ML20212D748
| ML20212D748 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/15/1987 |
| From: | Saegert S LONG ISLAND LIGHTING CO. |
| To: | |
| References | |
| CON-#187-2622 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8703040194 | |
| Download: ML20212D748 (120) | |
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NUCLEAR REGULATORY COMMISSION BT, FORE TH3 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 O
DEP'OSITION OF SUSAN SAEGERT t
Washington, D.
C.
Thursday, January 15, 1987 ACE-FEDERAL REl'ORTERS, INC.
a Stenotup 14vrters 444 North Capitel Street Washington, D.C. 20001 (202) 347-3700 s
Nationwide Coverage 800-336 6646 0703040194 070115 PDR ADOCK 0500 2
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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
- - - - - - - - - - - - - - - - - -x 4
In the Matter of:
Docket No. 50-322-OL-5 5
LONG ISLAND LIGHTING COMPANY (EP Exercise)
(ASLBP No. 86-533-01-OL) 6 (Shoreham Nuclear Power Station, Unit 1) 7
- - - - - - - - - - - - - - - - - -x 8
DEPOSITION OF SUSAN SAEGERT 9
10 Washington, D.
C.
Thursday, January 15, 1987 O
V Deposition of SUSAN SAEGERT, called for examination 12 pursuant to notice of deposition, at the law offices of Hunton and Williams, 2000 Pennsylvania Avenue, N.W.,
Suite 9000, at 14 2:05 p.m. before KATHIE S. WELLER, a Notary Public within and 15 for the District of Columbia, when were present on behalf of 16 the respective parties:
KATHY E.
B, McCLESKEY, ESQ.
MARY JO LEUGERS, ESQ.
18 Hunton and Williams 707 East Main Street 19 P.
O.
Box 1535 Richmond, Virginia 23212 On behalf of Long Island 20 Lighting Company.
21 1
22
-- continued --
ACE-FEDERAL REPORTERS, INC.
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A/
APPEARANCES (Continued):
2 CHRISTOPHER M. McMURRAY, ESQ.
Kirkpatrick & Lockhart 3
South Lobby, Ninth Floor 1800 M Street, N.W.
4 Washington, D.
C.
20036 On behalf of Suffolk County.
5 ALSO PRESENT:
6.
STEVEN BERKOW 7
8 9
10 O
12 13 14 15 16 17 18 19 20 21 0
22 ACE-FEDERAL REPORTERS, INC.
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_C _O _N T _E. _N T.S 2
WITNESS EXAMINATION 3
Susan Saegert by Ms. Leugers 4
5 6
EEEllllE 7
SAEGERT EXHIBIT IDENTIFIED 8
Exhibit 1 10 9
10 11 0
12' 13 14 15 16 17 18 19 20 21 22 O
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PROCEEDINGE 2
Whereupon, 3
SUSAN SAEGERT 4
was called as a witness and, having first been duly sworn, 5
was examined and testified as follows:
6 EXAMINATION 7
BY MS. LEUGERS:
8 Q
Dr. Saegert, I'm Mary Jo Leugers with the firm of 19 Hunton & Williams.
We represent Long Island Lighting Company g
i.
10-in these proceedings.
I'm going to ask you some questions 11 today about the February 13 exercise at the Shoreham 12 facility, and could you please state your name and' current 13 address for the record?
14.
A Susan Saegert, 347 President Street, Brooklyn, New 15 York.
):
16 Q
Were you at the February 13 exercise?
17 A
No, I was not.
1 18 Q'
Have you received any documents about the 19 exercise?
20 A
Yes, the FENA report.
f21 Q
Have you looked at any of the logs or messages?
22 A
I have looked at the messages, the EBS messages, b
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1 and the news center messages.
2 Q
But you have not seen any of the logs that any of 3
the players produced on the day of the exercise?
4 A
No.
5 Q
Have you looked at the plan on Revision 6?
6 A
No.
7 Q
How about Revisions 7 and 8 of the plan?
8 A
No.
9 Q
Have you reviewed the tapes at the ENC on the date 10 of the exercise?
11 A
No.
12 O
Were there any other documents other than the ones 13 we talked about?
14 A
The contentions.
15 Q
When did you review these items?
'16 A
Maybe the end of November, beginning of December.
17 Q
And for how long did you review these?
l l
18 A
I have not spent more than about six to -- well, 19 six hours at most.
20 Q
Have you done anything else to find out what 21 happened on the day of the exercise?
i-22 A
No.
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'l Q-Have you talked to any people about what happened 2
on the exercise?
l 3
A Yes, I talked to counsel.
4 Q
And when did you do that?
5 A
Well, when I was initially contacted toward the 6
end of November; and then we met'once in New York.
7 Q
When was that?
i 8
A I don't really remember.
It was in December..
I 9
think it might have been the second or third week in I, p 10 December.
V
'11 Q
Okay, have you talked to any other witnesses'irr 12 the proceeding?
13 A
Yes.
I talked to Dr. Cole and Dr. Loftus.
14-Q Have you ever developed a scenario for an 15 emergency power plant, an emergency exercise or drill?
i 16 A
No.
l 17 Q
Have you ever been an evaluator at a drill or l
18 exercise of a nuclear facility?
i 19 A
No.
I 20 Q
Have you ever participated as a player at one of 21 the drills or exercises at a nuclear power plant?
22 A
No.
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1 Q
Have you reviewed --
2 A
I don't know whether I read an evaluation of the 3
Indian Point drill or not, really.
4 Q
So you are not sure what you may have read about 5
that. power plant was something someone wrote about the report 6
or the actual report?
7 A
I have read a lot of things, and I can't remember 8
if that was one of them or not.
9 Q
You don't know if there are any official reports 10
.you have read?
i 11 A
No.
12 Q
Did you bring any official documents with you 13 today?
14 A
No.
15 Q
Have you read anything about the February 13 16 exercise?
17 A
No.
18 Q
There's no memos or letters that maybe you have 19 sent with counsel?
20 A
Not yet.
I just started working on this.
I told 21 counsel that I couldn't start working on it until January.
22 (Discussion off the record.)
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1 BY MS. LEUGERS:
2 Q
Are you working on any types of papers now?
You 3
said you started in January, so have you started working on 4
papers or documents?
5 A
Any written papers?
6 Q
Yes.
7 A
I haven't written anything yet.
8 Q
Have you taken any review -- when you reviewed the.
9 FEMA report, have you taken any notes or anything in that 10 order?
11 A
I think I might have made some marginal notes on 4
12 it.
13 Q
And that you would have been doing since November 14 when you first received the materiais?
15 A
Yes, although as I said I haven't really worked on 16 it very much yet.
l.
17 Q
Most of it has been within the last couple of l
l 18 weeks that you have been working on it?
I 19 A
- Yes, r
20 Q
When were you first contacted about this case?
f_
21 A
Toward the end of November.
I 22 Q
And that's when they also. talked to you about l
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1 being a witness or was that just.about maybe your expertise?-
2 A
Yes, it was to see whether if they sent me some 3
material I could see whether I thought I had something to'say-4 about it.
5 Q
So you reviewed some of the material before you 6
decided to become a witness?
7 A
The contentions, and I guess the FEMA report too.
8 Q
Who sent you these materials?
9 A
Counsel.
10 0
That would be Kirkpatrick & Lockhart?
11 A
Right. Tip Letsche.
12 Q
Did you speak to anyone before that time about 13 this litigation?
14 A
No.
15 Q
Not about something other than being a witness?
16 A
No.
I testified previously some years ago.
17 Q
That's right.
I take it since you first heard 18 from counsel at the end of November and you wanted to review 19 some of the contentions in the FEMA report that it was 20 sometime after that that you decided to become a witness?
21 A
Yes.
22 Q
What time would you say, about?
ACE-FEDERAL REPORTERS, INC.
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A Maybe the second week, first or second week in 2
December.
Right before we met.
3 Q
Have you discussed compensation for your 4
testimony?
5 A
Yes.
6 Q
What type of arrangements have you made?
7 A
Do you want to know how much per hour or what?
It 8
is a hourly rate.
9 Q
So you didn't first start really working on your 10 position up until the last couple of weeks?
]
11 A
Right.
12 Q
So is it safe to say you have not developed any 13 testimony so far?
14 A
Yes.
15 Q
What I'm going to do now is give you a copy of 16 your resume, and I would like to mark that as Saegert Exhibit 17 Number 1.
I 18 (Saegert Exhibit 1 identified. )
19 BY MS. LEUGERS:
20 Q
Could you review your resume and tell me if you 21 think there is anything that is not correct?
(~
i 22 A
Yes.
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on " associate professor."
2
-Q That's the second notation under " Experience"?
3 A'
Right.
It should be '77 to
'86.
Obviously I'm 4
now president of division'34.
5 Q
What page are you on?
6 A
On page 4.
7 Q
Okay, at the top.
I see, where it says president 8
elect, it should be president.
9 A
Right.
I'm also co-chair of the Environmental 10 Design Research Association on page 3.
11 Q
Environmental Design Research Association?
i 12 A
Right.
On page 9, two publications listed there I 13 have appeared in, and I see the page reference is not 14 included.
15 Q
I don't understand.
16 A
On page 9, these have now appeared and I could 17 include a page reference which is not here.
l l
18 Q
But we could get that from you?
19 A
Yes.
l Q
On the first page at the top it is noted as a 20 l
l 21 January '86 date.
Is that the most current or --
(
5 22 l A
Well, you know, actually this is not my most i
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current resume.
I don't think there's anything substantively 2
new but some of these changes would be on my current resume.
3 Q
I was wondering if we can get a copy of your 4
' current resume.
5 MR. MC MURRAY:
We'll provide that to you.
6 MS. LEUGERS:
Thank you.
7 BY MS. LEUGERS:
8 Q
So you have, according to your education, a Ph.D.
9 in psychology?
10 A
Right.
_s
.]
11 Q
And your specialty is social psychology; right?
12 A
It is environmental psychology, which is a new 13 field that was not a specialization when I got my Ph.D.
14 Q
How would you define the differences between 15 environmental psychology and social psychology?
16 A
Well, environmental psychology deals more with the 17 physical environment and it is more field research-oriented, 18 less laboratory research-oriented.
19 Q
Does the fact that you are now saying your field 20 is environmental psychology reflect a change in the direction 21 you are taking with your research?
l 22 i A-Well, actually, I have been working in the ACE-FEDERAL REPORTERS, INC.
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environmental psych department since prior to my Ph.D.,.n) it 2
doesn't really -- I have.always, since I have had my degree, 3
considered myself an environmental psychologist.
4 Q
It is more really a recognition in the field that 5
environmental psychology is a separate entity?
6 A
Right.
7 Q
Are there subareas within environmental 8
psychology?
9 A
Not to the degree that there are in some other 10 specializations.
People do research on different topics, but
,,_V 11 it is not a highly segmented field.
12 Q
Do you in particular deal with a certain area in 13 environmental psychology?
14 A
No, I don't think so.
I have done research in 15 quite a lot of areas.
16 Q
Would the public responses to emergencies that we 17 would be concerned about with the Shoreham litigation, would 1
j 18 that be a subpart of environmental psychology?
19 I A
Yes, it could.
20 Q
Or is that a broader area?
Would that be crossing 21 over a lot of disciplines?
Cl) 22 A
It wouldnA4 be interdisciplinary.
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work in environmental psychology is interdisciplinary.
It is 2
another difference, really, with social psychology.
3 Q
Is that given a particular name or are they all 4
considered environmental psychologists?
5 A
Yes, they are all considered environmental 6
psychologists.
7 Q
They wouldn't refer to themselves as a certain 8
type of environmental psychologist?
9 A
I don't think so.
10 Q
Have you studied public responses to emergencies 11 in' your work in the area of environmental psychology?
12 A
What do you mean by studied?
13 Q
Done any type of research or maybe is a field you 14 have looked into?
15 A
Well, I have taught a course on the topic.
I 16 taught a course on human participation in environmental 17 crises and I have done some writing that includes that as a f
18 topic.
19 Q
The course that you taught in human participation 20 and human 21 A
Environmental crisis.
22 Q
I dia.'t have that right.
Would that cover a ACE-FEDERAL REPORTERS, INC.
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1 broad range of emergency situations?-
1
-2 A
Yes.
3 Q
WouldLthat also include responses to a nuclear.
4 even t?
-5
.A Yes, it did.
6 Q
And you said you also had done some research in
.7 that area also?
8 A
Right.
Well, I have written something about it.
~
9 I have not_done original research on that specific topic, but 10 in the last paper on my vitae, " Environmental Psychology-and
.O 11 the World Beyond the Mind," that's a review of the last five 12 years of work in environmental psychology.
This is kind of 13 an honorary lecture-that the American Psychological.
14 Association asked someone in the field to give as a way of i
15 updating instructors on the field, and I considered this 16 topic and other things that deal.with technological hazards; I
17 and then a paper called " Environmental Psychology and Social i
f 18' change," on page 8, I talk about -- I have a section on l
19 nuclear power.
20 Q
On the " Environmental Psychology and Social l
21 Change," you said there is a section on nuclear power.
How t
O 22 do you address that?
l l
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A Well, I present it as a change in technology which 2
has required a change in social understanding and that people 3
have responded to as'a new kind of environmental 4
configuration.
I talk:about the way in which' nuclear power 5
is a human creation and the decision-making process 6
surrounding every stage of it, and then how different 7
segments of the population have viewed it, and then I review 8
the research on the topic.
9 Q
Is your emphasis in that research on how people 10 feel about nuc3 ear power?
11 A
That's one of the things I talk about.
I also 12 review studies that attempt to look at the relationship 13 between public reactions and decision-making.
14 Q
Public reactions to what?
15 A
To nuclear power.
16 Q
Any public reactions as far as if a disaster, a 17 nuclear disaster should happen, how they would respond to 18 that?
19 A
Yes, I certainly reviewed that.
I 20 Q
And on the first one that you mentioned, 21
" Environmental Psychology and the World Beyond the Mind,"
22 what did the research as related to nuclear power entail?
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A Well, I tried to review some of the research that 2
was done around the TMI incident, to give an example of the 3
kind of work that's gone on in the'last five years concerning 4
reactions to environmental hazards.
5 Q
So more you look at the research that was already 6
out there and pull it together for -- this was a lecture?
7 A
Right.
8 Q
And this also resulted in a paper, or was it just 9
a lecture?
10 A
Yes, it is published in a collection.
s.
]
11 Q
And did that also focus on individual responses to 12 TMI?
13 A
To some extent.
I also tried to kind of develop a 14 framework for looking at research and environmental 15 psychology and to talk about what are the dimensions of human 16 understanding, kind of human ecology, so I looked at hazards 17 and stress as one aspect of that.
So I related it to other 18 research also.
19 Q
And that again, as I asked earlier with the other 20 research, not only concerned their response to how they feel 21 about nuclear power in general but how they would respond in i
I j
22 an emergency?
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'l A
- Frankly, I. don't recall if I reviewed the 21 evacuation studies in that paper.
I think maybe I didn't.
3 Q
Did you review the evacuation studies in your 4
-previous paper we talked about?
5 A
Yes, I did.
(i Q
Are there any other publications or -- I notice 7
you also have grants and contracts that would be dealing with 8
this area?
