ELAINE D.
ROBINSON, called for examination 13 pursuant to notice, at Hauppauge, New York, at 9:00 a.m.,
14 before GARRETT J. WALSH, JR., a Notary Public in and for i
15 the Commonwealth of Virginia, when were present on behalf i
16 of the respective parties:
17 KARLA J.
LETSCHE, ESQ.
SUSAN M. CASEY, ESO.
18 Kirkpatrick & Lockhart 1800 M Street, N.W.
i 19 Suite 900, South
[
Washington, D.
C.
20036 20 On Behalf of the Intervenor, the County of j'
Suffolk 21 i
i i
22 t
I
~ _ _. _ _ _.. _. _ _,. _ _ _ _,. _ _ _ _.,. _. _ _ _. _. _, _., _, _ _. _ _ _ _.,,.., _, _..
2
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1 APPEARANCES:
(Continuing) 2 KATHY E.
B. McCLESKEY, ESO.
Hunton & Williams 3
707 East Main Street P.
O. Box.1535 4
Richmond, Virginia 23212 On Behalf of the Applicant, Long Island Lighting 5
Company 6
RICHARD J.
ZAHNLEUTER, ESQ.
Deputy Special Counsel to the Governor 7
Capitol, Room 229 Albany, New York 12224 8
On Behalf of the Intervenor, the State of New York 9
10 11 s-)
13 14 15 16 17 18 19 20 21 22 s-
3
,e
's 1
_C _O N _T E N T _S 2
3 Elaine D. Robinson 4
Examination by Ms. Letsche Page 4 5
6 7
8
_E.X_.H _I _B _I _T _S 9
FOR IDENTIFICATION 10 Robinson Deposition Exhibit Number 1 Page 9 11
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12 13 14 15 16 17 18 19 20 21 22
[v>
4 i
. P R, O_ C E_ E D, I N_' G S; Rptdj byJWalsh
.'1_
j TypedLby Swalsh
'2 Whereupon, 3
ELAINE D.' ROBINSON 4
was called as a witness and,Lhaving been'first' duly sworn, 5
was examined and testified as follows:
6
' DIRECT EXAMINATION 7
BY-MS. LETSCHE:
8 Q
Ms. Robinson, I'm_just going to state for the 9
record, my name is Karla Letsche.-
I'm with the law firm of-10 Kirkpatrick-&'Lockhart who represent Suffolk County in this 11 operating license proceeding before the Nuclear Regulatory O
12 Commission.
13 I'm going to be asking you..some questions this
~
14 morning, and if at any time you don't understand my ques-15 tion, please let me know and I.will try to clarify it for 16 you.
17 Would you state, for the record, your name and 18 address, please?
19 A
Elaine D.
Robinson, 175' East Old Country Road, 20 Hicksville, New-York 11801.
21 Q
And, what is your current position with LILCO?
22 A
It's Government Relations Representative, the
5
(~'y V
1 Office of Corporate Affairs.
2 Q
And, what do your duties entail in that position?
3 A
Among others, dealing _with local government, 4
county, towns, villages on a number of issues including 5
storm restoration, daily company operations as they affect 6
any of the localities.
7 I also am responsible for emergency planning for 8
the Shoreham Nuclear Power Plant, for virtually all of the 9
functions that are normally lumped under public affairs or 10 public information.
11 Q
Can you describe a little more what your emergency 12 planning responsibilities are?
13 A
Writing and reviewing procedure revisions, 14 participating in training, working with new personnel in 15 the organization, and actually being a player in various drills.
16 17 Q
Now, when you say working with new personnel in 18 the organization, what is the organization you are referring 19 to?
20 A
LERO, the Local Emergency Response Organization.
21 Q
And the_ writing and review of procedure revisions, 22 are those procedures relating to the LILCO off-site emergency b) u
6 fwb 1
response plan for Shoreham?
2 A
That's correct, the LERO plan.
3 Q
Okay.
And when you mentioned participating in 4
training, is that training concerning activities of LERO?
5 A
That's right.
6 Q
Your participation in training, has :that been 7
solely in the role of one of the players or one of the 8
members of LERO?
9 A
No.
Because of my experience in public affairs, 10 I have also worked with people on just general good public 11 affairs practice, answering questions, writing press releases.
O t
12 Q
Let me see if I can clarify it.
Have you conduct-13 ed any LERO training or training for other LERO personnel 14 in the public affairs area?
15 A
I have participated in the training, yes.
I've 16 never been the instructor, but I've been I guess what they 17 would call a resource person in the training program.
18 Q
Have you ever drafted or prepared materials used 19 in the LERO training programs?
20 A
No.
It has been all just oral presentation.
21 Q
And, has your participation been in panel 22 discussions and things like that when other people are m
~
7 i
O) v 1
observing?
2 A
What we call table-tops which may be what you 3
are calling a panel discussion, but they are part of the 4
training process.
It's classroom training, table-tops, 5
drills, working up to a full exercise.
6 Q
Okay.
Did your involvement in such training take 7
place prior to the February 13, 1986 exercise?
8 A
Yes.
9 Q
And, I'm talking about not as a player but in to this other role of yours?
11 A
To some extent, yes.
OO And, has it also taken place since the exercise?
12 0
13 A
Again, to some extent, yes.
It's not a primary 14 responsibility but it is one of the things that I've done.
15 Q
You mentioned that you also work with new person-16 nel in the organization.
What does that work entail?
17 A
Well, as people come into LERO or change jobs l
18 within LERO, you just have these training sessions, the l
l 19 table-tops, the many drills, full drills; and, one of the reasons for that is to familiarize new personnel, because 20 21 it's not ever a static organization.
22 0
Okay.
So, the working with new personnel is O
~=_
8 13
(_)
1 more of the training type activities we have been discussing?
2 A
Familiarization, yes.
3 Q
The new personnel which you work with, are they 4
limited to LERO personnel in the public information area?
5 A
No, because when you are working in the ENC there 6
is a lot of interaction with the LILCO on-site organization 7
so if they have new people you would be working with them as 8
well.
t 9
Q llave you participated in training sessions with 10 members of the on-site response organization?
11 A
Not since I became a member of LERO.
O 12 Q
And when was that that you became a member of 13 LERO?
14 A
I don't remember the exact date.
15 0
Was it back in '83 or '84?
16 It -- I believe it was in '85.
Prior to that, 17 I had bee.1 a member of the on-site organization.
It was 18 either '84 or '85.
I just don't remember the exact date.
19 MS. LETSCIIE:
Let's go off the record for a 20 second.
21 (Off-the-record.)
22 MS. LETSCIIE :
Let's have marked as Robinson i
9 O
1 Exhibit Number 1 this document.
2 (The document referred to is 3
marked as Robinson Deposition 4
Exhibit Number 1 for identifi-indexx 3
cation.)
6 BY MS. LETSCHE:
(Continuing) 7 Q
Ms. Robinson, is this a copy of your resume?
8 A
Yes, it is.
9 Q
And, is it true and accurate to the best of to your knowledge?
11 A
Yes, it is.
)
12 Q
I notice on here it says from May 1983 to 13 September '85 that you were on special assignment as a 14 Division Manager in the Local Emergency Response Implement-15 ing Organization.
I understand that LERIO is different from LERO, to 17 but does that in any way refresh your recollection as to 18 when you first became a member of LERO?
19 A
No.
It -- there really is no connection.
It is 20 possible to be working in LERIO and not be a member of 21 LERO.
22 Q
Why did you become a member of LERO?
O
10 0
1 A
To fill a vacancy in the public information 2
function.
3 Q
Your LERO job title is what?
4 A
At the time of the exercise, it was Public Information Staff.
It has now been formalized as Spokes-5 e
Person.
7 Q
The LERO Spokesperson?
8 A
Right.
9 Q
In that -- let's go back to the exercise for a 10 second.
Your title then was Public Information Staff.
11 During the exercise you did act as a LERO spokesperson, O
\\'l though; isn't that right?
12 13 A
That is correct.
14 O
Are there any other members of LERO who have the 15 job title of LERO Spokesperson?
16 A
YOS' 17 0
Ilow many others are there'in addition to yourself?
18 A
Currently, I believe there are two others who 19 are formally designated as that.
In their absence or my 20 absence, the coordinator of Public Information could just 21 designate another Public Information Staff person to take 22 that job if they weren't there.
But, there are two others --
O
~11 t'%
/
1 yeah, there are two others who are so designated at this 2
time, three shifts.
3 Q
Okay.
How many people are there who are part 4
of the Public Information Staff?
5 A
Without looking at the rosters, I would say there 6
are about a dozen per shift.
7 Q
Now, prior to the February 13 exercise did_you 8
know that you were going to be the spokesperson during the 9
exercise?
10 A
I knew that that would be my function if I 11 participated in the exercise, yes.
/~kT/
Q Did you know whether or not you would be partici-12 13 pating in the exercise prior to the exercise?
14 A
I expected to but I didn't know definitely.
15 Q
What would it depend on?
16 A
Well, it's my understanding that there have been 17 cases in the past where FEMA has simply, at the time of the I
18 exercise, said to certain people:
You'"e been killed in a l
l 19 car accident.
You know, the Shift 2 person come in.
l 20 So, there isn't that total certainty.
But, yes, f
2, I did expect to participate because I was Shift 1.
I l
22 Q
And Shift 1 is the primary respondent, the person
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i
12
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1 who is called first?
2 A
Not necessarily, but I did -
as I say, I expected 3
that Shift 1 would participate and that it would be me.
But 4
that's not necessarily true.
5 Q
Had you participated in sort of full-scale drills 6
or exercises that were held shortly prior to the February 13th 7
exercise?
8 A
Oh, I've participated in a number of full-scale 9
drills through the years.
10 Q
And, did -- were any of them those that were held 11 in December of '85 and January of '86?
12 A
I absolutely do not remember the dates.
There was 13 so much going on at that time that it becomes a blur.
But 14 I do know I participated in a couple of them.in the early 15 winter months.
16 Q
Did you also participate in table-top exercises I
17 in the months prior to the February 13 exercise?
18 A
I remember at least one.
I'm sure there were I
19 more.
I just remember one.
20 Q
Do you remember any other types of training or 21 other activities to prepare for the February 13 exercise in i
22 which you participated?
13 f
1 A
. Well, I had been.through-the formal classroom
~
2 training some time before I had completed the classroom 3
training,;the video tapes, the workbooks.
There were some 4
mini drills facility by facility where we exercised our 5
functions.
6 I.know I had observed other shifts participating 7
in-drills.
Again, I just cannot pin down, you know, what 8
was September, what was November.
But I.know that I had done 9
that to watch other people doing it, because you just learn 10 a lot from watching another shift doing the function.
E
. When you are doing it yourself,.you get terribly 11
,;). '
involved and you can't stand to-the side and watch yourself.
12 13 Q
In these sorts.of mini drills or other kinds of 14 drills that you had, was your performance'ever videotaped?
15 A
I think there were some instances in which we 16 used some videotape.
I know there was some training which 17 was videotaped and we did it just to get used to the camera.
1 i
18 Q
Did you ever observe your own performance on video-19 tape?
20 A
I did at one training session.
I remember seeing i
21 myself on tape and going:
Oh, my God.
4 22 O
That wasn't something that was regularly done i
I
L 14 O
1 in the training program, was'it?
2
-A-No. :It was just something, as I say, to get used 3
to having the. camera pointed at you.
A lot ~of people who 4
were participating -- and, in fact, sometimes'I have no idea 5
whether there'was actually tape in the camera or not.
It was 6
just a question of getting used to the idea that-somebody is 7
fgoing to come up and poke one in your face.
8 Q
Yeah.
When you had these, you mentioned facility.
9 by facility drills and your explanation of a mini drill.
I 10
.take it:you are referring to a drill which would involve 11 just ENC; is that right?
g 12 A
Well, I believe there were also drills that 13 involved perhaps just the EOC and oneLstaging area.
There 14 is a whole spectrum of the training process and drills are an 15 integral part of that, that go from one function up through 16 the entire facility, in and up through you know adding in 17 other facilities.
Is Q
Okay.
But there were some drills which would be 19 just involving ENC personnel?
20 A
Yes.
21 Q
Okay.
I would like to talk for a few minutes 22 about those.
In those kinds of drills, did members of the O
i 15 O
1 press or media participate?
2 MS. McCLESKEY:
Before you answer, I would like 3
to put an objection on the record.
We have been going on a 4
bit about the pre-exercise drills; and, as you know, LILCO 5
has a standing objection.
It is irrelevant to the training 6
information, that it happened before the exercise.
7 I'm not going to instruct you not to answer, but 8
I would like to note for the record a continuing objection.
9 MS. LETSCIIE:
Okay.
10 BY MS. LETSCHE:
(Continuing) 11 Q
Do you remember the question?
12 A
Would you just --
13 Q
I will rephrase it.
In the mini drills involving 14 the ENC that you referred to earlier, did members of the 15 press or media participate in those?
16 A
Oh, no.
Those are training sessions.
17 Q
Okay.
In any of your training sessions or drills 18 or exercises, aside from the February 13 exercise, did any 19 members of the media or the press participate?
20 A
I would hate to give you a total categorical no 21 on that because there may have been -- it would depend on the 22 definition, but by and large, no.
Those were training
-x
r 16 l
V procedures and there were no press there.
2 0
During those drills, was there any simulation of 3
press or media activities?
4 A
Yes.
5 0
And who did that type of simulation for you?
A Sometimes it would -- you would use off-shift 6
7 people, use consultant personnel, use people from other 8
utilities who have participated in exercises over the years, g
INPO personnel.
10 0
And what did those simulator individuals, I will call them, do during those training sessions?
11 1
A Ask you questions.
12 13 0
Since the exercise, since the February 13 exercise, 14 have there been any of these mini drills involving just the ENC that you mentioned earlier?
15 4
A I don't believe so.
16 17 0
There has been training conducted subsequent --
18 A
Absolutely.
19 0
-- to the exercise?
l 20 A
Absolutely.
)
i 21 O
can you describe that for me, please; that you 22 have participated in?
17
/~y O
1 MS. McCLESKEY:
Objection.
Irrelevant.
You may 2
answer the question.
3 TIIE WITNESS:
Classroom training, table-tops and 4
drills.
It's an ongoing process.
5 BY MS. LETSCIIE :
(Continuing) 6 O
Now, is the training that you have received 7
subsequent to the exercise, is it the same in nature as that 8
that you received prior to the exercise?
9 A
No, there have been some modifications based on to things that we learned in the exercise and where we have decided to modify certain procedures to improve the efficiency gi O
\\J so that we have been working with those changes.
12 13 0
Can you describe for me what the modifications 14 have been?
Let's break it down.
You said that there have been some modifications 15 in the training based on things that were Icarned during the 16 exercise and also based on decisions to modify the procedures 17 is to improve officiency.
Let's talk about those individually.
What are the modifications that have been based on 19 things that were learned during the exercise?
20 21 A
I would say the biggest one is that you don' t want 22 to have to rely too much on your copying machine.
They have O
18 O
1 a tendency to let you down.
So, what we have done is to 2
modify the procedure for getting information both to the ENC 3
and to the rumor control personnel that it, in essence, just 4
goes around any potential copying problem.
5 0
!!ow have you done that?
6 A
The way it's going to be handled now is -- in the 7
past, the primary route -- and again I'm confining this to 8
LERO procedures.
The primary route was for the emergency 9
broadcast message and the press release to be telecopied to 10 the Emergency News Center where it was then copied and dis-11 tributed both to the press and to the rumor control people O
12 who then -- from that point, distributed by computer terminal to the district offices and the emergency call boards which are i
13 14 set up to handle rumors and inquiries.
The way it will work now, it will be written on 15 the TSO which is a company network and edited and the clean to 17 copy, the approved copy, will be sent almost simultaneously with the EDS broadcast and simultaneously to the district 18 to officers, the call boards and the ENC by computer network.
So that while you will have to -- you will still 20 21 have to do the copying in the Emergency News Center for 22 the press releases to get them to the media, you are going to
19 O
v 1
get a clean copy quickly, and you won't have to copy for 2
the call boards.
3 And going back a step, the EBS messages, as you 4
are aware I'm sure from litigation, are very lengthy, to make 5
sure that the public that is at risk, the public that needs 6
the information, is getting a lot of it.
But in order to 7
answer inquiries and rumors, you really only need a few key a
parts of that information, such as the status of the emergency 9
and if there were any protective action recommendations what 10 they are and which are the zones.
