ML20234F570
| ML20234F570 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/01/1987 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#387-4025 OL-3, NUDOCS 8707080264 | |
| Download: ML20234F570 (176) | |
Text
.
ORGhu UN11ED STATES O
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO: 50-322-OL-3 LONG ISLAND LIGHTING COMPANY (Emergency Planning)
(Shoreham Nuclear Power Station, Unit 1)
O LOCATION: HAUPPAUGE, NEW YORK PAGES:
17610 - 17784 DATE:
WEDNESDAY JULY 1, 1987 n 0) o\\\\
L g0, te a
ACE-FEDERAL. REPORTERS, INC.
OfficialReporters 444 North Capitol Street 8707000p64 070701 Washington, D.C. 20001 PDR ADOC K 0 50003;!;,
(202) 347 3700 PDR NATIONWIDE COVERACE C
l 51900000 marysimons 17610 i
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5
6
X 7
In the Matter of:
8 LONG ISLAND LIGHTING COMPANY
- Docket No. 50-322-OL-3 9
(Shoreham Nuclear Power Station, 10 Unit 1) 11
X 12 Court of Claims 13 State of New York 14 State Office Building 15 Third Floor Courtroom j
1 I
16 Veterans Memorial Highway
)
l 17 Hauppauge, New York 11788 18 Wednesday, July 1, 1987 19 The hearing in the above-entitled matter 20 reconvened, pursuant to notice, at 9:00 o' clock a.m.
21 BEFORE:
22 MORTON B. MARGULIES, Chairman 23 Atomic Safety and Licensing Board 24 U.
S.
Nuclear Regulatory Commission 25
- Bethesda, Maryland 20555
51900000 17611 nerysimons
()
i JERRY R. KLINE, Member 2
Atomic Safety and Licensing Board 3
U. S. Nuclear Regulatory Commission 4
Bethesda, Maryland 20555 5
FREDERICK J.
SHON, Member 6
Atomic Safety and Licensing Board 7
U. S.
Nuclear Regulatory Commission 8
Bethesda, Maryland 20555 9
APPEARANCES:
io On Behalf of Lona Island Liahtina Company:
11 JAMES N. CHRISTMAN, ESQ.
I 12 MARY JO LEUGERS, ESQ.
13 STEPHEN W. MILLER, ESQ.
14 Hunton & Williams 15 707 East Main Street P. O.
Box 1535 16 17 Richmond, Virginia 23212 is On Behalf of Suffolk County:
19 CHRISTOPER M. McMURRAY, ESQ.
20 DAVID T. CASE, ESQ.
21 RONALD ROSS, ESQ.
22 Kirkpatrick & Lockhart 23 South Lobby, 9th Floor 24 1800 M Street, N. W.
25 Washington, D.
C.
20036-5891 0
I 51900000 17612 merysimons
)
1 On Behalf of the State of New York:
t 2
RICHARD J.
ZAHNLEUTER, ESQUIRE 3
Special Counsel to the Governor I
4 Executive Chamber 5
Room 229 6
State Capitol 7
Albany, New York 12224 8
On Behalf of the NRC:
9 GEORGE E.
JOHNSON, ESQ.
10 RICHARD G.
BACKMANN, ESQ.
11 U.
S.
Nuclear Regulatory Commission 12 7735 Old Georgetown Road 13 Bethesda, Maryland 20814 J
j, 15 16 17 e e e e e e 18 19 20 21 22 23 24 25
l l
l 51900000 17613 I
carysimons 1
C0NTENTS i
Direct Cross Redirect Recross Voir Dire 2
3 (Resumed Panel)
DENNIS MILETI 4
MICHAEL LINDELL J
5 ROGER LINNEMANN 6
DOUGLAS CROCKER 7
DIANE DREIKORN 8
RICHARD WATTS (Cont) 9 DALE DONALDSON 17614 17742 17782 to 11 EXHIBITS Identified Admitted 12 Suffolk County Exhibits 33 No. 10 17615 ja No. 11 17623 17626 15 No. 12 17673 17675 16 17 is LILCO Exhibits No. 2 17752 17756 ig No. 3 17756 17756 20 21 22 Morning Recess.................................
17671 23 Luncheon Recess................................
17722 Afternoon Recess...............................
-17779 24 25 O
I 51900101 17614 suewalsh
)
O i
raOcEsozuoS 2
(9:00 A.M.)
i 3
JUDGE MARGULIES:
elease come to order.
Are the J
d parties ready to proceed?
5 MR. McMURRAY:
Yes, sir.
6 MR. CHRISTMAN:
Yes, sir.
i 7
MR. BACHMANN:
Yes, sir.
8 JUDGE MARGULIES:
You may continue with your
]
9 examination.
10 Whereupon, 11 DENNIS S. MILETI, 12 MICHAEL K. LINDELL, i
13 ROGER E. LINNEMANN, j
O id DOUGLAS M. CROCKER, 15 DIANE R. DREIKORN, 16 DALE E. DONALDSON 17 and j
18 RICHARD J. WATTS 19 resumed as witnesses called by and on behalf of the 20 Applicant, the Long Island Lighting Company, and having been 21 previously sworn, were further examined and testified as 22 follows:
23 CROSS EXAMINATION 24 BY MR. McMURRAY:
(Continuing) 25 Q
Mr. Watts, let me show you a document which I O
i 17615
-51900101 suewalsh I
would like to have marked as Suffolk County Exhibit 10 for l
2 identification.
3 A
(Witness Watts)
Yes.
d MR. McMURRAY:
This is a -- it's the first two 5
pages of OPIP 3.6.1 in the LILCO plan.
i 6
JUDGE MARGULIES:
It will be marked as Exhibit i
7 Number 10 for identification.
8 (The document referred to.is marked as Suffolk County Exhibit Number 10 10 for identification.)
i i
11 BY MR. McMURRAY:
(Continuing) i 12 O
Do you have that in front of you?
1 1
13 A
I have the exhibit in front of me.
I'm e
Id wondering, are you intending to refer to the latest revision 1
15 of that procedure?
16 g
yem actually going to be referring just to Page I7 2 of the exhibit, Page 2 of the OPIP --
18 A
Yes, I understand.
19 Q
-- which is Rev 8.
20 A
Okay.
And, you want to direct your question at 21 Rev 8 --
22 Q
That's right.
23 A
-- not the drafts?
2d Q
That's correct.
Let me just refer your 25 attention for the time being to the second page of the 1
co l
17616 51900101 i
suewalsh l
I) 1 exhibit, which is also the second page of OPIP 3.6.1 of Rev 2
8; isn't that correct?
\\
3 A
Yes.
4 Q
Let me refer you to Section 3.4.
Do you see 5
that?
6 A
Yes, I do.
7 Q
Okay.
Does that accurately reflect the 8
circumstances under which evacuees will be told to report to 9
their designated reception centers?
10 A
If you will give me one moment, I would like to 11 double-check against the February 20th draf t which may have 12 a slight change.
13 Q
Well, the February 20th draf t is Attachment 8.
O 14 A
Yes.
15 (The witness is looking at a document.)
'l 16 I notice there is a slight wording'changd 1
(
17 between the two.
18 Q
Okay.
And, that change is the two words "for 19 monitoring" at the end of the first sentence?,
20 A
Yes.
t 21 Q
Okay.
Was that change just made to clarify why 22 people should be sent to the reception centers?
i 23 A
I believe so.
- f-l 24 O
So, in Attachment P, 3.6.1, Section -- let's 25 see, Page 2 of that OPIP, Section 3.4, accurately reflects t
O l
i x
1-
'l s{
j
17617 l
51900101 suewalsh I
the conditions under which people will be told to report to 2
the reception centers?
3 A
Yes, sir.
Again, I'm sorry, are you referring d
to Rev 8 or the February 20th draft.
5 Q
I'm talking about Attachment P, the draft 6
materials.
7 A
Yes, okay.
Is the exhibit now Attachment P or B
is it Revision 8?
O I'm sorry?
10 A
Is the exhibit that we are referring to now, 11 does the draf t become the exhibit or does Rev 8 become the 12 exhibit?
13 0
I will not be moving the exhibit into evidence.
Id Okay.
Let's go back to the text.
Page 47 of the text, 1
15 please.
~
16 (The witnesses are complying.)
I7 Ms. Dreikorn, let me refer you to Question and 18 Answer 95 where you talk about the type of registration that l'
will be done for evacuees.
There, you state that with I
20 respect to passengers arriving by car the license plates
?!
will be taken down but their names won't be taken down, 22 correct?
23 A
(Witness Dreikorn)
At the initial monitoring 24 station, the traf fic guide will be recording the license 1
25 plate number of the vehicle, the state from which the i
r--
3D i
1
17618 51900101 suewalsh r~)
(_/
1 vehicle is coming, the number of passengers in the car.
2 Q
And, they won't be taking down the names of the 3
passengers, correct?
d A
Not at that location, no.
But, there is 5
additional paper work that is done at the facility to 6
document individuals that are going on for further 7
monitoring.
8 Q
With respect to those who are not going on for 9
further monitoring, the names will not be taken, correct?
10 A
For those individuals arriving in private cars, 11 that is correct.
For individuals arriving on buses, there 12 is a document that is kept that documents each person's name 13 on it.
fmU 14 0
So that names of all evacuees arriving by bus 15 will be recorded whether it's at the initial monitoring 16 stage or the later monitoring stage, correct?
17 A
I would like you to repeat that, please.
1B Q
The names of all evacuees arriving by bus will 19 be recorded, correct?
20 A
That is correct.
21 Q
You state that if it's necessary to contact 22 these people that this method of registration should provide 23 sufficient information.
Do you see that in Question and 24 Answer 967 25 A
Yes, I see that.
O i
17619 51900101 suewalsh d
I lg Q
Now, what's your basis for stating that this 2
should provide sufficient information?
3 A
The information that we would have on d
individuals that arrive in their private vehicles and that
)
I 5
is recorded at the initial monitoring station, being the 6
license plate number and the state from which those people 7
came from, will be sufficient information for us to track 8
the individuals in that vehicle through the Department of Motor Vehicle's assistance in looking up those specific 10 license plate numbers and states if necessary to track them.
11 In addition, we have the record that is kept on 12 the individuals who are sent to decontamination areas for 13 further monitoring.
And, that form documents the J
Id individual's name, address and other pertinent information i
15 so that we could contact those people if it were necessary 16 for medical follow-up purposes.
17 Q
Have you contacted the Department of Motor 18 Vehicles in any state to determine whether or not the l'
information that you seek can be obtained quickly?
20 A
No.
We have not contacted them, but I'm sure 21 they.will be able to contact individuals by their license 22 plate numbers.
23 Q
Do you know how quickly that can be done?
24 A
I Would imagine the system is a Computerized 25 system which should be able to turn around the information R
)
17620 51900101 suewalsh I
that we need in a very rapid fashion, j
1 2
Q These are all assumptions on your part, correct?
3 A
That's true..They are assumptions, but I think d
they are appropriate assumptions.
5 Q
Why is it that you take down infomation about 6
evacuees who arrive at the reception centers?
1 7
A This is our method of registering evacuees that I
8 have come to the reception centers.
9 Q
But, why is that information necessary?
10 A
If it were necessary to track the individuals 11 that have come to the facility, specifically the most 12 important thing would be for medical follow-up purposes.
13 And, as I indicated, in those cases we do have a form that O
14 documents the infomation to contact the individuals if we 15 needed to call them back for situations such as Dr.
16 Linnemann described yesterday, whole body scans or thyroid j
17 uptakes, that type of medical follow-up work.
IB Q
Now, not everyone in a vehicle may be associated 19 with the -- strike that.
20 Not everyone in a vehicle might be a member of 21 the family of the drivers isn't that correct?
22 A
Yeah, I guess that's a possibility, sure.
23 0
Is it possible that you may need to call back 2d people who were not initially found to be contaminated?
)
25 A
I don't believe that, would be a highly likely O
a
51900101 suewalsh I
situation that we would need to call back people once they 2
had been monitored and found to be free of contamination.
3 Q
But, it's possible that you might have to?
d A
Highly improbable, but I guess possible.
5 Q
Mr. Crocker, with respect to the information 6
sheets that are referenced in the Questions and Answers 94 7
and 97, have those information sheets been finalized yet?
8 A
(Witness Crocker)
No, they have not.
O Dr. Mileti, have you reviewed a final version of 10 LILCO's infomation sheets yet?
II A
(Witness Mileti)
No, but I have discussed the 12 concept with them.
13 O
The concept?
Id A
Yes.
15 Q
What do you mean by, you have discussed the 16 concept with them?
That's it a good idea to have 17 infomation sheets?
18 A
Yes, I thought it was a good idea to have l'
information sheets.
And, I was at several conversations l
20 where several of us discussed them and agreed upon putting 21 them together and also addressed the kinds of topics that l
22 they would cover.
23 Q
Do you know whether or not -- strike that.
24 But, there is yet no information sheet that l
25 incorporates the topics that you discussed?
l I
)
17622 51900101 suewalsh O
i i
z don e xnow thee for sure.
I *now that I 2
haven't seen one.
That doesn' t mean that one doesn' t exist.
3 Q
Dr., Lindell, do you have any dif ferent d
information?
5 A
(Witness Lindell)
No.
It's the same 6
information.
I was at some conversations, and I haven't 7
seen a printed version of the information sheet.
8 9
10 11 12 13 0
15 16 17 4
18 19 20 21 22 23 24 25 O
1 I
l
17623 51900202 suewalsh I
Q Let's turn to Page 48 of the testimony.
2 (The witnesses are complying.)
3 At this time, I would like to show you, Mr.
Crocker, actually Ms. Dreikorn, I would like for you to look d
5 at this.
It's a document which I think was introduced at 6
your deposition a few days ago.
7 A
(Witness Dreikorn)
Yes.
8 MR. McMURRAY:
I would like to have this document marked as Suffolk County Exhibit Number 11 for 10 identification.
11 JUDGE MARGULIES:
The one page document entitled 12 "Information Sheet on Reception Centers for Shoreham Nuclear 13 Power Station, Long Island, New York" will be marked as Id requested.
15 (The document referred to is marked 16 as Suffolk County Exhibit Number 17 11 for identification.)
18 BY MR. McMURRAY:
(Continuing) 19 Q
Okay.
As Judge Margulies said, this is a 20 document that is headed "Information Sheet on Reception 21 Centers for Shoreham Nuclear Power Station," correct?
22 A
(Witness Dreikorn)
No, that's not entirely 23 correct.
What the sheet is that we are looking at --
24 Q
That's the title, the title of the document.
25 Ism just trying to identify it.
6 i
17024 51900202 suewalsh O
i A
unaerete=a taet. due it teue de mie1eeaine to 2
assume that this is the information sheet that we would give 3
reception center evacuees.
d Q
I understand that, Ms. Dreikorn.
But, we will 5
get to that.
6 A
Okay.
Fine.
7 Q
The title is what I said it was, correct?
8 A
The title on this page says "Information Sheet 9
on Reception Centers for the Shoreham Nuclear Power 10 Station."
11 Q
And, what is this document?
12 A
This document is a sheet that was prepared for 13 one of our training sessions on June 8th at the Hicksville O
Id reception center.
It was prepared by one of our consultants 15 to simulate what would actually be handed to evacuees when 16 they arrived at the reception center.
17 It's a bare bones outline of the type of 18 information that would be contained on the information sheet 19 that we would give our evacuees for information purposes.
20 Q
Which consultant prepared it?
21 A
A consultant in the LERIO group.
22 Q
Name, please?
l 23 A
Her name is Celia Banthekie (phonetic).
24 Q
Working for whom?
l J
25 A
Working for Long Island Lighting Company.
j O
17625 51900202 suewalsh I
Q She is a consultant, but who is she employed by?
2 A
She is employed by EBASCO.
3 Q
And EBASCO stands for what?
Is that an acronym?
d A
(Witness Crocker)
Let me address that.
That's 5
their formal company name.
I think it stands for Electric 6
Bond and Shareholding Company.
7 Q
Dr. Lindell or Dr. Mileti, either one of you can 8
address this.
Have you seen this document before, Suffolk 9
County Exhibit Number ll?
10 A
(Witness Mileti)
This is the first time I've Il seen it.,
12 (Witness Lindell)
I've not seen it before 13 either.
Id O
Okay.
So, you haven't been consulted on whether 15 or not this contains the type of information that you 16 discussed previously?
17 A
(Witness Mileti)
I don't think I have, but I've 18 talked about generically what I think might be on an l'
information sheet.
I've not talked about this one.
20 MR. McMURRAY:
At this time, I would like to 21 move into evidence Suffolk County Exhibit Number 11, Judge 22 Margulies.
23 JUDGE MARGULIES:
Is there any objection?
24 MR. CHRISTMAN:
Objection as to relevance to any 25 issues in this proceeding.
hy
17626 51900202 suewalsh 1
MR. McMURRAY:
It has been identified as the 2
document that contains at least bare bones infomation of 3
what's going to be handed out to evacuees.
d MR. CHRISTMAN:
I don't think it has been 5
identified that way.
It was a simulated sheet that was used 6
to hand out at the training session 80 that the traffic 7
guides would go through the process of handing a sheet to 8
the passengers in the cars.
9 You haven't established anything about the 10 substance of this.
Indeed, you've established that it's not l'
a prototype of the information sheet.
12 MR. McMURRAY:
It was identified as containing 13 the bare bones information.
I understand it's an outline.
O 14 (The Board members are conferring.)
15 JUDGE MARGULIES:
The objection is overruled.
16 The Suffolk County Exhibit Number 11 for identification is 17 admitted into evidence.
18 (The document previously marked as 19 Suffolk County Exhibit Number 11 20 for identification is admitted 21 into evidence.)
22 BY MR. McMURRAY:
(Continuing) 23 Q
Now, let's go to Page 48, Question and Answer 24 100.
25 (The witnesses are complying.)
O 1
51900202 suewalsh I
Ms. Dreikorn, I guess in the second sentence of 2
that answer -- strike that.
3 The question deals with how quickly monitoring d
personnel can arrive at the reception centers, correct?
5 A
(Witness Dreikorn)
That is correct.
I 6
Q And, you state that the selection of personnel 7
for LERO is in part based on the nearness of their homes to 8
their LERO reporting locations; is that correct?
A That is correct.
10 Q
Okay.
When did the LERO organization begin to II
^
exist as an organization?
s 12 A
I think Mr. Crocker would be able to address 13 that question for me.
O Id Q
Fine.
Mr. Crocker?
15 A
(Witness Crocker)
Although I wasn't involved at J
l 16 the time, to the best of my recollection it was late '82 or 17 early '83.
18 Q
And, at that time LILCO personnel were assigned 19 to -- some LILCO personnel were assigned to the monitoring 20 function; is that correct?
21 A
I have no reason to say otherwise.
I believe 22 so.
23 Q
Some time in the '82/'83 time period?
24 A
Yeah, I would say so.
25 Q
At that time, do you recall what facilities the iO
51900202 I7b2O suewalsh I
Suffolk County plan -- I'm sorry, what facilities the LILCO 2
plan called for as reception centers?
3 A
Let me preface this.
I became actively involved d
in LERO roughly a little over a year ago, so now I'm going 5
back to what I've heard that we did.
This is not direct 6
firsthand knowledge.
7 My understanding though, however, is that we had I
B originally facilities in Suffolk County.
I think one was 9
Suffolk County Community College and a BOCES facility and 10 Stony Brook University.
11 12 13 O
i.
15 16 17 18 19 20 a
a 22 23 24 25 l
O 4
i l
I
51900303 17629 i
joewalsh 1
1 Q
So that the LERO personnel at that time were 2
selected in part because of their closeness to those 3
facilities in Suffolk County, correct?
4 A
(Witness Crocker)
I suspect they probably were, 5
but I don' t have firsthand knowledge of what happened.
6 Q
Has there been a great deal of_ turnover in the 7
LERO monitors since that time?
l e
A We've had some turnover just due to normal staff l
9 changes in LILCO and the normal hiring and firing cycle, j
10 plus to meet shifting manpower needs we sometimes reassign 11 people from one function to another.
12 Plus, we've had a large influx of people into 13 LERO since those days.
14 0
Well, can you tell me in percentage terms, 15 taking into account all of the LERO monitors that there are, 16 how many were chosen for their proximity to the Suffolk 17 County facilities as opposed to how many were chosen for 18 their proximity to the new reception centers?
19 A
I don't have those numbers at my fingertips.
I 20 think the last batch was selected due to their proximity to 21 the N'assau Coliseum which is adjacent to our present i
22 facilities.
)
)
23 O
Ms. Dreikorn, do you have any different i
24 information, what precise percentage?
25 A
(Witness Dreikorn)
No, I do'not have any d
51900303 17630 acewalsh
(])
1 additional information on exact percentages.
But, I am 2
aware that we've had an additional staffing of the radiation 3
monitoring decontamination personnel and traffic guides that 4
would be assigned to the reception centers now designated at 5
LILCO's Hicksville, Bellmore and Roslyn facilities.
6 And, those individuals are being chosen, or 7
their location that they are assigned to is being chosen, 8
dependent upon their proximity to those facilities that they 9
will be assigned to.
10 Q
Can you tell me what percentage of the overall 11 number of monitors this new influx is?
j i
12 A
If you could just wait a few minutes, I will l
13 just check some numbers that I have with me on the staffing
/'N
(/
14 of the Nassau Coliseum versus the staffing of the present is facilities.
16 (Witness Crocker)
We will have to do a 17 calculation to answer your question.
18 MR. McMURRAY:
Rather than waste time and have 19 you do that, I will just go on, Judge Margulies, and come 20 back to this letter unless the Board would like for me to 21 wait..
22 JUDGE MARGULIES:
No.
It won't be necessary to 23 do that.
Can you bring that information up-to-date after 24 the next recess?
25 WITNESS DREIKORN:
Certainly.
I will be happy O
i
_ =.. _.
)
51900303 17631 joewalsh
(
I to.
2 MR. CHRISTMAN:
Just so -- I was going,to say 3
could we -- let's have the precise question restated so that 4
we know what We are going to Calculate, so we don't have to 5
go back and do this again.
Let's make sure our directions 6
are clear.
7 MR. McMURRAY:
Ms. Dreikorn mentioned there is a 8
new influx of personnel dealing with monitoring.
9 BY MR. McMURRAY:
(Continuing)
]
10 Q
Is that correct, Ms. Dreikorn?
11 A
(Witness Dreikorn)
That is correct.
There is a 12 new influx of personnel overall in LERO also.
13 O
And, you have stated that new influx of i
14 personnel was based on their proximity to the Nassau County 15 locations, the reception center locations, in part?
l 16 A
The individuals are being assigned to their j
17 designated locations dependent on their proximity, their 18 home location to the facility.
19 O
Is that the primary factor, or is that just one 20 of many factors?
l 21 A
Yeah.
It's the suitability for the job is one 22 of the primary factors, but certainly proximity to location 23 is taken into consideration on their placement to the 24 location.
25 Q
Okay.
With respect to this new influx that just i
i
51900303 17632 joewalsh
()
I came in, I would like to find out what the percentage is of 2
this new influx of monitors -- solely monitors, not traffic 3
guides -~ as a percentage of the total number of LERO 4
monitors there now are.
i 5
A Yes.
6 MR. McMURRAY:
Is that clear to everyone?
7 JUDGE MARGULIES:
Do you have that, Mr.
8 Christman?
4 MR. CHRISTMAN:
Yes, sir, s
l 10 BY MR. McMURRAY:
(Continuing)
{
11 O
Is that clear?
i 12 A
That's -- okay, fine.
Yes, it is.
l 13 JUDGE MARGULIES:
Is that information you can O
14 develop?
15 WITNESS DREIKORN:
Yes.
It is information we 16 have available.
17 BY MR. McMURRAY:
(Continuing) 18 Q
And, I would also like for you to define the 19 time at which this new influx began so that we can just be j
20 on the same wavelength.