9 A
Not directly.
I think a lot of the research that 10 I have done is relevant in the sense that it deals with.the
(~)
11 way people respond to different aspects of their environment, 12 and some of those have commonalities with the kind of 13 situation we're talking about, a evacuation situation, things 14 that have to do with handling information and things that 15 have to do with organizing information under stress and so 16 on.
17 Q
When I reviewed your resume I noticed a lot of i
l 18 your research has been with crowding or with women's issues i.
19 and sex roles.
What of those would you find helpful had you 20 to talk about it in a more general sense, what you are 2:1 planning to do with your research work?
22 l A
I think the crowding element is directly relevant.
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Q How is that?
2 A
In two ways. N it deals with crowding 3
as a stressful experience and the kind of framework I use, 4
and the information processing framework in my earlier work 5
is relevant to how people handle information under stress; 6
plus I try to deal with the parameters of group interactions 7
that have an information overload effect, and I think that's 8
an issue here too.
9
-Q So are you saying that research dealing in this 10 area, dealing with stress, would be helpful even in the
,U 11 emergency situation with a nuclear power plant?
t 12 A
Yes.
13 Q
Could you indicate some of those publications that 14 you think might be helpful?
15.
A Helpful in what way?
16 Q
In the research you are planning to do in 17 preparation for your testimony in this litigation.
18 A
Well, I think that -- the '78 review, I think, 19 might summarize some of the ideas.
20 Q
That's on page 7?
21 A
Right.
1 -
h 22 Q
Which of those, both of those?
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A No, the " Personal and Social Consequences of High 2
Density Environments."
3 Q
What did that study involve?
4 A
Well, the reason I pointed out that one rather 5
than the specific research studies is that it brings together 6
the different studies that I have done, and that my 7
colleagues have done, so it talks about studies of 8
problem-solving in high-density situations.
It talks about 9
/%fective and social responses to high density.
It talks 10 about the different kinds of density situations that have 11 different kinds of responses.
12 0
When you talk about high-density environments 13 could you give me an example of what you would have been 14 looking at there?
15 A
Sure.
Sometimes I looked at -- you mean in my own 16 research?
The studies that I specifically did myself?
17 Q
Yes.
18 A
I looked at train stations and supermarkets and 19 department stores, kind of public space interactions, and 20 then I have also done one lab study, some residential studies (N
also.
21 l
22 Q
And so from those studies, you would look at how ACE-FEDERAL REPORTERS, INC.
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' individuals handle the stress in those situations because of 2
the highdensity population?
3 A
Also what made them stressful or not stressful.
4 Q
From there, you would extrapulate some of your 5
opinions as far as how people respond in an emergency such as 6,
what we're discussing here?
7 A
Yes.
Although I would not only draw on my own 8
work.
I would draw on other research in the field on stress 9
and on reactions to emergencies and coping behavior.
10 Q
Could you give me an idea of some of those other V
11 materials that you would use?
12 A
I really haven't -- as I said I haven't been 13 working on this very long and I have not yet developed a 14 bibliography for this testimony.
15 Q
Do you have maybe not specifics but different 16 authors or people in the area who you would be looking 17 toward?
18 A
Well, I believe that the testimony that I prepared 19 last time I was on this case sort of gives a lot of the old t
20 references, and what I'm doing now is updating those.
Some 21 of the people I referenced in the past have done new work 22 which I will be looking at to see whether it is relevant to I
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this case, and I'm trying to find any references on the 2
Chernobyl incident that have come out in the last year or so.
3 Q
off the top of your head, without looking at the 4
testimony, since we don't have that testimony from three 5
years ago with us, can you remember any of the names you 6
would be looking at, the type of people you would be looking 7
at?
8 A
I think that the group at Clark has-done some 9
research on Chernobyl or at least some analysis of the event, 10 so I will look at that.
Beyond that, I don't think there's 11 anybody that I would point to specifically until I'm more 12 sure on what kind of argument I will make.
13 Q
Are there any other publications that you would 14 point to, for example, like in 1980 the first one you list, 15
" systematic Approach to High Density Settings"?
16 A
Yes, I think that all my writing on crowding, the 17 ideas may be relevant.
They are certainly in my mind.
I 18 will try to see whether the issues are relevant.
" Crowding 19 and Cognitive Limits" might be relevant, which is a 1981 20 paper.
21 Q
I understand that you see a connection because of 22 the stressful situations both in crowding and in emergency e
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response, but wouldn't there also be dissimilar aspects that 2
wouldn't be helpful?
3 A
Certainly.
I think there's another similar aspect 4
which is that in an evacuation situation it would involve 5
large numbers of people.
Without -- not operating in kind of 6
a face-to-face group but are each. operating with their own 7
goals. -That's the kind of situation I tended to study in my 8
crowding work, but of course the reason I will be reviewing a 9
lot of other work is because mine is not the only kind of 10
-work that's relevant.
d 11 Q
And then of course on page 9 you talk about your 12 recent activities when you were an expert witness before the 13 Suffolk County legislature.
Could you briefly describe what 14 your work involved then?
15 A
Yes.
I kind of organized the ideas and bodies of 16 research and psychology that seemed relevant to the issues i
17 that had to do with planning for an emergency at Shoreham, 18 and documented that in the literature,.and I searched the 19 literature in environmental psychology and other relevant 20 fields for things that are more specifically focused on 21 nuclear power plants and reviewed that and incorporated it L {s/
l T
22 into my testimony.
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I also worked with the other behavioral science.
2 experts, and so I reviewed'and incorporated into my testimony 3-the surveys done at that time.
I think I reviewed the Driver 4
behavior work too.
There may be other things that I did that 5
I'm not recollecting, but those are --
6 Q
That's okay.
7 MR. MC MURRAY:
Can we take a one-minute break?
8 (Recess.)
9
.BY MS. LEUGERS:
10 Q
I would like to ask you a couple of questions 11 about the class that you were-teaching in human participation 12 in environmental crisis.
When did you teach that class?
I 13 A
Last spring, I believe.
14 Q
Spring of '86?
15 A
Right.
16 Q
And what type of materials did you use?
17 A
Well, I used -- there are some general papers on 18 technological and natural disasters that I used, some general 19 theoretical papers, and we looked at research on nuclear 20 l
power.
We also looked at some research on use of resources, 21 a kind of Club'of Rome kind of thing.
We tried to develop an j
22 ecological paradigm that would look at the threats that ACE-FEDERAL REPORTERS, INC.
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people experience and how~they respond to cope with.them~and
-2 how'they kind of~ create them in some circumstances.-
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3 Q.
Did you also look at it from the planning stage, t
4 the emergency planning force, different types of disasters?
5 A
Not very much, no.
!=
6 Q-So basically it was how people respond.under 7
' stressful situations?
0-A I thought.you were using it in a more technical.
9 sense.
We looked at planning for emergencies, looked at work 10 on planning-for emergencies.
We didn't study specific. plans.-
)
t 11
-Q More in a generic sense, then, you didn't focus.in 12 on that planning may be different for different types of i:
13 disasters?
14 A
Well, certainly the general papers that we read 15 had to do with the different dimensions of disasters and the' 16 different kinds of information flows that they involve and 17 the different kinds of threats and time lines and people i
18 involved, so they conceptualized the differences between-19
. types of emergencies and types of hazards.
20 Q
As part of.this class, were the students required 21 to produce papers and do research also, that you may come 22 across other information?
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They did produce papers, shortpapers,aNwedid 2
a small. class project that was a research project on-how 13 people thought about hazards and daily life.
4 Q
'And do'you remember any.of the types of literature j.
5 you used, the names of the authors?
6 A
Well, we used the work that Fishhoff:and his c
7 colleagues have done.
Do you want me. to spell tilat?
/
8 F-i-s-h-h-o-f-f.. We used Andy Baum's work.
We used, as I jl 1
L 9-said -- that's his name, Hohensmer,~at Clark, and I.think we 0
10 might have used something that was writteth for t'he S oreham O
11 case.
It might have been Cole's-work or Johnson's work.-
12 There are a number of literature reviews in that[ area that I i-13 also used.
I can't rerember the. authors right now.
We also-2 14 looked at -- well, things like the Club of Rome Repo1t and 15 other works on ecology at different points in timec 16 Q
What's'the Club of Rome Report?
o 17 A
Since this was not just on nuclear power we looked.
l:
l 18 at a variety of threats to the environment.
So this was a e
19 book that came out quite a few years ago saying,that the j 20 world was going to have a series of environmental crises 21 related to resources.
That was some of the work that we 22 looked at.
Well, we looked at Kai Erickson's work on Buffalo 1
i i
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3.. -
-3 A
It is a book that talks about the reactions of the if 4
. town to having a flood that wiped the town out.
It is a 5
sociologichl study.
h 6
Q Would you say a lot oi' it is aftermath study of
~
7 how people deal with having experienced a disaster?
l A
Not completely.
A fair amount of it had to do 8
I 9
with what people think about disasters before they happen, 10 ;f and some of it had to do with the decision-making processes (T
l.
s /
t 11 around-particu'lar threats to the environment or environment O
12 l resource c6nflict kind of work.
We looked at work on the 13 Tragedy of the Commons, Julian Edney's work on that.
IfA f M 's 14
-. c n-l M work on that.
g 15 Q
You looked at how people felt about impending 1.
1,6 disasters, how they respond to disasters during the time they 17 are responding and then also the long-term stressful effects
,I 18 !
of disaster they have experienced?
J l
l A
Right.
197 20 Q
All those areas?
l 21 A
Yes.
l Q
And what type of behavior in particular did you 22-ACE-FEDERAL REPORTERS, INC.
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2 A
It really depended on the study.
Sometimes we 3~
looked at the behavior of decision makers, what are the 4
history of certain kinds of decisions.
Well, for example, we 5
did -- one of the students was interested in the dropping of BOMB 6
the first nuclear be4 tom and how that came to be, so we 7
reviewed the historical work on that topic, which she was 8
responsible for.
9 f
We did some of that, w2tting on nuclear power, the.
10
, history of the decision-making and the psychological s
k 11
. processes related to that, how do they relate to the 12 organizational processes that go into making a decision.
We 13 looked at behavior in emergencies and behavior after emer[sncies.
Behavior in emergencies would include what 14 L
15 people did to cope with the emergency or what they didn't 16 do.
How they understood it, and afterwards, the kinds of l
17 rebuilding or not rebuilding, how it changes people's lives N and the way they approach issues.
18 I
19 Q
Did you look at the behavioral aspects that 20 planners need to take into consideration in planning for 21 emergencies and how to respond to them?
22 A
Yes.
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Q What types of behaviors are those?
2 A
Well, one part of the analysis looks at 3
communication flow.
What are the information properties of a 4
disaster or an event that go into interpreting it as'a threat 5
or an_ opportunity to begin with.
And then how is that 6
information communicated and interpretations formed around 7
the information throughout a chain.
When is something 8
considered a hazard, when is something considered an event or y
,9 a disaster.
And then if you are going to cope with that what
/
10 sorts of information, first can you have yourself, in there
(/
l 1
different decision-making roles; and secondly, can you l
12 communicate what will be the problems in communicating, and 13 then how will it be received by various members of the 14 public.
l l
15 Q
So that's looking from the planner's standpoint 16 and how to plan for that?
i 17 A
Right.
18 Q
What type of behaviors of the public would a
\\
19 planner need to take into consideration?
20 A
You have to understand prior knowledge and 21 expectations and orientations.
Predispositions to behave t
22 would be one.
You would have to understand values that the L,
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-1 public may hold with regard to the' situation and how that 2'
might relate to their potential behavior, to understand how 3
they ~ are going to_ receive and interpret information that they 4
get; and then you need to know something about stress, about 5
how people behave under stress, and what conditions are 6
stressful and what conditions are less so.
7 Q
How would you go about getting this type of 8
information.as a planner?-
9 A
Well, there are people who try to take -- it 10 really draws on all of psychology, so there are some people 11 who take bodies of work in psychology and relate it to 12 planning for disasters.
There's a paper by Fishhoff and 13 Hohensmer that does that.
It is called " Handling Hazard / or 14
" Handling Disasters," and !.t tries to block out the various 15' phases of this.
16 Q
So that's the type of research you would also be 17 looking at in preparing your testimony for this litigation?
18 A
Yes.
19 Q
You have already stated that you have seen the 20 contentions?
21 A
Right.
22 Q
You first saw them in November?
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A Yes.
2.
Q Did you have any involvement in the writing of 3
those contentions?
4 A
No.
5 Q
Do you know who did write those contentions?
6 A
Not really.
7 Q
Who gave you the contentions?
8 A
Tip Letsche.
9 Q
Have you read all of the contentions?
10 A
No, only the ones that counsel thought my O
11 testimony might be relevant to.
12 Q
Do you know which contentions those are?
It may 13 be hard to remember the numbers.
14 A
I don't remember the numbers but I do remember 15 more or less what they are about.
16 Q
We'll get to those in a little bit.
17 A
Okay.
i i
18 Q
Other than just reading them, have you done any 19 work with them, taken notes or formulated some ideas about 20 them?
21 A
Well, I have formulated
- I had to first 22 formulate a general idea of whether it would be something I i
L ACE-FEDERAL REPORTERS, INC.
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1 would have something to say about, so I have done at least 2
that level of work on it.
3 Q
But you haven't gone into putting any of those 4
ideas on paper or developing them any?
5 A
Not really.
6 Q
Do you agree with the contentions?
7 A
Yes.
8 Q
Have you met with anyone about the contentions?
9 A
Well,'at the meeting that we had in New York, Tip 10 Letsche and Chris were there, and we talked about the 11 contentions somewhat, and the other two experts, and then 12 today we talked, but that's really about all the contact I've 13 had so far.
14 Q
The first meeting you were talking about, was that 15 the one in December?
16 A
Yes.
17 Q
That was like the first or second week in f
18 December?
19 A
I think it was a little later than that.
I don't i
20 l
remember the date.
l 21 Q
And the subject matter of what you talked about, t
22 was that about what your testimony would be?
I I
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A Right.
2 Q
You have already told me you can't remember the 3
numbers.
Maybe you could tell me in your own words what the-4 gist of the contentions are that you will be testifying on.
5 A
Well, they have to do with the fact that the way 6
in which information was handled throughout.the exercise 7
indicates that public response would not occur as LILCO 8
expects it to occur or as LERO expects it to occur because 9
the Emergency Broadcast System messages are confusing and not 10 always clear, sometimes internally contradictory, because the
[)h.
11-news center broadcasts also are not clear and sometimes 12 conflict with the EBS messages.
13 Rumor control proved to be ineffective in that 14 people would -- because of all these factors, people would 15 act on their preexisting behavioral intentions and their lack 16 of trust in what LILCO was saying and the kinds of l
17 instructions they received from LILCO would all add up to I.
l l
18 behavior different than that indicated or assumed by the 19 drill.
20 Now those issues come up in a number of f
21 contentions.
Some go into them more than others, and then O'-
22 there's another contention --
l i
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Q"
'Before you go.to that there are some questions I
'2 would like to ask you about that, and later we'll pull out
'3 the contentions and look closer at the individual ones.
You
'4 are basing your opinion on what-the contentions were.about-
~
'5 and you mentioned the EBS messages were confusing.