11 So that when the EBS message has been completed 12 and approved by the Director, that key information will be 13 extracted, put on a summary sheet which I think offhand may 14 be five or six spaces to fill in, and that will be transmitted to the district offices, to the call boards, and to the ENC 15 at the same time that the EDS message is being read over the 16 g7 air waves to the EDS station.
And so that the rumor control 18 responders or the inquiry responders will have that informatio n 10 just as soon as it goes out.
20 Q
Okay.
You said that in the past, before you made 21 this modification, EBS messages and press releases had been 22 telecopied to the ENC.
Where were they telecopied from?
O
20 OL]
1 A
From the EOC where they are prepared and approved 2
by the Director of LERO.
3 0
Okay.
And during the exercise is that the route 4
that was taken --
5 A
That's correct.
6 0
-- and these things were telecopied to the ENC 7 7
Were they telecopied during the exercise to any other loca-a tion?
9 A
No.
They came to the Emergency News Center and to then from the Emergency News Center they would be disseminated to the district offices and call boards.
11 12 Q
Ilow was that dissemination done during the exercise?
13 14 A
It was put into the CICS computer network, which goes -- it's a customer relations network and sent out over 15 terminals.
16 17 0
And just so I understand, that computer communica-18 tions method was used during the exercise to send EBS messages and press releases from the ENC to the district offices and 19 to the call boards; is that right?
20 21 A
That's right.
22 0
You know, in describing these modifications, you
~
1 o
c-1 21 1
said that -- or am.I correct that-both EBS messages and 2
the press releases areJgoing to be' written on this TSO which 3
is some kind of'a~ computer;-is that right?
4 A
It's a computer-network.
5 0
Okay. ~They are, under these new procedures, to be written at the EOC; is that-right?
6 7
A That's correct.
They will always be written at 8
the EOC and' approved by the Director of LERO.
9 Q
And is it the Public Information Staff at the EOC to who prepares.EBS messages and press releases?
11 A
It's done by the Coordinator of Public Informa-12 tion.
13 0
And then they need to be~ approved by the Director 14 before --
cy g3 A
By the Director.
16 0
-- they are sent?
17 A
Right.
18 0
And then this computer network would, by way of that computer network EDS me' sages and press releases would s
19 be transmitted to the ENC; is that right?
20 s
21 A
To the ENC.
To the -- the summary sheet and the 22 EDS message / press rolosse will be sent to the ENC and to the Ov 4
- -...,., _. -,, _.. _....., -..,,,, _,... -. -. ~., _ -, _. -..,., -, - - _ _, -,, _. -.
22
. f)
O 1
district offices and the call boards.
Everybody will get it 2
virtually at once.
I am saying virtually, because I'm not 3
a computer expert and I don't know if there are any micro-4 second time lapses.
5 Q
Okay.
Just so I understand that, there are going I
6 to be three things that will be sent from the EOC by way of 7
this computer network, EBS messages, press releases and the 8
summary sheet; is that right?
9 A
Well, the EBS message and the press release are f
10 really one thing.
The press release is simply the hard copy i
11 of the EBS message.
The content is identical.
/~T 12 And then there will be a summary sheet of that.
13 So, you will have a one-page summary sheet and a multi-page 14 EDS message / press release which will follow.
15 0
Okay.
So they are not individual -- there aren't 16 Press releases prepared by LERO that are any different from 17 the EBS broadcast messages; is that right?
18 A
Not necessarily.
When there is an EBS message, 19 there is always a press release that is the content of the 20 EBS message, flowever, it is entirely possible that you 21 might want to do a summary kind or chronology kind of press 22 release to send to the ENC which would not be an EBS message.
('%
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a
',4 23
%)
1 So, you can't.have anIEBS message without a 2
press release, but you could have a press release without an 3
oEBS message.
1 4
Q Okay.
I-just want to understand what it is:that 5
isfgoing out over this computer.
Am I correct that the text 6
of -- well, maybe I'm -- let me start again.
7 Any time there is an EBS message prepared'at the s'
8 EOC, under these new procedures will there also be a summary 9
sheet < prepared at the EOC relating to that message?
?
10 A
Yes.
11 Q
And, am I correct that that summary sheet is pre 12 pared I assume also by the Coordinator of Public Information?
13 A
Or a staff member at his direction.
i 14 Q.
And, is the summary.she'et also approved by the Director?
15 4
16 A
No, it doesn't have to be because the information i
17 has.already been approved by the Director.
It would simply j
18 be approved information.
19 Q
Okay.
But, the summary sheet would be sent by 20 this computer network to the ENC, the district offices and i
21 the call boards; is that right?
22 A
That's right.
- _ _... ~.. --.,..
t 24 gO 1
Q Okay.
Now, I gather from what you have just said 2
that any time there is an EBS message there would also be 3
some kind of combined press release and text of the EBS 4
message that would be sent via this computer network to the 5
ENC, the district offices and the call boards; is that right?
6 A
That's correct.
7 Q
Now, if there is some other kind of press release s
which is different from simply the text of an EBS1 message, 9
I take it that's also prepared by the Coordinator of Public 10 Information at the EOC; is that right?
11 A
That's right.
12 0
And those also have to be approved by the Director 13 before they are sent; is that right?
14 A
Oh, yes.
15 0
After such approval, such press releases would 16 also be sent by this computer network to the ENC, district 17 offices and the call boards; is that right?
18 A
Right.
Right.
We would make sure that they had 19 all the information that was available using -- you know, 20 setting up a priority system that the EBS summary sheet comes 21 first, the press release corresponding to the EBS message 22 comes second and then any other press materials would be O
v
i j
25 O
1 further down the line.
2 Q'
Youtmentioned is your initial description of this 3
-new procedure that you would -- that to answer rumors and 4
things like that you really only need. key parts of the-EBS 5
messages and that'was.the purpose of these summary shee'ts.
6 with five or'six spaces on them.
7 Does that mean that the ---with respect to-the 8
rumor control personnel, that they would receive only those 9
summary sheets rather than the full text.of the EBS-messages?
10 A
No, no.
And I hope I didn't use the word "only."
11 If I did, I misspoke myself.
I think that's the'most O
important information they need, because that's the informa-12 13 tion that people need to take -- if there are protective 14 action recommendations, that's the information they need to 15 respond correctly.
16 So, it's the most important, the primary informa-17 tion, the information that the responders need most quickly.
18 They will have the'other material, but this will just -- as 19 I say, they will get this more quickly, and I think it will make it possible for them to respond more quickly because 20 21 they will just have it right in frontFof them.
They will 22 have the most information -- the most important information O-
~
3;-
26
+.
1.
(
4 1
right in front of ' them.'
They will have other information as 2
well, and they will also:be getting materials from LILCO, 3
from the on-site organization.
4 Q
When you say "they".you are referring to the 5
district offices and the call boards?
~
6 A
The rumor control' responders,. district offices, 7
call boards, or the people in the rumor control--operation a
in the ENC who supervise the people -- ultimately supervise 9
and coordinate the people out in.the district offices and 10 call boards.
11 Q
Okay.
I want to come back to that in a minute but I want to finish understanding this new procedure' first.
12 13 It's your understanding, I'take'it, that under 14 this new procedure these EBS summary sheets are the first' 4
thing that would be transmitted by the EOC to the ENC and I
15 these call boards?'
16 17 A
Yes.
18 Q
Did you participate in the drafting of this new 19 procedure?
20 A
Yes.
l 21 Q
Who else was involved in preparing this?
l 22 A
Other members of the LERIO organization, L-E-R-I-O l-r h
1 1
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. organization.
2 Q
Did you draft this summary sheet' formvor prepare 3
'it?
4 A
I worked with the people who were doing it, yes.
5 0
You said that these summary sheets have five or 6
six spaces in them.
What is the information that is-intended 7
to be included on the summary sheet?
8 A
Since I-don't have one in front of me, I'm not i
9 sure I'm going to give it to you completely or in the exact 10 sequence.
But, as I say, the key information that people would need if they had to take actions to protect themselves; 11 4
12 the emergency action level, what stage in emergency we are 13 at; what recommendations had been made by LERO for the public; 14 have schools been recommended to stay closed or. implement 15 early dismissal; have any zones been advised to evacuate; have any zones been advised to shelter; what zones have been 16 17 advised to take no action, that kind of information.
18 Q
Now, you indicated initially that.this new proce-3 19 dure did not eliminate the need to make copies of whatever is transmitted from the' EOC, make hard copies to give to. the
'20 21 press at the ENC; is that correct?
22 A
That's correct.
-n.--a.,,,.
e
Y 28 4
1 Q"
Have you.made any other' modifications in your-2 procedures, or otherwise,'to' -
'I think'the word-you used 3
before was to get"around/the' copyingfp;roblem that you had 4
during=the exercise?
5 A
I wouldn't call them procedure changes.. They are 6
physical changes and equipment changes.
The Emergency News.
7 Center is changing' locations.- It is moving-into a new LILCO -
8 facility in Hauppauge,'the new training center, and at that 9'
location there will be significant improvements in the' cool-ing~ capacity'ofL he' locations of the machines,' the electrical t
10 service to the machines', and also just in the availability of 11 backup copying machines.
There will be significant capacity 12 13 improvement.
- 14 Q
The LILCO training facility, where is that located-again?
15 A
It's in Hauppauge.
16 17 Q
Is that -- that isn't near the EOC in Brentwood?
\\-
A No, it's not.
It's very close to where the EOF 18 19 was, and it's roughly across the street.
20 Q
Has the EOF been moved also?
21 A
I don't know if it has been moved yet.
It will 22 be.
-O 1.
e-
-. 2 9
.(y-~1 1
Q
'Where.is.that going to be moved?
2 A
It will be in-this new building.
3 Q
So, the ENC and the EOF-will be located in the 4
same building?
5 A
Yes, they.will.
6
- 0 Is that same of location reflected in any --
7 reflected in Revision 7 or 8 of the LILCO plan?
8 A
I don't think that -- it's not a procedure' change.
9 It's not a revision change.
It's just a location change, 10 and I believe that is something that would have to be put 11 into the LILCO on-site plan.
12 0
The location of the' ENC?
13 A
Of both facilities, yes.
14 0
So, to the best of your knowledge, it's not reflected anywhere in the LILCO -- in the~off-site plan?
15 16 A
No, because the procedures we would use would be-the same in that building as they are in the building we are 17 18 in now.
It will just be a better physical environment.
19 Q
Do you know why the EOF is being moved?
?
20 A
I would have to speculate about leases and rented 21 buildings.
Since you are going to be seeing Brian McCaffrey, 22 I think he is a more appropriate person to ask about that.
.30 x i.
Have'you'had'any drilis'o'r exercises at the new 1
10 2
. location of the ENC?
~
s khe are'still' in the existing ENC at the 3
A No.
4 Holiday Inn.
4 5
Q Okay.
Have there been any other changes or modifications made.in order to deal with the copying problem-
?.
6 4
7 during the exercise?
8 A
Well, I think-it's a dual approach.
One.is that you are going to be 'doing less copying; you will be copying i.
9 i
less pages and -- so that you are stressing, whatever machiner y 10 you are using, less and you are now providing physical improve-11 i
ment in terms of climate control, electrical service and
~
i 12 i
actual equipment availability.
D 13 14 Q
When you 'say you will be ' copying less pages, what do you mean by that?
15 A
Well, the -- as I have mentioned earlier, the EBS 16 t
messages contain a lot of information which adds up to 17 18 multiple page documents.
It's just less stress to copy a one-page summary sheet real fast than it is to copy a six-page i
19 EDS message real fast.
20 21 Q
So, I take it that the intention under the new procedure then is to provide the press only with copies of 22
(
l l
i i
31 x._,)
f I
the summary sheets and not with the full text of the EBS 2
message?
3 A
The full text of the EBS message will be in the 4
press release which will follow.
They will have the full text, 5
It's just that they will get the summary sheet 6
first.
7 Q
Okay.
But then you would have to copy the' full --
8 A
Right.
9 Q
-- text of the press release for the press?
10 A
Right.
But that would not affect them knowing 11 what the stage of the emergency was and what the protective
\\'
action recommendations are, and since we generally would be 12 13 having a press briefing shortly after distributing the 14 summary sheets those press releases really just amount to historical documents for them to go back and check or for 15 somebody who arrives late and wants to reconstruct what has 16 17 happened up to that point.
18 O
Are the summary sheets -- I assume these are blank 19 forms that have been prepared in advance?
20 A
Yeah.
They are -- you know, it's --
21 O
You just fill in the blanks?
22 A
Well, it's not even as complex as fill in the blank 3.
('s (j
i 1
4 32
- rT 1
There is a -- you;know; a:very brief statement.and then a line 2
after it. -And there'is -- what has to be written is little 3
enough and thereis' enough Jspace so" that' people can print 4-large and clear and, you know, just make it really. easy to read.
5 s
O And are-these summary sheets contained in Revision 7
7 or 8 of the off-site plan?
I. don't know which one, but it is 7 or 8, 8
A Yes.
4 I
g or possibly 7 and 8.
andTIA-Q Have you had any drills or exercises since the go 11 February 13 exercise using this new procedure with the summary J
sheets and the computer?
~
12 A
I know we have used the summary sheets, and I 13 14 know we-have used the computer to the ENC.
I cannot tell.
'y u about whether it has gone out to the district offices 15 l
and call boards or the rumor. control.
16 i
17 But we have definitely used the summary sheets is and the transmission by TSO.
i 19 Q
From the EOC to the --
t-A ENC.
f 20 L
21 Q
-- ENC?
22 A
Yes.
7
33 e
a LJ 1
Q And,1during the times that you have used the 2
summary sheets and the computer transmission to the ENC, 3
have those instances involved full-scale' exercises with every-4 one participating, or have they been of this mini-drill type?'
5 A
No.
They were pretty much full-scale drills.
6 Again, you know, I'm saying pretty much because.I cannot, 7
you know, be certain -- I'm in the Emergency News Center and 8
I'm really not sure at this point whether they had drilled 9
all three staging areas at the same time or two of the three.
10 But in terms of my end of the operation, it was full-scale.
11 12 Q
Okay.
And, what has been the -- what conclusions,
~
13 if any, have been drawn concerning the effectiveness or lack of effectiveness of these modifications?
14 A
Well, I'm personally very pleased with the results, 15 because it just makes it much easier.
I've got for myself a 16 17
-summary sheet that is right in front of me.
The staff people 18 have them.
We have not had a -- even though we are still in the old ENC and still using the copying machines that we used 19 20 during the exercise, although we have now got them on separate electrical lines just using an extension cord, we have had 21 22 no problems.
And we have really tried to stress the machines.
,C\\
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r 34 h
i We have made many more copies than we needed for 2
that day's operation.' 'So, from{thht'po nt of view, I think 3
it has solved that problem,-in addition to which~I get the 4
press release which contains the text of the EBS-message as 5
it comes,off a word processor which is in a clean, attractive 6
form.
It's more professional looking.
7 Q
Okay.
Have you received those -- well, let me 8
rephrase that.
9 In the, whatever drill or drills that you are refer.-
10 ring to when you have used theseLnew procedures since the 11 February 13 exercise, how quickly as far as,you know have 12 you received the summary sheets. subsequent to the approval 13 of EBS-messages by the Director?
14' When I say you, I mean at the ENC?
15 A-I can't.give you a' time, because all I knowiis 16 I.'ve had it.
I've had it when I needed it.
I haven't had 17 to call over and say:
Where is it?
You know, they have
-18 scheduled a press briefing.
I need more information.
l 19 It has just been in my hands when we have been 20 notified by the EOC that an EBS has been activated.
The
)
21 next thing I know, I've got the piece of paper in my hand l-22 that I need.
So, you know, it may be a minute; it may be two i o f
t
35 b,s 1
minutes but it's fast enough.
2 Q
I would like to go back and discuss a little bit 3
the rumor control operation.and the personnel since they 4
relate to this new procedure or theychave~a'part to play in it.
5 There are -- am I correct that there are rumor 6
7 control personnel located at the ENC?
8 A
That's right.
They are part of the on-site 9
organization.
10 0
Are there any rumor control personnel who are 11 part of the off-site organization?
12 A
No.
'~
13 Q
Now, the rumor control personnel at the ENC, what 14 is their function?
A Well, I have been out of the on-site organization 15 for some time and I believe there have been some modifications 16 17 to the procedures, so I think, you know, Brian can answer 18 that much better.