21 Now, you also state, Ms. Dreikorn, that the 22 Nassau Coliseum was fully matined in 90 minutes for the 23 February 13, 1986 exercise.
Do you see that?
24 It goes on to Page 49.
25 A
(Witness Dreikorn)
Yes, I do see that.
O J
17633 51900303 joewalsh 1
Q Okay.
Now, at that time just before the 2
exercise the LERO employees and LERO personnel knew that j
3 there was going to be an exercise on February 13ths isn't d
that correct?
5 A
Yes, they did.
6 Q
Goin to Question and Answer 101, there you u
7 discuss INPO teams arriving at the reception centers.
8 Do you see that?
9 A
Yes, I do.
10 Q
And, you talk about -- that the INPO teams would 11 be directed first to the Roslyn reception center <, correct?
12 A
That is correct.
Roslyn would be the first 13 location that they arrive at.
Since they would be coming c
'L Id most likely west of Roslyn, that would be the first point 15 that they would arrive at.
16 Q
Would that be because they would be travelling 17 on the LIE probably?
18 A
That's one means of travelling to Roslyn.
19 Q
Roslyn is just off the LIE?
20 A
That is correct.
21 Q
Now, you will agree, won't you, that during the 22 afternoon rush hour there is substantial congestion with 23 traffic travelling east on the LIE?
I 24 A
Could you specify a time frame that you are 25 referring to, please?
6 4
17634 51900303 joewalsh
'O o
oo vou have e time treme i=
taa dea ev 2
afternoon rush hour, the p.m. rush hour?
3 A
I guess we can assume you are discussing late 4
afternoon, at the end of a working day?
5 Q
That's correct.
6 A
Okay.
Fine.
7 Q
Do you want me to restate my question?
8 A
Please do.
9 Q
Given that time frame, isn't it true that there lo is substantial congestion on the major roads in Nassau 11 County travelling east?
I 12 A
There is traffic of people going home, yes.
13 O
And, it's substantial congestion, isn't it?
You O
14 are a Long Island resident; you should know that.
15 A
Yes, I am a Long Island resident.
And, I've 16 also been at the Roslyn facility during some training in the 17 late afternoon and getting on the LIE travelling eastbound 18 after those sessions.
19 And, I can't say that I was held up in any J
20 significant delays of getting home after those sessions.
21 And,.we usually end our sessions on the order of 4 or 4:30 22 in the afternoon.
23 Q
Isn't it true that there is significant traffic 24 on the roads travelling east in that time frame?
25 A
As I said, my experience is my own exit of the O
I
I 51900303 17635 joewalsh d
l Q
Roslyn facility after training sessions.
I'm not at that 2
location everyday, so I'm giving you my own experience that 3
I've observed.
d Q
Traffic is heavier at that time than other times 5
of the day travelling east, correct?
6 7
8 10 11 12 13 N
U i,
15 16 17 18 19 20 21 22 23 24 25
- d
51900404 17636 joewalsh
()
1 A
(Witness Dreikorn)
Again, I haven't been at 2
that location at every possible time of the day.
I've been 3
there certainly at various times of the day, and I really 4
haven't had any problems getting out of there.
5 Q
You then say that after arriving at the Roslyn 6
reception center, the INPO teams can be taken or directed to 7
the other two centerst isn't that correct?
8 A
That is correct.
9 Q
Okay.
Do you know of any analyses that have 10 been done of the roadway conditions that would exist during 11 an evacuation calling for monitoring around -- along the 12 roads that you feel the INPO teams would have to travel to 13 the other reception centers?
14 A
The roadway analysis studies that have been done
]
15 have been performed by Mr. Lieberman of KLD Associates.
16 And, possibly you would like to query him on studies that 17 have been done on the traffic in those areas.
18 Q
But, you are sponsoring this question and I just 19 want to know the basis for your knowledge.
Do you -- are 20 you aware of any analyses that have been done to determine 21 whether or'not the INPO teams can travel without undue delay 22 from the Roslyn reception center to the other reception 23 centers?
24 A
I have not been involved in any traffic analysis 25 of those areas, but just based on my general knowledge of O
i
17637 51900404 joewalsh 1
the traffic in those areas and the way that we would be-2 flowing people from the Roslyn f acility eastbound to the 3
Hicksville and possible Bellmore locations I don't think d
they would have any trouble reaching those locations.
5 Q
What's the basis for your answer?
6 A
Because the traffic would be flowing in an 7
eastbound direction and evacuees would be travelling in a I
8 westbound direction.
9 Q
Well, isn't it true that the traffic, after it i
10 leaves the various major arteries -- I'm talking about the il evacuation traffic -- will be travelling sometimes in a 12 northern direction and sometimes in a southern direction and 13 sometimes even in an easterly direction?
D 14 A
I suppose that's possible, yes.
15 Q
And, has anybody done an analysis to determine 16 whether that traffic, that evacuation traffic, or the 17 background traffic in Nassau County might inhibit the i
18 arrivol, or delay the arrival, of the INPO teams?
19 A
I believe Mr. Lieberman has taken into account 20 in his analysis background traffic.
21 Q
That's not my question.
22 A
You asked me if there was any analysis that has 23 been done.
Mr. Lieberman has done the traffic analysis 24 studies for us.
25 Q
Do you know if any deal with the INPO teams and
17638 l
51900404 l
j oewalsh O
i
.whether or not ther wou1d he de1eved?
2 A
The INPO teams delayed upon arrival at the 3
facilities?
l 4
Q Delay --
)
5 A
The Roslyn facility now you are referring to?
l 6
Q Delay from the Roslyn facility to the other two 7
facilities.
If you don't know of any analyses, you can just a
say no.
j 9
A All I'm saying is Mr. Lieberman did all of the I
10 traffic analysis studies that --
11 Q
Do you know of any analyses that have been done q
12 regarding the arrival of the INPO teams at the other two j
i 13 reception centers?
O 14 A
No, I guess not.
15 Q
Thank you.
Let's go to Question and Answer 16 103.
Mr. Crocker, I guess you are the sole sponsor to this i
17 question and answert is that correct?
)
18 A
(Witness Crocker)
Yeah, I have that honor.
19 Q
Now, with respect to the security contingent at 20 the reception centers, there is only one LILCO security 21 guard at Bellmore and Roslyn; is that correct?
22 A
That's our normal day-to-day staffing of 23 security at these facilities.
24 Q
Okay.
And this is the daytime staffing?
25 A
I believe it's also nighttime as well.
O
51900404 j oewalsh I
( )
1 Q
Is that true for Hicksville?
You say there that 2
there are going to be eight ' security guards at Hicksville.
3 Is that just daytime or is that at night, too?
d A
I'm just taking a mental count.
If you will, 5
bear with me for a moment.
6 I suspect Hicksville at night might be down to l
7 four or five.
8 Q
Has LERO given these security guards any 9
training at all?
10 A
No.
LERO -- these guards do not get LERO 11 training.
12 0
Do you know whether these security guards have 13 any training in handling large crowds?
0 NJ Id A
They get their standard security training on 15 handling access to the facility.
16 Q
Does that include crowd control?
17 A
I __
18 Q
Or, does that include checking the passes of 19 people to see if they are really LILCO employees?
20 A
It certainly includes the latter.
As to the 21 former, that is crowd control, I don't know the answer to 22 that directly.
23 Q
Let's go to Question and Answer 104, Mr.
2d Crocker.
25 (The witnesses are complying.)
6
1 17640 51900404 j oewalsh
()
1 Before you do that, let's go back to 103.
You 2
state that the Nassau County police will be requested to 3
assist in maintaining order if necessary.
4 Do you see that?
5 A
Yes, I do.
6 Q
Okay.
Do you have a written agreement with the 7
Nassau County police to that effect?
8 A
No.
But, we have a very good working i
9 relationship with them.
Our corporate securities is in 10 touch with them all the time.
And, we have the same-11 arrangement with Suffolk County, too.
12 Q
But, the answer to my question was no, you don't 13 have a written agreement?
O 14 A
No, we do not have a -- well, not-to my 15 knowledge.
16 Q
Question and Answer 104, there you discuss why 17 you feel the evacuees will not go to reception centers other 18 than the one that they are assigned to, correct?
19 A
Yes.
20 Q
And, you state that the emergency information 21 brochure that is given each household will contain specific 22 directions just to the designated reception center for that
.3 I householdt is that correct?
'24 A
That's right.
25 Q
And that based on that you feel that there is no
)
17041 51900404 j oewalsh bi
',),
I
(
reason to believe that evacuees would have a preference for 2
a facility different from the one that is designated?
3 A
Well, there are a number of reasons in addition d
to that one.
There is the reason we just cited.
There is 5
also the belief that people will tend to go to the same 6
areas as their neighbors.
So, people from Zone K would tend 7
to go to the same place just by staying -- maybe it's an 8
extension of the family unit concept, but there is no reason 9
for them to split up.
10 Q
Any other reasons why these people won't go to a 11 different reception center?
12 A
I -- if I were an evacuee, I wouldn't think of 13 any reason why I would go someplace else than I was told to 14 go to.
I am being sent there for a reason.
The resources 15 must be there.
I would follow the directions.
16 Q
Let's take the situation with the brochure.
You 17 are assuming, aren't you, that at the time of an emergency 18 people will either have or will remember what was stated in 19 the brochure about the reception center they are supposed to 20 go to?
21 A
Well, it's more to it than that.
They, indeed, 22 get this brochure annually which has the requisite maps and 23 directions in it.
In addition, they get the -- oh, we call 24 it the vest-pocket brochure.
And, they get several copies 25 of that.
And, the idea is for them to put it in the glove
!O
j 51900404 17642 joewalsh I( )
I compartments of either one or two, or however many vehicles 2
they happen to own, and that map is in there.
1 3
So, it's -- if they do as we request when they j
4 receive the information, they will put it in the glove box
)
4 5
of their car so that it's readily available.
6 0
Again, my question is, you are assuming that 7
they will have access to these brochures that you are 8
stating?
9 A
By virtue of being in the glove compartment and 10 by virtue of adhering to the directions where we ask them to 1
11 keep this thing, yes.
12 O
You are assuming that people will put the 13 brochures in their glove compartments?
\\J 14 A
I put emergency information in my glove 15 compartment.
16 0
You are assuming that other people will do so as 17 well?
18 A
Reasonable people will, yes, sir.
19 Q
And, all people who don't will be acting 20 unreasonably?
Is that your testimony?
21 A
I think a prudent person would put emergency 22 information, just like they do for storms and floods and 23 school emergencies, in a place where they have it available 24 in an emergency.
25 Q
Do all people act prudently?
51900404 17643 joewalsh r8 1
A I'm sure there are people who do not, but I L,_)
2 think most people do.
3 0
Now, it's possible, is it not, that someone who 4
is assigned to a particular reception center may actually 5
have as their ultimate destination a location that's closer 6
to a different reception center; isn't.that correct?
7 A
Yes,. that's entirely possible.
8 Q
And, isn't that a possible reason for going to a 9
different reception center; that is, the closer proximity of 10 that reception center to their ultimate destination?
11 A
I don't think that factor would change my mind.
12 It might change someone else's.
But, I think overall it 13 would balance out, because the people are pretty evenly 14 distributed in Nassau County.
15 16 17 18 19 20 21 22 23 24 25
m
- (
17644 i
51900505 suewalsh q
i o
^=d, it mer e1 o de ehet eome evecueee miohe O
I 2
feel that they can reach a non-designated reception center-3 more quickly or more easily than one thet has been 4
designated; is that possible?
5 A
(Witness Crocker)
It's posoible.
1 6
Q Let's go to Question and Answer 105.
7 (The witnesses are congplying e
c I
i 8
Again, Mr. Crocker, you spo::sor' that testimoby.
9 so I will direct it to you.
You are talking about the' size i
10 of the property where the reception c:*nters are -located.
\\
n' 11 With respect to the Hicksville facility, you d
12 state that it's 77 acres; is that correct?
13 A
Yes.
O 14 Q
Now, you are not Just talking about'the~ empty 15 space but you are including space with bu:[1 DIS)ps on iti j
16 correct?
._ \\
4
<,i 17 A
My understanding is, from the Real Estate
.': )
{
r y
18 Department, that this is the area within our property line.
i 19 Q
This is the total dimensions of th
- property, i
20 then?
21 A
Yeah.
22 Q
Monitoring is not going to take place on all the 23 property, correct?
j
\\
24 A
Clearly not.
25 0
Do you have any data on what' percent of the O
1
~
\\
1
\\
17845 51900505 suewalsh
-(
l Hicksville property is clear?
When I say clear, I mean not 2
obstructed by a building or equipment, a paved area?
l 3
A No one has ever made that calculation to my d
knowledge.
We didn't need it.
5 Q
Let's go to the Bellmore facilities.
You state 6
that is 10 acres, right?
7 A
Yes.
Bellmore is 10 acres.
8 0
Okay.
And, I assume that the same calculation 9
l that I've just described have not been made as to what is a MP paved or cleared area?
' 11 A
I do not believe so.
12 Q
Okay.
Does the 10 acres include the woods 13 that's to the west of the Bellmore facility?
r Id A
I suspect that a small patch of woods is 15 probably included.
16 Q
Let's go to the Roslyn facility.
You state 17 there that that's 15 acres, correct?
18 A
Roslyn is 15 acres.
\\
i 19 0
Okay.
And, also the same calculations that I've f
20 de. scribed has not been made for the Roslyn facility?
21 A
Again, not to my knowledge.
22 Q
Okay.
Does that 15 acres include the sub-23 station that is located to the east of the facility?
24 A
Yeah, I believe it does.
25 0
Okay.
In Question and Answer 106 you describe h
51900505 17646 suewalsh
()
I whether or not there are certain impediments that might 2
restrict traffic flow at the reception centers.
3 Do you see that?
4 A
Yes, I do.
5 Q
Okay.
You state that there is a curb between 6
the -- at Bellmore, that there is a curb between the 7
customer service window circle of the parking lot which will 8
be removed.
9 Do you see that?
10 A
Yes, I do.
11 Q
Okay.
Now, that curb restricts the flow of-12 traffic attempting to enter the Bellmore facility in which 13 the monitoring is stationed, correct?
14 A
Not anymore.
That has been removed.
I drove 15 through it the other day myself.
16 Q
So, it has been removed now?
17 A
Yes.
18 Q
You say the space in the fence off Sunrise 19 Highway will be expanded at Bellmore.
20 A
Yes, it has been.
21 Q
Could you expand on that?
So, the gate is now 22 how wide?
23 A
Forty feet.
I measured it last week.
2d Q
You say also some debris will be removed.
Has 25 that been removed now from Bellmore?
O
51900505 17647 suewalsh 1
A The -- I wasn't with New York State the day they 2
took the tour of the facility.
I know that there was some 3
debris that was in the area we were going to use and has now d
been relocated to an area we do not use.
5 I suspect that answers your question.
6 O
The debris is located somewhere else on the 10 7
acres?
8 A
It's in a corner that is not part of our plan to 9
use.
It's also a much smaller pile.
10 0
What assurance do you have from the people who il manage the Bellmore facility that the debris will not again 12 appear in the areas intended to be used for monitoring?
13 Have you received any such assurances?
O k~
id A
We've talked to a group in LILCO called Building 15 Operations, Building Ops, and they understand now what areas 16 we need to use.
And, they do keep it clear.
17 If somebody makes a mistake and it's not clear, 18 they can clear it for us very quickly.
We have that 19 arrangement with them.
20 0
Well, my question is, have there been specific 21 instructions given to the managers in Bellmore to keep the 22 monitoring areas clear?
23 A
We have talked to Building Ops at the facilities 24 to keep those things cleared, yes.
Now, you understand that 25 the -- well, it may not be clear at this particular moment H)
(_
17648 51900505 suewalsh
()
1 and we are not using it as a reception center either right 2
now.
3 When we need the reception center, when the LERO 4
plan goes into effect, those things will be kept clear.
5 Q
But, you are saying that now there may be debris 6
in the area that we are discussing?
7 A
When I walked it down the other day, there was 8
not.
9 Q
Are you saying that at the time of an emergency to that the debris will be cleared?
11 A
The intent is not to have any debris in our-way 12 at all.
In the unlikely event, for some strange unforeseen 13 reason something is there it can be cleared very swiftly, 14 because we keep the equipment necessary to move it right 15 there on the property.
I 16 Q
Do you have front loaders there?
j 17 A
It depends on which facility you are talking 18 about.
We generally, as we discussed earlier, we have an 19 array of equipment.
We have got bucket trucks.
By front 20 loader, I'm pot sure what you are referring to.
21 I assume it's the one with the big bucket in the 22 front used to scoop up dirt.
23 Q
Right.
24 A
I've seen them at our facilities.
But, we have 25 the equipment to move all the stuff.
I mean, that's how it
51900505 1764g suewalsh H
I
(_)
got there in the first place.
2 Q
You weren't at the siter is that correct?
3 A
At the time when you-all went?
d Q
That's right.
The site visit, I guess it was in 5
March, when the County and the State visited the various 6
facilities?
7 A
No.
Ms. Dreikorn was.
I was not.
8 Q
Let's go to the Roslyn facility.
Are any 9
physical changes going to be made to the Roslyn facility?
10 A
Well, we've installed the decon trailer.
We've 13 made the requisite, you know, provisions for power and water 12 supply.
Yeah, we've made those physical changes.
13 Q
Have you made any physical changes, for k- #
14 instance, to the size of the gates?
15 A
No.
We didn't do any gate changes at Roslyn.
16 Q
Okay.
Do you intend to do any?
17 A
Right now, I don't believe we see a need to.
IB Q
You don't intend to move any fences?
19 A
No.
20 Q
Let's go to Page 51.
21 (The witnesses are complying.)
22 There, Mr. Crocker, you describe the LERO family 23 relocation center.
24 A
Is this Question 110?
25 Q
That's right.
l l
l I
17650 51900505 suewalsh
()
1 A
I see it.
2 Q
The LERO family relocation center is for what 3
purpose?
4 A
It's a relocation Center for the family members 5
of LERO workers who reside in the plume exposure 10-mile 6
EPZ.
7 Q
You say that there are possibly 100 LERO 8
families that live in the EPZ?
9 A
We say fewer than 100.
10 Q
Where will they be kept at the Hicksville 11 facility?
12 A
They will be kept in one of our office 1
13 buildings.
Hang on a second, and I will find out which one.
(2) 14 (The witnesses, Mr. Crocker and Ms. Dreikorn, 15 are conferring.)
16 Right now, the plan is to relocate them to the --
17 well, I'm sorry.
When they arrive at Hicksville, they go to la the part of the building called our District Office.
19 Q
Do they go through monitoring?
20 A
If necessary, yeah.
They will go right through 21 the same system.
22 O
I don't understand what you mean, if necessary.
23 I mean, are they directed to go through monitoring when they 24 arrive or --
25 A
They go through the same monitoring process that O
17651 51900505 suewalsh I
the evacuees from the EPZ would.
But, at that point when 2
they have exited that process, they would go to the District 3
Office as families of LERO workers.
And, that's where they d
would reside.
5 Q
So, in addition to other evacuees and people 6
needing shelter, also the 100 LERO families in the EPZ would 7
be going to the monitoring stations, correct?-
8 A
Yeah, but they are counted in the population 9
already.
10 Q
Well, I think you stated earlier that not all Il pe9ple in the EPZ will be instructed to go to monitoring, 12 correct?
13 A
That's right.
r 1d Q
So, it's possible that LERO families outside of 15 that particular designated area might nevertheless go 16 through the monitoring stations, correct?
17 (The witnesses, Mr. Crocker and Ms. Dreikorn, 18 are conferring.)
19 A
Forgive me.
The facility can handle -- it's 20 District Office can handle all the members of the fewer than 21 100 LERO families that arrive there.
And, they would be 22 monitored.
1 23 Q
That's not my question.
24 A
Okay.
I 25 Q
Isn't it possible then that LERO families who s
O l
l
1 51900505 17652 suewalsh
()
1 live outside the area that's where people are requested to 2
be monitored fr.om would nevertheless have to go through the 3
monitoring stations because they have left the EPZ and are d
going to the reception centers to be sheltered?
5 A
Yeah.
We cannot tell, as we discussed 6
yesterday, by looking at them where in the EPZ these people 7
came from.
8 Q
Right.
9 A
We monitor them all.
10 Q
Could we go back to Page 47 for a second?
11 (The witnesses are complying.)
12 Question and Answer 94, the last sentence talks 13 about where people who need a place to stay they will be em 14 given a map to a congregate care center.
15 Do you see that?
16 A
Yes, I do.
17 Q
Will these maps be prepared ahead of time?
18 A
Yes, they will.
19 0
Well, at this time how many possible congregate 20 care centers does LILCO believe exist in Nassau County?
21 A
I don't know the total number.
We have our own 22 facilities, of course, plus wherever the Red Cross makes 1
23 available on that particular day.
1 24 O
Well, when you say that the maps will be printed 25 up ahead of time, how far ahead of time are they going to be O
51900505 17653 suewalsh 1
printed up?
2 A
Well, in advance.
The Red Cross has list of I
3 facilities that they can potentially use, and in A
anticipation of using some or all of them we have the maps 5
to a central facility prepared.
6 Q
You say maps to a Central facility?
7 A
Yeah.
You have to understand a little bit on 8
how the Red Cross typically works.
Let's postulate the 9
Crocker School District.
Typically, the way that would work 10 is the Red Cross has an arrangement with the school district 11 to use their facilities during an emergency.
The -- which 12 particular school in that district.
The Crocker School 13 District was the one that has 10 schools.
Which particular i
O l
Id 10 is unclear at any given time, but the central facility, 15 the District Office, or whatever, you do know in advance so 16 you give the people the maps to there and then they would be 17 directed by Red Cross personnel to the local school adjacent j
l 18 to that that they are using for congregate care.
19 Q
And, how many of these central locations are 20 there?
21 A
I don't have that information in front of me.
22 The Red Cross maintains that list.
23 Q
Wili LILCO have maps printed up in advance for 24 routes going to each one of these central locations?
25 A
That's our intention.
Io
1 I
17654 51900505 suewalsh
()
1 Q
But, you don't know how many of those central l
2 locations there are?
3 A
Not offhand.
We would get that information from 4
the Red Cross.
5 Q
Have you gotten that information yet?
6 MR. CHRISTMAN:
Objection.
At this point, I'm 7
going to object.
I believe the questions up to now have a
been legitimately directed toward how you handle the maps 9
and the logistics of that.
10 I think we are now starting to get into the 11 question of the Red Cross and the congregate care centers 12 which the Interveners have been trying to reopen for many 13 years now, and they have recently been denied the right to 14 reopen that by the Commission.
So, I think we are now 15 outside the scope of this proceeding.
16 MR. McMURRAY:
Judge Margulies, I have no 17 intention of getting into the congregate care or Red Cross 18 issue.
I'm just trying to explore whether these maps will, 19 in fact, be available at the time of an emergency.
20 And, the logistics seem difficult in light of 21 the fact that there may be a number of potential congregate 22 care centers but only some may be designated.
Therefore, 23 the question is how LILCO could have all of these maps 24 prepared in advance.
j l
25 So, I just want to know whether they've gotten l
L_________.____._____
51900505 17655 suewalsh
({
l the information yet.
2 JUDGE MARGULIES:
Well, the issue of the 3
congregate care centers is not a matter for review here.
I-d will permit this last question on the subject and won't let 5
you delve further into the matter of the congregate care 6
centers per se.
7 BY MR. McMURRAY:
(Continuing) i 8
Q Do you remember the question?
9 A
(Witness Crocker)
There has been enough 10 discussion that I would appreciate having it repeated.
Il Q
It's true, isn't it, you haven't yet gotten the 12 information from the Red Cross as to the central locations 13 that you state people will be directed to?
14 A
We do not have that yet.
j 15 16 17 18 20 21 1
l 22 l
23 24 25 d
1
17656 51900606 j oewalsh
()
1 Q
Turn to Page 52.