Have you.
6 read the EBS messages?
i 7'
A
~Yes.
8 Q
Have you analyzed them to. determine that they are 9
confusing?
10 A
I have begun to do that.
There are some points O
11 that seem clearly confusing to me, but I have not finished my:
12 testimony on that.
I haven't even written it.yet.
I have 13 begun that, yes.
14 Q
Can you tell us where you find these confusions?
i 15 A
Well, without looking over them all, one of the 16 confusions is in an EBS message in which in the beginning it l
17 is stated that there has been a release of radiation and l-j 18 later in the messageuit says there has not been a release of 19 radiation.
That, I think, would certainly be confusing.
The l:
20 way in which a condition is-presented to the public, I think, 21 would be hard for people to interpret.
L l
r 22 Q
What way is that?
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~A The specific information given doesn't really 2
inform the public initially about why you would start having-3 --
a condition'at all,.and the differences ~between an alert and 4
a site emergency and so on are not specified in the early
-5 messages.
You have to listen to the whole series to get.the 6
whole series, so'I think initially there will be some
^7 confusion about that, and throughout the series there will be 4
-8 some confusion about exactly what the point of the message 9
.is, why it is being issued.
The whole scheme that relies (ni-1 10 this zone information, I think, is going to be very' confusing 11 to people.
12 This is an area that there has been research in 13 environmental psychology about, people's ability to 14 understand spatial information.
People are not very good 15-about it even in familiar environments, and particularly poor l
16 at it when it is verbally described; and the response plan' 17 really relies on people knowing that fairly accurately, and
(
18 also assuming that a boundary is a boundary.
If you live on 19 one side of the street you are in one condition.
If you live 20 on the other side of the street you are in another 21 condition.
That's going to be confusing to people who are 22 listening and trying to decide whether they are safe or not.
L 4
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'l Q
You are saying that the EBS messages make that 2
issue confusing?
3 A
Yes.
You have to-think about your zone.
4 Q
Do you think the confusion is alleviated any by 5
the brochure which explains the zones and the area?
6 A
I have not reviewed the brochure as it now 7
exists.
I don't think that that completely deals with the 8
issue, however, because I don't think that everyone -- in 9
fact I don't think that most people will have the brochure 10 readily available, but map reading is another area in which 11 people's skills are not that great most of the time.
12 Q
So how would you suggest improving the EBS 13 messages?
14 MR. MC MURRAY:
I object.
This witness is not 15 here to offer any corrections to LILCO's plan or improve 16 messages.
I assume that based on her testimony earlier that l
17 she has not finished her review that that would not be l
18 something that she could testify to.
19 BY MS. LEUGERS:
l 20 Q
At this point, although you have not finished your l
21 review you have done enough to know that the EBS messages are 22 confusing.
I would gather that you would be able to decide l
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that, the way the EBS messages lare not adequate, you would
~
'2 have to have an image as h what would be adequate.
Can you
-3 give us-an-idea from yout-expertise as to what would~be
~
'4-adequate?
How best to. style an EBS message that.wouldn't be 5
so confusing since these were considered confusing?
6 A
I think when you are trying to convey technical 7
information that is anxiety-producing that you.have to think 8
through the words carefully, and.I don't think I-could give 9
you a professionally sound, you know, off the-top of my head n
10 kind'of answer to that.
I would have to sit down with each 11 word.
Some guidelines would be that you would want to e
12 provide information in language that people were familiar I
13 with and when you didn't that you would quickly define f
14 language you were using that they were not familiar with in a i
15 completely clear way so there wasn't a sense that the wool 16 was being pulled over their eyes or that they didn't know i
17 what had just been said to them.
You certainly would want to 18 take out any internal contradictions and any seeming 19 contradictions.
i 20 Q
So are you saying that maybe the terms need to be l
21 looked at?
I-22 A
Yes, I think the specific words that are used are L
ACE-FEDERAL REPORTERS, INC.
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very important, and the fact that they are anchored in some 2
hind of clear statement of what that means to you.
3 Q
Can you give us an example of the types of terms 4
that you came across that you found confusing?
5 A
Well, I think that, as I said, the basic 6
conditions were presented in a way that wouldn't make it 7
immediately obvious what that meant to a person listening.
8 Whenever dosages -- whenever health information or radiation 9
information was presented I think it is likely to be 10 confusing because it is technical language, and there's not 11 any transposition from what the technical language is to what 12 this means for you as a lay person.
I also think that it 13 doesn't deal with the questions that would arise if a person 14 were listening to this.
If there's no danger why should 15 animals be taken inside?
That sort of thing.
i 16 Q
And you mentioned their fear of having the wool 17 pulled over their eyes.
Is that what you mean because of the 18 contradictions they would feel that these are not truthful?
19 A
Yes, which is the truth, anyway.
20 Q
One of the other things you mentioned about the 21 contention is that the news center broadcas ts were not 22 clear.
What did you mean by that?
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-A They_had some of the same wording problems that 2
-the EBS messages did.
3 Q
What broadcasts are you talking about?-
,s 4
A-Did I say_ broadcast?
5 Q
That's what I wrote down.
6 A
What I'm talking about are the messages that were 7
compiled as' coming _from the emergency news center.
I'm not 8
really sure what-form they were presented in.
9 Q
You mean like the news releases?
10 A
Right, yes.
11 Q
News releases?
i 12 A
Yes.
l 13 Q
Are you talking about both the LILCO news releases.
14 and the LERO news releases?
15 A
Yes.
I don't have as clear a memory of exactly i
d 16 what those different things say.
I recall when I read them l
f 17 that they didn't seem to me always easy to interpret, and as i
18 the contentions state, their timing sometimes contradicted f
19 things that were being broadcast through the EBS.
[
20 Q
What is your understanding of the purpose of these i
l 21 news releases?
I
(:1 l
22 A
Well, to provide other sources of information for ACE-FEDERAL REPORTERS, INC.
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the public and for the media, who I know will be very.
2 interested in what's going on.
3 Q
Okay, we'll ask about some of the other 4
contentions that you said you would be testifying on, the 5
areas.
Do'you recall what other areas that you are going to 6
be testifying on?
7 MR. MC MURRAY:
Let me state for the record we-8 stated in a letter exactly which contentions she is going to 9
be testifying on.
You can test her memory now on the 10 subjects, but I assume you will go over each one individually 11 later.
12 MS. LEUGERS:
That's right.
Just what other areas 13 besides the EBS messages and rumor control --
14 MR. MC MURRAY:
To the best of your knowledge, 15 what others?
16 THE WITNESS:
There's one about evacuation 4
17 centers, about people needing to be monitored if the center 18 is set up since they will be concerned about whether or not 19 they received a dose of radiation.
I believe the contention 20 says that the plans for handling monitoring are inadequate.
I 21 MS. LEUGERS:
Okay, do you have a copy of the
)
t 22 contentions?
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MR. MC MURRAY:
I don't believe I.do.
Yes, I do.
2 MS. LEUGERS:
Do you know which version'that'is?
3 MS. MC CLESKEY:
That's not your version.
You 4
will have to tell her the number and she will have to look in 5
the table of contents for page numbers.
It is not so hard.
6 Chris insists upon using the red set of contentions, so --
7 BY MS. LEUGERS:
8 Q
I'm looking at Contention 30.
Is this one of the 9
contentions you will be testifying on?
10 A
Yes.
I 11 Q
Are you familiar with this contention?
12 A
Yes.
13 Q
And you have already talked about this has to do 14 with the emergency news center, you already mentioned 15 something about the emergency broadcast messages.
Could you 16 give me the gist of what your testimony is going to be?
17 A
Well, as I said, I'm still formulating it.
I i
18 think one of the main points, however, will be that people 19 will be looking to multiple sources of information in order 20 to determine how to respond to what they hear on the ERS, and 21 then once they start hearing other things how to understand 22 that also.
News center broadcasts that are not timely will ACE-FEDERAL REPORTERS, INC.
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-give the impression that LILCO is not providing public 2
information that is accurate and up to date.
3 Q
Again you said news center broadcasts, and I'm not 4
sure --
5 A
I don't exactly -- releases.
They are handed out 6
or something.
I would suppose that there will be local and 7
national television and radio people who come to be there who 8
will have on-site cameras and so on, be broadcasting in the 9
media simultaneously with other broadcasts what they are 10 finding out.
11 Q
So are you saying your position is because of the 12 delay in releasing news releases to the news that that will 13 affect what the public will do?
14 A
I think what it will do will increase their i
15 tendency to do what they thought they would do to begin with, 16 which is to leave if there was an accident.
17 Q
How will it endanger their health and safety?
18 A
Well, I think the main thing that will happen is 19 that more people than LILCO predicts will be attempting to 20 evacuate and that because of the geography and the 21 configuration of Long Island, this can create unmanageable k
22 traffic delays.
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1 Q
Because of the news releases?
2 A
As I think, the news releases are one part of the 3
system of interpreting the situation.' The way I understand 4
people's response to an emergency is that different members 5
of the public and actors in the scenario, as you call it 6
here, have to interpret the situation as it develops, and 7
that their beliefs and expectations and intentions to behave 8
at the time that something happens will enter into every 9
phase of what they do subsequently and how they understand 10 information they receive.
7, N.)
11 And whenever something suggests that there is --
12 that the utility is not revealing what it knows, particularly 13 if it sounds like the utility knows that the situation is 14 more serious than they are allowing the media to understand 15 and to ask questions about, I think many members of the 16 public, those many people who don't trust LILCO to begin with 17 will interpret that as one more sign that things are more 18 dangerous than they are being told and they will feel it is 19 in their interests to get out if they possibly can.
20 Q
In stating your position with 38 you said there 21 would be multiple sources.
What other sources besides the 22 news releases?
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A Well, there will be all of the media we have in 2
the United States.
Something like this would be on Wake Up 3
America or whatever.
You would wake up in the morning and 4
see it on television.
It'would be on radio stations across 5
the country, probably across the world.
I think the question 6
would be what news sources wouldn't it be on rather than what 7
ones would it be on.
8 Q
Besides news sources, what type of sources are we 9
looking at?
10 A
We'll, you know, I'm sure you have seen how O
11 Chernobyl was handled and how TMI was handled.
They will be 12 interviewing experts around the world on atomic power plants 13 and evacuation planning and radiation dangers and, you know, 14 anyone who has any expertise in this area will be called 15 upon.
People on the street will be interviewed.
This is one 16 way in which rumors get started.
There will be newsmen out 17 there saying to someone who lives across the street from the 18 !
EPZ, what do you think is happening?
19 Q
Would you agree that the prime consideration here 20 is the public health and safety of the people within the l
10-mile EPZ?
21 l
l l
22 A
No.
Well, I would say I would suppose it would bc N
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1 anyone who could be damaged through exposure to radiation in 4
2 the event of an incident.
3 Q
But would you say.that the primary' concern is the 4
health and safety of the public?
5 A
Yes.
,6 MR. MC MURRAY:
Objection.
Asked and answered.
4 7
BY MS. LEUGERS:
8 Q
So would you say also the news releases' purpose 9
would_be to insure the health and safety of the public, one 10 of the purposes?
.(
11 A
That's --
t 12 MR. MC MURRAY:
Is this in general or if done 13 properly or the way it was done --
14 MS. LEUGERS:
Either way.
Both ways.
j.
15 THE WITNESS:
Is that the purpose of them?
I i
16 mean, the way -- I have not finished reviewing this issue 17 because I have not looked at all of the possible relevant l
18 material on it even to show me exactly what happened, but l
19 from reading the concentions and the FEMA report, it is not i
i 20 clear to me that that's what they were designed to do, at l
21 least as they were carried out.
Perhaps that was LILCo's
\\
22 intent.
i ACE-FEDERAL REPORTERS, INC.
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BY~MS. LEUGERS:
2 Q
What, in your opinion, were.they designed to do?
i 3
A I believe they were designed to meet some 4
requirements of planning for an emergency.
5 Q
And wouldn't you imagine that the purpose of 6
planning for an emergency is the pm health and safety of 7
the public?
8 A
Yes, I think the overall planning intent is to do 9
that, yes.
10 Q
How would you characterize the relationship 11 between these news releases and the EBS messages?
12 A.
Well, I think they are contradictory, because 13 often one thing is being given out simultaneously with 14 another message, and I think that will be interpreted -- it 15 will be seen definitely as contradictory.
What the intent of 16 LILCO is in doing that, I would assume that that's a problem 17 in their ability to respond to an emergency rather than an 18 intentional, you know, thing they would do in a drill.
19 Q
I'm probably not asking my question very well 20 there.
I was looking more at how do they relate to each 21 other, not necessarily the substance as you evaluate them in 22 this situation but how you evaluate the relationship between ACE-FEDERAL REPORTERS, INC.
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news releases and EBS messages in an emergency.
2 MR. MC MURRAY:
Do you want a single question?
3 THE WITNESS:
I'm not sure what you are~getting 4
at.
It seems to me that it is not an entirely voluntary 5
thing, that people will want to know that -- the press and 6
the public will want to know at greater length from the 7
utility just what's going on, and that that's what the news i
8 releases are supposed to say..They should provide more 9
information, I would think, than the EBS, and they should be 10 open to interaction with the public so that more information O
11 can be exchanged.
12 BY MS. LEUGERS:
13 Q
What is the purpose of the EBS messages, in your 14 opinion?
15 A
To tell people what to do because there is a 16 condition in which their behavior may be important for their 17 health and safety.
l.
18 Q
Would you rank their priority?
I 19 A
I think that's an artificial distinction if you 20 j
are really interested in handling an emergency.
I think you 21 have to look at how people are receiving the information and h'
I 22 !
how they are handling it in the p1 ~ess of dealing with s-i i
l l
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information.and relating it to behavior.
You can't assign a-2 kind of a priori priority.
3 Q
So you wouldn't say that the EBS messages are more 4
important than a news release to the media, like a newspaper 5
that publishes once a day?.
6 A
I guess what I'm saying is that I think you have 7
to look at the information now and the interpretation of 8
events, and that to s..y that one thing is going to be more 9
important than another, there's no -- I know of no evidence 10 that would support that.
O 11 Q
Let's look at this information now, then, a little 12 bit.
EBS messages are released every 15 minutes, and you 13 have read the messages.
News releases are given out a bit 14 later, at the news center.
It is given out to the media and 15 the media are given an opportunity to ask questions.
The 16 media then report back, maybe to a newspaper that comes out 17 once a day.
Given that type of situation, can you say one is T
18 more important than the other?
19 A
That's one situation, yes, if the newspaper is not 20 going to come out until next day.
But you are going to have 21 other things.
You are going to have television channels --
i I
22 Q
Or even television, when the EBS comes out every ACE-FEDERAL REPORTERS, INC.
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15 minutes and television reporters get the material and 2
develop their story --
3 A
Here's what I think_ people will do.
The EBS will 4
come on.
They will turn on their televisions.
They may find 5
- a. radio and turn it on.also.
They will perhaps call people t
6 to find out.
I think they will immediately; attempt to' access 7
all possible sources of information to interpret the 8
situation, and I think that will begin as soon as anyone i
9 hears anything.
10 Q
And in making your position, what kind of O
11 information are you relying on?