19 Generally, it is to coordinate the rumor control 20 response; and their interaction with LERO is when they have individual inquiries that involve an off-site function, they 21 22 come to me or one of the other people there from LERO to get b) v
36-O l'
- an answer which we then usually have to get-for them from 2
another facility'because since they were individual, inquiries i: _
and some of them have been fairly eccentric..
3 4
Q Okay.
Now, you mentioned the rumor control person-
- 5 lnel at the ENC interacting with LERO.
I take it,that at least some of that interaction is with you; :Us that right?
6
+.
7 A
It's not -- quite' truthfully, it is least with me, because I am usually either conducting a press briefing 8
9 or preparing a press briefing.. So I am least likely to'be handling an iEdividual inquiry.
10 O.
But -- so, if you are not, who is it the rumor 11 control personnel --
12 A
Any one of_--
13 14 0
-- interact with?
A
-- the other Public Information Staff who are 15 there, who-are trained to handle that.
16 17 Q
Okay.
And how is=that interaction done?
What 18 happens?
19 A
The rumor control people come to us with a form that they have filled out that has, you know, just.a whole 20 range of fill-ins and check-off boxes and a question.
Usually 21 22 it's, as I say, an individual inquiry.
They give it to the O
t
-37 4
1 Public Information' Staff.
It is-logged.into a log which is
~
2 kept.usually by somebody who has been designated to be the
+.
t f3 communicator with the EOC.1 U
~
4 If it.'s something that we can answer. based on i
5 a material that we have.'there:like~afmap7of the EPZ or siren-6 locations or something like that, we will answer it there.
7 Again, because of the' ' eccentric nature of the 8
. inquiries that we have been.given~during drills and the
?
9 exercise, it's usually something tha't has to be called'into 10 the EOC, to the Public Information~ Staff there.
They have to 9..
i.
11 go to a specific ~ Coordinator ~who then has to obtain the h
12 information for them.
13 Q
Okay.
Now, the' rumor control. personnel at the
. 14 ENC who bring these forms to the LERO staff at the' ENC, are i
15 those personnel the ones'who have actually taken the tele-i i
16 P one call?
h l
l 17 A
Not necessarily.
They would -- again,.you are la going to have to confirm this with Brian but it is my 19 understanding that these are usually inquires that went into 20 a district office or the call board and because of the 21 individual nature of that inquiry which could not be handled 22 by the written materials it then came up the line to the ENC, l'
..-..,~-_..._.- _ _. _ _._, _ - -.. _. _.-,_ _.
_=- -._ _
h 4
38 e
i which~is at least how it used~to work.
-2 And, as-I say, if it involves an off-site function 3
then it comes over to us.
We'get the'information, we hand 4
it back to them', ; andithe'n th'ey gofback'into their own.
5 Procedure for relaying it back to the cal!.er..
-6' O
Okayj SAmII'correc't then that the LERO organization
~
7' does not~have any primary responsibility for rumor controlt 8
is that right?
i
)
9 A
It's one by the on-site organization. ~We'are a 10 source of information, we are a resource.
I think that's i,
gi fairly standard in~ emergency planning.
j-There may be places where it's done differently, 12 but that's usually the way it has been done in the' drills I.
13 t
l have attended,'because the utility has the phones and the 14 i
15 people.
i 16 Q
During the February 13 exercise, did.you have any l-interaction with rumor control personnel?
17 l
18 A
Yes.
I'm saying that collectively.
I'm answering i
i 19 for LERO.
My own interaction was really minimal.
Q The interaction by LERO during the exercise, was 20 i
21 that of the nature that you just described --
r 3
22 A
That's right.
lLO I
39
(}
g/
1 Q
-- where the forms were brought to them and they 2
were logged in and then they would either answer the question 3
or call the EOC and have somebody at the EOC get an answer?
4 A
Right.
5 Q
After that, I assume that the reverse procedure 6
was followed, the EOC person would call' the ENC person and 7
then that person would in turn pass the information on to 8
the rumor control personnel?:
9 A
Right.
And it was logged and done in writing to 10 make sure that it was accurate, that it was very precise, because the last thing that you want to do is have something 11 O
'/
coming out of your accuracy center or your accuracy control 12 13 procedure that is inaccurate.
14 So, that is the reason for writing down the 15 question, writing down the answer and keeping this log so that you know exactly what is being said.
And the people 16 17 are trained very carefully to do that, you know, to be very i
18 careful in what they say, to be very, very precise.
19 Q
Okay.
Now, this logging'in the questions and the answers and this concern about being precise that you 20 21 have just mentioned, I take it that is to be done by the LERO I
22 personnel at the ENC; is that right?
()
Rj i
i l
l t
40 O
1
-A If_the LERO -
when LERO,gets'the question, it 2
is already written --
I 3
Q-On the form?
4 A
-- on the. form..Before it..is,given back to LILCO, to th'e rumor control' staff, for,it to be relayed back to the s
6 inquirer the answer is written.down as well.
7 Q
On the same form?
8 A
Yes.
9 Q
Okay. lSo, there are not separate logs kept by the --
10 11 A
There are separate --
O.
12 Q
-- off-site personnel?
13 A
-- logs because it -- there is a rumor control 14 log.
I know that.
But in addition to which if we handle an inquiry we log it into our operation so that we know we is have handled it.
16 17 Q
Okay.
18 A
And we know where we got the answer from.
19 Q
Okay.
Let me just see if I can understand the 20 Paper trail that is layed here.
You have the on-site rumor control personnel who has filled out one of the little forms 21 22 when an inquiry has been received.
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1 A
Right.
2
.Q
-That little' form is then given to a LERO. person 3
at the ENC with'the. request that an answer be obtained to 4
this question.
4 5
A Right.
6 0
When~that form is obtained by the LERO personnel,.
7 it is logged-into a LERO rumor control log.
8 A
.That is not.a. separate. log.
That is-just'-the 9
communicator's log.
For instance, the day of the. exercise.
i 10 it was just one book, and she would just write in there:
-11 Received rumor number 17.
12 Q
Okay.
And then after writing-down, received 13 rumor number 17, that communicator would do what with that t
14 inquiry?
15 A
Call it over to the EOC, Public Information Staff.
3 16 Q
Okay.
And would say:
Here is this inquiry.
Tell 17 me what the answer'is, b
18 A
Right.
- 19 0
Okay.
Now, to your knowledge, did the ENC staff 20 log in that inquiry coming from the ENC?
21 A
You mean the EOC log?
I don't remember whether 22 they logged it as precisely as we did.
I was very concerned LO
{
42
(~3 v.
1 that-my people log it so that we had track of -- if there:
2
'were any.open inquiries that we had not received an answer 3
to.
So,.they were directed to do that from our.end.
When 4
they,got-the_ inquiry and then log when they.got the answer.
5 Q
Okay.. Let's just finish theichain here. 'It-has 6
gone over to the'EOC,' somebody at the EOC-has gone to a 7
Coordinator or whbrever they need'to go'to obtain the' answer.
t 8
After the answer is obtained, I'take it the EOC
~
9 person then calls back --
10 A.
Right.
11 Q-
-- the ENC.
Is it the' communicator that would i -
receive that call back?
12 13 A
Right.
It's whoever is answering the telephone.
1-14 It's generally the person-that is designated communicator 15 and usually you have more than one person.
You have people l
16 rotating through that role, because it's a very. tough function j
17 to perform.
18
-Q Okay.
And I take it when that call is received 19 with an answer to an inquiry, the answer is logged into that 20 109 --
l' 21 A
No.
The answer is not logged in.
The answer is l
l 22 written on the form and the time received is just put in the O
I
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log so you know you have closed your half of the loop.
2 Q
Okay.
So, it would say:
Received answer to 3
rumor control 17?
4 A
Right.
5 Q
Then, once that has been logged in I take it that 6
that LERO person would fill in that answer on the rumor 7
control form and give the form back to the on-site rumor 8
control personnel who had given it to LERO to start with?
9 A
That's right.
10 0
Now, what is your understanding as to what would 11 then happen with that answer which is now put on the rumor O
N/
control form?
12 13 A
Once it goes over there, as I say, you would 14 really have to ask Brian McCaffrey because there may have been changes in that procedure since I was part of on-site, 15 and I don't want to guess.
I 16 37 Q
Do you know what it was that happened during the i
18 exercise?
19 A
No.
Again, there may have been changes since I 20 was -- you know, and I'm not certain what revision of the on-site plan they were using during the exercise.
l 21 22 Q
Okay.
Am I correct, Ms. Robinson, that the f~%
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l 1
L
-.. ~..
L I
44-6 1
function of the. district offices and the call boards with 2
respect to rumor. control-responsibilities are the same?
3 A
.Ye s. ~
4 Q
' And' basically there'are people manning the phones 5
in those two places who are suppose'd to be prepared to take-4
~
6 calls from the,'public; is thatLright?
- r-
.s as they'normally do.
-I mean, that's.
j 7
A That's right, l
's part of their normal function,.to take public inquiries..
J 9
Q Are there any rumor control personnel at the EOC?
h
^ ~
.T eJEOC-is a LERO facility, and rumor
'10 A'
. No.
No..
I control is'an on-site function.
gg 1.
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. _ _ _ ~ _.. _. _. _ - - _
i:
45.
i: i 1
EOF?
i 2
A The Emergency News Manager is at the ENC.
3 0 'i During any of the'drillsLor training or exercises 4
that have been held s'ince'the February:13' exercise, has
~
5 there been~an exercise-of.the rumor control aspect of 4
6 emergency response?
i 7
A There.has been'in the ENC..
I really don't know 8
how it has~been:since the on-site plan has been exercised.
t 9
I know'that we have~ exercised the portion-where:
10 they come and.ask;LERO fore information'., Brian would.have to 11 be asked about what they've done with'the district offices j
12 and. call boards.
1 13 Q
Okay.
And with respect to the interaction with 14 LERO of which you are familiar, I am assume, and I'm talking i.
l Post-February 13-exercise here, have 'there bee'n any modifica-15 tions in procedures or the way that that rumor control inter-16 17 action has been handled?
18 A
No, because we have been very satisfied with.the i-19 way we have produced accurate information that way.
20 Q
Okay.
Why was your title changed from Public 21 Information Staff to LERO Spokesperson?
22 A
Just for better definition of the role.
i 1-
46 0
1
-Q But that was done subsequent to.the exercise; 2
is ' that::right?
3 A
'Right.
It wa'sn't worth a revision to the plan.
4 It was just a refinement.
5 Q
Was that.done in response to any FEMA comment 6
about exercise performance?
7 A
Not'that'I recall.
8 Q
Okay.
We sort of got onto this whole line of 9
discussion after~-- from your,1nitial response,to a question of mine that there had been some modifications in~ training 10 I' believe based on ' things that'y'ou had ' 1 earned during -.the
^
11 exercise-and ways to improve procedures and to' improve your
~
12 13 efficiency.
14 And you mentioned the copying problem.
Have there been any other modifications in your training based 15 on things that were learned during.the exercise?
16 17 A
Well, any -- you know, in general, for LERO any 18 time you change a procedure you change the training for the 19 people who use that procedure.
And that's just a given.
20 So, I'm sure there -- you know, whatever has 21 changed in Rev 7 and 8 there are comparable changes in the 22 training program.
O
4 47
-f-s e
b 1
Q Okay.
But we have discussed one group of changes 4l 2
-which is to deal with what_you referred.toLas-the copying 3
problem duringlthe exercise.
4 A
-Right.
5 Q
Were there'any other. problems or things learned 6
during the exercise other than this copying. problem that 7
you are aware of that have been addressed?
8 A.
.Well,;one of_the'other~ comments.-- and I don't g
have the FEMA report-in-front.of,me, but there was a comment I
about the maps and' charts.
They had made very specific re-go 4
11 quests -- and again that:was a simple physical equipment s-)'
modification.
We have simply produced the kind.of chart that'-
12 was requested and the kind of map that was requested and, 13 14 you know, it has just been done.
i That did not involve any change in procedure or
[
15 training.
It was just a question of having a more detailed i
16 j
g7 map with-a plexiglass cover that you can write on.
I F
18 0
Were there charts prepared.in addition to this j
gg more detailed map with the plexiglass cover?
l A
Yes.
Again, I don't remember the exact wording 5
20 4
21 of the FEMA comment, but I can tell you what we have produced, 22 which is a single large sheet, again of some kind of plastic f-1 i
l
.(
~
48.
i-I material, that has-the--four stages.of. emergency from unusual 2
event to general. emergency,and a space to write in the time' 3
that that level of emergency was declared so that there'is 4
a historical record, because previous to that we had only 5
posted the current state of emergency.
And the FEMA -- whoever evaluated that section 6
7 felt that it was important to have that. historical record in.
8 case somebody came zin ratja later.. level,' ',so - we just produced 9
that.
1 10 0
Was there'any otherJadditional equipment changes I
i
~
11 that were done following the exercise-based on what you-12 learned or on FEMA comments?
13 A
No. - We put an aerial map, actually based on'an I
aerial photograph ~again covered in plexiglass, simply because 14 it's a very good photograph'and it really shows -- it would 15 enable somebody who is_not that familiar with the area to 16 17 get a really good look at where houses are concentrated,=
18 where the major road network is.
i-19 And as something better became available,.we are l
t
!~
20 Putting it in there.
i r
21 Q
Anything else?
22 A
No, not that I can think of at the' moment.
4
49 E-)
t Q
Okay.
Any other things that were learned or 2
decisions that were made to' improve efficiency following the exercise?
3 4
A No.
From my point of view of how the ENC was 5
run, that was the primary consideration.
6 Q
I take it that, going back just a minute to the 7
more detailed map and the chart with the emergency action a
levels on it, that both of those' specific' things had been 9
suggested by FEMA; is that right?
10 A
Yes...They were pointed out by FEMA.
I don't remember the exact words.
I know there is somethi'ng about 11
/~'T l
it in the exercise report, the assessment report.
12 13 Q
Did you have any meetings or discussions with 14 representatives of FEMA subsequent to the exercise to discuss their comments or suggestions?
15 A
No.
16 17 Q
Did you ever receive any written comments concern-ing the exercise prepared by FEMA or FEMA representatives 18 19 other than the FEMA report itself?
20 A
No.
21 Q
Were there any suggestions for improvements made o
j 22 by any other observers or evaluators of the exercise other tha n
r~h lv}
)
L
s 50 1
- FEMA?
,/
2 A
Oh, there were observer comments that things U ke 3
the. heat in the work space and, you know, the' copying machines 4
and, you know,'those-kinds:of. things that are really being-
-5 addressed by.the physical' plant.-
6 Q
To your knowledge, wer'e there any other -.any 7
- comments other'than those relating-to the physical plant
~
8 or suggestions.that were made by. observers other than FEMA?
9 A-I don!t remember any other suggestions.
I know 4
there were other comments and some'of them were not'eveh o.
j 10 11 valid on review, but basically-:I think we have. met every 2
~
actual suggestion.-
7
/
12 end T1 13 MS. LETSCHE:
Let's,go off the record for 14 a minute.
(Off-the-record.)
15 BY MS. LETSCHE:
(Continuing)
-16 17 Q
Ms.-Robinson, in response to an interrogatory-18 propounded by the government in this case, yor '+cre identified j
19 as an individual who has knowledge of the
+ tr :oncerning Q
1 the development of the exercise scenario and objectives. l 20 21 Can you tell me what your participation was in 22 the development of the exercise scenario?
O r-c
..,,,. - ~
e
~-w w w-.r
-,,,,,-r--.,--=-----m.
_-y
,,,-,--+--,-.--,---y y~
.y
s 51
- /-'T
\\.)
~
1 A
None.
2 0
Okay.
When did you first see the exercise 3
scenario?
4 A
I've never seen the scenario.
5 Q
Okay.
Did you participate in any meetings or 6
discussions, say, back in November or December of 1985 7
concerning the conduct of a graded exercise of the LERO plan?
8 A
No.
9 Q
You never participated in any meetings or discus-10 sions at which there were discussions about requesting FEMA 11 to conduct an exercise or actually having an exercise' conduct-
'J 12 ed or graded by FEMA?
13 A
Well, I think I need some clarification.
Do you 14 mean, the internal preparations for an exercise or do you 15 mean -- I'm just not clear on what you mean.
16 0
Well, I guess that really was not a very good 17 question.
18 You knew at some time before February 13'that there 19 was going to be FEMA exercise, right?
20 A
Well, actually I didn't know until that Monday 21 night that there would definitely be a FEMA exercise, but 22 I certainly was aware that one had been requested and that C)
V
52 t
U 1
there were a lot of preparations for a FEMA exercise.