The question and Answer 115, 2
regarding INPO.
Mr. Crocker, I will direct these questions 3
to you.
4 A
(Witness Crocker)
I have got it.
5 Q
You see a passage that sets out Mr. Weismantle's 6
testimony in the 0-5 proceeding, do you see that?
i 7
A Yes, I do.
l 8
Q And roughly paraphrasing, he says that he called 9
INPO, and INPO said that 88 people would be available in 10 approximately six hours, do you see that?
11 A
Well, it is not quite right.
He called the EOF, 12 who in turn called INPO, and put him in touch with -- they 13 put LERO and the INPO organization in touch at that point.
O 14 Q
Mr. Weismantle wasn't in touch with INPO?
15 A
He was subsequently.
His first action was to 16 call the emergency plan advisor No. 1, which is the position 17 I fill in the EOF, and ask them to make arrangements with 18 INPO for this.
19 INPO, in turn, contacted Mr. Weismantle, then j
20 they had a number of discussions.
21 Q
Here it says in the middle of his first answer, 22 it says:
At 1:00 p.m.,
I called INPO and was told that 88 23 people from five utilities would be available in 24 approximately six hours.
25 Is that testimony accurate?
O
)
51900606 Joewalsh 1
A Yeah.
That first phone call to the EOF is 2
described in the first couple of sentences of that passage.
3 Your reading of the middle is accurate.
)
4 Q
The six hour time estimate was, in fact, an 5
estimate given by INPO, correct?
6 A
It was based on their conversations on earlier 7
date, with INPO member utilities, so they are real 8
estimates.
9 Q
You say there were conversations.
Were you 10 involved in INPO's conversations with the utilities?
l II A
No, I was not.
12 O
Was Mr. Weismantle?
13 A
Obviously not.
Dl V
14 Q
Was anybody from LILCO?
15 A
We understand from INPO, that they contacted the 16 member utilities.
17 Q
Was anybody from LILCO involved in the 18 discussions between INPO and the other utilities?
j 19 A
The process doesn't work that way.
g 20 Q
Do you know the basis for the other utilities
)
21 time estimates that they gave to INPO regarding when their 22 personnel would arrive?
23 A
Personnel availability, and distance to their 24 destination.
25 0
Were you told this by INPO, or were you assuming j
i
17658 51900606 joewalsh
()
I that?
2 A
I know how INPO works.
We attend conferences 3
down there, we understand how they do this for us, and they 4
have this emergency resources manual that, among other 5
things, lists travel times to various destinations, they do 6
a very elaborate study every year which they publish and 7
distribute to member utilities.
8 We keep copies of this study in our emergency
?
facilities, and they use that information plus what they get 10 from the member utilities in response to the phone call.
11 Salem nuclear generating etation can have people 12 here in three hours, for example.
13 Q
That is Salem's estimate?
14 A
That is Salem's estimate, and my experience 15 driving that distance.
16 Q
Has Salem personnel, for instance, analyzed 17 whether or not Salem personnel could get here in three 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />?
19 A
Salem personnel have come up to our place 20 frequently to participate as controllers and observers in 21 exercises, and they do it in that time.
22 Q
Have you asked them?
23 A
My counterpart and I down there talk all the 24 time.
25 Q
Do you know whether or not there has been an O
1 1
51900606 17659
{
j oewalsh
)
I analysis done of whether or not the actual people who would 1
2 be monitoring could arrive at the time INPO has estimated?
I 3
Has it been tested?
I 4
A I have the sense that it was tested as part of 5
the St. Lucie field exercise, but I would be hard put to 6
explain why I think that.
7 Q
You are speculating?
8 A
It is not speculation; I think I have heard it.
9 I would have to go back and root around to figure out where 10 I got it from.
Il Q
On Page 53, you discuss getting extra monitors 12 from Brookhaven National Lab in Question and Answer 117.
Do 13 you see that?
Id A
Yes.
15 Q
Brookhaven personnel are expected under the plan 16 to perform offsite environmental monitoring, aren't they?
17 A
Some of them are, yes.
18 Q
Do you know what percentage of the total 19 Brookhaven monitoring contingent would be doing that?
20 A
I can't give you a percentage because I don't 21 know.the actual size of the Brookhaven monitoring 22 c ontingent.
23 I know they have a heck of a lot health physics 24 people.
I don't know the total number.
.25 Q
So you don't know what percentage of those bl
51900606 17660 joewalsh 0
1 people might already be occupied with offsite environmental 2
monitoring?
3 A
(Witness Dreikorn)
I had numerous discussions 4
with Brookhaven Lab personnel in the radiological assistance 5
program, so I might be able to help you out here.
6 Q
Okay.
7 A
Generally during our drills and exercises when 8
Brookhaven personnel participate, what they do is they send I
9 out two field survey teams, and their field survey teams 10 consist of in most cases a health physics technician, and i
11 either a mechanic or driver-type individual, and another 12 health physics technician.
13 So, that would encompass about four individuals 14 and that would be their initial response, to send out two 15 vans with survey teams in them.
16 They could augment those teams later on if it 17 were necessary.
They have a substantial staff of health 18 physics technicians on board and by substantial I mean I
19 something on the order of like 15 to 20 individuals for that 20 support.
21 Q
Have any of those personnel been trained in the 22 LILCO procedures; specifically, the LILCO procedures?
23 A
Yes, they are trained in our monitoring and dose 24 assessment procedures.
They actively participate in our 25 drills and exercises.
O
1 bbI 51900606 joewalsh I
Q I am talking about the monitoring procedures for 2
evacuees?
3 A
These are health physics technicians that are very familiar with the instrumentation that we are using.
d l
5 O
The question is:
Have they been trained in 1
i 6
those specific procedures that LILCO uses in its plan?
7 A
They don't really need it.
They know how to use 8
this instrumentation.
It is instrumentation they use every 9
day at their location in their normal jobs.
10 Q
Are they equipped with the HP-260 probe?
11 A
I don't know specifically it they are equipped 12 with the 260 probe, but there is a probe, the HP-210, which
]
I 13 is the identical probe of the 260, which is a very commonly O
id used frisking probe, and that is certainly.available at 15 Brookhaven, so I am sure they are familiar with their 16 instrumentation as far as the various probes that we use.
17 Q
The 210 probe doesn't have the handle that you 18 said was appropriate to use, correct?
19 A
You are right.
It doesn't have the handle, but 20 it is the exact same probe as far as sensitivity to beta 21 particles and gamma rays.
It has the same window in it.
It 22 is the same surface area of protection, so it is identical 23 as far as its capability to detect radiation.
24 A
(Witness Watts)
I have something to add to 25 that.
I am a cosponsor on the question.
d
I i
I 17662 51900606 j
j oewalsh
()
1 We have gone over to Brookhaven on several 2
occasions and had meetings where we discussed dose 3
assessment, and other related issues.
We have discussed in 4
general terms the method that we are going to be using at 5
the three reception centers with them.
6 We have had a tour -- at least myself had a tour 7
on two occasions of their equipment storage area.
We 8
reviewed the types of instrumentation available.
I don't 9
have the inventory list with me, but among the types of 10 instruments that they have available are the pan cake probe, l
11 something almost identical to the HP-260 probe, if not the l
12 260 probe.
l 13 The same similar design, or possibly the 14 identical design.
They have a wide range of instruments, is and frisking techniques to the Brookhaven people is second l
16 nature.
So, we are quite competent they are capable.
]
17 In addition, it is not only Brookhaven that we l
l 18 are referring to when we talk about DOE.
As we practiced l
19 during the February exercise in 1986, we have one of the RAP l
20 team captains with us in the LERO EOC during an emergency, l
21 and if we decide that we need to muster additional i
22 resources, it is not just from Brookhaven.
l 23 That RAP team captain can send the word out to 24 other DOE facilities or lead monitoring teams in the greater j
25 New York metropolitan area, and in other nearby states, and
J 51900606 17663 Joewalsh
.( )!
I get these people on their way.
2 I don't have the exact number, but I believe we 3
made a request and got back from the RAP team captain that 4
there were about 150 DOE people on their way during that I
5 exercise.
6 I don't know where they were all coming from,
)
7 but we did run that question by them, so it is not just 8
Brookhaven, although they do have a number of qualified 9
people available.
10 Q
Do you know their estimated arrival time?
11 A
I. don't recall it.
I don't have it right in-12 front of me, but they were well aware of the time frame that 13 we had to work with.
Had several of them I know were l
14 available within the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
I don't recall the exact 15 percentage.
16 17 18 19 20 21 j
22 23 24 25 6
4 17b04 51900707 marysimons I
()
1 MR. McMURRAY:
Excuse me a second, Judge.
2 (Pause.)
3 In question and answer 119 in the second 4
sentence you state, Ms. Dreikorn, that anyone else who 5
requested monitoring would be monitored in the backup 1
6 procedure.
Do you see that?
Take your time and read it.
7 (Pause while the witness reviews the referred to 8
reference.)
9 A
(Witness Dreikorn)
Yes, I see the question you 10 are referring to.
11 Q
Is that stated in the plan, that people who 12 requested monitoring would be monitored if they requested 13 it?
14 A
Let me just check the draf t materials before I 15 answer that, please.
16 (Pause while the witness reviews documents.)
17 The answer to your question is yes.
What I'm 18 looking at is Attachment P.
It would be the draft materials 19 of February 20th, draf t materials of OPIP 4.2.3.
20 Q
All right.
j 21 A
I'm on page 7 of 29.
22 O
All right.
23 A
The section I'm referencing is 5.4.7 (d) which 24 states:
"If passengers did not travel together, monitor 25 passengers from other locations."
O
i 51900707 marysimons i
l(])l 1
Q That's not my question.
You also stated that 2
anyone who requested monitoring would be monitored, 3
regardless of whether they came from another location.
{
d A
That is a true statement.
If anyone else would 5
want to be monitored, they would be monitored.
6 Q
That is not stated explicitly in the plan, is I
7 it?
8 A
No, I guess it's not stated explicitly in the 9
plan, but it's something we talk about all the time in our 10 training sessions in training the individuals that certainly 11 they would provide monitoring to additional people that l
l 12 would request the monitoring, 13 Q
Have you done any analyses to determine, or to y,y 14 attempt to determine how many additional people might 15 request monitoring other than those that would be monitored 16 under the procedures set out here?
17 A
No, no analysis has been done on that.
IB Q
Go to the next page.
19 A
(Witness Crocker)
Is that page 54 in the 20 testimony or in the procedures?
21 MR. McMURRAY:
Page 54 in the testimony.
22 BY MR. McMURRAY:
23 Q
Dr. Linnemann, in question and answer 122 you 24 discuss the willingness of experts to volunteer their 25 services.
I I
O i
i 17666 51900707 marysimons
()
1 Do you see that?
2 A
(Witness Linnemann)
Yes, I do.
3 Q
Are you talking about experts other than the 4
INPO personnel and the occasionally DOE personnel that we 5
have already discussed?
6 A
Yes, those and other experts, universities, 1
7 wherever they may be.
)
8 Q-Do you have any estimates on how long it would 9
take those experts to arrive at the reception center?
10 A
I think it's a function of where they are i
11 located.
12 Q
But you can't tell me right now how quickly any 13 of these experts that you're talking about could arrive at 1
14 the reception centers?
15 A
No.
My statement was generic in the sense of 16 experience as well as talking to the people.
The people in 17 the field of radiation where there is an accident would 18 welcome the opportunity to help and they would be there as 19 quickly as possible, or at least that was my experience at 20 Three Mile Island.
It wasn't that we didn't have enough.
21 It was that we didn't have an organization into which we 22 could fit their talents and use them expeditiously.
23 0
Let's go to page 55 of the testimony, question 24 and answer 125.
25 There, Mr. Crocker, you discuss the buildings 1
17667 51900707 marysimons I
where people might be sheltered in bad weather, correct, in 2
the reception centers?
3 A
(Witness Crocker)
Yes.
d Q
one of the buildings that you discuss is the 5
Roslyn Warehouser is that correct?
6 A
Yes, it is.
7 Q
And isn't it true that the floor space in the 8
Bellmore Warehouse is filled shelving containing electrical 9
equipment?
10 A
(Witness Crocker)
I took an unannounced walk 11 through that building.
It was late last week and there are 12 indeed shelves there partitioned by wide aisles.
13 Q
So you would have people standing in the aisles i,,$
'~#
14 between the shelves.
15 A
Or sitting if they prefer.
16 Q
Is there seating in the warehouse?
17 A
It's on the floor.
18 Q
You also discussed the transportation buildings 19 in Hicksville and Bellmore as possible sites for i
20 sheltering.
These transportation buildings also house some 21 heavy equipment, don't they?
l l
22 A
Yes.
We would remove that at the time of the l
23 emergency.
2d Q
Well, there are things like hydraulic lifts that 25 can' t be removed; isn't that correct?
d
_.______________________d
l i
51900707 17668 marysimons
()
1 A
To that extent, yes.
They are just lowered to 2
the floor to give you the usable floor space.
1 3
Q There are things like drums of oil in there?
4 A
There are several drums in there, but no 5
transformers though.
6 Q
Any chemicals?
7 A
I'm sure there is motor oil, there is hydraulic 8
fluid and normal things you would find in a normal garage.
9 Q
And outside the Roslyn facility, if I recall 10 from our site visit, there is a drum of chemicals that-is li labeled dangerous or hazardous; isn't that right?
12 A
It's not outside the transportation facility.
13 It's adjacent to the warehouse at the other end of the O
14 property.
The signs indicates there is mercury and 15 contaminated material.
There is a 55 gallon drum with a 16 plastic liner and a lid.
We looked in that the other day 17 and there was nothing in it.
18 Q
But it is right next to the building where l
19 people are going to be sheltered, right?
20 A
.It's adjacent to the warehouse building, right, 21 but it's not near a -- I'm sorry.
It's near a set of stairs 1
22 that goes into, but it's sealed up tight and is not 23 particularly hazardous.
24 Q
It's only a couple of feet from the stairs that 25 people would take up to the warehouse, correct?
O
17669 51900707 marysimons
(
1 A
It's five or six feet.
2 Q
And it's maybe about 25 or 30 feet from the 3
decon trailert is that correct?
4 A
I would say closer to 60 or 70, but we can check 5
on the drawing if you would like.
6 Q
That's close enough.
7 Does the LILCO plan specifically have any-8 procedures in it which will assure that there isn't heavy 9
equipment in the transportation buildings that could present to some hazard to people who were being sheltered there?
11 A
Transportation has told us when we asked that 12 they will relocate equipment, and there is no specific 13 reference to that in the LERO plan.
W k~
Id O
In question and answer 126 you mention the 15 logistic support group that could call on local suppliers of 16 blankets and have them delivered to the reception centers.
17 Do you see that, Mr. Crocker?
18 A
Yes, I do.
19 Q
The logistics support group would do that at the 20 time of an accident; is that your testimony?
21 A
Yes.
These are people from purchasing that 22 operate from the emergency operations center and, yes, they 23 would do it at the time of the emergency like you do in 24 restoration emergencies and others.
25 Q
Do you have any supply agreements with this b
17670 51900707 marysimons
()
1 organization to supply the blankets?
2 A
I know our purchasing department where these 3
people are from have pre-established blanket purchase 4
orders, and let me clarify that term, okay?
5 It's not a purchase order to blankets, but it's 6
a purchase order that let's you buy anything, blanketing 7
whatever you might want to buy.
8 (Laughter.)
9 I knew as soon as I said it there would be l
l 10 confusion.
But, nevertheless, we have open purchase orders, 11 let's us that term, with a number of vendors for a number of 12 supplies and we use it all the time during restoration 13 emergencies, like Gloria, and we would do the same thing in 14 this case.
15 O
Do you have such a blanket agreement with the 16 blanket supplier?
1 17 (Laughter.)
18 A
I'm sure we have agreements with organizations 19 that among their other products can access blankets.
We 20 probably don't go to a blanket weaver directly.
21 Q
Well, do you know that for sure that there are 22 agreements with suppliers of blankets?
23 A
Our purchasing people are confident they can get
]
24 them through their normal sources.
I haven't seen written 25 agreements to that effect, no.
O l
17671 51900707 marysimons 1
MR. McMURRAY:
Judge Margulies, this is probably 2
a good time for our morning break.
3 JUDGE MARGULIES:
Is there ol;j ection, Mr.
d Christman?
5 MR. CHRISTMAN:
No, none at all.
When we are 6
off the record, I have a couple of pieces of information I 7
would like to give the Board.
i 8
JUDGE MARGULIES:
We will take a 15-minute 9
recess.
10 (Mid-morning recess taken from 10:25 a.m. to 11 10:45 a.m.)
12 JUDGE MARGULIES:
Back on the record.
13 MR. McMURRAY:
Judge Margulies, before I begin, kM 14 I just wanted to inform the Board of something I forget to 15 do this morning.
16 You will recall in the May 24 schedule that was 17 sent to the Board there weren't dates and times for the 18 Suffolk County panels for the schedule to begin I believe 19 July 8th through the 10th.
We told the Board that we would 20 inform the Board and the parties when LILCO counsel and the 21 County had agreed on times.
22 Of course, we are going to throw this out now 23 for the agreement of the other parties and the Board if it's l
24 acceptable.
25 There are going to be three Suffolk County b'
I
\\
I 51900707 marysimons
()
I panels.
The first one is going to be the panel' on 'the 2
planning basis which will appear from July 8th at,9 o'ciock 3
until the next day at lunchtime I guess.
4 The second panel would be the shadow phenomenon l
5 panel which would take the rest of that day, Jcly 9th.
6 Then the third panel dealing with monitoring 7
procedures and other monitoring issues would appear on July i
8 10th.
I j
9 Mr. Christman can correct me if I'm wrong.
l 10 MR. CHRISTMAN:
No, no correction.
11 JUDGE MARGULIES:
Do the parties find that 12 satisfactory?
13 MR. BACHMANN:
Yes, sir.
14 MR. ZAHNLEUTER:
That's acceptable.
15 MR. CHRISTMAN:
Yes.
16 JUDGE MARGULIES:
It is acceptable to the Board.
17 MK. McMURRAY:
Just a clarification.
The 18 planning basis panel would be without Dr. Harris as well as 19 the monitoring panel, and he is scheduled now for July 30th 20 and 31st according to the May 24th schedule.
j 21 JUDGE MARGULIES:
Thank you.
l 22 CROSS-EXAMINATION (Resumed) 23 BY MR. McMURRAY:
24 0
Ques tion 127, Mr. Crocker, just deals with the 1
25 toilet facilities available to evacuees?
()
l l
_-______-___a
519dO707 17673
' I marysimonn
.(
1 A
(Witness Crocker)
Question 127?
1 2
g
'yes.
3 A
Yes, it deals with the toilets.
j d
MR. McMURRAY:
Let me refer you to a document i
5 which is a one-page diagram with the heading down the lower 6
right-hand corner.
It states "Bellmore Operations Center -
7 District. Office Floor Plan, which I would like to have' 8
marked for identification as suffolk County Exhibit No. 12.
9 JUDGE MARGULIES:
It will be so marked for 10 identification.
II (The document referred to was 12 marked Suffolk County Exhibit 13 No.12 for identification.)
Id BY MR. McMURRAY:
15 Q
Do you have that document in front of you, Mr.
16 Crocker?
17 A
(Witness Crocker)
Yes.
This is No. 12?
18 Q
That's right.
19 Have you seen this document before?
20 A
Yes, I believe I have.
)
21
.Q There is some information written on the left-22 hand side regarding restroom facilities not shown on the i
23 diagram, correct?
i 2d A
Yes.
i 25 Q
Taking that information into account and taking
- d
1 17b74 51900707
()
I the information on the diagram into account, does this 2
document accurately reflect the restroom facilities. that are 3
available at the Bellmore Operations Center?
d A
Hang on a minute, I'm just going to check 5
something.
6 MR. McMURRAY:
Sure.
7 (Pause while the witness reviews his documents.)
8 WITNESS CROCKER:
Yes, I believe it does.
9 BY MR. McMURRAY:
10 Q
Also in that response you discuss the 11 possibility of getting portable toilets from vendors.
As 12 with the blankets, do you have any agreements regarding 13 getting the portable toilets during an emergency, any O
14 written agreements?
15 A
(Witness Crocker)
Because of the nature of our l
16 work, we use portable toilets at many of our construction l
l 17 sites.
Shoreham at one time was littered with them.
We l
18 have agreements where we can get these.
It's a standard l
19 course of business for us.
20 Q.
Well, do you know whether or not they can be 1
21 provided in quantity?
22 A
I believe they can.
I would be hard pressed to i
23 give you an upper bound.
These toilets are used in the very 2d vigorous construction industry that we have locally.
So 1
25 there should be a fair number out there.
O
3 17675 51900707 marysimons
(
1 Q
Well, but do you know whether they can be 2
provided in the event of a Shoreham emergency and that they
)
3 wouldn' t be out, for instance, on some construction sites?
4 A
I'm sure we can get some.
I haven't checked to 5
see how many.
6 MR. McMURRAY:
Judge Margulies, that concludes 7
my cross-examination on the monitoring issues.
Mr. Case 8
will continue the cross on the contamination section.
9 I would like to move for the admission into 10 evidence of Suffolk County Exhibit No.12.
11 JUDGE MARGULIES:
Any objection?
12 MR. ZAENLEUTER:
No obj ection.
13 MR. CHRISTMAN:
No objection.
,Q 14 MR. BACHMANN:
No obf.ection.
15 JUDGE MARGULIES:
It is admitted as Suffolk 16 County Exhibit No. 12.
17 (Suffolk County Exhibit No. 12, 18 previously marked for identifi-19 cation, was received into 20 evidence. )
21 BY MR. CASE:
22 Q
Mr. Crocker, if you would turn to page 4 of the 23 testimony.
2d A
(Witness Crocker)
Page 4?
25 0
Yes.
r
i 51900707 17678 j
marysimons.
()
1 A
I have it.
2 Q
You indicate on page 4 of your testimony that 3
neither NUREG 0654 nor any FEMA guidance memorandum provides 4
any indication on how many evacuees may need 5
decontamination.
Do you see that portion of your testimony?
6 A
Yes, I see it.
7 Q
Have you reviewed any NRC Licensing Board or s
Appeal Board decisions to see if they provide guidance on 9
decontamination?
10 A
I have reviewed the ones in the LILCO 11 proceeding.
I cannot say that I've reviewed those of other 12 proceedings.
13 Q
You have reviewed the LILCO proceeding 14 decisions?
15 A
Yes.
I've read most of them at some time _or 16 another when I got involved.
17 Q
Are you familiar with the passage and decision 18 of the Appeal Board in ALAB 855 of December 12th, 1986 where 19 it states "This being so, it seems beyond serious dispute 20 that monitoring and decontamination services must be 21 regarded as within the range of protective actions that 10 22 CFR 50.47 (b) (10) requires be developed for all members of 23 the public within the EPZ"?
24 A
Can I see the document, please?
25 MR. CHRISTMAN:
I object to cross-examination on O
17b77 51900707 marysimons
]
(
l the text of an Appeal Board decision.
I see no point or 2
purpose in that.
3 MR. CASE:
The question was, Judge Margulies, d
was he familiar with that decision.
He indicated he had 5
reviewed the LILCO decisions and the question is is he 6
familiar with that decision.
I'm not asking for a legal 7
opinion.
8 MR. CHRISTMAN:
And assuming he is or isn't 9
familiar with it, I fail to see how that will help to 10 advance this Board's inquiry, 13 MR. CASE:
Judge Margulies, Mr. Crocker is an l
12 emergency planner.
Certainly any decisions that indicate 13 the range of decontamination services that must be available t
14 would be relevant to his job.
15 (Board conferring.)
16 JUDGE MARGULIES:
The Board will permit the 17 question.
18 WITNESS CROCKER:
May I see the document, 19 please?
20 but. CASE:
Sure.
y 21 WITNESS CROCKER:
Before you come over here, do 22 you have a copy of 10 CFR with you, too?