12 A
There was research at TMI on what people -- how 13 people used information sources, and I'm checking into that 14 in terms of the Chernobyl situation.
15 Q
You have talked about TMI and Chernobyl.
I have a 16 question about that.
Did TMI have an emergency planning i-17 establishment for dealing with evacuation?
[
18 A
The same regulations were not in effect then.
The i
[
19 NRC regulations were different prior to TMI.
20 Q
Did they have these type of mechanism in place for i
j 21 informing the public with EBS messages, rumor control --
i 22 MR. MC MURRAY:
That's a multi-part question.
i I
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Either break it down or focus on the ENC or something like 2
that, but there are too many parts in that question.
3 BY MS. LEUGERS:
4 Q
Before TMI, do you know if there was a plan for 5
dealing with news to the public, a formulated plan?
6 A
I doubt that there was.
7 Q
Do you see any problem comparing how the public 8
reacted to a situation where there was probably no plan and a 9
situation where there is a plan?
10 A
only if the plan made a very big difference in the OO 11 information climate.
I'm looking at it from the perceiver's 12 point of view, not the planner's point of view, and there are 13 a lot of factors that have to be taken into account when you 14 try to understand how a person is going to hear a message.
I 15 think always it is an issue for planning whether people will 16 go along with the plan or not, whether the plan has any 17 reality or whether it is simply a document.
I think the 18 issues here are that some of the claims that were made about 19 what the information would be and do are not fulfilled, and 20 those claims come out of criticisms of things like the TMI 21 situation.
O
\\/
22 Q
And you are basing your position on -- have you ACE-FEDERAL REPORTERS, INC.
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talked to anyone who was at the exercise, what happened at 2-ENC --
3-A No.
4 Q
You said you looked at the FEMA report?
5 A
Yes.
6 Q
Have you done any independent research to verify 1
7 the type of facts that are set forth in Contention 38?
8 A
No, I have not.
9 Q
Are you intending on doing that?
10 A
I don't know.
I'm not sure exactly what that 11 would involve.
12 Q
Do you plan on looking at some of the logs of the 13 players involved at the ENC?
14 A
I don't know whether I will or not.
I have to 15 firs t get a clear picture of what information is available 16 and what use it would be.
17 Q
So how will you proceed in researching this issue?
18 A
Well, I will probably ask counsel about 19 documents.
It is very likely that he will look at the 20 l videotapes of the ENC, and as I'm working on my testimony if 21 I feel I need to know more details about what happened I will i
A -
22 l inquire about what sources might be available for learning i
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about those details.
2 Q
Why don't we turn to 38-A, the first subpart.
3 A
Okay.
4 Q
It says that ENC provided no information to the 5
media until three hours later and holds this as one of the 6
failures of the plan.
Would your opinion be different that 7
this is a failure if you knew other information was 1
8 disseminated to the media during this time?
9 MR. MC MURRAY:
Could you specify what information j
10 or-just any information?
O 11 BY MS. LEUGERS:
12 Q
Any information given by LILCO.
i 13 A
I would have to know the nature of the information 14 and how it was disseminated.
15 Q
Other press releases --
i 16 A
Not through the ENC?
17 Q
That's right.
18 A
My understanding of why they have the ENC is to i
19 l prevent contradictory information, and if LILCO itself were L
i l
20 providing different sources of information, that would 21 discredit the fact that the ENC was playing a central role, I 22 think that would be a problem.
l l
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Q At this point the ENC was not activated.
Prior to 2
that time, other information -- the media is able to call, 3
have their own hotline number so they could get information.
4 A
Was that part of the test?
5 MR. MC MURRAY:
Let her ask the questions.
6 BY MS. LEUGERS:
7 Q
If you knew that type of information were being 8
provided to the media, would your opinion be dif ferent as.to 9
the failures listed in 30-A?
10 MR. MC MURRAY:
I still have the same objection.
O 11 When you say "that type of information" -- all you stated is 12 a news release.
Unless you can talk about the substance I'm 13 not sure Professor Saegert can answer the question 14 meaningfully.
15 THE WITNESS:
It would depend on the nature of the 16 information and the exchange, what was going on.
17 BY MS. LEUGERS:
18 Q
Information dealing with what is happening at the 19 Shoreham facility, what kind of emergency protective action 20 is being taken.
If that information is provided.
j 21 A
Would I -- what was the question again?
22 j Q
If you knew that this type of information were ACE-FEDERAL REPORTERS, INC.
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being provided to the media prior to the time of the HNC 2
being activated, would that change' your opinion as to the L
3 failures listed here under 38-A?
U r 4
MR. MC MURRAY:
Same objection.
There's 5
insufficient basis for this hypothetical.
If you have an h-6 answer you can give it.
7 THE WITNESS:
No, I-think that unless I had some 8
material that I could see what the nature of the informatdor.
'9 was and the flow of timing and the relationship between 10 different messages put out, that I wouldn't be able to answer g
11 the question.
12 BY MS. LEUGERS:
s 13 Q
Would the fact that EBS messages were gding out in 14 the morning before this time have an effect upon yolirr answex?
15 A
No.
I know they were going out.
They were going j
16 out prior to that.
I suppose that -- I'think it is a similar 17 situation to rumor control, which is you can postulate an 18 ideal situation in which LILCO handles all requests timely, 19 accurately and in such a way that no contra <lictions are 20 created, but that's an ideal situation, and I can't speculste 21 on ideal situations.
I think emergency planning is to deal 22 with the realities of human experience, which is not ideal.
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1 Q
Have you looked at all of-the examples listed here
- 2 under.the failures?
3 A
Yes, I have.
4',
Q 38 N --
5.
A~
Is this the one that says,"At press conferences, t.
6 LERO personnel"'--
.y 7
Q
'Right.
5 i
8 A
Okay.
9 Q
Here it states th'ai LERO personnel misstated facts i
l1/)
and the example given is that they stated that a site
. O 11 emergency hact bt2en declared at 8:23 when the correct time was
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crucial?
1 j
t 14 3'
MR. MC MURRAY:
I object to the form of the I. s hquestionandtheword" crucial."
I 15 y
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15 l
BY MS. LEUCERS:
i
/ ':b this type of disstatement of facts the type i
17 Q
Is 10 that. would concern you in getting out proper information to l
i s
19
,, the public?
1
,20 A
The difference in time is fairly small.
I think 3
t f
21 the quei' tion it would raise is what's the process of
'O i
22 infor. nation and communication flow that results in an error.
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1 Why isn't it just correctly stated?
I think that in these 2
contentions, it is not each one -- each example does not have r
3 equ'al weight, but I think it is the pattern of multiple 4
errors that is an issue.
5 Q
So do you consider this one in particular to be a 6
problem?
7 A
I think it is a minor problem, yes.
8 Q
Would it endanger the health and safety of the r
j9 public?
l I
l0 MR. NC MURRAY:
Object.
Are you taking this.alone
~
e
,/
11 or in the context of the entire contention?
12 MS. LEUGERS:
Right now I'm just talking about 13 38-N.
r
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/
14 THE WITNESS:
As I said before, I don't think you 15 can evaluate information tiny point by tiny point and decide 16 what impact it will have on the health and safety of the l
population, I think you have to look at how information is 17 18 being generated and disseminated and interpreted in order to 19 answer that.
20 BY MS. LENGERS:
21 Q
Have you looked at that in particular?
b v
2 ')
A Well, that's what I'r,trying to analyze now.
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ACE-FEDERAL REPORTERS, INC.
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have begun to do that by reading the contentions and seeing 2
how the flow proceeds and what's accurate, what's inaccurate, 3
what.the problems are, and to look at the FEMA report for 4
that, and I will probably look at other kinds of information.
l 5
Q But at this point you.can't look at these and give 6
your analysis of how this information fits together and how 7
it flows?
8 A
Well, I don't think that I would ever pick out one 9
thing, particularly one of the minor things, and make a whole 10 analysis of it.
11 Q
If you were to look at all of 38, it goes all the 12 way up to Q.
At this point are you able to give your opinion 23 as to what the information flow is surrounding these 14 contentions and how it impacts the public?
15 A
Some of these are more obvious than others.
Some
/
16 of the lapses in time are not minor.
Some are fairly long.
17 I think the first contention that we've already talked about 18 a little bit, the lack of -- the. lengths of time before 19 opening the ENC I think would create a bottleneck of i
20 information because that's the major plan by which LILCO is 21 supposedly disseminating information.
- m (14 l '-
22 Q
Does that assume that that's the only information?
s ACE-FEDERAL REPORTERS, INC.
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A No, it doesn't assume it is the only.
It assumes 2
that it'has a purpose in the plan that.has to do with 3
coordinating information so that it is not haphazardly _
4 distributed to th'e public.
Let me look through this and look 5 ! at other things.
6 Certainly, this issue about ingesting KI tablets, 7
I think, would be a very significant thing to the public, and 8
I think that it is something that LERO should have 9
anticipated handling through the news center.
It is 10 certainly something that every newsperson on the story would 11 be extremely interested in.
12 Q
Have you done any research on that area?
13 A
What do you mean?
14
.Q As far as the contention?
Any independent 15 analyses --
16 A
Studies?
No, I'm just beginning to do work on 17 this, as I said.
18 Q
So pretty much what you are basing your opinion on 19 is what is written in the contentions?
20 A
And my reading of the FEMA report.
21 Q
So you are basing your opinion on 38 on what you 22 read in the contentions and in the FEMA report?
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A Right.
Well, I'm basing it on everything I have 2
read, which is those things plus the messages, the ENC 3
releases and the Emergency Broadcast System messages.
4 (Recess.)
5 BY MS. LEUGERS:
6 Q
I have a couple of things to ask you about 38, 7
Could you read 38-Q?
8 A
Yes.
9 Q
Tell me if you agree with that, please.
10 A
Yes, I agree with that.
s 11 Q
What is your opinion as to why these changes would 12 still create a deficiency in the LILCO plan?
13 A
My understanding is that we're really talking 14 about the way an emergency is handled, not the plan, and I 15 think what the drill is supposed to do is to see what people 16 do, even though it is under a much lower pressure situation.
l 17 And what the plan means when people act.
1 I
I 18 In terms of things like the copier and the 19 computer, I think that any real situation at any given moment l
20 in time, there can be technological failures.
A computer can l
21 fail or get messed up just like a copying machine can, and l
22 the issue is how people deal with that, whether they deal ACE-FEDERAL REPORTERS, INC.
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'I with it in such a way that it doesn't create a problem or it 2
does create a problem, so I don't think the details are the 3
most significant issue.
In terms of another spokesperson, I.
4 don't see what that would do at all, what kind of help that 5
would be.
It seems like the problems are systemic in terms 6
of the exchange of information and what the content is, and 7
without knowing who the person was or why they would be so 8
much better than the people that were actually there, I don't 9
see what difference that would make.
10 Q
As has been alleged by Suffolk County and the
'~'
11 other intervenors, there were delays in the information going 12 out, if another spokesperson or copy machine or the computer
- 13 would relieve some of those problems as has been alleged in 14 38, do you still see that having no effect upon the 15 deficiencies?
16 A
It really depends on how it is handled.
If things 17 are not well-coordinated, more sources of information can 18 create more conflicts rather than more clarity.
I would 19 really have to know what would happen.
20 Q
Do you intend to look into this and research 21 whether these factors will make a difference?
(~'
l j
5--
22 A
I don't know at this time whether I will do that l
I l
ACE-FEDERAL REPORTERS, INC.
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or not.
2 Q
Why don't we turn to contention 39?
Will you be 3
testifying on 39 also?
4 A
Yes.
5 Q
Can you give me a basic idea of what Contention 39 6
concerns?
7 A
Well, the intent apparently of the rumor. control 8
center is to correct misinformation, and it also seems to be 9
a place that people can call if they want to find something 10 out specifically.
From the examples in the contention, it 7-s
- \\d 11 appears that the information was not given out in a timely 12 way.
People's responses were put off, which I think is 13 counter to the whole idea of rumor control.
And then poor 14 judgment was sometimes used in the exact responses that were l-l 15 given.
16 Q
What do you see this to be the effect?
What l
17 effect will this have?
j 18 A
Well, it really depends on a number of things.
On l
19 l
one level, it will have the same impact that problems with l
l 20 the ENC will have, which is it will be translated by the l
21 media as an example that LILCO is either not answering things i
22 because they are concerned about giving out information, or 1
l ACE-FEDERAL REPORTERS, INC.
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that they are incompetent in some way because,they are'not on.
2
- top of the situation.
3
.Q
. Excuse me --
4 MR. MC MURRAY:. Let her finish her-answer.
7 7 -
5 THE WITNESS:
I'm assuming now that the media will 6
be out interviewing people all over the place in this area, 7
and I think that's a fair assumption.
Then if you.look at J
8 the different problems, I think they can have different t:
- 9 effects.
People will talk to each other, for one thing, and 10 this:will be a cumulative discrediting of the'particular L
O
- . (_/
11 source if it is not accurate.
For the specific people that 12-call, I think they can encounter.a whole variety of problems F
13 based on the fact that they are not told immediately an-14
~ accurate answer.
i 15 Some of these things like the caller from Shelter 16 Island, I~would suppose the question asked there would be 17 something that everyone on Shelter Island wanted the answer 18-to.
There would be people trying to get through who called,
(
19 so the person who gets a response, which in this case was not 20 an answer, will probably communicate that to other people who.
I 21 are seeking the same information.
(
22 That one I think, certainly the one about the Arab ACE-FEDERAL REPORTERS, INC.
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1 terrorist, I think it is really incredible, if this were a
~
2 real emergency, you would think that if this were not the 3
case, that the person who answered the phone would say, no, 4
this is not the case.
To delay an answer on something like 5
that gives it a potential credibility that's really -- would 6
definitely -- the chances are very high that that would be-7 picked up by the media.
8 Even things like whether the cooling power was 9-blown up.
That's a pretty serious thing.
I would suppose 10 that a caller who couldn't get a response to that would call.
11 other places, which is one way that information gets 12 generated.
You don't get an answer to your question, and f
13 then something gets into the media because you call a news 14 station or you call another source of public information.
15 BY MS. LEUGERS:
16 Q
So what are you saying will be the effect upon the 17 public?
18 A
What will happen is it will be broadcast over the 19 radio.
20 Q
How will it --
21 A
It is unlikely to stop calling at that point.
i 22 They are likely to dial another number, to dial a local news ACE-FEDERAL REPORTERS, INC.
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station or to dial, you know, the Red Cross, where'there 2
might be a newsperson standing there, saying we're getting a 3
lot of calls now, caller just informed us that they called 4
the LILCO rumor control number and asked if the cooling 5
~ towers were blown up, and there was no response.
6 Q
What do you base that opinion upon, that that 7
would be the people's response?
8 A
Well, that's what happened at TMI, and it is 9
generally what people do when they are seeking information, 10 particularly when they are dealing with a source that doesn't O
11 have high credibility, they seek other information to 12 confirm, particularly if they get no information, s
13 Q
From what we discussed earlier, TMI didn't have 14 this type of mechanism in place?
1.5 A
If the mechanism further compounds the problem, I 16 don't think you can argue that this is going to work, that 17 this is helping.