I 2
mean, that was what we were working on and what we were doing.
3 Q
Right.
Now, your working on that exercise and 4
preparing for that. exercise, what did that consist of?
5 A
Training, drilling.
6 Q
Anything else?
7 A
No, it seems as though that's what my life has 8
been for the last couple of years.
9 Q
Okay.
In the preparation for that exercise, did 10 you have any contact with non-LILCO or'non-LERO individuals 11 concerning participation in that exercise?
(~/
1
's-12 A
No.
13 0
You didn't have any conversations with representa-14 tives of the Red Cross?
15 A
Well, I was including that as part of LERO.
16 Q
Well, okay.
I wasn't.
I think I had said non-17 LILCO --
18 A
You said non-LILCO and non-LERO, and the Red l
l 19 Cross is very much a part of the LERO plan.
20 0
Okay.
Did you have any conversations with any 21 bus company representatives concerning their participation l
22 in the exercise?
l
's.
I 1
i i
}
53 i I 1
'A Yes.
2
~Q How'about with-the ambulance ~ company representa-3 tives?
4 A'
Yes.
5 Q~
How about.with school officials?
A No.
6 7
0 How about with hospital or nursing home-representa-8 tives?
1 9
A No.
^
10 Q
How bout the:U.S. Coast Guard?-
i 11 A
No.
I
[~D
\\2 12 Q
Howiabout Nassau County representatives?
13 A
No.
14 Q
State of Connecticut?
i A
No.
15 16 Q
Can you describe for me the conversations with 17 the American Red Cross representatives that you had concerning 4 -
18 participation in the exercise?
19 MS. McCLESKEY:
I am going to object on relevance 20 grounds.
You can answer the question if you can.
21 THE WITNESS:
They were just general discussions 22 about other exercises, mainly the conversation went around
54 f3
\\
)
1 other exercises that I had observed, how they were conducted, 2
what people did, how long did it generally take, just in 3
essence that kind of familiarization.
4 BY MS. LETSCHE:
(Continuing) 5 Q
When did these general discussions take place?
6 A
Over a period of time, between when the NRC and/or 7
FEMA -- and I don't remember which one did it -- announced 8
that there.would be a full-scale exercise at some point, mid-9 winter and when it actually took place.
10 Q
And'with whom did you have these discussions?
11 A
The Red -- you know, I have met so continually
('T
'\\ /
with these people over so many different issues, including 12 13 non-Shoreham issues, that it's hard to be that specific.
14 I'm sure I spoke.to Ed Thompson, but I may have 15 spoken to other people as well.
16 Q
What other exercises that you observed did you 17 discuss with Mr. Thompson or others from the Red Cross?
18 A
Well, I have observed exercises at all the sites 19 in New York State.
20 Q
Now, in these discussions with Mr. Thompson or 21 others from the Red Cross, what did you discuss about the 22 Red Cross' participation in the Shoreham exercise?
oO V
~.
>+-
d-
'h 4
..c, 55 1
.A-Oh,II don't' remember; specifics, but.I!-- again, 2
as I say, these were:just really-informal discussions.
They 4
3 were not training-sessions; they.were.not-specific points.
4
- Q
.Okay.
Did any American Red Cross representatives 5
or-personnel participate in any of-the. training sessions or; 6
drilling sessions that were done'in preparation.for.the-i 7
February 13 exercise?
f a
A I don't know if anybody did.
~
J
'9 Q
How'many Red Cross personnel ~ participated in the 10 February 13 exercise?
i 11 A-Again,!I just don't remember.
12 Q-Did you have any contact with the Red Cross f
~
13 personnel duringfthat exercise?.
14 A
No.
t h
15 Q
You mentioned that you have been an observer at exercises held at all sites in New York State.
Can you be 16 17 a little more' specific for me?
l l.-
18 What New York State exercises have you been an 19 observer at?
l A
Indian Point.
20 l
l l
21 Q
When was that?
And when were the exercises or l
22 exercise that you observed at Indian Point?
O i
56 f3 L.)
1 A
Oh, I don't remember the exact dates.-
I know that 2
I -- I have observed several at Indian Point.
I think ever 3
since the FEMA requirement for full-scale off-site exercises 4
I've been -- I know I've been to the ENC there at least 5
twice, and I also was an observer in the Rockland County EOC 6
when New York State conducted the interim procedures 7
exercise.
8 I was up at Ginna, and that one I know exactly 9
when I was there because I got called back to the response to to Hurricane Gloria.
11 Q
Okay.
So that was when?.
Hurricane Gloria's date O
k/
is not emblazened in my brain.
12 13 (Laughter.)
14 A
It is in ours.
That would have been October of
'85.
Actually, September of '85 was the exercise.
I think 15 16 it was September 25th or 26th.
The Hurricane hit on the 27th.
17 Q
Okay.
?
18 A
I've been up at the Fitzpatrick site.
l I
l 19 Q
You observed an exercise at Fitzpatrick?
20 A
Yes.
l 21 Q
Do you know approximately when that was?
I 22 A
Probably in
'84, but it may have been
'83.
i l
l
57 m
(
)
x_/
1 Q
Any others?
2 A
No, that's it.
There is also the Nine Mile --
3 I've also been at Nine Mile, but that's on the same site 4
as Fitzpatrick.
5 Q
Did you observe an exercise at the Nine Mile 6
plant separate from whatever you observed at Fitzpatrick?
7 A
I don't remember whether it was a joint exercise 8
or not.
I know I was in both facilities, but I just don't 9
remember the details.
10 Q
Did anyone else from LILCO attend any of these 11 exercises, to your knowledge?
tO
\\
12 A
Oh, yes.-
13 Q
Several people?
14 A
It was a large' contingent at the Rockland County 15 EOC.
We were serving as observers there.
We'were helping out le Q
How did you get tapped to do that?
17 A
By New York State, as a matter of fact at tL,t 18 time.
19 Q
You said you were helping out.
What were you 20 doing to help?
21 A
We were official observers.
We took notes and 22 handed in our logs at the post-exercise meeting, the whole O
58 v
1 group of us up there.
2 Q
You also stated that you had conversations with 3
bus companies concerning participation in the February 13 4
exercise.
Can you describe <those for me?
5 A
There was a meeting prior to the exercise in which we had invited all the contractors and there was a 6
7 general -- a couple of general presentations made.
I was a
there and socializing.
I mean, it's no specific conversations, 9
Q Who made the general presentations at that meeting?
A I introduced -- I'was kind of the social director 10 11 and introduced people.
There was a member of LILCO's Legal 12 Department there that night.
I don't remember who else.
There were a number of LERIO people there to answer questions 13 14 that were asked.
15 Q
Mr. Weismantle?
A No, I don't remember him being there.
16 17 0
Mr. McCaffrey?
18 A
No, he's not part of LERO.
He's not part of 19 LERIO or LERO.
He definitely would not have been there.
20 0
Mr. Daverio?
21 A
No.
He was not participating at that point.
22 O
What was the subject of the presentation?
O(_)
59 There were a number of topics discussed.
Among 1
A 2
others, at that time the case was pending before Judge 3
'Wexler in Federal Court on Suffolk County's local law and 4
as I remember it that was the primary subject of discussion 5
that night.
I believe it's Local Law 2.
6 0
Other than this meeting that you have. referred to 7
prior to the exercise, did you have~any other conversations 8
or contacts with bus company representatives prior to the 9
exercise concerning the exercise?
10 A
Not that I remember.
11 Q
Was it your understanding'that -- you said that all O)
\\-
of the contractors had been invited to this meeting.
Did 12 13 they all attend?
14 A
I don't remember exactly.
There were a large number of people there that night.-
15 16 Q
To your knowledge, Ms. Robinson, did any bus 17 companies indicate that they would not participate in the 18 exercise?
19 A
No.
20 Q
Do you know how it was determined which companies would be called upon during the exercise?
21 i
22 A
No, I don't.
t_-
I l
60
,f y
%-)
1 Q
Do you know who made that determination?
2 A
No, I don't.
3 Q
Do you know when it was made?
4 A
No.
5 Q
I take it from your prior answer that you did not 6
have any correspondence with any bus company representatives 7
concerning participation in the exercise?
8 A
No.
9 Q
You also mentioned that you had had some contacts 10 with ambulance company representatives.
Can you describe to it me what those were?
p 12 A
They were also at the large general meeting, and in addition I do remember visiting two ambulance companies 13 14 at their places of1 business.
15 Q
Do you know if all of the ambulance companies under contract to LILCO were invited to the general meeting?
16 17 A
I believe they were.
18 Q
Do you know whether they all attended?
19 A
Again, there were a large number of people there and without seeing the sign-in sheets, no.
20 21 Q
Do you know if any ambulance companies decided 22 not to participate in the exercise?
(h u>
l i
61
/~'8;
^
%)
1 A
No.
2 O
You don't know whether --
A No, to the best of my knowledge'there was nobody 3
who refused to participate.
4 0
'You mentioned that you visited two companies.
5 Which were those?
6 7
A Peconic and Stat.
8 Q
When did you visit them?
A Oh, I don't remember the exact date.
9 Q
Some time prior to the exercise?
10 A
Right.
11
?\\ *-
(s/
O And what did your visit consist of?
12 A
Again, it was just a -- it's the kind of thing, 13 34 you know, that we.in the LERIO organization had done p riodically which is keep in contact with contractors and 15 other people involved -- other non-LILCO members of LERO so 16 that it was nothing -- you know, it was that extraordinary.
17 It was not the first time I had been in either 18 1
P 0CO-19 Q
Okay.
20 A
And, again it was just a general discussion of 21 the exercise, what -- you know, again generally what they 22 1
62 0
1-
'could expect.
2 Q
.Now, I takefit, why were these two companies the 3
ones that.you visited as opposed to any of the other. companies 4
- that were under contract?
5
'A Oh, I know why those two.
My regular other job, 6
which takes me very often to Riverhead and to Hauppauge and 7
-since'Peconic is-in Riverhead and Stat is in Hauppauge, it 8
.just logistically was the logical place for me to.go.
9 Q
- I take it when you went to talk to them to discuss 10 the exercise it was because you understood that they would 11 be participating in'the exercise; is that right?
12 A
That it was possible that they would be called 13 upon to provide equipment.
14 Q
Did anyone tellLyou that -- instruct you or request that you go and visit those compan'ies for that purpose?
15 16 A
Well, as I say, this is something that we've 17 done on a regular basis and generally what you do is divide 18 up the list and see how,'you know, it works into your-19 schedule.
And since Long Island is aptly named and driving 20 takes up a lot of time, you just try to, you know, divide 21 it up on that basis.
22 Again, I had dealt with those companies early on O
r-63 1
in the plan and I knew the people, 'so there wa:s nothing unusual 2
about it.
3 Q
Were all of'the ambulance' companies under contract 4
to LILCO visited by someone'concerning the exercise?
5 A
I believe so.
I'm'not absolutely _certain, but I 6
do believe so.
7 0
Who else would have done those visits other than a
yourself?
9 A
Other members of the LERIO organization, people
-to who were working over.there.
11 0
were any bus companies visited?
12 A
I don't know.
13 Q
You didn't visit any?
14 A
I don't.think.so.
Again, it's hard -- you know,.
15 going -- it's over a year ago now.
And going back that far, 16 I've gone to bus companies since the start of the LERO plan 17 so many times, it's hard to remember which November I was 18 there and which December,I was there.
19 I've been I guess in virtually every bus company 20 headquarters now.
I may have gone to one or two.
I just 21 don't remember.
But, again it would have been the same time 22 frame.
O
64
(_)
1 Q
In the -- whatever general discussion you had 2
about the exercise or what would be expected during the 3
exercise, what sorts of things did you tell these ambulance 4
companies would be expected of them?
5 A
Well, again it was general.
To the best of my 6
recollection at this point, it was the kind of general 7
information that I would have given, you know, that had 8
been discussed which was if they participated, you know, they 9
would be observed, they would have to answer questions from, 10 you know, FEMA observers; they, you know, would follow 11 directions, that they would not be carrying members of the
[I 12 general public, that that was not what was done but that they N/
13 you know, that somebody could come up to them and say:
I am 14 an injured person or I am somebody from a nursing home, tell 15 me what you would do.
You know, that kind of thing.
And, I don't remember anything else except general
'16 17 conversation, how are things going.
The kinds of things that 18 you talk about when you deal with people on an ongoing basis.
to O
Was this same sort of information given to the bus companies during your general meeting that you mentioned 20 21 carlier?
22 A
I don't remember exactly, but I'm pretty sure it O
65
-m (v) i was.
2 Q
Okay.
Were the ambulance companies or bus companies 3
who agreed to participate in the exercise paid by LILCO for 4
that participation?
5 A
Well, per the contract any time you use equipment 6
you pay a rental fee.
That's the contract.
7 Q
And I take it there were individual ambulance 8
personnel and bus company personnel who actually participated 9
.in the exercise; is that right?
A Well, I know there were ambulance company person-10 nel.
I don't know of any bus company personnel.
11 D(~
Q Okay.
The individual ambulance company personnel 12 I guess would be the drivers or the med techs or whoever in 33 the ambulance, were they paid for their participation in 14 the exercise?
15 A
You know, going back again, it's whatever is in 16 the contract.
That's covered in the contract.
You pay for g7 18 their time just like you pay for the equipment.
And there 19 are regular rates set in the contracts.
I didn't have anything to do with that.
20 21 Q
With respect to the bus company personnel, you 22 said you didn't know that any participated.
I assume you
("3 l
\\j
66 q\\s.
1 are referring to drivers?
2 A
Right.
3 0
Didn't the dispatchers or whoever it is that is 4
responsible for letting LILCO people take the buses get 5
paid?
A In that sense, yes.
In that sense, yes.-
I 6
7 thought you were talking about actually being in the exer-a cise, you know.
That would have been -- in my mind, at 9
least just doing their commercial function which is coming to to rent a bus.
11 Q
llave you had any conversations or contacts with 12 representatives of the Red Cross or bus companies or ambulance 13 companies subsequent to the' exercise?
14 MS. McCLESKEY:
Objection, relevance.
BY MS. LETSCIIE:
(Continuing) 33 0
Let ne just add on to the question, concerning 16 17 what happened during the exercise?
18 A
No.
19 0
llave you had any such contacts concerning changes or revisions in the LILCO plan or subsequent training drills 20 21 or exercises, things like that?
22 A
I don't remember any.
Not -- no.
O
67 y(d 1
Q-To your knowledge, have any bus companies, 2
ambulance companies or the Red Cross participated in any 3
drills or exercises subsequent to the February 13th one?
4 A
I just don't know.
5 Q
Ilave you had any conversations with any school, or hospital or nursing home officials subsequent to the 6
7 exercise concerning their participation in any LILCO plan 8
or LERO plan?
9 A
No.
10 0
Oh, I knew there was one other group I should have 11 asked you about.
Did you have any conversations with WALK O
k' radio or any other radio station concerning the February 13 12 exercise?
13 14 A
Yes.
0 And when did those conversations or contacts 15 take place?
16 g7 A
Again, that's on a regular -- you know, that was 18 always on an ongoing basis, and I couldn't give you any 1
19 specific time frame.
20 0
What did those conversations consist of?
21 A
There are two -- you know, I have to separate them into two things because very often I an talking to radio 22 O
U
68 p,)
(s I
stations as a media representative, as somebody answering 2
questions about what is happening in the LERO plan and the 3
stages.
4 Q
Let's set that aside for a minute.
A Okay.
That's not what you are referring to?
5 0
Right.
I'm talking about WALK radio'.s participa-6 7
tion as a part of the LERO plan?
8 A
I would say I have spoken to them at various times 9
through the late fall, early winter.
0 What discussions did you have with WALK radio 10 personnel about participating in the February 13 exercise, 11 if any?
12 i
A The major question was whether or not the sirens 13 would be sounded and the EBS activated as part of that exer-34 cise and how that would be affected by Local Law 2.
This 15 was prior to the Wexler decision.
16 17 0
Right.
And, obviously the sirens were not sounded and the EBS station was not activated during the exercise, 18 19 right?
f A
- Right, 20 i
0 Were you involved in that decision?
(
21 l
l 22 A
No.
I did not make that decision.
)
/~
(_s%
i l
69 m(_)
1 Q
Who made it?
2 A
I really don't know.
3 Q
Do you know why it was made?
4 A
I could only speculate.
5 Q
Can you tell me why you think it was made?
MS. McCLESKEY:
Objection.
The witness can't 6
7 speculate.
The witness has stated that she doesn't know why 8
it was made or who made it.