23 (Counsel Case places the documents before 24 Witness Crocker.)
25 BY MR. CASE:
i 17678 51900707 marysimons 1
Q If you would turn to page 17 of the decision,
(])
2 Mr. Crocker.
3 A
(Witness Crocker)
Page 177 4
Q Well, let me start up front.
Have you seen this 5
decision?
6 A
Yes, I believe I have.
7 Q
If you would just turn to page 17 of the e
decision, the top paragraph, and really the only full 9
sentence in the top paragraph.
10 A
The pcragraph that begins on the proceeding 11 page?
f' 12 O
Yes.
The sentence begins "This being so bn 13 page 17.
4 O
i 14 A
Hang on a moment.
I would like to read it.
15 (Pause while the witness reviews the document
)
16 being referenced.)
17 I have read it.
1B Q
Are you familiar with that passage?
19 a
I have read it.
20 Q
Prior to today were you familiar with it?
21 A
I read the document and I assume.I read this 22 paragraph.
23 Q
Now, Mr. Crocker, on page 5 of your testimony, 24 the first sentence there indicates "If contamination is 25 found on evacuees, it is likely to be easily removable due
()
17679 51900707 marysimons 1
to the dust-like nature of the particles and decontamination 2
should be simply a matter of removing outer layers of 3
clothing and/or washing exposed skin surfaces."
d That sentence does not refer to thyroid 5
contamination, does it?
6 A
No, it does not.
It refers to the skin or 7
surface contamination.
B Q
Dr. Linnemann, what is the treatment for thyroid 9
contamination?
10 A
(Witness Linnemann)
11 Q
And at certain levels of thyroid contamination 12 treatment is to be done as soon as possible; is that 13 correct?
14 A
That is correct.
15 Q
Now, Mr. Watts, if you could turn to page 56 of
]
16 the testimony.
17 Mr. Watts, in your response to question No. 131 18 you have a general discussion of how long it would take to 19 decontaminate people; is that correct?
j 20 A
(Witness Watts)
We provided a number of 15 21 minutes for a complete shower.
22 Q
Prior to providing that number in response to 23 No. 131 you identify some variables on the number of people 2d who can be decontaminated; is that correct?
25 A
I mentioned in the response'to that the number
1 I
17680 51900707 marysimons
(])
1 of people who could be decontaminated depends on the level 2
and nature of the decontmnination and how it long it takes 3
individual people to shower or wash the contaminated 4
portions.
5 0
The first variable on the number of people who 6
can bn decontaminated you identify as the level and nature 7
of decontamination?
Should that be level and nature of 8
contamination, or level and nature of decontamination?
9 A
Well, as I read it, it's in reference really to 10 the extent to which decontamination and the type of Il decontamination that is necessary.
We may not need to 12 shower.
In fact, I would expect that we would probably not 13 need to shower the major of people.
14 O
The level of decontamination depends upon what i
15 variables?
16 A
The level of decontamination?
17 Q
Yes.
18 A
One that I can think of is the extent of 19 contamination on the body, the amount of exposed skin area 20 that has been contaminated.
]
21 Q
So, in other words, the more surface area of the 22 body that is exposed, it may require a different sort of I
23 decontamination effort than if only the clothing contained 24 contaminated particles; is that correct?
25 A
Yes, that's possible, or it may be that other O
17681 51900707 marysimons i
I portions of the body may have minor contamination that still 2
can be readily removed by washing in a sink.
3 4
5 6
7 8
9 10 11 12 13 k
14 15 16 17 l
18 19 20 21 22 23 24 25 6
1
i 17002 51900808 suewalsh
]
1 Q
Now, what is the basis for that estimate?
2 A
(Witness Watts)
A number of us who have been 3
involved -- in fact, a number of us on this panel who have 4
been involved, have experience in decontamination and gave 5
it some thought and arrived at a consensus of about 15 6
minutes which we felt was probably a conservative estimate 7
of how long it would take to cycle people through a shower.
8 I should probably clarify we don't expect a 9
person would be standing in a shower for 15 minutes.
We recognize there are other activities associated with that[,.
10 where you monitor the person and assist them in the agower.
11 12 and monitor them atterwards.
4 13 0
So, what does this 15 minutes include?
Does 14 this include standing in the shower for 15 minutes?
15 A
No.
As I just mentioned, it does not only 16 include that.
We recognize there are other activities 17 associated with handling someone who requires a shower.
IB Q
So, that 15 minute estimate includes these other 19 activities?
20 A7.( Yes.
And, again I've worked in a nuclear power
- 3 yp,..
.,y-21 pl~ ant"beforer I've supervised decontamination efforts of 22 people who have needed showers and people who have not 23 needed showers.
24 But, it appeared that 15 minutes was probably a 1
25 good estimate for handling someone who may need one or more O
l L__-_-----------------------
1 i
17683 51900808 suewalsh I
cycles in the shower.
You may not catch all of the 2
contamination if showering is needed the first time.
You 3
probably handle the majority of it.
d But, afterwards we will re-check the person who 5
is contaminated, we may ask them to go back and take another 6
shower.
But, I would expect that that process on the 7
average would be activities of checking the person af ter 8
they come out and would probably entail about 15 minutes.
9 Q
In your experience -- I will give you a chance V
10 at the same questions, Dr. Mileti.
I know you sponsored l
11 this testimony.
$ ?:
. - g.w ):.
12 In your experience, Mr. Watts, how many tim 6i'- @
.A
~
'^"
13 has a -- someone needed decontamination by shower?
~J Id A
In my experience?
I don't remember the exact 15 number.
I have seen several situations where contamination 16 has been reported on people who have been frisking out at 17 the controlled area of a nuclear power plant.
18 I don't remember the exact number of times that 19 showers were needed, but it's a relatively small fraction of 20 W..the. H=am. tehore some form of decon was needed.
g p T**.%.;. 7 gl 21 F;,gfe jon Page 57 of your testimony, you reference the.
22 ac'cJdent at Ginna where out of 11 people only one needed a 23 shower.
Do you have any other examples of decontamination 2d by showering other than that one?
25 A
Well, as I've just mentioned, it's part of the l
If>
V
i 17684 51900808 suewalsh
()
I routine monitoring of workers coming out of the controlled 2
area of a nuclear plant.
Having supervised several shifts 3
in my career, my recollection was, and my general impression 4
was, that there were -- of the several instances that I knew 5
of requiring decontamination, there was a small percentage 1
6 of those instances that required showering.
I don't 7
remember the exact number.
8 In putting together the answer to this question, 9
however, I wanted to cite at least one example I was 10 directly associated with, that was what happened at'the 11 Ginna accident.
I went back to the records and look,ed at 12 that, and that percentage of the number of people who needed 13 showering pretty well matched my overall experience in 14 working as a routine power plant health physicist.
15 Q
How long did it take to decontaminate that one 16 individual at Ginna who required showering?
17 A
Let me just refresh my memory.
18 (The witness is looking through a docsient.)
19 The one individual who we showered had 20 contaminst4sst that was limited to the top of his head.
We 21 figured we,would just let him use some shampoo and take a N;,
22 shower.
Il don'trecallthatitwasanunduelengthoftime.
23 It may very well have been around 15 minutes.
I j
24 don' t remenber exactly.
25 We found that after we had h'im shower, he had O
l 17685 51900808 suewalsh I
only one very barely detectable spot remaining, and we 2
determined that he could be released.
3 Q
So, this one individual at Ginna had d
contamination simply on the top of his head?
5 A
Yes, others had contamination on their clothing, 1
6 on their shoes.
4 7
Q Okay.
And, he was directed to shower and 8
shampoo as part of the decontamination process?
9 A
Right.
10 0
You don't recall specifically how-long that took 11 right now?
-7 12 A
My general impression is that it was a fairly 13 short time.
It was a routine shower that you and I are both O
1d familiar with.
15 0
Was he a -- he was obviously a worker at the i
16 plant?
17 A
Yes, he was.
IB Q
An experienced worker, do you recall?
19 A
Hhat do you mean by experienced?
20 g,gy,A long period of time at the plant, if you am a
21 recall?
. 'i 22 A
I don't think so.
It's my recollection that he 23 was a relatively young maintenance person.
He was a 2d relatively young maintenance worker.
He was, I assume, i
25 quite experienced at taking showers.
i
)
f I
17bbb 51900808 suewalsh O
1 o
I esseme eo-or tinnemenn, vou identtrv 60 2
cases in'your experience where there was treatment by.
3
-hospital personnel.
In general, what did those 60 cases 4
involve?'
5 Were they accidents at plants or what?
6 A
(Witness Linnemann)
Yes.
Those were 7
contaminated injured and/or ill people that were taken from 8
a nuclear power plant to a local hospital; and, of course, 9
they were taken to the emergency room because of their-10 injury or their serious illness.
11 And, in these cases what you find is that they 12 have contamination on the clothing and they will have 13 contamination on their face or hands or any open skint or, O
14 if there is a torn piece of clothing and a wound you will 15 find the contamination there.
And, in those kinds of cases 16 when you remove the clothes,_you are left with the 17 contamination really that's on open skin.
18 There was only one case in which a person 19 required a total bath.
And, that case I happened to have 20 been on site when the accident occurred.
It was an 21
' explosion which drove the particles of radioactive particles 22 through the clothing, abraded the skin as part of this 23 explosion thing, and that patient required a total bath.
24 I think it needs to be emphasized in not only 25 this experience but in the experience that I've had with O
I 1
j 17687 51900808' suewalsh I
contaminated environments that it is rare, very infrequent, l
that if you have clothes on you get contamination under the 2
J 3
clothes.
There has to be a reason, as an explosion.
d It's just very. hard to imagine atmospheres in 5
air.
And, I've seen them where the building, the room was 6
contaminated, the floor, the equipment, the people were on 7
exposed parts but not under their clothing.
These were 8
accidents, for example, that occurred in a cobalt radium 9
facility where loose, dry bags of contamination -- somebody
~
10 broke open a bag and this stuff went all over the room.
11 Really, I would expect -- and, I can't emphasize 12 it more than you would have very few people who would 13 require a shower if they have clothes on.
And, I -- even in Q
id this one that I handled -- and that was the highest. level of' i
15 contamination, and we were working in a field of 40 MR per 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.
That's about 120,000 counts per minute where this 17 accident occurred and rescuing this person, and my clothes 18 were contaminated but I didn' t have to take a shower when I 19 finished with this.
20 Q
Now, obviously clothing will not protect your 21 face and hands?
22 A
No.
23 Q
And, obviously to the extent you are wearing 24 shirt sleeves or shorts, any exposed part of the body that's 25 contaminated would require decontamination by washing; is o
1 51900808 suewalsh I
that correct?
)
()
2 A
Right.
And, I think that's the other emphasis 3
to be made, that again usually, whatever, the highest 4
percentage of cases one just -- just plain soap and water 5
one time will remove this contamination.
6 Very rarely do you have to do it more than once, j
7 and that's usually in cases where people have kind of ground 8
particles into their -- working with it into -- you know, a 9
working man's hand where you would fissuring and that may 10 require two or three washings.
I il O
Now, Dr. Linnemann, these 60 cases you've worked 12 on, did they include any members of the gene al public that 13 you can recall?
)
14 A
No.
These were employees in plants who for some is reason had an accident in a contaminated area.
16 Q
And, the one individual who did require a bath, 17 you indicated bath.
Obviously, you didn't shower this 18 individual to be decontaminated?
19 A
No.
Remember this is a totally different 20 procedure.
You have an emergency room, and what we have 21 there is a designed tub where you bathe them and collect the 22 water so that he essentially got a total bath.
23 Q
How long, when you have an individual with that 24 level of contamination on his skin, does it require to bathe 25 him?
d
y 17689 51900808 suewalsh
(
1 A
In this case, it took us dbout as I recall five l
2 or six washings.
But, you have to remember, this is a 3
person who is injured.
He had abrasions from this 4
explosion, also abraded his skin and drove the radioactive 5
particles under the skin and in this abraded skin, inj ured 6
skin.
7 So, the time was not really a function of how 8
long it takes to bathe him.
The time was a function of 9
medical care in addition to washing him.
10 0
And, how long did it take to decontaminate him 11 through this bath?
12 A
Well, the decontamination procedures, that part 13 of it was usually a washing for two or three minutes and we 0
14 would wipe him down and then measure and then wash him again 15 for two or three minutes, wipe him down and measure.
16 But, the rest of the time was occupied in just 17 the medical care of the patient.
1B Q
In your experience, Dr. Linnemann, the 60 19 minutes or -- excuse me, the 60 patients you are familiar 20 with, did anyone request decontamination by showering even 21 though removing clothes might have been sufficient?
22 A
No, no.
Usually -- remember, they are brought i
l 23 in injured and they were treated in the emergency room, and 24 wherever we found contamination we noted it and cleaned it 25 up.
17690 51900808 suewalsh
(])
1 Q
Dr. Linnemann, are you familiar with any studies 2
on how many people will require a shower in the event of a 3
nuclear plant accident?
4 A
I don't think -- the answer is no.
5 0
Are you familiar with any studies concerning the 6
number of people who would require showering in the event of 7
an accident at the Shoreham plant?
8 A
Studies per se, no.
I think, if I might add 9
just a point, it's a pretty good evaluation by many people 10 familiar with contamination that what I said, that few of us 11 expect that very few people would require total showering.
12 And, that's not by study; it's just by experience dealing 13 with contaminated environments.
O l
14 Q
And, when you say require total showering, you 15 mean requires -- it's a medical judgment on your part or 16 whoever is there to decontaminate?
17 A
I'm sorry.
18 Q
Let's back up.
When you indicate a small 19 percentage would require decontamination by showering, you 20 are examining it as a doctor from an objective point of view 21 given the readings that would be available, let's say, after 22 they removed his clott.Ang and he washed his hands.
23 A
Well, t'.lere's two parts.
The first is just 24 experience of havin,t dealt with people in contaminated 25 environments where they were located in air contamination O
I 17691 51900808 suewalsh r~h i
and finding that they weren't contaminated under the
&_j 2
clothing; therefore, it didn't require a total shower.
3 That's what I base my opinion on, and I think d
many people who have dealt with this felt the same thing.
5 That's --
6 Q
Okay.
I understand.
7 A
-- why we all say, I don't think we are going to 8
require showers.
9 Now, the second part of your question as I 10 understand was, how would you determine if they needed a 11 shower, a total shower?
12 O
No.
It was actually the same part of -- the 13 same question.
You answered the question.
Okay.
Id Mr. Watts, if you would turn to Question 139, 15 the second sentence in your response there, "In the unlikely 16 event that this situation should happen, LERO would attempt 17 to handle the affected population at the three reception 18 centers."
19 What do you mean by "to handle?"
Does that 4
20 include decontamination and monitoring or simply 21 decontamination?
j 22 A
(Witness Watts)
I think the answer to the l
23 question was directed at decontamination.
However, I think 3
l 24 the philosophy in our planning is to address both, l
25 Q
Okay.
So, what does it mean in response to this i
I 51900808 suewalsh
()
1 question?
Does it mean decontamination and monitoring, or 2
decontamination?
1 i
3 A
I think in reference to this question, since 1
4 this is under the section of our testimony labeled 5
" Decontamination" it has to do with decontamination.
It i
6 doesn't preclude that we would not make every attempt to I
7 handle POOple in terms of monitoring.
8 Q
I understand that.
9 A
- Okay, f
1 10 Q
But, the question specifically addresses J
11 decontamination.
And, "to handle" means decontaminate?
j 12 A
Yes.
13 0
Okay.
The last sentence there indicates, "This O
14 would be adequate if only a limited portion of the EPZ were J
15 contaminated."
16 Does "this" mean decontamination?
t 17 A
Yes.
1 18 Q
So, in other words, we can read this sentence to 19 mean decontamination would be adequate if only a limited 20 portion of the EPZ were contaminated?
1 1
21 22 23 24 25
51900909 17693 joewalsh
()
1 A
Yes, given the resources that LERO itself has, 2
we have provided to go beyond LERO resources, however, in 3
our plan.
d Q
I understand, but the sentence can be read, or 5
should be read when we substitute a proper noun, or a noun 6
for the pronoun, decontamination would be adequate if only a l
7 limited portion of the EPZ were contaminated, is that 8
correct?
9 A
In reference to LERO resources.
]
10 Q
And limited portion, you quantified that at all?
j i
II A
I can give you one answer.
Perhaps Mrs.
12 Dreikorn or Mr. Crocker would like to add to it.
But if we 13 were to assume 15 minutes per person, my estimate is over --
)
id for instance, if you accept a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period, you could 15 handle something on the order of 3,800 people at the 16 trailers.
17 If we had to shower 3,800 people, we estimate 15 18 minutes of cycling each person through, we can handle about 19 3,000.
20 Q
Which is two percent of the EPZ?
21 A
Excuse me?
22 Q
Is that two percent of the EPZ population?
23 A
I haven't done the arithmetic on that.
24 Q
In the event of an accident at Shoreham, in a'12 25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> period could 8,000 people be handled in a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> O
_ _ ___ ________________ _ _ _ _ _ w
17694 51900909 j oewalsh I
period, decontamination by showering?
2 A
Could I have the question again?
3 0
Okay.
In a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period, in the event of an d
accident at Shoreham, could-8,000 people be decontaminated 5
by showering in a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />' period?
6 MR. CHRISTMAN:
Objection.
The question may be 7
unclear without specification of details.
Are we talking 8
about -- are we asking about a single shower, one' time 9
through, how many people can take showers at 15 minutes per.
10 WITNESS WATTS:
I mentioned 3,800 and you came Il back with 8,000.
12 MR. CHRISTMAN:
That is my second objection.
I3 JUDGE MARGULIES:
Just one minute.
One at a 14 time.
15
.MR. CHRISTMAN:
My second obj ection was asked I
16 and answered if all we are doing is asking the same question 17 we just had.
18 MR. CASE:
Judge Margulies, I came back with 19 8,000 as a hypothetical number, a little over double the 20 figure that Mr. Watts had provided, merely to test if 21 decontamination could be done in 15 minute showers over a 12 22 hour2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> period.
23 MR.'CHRISTMAN:
But if the assumptions under the 24 8,000 question are the same as the assumptions that are 25 listed of the number 3,800, then the question has been asked j
l IO 1
-]
51900909 17695 joewalsh
()
I and answered.
2 MR. CASE:
Let's keep the assumptions the same, 3
the question hasn't been asked and answered.
Mr. Watts 4
indicated that they could handle 32 under those set of I
5 assumptions.
The question is now can they handle 8,000 6
under those set of assumptions?
7 WITNESS WATTS:
No, I think you --
8 JUDGE MARGULIES:
Just one minute.
9 (Board confers.)
10 JUDGE MARGULIES:
This is cross examination, and 31 I will permit counsel to press the matter on the different 12 number.
13 BY MR. CASE:
(Continuing)
O 14 Q
The same set of assumptions you gave me, your 15 3,200 --
16 A
(Witness Watts)
I did not say 3,200.
17 Q
Three thousand -- what was your number?
18 A
It was 3,800.
19 0
Under the same set of assumptions, in a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 20 period, can 8,000 people be decontaminated by the showering i
21 method?
22 A
By whom?
23 Q
By LERO.
Under LERO resources.
24 A
Given the same assumptions that I referred to j
25 before?
j O
1
L-17696 51900909 joewalsh I
I Q
Yes.
2 A
Using only LERO resources?
3 Q
Yes.
d A
Over a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period, the answer is, no.
5 Q
Now, Mr. Crocker, Page 140 -- excuse me --
6 Question 140, you reference a draft chepter of an EPA manual 7
dated June 27, 1986.
Do you see that reference?
8 A
(Witness Crocker)
Yes, I do.
Q Do you know if that draft manual has been 10 adopted as a final document by the EPA?
A To the best of my knowledge it has not.
12 Q
Do you know if it has been adopted as a final 13 document by the NRC?
r Id A
I don't know for sure.
I believe it is still a 15 draft.
1 16 Q
And it hasn' t been adopted, to your knowledge, 17 as a final document by FEMA?
18 A
Not to my knowledge.
19 A
(Witness Dreikorn)
I would like to add to i
20
.that.
That EPA draft materials has been utilized in an EPA 21 table top that was conducted on relocation soon after the 22 draft came out, so they are teaching by that draft document 23 at this point, although it is still in draft format.
24 Q
I understand.
Mrs. Dreikorn, one question to 25 you.
When people evacuate the EPZ, are they directed to
- d
1 176g7 51900909 joewalsh
()
I take any pets, or family pets with them?
2 A
Mr. Crocker is informing me in the brochure if 3
people have pets, they are directed to take those pets to an d
animal shelter.
5 I would assume, not being a pet owner, that I
)
6 would take my animal with me.
It wouldn't be uncommon to 7
take your animal with you when you evacuate.
)
8 Q
I guess, Mr. Crocker, you might be the more 1
9 informed person on this.
10 A
(Witness Crocker)
I hope so.
Il Q
Are they supposed to take it to the animal 12 shelter before or after they get monitored, decontaminated?
13 A
We prefer they take the animal before.
1d Q
Before.
If they don't, what-provision has been J
l 15 made for animals during the monitoring phase?
16 A
That question has come up in a lot of our 17 training sessions, and we have been telling our people to 18 have -- for example, if you have a doberman, people are l
19 naturally apprehensive.
The owner is required to restrain 20 bis animal.during the monitoring, if necessary.
21 Q
And during the decontamination process, what 22 provision is made for the animals while people are waiting 23 at the decontamination trailers?
2d A
I believe we would direct them to leave the 25 animal in the car.
O
17698 51900909 joewalsh I
Q One question.
For any pets, would they be 2
monitored?
3 A
If someone asked, and the animal looked d
friendly, they would.
5 (Laughter.)
6 Q
On the other hand, if there was an angry pit 7
bull terrier, discretion would say otherwise?
8 A
We would get the very long extension handle.
9 (Laughter.)
10 MR. CASE:
I have no further questions, Judge Il Margulies.
j 12 MR. McMURRAY:
Judge Margulies, we have no I
13 further questions.
D Id JUDGE MARGULIES:
That concludes your 15 examination on LILCO's Exhibit No. 1?
16 MR. McMURRAY:
Yes, sir.
]
17 JUDGE MARGULIES:
Is the State of New York ready 18 to proceed?
19 MR. ZAHNLEUTER:
Yes, I am.
20 CROSS EXAMINATION 21 BY MR. ZAHNLEUTER:
22 Q
Mr. Crocker, could you turn to Page 24, please?
j 23 In the answer to Question 36 --
]
24 A
(Witness Crocker)
Twenty-four?
25 0
Yes, page 24.
In the answer to Question 36, you j
- d
17699 51900909 j oewalsh
()
say, in the last sentence that:
The three facilities LILCO I
2 has designated are the closest available.
LILCO does not 3
own suitable facilities significantly closer to the plant.
4 In your view, what features would a suitable 5
facility have?
6 A
primarily, sufficient space.
7 Q
Would it have a source of power and water?
l l
8 A
Or allow you to make those provisions, yeah.
9 Most of our facilities have power and water.
10 Q
Can you think of any other features?
H A
Well, obviously location and size.
12 Q
Now, LILCO's monitoring facilities at Roslyn, 13 Hicksville, and Bellmore, are essentially open air locations O
14 on a flat, hard surface, right?
15 A
Yeah, the terrain is level there.
16 O
And LILCO's decontamination facilities at 17 Roslyn, Hicksville, and Bellmore are essentially trailers, 18 and again, flat hard surfaces, and a source of power and 19 water, right?
20 A
Plus we have the facilities in other buildings 21 around that area.
22 Q
And you also have waste water storage tanks for 23 decontamination facilities, correct?
24 A
The effluent from the trailers is collected in 25 storage tanks.
1
I J
l 1
17700 51900909 joewalsh I
Q LILCO already has agreements with the private se 2
sector to use facilities with these types of features as 3
transfer points, isn't that correct?
d A
What features are you referring to?