18 Q
Are you basing your opinion upon any logs or 19 messages that you have read?
20 A
No, just on the information in the contention.
21 Q
So you have not made your own determination i/
22 whether these facts are correct?
ACE-FEDERAL REPORTERS, INC.
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A No, I have not made a separate analysis of'whether 2
these things occurred or not.
3 Q
And you have not looked at -- you have not 4
analyzed the mechanism involved in rumor control?
5 A
only to the extent -- I have just begun to look at 6
it.
I tried to figure that out from what FEMA said somewhat.
7 Q
So you don't really know what's involved in 8
answering a rumor or a question?
9 MR. MC MURRAY:
Objection.
You are trying to put 10 words in the witness' mouth that I'm sure she didn't intend.
O 11 The question is vague and I'm going to ask you to rephrase it 12 with respect to whether she knows how it works.
Clearly we 13 have set out in the contentions a lot of how it worked or 14 failed to work.
If you are talking about the flow of 15 information or you are talking about a flow chart or 16 something like that, that's fine, be specific about it;-but I 17 didn't understand the question.
18 BY MS. LEUGERS:
19 Q
Do you have an understanding of how people at 20 rumor control got answers to questions from the public?
21 A
I don't have a clear understanding of what their A
22 instructions were or what kind of process they followed.
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is clear to me from reading this that they could not answer 2
immediately.
3 Q
Do you intend upon doing any type of research on 4
how this mechanism works?
5 A
I don't know at this time whether that will be 6_
necessary or not.
7 Q
In reaching your conclusions and making your-l 8
opinions on 39, will you be using any of your own 9
4. publications or research?
10 A
I really don't know.
11 Q
Will you be using any other individuals' research 12 or publications?
13 A
I really have not gotten very far with this 14
-contention.
I don't know what material I'm going to use.
15 Q
okay.
In your opinion, what is the purpose of 16 rumor control?
17 A
To -- it appears to be to correct misinformation 18 that people have, and to allow people a place to get greater 19 information that they are confused about what the meaning of 20 information that they have heard might be.
21 Q
In your opinion, how does the function of the e
22 i
rumor control fit into the whole picture of public ACE-FEDERAL REPORTERS, INC.
202-347-3700 N.ition*ide Coserage Mn336-6646
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2 A
Well, it is a place where specific individuals can 3
try to' check out questions they might have about what's 4
really going on.
It is directly provided by LILCO.
5 Q
Do you make a distinction between rumors and 6
questions?
7 A
Well, they are not the same idea, right, but I 8
don't know that functionally in this they are so different; 9
that something like have Arab terrorists taken over the 10 Shoreham plan is a question a person has in response to 11 information they have received.
When a person gets 12 information, they don't know if it is a rumor or the truth, 13 so to try to make that distinction is very difficult, even 14 though afterwards it can be made easily.
15 Q
How would you define a rumor?
16 A
Information which turns out not to be true.
17 Q
And would you say, can you determine from 18 reviewing 39 whether these are rumors or questions?
Can you 19 make that distinction?
20 A
As I said, I don't think even in an exercise I 21 don't think you can determine that, i
(2) l j
22 Q
What kind of effect would -- what kind of effect ACE-FEDERAL REPORTERS, INC.
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3 A
Depends on how good the rumor control is, I guess.
4 Q
I probably didn't convey that very well.
If there 5
were no rumor control function whatsoever built into the 6
plan, what type of effect would that have on an emergency and 7
the public's health and safety?
8 MR. MC MURRAY:
Let me get a clarification on 9
this.
Are we talking about this rumor control plan or one 10 that works ideally and that is effective?
I'm not clear
_()
11 where you are going.
12 MS. LEUGERS:
I don't make a distinction on that.
13 MR. MC MURRAY:
You are just talking about any 14 rumor control plan, whether it is effective or not.
15 THE WITNESS:
I don't think that those kinds of --
16 that's really too undefined a situation to say how it would
?
17 work.
18 BY MS. LEUGERS:
19 Q
What is the effect of rumor control on public 20 health and safety?
A of this rumor control?
21 l
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Q Of rumor control function itself in any type of i
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emergency.
2 MR. MC MURRAY:
Assuming it is effective.
3 MS. LEUGERS:
In a generic --
4 THE WITNESS:
First, I don't think that I should 5
assume it is effective.
It seems to me this whole thing
~
6 about how information flows and accumulates and people begin 7
to interpret it depends on what actually -- how information 8
actually develops, and without knowing that kind of 9
information, to say whether rumor control is_ effective as an 10 idea is meaningless.
It is either effective because of the V
11 way it works and because of the rumors that start and are 12 effectively cut off, or it is not because rumors start that 13 can't be effectively handled through this mechanism, or it is 14 ineffectively handled or rumors don't come to the attention 15 of this, or there are just a million different things that 16 could happen there.
i' 17 BY MS. LEUGERS:
18 Q
Okay, and looking at 39 A, I don't know which page 19 l
that is for you, probably the next page -- are you familiar I
20 j
with 39-A?
21 A
I'm familiar with it but I need to go over it to
(,
I 22 i answer any of your questions.
l I
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1 L Q-That's okay.
You can look over them.
What is 2-your position on'39-A?-
3 A
Well, this does'not sound like effective rumor 4
control.
Is that what you mean?
5 Q
. Well, if that's your position,'what you would be 6
testifying on 39-A.
7 A
Okay, again, what my testimony -- I think it is 8
sort of clear from what I.said so far that the way I'm 9
thinking about my testimony now ---and this may change later,.
4 i.
10
.in some ways, but I don't think the overall framework will 11 change -- is that all these pieces have-to be. looked at from-l j '-
12 the' point of view of what the public, different members of
'13 the public were receiving and how they were interpreting i
14
'that, so the details of the logs are important within the 15 framework of whatever else is going on and how it affects I.
16 what information people are getting, and how their concerns 17 are being responded to.
i:
I 18 Q
Okay, in looking at that framework, and for the i
19 sake of argument assuming that all these delays existed, how 20 does rumor control answering questions having this type of 21 information and answering questions to the public fit into 22 the whole framework of the information to include EBS ACE-FEDERAL REPORTERS, INC.
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2 whatever other information, what relevance do you put on l
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this?
4 A
Well --
5 MR. MC MURRAY:
Do you understand the question?
6 THE WITNESS:
The idea of what relevance is, I'm 7
not really sure.
There's one issue that I think this 8
addresses, which is that this gives people a place to call i
9 that.they can say a question, find out information rather 10 than just hearing things which they may or may not understand
(-.%
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11 and which they have not generated themselves.
Does that 12 answer your question?
13 BY MS. LEUGERS:
14 Q
I think it answers part of it.
Let me see if I 15 can narrow that down.
That was a long question.
16 A caller's receiving this type of information or 17 the caller's receiving outdated information from rumor 18 control, what effect does that have on the public's health 19 and safety?
20 A
That's one part of the situation.
I mean, for the 21 individual person.
It probably increases their anxiety about (m
i 22 the situation, and it would encourage them to turn to other ACE-FEDERAL REPORTERS, INC.
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2 ForLthe' people who can't get through, it will have the same
.3 effect.
Then the way-this is interpreted and picked up in 4
the media, this will create a demand for'other sources of 5
information that are responsive to questions, and if those 6
other sources of information provide information that-either 7
confuses people further or creates' anxiety, it will further 8
increase the probability that they will try to get out of the 9
situation.
10 Q
LWould you say some of the other sources they would
)=
11 turn to would be the EBS messages and other information from 12 the news media?
i
.13 A
I think that they probably wouldn't turn to EBS 14 messages, particularly because they have already heard the 15 EBS messages.
If those had been sufficient to answer their 16 questions, then I doubt that they would have called in the 17 first place.
It doesn't seem to me the questions that people i
18 ask in the simulations were of the sort that were answered by l
19 EBS messages, k
.20 Q
In just looking at A, we're looking at time frames 21 of what was happening, not questions about Arab terrorists or i
g.
22 lobsters or whatever.
[
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Let's turn to 39-B.
Are you familiar with 39-B?
2 A
Yes.
~
"3 Q
And I know you have talked a little bit about'some 4-of-the questions here, but could you-briefly again state what-5 your testimony would be?
-l l
6 A-Well, what I will.try to do is to lay out a
.l
~
~7 picture of the information climate and relate it;to people's 8
likelihoods of-behavior in different ways, and how it will 9
affect their compliance with LILCO requests.in:one way or-10 another; and the rumor control messages feed into part of a.
t-
~
11 picture of inadequate information being provided by LILCO, 12 which will increase the likelihood that people are'just going
.)
j
.13 to get out rather than to stick around and be further 14 confused.
15 Q
I'm not sure if I understood all that.
Let me see
.16
-if I have.
In 39-B, you would be focusing not on the delays 17 in the calls but more how --
r 18.
A Yes, I think that the delays -- I have already.
19 said some of this.
Some questions, it makes no sense to have 20 a delay to the caller even if there's a procedural reason 21 that LILCO has for not answering immediately, f
22 Q
Why do you say there is no reason for the delays?
d i
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A I said there could be reasons on LILCO's sides.
2 I'm saying that it will not seem reasonable to the caller 3
that certain questions can't be answered.
4 Q
What is the prime importance in answering? 'Is it 5
speed or accuracy?
6 A
I can't trade those two off against each other..
7 Both can be fatal to a message.
A message that's accurate 8
but too late will no longer have a listener.
A message
'9 that's inaccurate but immediate would also obviously be bad.
10 Q
In your opinion, what would be an adequate amount
(,,T U
11 of time to answer questions such as the ones in 39-B?
12 A
It depends on the question.
I think that as I 13 said, some questions immediately go to the credibility of the 14 rumor control process at all, whether the person answering 15 the phone is actually capable.
Some questions seem too much 16 to be a central part of the emergency for there to be any 17 reason why a caller shouldn't get an answer when they call.
18 Other things, there's inevitably going to be tension between 19 what a caller needs and what LILCO has.
If you are concerned 20 about your child, 10 minutes is way too long.
Ashour is way 21 too long.
Your choice is am I going to try to do something 22 or am I going to sit around waiting for LILCO to call back?
ACE-FEDERAL REPORTERS, INC.
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1 Q
In your example of an-Arab terrorist, you said 2
something like that should be answered immediately?
Is that 3
.your response?
4 A
I think from the caller's point of view, yes.
5 Q
From the point of view of providing accurate 6
information to the public, do you think that should have been 7
answered immediately?
8 A
I don't think that's what I'm here as a 9
psychologist to testify about.
I think what I'm here tc 10 testify about is how the public will respond, and hear uhat s
11 the messages are that LILCO puts out through different 12 channels.
It is difficult to manage an emergency.
I grant 13 that.
And to manage it successfully is difficult.
I don't 14 think that's what I'm supposed to testify about.
15 Q
So you are only looking at the time frames here 16 from the standpoint of the caller and not from the standpoint 17 of the system developed to make sure that accurate' 18 information is given to the public?
19 A
At this point I am.
It is possible that as I 20 develop my testimony I will try to look at it from the point 21 of flow of information within the system. but I have not done C%s)
~
22 that yet.
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.Q Would you agree that it is important to look at it 2
from both standpoints?
3 A
I think that it is important to look at it from 4
both standpoints, yes.
5 Q
Suppose in your research you conclude that it'is 6
important that it take this amount of time to provide 7
accurate information to the public.
Would you consider these 8
still deficiencies?
9 MR. MC MURRAY:
Assuming all these delays were 10 necessary in order to provide the correct answers?
Would her v
11 testimony change?
Is that what your question is?
l 12 MS. LEUGERS:
It is the same time phase as 13 necessary to find correct answers to for the public.
14 MR. MC MURRAY:
Is the question then would her 15 testimony on human behavior change?
I just don't understand 16 the question.
l 17 BY MS. LEUGERS:
18 Q
39-B alleges that all of the calls listed here for 19 rumor questions to LILCO were not timely responded to, and I 20 understand your saying even that you agree with that?
21 A
Yes, from the point, as I said before, from the 22 point of view of the perceiver or the receiver of the ACE-FEDERAL REPORTERS, INC.
202-347-3 3 0 Nationwide Coserage R&34-M>46
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information, I agree with that.
2; Q.
So you in your research should discover that it 3
necessarily takes this long to get a response, would you 4
still agree with y.our statement?
5 A
I would still agree with my statement.
I would 6
look at that in terms of problems that this information 7
cystem has.
8 Q
I may have trouble with this one.
I think we can 9
all appreciate that anyone making a call wants an immediate 10 answer.
Doesn't the system have to also take into account 11 that just because they want an immediate answer they can't 12 get an immediate answer?
13 A
Well, it does if you assume everything else about 14' the situation is necessary and given.
l 15 Q
I don't understand what you are saying.
What do 16 you mean, "everything else"?
l t
17 A
Well, that you are going to try to control 18 information through this mechanism, that you have LILCO's 19 plan and that you have LERO running the program and this is 20 the way you have decided to take questions from the public, 21 then you created a problem.
Now, once you have created a 22 l
problem, it may be partially insolvable.
It may be that in ACE-FEDERAI REPORTERS, INC.
l 202 347-3NU Nationwute Coverage Buk336e46
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'l that system the tradeoffs-are impossibleLto make, but that 2
doesn't mean that's the only possible system that could 3
exist.
4 Q
Since you basically now are looking at it from the 5
caller's standpoint, from the caller's standpoint is it 6
better to have an immediate answer that may not be accurate, 7
or that they have to wait a half an hour for an accurate 8
answer?
i' 9
A I think what I'm saying to you that that's not an 10 answerable question from the caller's standpoint.
That 11 assumes that one is better than the other.
They may.both be 12 equally bad and that may be the problem that the system has.
13 Q
What would be the impact on the health and safety 14 of the public because it takes a hour, 30 minutes to respond 15 to a caller's question?
16 A
It would be one more factor that will increase the 17 likelihood that people will evacuate regardless of what they 18 were told to do.
It will also further decrease the 19 credibility of LILCO and contribute to an atmosphere of 20 question answering and rumor spreading that will make it even 21 more improbable that LILCO can control what's happening
'A d
22 through their message system.
4 ACE-FEDERAL REPO_RTERS, INC.
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Q And I think -- Contention 44 is admitted under 38 2
and 39 for the first sentence.
I'm not sure where it is 3
going to be in yours.
And it is just the first sentence.
Is 4
that indicated on there?
5 A
Yes.
Okay, what about it.
6 Q
What is going to be your testimony on this?
7 A
Well, I think I just said what it was going to 8
be.
I will attempt to look-at the ways that these different 9
kinds of information that LILCO is generating create an 10 information climate of confusion and inconsistency, and to 11 relate that to causes of evacuation.
12 Q
Are you going to testify then on evacuation 13 shadow?
14 A-I'm not sure at this point whether I will or not.
15 Q
Are you familiar with shadow evacuation?
16 A
Yes, I am.
17 Q
Could you define that for me?
18 A
It is the people who evacuate who are not 19 specifically instructed to do so.
20 Q
Would that include also people who evacuate early?
L 21 A
Yes.
22 Q
So at this time you really don't know if you will i
ACE-FEDERAL REPORTERS, INC.
M-347-3NU Nationwide Coserage M43366646
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1 testify on 44?