9 BY MS. LETSCHE:
(Continuing) go Q
Ilave you had any discussions with -- I think I asked this question, but I'm not sure I got an answer.
Did
~
11 you have any discussions with WALK radio concerning its 12 participation in the February 13 exercise?
13 14 MS. McCLESKEY:
Asked and answered.
Objection.
BY MS. LETSCHE:
(Continuing) 15 Q
Let me just -- you said there was some discussion 16 about whether the sirens would be sounded or the EBS activat-17 ed.
Is that what you meant by a conversation with WALK 18 radio about its participation in the exercise?
19 A
Yes.
20 21 Q
Okay.
I take it NALK was -- did WALK radio 22 personnel indicate that they did not want to participate in
s i
70 D
1
.the exercise?
2 A
No.
3 0
But they did not; is that right?
4 A
'At some point -- and, again I' don't know at what 5
Point or precisely by whon or even precisely why, the decision was made that the prompt notification system would be-tested 6
7 separately from the February. exercise.
It would be what's Re,p.
y' 8
s And-that information -- you know, that' decision 10 was just made but that's all.
33 Q
Okay.
Is it your understanding.that a FEMA O
240 l
D
-Rev 10-includes activation of EBS stations and broadcasts FM 12 4
those messages over the air?
l 13 f
Of a message that a test is taking plag.
That 14 A
is my. understanding.
I don't have the precise language, j
15 t
but I believe that-is what is generally'done.
to i-It's a prompt notification system and that's part g7 l
18 of the system.
Q Ilas any such test taken place?
IL D9 gM A
As PEMA -Rev 10?
No.
20 21 Q
lias there been any test of the prompt notifica-l-
tion system that includes the activation of the sirens and 22 O
71 tT CJ g
the activation of the EBS, or the broadcasting of the EBS 2
test message?
A Yes.
You are going to ask me for the date, and 3
4 I don't remember precisely.
It was a few years ago.
Q And during that test, there was actually a broad-5 cast on WALK radio of an EBS message?
6 7
A Again, it was a test message.
It was a message a
that said the sirens are sounding.
There were a number of g
means used to notify the public that the sirens would be tested that day and that is what it was, 10 It was a tect.
It did not signify any other kind gg p
k/
f alarm.
12 g3 Q
Were all of the sirens sounded in connection with that?
g4 A
Yes.
It was a full test.
15 O
Was that observed by FEMA?
16 A
I just don't know.
37 Q
To your knowledge, is any FEMA 4Hw 10 test ESA gg 19 scheduled for any time in the future?
A I don't know.
20 Q
Itave you had any conversations or contacts or 21 correspondence with WALK radio personnel subsequent to the 22 O
%_J l
l l
72 (v) 1 February 13 exercise concerning their participation in 2
the LERO plan?
A Yes.
3 4
0 And can you tell me what those are, please?
MS. McCLESKEY:
Objection, relevance.
I am not 5
going to instruct you not to answer, but I will note for 6
the record that it's 10:40 and this witness has been identi-7 8
fled for some specific issues and you've spent precious little g
time talking about them.
And I do expect this deposition to end around noon, 10 because we have someone else coming.
11 O
L
MS. LETSCllE :
I hope to finish by about 12:30.
12 BY MS. LETSCIIC :
(Continuing) 13 14 0
we were talking with the conversations with WALK radio personnel subsequent to the exercise.
15 A
Yes, I have spoken to them.
16 17 Q
And, can you tell me the substance of those conversations?
la 19 A
Apart again from normal ongoing business dealings involving media relations, I have had at least two telephone 20 conversations and one meeting with the management at that 21 station regarding their concern about the legality of their 22
' O 1
fa
)
/
73 r%
v 1
continued participation,as the EBS station.
2 Q
Have you had any conversations with other radio 3
stations concerning their participation in LERO as the 4
primary EBS station?
MS. McCLESKEY:
Objection, relevance.
And I will 5
instruct the witness not to answer.
6 7
BY MS. LETSCIIE :
(Continuing) 8 Q
Ms. Robinson, you are' aware of the fact that I g
assume WALK radio has terminated its agreement to participate in the LERO plan; is that right?
10 A
I have seen their correspondence.
11 12 Q
To your knowledge, has any substitute radio station been obtained by LILCO?
13 14 MS. McCLESKEY:
Objection.
It's irrelevant to the exercise litigation, and I instruct the witness not to 15 answer.
16 BY MS. LETSCIIE:
(Continuing) g7 18 0
You have stated -- strike that.
Ms. Robinson, when was the first time that you saw the objectives for lo the February 13 exercise?
20 A
I don't think I've over seen them.
21 22 O
You didn't attend a meeting prior to the exercise,
74
[\\
v i
some kind of a training session at which the' objectives of 2
that exercise were discussed and gone over?
3 A
No, I don't think so.
I don't remember any such.
4 Q
You are familiar with the exercise objectives, I take it?
5 A
Well, I'm familiar with what exercise objectives 6
7 are, and I've seen exercise objectives but not --
a Q
You've never seen the objectives for the February 9
13 exercise?
A Not that I remember.
10 11 0
Let me show you, Ms. Robinson, or perhaps your counsel can show you since she actually found the --
12 MS. McCLESKEY:
Page 8.
13 34 BY MS. LETSCHE:
(Continuing)
Q Beginning on Page'8 or Page 9 of the FEMA report, 15 I will show that to you and ask you if you have ever seen 16 17 those exercise objectives?
(The witness is looking at the document.)
18 19 A
Okay.
Yes, I have.
I think there was just some confusion about what you meant by the exercise objectives.
20 21 O
All right.
That makes sense.
Let's turn to the ones on -- there is a whole set on the ENC which begin on 22 t
75 A
1 Page 12 of the FEMA report.
And I take it you have seen 2
'those ENC related objectives before'?
3 A
Yes.
4 Q
Did you see those, or discuss those in any kind 5
of a training session or meeting prior to the February 13 exercise?
6 7
A No.
8 Q
From your other exercises and drills for LILCO g
as well as others that you have attended, did you understand to in general that these kinds of objectives would be involved 11 in the February 13 exercise?
'\\-'
A That the general functions -- the objectives, I 12 13 guess, are a little more specific.
But certainly I understood 14 what the general functions were of the Emergency News Center.
15 Q
And that the types of functions and abilities that are set forth in these ENC objectives, I through 7, would 16 17 be the subject of the February 13 exercise; did you generally 18 understand that prior to the exercise?
19 A
These kinds of functions, yes.
20 Q
Ms. Robinson, will you be testifying concerning i
21 whether or not the February 13 exercise was a full participation 22 exercise?
m
76
/-
(s t
A No.
2 Q
Do you -- strike.that.
Did you have any 3
discussions or involvement in the drafting or suggestion 4
of objectives for the February 13 exercise prior to that exercise?
5 6
A No.
7 Q
Did you participate in any meetings or discussions 8
or correspondence with Mr. Weismantle or Mr. Daverio concern-9 ing what sorts of things we might want to do during the 10 February 13 exercise?
A None.
11 A(-)
Q Did you have any meetings with Mr. Aidikoff or 12 13 Mr. Behr concerning the exercise objectives or scenario 14 prior to that exercise?
15 A
None.
16 Q
Did -- do you know why you were identified in 17 response to an interrogatory as someone who has knowledge of the facts concerning the development of the exercise 18 19 scenario and objectives?
A Only to the extent that I know nothing and was 20 l
21 told nothing.
l l
22 MS. McCLESKEY:
I will stipulate for the record L' T J
l i
l l
77-f
\\J 1
that that must have been an error, and we withdraw her 2
name in response to that question..
And I apologize for 3
it.
i_
4 MS. LETSCHE:
Okay.
BY MS. LETSCHE:
(Continuing) 5 6
Q Ms. Robinson, I~ understand that you are going to gl 7
be providing testimony on several of the admitted contentions 8
or subsumed contentions.
I g
,Can you -- maybe the easiest way to do it -- I
,t to don' t want to go through a lot :1f you are not going to testify on them.
Can you list for' me the contentions on 11
(' /
which you intend to testify?
12 A
I'ht not sure I can give you a complete set of 13 g4 numbers off the top of my head.
I expect to be on the Panels where public information is involved.
I believe 15 it's 38 and 39 and some subsumed parts of other contentions.
16 17 O
Okay.
MS. LETSCHE:
Off the record.
18 (Off-the-record.)
19 BY MS. LETSCHE:
(Continuing) 20 21 O
Okay.
For the record, we are looking at the version of the contentions that was prepared at the instruction 22
[~~
l L-]
-,--r-,-
78
'w) 1 of Judge Frye.
Nould you turn to Page 38 of that version?
2 MS. McCLESKEY:
Page 38?
3 MS. LETSCHE:- Yes.
4 BY MS. LETSCHE:
(Continuing) 5 Q
Beginning on Page 38,is Contention X-22 and in 6
Particular X-22.A.
Is that a subject upon which,y'ou will be
)
7 submitting testimony?
8 A
I believe that I may.
9 Q
Okay.
Have you begun to prepare any of your 10 testimony on that contention?
11 A
No.
p 12 Q
Well, at this time do you know the general subject 13 matter of your testimony on that contention?
14 A
As I said, there has been no testimony prepared.
15 I have an opinion, but I haven't prepared any, testimony.
16 0
Why don't you tell me what your opinion is?
g7 A
My opinion is that we had a valid agreement from the Nassau Coliseum at the time of the exercise.
We activated 18 l
l 19 it.
We demonstrated the techniques there that would be used 1
20 in any monitoring at decontamination facilities.
21 Q
Were you at the Nassau Coliseum at all during l
l l
22 the exercise?
m
(
79 4
O 1
A No, I was not.
2 O
Did you have any contacts during the exercise 3
with LERO personnel who.were,at the Coliseum?
4 A
Not directly.
5 0
Did you have indirect contact?
A Yes.
6 7
O And what were those?
8 A
Through the EOC in response to inquiries from endT2A g
the media.
(
10 Q
It is true, isn't it, Ms. Robinson, that during the exercise.it was assumed by the exercise players that 11 the Nassau Coliseum was the reception center to which people 12 were being directed in your EBS messages and your contacts 13 with the media?
34 A
Yes.
We had an agreement with the Nassau Coliseum.
15 We had a contract with '.ga.ti.,lh Aage.W1 eat g
N
_ red man 2;crent.
16 gp Q
Right.
And you don't have that anymore?
A That's correct.
18 19 0
Now, continuing with this document, beginning on Page 39 is Contention X-46.
Is that also a contention upon 20 which you intend to provide testimony?
21 22 j
(The witness is looking at the document.)
O
80
! /
t A
It's possible.
You know, the contentions have 2
changed so many times in their form that I'm getting a little confused with which one is which.
3 4
Q Well, certainly look 'it over because I don't 5
want you to answer without knowing what we are talking about here.
6 7
(The witness is looking at the document. )
8 A
Well, from what it says, 46 is one of the subsumed g
into 22.A.
So, on that basis I would have to say probably 10 yes.
11 Q
okay.
And I take it you haven't prepared any
(;
\\_/
testimony on that yet?
12 A
No, I have not.
13 14 Q
Do you, sitting here today, have an opinion or an -- an opinion concerning that contention?
15 A
Well, the opinion is that at the time of the 16 17 exercise it certainly -- because there was a valid contract, it certainly was assumed that the EBS messages would direct 18 39 evacuees who required monitoring and possibly decontamination to go to the Nassau Coliseum where that would take place.
20 If the facility changes for any reason, you 21 22 simply change the content of the EBS message and the f~s V)
81
(/
t brochures.
2 O
okay.
I assume you would agree with me though 3
that implementing an evacuation as set forth in the LERO 4
plan does require the availability of some reception center; 5
is that right?
A Yes.
That's a function of NUREG 0654, that you 6
7 provide for monitoring of people who arrive there within 12 8
hours.
9 Q
Okay.
Would you turn to Page 45, please?
10 A
Yes.
11 Q
I think you said before that this was one of the (k'
contentions you would be providing testimony on, Contention 12 X-38?
13 14 A
Yes.
Q Have you begun to prepare your testimony on 15 this contention?
16 17 A
Not formally, but I have had discussions with counsel.
18 19 Q
Have you prepared any kind, or seen any kind of a summary or statement of general position of LILCO witnesses 20 21 concerning Contention X-38?
22 A
Again, I've been working with counsel and there
r 82 has been correspondence.
I don't know that I would define l
1 2
it the same way that you have defined it, but there has
.3 been a work product working with the attorneys.
4 Q
~Okay.
You yourself haven't separately prepared 5
any summaries or statements of position'concerning Contention 6
38?
7 A
No.
I've participated in discussions with the 8
attorneys.
9 Q
'Okay.
Do you have an opinion -- strike that.
10 What do you intend your-testimony to be concerning Contention 11 X-38?
12 A
I'm afraid you are going to have to be a little 13 bit more~ specific than that or we are going to be here'for 14 two days while I tell you everything I think about dealing 15 with-the press.
16 Q
Okay.--I thought maybe we could do this shorter
'17 but I guess not.
l 18 MS. McCLESKEY:
To short-circuit this, perhaps
~ 19 you could give a brief summary of the gist of your response l
20 to Contention 38.
21 THE WITNESS:
If that's satisfactory.
I believe i
22 that despite certain equipment problems and some really o
83
/m k_)
1 peripheral problems that we had, that the ENC functioned as 2
planned, in that it was activated, it was staffed.
The press arrived there.
There was a single location available for 3
4 the press to come for information.
5 The participants in the exercise, LILCO and LERO, had spokespersons there to provide information.
Regular 6
7 briefings were held, that they were very frequent.
We had 8
a problem with providing hard copy because of a breakdown in 9
the copying machines but that the important information was 10 Provided to the media through press briefings, which is a 11 better way of doing it anyway than handing them pieces of
(~T U
12 Paper.
13 They needed background information.
There were 14 very comprehensive press kits there for both LERO and LILCO.
As far as the rumor control and the on-site part 15 16 of that, I think Brian McCaffrey is the better person to 17 tell you how that operated.
But there was good information 18 flow, at least from my point of view from the Operating Center l
l 19 from the EOC, I was able to get the information that I 20 needed to answer the questions I was being asked, of course, 21 within the constraints of the scenario.
l 22 And --
l
/~N N-]
84
~
O 1-LMS. LETSCHE:
Okay.
That's very helpful.
2' BY MS.'LETSCHE:
-(Continuing) 3 Q
You indicated that your opinion that the ENC 4
functioned as planned exists despite'the fact.that there 5
were equipment problems and peripheral problems.
6 With respect to equipment problems, are you 7
referring to anything other than.the copying' machines?
8 A
No.
That was the main problem.
And'I must tell 9'
- you, I' don't think I've ever attended an exercise where 10 somebody's copier didn't break.
Copiers are temperamental
-11 and that's why we have tried to work-around them as much as 0
12 possible.
'13 Q
Okay.
You also mentioned that you thought _the 14 ENC functioned as planned despite other peripheral problems.
15 What did you mean by~that?
16 A-Well, it's not perfect.
And I don't think any 17 press operation has ever been perfect.
You are dealing --
18 you know, it's not -- you can't compare it to kind of like 19 the evening news where you have a huge staff who prepares 20 things, where people are working from a written script with 21 teleprompters.
They are professionals, and it's very smooth 22 and very polished, and it just looks so totally effortless O
85 a
1
'and flawless.
-2 Wh'en you are dealing from a scenario which you 3
haven't seen, which makes it very real, and you know you are 4'
going to.have. problems where you repeat yourself, you 5
fracture the syntax, you may have to go back at some points a
and correct yourself, you may not have specific information-
-7 that is asked for the-first time you do a; press briefing.
8 You sometimes have to, you know, get it from somebody.
9 So, as I say, I think those are peripheral problems.
- 10 I think we were able to provide the essential information.
11 I'm not going to talk for Brian.
He will tell you how he 12 felt about his side of the operation.
13 But, from the LERO side,.I was notified when th'ere..
i 14 were changes in emergency status, I was notified of public 15 protective action recommendations.
When I called over, I 16 was able to get very specific information about staffing,.
~
j.
17
' activation, where. people were.
l 18 So, from'my point of view,.we were able to get
[
19 the important information, that which would affect'the' i
20 public, you know, the public's health and safety.
21 Q
Okay.
Is it your opinion Lhat you were able to 22 obtain, or were notified of, what you call the essential
- O i
n.,
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7.,
,,,_-.,---,_,,,.-m,e
-,.,,,,.,,.-n, e
e
86
,/
1 information in a timely manner?