5 Q
The same features that you mentioned to met 1
6 space, location, source of power and water.
7 A
Not necessarily power and water.
The others, 8
yes.
9 Q
So, your answer is LILCO does have agreements 10 with facilities that have these same types of features, and LILCO uses them as transfer points, is that your answer?
12 A
Yeah.
13 Q
Now, Mr. Crocker, you are familiar with the
)
Id LILCO facility at Brentwood, aren't you?
15 A
Yes.
The Brentwood Operations Center.
16 0
That facility is approximately 20 miles from 17 Shoreham, isn't it?
'8 A
I will accept your nymber.
19 Q
Well, let me refer ym f.o your Attachment H to l
20 your testimony, and you can see from the map approximately 21 where Brentwood ier 22 It is approximately 20 miles from Shoreham, 23 isn't it.
24 A
Just one moment.
25 (Witness peruses document.)
6
I l
17701 51900909 joewalsh
()
1 A
(Continuing)
My reading of the scale will give 2
me 22 miles.
l 3
Q The Brentwood facility has open air storage-d areas with flat, hard surfaces, and water and power sources, 5
doesn't it?
6 A
Indeed it does.
7 Q
And the open area space at Brentwood is 8
approximately twice the open space area at the Roslyn 9
facility, isn't it?
10 A
I would be speculating.
It could be twice, it H
could be three times.
12 O
You are familiar with both sites.
13 A
I walked them both down, but I haven't laid them O
3d on top of each other to see their respective areas.
15 0
Okay.
16 A
I will grant you Brentwood is larger than 17 Roslyn.
IB Q
Much larger?
19 A
It is larger.
20 Q
,-Approximately twice the size?
21 A
I beg your pardon?
22 Q
Approximately twice the size, and I am speaking, 23 of course, of open space area.
24 A
Perhaps.
I haven't figured out the acreage.
I 25 haven't done that study.
O
17702 51900909 j oewalsh I
Q Well, you have seen the Bellmore facility, too, 2
haven't you?
3 A
Yeah, I have been there.
d Q
And would you also characterize the relative 5
size of'the Brentwood facility compared to Bellmore'as 6
larger?
l 7
A It is definitely larger.
8 Q
Would you call it much larger?
9 A
It is, perhaps, two or-three times as large.
10 Q
Mr. Crocker, you are also familiar with the il LILCO Training facility in Hauppauge, correct?
12 A
That is where my office is.
13 r
0 And that is a little less than 20 miles from the m0 Id Shoreham plant, right?
15 A
I think the number is 18 miles.
16 Q
And that facility in Hauppauge has an open air 17 parking lot with flat, hard surface, and a source for power 18 and water?
19 A
Yeah.
That facility, like Brentwood, is 20 dedicated to other uses in an emerger.cy, but yes, it has all 21 those facilities.
22 Q
That's true.
The facility in Hauppauge is an 23 EOF and an ENC, isn't it?
24 A
Yes.
I believe you were on the tour that day.
25 O'
And Brentwood is an EOC?
- 6
17703 51900909 j oewalsh
)
I A
It is the LERO EOC and EWDF.
2 Q
And at Hicksville, there is the family 3
relocation center and also a congregate care center, isn't d
that correct?
5 A
Yeah.
The congregate care center is there, and j
i 6
the family relocation center we discussed earlier.
7 Q
And Roslyn and Bellmore are also congregate care
)
{
B centers.
{
l 9
A They may be used as that, yes.
l 10 Q
And the parking lot at the Hauppauge facility 11 isn't part of the EOF or ENC, is it?
12 A
Well, to the extent that our responding staff 13 and the large number of media we expect would use it, yeah, O
Id that is where we would park.
15 Q
LILCO also owns facilities in Babylon and 16 Huntington and Bridgehampton, isn't that correct?
17 A
They have facilities all over the island.
18 Q
Now, Ms. Dreikorn, I would like to ask you some 19 questions about your testimony on Page 47, dealing with 20 registration.
21 It is fair to say, isn't it, that the purpose of 22 LILCO's registration scheme is limited to gathering license 23 plate information for -- to facilitate follow up medical 24 procedures?
25 A
(Witness Dreikorn)
.No, that is not correct at O
l 1
17704 51900909 joewalsh I
all.
What we would do is we would gather information on the 2
vehicles at the initial monitoring stations, specifically 3
their license plate number and state, and number of 1
1 d
occupants.
5 In addition, we would gather information at the j
6 decontamination facility on a form that we would refer to as 7
the Evacuee Exposure Record form.
That would include 1
8 details of the individual that was monitored further.
The 9
levels of contamination, the methods of decontamination.
10 Whether or not those methods were successful.
II And that really would be information that would l
12 help you with medical follow up, in addition to information 13 of a general nature which would be collected at the initial i
1 Id monitoring station.
15 Also, as I indicated earlier, the other means of l
I 1
16 record that is kept is of bus evacuees who arrive on a bus, 17 and that document logs in their name and I believe their l
1 18 address also on that form on an individual basis.
19 Q
So, with respect to cars or vehicles other than 20 buses, and with respect to people who arrive at the
]
21 reception centers but do not need decontamination, the 22 information that LILCO will have about them from the j
23 registration scheme is the vehicle license plate number, and l
24 the number of occupants in the car, is that correct?
25 A
That is correct.
O
17705 51900909
.joewalsh 1
Q LILCO is relying on the New York State 2
Department of M'otor Vehicles to provide LILCO with names and 3
addresses that correspond to those license plate numbers.
i d
That was your testimony before, is that correct?
5 A
That is correct.
What I said was the Department 6
of Motor Vehicles would be enlisted to assist us in 7
contacting individuals if it were necessary to contact those 8
individuals, and we would utilize the license plate numbers 9
and states -- to go through either New York State Department 10 of Motor Vehicles or in the case of a transient, possibly in 11 other states Department of Motor Vehicles if it were 12 necessary to contact those people.
13 Q
Is it LILCO's position that LILCO enlist state Id agencies?
15 MR. CHRISTMAN:
Obj ection.
That is 16 a argumentative.
We all know where counsel is going, and it 17 is a silly question.
18 MR. ZAHNLEUTER:
Well --
19 JUDGE MARGULIES:
Do you wish to respond?
20 KR. ZAHNLEUTER:
My question stands, and I am 21 asking for an elaboration of a word used by Ms. Dreikorn in
]
22 her answer to my question.
23 MR. CHRISTMAN:
If counsel wants the meaning of 2d the word, " enlist," he can look it up in a dictionary.
It 25 means assistance would be asked for.
I don't see any point
(:)
17706 51900909 j oewalsh I
in pursuing this line of questioning.
2 JUDGE MARGULIES:
This is cross examination.
3 The question will be permitted.
d WITNESS DREIKORN:
I guess to clarify the term, 5
" enlist," what I would mean would be that LILCO would 6
contact the State and request that they assist them in this i
effort, which I feel the State would certainly come through 8
with in an emergency situation.
And being a former member of the Department of 10 Health, Bureau of Radiological Health and Bureau of M
Environmental Radiation Protection now, I know in my ' !;,
4 12 position there, when we receive requests that came from Nhe 13 outside, from any organization whatsoever in an emergency Id response capacity or whatever, we would certainly go out of 15 our way to assist in the response that we could provide.
16 BY MR. ZAHNLEUTER:
(Continuing) 17 Q
Is there a letter of agreement in existence 18 between LILCO and the New York State Department of Motor 19 Vehicles concerning this function?
20 A
"(Witness Dreikorn)
No, not that I am aware of.
21
.O As an emergency planner, wouldn't it be prudent j
i 22 to verify the legality of whether or not the New York State 23 Department of Motor Vehicles may give out names and 24 addresses to a private company?
25 A
I don't really think this would be necessary.
6
17707 51900909' j oewalsh
()
1 Again, this is emergency response that we are talking about.
2 O
It is LILCO's emergency response that you are 3
talking about, correct?
d A
Yes.
In addition within the LERO organization, 5
we have a recovery action committee that would bring in 6
Federal programs through the Firm Rap Program, and if 7
necessary, we could go through the Feds to get the support 8
of state agencies, if that were a necessary way to contact 9
the states.
10 Q
Isn't it more important for LILCO to know where 13 the evacuees are going to relocate rather than the location 12 of the contaminated places that they evacuated from?
13 A
I really don't think I know of any other plan O
Id that does that.
{
15 Q
Could you answer my question, please.
If I need 16 to repeat it, I will.
17 A
Please repeat it.
1 18 Q
Isn't it more important for LILCO to know where.
19 the evacuees are going to relocate rather than where the 20 evacuees -- or what contaminated place the evacuees came 21 from?-
22 A
I am not sure what the purpose would be.
Once 23 the people are monitored and found free of contamination, 2d they are free to go wherever they would choose to go.
25 They may go to a relatives house, or they may go O
17708 51900909 joewalsh I
to congregate care that is offered through the Red Cross.
2 They may go to a hotel.
3 A
(Witness Watts)
In addition to that, I foresee d
a need later on, after the emergency has subsided, to make 5
an estimate of population doses, and I could foresee 6
probably several organizations, perhaps State, very likely 7
Federal, to reconstruct the exact sequence of events of an 8
evacuation in the event of an emergency, and to attempt to 9
do a refined population dose estimate.
10 And I can envision some agency requesting.
II information to try to identify who came from which location, 12 and at what time.
That may very well happen later on.
4 13 So, I think there would be some interest in that Id at a later point.
To do a refined population dose estimate.
15 Q
Mr. Watts, does the registration scheme 16 incorporate the time of arrival for monitoring?
17 A
I think those types of estimates could be put 18 together within a window.
19 I think the main thing is to know who left which j
i 20 location.
{
21 0
Do the procedures, as they exist now, include J
the provision for taking down the time of arrival?
22 23 A
No, they don t, no.
It would be useful
{
information anyhow if someone were to try to reconstruct 24 25 population doses.
17709 51900909 j oewalsh O
i o
xma ur. weete, the eaareeeee of the 91 ecee --
2 the locations of the places that were evacuated were known, 3
because --strike that.
d A
You would use the information that you had 5
available.
That is all I am saying.
6 7
8 9
10 11 12 13 O
15 16 17 18 19 20 21 22 23 24 25 O
51900707 17710 marysimons I
Q Now, Ms. Dreikorn, isn't it possible that it 2
could be days, months or years before evacuees could return 3
to their homes?
d A
(Witness'Dreikorn)
I guess that would depend on the type of accident that you are postulating.
)
5 6
Q So it would be possible, wouldn't it?
7 A
Highly improbable.
8 Q
Would it be possible?
9 MR. CHRISTMAN:
The question was I believe, and l
l 10 I'm making an objection, was whether it's possible that it j
11 might be days, months or years before people could return.
12 So part of that question is is it possible that it could be, 13 days before people could return, as I understand the i
14 question.
15 I guess my objection is the question is unclear 16 unless it means what I just said.
l l
17 JUDGE MARGULIES:
I think it would be helpful if 18 the question were broken down into the segments as to time.
19 BY MR. ZAENLEUTER:
20 Q
Ms. Dreikorn, is it possible that it could be 21 days before evacuees are able to return to their homes?
l l
22 A
(Witness Dreikorn)
When you are referring to 23 days, could you give me a number of days that you are 24 considering?
25 Q
One.
I
17711 51900707 marysimons
( )
1 A
One day?
2 O
Yes.
3 A
It is possible that one day could be a day 4
evacuation time period, and I think that is well shown in 5
the Nanatauk evacuation that recently occurred in March 6
where we had a chemical fire at a processing plant ---
7 Q
Ms. Dreikorn, all I'm asking you about is if 8
it's possible that one day could elapse before an evacuee 9
can return home.
I'm not asking about this other disaster 10 that you're talking about.
11 Is it possible that 10 days could elapse?
12 A
Could you give me details on the accident i3 conditions?
(
14 0
Is it possible within the realm of accidents i$
required to be planned for by NUREG 06547 16 MR. CHRISTMAN:
I object to this line of 17 questioning on the grounds of relevance.
18 JUDGE MARGULIES:
Would you please respond to 19 that, counsel?
20
,MR. ZARNLEUTER:
What I am trying to ascertain 21 is the usefulness of the information that LILCO gathers 22 during its registration scheme when the information is 23 limited to the location of places that people left and will 24 not be at when it might be necessary for LILCO or others to 25 contact those people?
O
17712 51900707 marysimons
(
)
MR. CHRISTMAN:
I don't see how that question 2
furthers that purpose.
It seems to me that the question is 3
directed either to the ingestion pathway issues which were 4
litigated a long time ago or to the issue of the proper use 5
to which reception centers may be put in light of a passage 6
in the State's testimony that was stricken and, therefore, 7
in either case whether it goes to the testimony that was 8
stricken from the State's testimony or whether it goes to 9
the ingestion pathway issues already litigated is beyond the 10 scope of this proceeding.
11 The objection stands.
12 MR. ZAENLEUTER:
Judge Margulies, if it is true 13 that questions about registration procedures are irrelevant J
?^'
I j
14 and should be stricken, then I would also move that the two 15 questions and answers on page 47 in LILCO's testimony about 16 registration procedures be stricken.
17 MR. CHRISTMAN:
Well, in the first place, that 1B is a frivolous motion and the Board already has a decision 19 to make before counsel makes frivolous motions.
20 MR. ZAHNLEUTER:
I disagree.
This is not a j
1 21 frivolous motion.
22 MR. McMURRAY:
Judge Margulies, may I be heard?
23 JUDGE MARGULIES:
You may.
24 MR. McMURRAY:
This testimony sets forth the 25 registration procedure and it says that that should provide
51900707 17713 marysimons i
sufficient information if people need to be recontracted.
(}
2 Now this is exactly what Mr. Zahnleuter is 3
exploring, does it provide sufficient information so that 4
these people can be recontracted in a timely manner?
5 Now if the information that is being obtained by 6
LILCO is information that will only refer LILCO back to 7
their home addresses and not to their relocation addresses e
and if there is a possibility that they may be at the 9
relocation addresses for a long time, then obviously the 10 information is not sufficient.
11 Mr. Zahnleuter has the right to explore that 12 question.
i3 (Board conferring.)
ja JUDGE MARGULIES:
The Board will permit the is question if you link it to public health and safety rather 16 than the matter of providing the information for purposes of 17 convenience in terms of assisting parties to locate family is members and things of that sort.
19 We struck some testimony previously in that it 20 related to providing information that would enable people to 21 find.out the locations of family members as a matter of 22 convenience, and it didn't extend to public health and
)
23 safety.
24 If you could link of your line of questioning to 25 matters of public health and safety, we will permit O
(
51900707 17714 marysimons
(
1 inquiries in that area.
2 MR. ZAHNLEUTER:
Thank you.
If I may have half 3
a minute.
4 JUDGE MARGULIES:
Certainly.
5 (Pause.)
6 MR. ZAHNLEUTER:
I'm sorry.
7 JUDGE MARGULIES:
You may proceed.
l 8
BY MR. ZAHNLEUTER:
9 Q
Is it conceivable that LILCO may need to recall 10 or recontact people who passed through the monitoring.
Il facilities at the reception centers for the purpose of 12 remonitoring them or otherwise ascertaining the time of 13 their evacuation or the time of their arrival at reception D) k-14 centers?
15 MR. CHRISTMAN:
Objection.
If this question l
16 asks about people who have gone through the monitoring and 17 are clean, that question was asked earlier by Mr. McMurray.
18 JUDGE MARGULIES:
It's my recollection that this 19 witness testified that there might be a need to contact 20 those people.
I believe it was testified early on this 21 morning to that effect.
l 1
22 MR. CHRISTMAN:
My objection was asked and 23 answered.
24 JUDGE MARGULIES:
The witness was not specific 25 as to what those instances constituted and if the question d
17715 51900707 marysimons
(]
1 very practical means of getting ahold of people that you 2
need to contact.
3 If you recall, a couple of years back the 4
Department of Health issued notices to individuals-to bring 5
their radioactive gold in for monitoring, and I was part of 6
that monitoring program.
The way we reached those 7
individuals who had possibly the radioactive gold was a
through the media.
We had radio announcements, we had 9
published announcements in the newspaper which brought 10 people into facilities, both County and State offices for 11 monitoring of their gold, whether it be radioactive or not.
12 So that's certainly a great way of getting ahold 13 of people and having them come to a location if it's 14 necessary to gather information to provide monitoring.
15 Q
Is that mentioned in the LILCO plan?
16 A
It would be a recovery action.
I'm not sure if 17 it's specifically mentioned in the plan in that context, but 18 we certainly used the media, and that is why we have an j
J 19 emergency news center established that would work with us in j
a 20 those mechanisms to contact the people if necessary.
21 Q
Ms. Dreikorn, do you know of any other current 22 plan in Ncw York State that calls for the registration of 23 evacuees in the manner proposed by LILCO?
24 A
I'm not sure if in New York State there are i
25 plans that do it in the exact manner that we do it here.
l l
l
~h V
51900707 17710 marysimons
(}
1 goes to ascertaining more specifically what those instances 2
are, the question may be asked.
i 3
MR. ZAHNLEUTER:
That's correct.
]
j 4
BY MR. ZARNLEUTER:
5 Q
Ms. Dreikorn, I would like to ask you for an 6
explanation of the specific instances where a recall might 7
be necessary.
8 A
(Witness Dreikorn)
The type of instance that l
9 comes to mind initially would be, as Mr. Watts explained l
10 when we were doing total population dose calculations, there I
11 might be information that would be received back from t ose 12 individuals that did evacuate.
13 Also, as Dr. Linnemann has pointed out, during
(
14 Three Mile Island, they did through the media contact is individuals to come back after a couple week time frame so 16 that they could provide whole-body counts and thyroid l
17 monitoring to those individuals.
So certainly the media 18 would be an excellent way of reaching those people.
If we l
l 19 need to, we could take full-page advertisements out to 1
20 contact people and have broadcasts over the news, the radio 21 systems and the television to call back people if it were 22 necessary.
1 23 0
In light of your registration scheme, the media 24 would be necessary, wouldn' t it?
25 A
I think it would be an asset.
It would be a
()
)
51900707 17717 marysimons
]
1 There are several variations to I guess identify individuals 2
that have gone through monitoring in review of FEMA exercise l
3 reports in preparation for these hearings, I read a FEMA 4
exercise report that commented on individuals going through 5
monitoring were just denoted with an "X" on their hand that 3
6 they had gone through monitoring and then they were sent on i
7 to congregate care where the Red Cross would register the a
individuals that come into congregate care.
9 So that is just another variation of identifying i
10 people that have gone through monitoring.
So I guess there 11 is a whole spectrum of mechanisms for identifying those 12 individuals.
13 Q
Do you know of any other current plan in New 14 York State that relies on motor vehicle license plate 15 numbers for registration, and if you could answer the 16 question yes or no before you explain if necessary, I would 17 appreciate that.
18 A
No, not off the top of my head.
j 19 Q
Professor Mileti, on page 47 at the bottom, the 20 very bottom, your testimony states " People are going to have 21 questions.
That is why we put so much emphasis on EBS 22 messages."
23 Now LILCO's purpose in putting so much emphasis 24 on EBS messages is to make the messages informative and 25 persuasive; isn't that correct?
)
O
51900707 17718 marysimons
,(
1 A
(Witness Mileti)
No, I wouldn't use those words 2
to characterize the EBS messages at all.
3 Q
They are not intended to be persuasive?
4 A
I wouldn't use the word " persuasive."
I would 1
5 use the words, to provide information to the public so that 6
they could make good decisions about what to do in the l
7 emergency.
8 Q
Now it's true that you believe that the purpose l
9 of the EBS messages is to make the information effective so 10 that people who are affected by the message will be able to 11 utilize that information?
12 A
If what you just asked is do I think the 13 information should be useful so that the people can make L
14 good and informed decisions, then the answer is yes.
15 JUDGE MARGULIES:
I don't want to cut you off, 16 Mr. Zahnleuter, but we were requested yesterday to recess i
17 because of witness needs as close to 12 as possible.
1 18 MR. ZAHNLEUTER:
I only had two or three minutes 19 of questioning left.
l 20 MR. CHRISTMAN:
That's okay.
21 JUDGE MARGULIES:
You may proceed.
1 22 BY MR. ZAHNLEUTER:
23 Q
Mr. Watts, during the February 13 th, 86 exercise 24 LILCO instructed approximately 95,000 via EBS messages to 25 report to the reception center for monitoring; isn't that I
()
51900707 marysimons 17719 1
true?
2 A
(Witness Watts)
I'm not sure that is exactly 3
correct.
I don' t remember the exact breakdown, but we 4
initially came forward with an evacuation recommendation 5
which was then later followed up with a specific message 6
aimed at identifying certain zones which we felt may have 7
been Contaminated, and I believe there were six zones, and 8
we recommended to people coming from those zones that they 9
report for monitoring and decontamination.
10 We assumed that of the remaining zones that 11 there would be 20 percent who would also be reporting to the 12 reception centers.
13 Q
If I told you that zones A, B,
F, G,
K, and Q 14 were told to report to the coliseum for monitoring, would 15 that refresh your recollection?
16 A
That sounds right.
17 Q
And as you told Mr. McMurray yesterday, the is population of the three 22 and a half degree sectors to the 19 west of Shoreham is about 76 percent of the total population l
20 of the EPZ.
l 21 A
Could you repeat that again?
22 Q
Do you recall saying yesterday that the 23 population of the three 22 and a half degree sectors to the 24 west or Shoreham is about 76 percent of the population of 25 the EPZ?
O
l 51900707 17720 marysimons 1
MR. CHRISTMAN:
I would like to object to the 2
characterizatipp "to the west of Shoreham."
I think the 3
question would only be competent if he specified the exhibit 4
we are talking about and what the sectors are that were 3
5 identified yesterday.
It would be much more clear to j
6 identify the sectors.
7 MR. ZAHNLEUTER:
I'll specify the three northern a
and western-most sectors in the Shoreham EPZ which cover the 9
land.
10 BY MR. ZAHNLEUTER:
I 11 Q
Mr. Watts, is there a problem with my 12 description?
13 A
(Witness Watts)
I'm a little confused about I
Fl 14 what you're after, Mr. Zahnleuter.
15 MR. ZAHNLEUTER:
I'll withdraw the question then 16 and I will rely on the record as it existed from yesterday.
17 BY MR. ZAHNLEUTER:
18 Q
Professor Mileti, on page 14 of your testimony 19 in the answer to question 19 you state "This is why EBS 20 messages are so important to encourage those advised to be 21 monitored to do so."
22 Is it your testimony that you think it's 23 important to instruct people to'go to reception centers for 24 monitoring if the accident warrants monitoring?
25 A
(Witness Mileti)
For the people that would need I
u) l s
51900707 1777y marysimons
(]}
1 to be monitored, yes, I would issue an EBS message 2
suggesting that they do that, yes.
3 Q
Suggesting that it's important that they do 4
that?
l I
5 A
Suggesting that they do it, yes.
6 Q
Would you suggest that it's important that they I
7 go to a reception center to be monitored?
3 s
A If what you're asking me is would I put in the 9
EBS message the word "important," I may or may not depending 10 upon what I was thinking when I was writing the EBS 11 message.
I would try to convey in the EBS message i
i 12 information that would lead them to conclude that it was 1
13 important enough for them to go to give them the perception la that it was important that they engage in that behavior.
15 Q
Okay. Thank you.
16 Now, Mr. Crocker, the Krim memorandum, which is 17 Attachment L to your testimony does not contain any 18 reference at all to EBS messages which instruct people to go 19 to reception centers for monitoring, does it?
20 A
(Witness Crocker)
Hang on a moment.
You said 21 Attachment L?
22 MR. ZARNLEUTER:
Yes.
23 WITNESS CROCKER:
Let me refresh my memory.
24 (Pause while the witness reviews the document 25 ref erenc ed. )
O
17722 1
51901111 i
suewalsh j
i l
f~')
1 Q
My question was whether Attachment L contained
%s' 2
any reference at all to EBS messages which instructed people 3
to go to reception centers for monitoring?