1 I
2
.A No, I will testify on 44.
The extent to which-I 3
will deal -- if the shadow -- I have not decided -- there are-I 4
a number of experts.
It is not clear whether my role will be 5
primarily on that or on the information part of it.
6 Q
~ And turning to Contention 22-F, which is also 7
admitted under 38 and 39, are you familiar --
8 A
I remember this.
9 Q
You will be testifying on 22-F?
10 A
Yes.
'11 Q
And what will your testimony be?
12 A
Well, this has a lot of parts to it, and I have 13 not -- as I said, I have not written my testimony yet, and it 14 is not yet completely clear to me what parts I will have more 15 responsibility for and what parts other experts will have 16 more responsibility for.
Given that, I am considering 17 working on all of the points on page 71.
18 Q
I'm not sure what tha+ is.
I have different 19 numbers.
20-A These have to do with the public response to the 21 nuclear accident at Chernobyl, findings of ASLB, the survey 22 research and so on which would make the link between the ACE-FEDERAL REPORTERS, INC.
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1 information and the evacuation.
Specifically, on the-2 problems with the contents of LILCO's EBS messages, the 3
contents and timing of its press advisor, rumor control 4
activities, conflicting and inconsistent information in press 5
reports, preexisting perceptions and fears of Long Island 6
residents concerning nuclear accidents, and LILCO's lack of i.
7 credibility.
8 Q
What is your -- you have read 22-F.
What is your 9
understanding of the purpose of 22-F, the allegations in 10 22-F?
. h 11 A
The allegations are that the way in which 12 information is provided will not induce in the public 13 cooperation with LILCO's plan, and that the way in which this 14 will be manifest is that many more people than those who are 15 instructed to evacuate will evacuate.
16 Q
Is it your understanding that this contention also 17 refers to voluntary evacuation that's not planned for?
18 A
Yes, that's my understanding of the part of what 19 the evacuation shadow was.
20 Q
Is that your understanding of what 22-F concerns?
21 A
Well, it has a lot of parts to it.
22 l Q
Just take your time and read it over.
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1 A
Do you want me to'go through and tell you each 2
part of what I think this concerns?
3.
Q Why don't you look over it and get familiar with 4
each part of it at.this point.
5 A
Yes, that's my understanding of what it involves.
6 Q
The voluntary or shadow evacuation?
7 A
And its relationship to what LILCO's performance 8
in the exercise actually shows.
9 Q
.So h' ave you done any research on'7q,I know-you are
\\
10 talking about doing survey research data, but have y'ou done
. ()
11 any_research on this as it relates to shadow evacuation or' j
12 any preparation?
13 A
I~ don't understand the question quite.
I'm sorry.
14 Q
22-F deals with the shadow evacuation or voluntary 15 evacuation, and I'm asking have you done any type of analysis s
16 as far as shadow evacuation under 22-F?
i 17 A
No, nothing new.
l 18 Q
Nothing new?
Does that mean you have other -~
19 A
In the previous testimony, two years ago I worked copr/Wrra J e
20 with the group that worked on that eeWywJent.
21 Q
So far you don't have any'hing current other than t
! O
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22 what you did a couple of years ago?
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1 A
Right.
I 2
Q.
Okay.
.On, I guess it is the second page,.you i
i i,
3 talked about $ne survey research dat'a.
4 A
Yes.
5 Q
What are you going to testify as far as the survey 6
research data?
7 A
Well, it depends on what the analysis shows.
i 8
Q Analysis'of what?
y, y 9
8 A
If there are new surveys --- or also, I haven't i,l
.i skept tip to date with' the surveys that were done between '04 10 V,.,s
-anii ',86 about Long,Islandiresidents' intents.
m 11 j
A 12 4
C Have you done any research surveys?
13 A
No.
14 Q
Do you know of any that have been done?
15 A
Surveys of what?
16 Q
That would be related to this contention.
This 17 survey research data.
Sayn " based upon survey research 18 data."
19 A
Yes.
I think Steve Cole has done some surveys 20 during that period from '82 to '86 or,'87.
21 Q
Have you talked to him abolit these research O-22,!.
surveys?
ACE-FEDERAL REPORTERS, INC.
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A He has mentioned them in passing, but I have not 2
- yet gotten the information from him in enough detai3 to ' use.:
3 it. :
1
-~
4 Q
When did you --
j 5
MR. PK: MURRAY:
For the record, we have given the 6
survey instrument to Ms. McCleskey at a previousideposition.
1
[
7, MS. LEUGERS:
I missed it.
8 MS. MC CLESKEY:
Off the record.
h 3f' (Discussion off the record.)
10 MR. MC MURRAY:
I think Dr. Cole testified on his 7,
11 deposition about that survey.
12 BY MS. LEUGERS:
13 Q
Have you seen the survey instrument?
14 A
I saw a draft of it.
I don't think I have seen 15 the'same one that she has.
[
16 Q
Have you talked to Steven Cole since then?
17 A
No, I haven't.
l, 1
-18 Q
I may have asked you this before, b'ut are you 19 planning on doing any surveys?
20 A
Not at this time, no.
21 Q
What will you -- the survey research data, you are i.'
22 talking about what Steven Cole will be doing?
r i
ACE-FEDERAL REPORTERS, INC.
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A' Right.
'2 '
Q-
.And at this point you do not know what that data
-3 is?-
4 A
Right.
5 MR. MC MURRAY:. I believe she said what-he already 6
has done.
There have been a lot of surveys.
7 THE WITNESS:
I will look at his old work too.
8 MR.'MC MURRAY:. _From '82 on.
~
9 BY MS. LEUGERS:
10 Q
At this time, are you able to give'an opinion on
'O '
11 Contention 22-F based upon the survey research data?
.12 A
No.
13 Q
And the next is the public response to a nuclear
{
-14 accident at Chernobyl.
What kill your testimony be on this?
15 A
I really don't-know.
This is an area where I have 1
16 begun to gather information and to try to evaluate its 1
17 relevance and to look at possible existing U.S. surveys and 18 so on.
It is something that I have to do more preparation on 19 before I know what my testimony will be.
20 (Discussion off the record.)
21 THE WITNESS:
One of the things, at a simple
-22 level, I can say that Chernobyl has heightened public ACE-FEDERAL REPORTERS, INC.
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awareness, and concern and belief that it is possible to have 2
a serious accident, and that this would affect people's 3
behavior.
4 BY MS. LEUGERS:
5 Q
So this may be a strange question, public response 6
is referring to response of the United States, not in the 7
Soviet Union, right?
Is that correct?
8 A
No, it seems reasonable that I would look -- you 9
could use that information in different ways.
10 Q
But is it public response in the Soviet Union to
(,_)
v 11 Chernobyl or public response in the United States to 12 Chernoby1?
13 A
I would look at both issues.
14 Q
Okay.
How would you use this information?
15 A
Well, the first type of information is relevant to 16 a body of research on how people respond to emergencies.
The 17 second information has to do with bow people will understand 18 and evaluate information that they get about an accident 19 after Chernobyl.
t 20 Q
How will public 1esponse to Chernobyl affect i
21 l
shadow evacuation?
p) g i
.I 22 t
A Well, earlier work indicated that the majority of l
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people on Long Island, a much larger portion of people, 2
enough to clog the roads and make the evacuation difficult or
-3 impossible to handle, intended to evacuate.
One of the 4
reasons for that had to do with fear that a serious accident 5
would occur.
This will increase their fear and most likely 6
increase the speed with which they -- soonness after any 4
7 incident is announced with which they will evacuate, and also 8
their suspicion that it is more serious than people are 9
telling them.
10 Q
And what research were you talking about?
O 11 A
Now I was talking about the old evacuation shadow 12 research that I'm familiar with.
13 Q
From two years ago?
14 A
Yes, and I do also draw on other research that 15 looks at what affects people's attitudes towards the severity 16 of nuclear accidents.
7 i.
17 Q
What are those factors?
18 A
Well, the concern, the differences in concern.
19 People who are -- this are quite a few, but women are more 20 concerned about accidents than men are.
People with young 21 children are more concerned.
People who place higher values l
22 on human life and reproduction and that sort of thing tend to l
l l
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KSW 88 1
Ebe more concerned and to believe that accidents could be more 2'
serious -than people who evaluate' trade-offs more toward an 3
economic growth kind of potential.
There are quite a few 4
types of research that have bearing on this.
5 Q
Also you mentioned that you would base your l:
6 opinion upon findings of ASLB.
Could you explain that for me 7
too?
8 A
Well, I have yet to review that, so I don't know 9.
whether I personally will base mine on that or not.
10 Q
Are you familiar with that?
11' A
I'm not familiar with the document, no.
t l
12 Q
And then it says for the reasons set forth in 13 Contention 44, which was the one we just talked about.
I 14 gather it will be the same you just mentioned about the 15 shadow evacuation?
16 A
I'm sorry, I don't know exactly what you meant 17 would be the same.
18 Q
Well, tell me what your testimony would be for the 4
19 reasons set forth in Contention 44.
I 20 MR. MC MURRAY:
What subpart are we in?
21 MS. LEUGERS:
The second sentence after
\\O j-22 Chernobyl.
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\\ I KSW 89
-1 THE WITNESS:
Did I just testify about Contention 2
44?
Do you want me to say again what I would say about 3
that?
4 BY MS. LEUGERS:
5 Q
What I was really saying is that just going down 6
this list and including that in the list as being one of the 7
things you would testify on rather than going through it 8
again.
9 A
Yes, I expect at this time that I will testify 10 about the things on this list.
(
11 Q
Now I'm looking down to.the next one, A through F, 12 and we have looked at A which is the content of EBS 13 messages.
Do you have any -- other than what you have 14 discussed earlier about the EBS messages, how that would 15 affect shadow evacuation?
16 A
No, I don't yet have any.other analysis of that.
17 Q
How about the content and timing of advisories as 18 they would affect shadow evacuation?
19 A
I think we've covered my thinking on that issue I
20 and also rumor control.
21 Q
And preexisting perceptions and fears of Long 22 Island residents?
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90 KSW 1
A Well, that will contribute to a readine'ss to p
2
-evacuate.
3 Q
And I imagine you have not done any research on
[
- 4
-that-yet,and that's part of the survey?
5 A
I have literature which already exists, some of.
6 which I:am familiar with, and I will draw on the survey if it-7 is relevant.
8 Q
And LILco's lack of credibility -- what type of 9
testimony will.you'give in relation to shadow evacuation?
-10 A
Well, I'm not sure.
I will relate lack of' O
11 credibility to the disregarding of information not to 12 evacuate or to take no unusual actions, but exactly how I 13 will develop the argument I don't know yet.
I might -- it 14 really depends on what kind of information I find out is 15 available.
16 Q
The next paragraph talks about the impact this 17 type of evacuation will have on the ability of local players 18 to perform.
Will you be testifying on that?
19 A
I don't know at this time.
20 Q
The next contention is 42, subsumed also under 38 21 and 39.
I wasn't sure if you were testifying on that either.
22 A
42 --
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MR. MC MURRAY:
Is there a subpart of 42?
2 MS. LEUGERS:
Not from what I have here.
It just 3
says-42.
Says matters raised in 42 will be heard under 38, 4
39, 41 and 50.
5 MR. MC MURRAY:
I think we have identified her for 6
42 -- 40-C.
I don't think we have identified her for 42.
7 MS. LEUGERS:
So as far as you know now,-
8 Dr. Saegert, you won't be testifying on 42?
9 THE WITNESS:
This doesn't look familiar to me.
10 BY MS. LEUGERS:
O 11 Q
The next one, you said 40-C?
Are you looking at 12 just 40-C or --
13 A
Yes.
14 Q
In your own words, what is your opinion that 40-C 15 involves?
16 A
Well --
17 MR. MC MURRAY:
Off the record.
18 (Discussion off the record.)
19 THE WITNESS:
This again goes to the point that 20 l for the public to see LILCO as providing inaccurate 21 information undermines the likelihood that people will comply 22 with LILCO's information.
LILCO says it will have traffic ACE-FEDERAL REPORTERS, INC.
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guides and doesn't,~so it raises a question of what else is 2
LILCO saying that is not. accurate.
3 BY MS. LUUGERS:
4 Q
Have you read this EBS message?
5 A
I have read all of them, but I don't, without 6
looking at them3 recall this specific one.
7 Q
'So at this point you are:not able to give an 8-opinion about the content of this particular EBS message?
9 MR. MC MURRAY:
Objection.
That mischaracterizes 10 her testimony.
She said "without looking at it."
You.have O
~11 asked her without showing her the message.
If you showed it 12 to her, she might be able to do that.
13 MS. LEUGERS:
I don't have the message with me.
14 BY MS. LEUGERS:
1 15 Q
I may have asked you this already.
The ERS 16 message that is referenced in 40-C, you have looked at it?
17 A
I have looked at all of them, yes.
18 Q
But this one in particular you can't bring to 19 mind?
20 A
If I had it before me, I would remember; but there 4
21 were a lot of them, and I don't particularly remember the k-22 time that each one was announced.
i L
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93
- l
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Q.
What affect does this have upon'the:public health 2
and safety?'
3
.A-I don't think I can answer that without seeing the; l
4 message.
I 5
Q.
.From what you read in 40-C, assuming the 1.
6-
' correctness of 40-C?-
7
-MR. MC MURRAY:
I think this has been asked and 8
answered.
Go ahead and answer it again.
9 THE WITNESS:
I would say it would decrease the
.10 public willingness'to believe that LILCO was.giving accurate
\\
l 11 news information.
12-BY MS. LEUGERS:
13 Q
How does that affect their health and safety?
14 A
It relates to the fact that they will then do what 15 they think is best for themselves, which we expect would'be 16 that people would attempt to leave Long Island, creating a 17 traffic problem that was unmanageable.
18 Q
Would you agree that the only way a person would 19 know if traffic guides were in place was when they were 20 already on the road?
21 A
Well, someone might tell them and they might --
O'.
this again depends on the information climate.
There might 22 ACE-FEDERAL REPORTERS, INC.
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'M KSW 94 1
be -- likely, there would be some enterprising newsman would 2
go'to a corner and say, contrary to LILCO's broadcast, no 3
traffic guide is in place to answer our questions yet.
~
4 That's a possibility, or you know, someone might be going to 5
pick someone else up and tell the people that they couldn't 6
find information.
7 Q
What in particular will you be relying on in 8
giving this testimony in 40-C?
.9 A
Well, I think it is part of the same problem that-10 I will rely on the same kinds of material probably that I O
11 will rely on in terms of evaluating the accuracy and efficacy 12 of the information LILCO is providing in my other testimony.
13 0
Will you be looking at players' logs?
14 A
I don't know yet whether I will be or not.
15 Q
Will you be looking at reviewing any of your type 16 of research or publications?
17 A
I don't know yet whether they would be relevant to 18 the specific testimony about traffic guides.
19 Q
so what effect will this have on shadow 20 i
evacuation?
A It will be one more discrediting factor that will, 21 22 as I have said before, increase the likelihood that people ACE-FEDERAL REPORTERS, INC.
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who have thus far hesitated to evacuate will now do so.
2 MS. LEUGERS:
Let's go off the record a second.
3 (Discussion off the record.)
4 BY MS. LEUGERS:
5 Q
Have you found 49?
6 A
No.
Okay.
7 Q
Are you going to testify on Contention 49?
8 A
Yes.
9 Q
What will your testimony be?
10 A
Well, I have not formulated it completely, and
- h'
'~
11 this is kind of a new issue for me, but it will relate to the 12 problems, the fact that people would not be able to know 13 whether or not they had been exposed to radiation in the way 14 you normally know if you have been injured, so that would 15 tend to increase people's uncertainty and they would want 16 information about that topic.
The rest of it has to do that 17 we expect that many more people will be concerned than LILCO 18 predicts.
Q Okay, and what is the effect of that?
19 l
20 A
It is going to create a kind of a bottleneck.
It 21 is certainly going to create an unpredictable element, and it I
will increase people's confusion to understand how to manage k'
22 I
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the emergency in some way.
-2' Q
How would that effect decontamination-monitoring,
-3 the_ radiological. monitoring?-
4 A
It will -- if more people want to be monitored 4
5' than they are prepared to. monitor, it will mean that-people f
6 are not getting monitored when they want to and' it will ---
?
7 I'm not sure, I.have not analyzed the rest of it.
I have to t-8 find out :where it fits into the rest of the evacuation -
l 9
management better.
10 (Discussion off the record.)-
OL 11 THE WITNESS:
I mean, it seemed on the basis of 4
i 12 the FEMA report that they had underestimated how much time it 13 would take to monitor people; and if people actually-have i
l 14 radiation on them, that's going to make it much longer, I
'15 would predict.
It could also create panic in some ways, 3
16 people who are finding radiation.
17 BY MS. LEUGERS:
1 18 Q
Have you done any research on that position?
l k
19 A
No, not really.
Not yet.
20 Q
What do you base that opinion upon?
21 A
Research on how people handle information about i
22 threats and the ways in which uncertainty increases the need j-ACE-FEDERAL REPORTERS, INC.
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- KSW 97 1
for information, the ways in which people respond to negative 2
information about health conditions.
3 Q
Is that your research?
4 A
No, that's not my research.
S Q
Whose research would that be?
6 A
Well, there's a huge body of research on the 7
effects of uncertainty and how people handle uncertain 8
information in psychology.
It is a really big topic.
It has 9
been researched for 40 years, and that's part of what I --
10 and I think it would not be useful for me to try to remember 11 and list a whole lot of sources, because I will bring my 12 sources up to date for this testimony.
13 Q
So what type of -- what will you be relying upon 14 in bringing your research up to speed on this contention?
15 A
Frankly, I don't know what's out there.
I will be 16 looking to see how specifically, if there are any situations 17 that are fairly close to this that have been studied.
I will 18 go back through the TMI, look at whatever new survey data is i
ih generated to try to see whether there's anything that would 19 a
20 point to this directly.
I will look at the Chernobyl --
l 21 research on that.
Other research on hazards that you can't-A 22 identify easily I might draw on, like research on how people i
i l
i ACE-FEDERAL REPORTERS, INC.
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KSW 98 1
deal with rumors of toxic waste or something like that.
2 Q
And you will be doing that type of research to' 3
determine how many people would want to be monitored?
4 A
I don't think that I will be giving an exact 5
numerical' estimate.
I can indicate whether it will increase 6
the numbers,_you know, looking at the population of Long 7
Island-and the areas -- probably, I would work with oteve 8
Cole maybe on that.
It is related to his population 9
projections.
I wouldn't be doing population. projections 10 myself.
- O 11 Q
Have you talked to Steve Cole about this 12 contention?
13 A
We didn't discuss it in great length.
I think 14 that a question was raised as to whether this could be 15 included in the survey or not and I don't know whether the 16 final draft included it since I have not seen the draft.
It 17 wasn't included in the draft that I looked at, and since then 18 I don't know whether it has been included or not.
19 Q
Do you think there will be any type of survey on 20 this contention for what you are talking about?
Are you 21 anticipating doing any research --
22 A
I don't know whether the decision was made to ACE-FEDERAL REPORTERS, INC.
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,(] 29487.1
's ' KSW 99 1
include it or not to include it.
It was raised.
2 Q
Contention 31 subsumed under this.
I. don't know 3
if that's in the same spot.
Do you want to briefly look at 4
that, please?
5 A
Yes.
6 MR. MC MURRAY:
We have not identified professor 7
Saegert for this.
8 BY MS. LEUGERS:
9 Q
Earlier when we were talking about 49, you said 10~
that under 49, it was your understanding that it took longer O
11 for those individuals monitoring the evacuees to do their 12 monitoring.
What effect do you think that the fact of an 13 actual emergency and long lines have upon how quickly a 14 person would perform their task of monitoring?
15 MR. MC MURRAY:
Do you understand the question?
16 THE WITNESS:
Yes, I understand the question.
I 17 was thinking about it.
It would depend on a lot of factors.
18 It would depend on how well trained the person was and how 19 familiar they were with the equipment.
It would depend on 20 how that person handled stress, whether they were the type 21 that was able to really get into gear or whether they kind of 22 froze and created more mistakes.
Sometimes, for example, 1
l I
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when people are trying to do a task under pressure they make 2
more mistakes.
The more they try to hurry, the slower the 3
actual outcome can be.
4 It also depends on how the people behaved.
If 5
they were extremely hostile or anxious or frightened -- I 6
would think under any real emergency situation, dealing with 7
people would take more time because they would.be people in 8
distress, and they would make demands on people around them 9
to pay attention to their distress.
10 BY MS. LEUGERS:
('~')
11 Q
Are you saying that in an emergency a person is 12 more likely to take a longer amount of time to do a task than 13 a shorter amount of time?
14 A
I told you it depended on how well the people were 15 trained, how frequently they did this task, and how they 16 personally handled the stress.
That's on the person 17 performing the task side.
In this situation, since it is not f
18 l scmething they do every day, it is quite likely that at least i
19 l some of the monitors would do it more slowly.
Others might i
j do i t more rapidly if they were good, calm, cool headed 20 21 people; but regardless of how the people performing the task
(~h
'w '
22
-- the people coming through would make more demands on them, 3
l ACE-FEDERAL REPORTERS, INC.
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because'they would be upset and frightened; and they would 2
make more demands on them and would want opin' ions about what 3
was going on.
I g~
4 Q
Is it correct, you are unable to really decide.
5 what effect an emergency situation would have upon how 6
quickly someone would perform'a task?
7 A
No, that's not what I said.
What I said is that 8
there are different factors that would enter into how fast 9
they performed the task.
Whether it is something that can be 10 determined ahead of time -- you are assuming that that's O
11 something that can be determined ahead of time.
I think that 12 a psychologist's position on that would tend to be that you 13 would have to analyze the position, the specific conditions 14 under which the monitoring was occurring, and it would help 15 if you knew something about the people performing the 16 monitoring.
17 Q
So basically, you can't make any type of judgment 18 on my question one way or the other if it would take longer 19 or less time?
20 MR. MC MURRAY:
For individuals performing the 21 monitoring tests?
22 MS. LEUGERS:
Yes.
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102 1
THE WITNESS:
I did say one factor'that would-2
. increase the time it-takes.
People would want to ask 3
questions _and not'be just going through an exercise.
I think 4
that would increase the time.
-5 BY MS. LEUGERS:
I 6
Q Is this type of behavior something a social j'
7 psychologist would study?
8
~ A What do you mean by "this type"?
Behavior under 9
stress or --
10 Q
In an emergency when there's -- when the tasks O
11 that you are required to do are more -- how should I say?
12 For example, in this situation wheie there's long lines 13 versus just one person you have to monitor.
14 A
There might be research on that specifically.
15 Q
Would you be looking at that type of research?
16 A
I will be looking for it.
Yes, yes I will.
17 Q
But at present you have not done any type of 18 research on that particular subject?
19 A
I conducted research myself?
20 Q
Right.
21 A
That's true.
I think my own research would have 22 some bearing on that kind of a situation.
l ACE-FEDERAL REPORTERS, INC.
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Q If I'm correct, from what you have said, your 2
position is that people are more -- people are more likely to 3
go to be decontaminated than predicted because of all of the 4
other variables we have been discussing.
5 A
Yes.
6 Q
Do you think it is also a possibility that because 7
people will be evacuating early according to the contentions 8
or people evacuating who are not supposed to evacuate that 9
they will just skip decontamination and just leave?
10 MR. MC MURRAY:
And monitoring too?
11 BY MS. LEUGERS:
12 Q
Any kind of monitoring, decontamination of people 13 who are not instructed to go there.
14 A
Well, no, I wouldn't predict a difference between 15 people who were instructed and people who were not, 16 particularly, but I think it is possible that people might 17 skip it, which might also endanger their health.
18 Q
But would it also be true then, not only could 19 there be an increase, but there may not be an increase 20 j because some people won't go?
i 21 A
It is a possibility that I will have to evaluate O
22 l
before I write my testimony.
l ACE-FEDERAL REPORTERS, INC.
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Q In your opinion, how can this system be improved?
s 2
MR. MC MURRAY:
Objection.
This is not proper 3
questioning. -This witness is not here to improve LILCO's 4
plan.
4 5
THE WITNESS:
Am I supposed to answer now?
6 MR. MC MURRAY:
If you can improve LILCO's. plan --
7 THE WITNESS:
I have not studied this enough to 8
figure out what would be a better way to handle the 9
situation.
10 MS. LEUGERS:
That's all I have on 49.
I have a O
11 couple of follow-up questions I wanted to ask you.
12 BY MS. LEUGERS:
13 Q
When we were discussing Contention 39 concerning 14 rumor control, and specifically 39-B, concerning how long it 15 took to respond to questions, and one example you gave was 16 the Arab terrorists and that should have been answered in 17 your opinion immediately.
Why should that have been answered 18 immediately?
19 A
I was -- as I stated, a person calling LILCO to 20 find out whether or not the company had been taken over by an 21 Arab terrorist, I think, would expect that at that level the 22 people handling the emergency ought to know whether that was ACE-FEDERAL REPORTERS, INC.
mume sm_m_.
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the emergency or not because it is a major issue.
The 2
question in the mind of the caller would then be if they 3
don't even know that, what do they know about this?
What is 4
LILCO really trying to do?
5 Q
So are you suggesting that rumor control should be 6
able to respond to certain questions immediately because of 7
the type of questions they are?
8 A
Well, it seems like, yes, that rumor control ought 9
to have some basic descriptive information about the state of 10 the emergency that they could provide to anyone who called p_
e i
~
11 I that would not be contradictory to other information being 12 i
given out.
1 13 Q
And do you think something about an Arab terrorist 14 would be something that would be available?
15 A
I think that the system of information and the 16 training should be such that a question like that -- the 17 person answering those calls would know if that were the 18 case; I would be informed about it, and not have to wonder 19 whether or not that's the case.
As I recall, this was not a I
20 ques tion that was raised at 6:20 in the morning, either.
I 21 can look.
Do you want me to look that up?
1
\\>
22 l
Q Even assuming it were not, even if it were some i
ACE-FEDERAL REPORTERS, INC.
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' M KSW 106 1
later point in the day, are you saying, then, that the person 2
receiving the call about this question about Arab terrorists 3
should make a decision in their own mind --
4 A
No, I'm saying the information system should be 5
such that the person receiving the calls would know whether 6
something that unusual had occurred or not.
7 Q
And at some point they would have to make a 8
judgment whether they should proceed with more information 9
about this question or any other question.
10 MR. MC MURRAY:
Is that a question?
11 MS. LEUGERS:
Yes.
12 THE WITNESS What was the question?
13 BY MS. LEUGERS:
14 Q
Is it your position, then, that the person 15 answering the phones must make their own judgment as to 16 whether they need to go for further information?
17 MR. MC MURRAY:
Objection.
Asked and answered.
18 MS. LEUGERS:
It was the second question, I 19 guess.
Why don't you answer that, and it will lead me into 20 the next.
21 THE WITNESS:
What I said is, the system and 22 training should be such that the person is not left on their i
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own to.make that judgment.
2 BY MS. LEUGERS:
3 Q
Okay, I have one last question.
What information 4
do you think has been gained from the exercise, to support 5
your opinions on the public response to an emergency?
6-MR. MC MURRAY:
I'm going to object to that 7
question.
I think it is over-broad and vague.
We have gone 8
over for 2-1/2 hours all of the reasons supporting the 9
contentions.
Are you asking for other reasons that she might 10 not have already stated or other information that may have 11 been gained?
12 BY MS. LEUGERS:
13 Q
Dr. Saegert, you have testified previously, I 14 guess about two or three years ago, and frora that time --
15 with the information from.this exercise -- what information 16 have you in particular gained from the exercise that you can 17 use?
18 A
Well, LILCO has responded to problems that have 19 been raised in terms of accuracy of information and timing 20 and dissemination that those would not be problems for them.
n\\ l.
l 21 This exercise demonstrates that they will be problems for l
them.
They can be problems for them.
22 ACE-FEDERAL REPORTERS, INC.
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1 Q
Do you see one of the functions of an exercise or 2
a drill is to point out' areas where problems may need to be 3
corrected?
4 A
That's.certainly one of the functions.
Another 5
function is to evaluate whether or not the promises made are 6
promises kept.
7 MS. LEUGERS:
I have no further questions.
hank
?
J 8
you.
9 MR. MC MURRAY:
No questions.
10
-(Whereupon, at 4:50 p.m.,
the deposition was O
11 concluded.)
12 13
_ _ _-- _h_ _
14 SUSAN SAEGERT 15 16 39 o bdON h t
c6btdE00
^/
'g 17 d'
18 l..
s tM omN0gion W wa C
20 21 DONALD AREY
.O Notary Pub:;, State of New Yorf 22 No. 31 4515161 Qualiflad in New York County Commission Expires March 30,19 ACE-FEDERAL REPORTERS, INC.
2tCJ47-DO Nationwide Coserage NXFhud6
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1 CERTIFICATE OF NOTARY PUBLIC & REPORTER 109 I, KATHIE S. WELLER the officer before whom the foregoing deposition was taken, do hereby certify
- that, the witness whose testimony appears in the foregoing deposition-was duly sworn by me; that the testimony of said witness was taken in shorthand f
and thereafter reduced to typewriting by me or under my direction; that said deposition is a true record of the testimony given by said witness; that I am neither counsel
- for, related to, nor employed by ' '
any of the parties to,the action in which this f
deposition was taken;
- and, further, that I am not l
a relative or employee of any attorney or counsel-l o.
i employed by the parties
- hereto, nor financially or otherwise interested in the outcome of this action.
'I i
r) $
1 A
l2h Notarf Public in and for the 1.
District of Columbia My Commission Expires 11/14/89 l
I l
O i
i 0
i s
a
[
exusser l
'/
O January 1986 CURRICULUM VITAE s
Wane Susas Saagert Address:
347 Frasident Street (home)
Brooklyn. New York 11231 3
(business)
Environmental Psychology Program The Graduate School and University Center The City University of New York 33 West 42nd Street New York. New York 10036 Telephone (718) 624-4535, (home)
(212) 790-4551 (business) i i
ranentian O
Ph.D.
1974. University of Michigan Field of Specialisation: Social Psychology Departseat of Psychology 1
3.A.
1968. University of Teams Suana com laude with honors la government 3
i i
i i
Experiamens January 1986 Professor. Environmental Psychology Progran to present The Graduate School and University Center. The City University of New York i
1977 Associate Professor. Environmental Psychology Program.
to present The Graduate School and University Center. The City University of New York Spring Invited Associate Professor of Urban Planning.
1980 school of Architecture and Urban Planaias. Columbia University--REE sponsored course on Housing and Behavior July 1977 to Director. Center for the Study of Womes and Sex Roles.
O January 1980 The Graduate School and University Center. The City University of New York Assistaat Professor. Environmental Psychology Frogram.
September 1973 to 1977 The Graduate School and University Center. The City University of New York
L' 0+v Sasas Saegert f,
w Page ' hse 3
Esparlanca (continued):
Septer.ber Research Coordinator. NDE Grant ($361.312): innsebold 2 1973 to settings: Life styles and. mental health." twironnental i
' June 1977 Psychology Program. The Craduate School and University Center. The City University of New York l
sg Research Supervisor. NIME Grant ($94.558): " Change Feb'ruary~
in ward design." Environmental Psychology Program.
1971 to July 1973 The Craduate School and University Center. The City University of New York
~'
i
\\
A.,meda and Benerarv Amane4mtfana J
Phi Beta Esppa Alpha Lambda Delta Woodrow Wilson Fellow. 1969-1970 l~
National Institute of Mental 3ealth Trainee. 1969-70 O
nationat icience Found tien Fetio.1,70-12 Fellow of the American Psychological Association.
elec.ted 1982 C. Stanley Ea11 Lecturer in Environmental Psychology.
l American Psychological Association. 1985 s.
4 f,uat a and contractat
'1977 National gelence Foundation Trasel Award to NATO Conference on Human Consequences of Crowding. Antalya. ' Turkey.
1977 - 1978,
Faculty Research Award. City University of New York.
I Regional Cooperisons of Experiences of Crowding ($14.479).
1 1977 - 1980 National Institute of Mental Realth. Residential Density and Adjustment in 14w-Income Children ($54.071).
1978 - 1979 Faculty Research Award. City University of New York.
Sex Dif ferences. Spatial Abilities and Environmental Competence ($13.116).
1979 - 1980 Ford Foundation Grant to the Center for the 8tudy of Women and Sex Roles ($24.910).
I i
1980 - 1981 Faculty Research Award. City University of New York.
The Role of the Environment in the Development of 1
Social Relationships ($12.000).
1
e:
I q
O
.n.
8.e.er.
Page Three I
cr..es==i camer ces (continued)3 July 1980 -
Contract with Denver Rousing Authority. Feasibility November 1980 study:
The Market for Downtown Rossing in Denver
($29.000).
January 1981 Contract with Denver Housing Authority. Survey of
-October 1981 of Housing Weeds of Employees in Downtown Denver
($105.000).
January 1981 Carnegie Foundation (with Marilyn Gitte11). Planning
- July 1981 Grant for the Study of Women in Urban Communities (415.000).
September National Science Foundation Travel Award to present 1980 paper at Japanese-United States Seminar Psychology and the Environment in Tokyo. Japan.
i February 1984-The Society for the Psychological Study of Social O
September 1984 Is sue s. Beyond the Bottom Lines An Evanuation of Low Income Tenant Cooperatives in New York City i
($500.00).
l September 1984 National Institute on Aging. Lessons From Older Persons
- July 1985 Saving Abandoned Buildings (414.975).
April bs? -
Department of Rousing Freservation and Development.
December i b Evaluation of Department of Alternative Management l
Frograms for Resale of Tam Arrears Buildings Vested by New York City: Resident Ferceptions (with Jacqueline I
Leavitt) (49.420).
Praf malan.1 letivlelaat Editarial
-Associste fditor. Envf en ne and' tahawlar.
1980 present Manhar.
-American Psychological Association
-Society for the Study of Social Issues
-Environmental Design Research Association ut.ce.d offic.
-Member at Large. Executive Committee. Division 34 Po pu l a t ion and Enviro'naent. American Psychological Association. 1980-1982 O
-Board of Directors. Environmental Design Research Association. 1983 present L
s o
..a..e.e..
Page Four Frafmaalanal Activities (continued):
-President-elect. Division 34. Population and Environment. American Psychological Association.
1985 finivarattet 1980 to present
-Executive Committee. Center for the Study of Women and Sex Roles. The City University of New York Graduate School 1974 to 1977
-Deputy Executive Officer. Department of Psychology.
The Craduate School and University Center. The City University of New York 1976 to present
-Executive Committee Member. The Center for Human Environments. The Graduate School and University Center. The City University of New York O
1977 to 17'
-= e ti e co mittee = ember.1 stit te for Sese ren in Bussa Affairs. The Graduate School and University l
Canter. The City University of New York l
1977 to present
-Review Committee Member. Faculty Research Award Frogram l
Raaka and ilanographa Saegert. 8.
(Ed.).
(1975). crowdine in real envira---men.
Beverly Bills. CA:
Sage Publications (Sag's Social Science Monograph 025: reprinted from Enviran= ant and Behavfar special issue.
1975. 1. Whole No. 2).
Lamont.
R.. Kaplan. F.
& Saegert. S.
(Eds.).
(1980. Spring).
Women in public and private spaces. Special issue of centrapaint.
Other Publientiana and Puh11e Addrenamat 192At Saegert.
S..
& Jellison. J. M.
(1970).
Effects of initial level of response competition and frequency of exposure on liking O
and exploratory behavior. Journal af Permannlite and Racial Psychalage. 31. 553-558. (Also presented at Midwestern Psychological Association Convention. May 1970).
O m
-,r_,_-.._._-
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,_,,,,.m_._.,_,_-
B e
Sussa Seegert Fase Five Other Publientiana and Puh11e Addensana (continued):
11Z18 Rajecki. D. W.
& Saegert. 8.
(1971). Effects of methamphetamine hydrochloride on imprinting in White Leghorn chicks. Pavehana=le Sciance. 21, 7-8.
1221s Seegert. 8-(1973). Crowdingt Behavioral constraints and cognitive overload.
In W. Preiser (Ed.). Envira=antal Damien naamarch.
l Precandines af the EDRA IT canfaranen. Stroudsburg. PA: Dowden.
Butchinson & Ross.
Saegert.
8.. & Rajecki. D. W.
(1973). Effects of prior exposure to animate objects on approach tendency in chicks. nahawineal ninteev. 1. 749-754.
O l
Saegert.
8.. Sway. W.. & Eajone. R.S.
(1973). The effects of mere exposure on interpersonal attraction. Journal af Paraangligg and Enef al Pavehalaew. 21 234-242. Reprinted in T. Blass ('8d.).
canre==crare ane{al newehntanut amermaantative readinaa. Itasca.
ILt Peacocit Publicatioss.1N6.
~
~
~ '
Holshan. C. J.. & Saegert. S.
(1973). The psychological impact l
of planned environmental changel Remodeling a psychiatric ward
(
in an urban hospital.
Jaurnal of Abnormat pawcholanw. 11, 454-462.
1111:
Seegort. S.
(1974. May). The consequences of high density living.
Some unresolved issues and recent evidence. Address given to the M*= York Acade=w of Relenema.
Saegert. S.
(1974).
The ef f ects of social and spatial density on arousal, mood. and social orientation.
Ph.D. Dinaartstian.
University of Michigan.
1311:
1 n l
\\._/
Saegert. S.. Nackintosh.
E.. & West. S.
(1975). Two studies'of crowding in urban public spaces.
Enviran= ant and Bahawine.
I l 159-184.
e w.
v.
y.-r,
.v----
- +- - - ---
=.-=,r-
-wm
=-w- - - - - - - - - - - - - - - - - *. ---------------------i-----------
O Sesaa Seegert Fase Six Other Puh11emelana and Puh11e Addressen (continued)s Baegert. S.
(1975). Stress-inducing and reducing qualities of environments. In I. Prosbansky. W. Ittelson & L. Rivlin (Eds.).
Rawira-anent Payehaf are. 2nd edition. New York: Bolt. Elaehardt
& Winston.
S e eg e r t. S.. & R411. M.
(1975). Effects of reduction of uncertainty on responses to crowding. Presented at Eastern Psychological Conference. New York.
Saegert. S.
(1975. May). Nouse and home in the lives of women.
Presented at Environmental Design Research Association Conference VI. Lawrence. Kansas.
(Reprinted in cantarnainet An Ynear.
DIncin1(nary Jaurnat.)
19218 Saegert. S.
(1976. December). Book review of Crowdine and Enhawler 3 1 a
3
-' fi *<
1 n
2.4.-41.
O 67 Saegert. S.
(Chairperson) (1976.May). Toward better person-environment relations: Changing sex roles and changing environmental needs.
Workshop at Environmental Design Research Association Conference VII. Vancouver. 3. C.
Summtary in Praenadinem af the In I* - a1 Daalen Ramsarch Ammaclacian Canfarenen TII.1976.
1121:
Saegert. $.. & Hart. R.
(1977. Spring). The development of environmental competence in girls and boys.
The Bewa1.tene far the saetae,
far the Raelnew far the Ithanevanhie Send,af Plaw.
(Reprinted in M. Salter (Ed.). P1mwr An anthennainefeat naranseelva. 1978.)
Roberts. C.. & Seegert. S.
(1977. April). Crowding and urban stress.
Fresented at Eastern Psychological Association Meeting.
Juhass. J.. & Saegert. S.
(1977. April). The significance of symbols in the environment. Co-chaired workshop at Environmental Design Research Associat' ion Conference VIII. Summary in the Praemedings af the Environnantal Dealen teamarch Amaneine{an Canfaranen
.Y1 H. Dowden. Hutchinson & Ross. 1977.
Langer.
E., & Saegert..S. (1977). Crowding and cognitive control.
O Janenal af 7.ranna11ew and naetat psychatary 3L 175-182.
I w---.w--,-
,-,-m-,
,.w..,,.w--
mwm r
,,---,,-,,-,,-,mv
t l-
~
O Sassa Seegert Page Seves oeher' Puhtientiana and Puh11e Addreason (continued):
1111:
Saegert. S.
(1978). The personal and social conseguences of high density environments.
In A. Baus & Y. Epstein (Eds.). Innan Rennenaea en cravaine. E111 side. NJ: Erlbaum Associates.
McCarthy.
D.. & Saegert. S.
(1978). Residential density. social overload and social withdrawal.. w-=.n mentaav. 1 (3). 253-271.
(Reprinted in J. Aiello & A. Baum. mieh denalty reaf dentini anvironments. Billside. NJ: Erlbaum Associates. 3979.)
138A Saegert. S.
(1980). A systematic approach to high density settings:
Psychological, social and physical environment factors.
In M. Curkaynak & W. LeCompte (Eds.). Ba==n conaeauences af e,meline.
O New York: Plenum Press.
Saegert. S.
(1980. Summer). Masculine cities and feminine suburbs Polarised ideas. contradictory realities.
Rienst A=
fneerdiscintinarv Journal af va=== and culture. Special Supplement.
Reissued as K. Stimpson. M. Nelson.. & K. Taktrakas. Roman and the Amerienn city. Chicago: University of Chicago Press. 1981.
Saegert.
S.. & Winkel. G.
(1980).
The hone A critical probles for changing sen ro3es. In G. Wakerle. R. Peterson & D. Worley (Eds.). New anseen for women.
Boulder. Colorados Westview Press.
11Als Saegert. S.
(1981).
Crowding and cognitive limits. In J. Earvey (Ed.). cannitian-aneful hahawine and the enviran=ane. Billside.
NJ: Erlbaum Associates.
Saegert. S.
(1981). Residential density and psychological development.
Praesedhem of the Janan-Unlead Renten R = fame on Pavehntaev and the Environment. Tokyo. Japan: Nipon University. National Science Foundation sponsored publication.
O
t O
. g.rt Page Eight Other Fuh11entiana and Public Addrr sama (continued):
1181:
Seegert. S.
(1982).
Environment and children's sental health Residential density and low income children. In A. Baus & J. Singer (Eds.). Emndhank of anychniaev and health
- 1. Ei11 side. NJ:
Erlbaus Associates, pp. 247-271.
Saegert. s.
(1982). Towards an androgenous city.
In G. cappert
& D. Knight (Eds.). cleina of the eventy-f t rae caneurw. Beverly Hills. CA: Sage Publications.
saegert, s.
(1982. October). Eigh density society and individual experiences:
Froblems and resolutions.
I'm Wan and Snaea.
Report of the International Association of Traffic and Safety Sciences Symposium.
IO Leavitt. J.
& Saegert. S.
(1984. Summer). Women and abandoned Raela1 Palfew, buildings: A feminist approach to housing.
pp. 32-39.
i 1181:
Saegert. S.. Liebman. T.. & Melting. A.
(1985). Planning the city for working women: The Denver experience. In E. Birch (Ed.).
The unahnteered va===.
New Brunswick. NJ: Center for Urban Policy Research, tutgers. University. pp.83-100.
Saegert. 8.
(1985). The androgenous city: From critique to practice.
eaelataele=1 Ferna.11 (2). pp.161-176.
(in press). Environmental psychology and social change.
Saegert. S.
In I. Altman & D. Stokols (Eds). Mandhank af Envf ran= ant al Pavehalnew. New Tork: John Wiley.
Saegert. 3.
(in press). Environment as materiale artif act and matrix.
In F. Springer & D. Jodelet (Eds.). Tavard a mae4=1 nawehntan, af the environsane.
Cambridge. Englands Cambridge University Press.
lO l
l i
f.
O sessa Seegert Fage Nine och., PE11emeines and puh11e Addreanas (continued):
1 Saegert. 8.
(in press). The role of housing in the experience of dwelling.
In I. Altman & C. Werner (Eds.).
E==
un.f ra-ne.
Tal. 8 in the marian an=an Behawlar and Envirna-anen. New Yorks Plenum Publishing Corp.
)
Saegert. S.
(in press).
Environmental psychology and the world beyond the aind.
G. Stanley Es11 Lectures for 1985. Washington.
DC: American Psychological Association.
Recent Canauttation Winter Expert witness before the suffolk County Legislature 1982 - 1984 regarding psychological issues in planning for a nuclear
, emergency.
Recent Tavited f.eetures and Conference Partleinstian O
August 1981 Chairperson of symposiva
" Feminist Issues in Urban Communities." presentation with Merilyn Gitte11.
" Women and community organisations.
American Psychological Association Annual Convention. Los I
- Angeles.
November 1981 " Social and Psychological Issues in Housing." Invited address to Program in Environment and Behavior. School of Architecture and Planning. University of Michigan.
January 1982 spects of Housing Desian and Development Affecting
~
Women.
Invited presentation to Seminar on Women and Housing. sponsored by Donna Shalala. President of Euster College and the Ford Foundation.
March 1982
" Women and the City." Keynote speech. Conference on Women and the City. Alverno College. Milwaukee.
April 1982 (with Lynn Faxson). Symposium organizer. New Research and Findings in Housing. Paper presented: Denver's Downtown Workforce and Questions of Urban Housing.
Environmental Design Research Association Conference.
College Park. Maryland.
O
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