2 A
Oh, yes.
I will add that timely does not mean 3
instantaneous.
4 Q
How many press briefings were held on the day of 5
the exercise?
6 A
I find a discrepancy from my own memory and the 7
notes that I've reviewed since then.
I believe the FEMA 8
report said there were six.
From what I've reviewed from 9
the materials which I believe have been made available, or 10 have been made available in discovery, I believe that it was 11 seven joint briefings and one LERO announcement, which I do 12 remember doing where protective action recommendations were 13 announced by LERO while I had been in the press briefing 14 so I just went back out myself and made that announcement 15 to the press.
16 It was about a five minute announcement where I 17 told them simply what was going out over the EBS system.
i 18 Q
What was that?
That was which recommendation 19 that you announced separately, if you recall?
20 A
I would have'to go back and look at the timelines 21 and the logs to see which one was which, but I know that that 22 was the only exception to the joint briefing policy, was that nU l
L
'~
87-s
~
1; I went out and made an announcement to.the' press.
2 Q
When you say joint policy, you mean you and Mr.
3 McCaffrey at a joint briefing?
4 A
That's right, that we were available to the 5
press at the same time.
6 Q
Is that part of the plan, that you would always 7
be available together rather than separately?
8 A
Not.always, but that that is'the general policy, 9
that for full-scale briefings both are available.'
That1does
~
10 not preclude making important announcements.
11 Q
You said before=that you. believed all the 12 important information was provided to.the media even though 13 you had a problem with obtaining the hard copy, and you said 14 that you thought that the briefing method was better than 15 providing paper to the media in any event.
16 What's the: basis for that opinion?
17 A
Having. dealt with them over'a number of years.
18 Generally speaking -- and this is not just for emergency 19 planning, but in general when you deal with-the press, even 20 if you give them the.most carefully. drafted and complete 21 press releases, it's only a starting point for them being 22 able to ask a live representative questions.
O
88 7(/
1 In addition to which there is just no way that a 2
press release, a written press release, can ever be gotten 3
out as quickly as you can orally convey important informa-
~
4 tion.
So, in any kind of a fast breaking incident or event 5
or, you know, whatever you want to call it, you are always 6
going to be able to give newer, fresher information by a 7
live briefing, which then it's a good idea to follow up 8
with a written press release so that there is a record that 9
can be checked back with, especially if numbers are involved to or any kind of information like that.
11 It's very good to have the written press release
(~';
12 to give out afterwards.
But it's a follow-up or a backup 13 to the live press briefing.
14 Q
But, in order to do that, I take it, you need --
15 you or whoever is doing the briefing needs to have the 16 accurate, up-to-date information in order to give it out, li right?
18 A
That's correct.
But you can get that from --
19 on the telephone in summary form and convey it that way very 20 quickly.
It takes longer to write it, clear it and --
21 just the production itself takes a certain amount of time, i
22 no matter how quickly you do it.
It's never as fast.
(~()
1 89 D"[ '
'l Q
-Is it your opinion:that during the exercise, you 1'
2
-did successfully receive the information on the telephone =
p 3
and dispense it to the press?
4 A
~Yes.
5 Q
Let me direct'yoOr attention to Page 46 of 6
the! contentions and in particular to.the' paragraph headed 7
X-38.A.
8 A
Right.
i
~
9' Q
Is it your opinion that the fact that there-j' to wasn't a~ press briefing until'8:40_-nonetheless resulted in a.
)
11
. timely provision of information.to the media on -the day of.
i 12 the exercise?
i
= 13-A Oh, yes, because that was not the'first-thing 14 that was available to them.
That was just the first briefing l
15 at the ENC.
I 16 Q.
I see.
What was available to the press prior to 17 that press briefing?
I
.A couple of things.
Some I can tell you about.
t 18 A
~
19 more specifica11yLthan-others simply because I wasn't part l
20 of the on-site organization.
l i
21 The media, to a very large extent, would have heard 1
i 22 the broadcast of an EBS message if there had been an EBS l
(
i i
t
..-.,.,.._..._,._.,___m-._....,_...~.
90
,(v i
1 message broadcast.
They would have heard it.
Certainly, 2
if sirens were sounded, not only would some media probably 3
have heard the sirens themselves but the public has a habit 4
of calling radio stations and saying:
What's happening?
5 So, the radio stations would have known that there 6
was something happening.
They would have done what they do 7
365 days a year which is to call the LILCO media information 8
number that is a telephone number that is covered 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 9
a day, seven days a week.
So, they would have had a source 10 of information.
11 I also know that LILCO put out two press releases
/]'
12 in that intervening period.
I'm just not familiar with
\\-
13 the specific times and the content of that.
You will have 14 to ask Brian.
15 0
But there wasn't any -- other than the EBS to messages and the sounding of the sirens, there was no other 17 information available to the press concerning off-site 18 conditions or recommendations prior to the press briefing; 19 is that right?
20 A
Well, again, had they called LILCO they would had 21 a way of feeding in questions, but by plan the on-site 22 organization activates the ENC at an alert.
And that's -- at O'a
91 I
(/
1 that point that's when you have the full-scale ENC.
But 2
the press has other means of getting information prior to 3
that.
4 0
Okay.
Well, you mentioned that they could hear 5
the EBS messages and that they could hear the sirens or 6
would have gotten phone calls from the public if the public 7
heard sirens.
8 A
Right.
9 Q
And you also mentioned the fact that the press to could have called the LILCO media information number.
What 11 is that?
Is that the rumor control function?
O#
12 A
No, no.
There is a regular -- the Corporate 13 Communications Department at LILCO maintains 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> phone 14 coverage.
There is a telephone number which is available to 15 the media, not to the public, and whether it's, you know, 300 16 houses out because there has been a lock-out in the sub-17 station or something as big as Hurricane Glorio or just --
18 you know, I've got a slow day, is anything doing?
That's 19 the number that the media calls.
20 Q
I see.
And during the February 13 exercise, 21 did the Corporate Communications Department 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> phone 22 line receive any information from LERO prior to 8:40?
('T U
92
(_./
1 A
No, because it was not a real emergency.
But in 2
a real emergency, what would have happened would be that 3
the LILCO press release, the first two press releases would 4
have gone out on the AP wire.
That AP wire, the same wire 5
that the radio stations get, is in the Corporate Communica-6 tions office and they would have access who to call into 7
LERO if they needed more information.
8 But, basically the only LERO information at that 9
time was what was on the EBS message, which was that the 10 schools were recommended to stay closed or implement early 11 dismissal programs ~if they had started picking up children.
12 Any other information at that point would have been informa-
'~
13 tion that's -- you know, Brian will, I'm sure, detail how 14 they get that.
15 Q
Okay.
But, during the exercise there wasn't any i
16 contact between LERO and this Corporate Communications l
l 17 telephone line, right?
l 18 A
There was some inquiries later in the day.
I 19 don't know -- you know, I just don't remember the log off-I
[
l 20 hand.
l 21 Q
Well, this Corporate Communications number or 22 this Department isn't mentioned anywhere in the LILCO plan, j
\\
(~)h
\\_
93 g-D 1
is it?
2 A'
hit is-in the on-site plan, yes.
I..justL-- as
~
3 I said, I'm not familiar with the details now.
~
4 Q.
But it's not mentioned anywhere in the plan 5:
that it involves LERO; is that right?
6 A
No.
7 Q
Did you have any contact with this Corporate 8
Communications Department during the exercise?
9 A
No,_I didn't.
10 Q
Let me just, direct your attention, Ms. Robinson, 11 to the bottom of Page 46 and continuing over to Page 47.
12 The_ paragraphs headed X-38.B and X-38.C relate to LERO 13 news releases that include--the information: that is described 14 in the paragraphs themselves.
15 A
Right.
16 Q
And they mention the times at which those press 17 releases were made available to the media.
18 A
Right.
19 Q
I take it from your earlier answer that you don't 20 believe that the time periods stated in here, between when 21 various decisions or declarations were made and when these 22 press releases were released to the press, that you don't O
94
- Q g
i believe that.that was'.any kind of.a problem; is that right?
-2 A
No, I don't.
- 3' Q'
Okay.
Can you tell me.why you don't think that 4
those. time periods represent any kind of a problem?
5 A'
Well, looking specifically at X-38.C where you-
~
6 are talking about something that went out on an EBS message, 7
our primary concern is getting_the EBS message drafted, ap-8 proved and aired, because that goes to the people you are 9
most concerned about, those who may have to take some. action 10 for-their own health and safety. -That is the primary concern, 11 and I don't think there is any question in any of.our minds 12 about that.
- 13 The second interest is in getting that informa-14 tion to the media so that they can (a) confirm, perhaps do 15 a wider broadcast of the information that's going out to the 16 population in the EPZ; and, also simply because there is 17 always a risk that if you are not giving them any information 18 that misinformation will get out.
.19 I feel very strongly that in a fast breaking 20 incident of any kind, the best way to do that is through 21 press briefings, not by handing out th'e paper.
And, besides 22 which looking at these times, if they are accurate, I think.
O
95 I
)
xs 1
we did damn well in getting out hard copy.
2 Q
Directing your attention to the bottom of Page 47, 3
the paragraph headed X-38.F, there is a reference to the 4
fact that EBS messages provided to the media contained 5
extraneous information.
6 I assume you agree that that's the case, that 7
did happen?
8 A
I agree that they were very sloppy looking, but 9
again the primary concern was getting the information out.
10 It wasn't the normal standards of production that you would 11 use in a public affairs operation, so that normally, of U<w 12 course, you would never put out anything that had things la crossed out or written in.
It would always be very smoothly 14 retyped.
15 But that just -- you know, I don't think it's, 16 you know, a first priority.
And to the extent the copies 17 looked sloppy, that is corrected by using the word processing 18 equipment, by using the TSO rather than a handwritten 19 copy, that is telecopied.
20 0
Why is it that normally you would never hand out 21 something that has cross-outs and things like that on it?
22 A
Well, because it just really doesn't look professior al r
u 96 1
and it's not the kind of impression.that you;want to give.
2 But if you are dealing with an emergency,.you don't worry 3
about appearances.
4 Q
Let me direct your attention to Page 48, the
~
5 paragraph headed X-38.H.
6 A-
~ Right.
7 Q
Okay.
There was not a briefing or a message'given 8
to the media concerning the full EPZ evacuation until 9
approximately 12:45, 12:47,.around.that time frame,1even 10 though that decision had been made quite a1 bit earlier and 11 the EBS message had gone out at around noon.
12 Is it your opinion that that is also an adequate
. 13 dissemination of information to the press?
14 A
Yes.
I would-have.been very concerned had the 15 sequence gone.the other way and the media had the information 16 before it was being broadcast on the EBS.
But, because the 17 sequence is correct -- and that's of primary importance --
18 from this, and just from memory I cannot remember what else 19 was going on in that time period, but I would say the 20 sequence is the most important-thingtand that's what is 21 acceptable.
22 O
Why would you have been very concerned if the media j.
6
-,,,,.-y
-97
)-
I had had that information first?
2 A
Again, the EBS system that goes to the people 3
that.have'to take the action, has to be the primary source.
4 of information.
5
.Q Why is that?
6 A
Because those are.the people that if the --
7 when you are-talking to the media, if.nothing else,'-aside-8 from the radio stations who may go on live, the television 9
stations may not use the information until the'6 or 11 o' clock 10 broadcast that night if they are not part of an EBS network.-
11 If they are part of the EBS network, they already have the O
\\"l information.
12 13 And the print media may not use it until the 14 following day.
So, to get the information to the public 15 you've got to make your EBS network the. primary considera-16 tion.
17 Q
And the fact that there is nothing but the EBS 18 message for roughly an hour on this type of protective action 19 recommendation doesn't concern you; is that right?
20 A
Well, looking at.this,.the time frame, it's 21 closer to three-quarters of an hour.
And, no, I think that 22 is -- in my opinion, that's quite reasonable.
O
98-
,7 V
i O
Okay.
A'ddressing your attention to: paragraph-2 X-38.I on the bottom of Page 48, that involves the 3
ingestion of potassium iodide tablets..When did you learn 4
during.the exercise that.that instruction had been given 5
to the LILCO and LERO workers?
6 A
I don't'know.about LILCO workers, and I.really 7
don't remember if Ileven was told.about'the -- you'know, 8
when I was told about the LERO workers.
9 Q
You were never instructed to ingest potassium 10 iodide tablets during the exercise?
11 A
Oh, no.
I was in the News Center which is well 12 outside the emergency planning zone.
There would be no 13
' reason.
14 Q.
Were you asked any questions during any of the 15 press briefings about-ingestion of potassium iodide by 16 workers?
17 A
No.
18 Q
Do you know whether'Mr. McCaffrey was?
1 l
19 A
Not in my presence.
20 Q
Do you know whether the media was ever officially 21 informed by anyone from LILCO'or LERO about thatLinstruction?
22 A
I don't believe they were, because it did not affect
~..
~.
. ~ -
99
-(
)
v 1
the public.
And since -- as I say, I was prepared to answer 2
questions about it, but I was never asked any.
3 Q
So, you did-know that they had been instructed 4
to ingest it?
5 A
No.
I knew that it was part of the plan, that'at 6
a certain point those workers who would have to remain in 7
the field during a possible release and assist people in the 8
evacuation would be told to ingest KI.
9 Q
But you never learned during the exercise --
10 A
I'm sure --
11 Q
-- whether that' instruction had been given one p.
12 way or the other?
13 A
I'm sure I was told at some point, but again it 14 was just something.
15 Q
Okay.
That wasn't something that you felt was 16 important to tell the press?
end T2 17 A
No, because it did not affect the public.
18 Q
If you had been asked that question, would you 19 have told them?
20 A
Oh, absolutely and explained exactly why it was 21 given to the field workers and not distributed to the 22 general public.
O v
100 (v) 1 Q
What was your source of information during the 2
exercise concerning traffic conditions in the EPZ?
3 A
The Emergency Operations Center.
4 O
And that was by telephone that you received such 5
information?
6 A
By telephone, by -- I'm trying to think if I 7
actually received anything by telecopy.
I don't remember, 8
but it certainly was a possibility.
9 Q
Any particular person at the EOC that was your-10 source of information?
11 A
The Public Information Staff members.
(~
\\
t 12 Q
And, do you recall when you first learned about
'~'
13 the traffic impediment that had occurred during the day 14 of the exercise?
15 A
Oh, no, I don't remember specific times at all 16 at this point.
17 Q
Did you keep a log during the exercise?
18 A
No, I didn't personally.
I didn't have time to 19 Write anything.
20 Q
Did anyone keep a log concerning your activities?
21 A
The person on the telephone kept a log, and then 22 one of the Staff members basically was taking notes from me.
O\\_)
-=
101
)
4 And so she would take information, either that she had 1
2 gotten' on'the telephone or out of the log and I guess it 3
was like on a yellow pad, she would write me these notes 4
with times; and,-then when I was about to do a press briefing W
what we would do was -- if the cop;. ";; were working -- I would. $$6 s
1 i
just xerox, you know, the pages that she had ad'ded since 6
i
.7 the-last briefing and use those as my notes for.the press 8
briefings, because-I just did not have time to write anything.
(
-9 0
And is that the --fwas that acc'ording to the plan, 10 that the only logs that would be taken would be the person 11 on the telephone and the Staff: member who would take notes 12 for you; is that --
13 A
Well,.the only thing that's by plan, or specificall y 14 by procedure, is that there is a log kept.
The notes weren't 15 you know, were just one method of doing that, an additional 16 method of doing that.
l 17 0
And the log that is supposed to be kept, according 18 to the procedures, is to be kept by whom?
.19 A
A Staff member.
And, you know, it's in a book 20 and it's just logging your activities.
21 The operation at the ENC has to be very flexible 22 by the nature of what you are doing and you are responding
-- y
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4 102 N
L l'
to other people's needs in a sense, and you can't pin it down 2
too much.
i-t 3
0 Now, going back'for a second to modifications 4
in your procedures that have been made subsequent to'the 5
exercise, there hasn't been'any decision to'have more than 6
one lERO spokesperson acting?
7 A
Not at one time.
That would defeat.the purpose.
i
?
8 0
Why is that?
9 A
Well, the idea is to have a focal point for to information so that'everybody is getting consistent informa-11 tion.
And that's why you have the single focal point, who is the O
12 spokesperson.
13 That doesn't mean you don't have assistance from 14 the Staff but somebody has got to be heading it up.
15 0
Are you familiar with a group of personnel among.
f 16 the Public Information Staff whose responsibility is to l
17 monitor the meeting?
18 A
That's an on-site function.
Media monitoring i
3 1
19 is an on-site function.
I 20 0
Did you have any involvement with any media
- 21 monitoring personnel during the February 13 exercise?
22 A
What LERO does is, in essence, use a LILCO 1
.. - ~
-- ~.
103 l
1 resource so.that one of-the LERO Public Information Staff-r 2
people'will go into the monitoring,-we'll look at-their 3
logs,. check to see.if there is any information that needs 2
4 correcting either. immediately -- if it's. bad ~enough, you 5
might go out and do an announcement.- That would be one 6
. reason why you would want to do an individual announcement 7
if there is information out there that is just wrong or-8 something that there seems to be-a pervasive question about, 9
an issue that you would want the spokesperson to bring up at to the next meeting.
11 LERO uses the media monitoring, but does not --
O.
12 it's not a LERO function.
13 Q
Was the' media monitoring used by LERO during.the 14 exercise?
15 A
To that extent, yes.
16 Q
Did you do any of that yourself?
17 A
No.
18 Q
Who did?
19 A
There -- as I say, there were a number of Staff 20 people and periodically one of them would just go down the i
21 hall and do that.
22 Q
Now, during the exercise, what was it that the
! (~)
l 4
_ - _. - _ -. - -, _, -... -. _ -. _ - _, _ - ~,, -,,. -. _. -. -
104 V
1 media monitoring personnel were monitoring?
2 A
They were listening to actual coverage.
Obviously, 3
if it was a real accident they would be listening to the 4
coverage of the real accident.
But there was -- particularly 5
in the case of radio, there was coverage of the drill, the 6
exercise, throughout the day.
7 So, they were able to exercise their function 8
pretty accurately.
9 Q
I see.
And when the LERO individuals who, during to the exercise, used the media monitoring materials, what did 11 they do?
t
/
12 A
Well, they would go down, as I say, and check 13 the logs.
Now, had it been a real accident where public 14 protective action recommendations were being made to the 15 public, they would want to check to make sure that the correct 16 zones were being told to evacuate or shelter, that kind of 17 thing.
18 This way, they would just -- as I say, monitoring 19 the information that was available.
20 0
So, they really didn't have to engage in a decision 21 of whether it was misinformation or things that needed to 22 be corrected on the day of the exercise?
O U
- 3 105
-(];.
1 A
Well,'what they -- they'just came back and 2
' reported on:the coverage so that we knew what was going on.
.3 Since most of the coverage was~outside the scenario'and 4
things ~that we.could not talk about until the exercise was 5
ter inated, to that point we couldn't do anythina about-it.
1 6
MS. LETSChiE:
Off the record.
7
'(Off-the-record.)
8 BY MS. ~ LETSCHE:
(Continuing)-
j g
9 Q
Okay.
Ms. Robinson, would you tuze to Page 51 10 of the contentions, please?
11 It's where Contention X-39 is.
This is a con-12 tention that deals with the rumor control activitie's during 13 the exercise.
Is this also one that you will be providing 14 testimony on?
15 A
Yes, it is.
16 Q
Maybe we can use the same procedure we used 17 before with Contention 38.
Can you tell me gen'erally what 18 your opinion or position is going to be concerning Contention 19 X-39?
20 A
I will try to summarize it.
First of all, I 3
21
'think that we have to set standards for what we are trying 22 to do here, and that is to provide accurate and timely 1
s 4
106 4
-s
-' h, 1
information and-accurate comes before timely.
Information 2
that is not-accurate is not just valueless, it's potentially 3
dangerous so that that's the way that I would set the-4 standard.
\\.
5 I think that a problem has been identified in the timeliness factor.
It was caused by the procedures' e
7 dependence on copying machines, which were certainly not 8
.as reliable as I.would have liked them to be, and so there 9
was some delay in answering individual inqui ies, especially.
K i
~
involving the status of the emergency level at various lo 0,)
' 11 points.
O' 12 I think that the new procedures that we've E~
13 developed and submitted in Rev 7 and/or 8 will. cure.that 14 problem.
15 As to the individual inquiries, again I don't 16 think that timely means immediate.
I think that the need 17 for accuracy, especially in dealing with that kind of --
18 again, I wish I could think of a better word than eccentric-is inquiry, but where somebody is really asking a question that 20 you just cannot provide standard answers for, -you -- it's 21 going to take some time to get the answer, because there 22 may be only one or two people who can provide that kind of I
107 f
l'h G
1 answer, so you have to find them, you have to get the 2
answer.
In those cases, you know, there has to be a different 3
definition for timely than you would use, say, to get an 4
EBS message out where people have to take protective actions.
^
5 In addition, you also have to set a hierarchy of 6
how you are going to handle information.
And, as I said 7
before, the EBS system is always number one.
Then, are the 8
press briefings and.the backup press releases for the media, 9
because again that goes out to large numbers of people.
10 And then you deal with the individual inquiries, 11 because when you deal with emerges.cy planning you are dealing n
)
(' ~'
12 with a large population.
So, you want to satisfy the 13 individual and protect the individual but that can't be 14 your first priority.
15 0
Ms. Robinson, on Page 51 there is a quotation 16 there about halfway down the page, it starts:
"LILCO r
17 personnel at these locations..." do you see that?
l 18 A
Right.
19 Q
That's a quotation from the LILCO plan, and it 20 says that if people at these locations -- and it's referring 1
21 to the customer call boards and district offices -- can't i
i 22 answer an inquiry they will call the ENC where a coordinated
,m.
%,')
(
108
'x_)
1 rumor control point will be manned by representatives from 2
LERO and the utility.
3 I take it from what you have said earlier in this 4
deposition that that's not the case, that in fact the 5
coordinated rumor control point is manned by representatives 6
just from the utility; is that right?
7 A
The personnel are from the utility, but they 8
coordinate with the LERO operation.
They have access, 9
continual access, to the LERO organization in order to get to information.
11 O
Right.
But the rumor control personnel, all o
I'~ ]
12 the people who have titles of rumor control as well as those 13 who are involved in the media monitoring, are in fact all 14 utility employees and not LERO --
15 A
They are not members of LERO, no.
16 Q
And, all the people who are the district offices 17 and customer call boards are also regular LILCO employees 18 and not members of LERO; is that right?
19 A
That's correct.
20 0
And so none of -- strike that.
Now, you mentioned 21 in your general summary that in your opinion the new procedure s 22 will cure the -- what you call problem with timeliness, and
(~')
109 O
rL ;i 1
you referred to some delay in answering some of the inquiries, 2
especially about the status of the emergency.
Are the new 3
Procedures you are referring to the use of the computer 4
that we discussed earlier?
5 A
The combination of the summary sheet which gives 6
the status of emergency and any protective action recommenda-7 tions and the simultaneous transmissions by TSO network, 8
yes.
9 Q
But I take it from the rest of your answer that to with respect to responses _to what you call the eccentric 11 inquiries that there really hasn't been any modification
(
12 in the procedures to try to reduce the amount of time it
'~'
13 takes to respond to those; is that right?
14 A
I think that the fact that it is an individual 15 inquiry requiring specific information which is not the 16 kind of information that you are using for your general 17 response work for the general public information, sets 18 the kind of minimum time frame on it, combined with the need i
19 for absolute accuracy in this kind of thing, because 20 especially if it's a rumor involved you've got -- rumors 21 are not inquiries.
Rumors are something that people believe l
22 without a basis.
It's even possible that a rumor might be l
(<h>
I l
110
(-
\\_,'
I right, but they just don't know why it's right.
It's the 2
kind of, you know, the they-say kind of thing.
3 So that in order to deal with that you have to 4
be -- especially if it's something that somebody believes 5
is wrong, you have to have very specific and certified 6
information to dispel that rumor.
You just can't do that 7
off the top of your head, because'if a person believes 8
something, you know, just somebody at the other end of a 9
phone saying, no, that's wrong.
I mean, that's just not to going to do it.
You have to tell them why it's wrong, 11 and there has to be a formalized procedure for confirming fT' 12 that information..
13 So, I would say that where you see times on 14 individual inquiries of 30 or 35 minutes, I think that 15 is just about as good as anybody could do with that.
16 Q
Now, let me -- would you turn to Page 53,'and 17 beginning on Page 53 and going over to Page 55, under the 18 heading X-39.B, there is a whole group of telephone inquiries 19 that were rumor messages --
20 A
Right.
21 0
-- generated during the exercise.
Would you l
22 characterize all of that list of inquiries as in your (v~)
s.
I 111 l'
' eccentric. question category?
2-(The witness is looking.at the, document.)
-3 A
I think-I should define by eccentric'thatI mean
~
4 individual --
5 Q
Right.
6 A
-- not within what can be -- it's something that t
7 just cannot be planned for, because you -- nobody could 8
possibly. plan for every single inquiry that. people are going 9
to think up.
10 Q.
Right.
Okay.
Well, give me~your definition.
11 A-
'I would;say thati<--?on going through'this ---
12 these were all inquiries about individual response -- I 13 don't see anything that I would really classify as a rumor.
14 Q.
In.your opinion,.are rumors capable of being 15 handled differently than the individual inquiry type 16 question that we have been discussing?-
17 A
Again, it would-depend on what the rumor referred 18 to.
If the rumor referred to:
I heard there is a general 19 emergency at the Shoreham Nuclear Power Plant; and the answer 20' is:
No, there is an alert level of emergency, that is a 21 rumor that could be handled differently.
22 Q
Okay.
But all of these ones in Contention X-39.B O
112 f3
()
1 are in the individual category?
2 A
They are individual questions, right.
They are 3
questions that -- now, if you started getting a pattern of 4
questions like this, then it becomes in the rumor category 5
and there are, you know, different ways of handling it.
6 Q
Okay.
If there were a pattern, if the pattern 7
were established along the lines that you have just said, 8
how-would that -- that would then turn into a rumor, and 9
how would that be handled --
10 A.
Well, there are --
11 0
-- under the LERO plan?
12 A
There are a couple of ways handling them, and j
13 actually during the exercise itself the only one that came 14 into that category was an "on-site" rumor and was handled i
15 by the on-site organization.
It involved the question of i
whether or not a nuclear plant can blow up like a bomb.
16 i
17 And the reason I'm familiar with this, I was la sitting in the room when it was handled.
The Emergency News l
19 Manager just came out and made an announcement that there 20 were a number of rumors regarding this and the correct 21 information.
That's one way of handling it.
22 Again, I'm going to have to give you a hypothetical OO
113 i) x/
1 If it was a LERO question of, say, a zone being told to 2
evacuate when they should have been sheltering or sheltering 3
when they should have been told to evacuate, you would_want 4
to get right out to the media and make a special announcement 5
and ask them to please get on the air, you know, and correct 6
this.
7 Q
But none of those happened during the exercise?
8 A
I don't remember anything like that.
As I say, 9
the only one I remember was an on-site question.
And, you 10 know, Brian will be able to tell you how he picked up that 11 pattern.
(q think is probably 12 Q
Staying on Page 55, which I
\\
13 where you landed, that's -- on that page is where paragraph 14 X-39.C begins, and there are a number of examples of rumor 15 messages listed --
16 A
Right.
17 Q
-- under that heading also.
I take it from the 18 definitions we have been talking about that each one of l
19 those would also be in your individual inquiry category; is l
20 that right?
I 21 A
Well,they are individual categories.
Some of them 22 look to me more like media inquiries than inquiries coming
'N (O
114 0
1 from members of the public.
But, I don't know that that's 2
an important definition.
I think there'are one or two that 3
are-media" inquiries.
4 Q
Under the LERO plan, areimedia inquiries handled 5
.any differently from~ inquiries from a member of the public?
6 A
Up to a point, no.
AndJafter:that point,. media 7
are told:
Cone to the Emergency NewsLCenter where the-8 information they*want,is available'and where spokespersons 9
are available to respond to them.
10 Q
Well',(what'.isEthe-point at'which that -- and, 11 I take it-that --
12 A
I mean, if'a~ media person just called and asked 13 for the status of emergency, whoever is answ~ering if they 14 have the information they are' going to give it to them.
If 15 they start asking questions, they are going to tell them 16 they have'to go to the Emergency News Center.
17 0
And this is the customer service people at the 18 call boards or' district office --
19 A
I know that all -- I really cannot answer.
You 20 will have to ask Brian about district office personnel.
I l--
i 21 know that all LERO people, you know, are informed that all
[
22 media inquiries go to the Emergency News Center.
LO 6
s-
115
(-
C/
1 Q
Okay.
I take it though that the ones that you 2
would characterize as media inquiries that are set forth 3
in subpart C of Contention X-39, that none of-those got 4
up to the point where these people were told to come to 5
the ENC.
The inquiries instead were just answered; is 6
that right?
7 A
That's correct.
From what I see here, there 8
was no attempt to interview anybody.
9 Q
Okay.
Would you turn to Page 58, please?
At 10 the bottom of that page is the first sentence of Contention 11 X-44 which has been consolidated with these other contentions.
O 12 Is that a matter or an issue upon which you 13 will be providing testimony?
14 (The witness is looking at the document.)
15 A
On the first portion of that, yes.
16 0
Okay.
Do you know the gist of the testimony that 17 you intend to provide on the first question of what is in 18 Contention X-44?
19 A
Well, I guess that we do not agree that it 20 revealed a fundamental flaw in the ability to provide in-21 formation.
22 O
Okay.
And, is that for any reasons other than OV
116
..Q:
V 1-those we have already discussed with respect to Contentions-
'2 38 and 397 3
A-I-would say that generally.-- again, I am' going 4
to try and summarize very quickly -- that in the most 5
essential' area, which is information to the public, either 6
the -- I'm going to call them the public at' risk, the people 7
within the EPZ,.those who have to take a protective action 8
recommendation, that the EBS messages were clear, accurate, 9
concise and' issued in a very_ timely manner, that additional to information was provided to the press ~ media through press 11 briefings in,;again I think, very frequent and complete
[)
12 briefings.
You can't answer questions that aren't asked.
'~'
13 If they didn't!!ask!the: questions, you:can't say that we 14 didn't answer them.
15 But that a lot of information was given out.
16 There were some problems because of the copying with hard 17 copy and there also were some problems with providing 18 information to these district offices and call boards for 19 answering individual inquiries.
In that case, I think that 20 the problem, you know, has been fixed so I don't see that 21 there is a fundamental flaw at all.
22 Q
You mentioned in your answer that you can't --
4 117
.i this isn't a quote, but what I jotted down, was that you.
2 can't say.that you didn't answer questions if the questions
-weren't asked. Did you have anything in particular in mind 3
4
. when you said that?
5 Have -there been suggestions by observers or 6
evaluators of the exercise that there was.some problem in i
7 not'providing certain information?
8 A
Just based on the contention.
g Q
Anything in particular in the contention that-10 you are referring to?
A I think an example would be the portion of the it 4
12 contention-on the'KI, on the distribution of KI.
4 13 0
I see.
.okay.
Other than the-problems with the-i hard copy and the timeliness facts concerning answering 14 15 individual inquiries, have you been told by any evaluators 16 or observers of any other problems or things that could be 17 Improved upon or corrected among the responses at the ENC 18 during the exercise?
19 A
Oh, there were comments and I think there was 20 one that I remember, and I certainly don't remember the exact 21 words, about this question of being polished.
And I think 22 I explained that before.
Quite truthfully, in terms of i
e
118
%)
1 providing emergency information, in terms of providing --
2 dealing with that, I really think polish is unimportant.
Q Any other comments or observations about things 3
that could be improved upon or that were not accurate?
4 A
Not that I remember.
As I say, there was this 5
problem with providing hard copy and getting it out to 6
remote locations, and we have tackled it.
7 8
Q And, you have indicated that your testimony would 9
only cover the, I think you said the first part of what's in this portion of Contentimt. X-44.
I take it that you do 10 not intend to provide testimony on whether or not there 11
(/
w uld be a voluntary evacuation or an evacuation shadow in s_
12 the event of a Shoreham accident; is that right?
33 A
I will testify as to the facts of what went on 14 that day.
I don't consider myself an expert on human 15 chavior.
i 16 Q
Okay.
Now, during the exercise you were asked g7 a question, or maybe more than one question, about some --
l 18 l
from the press, by the press, about whether or not there was 19 any v luntary evacuation; is that right?
20 l
A There were several questions to that effect.
21 l
22 O
And during the exercise, your response was that f~L)j l
l
119
!ml
%)
I there wasn't any; is that right?
2 A
Again, I don't remember my exact words.
But I 3
do remember on several occasions saying that none had been 4
reported.
And, again within the scenario, none were 5
reported.
That's what you deal with during an exercise.
6 Q
Okay.
Would you turn to Page 59.
That is headed 7
X-22.F.
Is this a -- the substance of it was subsumed under 8
Contention 38 and 39.
9 Is this an issue, or are the issues stated in 10 here issues upon which you will be testifying?
11 A
To some extent, yes.
Ch kJ O
Can you describe for me the extent?
12 13 A
Well, the extent is to -- you know, to the 14 extent that I can testify to this, is how we operated that 15 day.
And it was not -- you know, it was not based on 16 assumptions.
It was based on a scenario, which we were being 17 which was being fed into the processes as the day went along.
We were not making independent assumptions.
18 19 Obviously, we had certain knowledge and background as we dealt with the various roles.
But, certainly for myself I 20 21 was not making any independent assumptions.
22 O
Right.
[x>
120 p
V 1
A I was just working on the scenario.
To that 2
extent, I would expect to but not beyond that.
3 Q
Right.
So, you are the -- the basis of your 4
activities during the exercise was the scenario and the 5
assumptions that were in the scenario, or what you were 6
relying upon or operating on?
7 A
Well, I wouldn't call them assumptions.
They are 8
the parameters of the scenario.
And that is the information 9
that is in scenarios.
There is a whole -- obviously, when to you come into the scenario, you bring with you your 11 experience and your knowledge of certain kinds of operations.
}
12 But it was not something that was done on my
~'
13 assumptions or anybody else's assumptions.
14 Q
They were what you were told --
15 A
Is the situation.
16 Q
-- is the situation?
Okay.
And that was what 17 was in the scenario, correct?
18 A
That's correct.
19 Q
Now, during the exercise, I believe you said that 20 there were no reports given to you that there had been any 21 spontaneous evacuation, right?
22 A
That's correct.
O
121
(~')
\\J 1
Q And I take it that you also didn't have any 2
reports that there were any traffic problems on the roads 3
prior to the time that you made an announcement to the 4
press concerning the impediment; is that right?
5 A
Well, we had discussed traffic in general and the 6
fact that evacuations take place at slow speeds and there 7
are traffic guides to help out but, no, there were these 8
two -- which I, to this day, find extraordinary that these 9
two major accidents happened so close to one another in such 10 a short space of time.
But that was what was in the scenario.
11 0
Okay.
And, I take it that also during the C)i k_
exercise you were told by the EOC that the approximate number 12 13 of people who had-been advised to go to the Nassau Coliseum, 14 was it 95 or 100,000, up in that range?
A Some of the calculations came from the EOC.
Some 15 of them were just done out of the press kits.
The informa-16 17 tion was in the press kits of how many people lived in the i
18 zone.
And I know on one of the answers to the questions, one 19 of the guys just took out a little hand calculator and added 20 up the population in those zones.
21 0
okay.
22 A
So, that's not something that would have to necessarily
(
(~'T RJ l
l
122
/~h o
1 come from the EOC.
I don't remember which was which.
2 But that information was all at the ENC.
3 Q
I take it that you don't intend to testify about 4
survey research data or public response to the accident at 5
Chernobyl or any of the other matters listed on Page 60 6
in your testimony concerning --
7 A
No.
As I say, I'm not an expert witness on human 8
behavior.
g Q
Do y u intend to provide any testimony concerning 10 the contents of LILCO's EBS messages beyond the opinion that 11 you stated before?
m 12 A
Just as to the facts.
13 Q
I don't understand what you mean by that.
14 A
Well, that what was in the EBS message was accurate as to what had been decided by the Director of LERO at 15 that time.
16 g7 O
All right.
And I assume you are not going to 18 be providing testimony concerning LILCO's credibility with 19 the people on Long Island; is that right?
A That's correct.
20 l
21 O
Okay.
On Page 61, we have the beginning of 22 Contention X-42, which has been subsumed under some of these
/"M
,-]
123
(
).
%.J 1
other contentions.
Do you intend to provide testimony 2
concerning any of the-matters set forth in that contention?
3 (The witness is looking at the document. )
4 A
You will have to give me a minute to read here, because with the subsumed --
5 6
Q Yes.
7 (The witness is looking at the document.)
s A
We have already discussed it, 42.C.
9 Q
And would your testimony on that be any different to from what we have already discussed on the Contention 39?
11 A
No.
And 42.G as well.
(
12 Q
Okay.
And would your testimony concerning 42.G 13 differ from what we have already discussed?
14 A
No.
That would be under 38.
Q Okay.
Turn to Page 84.
15 A
- Okay, 16 g7 MS. LETSCHE:
Off the record.
18 (Off-the-record.)
l l
19 BY MS. LETSCHE:
(Continuing) 0 Okay.
Beginning on Page 84 is Contention X-49.
20 i
l 21 Is that a contention upon which you intend to provide 22 testimony?
124
~h (V.
1 (The witness is looking-at the document. )
2 A
Yes.
3 Q
Okay.
Can you summarize for me the gist of 4
your opinions or. testimony concerning the issues raised in 5
Contention X-49?
6 A
To the extent that it involves activities at the 7
Coliseum, the EBS portion of that, how that was handled 8
with respect to it, and the fact again.that this -- this is 9
my opinion, that we demonstrated the ability to do this, 10 whether it was directing people to the Coliseum cr some 11 other facility or facilities.
O l-12 0
okay.
I guess I'm not real clear what you mean 13 about you are going to testify about the EBS aspect of this 14 contention.
Is there something in particular that you are 15 referring to?
16 A
Well, one of the parts of this involves directing 17 people to the reception centers over the EBS and the numbers 18 of people that would be involved.
19 0
And, what do you intend to testify to about that?
20 A
I'm trying --
21 0
Let me just see if I can understand.
Are you 22 referring to the statement on Page 85 that during the exercise O
v
125
(~'%
V 1
LILCO and simulated EBS messages advised over 100,000 2
evacuees --
3 A
Well, you are going through that and then through 4
the portions of -- some portion of 31 which had been subsumed 5
which referred to the -- specifically to the question of the 6
Coliseum and directing people there through the public 7
information program, the numbers of people involved.
8 Q
Okay.
Let's see if we can clear this up a 9
little bit.
I an a little confused.
10 I take it you are not going to be testifying about whether the monitoring procedure and how long it took people it
(")
\\/
at the Coliseum to monitor evacuees, whether or not that was 12 13 adequate?
14 That's not something that you are going to be 15 testifying about?
16 A
In terms of any technical details of monitoring, 17 the answer to that is no.
I am not a health physicist.
18 Q
Okay.
Or, do you intend to testify about any 19 aspects of the monitoring that went on during the exercise?
20 A
Yes.
I have an opinion based on just dealing with 21 people as to why it sometimes took as long as it did.
22 0
And, what is that?
126 l
V 1
A That it was the fact that this was an exercise 2
with a.-- while I think it was a fairly large number of 3
people that they got to monitor for an exercise, you know, 4
who actually went to the reception center to be monitored, 5
there were so many monitors provided in the LERO plan that 6
they tended to, you know, try to fill up the time and I don't 7
think they were, you know, looking at their watches at this 8
point because it's nobody waiting to be monitored.
9 I think you would see a very different response 10 in a real emergency where there is, you know, just the 11 pressure of people standing there, to get them moving.
I've
/~N kJ seen them do it in 90 seconds, to the satisfaction of 12 13 observers who are health physicists.
And, you know, to 14 that extent I could-testifv to the fact.
15 Q
Okay.
Is it true that you have been at LERO drills or exercises and observed actual monitoring by LERO personnel?
16 g7 A
No.
This was when we were very early on, the la times when we were working on the plan originally.
The times 19 were not just pulled out of people's heads.
They were very clearly defined by testing them, 20 21 just as we tested telephone calls by actually having people 22 call one another and seeing, you know, how long a certain l
127 p
V 1
number of rings takes, how long -- you know, that kind of 2
thing.
3 We also did that with monitoring.
And there are 4
specific rates that are set for the equipment.
And, you 5
know, working at that rate with somebody standing with a 6
stop watch to do an accurate' scan, and that's how we came 7
up with the 90 seconds.
8 Q
And it's based on that activity that took place 9
early on, as you put it --
10 A
Right.
11 Q
-- that you believe that in a real emergency the 90 second time would be adhered to?
12 13 A
Would be adequate, yes.
14 0
But, that that would actually be performed --
A Yeah.
I think that --
15 Q
-- by those individuals?
16 g7 A
I think that that combined with the fact that 18 when, you know, there is the pressure of a line of people f
19 coming in and the pressure to get it done, the supervisors l
would see those lines and would be much more conscious of 20 f
21 keeping the people to a schedule.
22 Q
So, in a real emergency you think people would do i
128 (3
C/
1 it faster?
2 A
Yes, I do, endT3A 3
Q Have you observed any drills or training or 4
exercises subsequent to the February 13 exercise at which 5
LERO personnel were monitoring or practicing their monitor-6 ing?
7 A
No, I haven't.
8 O
Now, would you turn to Page 86, please?
The 9
paragraph on that page is headed X-49.B concerns the proposal 10 to telephone INPO and other power plants and other entities 11 to obtain additional monitoring personnel.
12 Is that a portion of Contention 49 that you 13 intend to testify on?
14 A
No, it'is not.
15 Q
Also on that page is a paragraph headed X-49.C which talks about whether or not there eould be substantially 16 17 more people than the number advised to go to the reception 18 center who would actually seek monitoring.
19 Is that a portion of the contention upon which 20 you intend to testify?
21 A
No.
22 Q
To your knowledge, Ms. Robinson, are there any O
129
/mC 1
other contentions upon which you have been asked to testify 2
or intend to?
3 A
No.
4 Q
And with respect to Contentions 39 and 49, have 5
you prepared any documents or reports or statements of a
your position or your opinions?
7 A
No.
8 0
Itave you met with, or had discussions with, any 9
other witnesses concerning the testimony on those contentions?
10 A
Yes.
11 0
And, who is that?
A Oh, I've spoken to Brian McCaffrey.
And I have 12 13 spoken to Dennis Mileti, although not specifically on my 34 testimony but we have had discussions.
And I've spoken to Chuck Daverio and John Weismantle and Rick Watts, although 15 no specific discussions as to preparation of testimony.
16 37 But we have spoken to each other.
is O
Ilave you spoken with each other about generally i
19 what LILCO's position is going to be on these contentions?
A We have discussed some of the specific issues.
20 We were in different places.
Rick Watts was the Rad !!ealth 21 22 Coordinator in the EOC.
I had had to get some information i
l
~
130 (m.
L]
1 from him.
So, we have just talked from that point of view.
2 0
Your conversations with Mr. Mileti, have they 3
involved LILCO's position concerning any of these contentions 4
that you and I have been discussing here?
5 A
No.
We've talked about what happened, and-we e
have -- you know, given him materials to review and that kind 7
of thing.
But, it hasn't been what I guess you would call a 8
strategy session.
9 Q
Mr. Mileti was not at the exercise, was he?
10 A
Dr. Mileti was not at the exercise, no.
It MS. LETSCHE:
At this time, I don't have any 12 other questions.
I would like to make a request of Ms.
13 McCleskey, though.
We have heard from Ms. Robinson and I 14 gather also from Mr. Daverio on Monday that the rumor control 15 portion of the LERO plan, in fact, is contained in the on-site plan which is something we were not aware of, since there are 16 17 lots of references to the rumor control plan, at least in the 18 versions of the LERO plan that we were dealing with prior to to the exercise.
20 If you recall, about a year or so ago I tried to 21 obtain from you updated versions of the on-site plan.
Since 2:
Kirkpatrick & Lockhart has been taken off of the service
131 v
1 list, we hadn't gotten them.
I would like to request the 2
portions'of the on-site plan that deal with the rumor control 3
issues.
4 And it sounds to me like it's probably larger 5
than that, and it's whatever the ENC issues are since it's 6
media monitoring and several. things apparently that are dealt 7
with in that plan.
I would like to receive a full set of 8
those including'any revisions that have been made subsequent 9
to the exercise.
10 MS. McCLESKEY:
Okay.
I will look into your 11 request and we will respond to it.
12 f tS. LETSCHE:
Okay.
At this time, I don't have 13 any further questions of fis. Robinson.
14 MS. McCLESKEY:
Okay.
Thank.you.
MR. ZAHNLEUTER:
Excuse me.
I have.no-questions 15 for Ms. Robinson, but I, too, would like to ask that any 16 17 documents you may send to Kirkpatrick & Lockhart you also 18 send to me by mail.
1 19 MS. McCLESKEY:
Okay.
That's it, then.
20 (Whereupon, the taking of the deposition was 21 concluded at 12:15 p.m.,
Wed y, January 7, 1987.)
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132 1
CERTIFICATE OF NOTARY PUBLIC 2
3 I i GARRETT J. WALSII, JR.,
the officer hefore,whom the 4
foregoing deposition was taken, pages 1 through 131, do 5
hereby certify that the witness whose testimony appears in 6
the foregoing deposition was duly sworn by me; that the 7
testimony of said witness was taken by me and thereafter 8
reduced to typewriting by me or under my direction; that 9
said deposition is a true record of the' testimony'given by the witness; that I am neither counsel for, related to nor 10 employed by any of the parties to the action in which.this 11
~
12 deposition was taken; and further, that I am not a relative or employee of any attorney or counsel employed by the 13 parties hereto, nor financially or otherwise interested in.
14 the outcome of the action.
15 16
' GARRETT g WALSii, JR.
j 17 18 Notary Public in and for the Commonwealth of Virginia i
19 20 My Commission Expires:
January 9, 1989 21 22 O
1 l
o l
Elaine D. Robinson,
PROFESSIONAL _ EXPERIENCE i
LONG ISLAND LIGHTING COMPANY since 197_8 l
Office of Corporate Affairs / Government Re_lations Monitor le@Is lation and regulation, analyse i
the implications Keep top management informed of legislative and regulatory actions Direct contacts with government officials to implement l
Company policy l
Responsible for administrative functions within the office of Corporate Affai e including development and l
implementation of a legislative tracking and reporting Responsible for continued contact with outside organisations, public education and public information 1
for nuclear emergency planning system for federal, state and local government i
Primary spokesperson for offsite emergency planning n
for the the Shoreham Nuclear Power Plant V
Assigned to manage the program to develop procedures and materials, make physical modifications and train personnel in order to expand and upgrade publio j
information during non-nuclear emergencies
(
May 199_.1--Seatember 1985 -- on special assignment as a Division Manager in tTe Local Emergency Response Implementing Organisation -- a task force' dedicated to the development, licensing, training and exercising of an emergency response organisation for the Shoreham Nuclear Power Station.
I Managed the " External organisations Team" that negotiated agreements with agencies, private contractors and voluntary organizations December 198L -- Manager of the_Commur.:,ty Relations Department i
AdmGnistered a professional (W) and clerical start Responsible for public education programs on
)
energy issues involving economics, the environment and 1
safety i
Liaison with local governments and regulatory agencies Provided communications support for the operating departments.
t Notes (This department was abolished as part of the stringent i
austerity measures taken in 1984)
April _1978 Associate Director of Public Affairs i
~
~
O Represented the Vice President /Public Affairs on corporate task forces including management audit, coal conversion and nuclear emergency planning Acted as liaison to Jocal government and regulatory agencies Researched and wrote papers on significant corporate issues 1972--1978 Loca1 Government suffolk County Legislator Member of the Town of Huntington zoning Board of l
Appeals Member of the Town of Huntington Consumer Protection Board OTRE s.
Teacher in the New York city public schools sales service with the Crown zellerbach Corporation EDUCATION
()
M.B.A., Adelphi University Delta Mu Delta B.A., Queens College i
Phi Beta Kappa Certificate -- The Fundamentale of Finance and Accounting for l
i the Nonfinancial Executive, The Wharton School Certificate, Women's computer Literacy Project Thirty graduate credits in History at Queens College and Hofstra University s
e O
764743 L
l
ELAINE D. ROBINSON Emergency Planning Testimony Hearing Testimony Dates Transcript Page 03/29/84 5337 04/03/84 5717 04/06/84 Volume 2 05/01/84 7526 05/02/84 7698 05/10/84 Volume 2 05/30/84 Volume 2 06/06/84' 10396 08/21/84 14707 Deposition Dates 10/11/83 Testified before Marburger Commission in August,1983.
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