4 A
(Witness Crocker)
No, it does not.
q 5
MR. ZAHNLEUTER:
Thank you.
I have no other 6
questions.
7 JUDGE MARGULIES:
We will recess for lunch until 8
1:30.
i 9
(whereupon, the hearing is recessed at 12:10 to p.m.,
to reconvene at 1:32 p.m.,
this same day.)
11 12 13 14 15 16 17 18 19 l
1 20 21 22 23
]
24 25 i
)
51901111 17723 suewalsh 1
AFTERNOON SESSION 2
(1:32 p.m.)
3 JUDGE MARGULIES:
Back on the record.
Is the 4
Staff ready to proceed?
5 MR. JOHNSON:
Yes, sir.
6 Whereupon, 7
DENNIS S. MILETI, 8
MICHAEL K. LINDELL,.
9 ROGER E. LINNEMANN, 10 DOUGLAS.M. CROCKER, 11 DIANE P. DREIKORN, 12 RICHARD J. WATTS 13 and 14 DALE E. DONALDSON 15 resumed as witnesses by and on behalf of the Applicant, the 16 Long Island Lighting Company, and having previous 1'y been 17 duly sworn, were further examined and testified as follows:
18 CROSS EXAMINATION 19 BY MR. JOHNSON:
20 Q
Dr. Linnemann, would you_ turn to Question 122 on 21 Page.54 of your testimony?
22 (The witnesses are complying.)
23 A
(Witness Linnemann)
Yes.
2a Q
Is there a provision in the LERO plan for-25 calling upon volunteers to assist to provide back-up O
i 51901111 17724 suewalsh 1
resources in the monitoring effort?
2 A
I'm not sure it's volunteer, but I believe j
3 recalling reading the plan that they have plans for calling 4
on outside resources like INPO, DOE and others in the event l
5 the situation is larger than their own resources.
6 Q
Okay.
Focusing on other than INPO and DOE 7
governmental resources, the'other resources that you are 8
alluding to --
9 A
Right.
10 Q
-- are there procedures or lists or methods that 11 might be available in case of an emergency --
12 A
I believe --
13 Q
-- for use in that purpose?
14 A
I believe Mr. Crocker could answer that better 15 than I could.
l 1
16 Q
Mr. Crocker.
17 A
(Witness Crocker)
Did the question go to i
18 agreement with other agencies aside from DOE and --
19 Q
I didn't say anything about agreements.
I said 20 what mechanism -- I was really asking, what mechanism would 21 you use to obtain the type of supplemental resources that 22 Dr. Linnemann was referring to?
23 A
Uh-huh.
There is a number of methods.
Dr.
24 Linnemann himself is one of our resources, and his 25 organization.
That's embodied in one of the EPIPs, the on-b
1 l
1
}
51901111 17725 suewalsh
(}
i site emergency plan and procedures, where we could call at 2
LERO's request his resources and the connections to the 3
industry that he has.
4 In addition, we have contacts with organizations 5
like U.E. which has some health physics capability.
I'm 6
trying to' recall what others.
I can't recall any others.
7 (The witness is conferring with Ms. Dreikorn.)
e And, obviously through DOE and FEMA,.the federal 9
master plan, which is a large part of the resources we would to rely on.
l 11 Q
And, do any of the organizations that you have 12 mentioned, Dr. Linnemann's organization, G.E. or DOE 13 maintain lists or procedures for contacting resources lof 14 this sort?
15 A
By G.E.,
I'm considering their own staff.
Dr.
16 Linnemann could answer the question.
He keeps track of his
)
17 own resources.
18 (Witness Linnemann)
I do have a list of 19 physicians in this field, health physicists that I would 20 call upon to assist us in any problem that would exceed our 21 own capability.
22 Q
Do you have set procedures that you would use to
)
23 contact these people?
24 A
No.
It would be by telephone.
And, I would get 25 them as they were available.
(:)
51901111 17720 suewalsh
(
1 Q
Are any of these people on notice that they 2
might be called upon to be available in the case of an 3
emergency at Shoreham?
4 A
Yes.
I've talked with them all and asked them 5
if I could put them on a list that didn't commit them to be i
6 available but if they were available, and they all readily 7
volunteered to do that.
8 Q
And, how many individuals are on this list or 9
available?
10 A
Six of them on radiatien medicine physicians; 11 and, I believe there is about an equal number of what I, call i
12 health physicists, dosimetrists particularly that I rely on.
13 0
Thank you.
And, Mr. Crocker, can you estimate 14 the amount of -- the number of individuals who could be 15 called upon from the resources that you enumerated?
16 A
(Witness Crocker)
This is in addition to DOE 17 and those that we have excluded previously?
)
18 Q
Yes.
19 A
Off the top of my head, I don't know what G.E.
20 and Stone and Webster and the others could provide us.
I 21 haven't got the count in my head.
22 (The witness is conferring with Mr. Watts.)
23 My colleague, Mr. Watts, has also pointed out 24 something that I had forgotten.
We have arrangements with --
25 you are familiar with the term " Rent-A-Tech" which is the 6
i
51901111' 17727 suewalsh
)
()
i organizations that provide us health physics technicians on 2
site for occasional outages and periods of high work load.
3 And, you know, we can secure people from those organizations 4
as well.
5 Q
I'm not sure who should answer this question, 6
because Mr. Crocker, Ms. Dreikorn and Mr. Watts have 7
sponsored the answer to Question 123.
But, I would be s
interested to know -- strike that.
9 I'm assuming that a calculation is made, in that to you determined with respect to your answer to Question 123 11 what number of individuals would be expected based on 12 directions to proceed to a reception center from the EPZ to 33 each of the -- that would be directea to each of the three O
14 reception centers.
is And, I was wondering if there is a proced:2re for a
determining when to make the determination that you are 17 going to call out the extra resources, the supplemental is resources?
19 A
Having done the calculation to assess how many 20 people we anticipate at the reception centers, the trigger 21 point is the 30 percent.
When we hit that, we will begin to 22 call in additional resources.
23 That doesn't preclude us from doing it earlier 24 if we feel it's prudent but 30 percent would certainly make 25 us start calling them in.
O
17728 51901111 suewalsh i
1 Q
Who makes that determination?
2 (The witness is conferring with Mr. Watts.)
3 (Witness Watts)
That determination is done at i
4 the LERO EOC.
The Rad Health Coordinator takes the 5
information available concerning the zones which have 6
received the recommendation to evacuate as well as zones 7
that may be affected by the plume specifically.
8 What we do then is meet with the Health Services 9
Coordinator and Evacuation Coordinators and determine rather I
10 quickly what the population numbers are within the specific 11 zones of concern and also factor the 20 percent of the 12 remainder of the EPZ not being asked specifically to report' gs 13 to the reception centers for monitoring.
$_)
s 14 That is done at the LERO Emergency Operations 15 Center.
16 Q
I'm sorry.
I didn't hear the last part.
17 A
That is done at the LERO Emergency Operations 18 Center really by three or four key coordinators who work on 19 that particular problem with a majority of input from the 20 Radiation Health Coordinator.
i i
21 We also use the 30 percent as a trigger in our 22 procedures, recognizing that we can handle we calculate j
l 23 about 46 percent or so, 46 to 47 percent, ourselves.
- But, 24 we use the 30 percent as a conservative trigger point to 25 initiate phone calls that we feel might be needed.
1
17729 51901111 suewalsh
()
1 0
Thank you, There was some discussion earlier I 2
think with respect to Question 123's answer that brought in 3
the -- I think Mr. Crocker did bring up the federal field 4
exercise at St. Lucie in connection with the use of INPO 1
5 resources.
6 Could you explain how the use of INPO resources 7
of these sorts were demonstrated, was demonstrated, at that a
particular exercise or would be demonstrated at a federal 9
field exercise?
10 A
(Witness Crocker)
Okay.
As -- when I said 11 that, I also referred to the fact that I had trouble 12 remembering where I had heard that from.
I don't have the i3 details at my fingertips.
I just know that I've heard in O
14 discussions with other planners that INPO had gone there.
15 I didn't see them myself.
16 0
Okay.
Thank you.
Maybe Dr. Lindell or Mr.
17 Donaldson would be aware of what is demonstrated at full --
18 at the federal field exercises.
I don't know.
19 Do you?
20 A
(Witness Lindell)
I was not at the St. Lucie 21 exerc.ise and so I couldn' t speak to that.
I'm not -- I just 22 can't recall what INPO's involvement was even through l
23 secondary information from other people.
24 0
I'm not limiting myself to the St. Lucie federal 25 field exercise if there were others.
l
(
i l
1
-l l
1 51901111 suewalsh 1
A (Witness Crocker)
There was one other federal field exercise that I'm aware of and that was the one that 2
1 1
3 was recently concluded at Zion.
Other than the fact that 4
they had it, I haven't received any feedback as to what they.
5 did or what happened there.
6 Q
Thank you.
Mr. Donaldson, do you -- are you 7
able to supplement that?
8 A
(Witness Donaldson)
No.
9 Q
Okay.
Thank you.
-Mr. Watts, turning to 10 Question and Answer Number 146 on Page.61, please --
11 (The witnesses are complying.)
12
-- with respect to the decontamination of 13 vehicles.
Are you at the location?
14 A
(Witness Watts)
Yes, I am.
15
-Q How long do you anticipate the decontamination 16 of a vehicle to take?
1 17 MR. McMURRAY:
I'm sorry.
I didn't understand I
t 18 that question.
Could I have that again?
19 BY MR. JOHNSON:
(Continuing) 20 Q
The answer speaks to a provision for 21 decontaminating vehicles by wiping them with disposable
]
22 paper wipes and a common household cleaner.
i 23 And, my question is:
How long do you anticipate 24 that such an operation will take in an emergency?
I 25 A
(Witness Watts)
I'm afraid I can't give you an
-l 1
17731 51901111 suewalsh l
(
1 absolute answer in terms of time, because it depends on the 2
cxtent of the contamination and the coverage of it, outside 3
and inside the vehicle.
4 Q
Do you have estimates as to the number of 5
vehicles or the percentage of vehicles that might be 6
contaminated?
7 A
Not specifically, no.
I might add though that a
we have, in addition to the wiping method that we mentioned 9
here, we also have capability at each of the three reception 10 centers to use facilities that are normally used for truck 11 washing that have drainage connected to underground storage 12 tanks.
i3 I know at Bellmore and Roslyn the tank capacity O
u is 6,000 gallons underground.
At Hicksville, it's 10,000 15 gallons.
These would be enclosed locations in the 16 transportation buildings that could be used if we needed to 17 expedite decontamination of cars.
l 18 This is yet another resource that we have.
l l
19 Q
Well, with your procedures anticipated and the l
20 resource that you just mentioned, how would you deal with a 21 large number of decontaminated -- of contaminated vehicles 22 arriving around the same time?
23 A
If we -- we would attempt to decontaminate the 24 cars as they arrived.
And, if it turned out that we had 25 excess contaminated cars on hand we have provisions at the
17732 51901111 suewalsh I
the three reception centers for parking of those 2
contaminated vehicles.
3 In the event-that we -- if we had a backlog, we 4
at least have a place to locate them.
4 1
5 Q
Okay.
And, what would happen to the individuals 6
af ter those vehicles were parked?
7
.A The occupants?
8 Q
I'm sorry, the passengers and the driver?
9 A
They would be monitored and decontaminated if j
10 necessary.
We would then determine what their destination 11 is going to be, should it be congregate care or some other 12 location and make provisions for transportation of these 13 people as appropriate.
l 14 Perhaps Mr. Crocker or Ms. Dreikorn could add to 15 that.
16 Q
Thank you.
17 A
(Witness Crocker)
At each of these three 18 facilities, we also have an area designated as congregate 19 care.
We can put some of them up there either temporarily 20 while we arrange for transportation or use that as their 21 congregate care f acility.
22 Q
I take it that some time after their vehicle was 23 parked and there was time they would have the vehicle 24 decontaminated and then they would come and get their cart 25 is that correct?
rm
51901111
}))33 suewalsh
()
i A
Absolutely.
As you heard the others testify, as 2
time goes on we probably would be buried with outside l
l 3
support.
You know, as more DOE rolls in and they tap the l
1 4
resources of other federal agencies.
We would have 1
5 significant numbers of people devoted to cleaning up these I
6 cars.
7 Of course, the first priority is the people.
1 s
But, once we are done with that we can put these additional 9
resources on the cars and give them back to the owner.
10 11 12 i4 15 16 17 18 l
i9 4
20 21 l
22 i
l 23 i
l 24 25 I
i 1
l l
i 51901212 17734 joswalsh-l
()
i Q
Okay.
Turning to Question 139, this answer is 2
sponsored by Mr. Crocker, Ms. Dreikorn and Mr. Watts.
3 Could one of you tell me what is meant by the 4
term "very unrealistic accident?"
What do you mean?
5 A
(Witness Crocker)
I will take a stab at that 6
first.
FEMA, in discussions with us in preparing the 7
scenario, wanted to see certain off-site objectives met, e
demonstrations of, you know, evacuation and directing people 9
to reception centers, et cetera.
In order to do that, we 10 have to postulate an accident that is at the high end of the l
11 spectrum we talked about earlier, you know, the very j
12 improbable, relatively severe accident.
13 So, that -- with that as a goal to demonstrate 14 these objectives, we then turned to the plant and postulated
)
l 15 sufficient malfunctions in series that in toto were very 1
16 improbable in order to get the accident consequences we
)
l 17 needed to meet those off-site objectives.
l 18 Q
I see.
In other words, the reason you are using I
l 19 that term there is in order to get a consequence that would I
i 20 involve a large segment of the population, is that the --
)
21
.A Yeah.
FEMA insisted that we do that, because I
1 22 they were looking -- they wanted to prompt certain off-site 23 responses.
24 Q
Okay.
25 A
(Witness Watts)
I might add to that by saying O
o__________
l 17735 51901212 jozwalsh 1
that many exercises use unrealistic scenarios, unrealistic 2
sequences of events to break the plant in the first place.
j 3
In the Shoreham case, there was a core melt d
accident that was postulated, a very large particulate 5
release that was postulated.
We had to achieve a release 6
level that required off-site protective action guides to be l
l 7
implemented.
8 And, also significantly it was purposely done in 9
a wind direction that is predominantly the upwind wind 10 direction.
In terms of the wind rose that we would use for 11 the Shoreham site, that wind direction occurs only about 12 four perc6nt of the time in that particular direction.
i 13 So, it was -- there was a series of very O
14 conservative assumptions used in that scenario to fully test 15 the plan.
16 Q
Thank you.
What I'm interested in knowing --
17 the second part of this answer is sponsored, in addition to 18 the three that I mentioned, Dr. Linnemann as well.
What I 19 would like to know is how the determination to advise the 20 procedure that is mentioned in that second paragraph of 21 Answer 139 is implemented?
22 What's the procedure?
Is there a criteria, i
23 criterion, for making the determination?
Is there a cut-off j
24 point?
1 25 And, who makes those determinations?
l i
s
17736 51901212 joswalsh
()
i I will break it down.
First, who would like to 2
answer this question?
Maybe I could just talk to somebody.
3 A
(Witness Crocker)
If you give us a moment, we 4
will find the appropriate section.
5 (The witnesses are looking through documents.)
6 (Witness Watts)
I will try to answer the y
question and invite my colleagues to supplement if a
necessary.
9 Q
Fine.
Fine, Mr. Watts.
Do you understand the to question that I'm asking?
I will restate it if you like.
11 A
Yes.
Please restate it.
12 Q
All right.
First of all, there is -- implicit i3 in this answer is a change in strategy in terms of the type u
of decontamination that you are going to anticipate the I
15 population taking based on the number of people you, 16 anticipate needing decontamination.
17 Am I correct in that assumption?
18 A
Yes, there is somewhat of a change, yes.
39 Q
Okay.
How would the determination to advise the 20 population in the EPZ or certain populations in the EPZ to 21 take the actions stated in the second paragraph on Answer j
i 22 139 be made?
23 A
Okay.
I would specifically refer you to OPIP 24 3.6.1 which is listed in our Attachment P, Page 2 of OPIP 25 3.6.1, the February 20th draft.
O
17737 51901212 jotwalsh 1
Q Which page, please?
2 A
Page 2 of 44.
Given the -- and, I will separate 3
this an'swer from monitoring.
We would maintain 4
communications with each of the three reception centers.
5 The way that is done is via the communicator at each of the 6
three reception centers who is in constant contact.with the 7
supervising decontamination leader at each of the centers.
8 Contact is maintained with the Emergency 9
Operations Cente-at Brentwood.
The person who is to constantly monitoring the situation as far as j
11 decontamination and monitoring at the reception centers is 12 the Decontamination Coordinator.
13 He is constantly asked what the status is of the 14 reception centers by the Radiation Health Coordinator and 15 other managers at LERO.
We would be following the situation 16 very closely to see if there were any problems with regard 17 to decontamination efforts.
If we were finding that we were 18 having more people and more cars than we felt we could 19 handle using LERO's existing resources at a particular 20 facility, I think the first thing that we would do is try to 21 shift.using management philosophy, just shift resources from 22 other facilities that might be under-utilized.
23 But, referring you to Step 3.5.a in OPIP 3.6.1, 24 our first step is to utilize the decon facilities at the 25 trailers themselves.
If we found that -- or we were
17738 51901212 joswalsh
-( )
1 anticipating a problem in keeping up with the flow for 2
decontamination, the Health Services Coordinator, Radiation 3
Health Coordinator, Decon Coordinator, and the Director of 4
LERO would immediately have a huddle and they would decide 5
what direction they wanted to take.
6 The second step in our tiered approach.here is 7
to try to obtain resources from federal, state, county and l
8 other private resources to see if we can supplement the LERO 9
resources.
And, we would have the Health Services i
10 Coordinator working on that particular task.
11 If it looked like that was not going to be 12 feasible to do, we could also utilize the option for Step C 13 which would be to issue an advisory for those people who O
14 required congregate care to continue to the reception 15 centers.
Those people who did not require congregate care 16 to proceed to their normal evacuation destination, remove 17 clothing, take a shower, bag the clothing and bring it back is to -- bring themselves back to the reception center at a 19 later time when they can.
20 No would maintain the reception centers in a 21 fully. active state to allow that.
22 Q
Okay.
I assume from -- or, I presume from what 23 you are saying that the determination to adopt a strategy of 24 advising individuals to take their own showers, et cetera, 25 as indicated in the second paragraph of Answer 139, would O
17739 51901212 jozwalsh 1
!()
I not be made on estimates of the number of' individuals who 2
would see the plume?
I 3
A No.
We would not do that.
We would use that'as 4
a -- really our last method, our last option.
That would f
5 not be something that would be made up front.
We would wait 6
and try to accommodate the situation using the existing 7
resources that are available so that we could handle the 8
situation, monitor the people, do the decontamination and 9
maintain as much control over the situation as possible.
10 We know that the other -- the third method.that 11 we are referring to about going to Aunt Minnie's and taking 12 a shower and coming back is a valid emergency planning 13 concept and it's suggested in the draft EPA guidance that we 14 referred to earlier.
We think that's a valid concept.
15 And, we maintain it as an option.
That's not 16 our primary method, however.
17 Q
Could you be any more specific about the factors 18 that you would consider in making that determination?
19 I understand that it would be an operational i
20 type of situation.
You would be looking at the centers, how 21 they were functioning.
22 And, what I'm asking is, in making your decision 23 what specific factors would you be taking into account?
i 24 A
We would be looking at whether we were 25 maintaining a steady throughput of people requiring
51901212 17740 jotwalsh
()
i decontamination at the trailers, whether we had gotten an 2
indication perhaps that we needed to have people temporarily 3
stand or sit in the transportation buildings or other 4
available buildings at the reception centers.
And, if it 5
looked like those buildings were starting to fill up we 6
would get the feedback at the EOC.
7 So, people would be one thing that we would be 8
gauging, just the throughput of the process.
And, vehicles 9
as well.
If it looked like we were getting a number of 10 vehicles that were contaminated and could not be readily 11 decontaminated and we started utilizing a significant 12 portion of the parking areas available at the reception 13 centers, that would raise a flag to us to evaluate what else 14 alght have to be done.
15 So, it's a feedback process from the reception 16 centers back to the EOC.
And, those questions on how things 17 are proceeding are asked on a regular basis in briefings is held with the Radiation Health Coordinator and with the l
19 other senior managers of LERO.
That's a question that we 20 would be asking very frequently.
21 MR. JOHNSON:
Thank you.
I have no further 22 questions.
23 JUDGE MARGULIES:
Do we have that information as 24 to the number of LERO people that were taken on recently?
25 MR. CHRISTMAN:
The witnesses did ask some staff O
i 17741
$1901212-joswalsh
(
)
people to do that calculation.
We can ask them if they have 2
it.
3 WITNESS CROCKER:
In part, that was the reason 1
I 4
for our tardiness.
When we arrived at our home office at i
5 lunch, we found the staff was working on it but it wasn't 6
quite the question we asked them to work on, so we had to re-7 channel our energies.
s We have some preliminary numbers here.
We can 9
give you a little bit later the final answer that our staff 10 is working on now, hopefully in the right direction this 11 time.
We leave it to your choice.
12 JUDGE MARGULIES:
Do you want to wait, Mr.
13 McMurray for the final figures?
'd 14 MR. McMURRAY:
I don't think it makes any sense 15 now to get preliminary or interim figures, Judge Margulies.
16 At some later point in the hearing -- it could even be 17 presented to the parties in writing, and if I feel there is 18 cross-examination necessary we can meet that at that time.
19 But, I don't see the need to get preliminary 20 figures now so that they could be changed in the future.
21 MR. CHRISTMAN:
Let me ask the witnesses, will J
22 the information be ready -- not to hurry them, but will the 23 information be ready later this afternoon?
24 WITNESS CROCKER:
We have every reason to expect 25 that it is unless they have gone astray again.
17742 51901212 joswalsh
()
i MR. CHRISTMAN:
Then, I think we should finish 2
up here and break until we get the information.
I r.eally 3
don't think we ought to try to provide it after we have all 4
dispersed and then possibly have to come back together to 4
1 5
address those figures.
6 If we can get it this afternoon, we ought to do 7
that.
And, it sounds as though the probabilities are we 8
will.
9 JUDGE MARGULIES:
You may proceed.
Do you have to something, Mr. McMurray?
11 MR. McMURRAY:
No, sir.
I was going to say that 12 I have no problem with addressing it after Mr. Christaan's redirect.
i3 O
14 JUDGE MARGULIES:
You may proceed with redirect.
15 MR. CHRISTMAN:
Thank you, Judge.
REDIRECT EXAMINATION 16 17 BY MR. CHRISTMAN:
is Q
Mr. Watts, when Mr. McMurray yesterday asked you l
39 some questions about when the 12-hour guideline of Criterion i
20 J.12 begins to run you started to say something about your 21 understanding of how the 12-hour starting point is 22 interpreted, and you were cut off.
i 23 What were you going to say?
I 24 A
(Witness Watts)
My understanding was that the 1
25 12-hour criterion began at the time of arrival of the first j
I 1
i I
l
-17743 S1901212 i
joswalsh 1
evacuee at the reception center.
And, also that my general 2
impression in working in emergency planning issues, that 3
that was a commonly held view in the industry.
4 I might also add that I have yet -- I have heard 5
of yet another interpretation of that, that the State of 6
Nebraska had related to us, and that is that 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> j
1 7
started -- or, the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> applied to each evacuee who 8
reported to the reception center, meaning that there was a 9
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> window that applied to each evacuee from the time
)
10 that evacuee reported until the time that evacuee exited the 11 reception center.
12 Q
Mr. Donaldson, do you have an opinion about 13 whether there are differing opinions on this question in the 14 industry?
15 A
(Witness Donaldson)
There certainly are 16 different opinions.
I think I expressed one in my initial 17 deposition and yesterday.
18 Of late, I had a conversation with~the Chairman 19 of the Regional Advisory Committee for the NRC, the NRC 20 representative, to check my interpretation and 21 understanding.
As it turns out, there has been no written 22 direction as to when the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> begins.
23 However, the accepted starting time is as Mr.
24 Watts has stated.
The acceptance criterion being used is 25 the arrival of the first individual at the reception center 4
i o
51901212 17744-joewalsh 1
i Q
Mr. Crocker or Ms. Dreikorn, either one, one of 2
you and I think it was Ms. Dreikorn-said in response to a 3
question yesterday that you were relying on the Krima j
4 memorandum for the 20 percent planning basis.
5 What basis do you have, if any, in addition to 6
the Krima memorandum?
7 A
(Witness Dreikorn)
In addition to the Krian 8
memorandum utilizing the 20 percent, we are using the 20 9
percent figure based on sound judgment as emergency I
10 planners, that this is a good basic point to start with and
]
11 where we can base our resources from..
12 It's just a basic response framework that we are 13 dealing with that we can expand upon.
And, as I believe Mr.
i4 Watts pointed out, actually initially -- with our initial 15 setup of the facilities, we can do approximately 46 percent 16 of the EPZ population at our facilities.
17 So, we go above and beyond the 20 percent is discussed in the Krima meno.
And, that 46 percent is also 19 accomplished within a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time frame.
20 Q
Mr. Donaldson, you said yesterday that you had
-]
j 21 seen the reception centers on June 8th.
What other time did 22 you see them; do you remember?
23 A
(Witness Donaldson)
June 8th during the 24 training exercise, and approximately one week. prior when 25 they were unoccupied essentially and they are ready to use 0
l 17745 51901212 jo:walsh I
during the work week state.
2 Q
Now, Mr. Donaldson, while I'm with you, you were 3
asked several questions about the providence of Criterion i
4 J.12 and whether -- and whether your original intent was 5
carried over into J.12 or not, but you weren't allowed to 6
finish your opinions on that I think.
7 Do you have any additional information that you i
a can provide?
9 MR. McMURRAY:
Judge Margulies, I'm going to 10 object to that question.
He is just asking an open-ended 11 question and asking the witness to provide additional 12 information.
That is not proper redirect.
13 MR. CHRISTMAN:
Well, I'm not allowed to ask a
,_O 14 leading question.
]
15 MR. McMURRAY:
You cannot ask an open-ended 16 question just asking for additional information on something i
1 17 that he has supposedly addressed in his direct testimony.
18 BY MR. CHRISTMAN:
(Continuing) 19 Q
What additional information do you have that you j
20 have recently learned?
j
?
21 MR. McMURRAY:
Same objection, Judge Margulies.
22 JUDGE MARGULIES:
Can you be a little more i
i 23 specific?
j 24 BY MR. CHRISTMAN:
(Continuing) 25 Q
Have you, within the last 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, learned 4
I a
17746 51901212 joewalsh
()
i anything more about the origin of Criterion J.127 2
A Yes, I have.
3 MR. McMURRAY:
Judge Margulies, I'm going to 4
object to this line of questioning.
This is something that 5
we haven't had a chance to conduct any discovery on.
6 And, Mr. Christman is trying to supplement the 7
record with more direct testimony that we have just not been 8
able to examine ourselves.
It is not proper redirect.
9 MR. CHRISTMAN:
Well, this is as much new 10 information to us as it is to anyone.else.
And, if the 11 Board wants a complete record on this, I think it should l
12 allow the qusstion.
i3 And, Mr. McMurray can either address it on O
ia recross or complain.
15 (The Board members are conferring.)
16 JUDGE MARGULIES:
The Board will permit the 17 question.
This is an administrative proceeding.
We are is looking for a complete record.
19 You may answer the question.
20 WITNESS DONALDSON:
Would you restate the 21 question, please?
22 MR. CHRISTMAN:
I was afraid you would ask that.
23 (Laughter.)
24 BY MR. CHRISTMAN:
(Continuing) 25 Q
Mr. Donaldson, have you gotten any recent i
l 17747 4
51901212 1
joswalsh l
1 information, say within the last 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, about the origin 2
of Criterion J.127 3
A (Witness Donaldson)
Yes, I have.
Largely from 4
my viewpoint, in trying to ascertain how much of the 5
original -- my recollection is how much of the original 6
precursor document and the original Rev O,.NUREG 0654 7
appeared in J.12, I reviewed documents, NUREG 0742, FEMA REP-8 4, dated April 1981 entitled " Joint Review of Comments, 9
Criteria for Preparation of Radiological Emergency Response 10 Plans."
11 And, what this NUREG is is a compendium of 12 comments against the original draft NUREG 0654.
- And, 13 essentially what I discovered, much to my chagrin in some L "}
/
14 case, is the fact that criterion K.8 which appeared in Rev 0 15 of NUREG 0654, was through comments transposed to become the 16 first sentence of J.12.
So, that in Rev 1 what now is J.12, 17 Criterion J.12, used to be K.8.
J 18 In addition to that, the 12-hour criterion 19 addition was added but there was no discussion in the 20 comments.
In an attempt for my own edification to clarify 21 where.that happened, I had a discussion with -- I reviewed, 22 I should say, the NRC Staff testimony by Mr. Falkanter had a 23 discussion with Mr. Brian Grimes who is the Chairman of the 24 FEMA Steering Committee at the time to clarify where the 12-25 hour addition came from in that particular criterion, at
51901212 17748 jo;walsh
( )
i which time I was informed that it was a compromise between 2
agencies and opinions as to the need for decontamination and 3
reception centers.
4 And, essentially the points are the following:
5 That, as reflected in Mr. Falkanter's testimony even, the 6
need for monitoring and decontamination was considered to be l
7 one where it was to be an option available to the public
]
1 e
should they desire or want to have confirmatory monitoring; i
9 that the probability of there being contamination was small, io and that if there were contamination it would not be life-11 threatening.
12 In addition to that, the comment was made -- and i3 which I might mention is consistent with our original 14 thinking in the development of the precursor document --
15 that federal assistance would be available as stated by Ms.
16 Dreikorn and Mr. Crocker to assist in this monitoring of 17 individuals should be it necessary or prudent.
18 Mr. Grimes indicated that the thinking of the 19 Committee at the time in adding the 12-hour assistance is I
20 that the 12-hour time frame in their mind would include the 21 fact that federal assistance, DOE and others, would be 22 available in some multiple time frame within that 12-hour 23 Period, such that the 12-hour period for monitoring was not 24 the intent to be solely covered by the state or local 25 agencies -- in this case, LERO -- in that time frame.
]
17740 51901212 joswalsh 1
The final comment that was made is that in 2
considering the numbers of people and the capabilities of 1
3 these areas, is that whdle they did not anticipate that i
4 people would be prepared to house people for long periods of 5
time they did not anticipate that in Criterion J.12 they i
6 would have any problem with people hanging.around for 7
awhile, as it was put, until they could get around to being 8
monitored.
9 Again, I pursued this because I wanted to ensure 10 myself that my recollections and my understandings were 11 consistent as I've stated.
And, I feel that based upon that 12 information that the original precursor document which 13 incorporated an approach to monitoring and decontamination o~
14 of the public is consistent with the current document.
15 I
J 16 17 l
18 19 20 21 22 23 24 25 D
l
.17750 51901313 corysimons I
(
i MR. CHRISTMAN:
Mr. Watts was asking ---
2 JUDGE MARGULIES:
Just one minute.
Excuse us.
)
3 (Board conferring.)
i 4
JUDGE MARGULIES:
It appears that some of this' 5
testimony is new to the parties, and if the interveners 6
request additional time to review this and to further examine Mr. Donaldson on this testimony, we will grant them 7
a an appropriate amount of time to examine this.
9 MR. McNURRAY:
Thank you, Judge Margulies.
I w
think we would like to take you up on your offer.
I saw l
11 that Mr. Donaldson was referring to a document that I don't 12 think I've seen before, and he has also read a lot into the i3 record.
O 14 Unfortunately, I don't think this is something I 15 can do today.
I need to review the transcript and I would also like to review the document that he is referring to.
16 17 After doing that, I will inform the Board is whether I feel -- assuming the Board is not going to in reconsider my motion to keep this information out, I'will 20 the Board and the parties whether I think further cross-1 21 examination is necessary.
Then I expect that you will grant 22 my motion and we can bring Mr. Donaldson back.
MR. CHRISTMAN:
That sounds okay so long as any 23 additional examination is done either tomorrow or next 24 i
25 Tuesday, which is the time set for these witnesses to 1
(:)
i l
l l
51901313 17751 marysimons
([ j 1
appear, and that seems to me a reasonable request since we 2
are going to end it appears two days early in the schedule.
3 MR. McMURRAY:
Well, I'm not even going to have 4
a transcript until tomorrow.
But I do agree that if we try 5
to bring back Mr. Donaldson, it would at a time agreeable to 6
all the parties and to the Board and we could work it out.
7 MR. CHRISTMAN:
May I proceed?
8 JUDGE MARGULIES:
The Board wishes to state that 9
we will remain flexible on this and expect to hear from you, 10 Mr. McMurray, as soon as possible after reviewing the 11 transcript and let us know what you are seeking to have done 12 in this matter.
13 MR. McMURRAY:
Yes, sir, n"
14 BY MR. CHRISTMAN:
(Resuming) 15 Q
Now Mr. Watts was asked a series of questions 16 yesterday about Suffolk County Exhibit 1 and about various 17 down-wind sectors that the wind might be blowing along, 18 particularly I think to the southwest and west.
19 Mr. Crocker, do you have any information about 20 the percent of the time that the wind blows at Shoreham in 21 various directions?
22 A
(Witness Crocker)
Yes, I do.
Bound into 23 Appendix A of the LERO plan, in addition to other Shoreham 24 licensing documents, is a wind rose that depicts the 25 frequency with which in the course of a year the wind blows b
v
17752 1
51901323 marysimons i
()
in a given direction, and it's organized by the same sectors i
2 that were shown on Suffolk County Exhibit 1 with the map of 3
the EPZ.
)
4 The wind direction they postulated went to what 5
we call in the direction of "K".
Basically the wind is from 6
the east / northeast heading westerly through the area of 1
y greatest population, and the frequency with which the wind a
blows in that direction is 4.1 percent of the time in a 9
given year.
10 We have this available.
It's also in the plan 11 itself.
12 Q
Do you have extra copies of that document?
13 A
Yes, we do.
O 14 MR. CHRISTMAN:
Then I will hand out copies of 15 this document and ask that it be marked as LILCO Exhibit 2 16 for identification.
17 JUDGE MARGULIES:
The document will be marked as l
1e LILCO Exhibit No. 2 for identification.
19 (The document referred to was 1
1 20 marked LILCO Exhibit No. 2 for 21 identification.)
22 JUDGE MARGULIES:
Parenthetically, are the 23 Parties supplying the reporter with three copies of each 24 document?
25 MR. McMURRAY:
We have been, sir.
l
17753 51901313 anrysimons
(,
1 MR. CHRISTMAN:
Yes, we'll do that.
They have 2
three copies of this.
3 JUDGE MARGULIES:
You may continue.
4 WITNESS CROCKER:
'che only other remark that I 5
wanted to make was that this frequency was based on a three-6 year period of data collection for wind at.the Shorehsa f
i 7
Meteorological Tower.
So the average is based on three-8 years data.
9 BY MR. CHRISTMAN:
10 Q
When you are looking at wind rose data, what is 11 the appropriate percentage of the time to use for a downwind 12 sector consisting of three 22.5 degree sectors in general?
13 A
(Witness Crocker)
If I understood the question, b'
14 the sector that you use to determine the affected zones is 15 the one that the wind is blowing down.
16 In the case that the County was questioning us 17 about yesterday, you're concerned about the center sector.
18 The ones on each side are just included by virtue of the 19 fact that they are adjacent to that central sector.
20 So those three sectors would be affected 4.1 21 percent of the time.
22 Q
Do you have anything to add to that answer, Mr.
j 23 Watts?
24 A
(Witness Watts)
No, I don't.
I 25 JUDGE SHON:
I have a question to ask.
Winds k >Q V~
1 1
17754 51901313
(
)
are usually named for the direction from which they are 2
- coming, i
}
3 WITNESS CROCKER:
Yes.
4 JUDGE SHON:
Thus the southwest wind would be 5
one coming from the southwest, and yet what we were 6
discussing the other day was a wind that was going to the 7
southwest.
Is that not correct?
8 WITNESS CROCKER:
Yes.
And that's why when I 9
began this discussion I referred to this wind as the to eact/ northeast wind.
That would be the direction it would 11 come from to go west / southwest.
12 JUDGE SHON:
I see.
So on this diagram the 13 convention is reversed; is that right?
If it says SW, it O
i4 means an east / northwest wind or it means a northeast wind.
15 WITNESS CROCKER:
Well, I think the label there 16 is labeling the sector and not the wind direction that would 17 affect that sector.
So that is the west / southwest sector, is and it's affected because there is an east / northeast wind, i9 Surprisingly, the same problem about convention 1
1 20 arises frequently in our training and drill sessions, too.
21 JUDGE SHON:
I just wanted to make certain that 22 the diagram is named for the affected sector and not for the 23 conventional wind direction; is that right?
24 WITNESS CROCKER:
Yes.
25 WITNESS WATTS:
Judge Shon, I might add that O
51901313 17755 cnrysimons
(
)
there is an accompanying Table 1 that goes with that wind 2
rose that I think we have enough copies of that we would be 3
happy to share with you because it does explain the basis i
4 for the p;rrentages and it's labeled as wind toward.
5 JUDGE SHON:
I don't think that's necessary.
I 6
just wantet( to make sure of exactly what the Convention was 7
on this ditgre_m that we were looking at here.
8 WITNESS WATTS:
That's a good question.
9 MR. CHRISTMAN:
If you'll forgive me Judge Shon, t
10 let me ask them if Mr. Watts has an additional sheet that 11 might offer additional or more data on wind direction?
12 WITNESS WATTS:
Yes, I do.
I have a shaet that 13 is to be used in conjunction with the wind rose.
14 MR. JOHNSON:
And you say you do have extra 15 copies of that?
16 WITNESS WATTS:
Yes, I do.
I 17 MR. CHRISTMAN:
And this could be used in 18 conjunction with the wind rose?
19 WITNESS WATTS:
Yes.
20 MR. CHRISTMAN:
Could we have copies passed out 2) to the parties and three copies to the Board.
I'll ask that 22 it be marked for identification as LILCO Exhibit 3.
23 JUDGE MARGULIES:
It will be so marked.
24 25 v
i
1 51901313 corysimons 17756 O
i 2
The document referred to was 3
marked LILCO Exhibit No. 3 4
for identification.)
5 BY MR. CHRISTMAN:
6 Q
Mr. Watts, did you way what LILCO Exhibit 3 came 7
from or what the source of it was, the plan or the 8
Procedures or what?
9 A
(Witness Watts)
It's from Appendix A, Part 2 of 10 the plan.
11 MR. CHRISTMAN:
Judge, I would like to move 12 LILCO Exhibits 2 and 3 into evidence.
13 JUDGE MARGULIES:
Is there any objection?
14 MR. McMURRAY:
No objection.
15 MR. ZAHNLEUTER:
No objection.
16 JUDGE MARGULIES:
They will be admitted as 17 LILCO's Exhibits 2 and 3.
is MR. CHRISTMAN:
Thank you.
19 (LILCO Exhibit Nos. 2 and 20 3,
previously marked for 21 identification, were admitted J
22 into evidence.)
23 BY MR. CHRISTMAN:
24 Q
Mr. Watts, I want to make one clarification of 25 something you said yesterday.
You said that in a plan for o
17757 51901313 cerysimons (j
1 Orange County if a car was contaminated then the passengers 2
were monitored further.
3 Under that same plan if the same car is found to 4
be uncontaminated after the initial monitoring, what happens 5
to the car and its passengers?
6 A
(Mitness Watts)
It's my understanding that the 7
car and the passengers and then free to go to their a
evacuation destination or to go to another portion of the 9
reception centers where they can obtain further information 10 on congregate care and be so~ processed.
11 Q
Mr. Donaldson, you were asked yesterday about 12 whether behavior at Shoreham would be similar to TMI or the 13 same as TMI under similar circumstances, and the record will 0
14 reflect the exact question.
15 Dr. Mileti, what is the likelihood that 16 circumstances at a Shoreham emergency would be similar to 17 the circumstances at TMI?
18 A
(Witness Mileti)
It's inconceivable to me that 19 what happened at Three Mile Island could happen at Shoreham 20 or, to be honest with you, any other nuclear power plant in 21 this country, and there are several reasons why.
22 Q
Why?
23 A
First, we have some pretty good emergency 24 planning regulations that came down the pike since and 25 because of perhaps Three Mile Island, and'specifically
i 17758 51901313 marysimons
()
I because of those regulations we have started emergency 2
Planning to address what is the key or root cause of human 3
behavior in emergencies, namely, emergency public 4
information, and that manifests itself, for example, in 5
terms of having an EBS system, there wasn't one at Three-6 Mile Island, as well as having good emergency broadcast 7
system messages and, as I'm sure everybody in this room a
knows I think very well of Shoreham's emergency broadcast 9
system messages and what-have-you.
10 Therefore, the helter-skelter that occurred at 11 Three Mile Island I don't think has any chance of occurring 12 at a place that has devoted this auch attention to i3 addressing the key determinants of human behavior in ja emergencies, i.e.,
good emergency information.
15 Q
Still with Dr. Mileti, Dr. Linnemann was asked 16 yesterday about people waiting to be monitored and whether 17 they night experience anxiety.
18 Dr. Mileti, to what extent is it necessary to 19 relieve this sort of anxiety?
20 A
Well, first let me say that I think most members 21 of the public who go through any emergency experience i
22 anxiety or stress or~what-have-you.
I would prefer calling it' stress.
23 l
1 24
(
It was never in my mind and I don't believe in i
25 the minds of anyone at LERO to pass out emergency s
_a m
i 17759 51901313 1
information at the relocation center to relieve anxiety 2
because we didn't perceive that anxiety amongst those 3
waiting to get monitored would be a sort that it needed to 4
be addressed at that coint in time.
5 Q
What is the function of that information sheet?
6 A
The function of that information sheet was 7
simply to answer most of the sorts of questions that most of 1
8
.the sorts of people who were arriving at the relocatioc.
a 9
center for monitoring might have in their minds so that less
)
10 time would be spent asking the monitors as they were 11 moniting the public as they were going through and only to
]
12 serve that purpose.
13 Q
Mr. Crocker, when I asked Ms. Dreikorn a few I
Q"i 14 minutes ago about the Krim memorandum and the basis for the 15 20 percent, did you have anything to add to her answer?
16 A
(Witness Crocker). Well, Ms. Dreikorn responded 17 that the 20 percent agrees with her emergency preparedness 18 experience, and I agree it coincides with mine, too.
19 Perhaps I can relate by way of illustration.
20 When I was working in Kentucky preparing 21 emergency plans for several counties, five counties in that 22 State for other nuclear plants, we were working with the 23 State agencies there and the disaster preparedness folks in 24 the State government, they had some trouble with the concept 25 of congregate care and why I was waiving NUREG 0654 at them 4
]
17760 51901313 1
saying we have to do this and we have to make provisions for 2
this.
3 The reason they were having trouble with it was 4
they in the course of normal business routinely responded 5
and dealt with evacuations in particularly eastern Kentucky, 6
in Martin County specifically where there were regular 7
evacuations due to floods and coal mine related problems.
8 They used to set up schools and similar type 9
facilities to receive evacuees and they uniformly found that 10 they had to close them within a few hours because no on ever ti showed up.
12 Given this, it seems that the 15 percent or so u
of the people in the Krim memorandum, that might get cited O
i4 in ASLB hearings in reference to the Krim memorandum 15 requiring congregate care is a conservatively high number.
16 So given that experience, I'm satisfied based on my planning 17 experience and what I have seen in other counties and States is that the 20 percent number is a good, solid planning basis 39 for the monitoring and congregate care.
20 That is basically I was going to add to Ms.
21 Dreikorn.
22 Q
Thank you.
23 Ms. Dreikorn, you were asked yesterday about 24 whether the alarm on the RM-14 could be heard over engine 25 noise and you gave some of your experience.
O j
51901313 17761 mnrysimons f
I What other experience, if any, do you have that 2
might bear on that question?
3 A
(Witness Dreikorn)
The additional experience 4
that I would like to speak of is that instrument being used
)
1 5
very commonly in nuclear power stations and it is often 6
found at the access points to radiation controlled areas.
7 In a nuclear power station you have a lot of I
8 noise that is going on just because of the generation of 9
power, and so you have a lot of ambient noise level.
10 The point I would like to make is in addition to 11 having that general ambient noise present, you can certainly 12 hear the alarm going off on the instruments even at times 13 when you have a large number of people leaving those
(.
14 controlled areas, for example, during an outage period when 15 people are exiting in large numbers and frisking themselves.
16 In addition to the noise of the general 1
17 atmosphere of the power plant, you also have the workers 18 talking among themselves exiting.
So I would like to just 19 add that additional comment.
20 Q
That's fine.
Thank you.
21 Ms. Dreikorn, while I'm still with you, you were 22 interrupted yesterday when you tried to express an opinion 23 about the practice of having reception centers in 24 residential or commercial areas.
25 What information were you trying to provide?
s,
17762 51901313 narysimons O
i i
rn aaitio= 2 >=1== *a
- 1
=t a to
- a 2
we were using the photographs of the three LILCO facilities 3
is that it is a very common practice in New York State and 4
in other States that general public reception centers are 5
designated at facilities such as schools or fire houses, for 6
example, and it is not in common to find these schools and 7
fire houses that are designated as general public reception l
8 centers in residential areas.
9 Q
Mr. Crocker, Mr. Watts said just a little bit 10 ago that LERO could park cars at the three reception 11 centers.
How many parking spaces are there at the three
]
12-reception centers?
j l
13 A
(Witness Crocker)
We did a calculation.
One of O
14 my people went over the site plans for those facilities and 15 came up with the available space that would not interfere 16 with any of the ongoing operations at the facilities, that 17 is surplus space that we had readily available to park cars i
18 that we could not decon immediately.
19 At the three facilities, the numbers that we 20 came up with were in Hicksville, particularly because we 21 have those very large extensive ball fields just south of 22 the facility, we have room for 7,000 cars, and that is based 23 on allowing 120 square feet per car, which is in my mind a 24 reasonably large number.
I think Ms. Dreikorn's car and 25 mine can both fit in that space.
O
17763 51901313 merysimons 1
At Bellmore we came up with the number of 1,670 2
on LILCO property, and at Roslyn we came up with the number 3
of 2,200.
So in total, and let me do a quick calculation 1
4 here, we can handle on our property approximately 10,870 5
cars without interfering with our operations.
6 Q
Dr. Linnemann, you were asked I think a single i
7 question about treating thyroid contamination with potassium 8
iodide.
9 My question for you is under what circumstances 10 would you treat thyroid contamination with potassium iodide?
11 A
(Witness Linnemann)
Generally it is recommended 12 that you expect a thyroid gland to get about 25 or 30 rem 13 total dose from the inhalation of radioactive materials, G-14 then you should block the thyroid gland, and of course the 15 sooner you block it, the better.
16 However, in accidents at nuclear power plants, 17 this problem has been given considerable attention by both 18 Federal, State and non-government organizations, and it is 19 felt not to have potassium iodide available for the general 20 public, but rather to use the mechanism of evacuation to 21 avoid.such doses of potassium iodide, and therefore LILCO in 22 their plan does not intend to give potassium iodide.
23 I might add that is a considerable air 24 environment of iodide to get that kind of a dose.
You would 25 certainly have other probably more immediate problems of 0.'
1 1
51901313 17764
)
mirysimons
]
()
I total body exposure with that kind if an iodine atmosphere.
2 Q
Mr. Crocker, you were questioned about the 3
necessity for making modifications at Roslyn.
I think you a
were asked about gates or something like that.
5 Why is it not necessary to make modifications at 6
Roslyn?
7 A
(Witness Crocker)
There was one question about 8
one gate at one time, about whether we might need to widen 9
it or not, and we tried it and we tested it on two different to occasions and we discovered that several vehicles, two, 11 could go through it side by side at high speed without i
l 12 difficulty.
I'm not talking about 60 miles an hour, but
{
i3 they were moving through at a reasonable clip.
{
O 14 In fact, Mr. Donaldson was driving one of those 15 cars and he made the mistake of leaving his window open and 16 the car next to him went through a puddle and dumped the 17 water in his window.
So it gives you a feel for the speed is with which he was progressing, in Subsequent to that you heard reference to a 20 training session we ran at the Roslyn facility, and we ran j
21 many, many cars through those gates for monitoring, most of 22 the time two abreast, and we had no difficulty with the 23 gates.
So we concluded that no changes were necessary.
2a Q
While I'm with you, Mr. Crocker, you were asked l
I 25 by Mr. Zahnleuter earlier today about possible alternative Ov l
l
51901313 17765 1
facilities for reception centers.
2 Why were the facilities he mentioned not. chosen?
3 A
The facilities he mentioned, i.e.,
the Brentwood 1
4 Operations Center and our relatively new Hauppauge Training 5
Center are committed to other emergency response functions 6
that essentially consume all of the available resources of 7
those facilities.
The Hauppauge Training Center on the 1
8 first floor is our emergency operations facility, which is 9
part of the onsite plan.
The second floor is our emergency 10 news center, again part of both the onsite plan:and offsite.
)
11 The parking area around it we assumed would be 12 consumed by our staff and the media.
)
13 The Brentwood Operations Center houses the EOC i
14 for LERO and the EWDF for the emergency worker decon 15 facility.
There is a lot of parking consumed by the staffs i
16 of those facilities.
In addition, we dispatch things like 17 ambulances out of there.
18 So the potentially available resources we're 19 just already CORaitted to other response functions, i
20 Q
Dr. Mileti, you were asked about the number i
21 144,000 and if that wasn't the nu2ber of. people that 22 evacuated TMI.
23 Why did 144,000 people by one estimate evacuate 24 at TMI?
25 A
(Nitness Mileti)
I would have to say in all
_J
i 17700 51901313 carysimons I~T likelihood the prime would have been that 144,000 or so 1
V 2
people thought it was the right thing to do at the time.
3 That is, their situational perception of risk based on the 4
mix of information that they received at the time led them 5
to reach that as a prudent conclusion for their own 6
behavior.
Those situational perceptions and how those j
7 perceptions are shaped by the kind of emergency information a
that goes out is the same sequence of cause that would l
9 determine, for example, most public response to emergencies, 10 including, for example, going to seek monitoring.
11 The root of both, if you will, evacuation 12 behavior or seeking out of monitoring would be the same.
13 Q
Well, Dr. Mileti, you sa$d at transcript 17,479 14 when asked about the advisory to evacuate at TMI that the 15 advisory had gone out as well as a lot of public
)
16 information.
17 What other public information were you talking i
is about?
)
19 A
The public information that went out during 20 Three Mile Island that I would point to could fill half a 21 book, but significant bits of information went to the public 22 beyond the Governor's advisory to have pregnant women and 23 pre-school age children evacuate.
24 For example, civil defense of so.?ts, the j
25 director of something, and I've forgotten the jurisdiction, O
1
L l
17767
)
51901313 marysimons I
was on the media talking about the potential evacuation of a 2
10-mile area around the reactor.
3 There was also information about a potential i
l d
evacuation at 20 miles around the reactor.
The Catholic 5
Church granted general absolution of sins for people living 6
in the greater Harrisburg area, which is significant risk' 7
information for even Moslems and Jews, et cetera.
8 In addition, the Nuclear Regulatory Commission 9
or one of its employees claimed that in a day or two there 10 could be a core melt and that a hydrogen bubble could 11 explode leading some people in there to conclude that an 12 explosion could occur in their minds similar to a nuclear 13 bomb explosion.
O 14 In other words, the kind of information that 15 went to the public from very reputable sources was mixed, 16 and to just single _out one piece of reputable information' 17 and use that as the standard by which to judge public is response I think is unfair and inappropriate.
')
J 19 I think the public at Three Mile Island behaved 20 in ways consistent with their perceptions of risk, and I've 21 always said that more than 144,000 people didn't evacuate.
22 23 24 25 1
i l
17768 51901414 cunwalsh 1
MR. CHRISTMAN:
I think the Board is being 2
addressed.
3 (A spectator is speaking.)
d JUDGE MARGULIES:
We are not taking public 5
witnesses at this time.
We have not scheduled public 6
witnesses for this entire session.
7 You certainly are very welcome to attend and to 8
listen, but we don't have witnesses scheduled.
9 SPECTATOR:
Do you anticipate that in the near 10 future?
j 11 JUDGE MARGULIES:
No.
We made the decision not 12 to hold limited appearances in connection with this hearing 13 session.
1d SPECTATOR:
They should have said that on the 15 radio.
16 BY MR. CHRISTMAN:
(Continuing) i I
17 Q
Dr. Lindell, I have a fairly minor question I 18 think.
At Transcript 17502, you were questioned about 7
19 physicial cues as a source of warning confirmation in 20 emergencies.
And, you said I believe they are not the only 21 source of warning confirmation.
22 So, what are some of the other sources?
23 A
(Witness Lindell)
Well, the other sources of 2d warning confirmation are social sources.
That is, if 25 somebody hears about the fact that an emergency is in O
17769 i
51901414
)
cuewalsh I
progress, if they hear it via a friend, relative or 2
neighbor, that they can turn to the EBS if they haven't 3
heard, for example, the siren.
Or, vice-versa, if they've 1
d heard the siren and want to confirm the information through 5
listening to the EBS or listening to the news media, 6
television or radio anyone of a number of other sources.
7 Q
And, while we are still talking about physical 8
cues, on the same page of the transcript, 17502, when you 9
were talking about physical cues and spider warts and things 10 like that, are there other physical cues that might be used j
by the public in a radiological emergency other than the j
12 ones that you talked about yesterday?
13 And, what are they, if so?
)
Id A
Those are the primary ones.
And, the -- but, I
{
15 think that the point about the absence of physical cues to 16 radiation hazard is somewhat overdrawn, because there are 17 other kinds of hazards in which there might not be physical 18 cues.
For example, with hydrogen sulfite which does have a 19 very distinctive odor when it reaches lethal concentrations 20 it overcomes the old factory sense and so you can no longer 21 smell it when it reaches a lethal dose.
And, so that's -- I 22 don't think that that is -- that radiation hazard is l
23 necessarily distinctive in that respect.
i 24 Q
Thank you.
Dr. Mileti, at 17521 of the i
25 transcript you were asked questions about the relocation l
I 4
-____A____-.___-__u
51901414 177'O cuswalsh I
centers of Hershey during TMI, and you said they were used 2
for sheltering and they also had other capacities.
3 What other capacities did you mean?
d A
(Witness Mileti)
The Hershey Medical Center had 5
food in it, hot dogs I know.
A lot of people -- I saw
)
6 pictures of hot dogs, let me put it that way.
And, as I l
7 recollect they also had the capacity to -- although not a 8
sophisticated capacity -- provide water for outside 9
decontamination of people should anybody show up seeking 10 that, with a garden hose literally, defined as having that 11 function.
12 MR. CHRISTMAN:
Thank you.
If you will indulge 13 me for just a minute while I read about three or fear lines 14 of my notes.
1 15 JUDGE MARGULIES:
Yes.
16 (Pause.)
l 17 BY MR. CHRISTMAN:
(Continuing)
IB Q
Dr. Lindell, I seem to recollect and have 19 written down that on Page 17523 of the transcript you said 20 that people acted on their perceptions of risk based on the 21 information that they have at the time.
i 22 How do they do that?
How does that process 23 work?
24 A
(Witness Lindell)
Well, what happens is that my 25 research and that of others suggests that people do have O
1777I 51901414 cu:;walsh I
some beliefs about radiation hazard as well as about other 2
hazards.
In the process of making their decision in an 3
emergency that they look for certain kinds of information in d
the nature of physical cues or in the nature of information 5
that's received from other sources or they actively seek out 6
information from other sources.
7 That winds up being the basis for their 8
assessment of the threat; that is, of the consequences of taking no action whatsoever.
Now, that's different from 10 their perception of the consequences of taking an action.
II In order to make a decision to take no action, 12 to prepare to evacuate, to shelter or to evacuate, what they 13 do is look at their perception of the consequences of taking j
(,-.
Id no action and then balance off against that the consequences 15 of taking a particular action like evacuation, so that if 16 they assumed that there would be no action or that the 17 consequences of no action would be that they might 18 experience a life-threatening dose of radiation and that 19 there are few or no barriers to evacuation, there are few or j
- o no costs, and that evacuation would be a very effective 21 response alternative, then they are liable to evacuate.
22 On the other hand, if they believe that they are 23 in little or no risk and that there are barriers to 24 evacuation or that it would be costly, that they are 25 unlikeJy to evacuate.
That makes a big difference as to how d
1 i
i f
1 E
_j
51901414 17772 nuswalsh.
()
I people respond or between how people respond in an emergency 2
and how they say they might respond in response to an 3
opinion poll prior to the emergency.
d Prior to the emergency, all they have is 5
information about the consequences or the potential 6
. consequences of taking no action.
That kind of information 7
tends to be fairly unreliable.
It can be reliable.
B Behavioral intentions data can be reliable.
In-9 some cases, for example, in voting intentions there can be 10 up to as much as about an 80 percent correspondence between 11 people's intentions to vote for a particular candidate and 12 their actual voting behavior.
In other kinds of 13 circumstances, there has been found to be no correspondence O
14 whatsoever between intentions and behavior.
15 And, that's because the people who did the study s
16 looked only at the consequences -- in this case, it would be 17 the consequences of taking no action and did not look at the 18 consequences of taking action as well.
19 So, that you have this problem in looking at 20 evacuation intentions data of trying to decide where in that 21 range from no predictive validity whatsoever to 80 percent 22 predictive validity that your data would suggest that you 23 would be.
And, it's my belief based on my research doing --
2d collecting information on public perception of risk as well 25 the -- as public perception of risk in a non-emergency O
17773 i
51901414 i
auswalsh I
situation as well as public perception of risk in an 2
emergency situat' ion that assessments of public perception of' 3
risk or that public intentions to evacuate in response to a d
particular scenario are much different from their 5
perceptions of risk, very different from their intentions to 6
evacuate or their actual evacuation behavior in a real 7
emergency.
i 8
Q And, how does what you have just told us relate l
9 to people going in for monitoring for radiological 10 contamination?
II A
Well, I think as Dr. Mileti said that the same 12 principals apply in speaking about intentions to evacuate 13 q
and intentions to seek monitoring.
What is likely to happen Id is -- if you say that there are some people at risk that is have been advised to go in for monitoring, then that makes 16 salient the fact that there is a possibility'of exposure.
17 Now, what happens in an actual emergency is that 18 the behavior may be very different from that.
In an 19 emergency, what will be salient not only is the potential 20 hazard from the release of radioactive material but also the 21 inconvenience of going in.
If there are people in line, 22 people will balance off.
There is going to be a conflict 23 between the possible negligible perception of risk and the i
24 inconvenience of standing in line to get monitored if there 25 is any kind of line at all.
i 17774 s19o1414 cunwalsh
()
1 During an emergency, people will balance those 2
off and make what they consider to be a reason to action.
i 2
Q Mr. Donaldson, yesterday at Page 17525 of the d
transcript you -- I alluded to this earlier.
You talked 1
5 about people at Shoreham acting similar to those at TMI 6
under similar circumstances.
And, you were asked about 7
whether what you said about that in your deposition was 8
unqualified or not.
9 What's the significance of the fact that it was 10 unqualified in your deposition?
11 A
(Witness Donaldson)
Well, I think the fact that 12 it was unqualified relates to what Dr. Mileti had said, that 13 in similar situations where they act similarly I say yes, O
14 because in the absence of proper information they would be, 15 as Dr. Mileti pointed out, expected to act that way.
16 If we are talking about the Shoreham situation
!7 as opposed to Three Mile Island then the answer would be, of 18 course, different.
19 MR. CHRISTMAN:
Thanks.
Now, Judge, I have one 20 more question to ask.
And it will prompt an objection.
21 (Laughter.)
22 And I will tell you what the question is going 23 to be.
The question is going to be for Dr. Lindell -- and 2d Dr. Lindell, as you know, has sat here patiently for a day 25 and a half and has been asked almost nothing.
We brought O
l i
17775 51901414 auswalch rN)
I him here at considerable cost and time and money so that he s.
2 could give you his opinions.
3 Now, he hasn't been allowed to do that, because d
he wasn't asked any questions, essentially no questions.
5 And, what I would like to ask Dr. Lindell is what is his 6
opinion of the County witnesses' interpretation of his 7
life's work.
8 I believe that's a proper question, and I 9
believe it's a very important question and that this Board 10 needs to have that on the record to make its decision.
I II would like to ask that question now.
12 MR. McMURRAY:
Well, I do object.
13 77 (Laughter.)
U 14 It will be no surprise to the Board.
But, this 15 is outside the scope of our cross-examination.
I realize, 16 Judge Margulies, this is an administrative hearing but there 17 have got to be some rules.
If I haven't asked any questions 18 about a particular topic, Mr. Christman just can't go and 19 supplement the record and let Dr. Lindell or any other 20 '
witness give a speech about what he would like to tell the 21 Board.
22 Now, I understand that Dr. Lindell has come a 23 great distance and he's a witness.
That's what he is paid 24 to do, come a great distance and if he's asked questions to 25 answer them.
b U
51901414 outwalsh
()
1 But, LILCO can simply not supplement the record 2
at will.
There have got to be some rules.
3 MR. CHRISTMAN:
Well, let me say that in the.
4 alternative I believe that the Board should rule that the --
5 all that testimony by other people about what Dr. Linde11's 6
research means should not be relied on for any opinion in 7
this case.
It should be regarded as of no probative value 8
whatsoever.
9 And, unless you really -- I mean, if you really 10 want a meeting of the opinions of the experts, then you j
11 should allow that question to be asked.
12 MR. McMURRAy:
Let me make one other point, I
13 Judge Margulies.
We submitted our testimony with Dr. Cole's O
14 comments on Dr. Linde11's work I believe on April 15th, 15 somewhere around there.
16 After that time, the parties all had the i
17 opportunity to submit rebuttal testimony on all the direct 18 testimony that had been submitted to that date.
The County 19 took that opportunity and submitted rebuttal testimony by 20 Mr. Minor and Mr. Sholly discussing the NRC's testimony.
21 LILCO took that opportunity to address Dr.
22 Hartgen's and Mr. M111spaugh's testimony.
I believe the i
23 State took that opportunity to address Mr. Lieberman's 24 testimony.
25 LILCO apparently made a tactical choice not to a
17777 51901414 sunwalsh i
I j
submit rebuttal testimony by Dr. Lindell on the comments
)
2 made by Dr. Cole.
Now, LILCO has made that choice.
LILeo 3
should have to live with that choice.
d MR. CHRISTMAN:
That argument makes a great deal 5
of sense if we were practicing a trial in the old days when 6
it was trial by -- trial as a game or trial as a contest.
j 7
But, this one question that I propose to ask is designed to 8
provide important data that any Administrative Board, any 9
expert Board, should have before it when it makes its final 10 decision.
II And, my basic point is that the evidence is 12 necessary to use to make a judgment about the evidence.
13 JUDGE MARGULIES:
Does the Staff wish to be Id heard?
l l
15 MR. JOHNSON:
One second, please.
16 (The Staff counsel are conferring.)
17 MR. JOHNSON:
I believe there is some cogency to 18 both sides of the argument that we've heard.
And, I think 19 that the principal objection to allowing the testimony to go 20 forward in this matter is a prejudice that may be possible 21 to Suffolk County.
22 And, it seems to me that if the Board determines 23 that there is probative evidence and it would like to hear 24 that, that Suffolk County be given an opportunity to cure 25 any prejudice that may result from the supplementation of b
51901414 1777g cucwalsh
()
I testimony.
2 MR. ZAHNLEUTER:
May the State be heard?
3 JUDGE MARGULIES:
Certainly.
d MR. ZAHNLEUTER:
The State supports the County 5
in this matter.
And, the rules are the rules.
And, if we 6
disregard the rules we will open this hearing up to a free-7 for-all where all parties will probably seek to have the 8
same advantage in the hearings.
9 I suggest that regardless of what has happened 10 in the old days or what might happen in the new days, the 11 rules are the rules and not allow Dr. Lindell to supplement 12 his testimony today.
13 MR. CHRISTMAN:
Let me say something if I may, fs 14 one more thing.
This is sort of a unique case I think, in 15 that you've got some experts and some expert witnesses on 16 both sides.
And, you've got one party characterizing and 17 trying to rely on their interpretation of the other party's 18 witnesses.
If you do not allow that other party's witness 19 to explain whether he agrees with the characterizations of 20 his own work, you just don't have a basis for relying on 21 those characterizations, you just can't do it reliably.
22 JUDGE MARGULIES:
We will take our 15 minute 23 recess at this point and probably come back with an answer.
24 MR. CHRISTMAN:
Maybe we can have that other l
25 information for you at that time.
O w_.__-_________
51901414 1777g zuewalsh I
(Whereupon, a recess is taken at 3:00 p.m.,
to 2
reconvene at 3:15 p.m.,
this same day.)
3 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 D
17780 l
51901515 l
joswalsh 1
(3:15 p.m.)
l 2
JUDGE MARGULIES:
Back on the record.
The. Board 3
has carefully considered the Motion of the Applicant, and l
l d
all the arguments made in support and against it, and
)
5 concludes that the Motion shall be denied.
6 This is not a situation where the parties have 7
been playing cat and mouse, and the Board has been denied 8
information.
This proceeding has been a very well crafted 1
9 proceeding, giving all the parties a very liberal l
l 10 opportunity to make their cases on direct and in filing 11 rebuttal.
12 Applicant still has the opportunity to cross 13 examine Intervener's experts at length.
They haven't even 14 arrived at that point.
It would be highly improper to open 15 up the case at this point to permit Mr. Lindell a broadside 16 when we don't know what cross examination wi.11 show.
17 The Board will deny the Motion at this time.
18 The Applicant has the opportunity of making the Motion again 19 later in the proceeding if it deems it to be appropriate.
l 20 By permitting the Applicant to again f11e the Motion, that 21 does not indicate in one form or other as to what action the 22 Board will take.
23 It would best be filed at the conclusion of the 2d cross examination of the Intervener's witnesses, and it 25 should be in writing.
O
l 177b1 51901515 joswalsh I
MR. CHRISTMAN:
Thank you, Judge.
Since you 2
denied the Motion, for the purposes of appeal if necessary, 3
let me make an offer of proof and say that if we were d
allowed to put on this evidence at this point, I think Dr.
5 Lindell would testify that the Intervener's witnesses have 6
misinterpreted some of his research.
7 JUDGE MARGULIES:
Does that conclude your 8
redirect?
i 9
MR. CHRISTMAN:
Yes.
I have no more questions.
10 MR. McMURRAY:
There is the matter of the data.
II I don't know what LILCO has at this time.
12 MR. CHRISTMAN:
Yes, I forgot about that.
We do 13 have some data, and let's see if it is satisfactory.
O V
Id Mr. Crocker or Mrs. Dreikorn either one, can you 15 tell us what you found out in trying to answer Mr.
16 McMurray's question?
17 WITNESS DREIKORN:
The information that I have i
18 is based on the numbers of staffing that we needed at the
{
19 Nassau Coliseum, and now the numbers that we need of Rad 20 Monitors for the Hicksville, Bellmore, and Roslyn 21 facilities.
For the FEMA exercise of February 13th of
'86, 22 we needed 180 radiation monitoring personnel to staff that 23 facility for 150 percent staffing.
)
24 We now need 293 radiation monitoring 1
25 decontamination personnel for the three LILCO facilities, ti 1
i 17782 51901515 joswalsh (3)
(,
That change that has occurred is 113 individuals; 113 rad 1
2 monitor personnel.
That difference, the actual number, 3
percentage wise to the total number that we need now for d
Hicksville, Bellmore, and Roslyn, is at 38.5 percent 5
difference.
What that doesn't take into account is of the j
t 6
original 180 personnel assigned to Nassau County Coliseum, 7
the small number of people that may have left and been 8
replaced by new individuals in radiation monitoring titles.
9 Also, you requested a time frame for that to change.
The best time frame I can provide you is soon after il the Nassau Coliseum was withdrawn from our plan, which 12 occurred in June of 1986, LILCO recognized the need to 13 utilize its own facilities as monitoring decontamination f_,d 14 locations for the general public.
As soon as that need was 15 recognized, we began signing up new LERO workers in 16 monitoring and decontamination titles for these reception 17 centers, and based their location of assignment on their 18 home proximity to those locations.
19 MR. McMURRAY:
That is fine, Judge Margulies.
20 JUDGE MARGULIES:
You may continue with recross.
21 MR. McMURRAY:
I have no recross, sir.
22 MR. ZAHNLEUTER:
I have one question.
]
23 RECROSS EXAMINATION i
24 BY MR. ZAHNLEUTER:
25 Q
Mr. Crocker, has LILCO ever conducted a study to O
i
17783 51901515 I
determine the feasibility of using the Brentwood facility as 2
a reception cent'r?
e 3
A (Witness Crocker)
Not to my knowledge.
For as d
long an I have been involved in LERO, it has been the EOC 5
plus the other functions I named, and we have left it that 6
way.
7 MR. ZAHNLEUTER:
Thank you.
1 8
MR. JOHNSON:
The Staff has no recross.
9 JUDGE MARGULIES:
Is there anything --
10 (Board members confer.)
U JUDGE MARGULIES:
The Board has no questions of 12 the panel.
The only matter we have left is the matter of l- - - -
13 possible cross examination of Mr. Donaldson on J-12 and its Id evolution 15 Mr. Donaldson will be subject to recall on that 16 sole ground, that limited area, and otherwise the Board --
17 or the panel is dismissed.
Thank you.
18 WITNESS PANEL STANDS ASIDE.
19 JUDGE MARGULIES:
Is these any way of working 20 out at this time when Mr. Donaldson can come back.
When it 21 will be appropriate.
1 22 MR. McMURRAY:
As I understand it, he is not 23 available on Tuesday, is that right, and in any event I 24 haven't been able to review the documents.
25 MR. CHRISTMAN:
Maybe we can go off the record d
l 1
51901515 jorwalsh I
and ask him if he is available on Tuesday.
2 JUDGE MARGULIES:
Off the record.
3 (Off the record discussion ensues.)
d JUDGE MARGULIES:
Back on the record.
The 5
parties have concluded that part of the examination that 6
they expected to complete by Tuesday of next week.
7 In that there is nothing further to be heard by 8
the Board tomorrow or on Tuesday, we will recess this 9
hearing until Wednesday morning at 9:00 o' clock.
10 (Whereupon, the hearing adjourned at 3:00 p.m.,
11 Wednesday, July 1, 1987, to reconvene at 9:00 a.m., on 12 Wednesday, July 8, 1987.)
14 15 16 17 18 19 20 21 22 23 24 25 0
CERTIFICATE OF OFFICIAL REPORTER O
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING:
LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
DOCKET No.:
50-322-OL-3 (Emergency Planning)
PLACE:
HAUPPAUGE, NEW YORK C\\
DATE:
WEDNESDAY, JULY 1, 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Cossaission.
t (siet
, M, (TYPED)
MARY C. SIMONS Official Reporter ACE-FEDERAL REPORTERS, INC.
Repo ter's Affiliation s' n
/
GARRETT J.
ALSE hu m MYRTLE SUE WALSH
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ -