ML20234F596
| ML20234F596 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/30/1987 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#387-4020 OL-3, NUDOCS 8707080272 | |
| Download: ML20234F596 (208) | |
Text
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1 RGB L' UNITED STKrES lO NUCLEAR REGULATORY COMMISSION
_ . _ _a r .
IN THE MATTER OF: DOCKET NO: . 5 0-3 2 2-OL-3 LONG ISLAND LIGHTING COMPANY (Emergency Planning)
(Shore' nam Nuclear Power-St.ation , Unit 1) l 0 -
LOCATION: MAUPPAUGE, NEW YORK PAGES: 17403 - 17609 DATE: TUESDAY, JUNE 30, 1987 9 . is \
q,.4 s
0 I i
l ACE-FEDERAL REPORTERS, INC.
Oficial Reporters 444 North Capitol Street i j gg?70007:m 070d>30 Washington, D.C. 20001 7 AI)DCX 05000 ,;,
(202)347-3700' l
' NATIONWIDE COVERACE
1 51800000-
'marysimons 17403 i
'1 UNITED STATES OF AMERICA
]
2 WUCLEAR REGULATORY COMMISSION l
4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5
6 -----------------------------------X q l 7 In the Matter of: :
8 LONG ISLAND LIGHTING COMPANY : Docket No. 50-322-OL-3 9 (Shoreham Nuclear Power Station, :
ic Unit 1) :
ij
__________________________________.x 12 Court of Claims i
13 State of New York 14 State Office Building 15 Third Floor Courtroom 16 Veterans Memorial Highway i
17 Hauppauge, New York 11788 1B Tuesday, June 30, 1987 19 The hearing in the above-entitled matter 20 reconvened, pursuant to notice, at 9:15 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 o
- -- o
51800000 17404 marysimons f 1 JERRY R. KLINE, Member
)
2 Atomic Safety and Licensing Board i 1
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 J B Bethesda, Maryland 20555 9 APPEARANCES:
10 On Behalf of Lonc Island Lichting Company:
11 JAMES N. CHRISTMAN, ESQ.
12 MARY JO LEUGERS, ESQ.
13 STEPHEN W. MILLER, ESQ.
O-14 Hunton & Williams
- 15 707 East Main Street 16 P. O.-Box 1535 17 Richmond, Virginia 23212 18 On Behalf of Suffolk County:
19 CHRISTOPER M. McMURRAY, ESQ. I 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 ,
l I()
i
17405 51800000 marysimons
/]} 1 On Behalf of the State of New York:
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. BACHMANN, ESQ.
I 11- U. S. Nuclear Regulatory Commission
]
12 7735 Old Georgetown Road 13 Bethesda, Maryland 20814 u ,
15 I
18 l l
19 20 21 22 23 2A 25 O
51800000 17406 marysimons l
1 C0NTENTS 2 Direct Cross Redirect Recross Voir-Dire !
3 DENNIS MILETI 4 MICHAEL LINDELL 5 ROGER LINNEMANN 6 DOUGLAS CROCKER 7 DIANE DREIKORN g RICHARD WATTS 9 DALE DONALDSON 17413 17422 10 EXHIBITS ti Identified Admitted 12 Suffolk County Exhibits i3 No. 1 17458 17468 14 No.-2 17462 17468 15 No. 3 17463' 17468 16 No. 4 17503 17547 3
17 No. 5 17509 17547 18 No. 6 17529 17547 19 No. 7 17531 17547 ,
i 20 No. 8 17537 17547 21 No. 9 17539 17547 22 LILCO Exhibits 23 No. I 17421 17421 24 Morning Recess.................................. 17451 25 Luncheon Recess................................. 17493 Afternoon Recess................................ 17542
51800101 suewalsh O i PaOCssoznGS 2
(9:15 A.M.)
3 JUDGE MARGULIES: Please come to order. Good d
morning. This hearing is part of the application proceeding )
l 5
in which the Long Island Lighting Company seeks an operating .
6 license for Unit 1 of the Shoreham Nuclear Power Station. l 7
The Shoreman facility consists of a boiling 8 water reactor with a rated electrical output of 820 9
megawatts. It is located in Brookhaven, New York which is 10 in the north central part of Long Island.
11 This Licensing Board heard the issues concerned 12 with the off-site emergency plan for Shoreham. In a 13 concluding Partial Initial Decision of August 26th, 1985 14 this Board found that there is no reasonable assurance that 15 adequate protective measures can and will be taken in the 16 event of a radiological emergency at Shoreham and that no 17 operating 11 Cense should be issued for the nuclear power 1B reactor.
19 Our decision was appealed by Applicant and those 20 parties opposing the granting of a license. As a result of 21 those appeals, this Board has had a number of issues 22 remanded to us for further hearing. One of those issues 23 that was remanded involves the subject of this hearing, the 24 suitability of reception centers.
25 In the case of a radiological emergency, the O
l 1
17408 I 51800101 suewalsh I
monitoring and decontamination of evacuees is to take place 2
at reception centers. At the time of the former hearing, 3
the Nassau Veterans Memorial Coliseum at Nassau County was to serve as Applicant's reception center.
5 In remanding the matter of the adequacy of the i 6
reception centers to us, the Commission's. Appeal Board in i'
7 the decision of March 26th, 1986 styled "Long Island 8
Lighting Company, Shoreham Nuclear Power Station, Unit 1, I
ALAB 832, 23 NRC 135," said we were to determine whether 10 there were any factors that might make that facility )
II unsultable to serve as a reception center for emergency 12 planning zone evacuees. With the Nassau Veterans Memorial 13 Coliseum becoming unavailable f or use by LILCO, the 1
"~
Id Applicant moved to reopen the record for the purpose of 15 permitting a substitution for the Coliseum with three of 16 LILCO's own facilities, the Hicksville, Bellmore and Roslyn 17 operation centers.
18 In a Memorandum and Order, dated December lith, 1 1
19 1986, we granted Applicant's motion to reopen the record on i 20 the matter of the substitution and further found that the 21 issues raised in the reopened proceeding encompassed all of 22 tne issues contained in the Appeal Board's remand of the 23 Coliseum matter in ALAB 832.
24 This hearing shall decide all of the issues 25 raised by the reopening of the record and by the remand of
l 17409 51800101-suewalsh O ' the ^vvee1 soera- Tae ecoge or en1e proceea1=e.~ee aet1=ea i 2
in our December lith Memorandum and Order.
3 We shall now take appearances. Who appears for
{
d the Applicant?
5 MR. CHRISTMAN: Thank you, Judge. My name is 6 James N. Christman of the law firm of Hunton & William, j 7 P. O. Box 1535, Richmond, Virginia 23212. With me is i 8 Stephen W. Miller on my right; and Mary Jo Leugers of the 9
same firm. We represent the Applicant, the Long Island 10 Lighting Company. I 11 JUDGE MARGULIES: Who represents Suffolk County? i 12 MR. McMURRAY: Judge Margulies, my name is 13 Christopher McMurray. To my left is David T. Case. To his O- 14 left is Ronald Ross.'
15 JUDGE MARGULIES: Who appears for New York 16 State?
17 MR. ZAHNLEUTER: My name is Richard J.
IB Zahnleuter. And, I represent the Governor and the State of 19 New York.
l 20 JUDGE MARGULIES: Are there any other j l
21 appearances for Interveners?
22 MR. McAURRAY: No, sir. j 23 JUDGE MARGULIES: Who appears for Staff?
24 MR. BACHMANN: Judge Margulies, my name is l 25 Richard George Bachmann. I represent the Staff of the O
I
1 I
I 51800101 17410 suewalsh l
I United States Nuclear Regulatory Commission. On my left is 2
George E. Johnson, who has also filed a notice of 3
appearances in this proceeding, d
JUDGE MARGULIES: There are several preliminary 5
matters the Board wishes to take up before we start hearing
]
6 from the witnesses. The first is the proposed schedule for 7
hearing of June 23rd, 1987 agreed to by all of the parties.
8 The Board is well satisfied with the proposed 9
schedule and will endeavor 'o implement it. We do wish to 10 make it clear it is the Board's responsibility to regulate the course of the hearing; and, in following the proposed 12 schedule it should be understood we are not abrogating our 13 responsibility to direct the course of the proceeding.
"~
id Circumstances may require that in order to 15 properly manage the case, there might be a need to depart 3
16 from the sche-3ule. If so, we will take whatever action is l U l necessary when the time arises and exercise our '
1B responsibilities as set out in 10 CFR 2.718 and 2.757.
19 On May 29th, 1987, LILCO had filed a motion to 20 set a firm schedule. The schedule we now have renders the 21 motion moot. Therefore, the Board now dismisses the motion i 22 for mootness.
23 The next matter the Board wants to discuss is 24 LILCO's May 5th, 19 87 motion to limit cross-examination by 25 New York State and Suffolk County. The motion was filed
51800101 17411 suewalsh
() I both in this proceeding and in the OL-5 case. Stating the 2
matter succinctly, it would limit Interveners to conducting 3
redirect examination of each other's witnesses rather than d
permitting cross-examination. Additionally, it sought to 5
have Interveners use one person to cross-examine on i 6
Contentions EX-15 and EX-16 in the OL-5 proceeding.
7 Applicant is supported by Staff and is opposed 8 by New York State and Suffolk County. LILCO sought leave to 9
file a reply to the State and County responses on the basis 10 of their alleged incorrect representations as to the nature 11 of the OL-5 Board's May 13th, 1987 ruling on the 12 consolidation of the Intervenor's on Contentions EX-15 and 13 EX-16.
14 The Board finds no need for LILCO to file a 15 reply based on the action in the OL-5 proceeding in which 16 the Board took action in regard to the consolidation. The 17 l requested consolidation of the parties was a matter only i 18 involved in the OL-5 proceeding and is not materially 19 significant to this case.
20 The issue here is whether Interveners should 21 have their right to examine restricted. Having reviewed the 22 filings and the arguments of the parties, we conclude that 23 the record does not support a showing of past or potential i 24 abuse by Interveners so as to require consideration of 25 limiting their right to cross-examination.
O
51800101 17412 suewalsh i I i I
As a consequence of that determination, the
'(]
2 Board denies Applicant's motion of May 22nd, 1987 to limit 3
c ross-examination . This ' action is taken without prejudice d
to Applicant renewing the motion should it believe such 5
abuse is present during the course of the reopened 6
proceeding.
7 Is the Applicant ready to proceed at this time?
8 MR. CHRISTMAN: Yes, sir, we are.
9 JUDGE MARGULIES: I would like to swear in the M panel. Would the members of the panel that are about to II testify please rise? Would you raise your right hands?
i 12 (The panel of witnesses are sworn by Judge I3 Margulies.) '
~'
Id MR. CHRISTMAN: Thank you, Judge Margulies. i 15 Whereupon, 16 DENNIS MILETI, I7 MICHAEL LINDELL, I8 ROGER LINNEMANN, l9 DOUGLAS M. CROCKER, 20 DIANE P. DREIKORN, j 21 RICHARD WATTS 22 and I 23 DALE DONALDSON 24 were called as witnesses by and on behalf of the Applicant, 25 the Long Island Lighting Company, and having been first duly i
i l
1 1
51800101 17413 suewalsh
() I sworn, were examined and testified as f ollows:
2 DIRECT EXAMINATION 3
BY MR. CHRISTMAN:
d Q I will ask each of the witnesses who have 5
already taken the stand to identify themselves by name and 6
occupation starting with Dr. Mileti who is at the position I
7 farthest from the Board. !
l 8 A (Witness Mileti) My name is Dennis Mileti. I'm l 9
a Professor of Sociology at Colorado State University.
10 (Witness Lindell) My name is Michael Lindell.
11 I'm a Professor of Psychology. I will be at the Michigan 12 State University in the Fall.
13 (Witness Linnemann) My name is Roger s-14 Linnemann. I am a physician and radiologist, President of {
l 15 Radiation Management Consultants and the Associate Professor '
16 of Radiology at the University of Pennsylvania School of j 17 Medicine.
18 (Witness Crocker) My name is Douglas Crocker.
19 I am the Manager of Nuclear Emergency Preparedness for Long 20 Island Lighting Company.
21 (Witness Dreikorn) My name is Diane Dreikorn.
22 I am a Senior Emergency Planner with the Long Island 23 Lighting Company.
24 (Witness Watts) I am Richard J. Watts. I'm a 25 Health Physicist and Emergency Planning Consultant,
i 1
17414 51800101 suewalsh I
President of Richard J. Watts, Incorporated.
]
2 (Witness Donaldson) My name is Dale Donaldson, 1
3 Health Physicist and Manager in the Radiological Engineering i d '
Services Division for Hydronuclear Services, a subsidiary of 5
Westinghouse Electric. I I
6 MR. CHRISTMAN: Thank you. Let me show the 7
witnesses a document dated March 30, 1987 of 62 pages. It 8
l is entitled, as it has been marked up, " Written Testimony.of 9
Douglas M. Crocker, Dale E. Donaldson, Diane P. Dreikorn, 10 Edward B. Liebermann, Roger E. Linnemann, Michael K.
II Lindell, Dennis S. Mileti and Richard J. Watts on the 12 Suitability of Reception Centers."
13 And, I should note for the record, Judge, that
" ~~
Id this is the marked up version that we sent out to parties on 15 June 19th, so it shows the errata that we had identified at i 16 least as of that date.
" Let me show the witnesses and identify for the 18 record a set of attachments A through T, about two inches in 19 thickness. And, let me note for the record, Judge, that we 20 have substituted for the old Attachment A which was Mr.
l 21 Daverio's resume two attachments, A-1 and A-2 which are the l 22 resumes of Douglas M. Crocker and Diane Dreikorn who have 23 been substituted for Mr. Daverlo.
24 BY MR. CHRISTMAN: (Continuing) 25 Q And, let me ask you if those represent your
17415 51800101 suewalsh
) I testimony in this proceeding and if they were prepared by 2 you or under yo'ur direction and supervision?
3 You can all answer.
d A (Witness Crocker) Yes, they do.
5 (Witness Dreikorn) Yes.
6 (Witness Watts) Yes.
7 (Witness Donaldson) Yes.
8 (Witness Mileti) Yes.
9 (Witness Lindell) Yes. l l
10 (Witness Linnemann) Yes. t i
11 MR. CHRISTMAN: And, Judge, I have two addenda, 12 if you will, to the testimony and attachments. I have one l
{} 13 14 document called " Addendum" which has the text of the revised Question and Answer 67 which -- the text of which is I 15 identical to the version I sent out in my letter of I think l l
16 June 24. I would like to hand out copies of that addendum 17 to the Board and parties in just a moment, it I may.
IB I also have two draft maps of the Roslyn 19 reception center showing the addition of two monitoring 20 stations, 30 and 31, in the southeast corner and slight 21 relocation of Stations 9 and 10 which is consistent with the 22 marked up errata that we showed on the testimony that was 23 sent out June 19th.
2d I would like to hand all of you a copy of those 25 documents now.
() (Mr . Christman distributes the documents.)
l 51800202 17416 1 joewalsh I
MR. CHRISTMAN: There are two maps, because you 2
will recall there is a primary and secondary method of (
a 3
monitoring. The setup is different for each of them.
d BY MR. CHRISTMAN: (Continuing) 5 Q Let me show the witnesses, particularly Mr.
6 Crocker and Ms. Dreikorn, the addendum which is Question and l j
7 Answer 67, and Mr. Watts who sponsors that with Ms. l I
8 Dreikorn, and the new drawings of the Roslyn reception 9
center with the slight modification in the southeast corner 10 of the monitoring stations and ask you if those were 1
II '
prepared by you or under your direction and supervision?
12 A (Witness Watts) Yes, they were.
13 Q Now, let me ask you as to all four of these
'~
Id l
documents, the testimony, the attachments, the addendum and 15 l the two new maps, whether those documents are true and l
l 16 Correct to the best of the witnesses' knowledge and belief?
17 Answer orally, if you would.
1 18 A (Witness Dreikorn) Yes.
M (Witness Watts) Yes.
20 (Witness Crocker) Yes.
21 Q Now, Mr. Crocker, are there any corrections, any 22 additional corrections, or changes that you want to make to 23 the testimony as I've Just supplied -- as it has been 24 supplied to everyone?
25 A (Witness Crocker) Yes, there are.
1 i
51800202 17417 30ewalsh O I o wou1d vou reed those into the record. 91eeee2 2 A I have corrections by page and line. I will go i 3 through them slowly. If people have trouble keeping up, d
slow me down, please.
5 On Page 12 of our testimt /, the first word in 6 Answer 16, "LERO" should be changed to "the LILCO of f-site 7 emergency preparedness section."
l 1 ,l l 8 Mr. Crocker, let me suggest that in addition on Q i 9
that page we should strike out the parenthetical in the 10 question. That's not really your bailiwick, that's mine.
i 11 But, the parenthetical that says "in terms of percent of EPZ i 12 population" should be stricken since the question no longer 13 addresses percent of EPZ population.-
O 14 A Yes. On Page 21 of the testimony, on the very i
15 first passage delete Dreikorn as a sponsor.
I 16 MR. McMURRAY: Sir, is that for the sentence 17 beginning "There is no evidence. . 2" 18 WITNESS CROCKER: Yes. On Page 22, in the fifth l 19 line of the answer to Question 30 change " miles" to 20 " kilometers."
21 On Page 53, on Question 118 in the second line 22 of the answer change the number 13 8 to 140. On th same 23 page, Page 53, Question 119 in the second line of the answer 24 change " revision of the plan" to " Attachment P."
25 BY MR. CHRISTMAN: (Continuing)
O
51800202 17418 j oewalsh I' I think that should be " Change Revision 8'of the Q
2 plan to Attachment P."
3 A (Witness Crocker) Revision 8, that's correct.
d Also, make the change " driver's hands and feet" to " driver's 5
head, shoulder, hands and feet."
6 On Page 59 on Question 139, in the seventh'line 7
of the answer, change "Daverio" .to "Crocker, Dreikorn."
8 Is that all the changes that you want to make to Q
9 the testimony as opposed to the attachments?
10 g yeg, II Q Do you have any changes to the attachments?
12 A Yes. We have a number of changes to Attachment I3 P. In OPIP 4.2.3 on Page 15 of 29, which is also Attachment ~
~
Id 2 of Page 1 of 1, it's title is " Reception Center, Personnel l
15 and Zone 7.ssignments," we have the following quantities to 16 change: On the first column under the heading of Bellmore --
I7 OUDGE MARGULIES: Just one moment.
I8 WITNESS CROCKER: Okay.-
19 JUDGE MARGULIES: This is Page 15 of 29?
20 Yes, of OPIP 4.2.3, WITNESS CROCKER: it's 21 Attachment 2, Page 1 of 1. It's a table with personnel 22 quantities indicated.
23 JUDGE MARGULIES: Reception Center Personnel and 24 Zone Assignments?
25 WITNESS CROCKER: Yes.
JUDGE MARGULIES: Yes.
17419 51800303 marysimons
() 1 WITNESS CROCKER: In the first column under the 2
heading of "Bellmore" the number 28 should be changed to the 3 number 30.
4 Similarly in the same column the number 14 5 should be changed to the number 15.
6 In the second column under the heading of 7
"Hicksville," and the additional subheading of " Area B" the 8 number 31 should be changed to the number 36, and the number 9
16 should be changed to 18, that is one eight.
10 Further down that table in the same column, the H
number 12 should be changed to the number 24.
12 MR. McMURRAY: I'm sorry, Mr. Crocker, could you 13 repeat that, please?
14 WITNESS CROCKER: Okay. The last one in the 15 same column under Hicksville with the side heading " Initial 16 Monitoring Personnel" the numeral 12 should be changed to 17 24.
18 In the third column under the heading of 19 "Roslyn" the number 28 should be changed to 32, and the 20 number 14 should be changed to 16.
21 As a result of these changes, the totals at the 22 bottom of each one of these columns also change.
23 The total at the bottom of the Bellmore column 24 should now be 73, the total at the bottom of the Hicksville 25 column, f ormerly 157 should now be 17 5, and the total at the O
51800303 17420 marysimons l I
-( bottom of the Roslyn column, formerly 64, is now 70, seven I zero.
- 3 BY MR. CHRISTMAN: )!
Q Are there any other corrections that you need to )
I 5 '
make either to the testimony or the attachments?
6 A (Witness Crocker) No, there are not.
7 Q With those corrections, are the testimony and i l ,
8 attachments true and correct to the best of your knowledge !
l 9
and belief?
10 A Yes, they are. j ll MR. CHRISTMAN: Judge, with that, I would like l
12 to move into evidence the testimony and attachments as 13 I
,-ss LILCO's correct case and propose that they be bound into the j
'Q^)
Id l transcript as though read. As to the latter, we are 15 prepared to provide 10 copies of all of these things to the 16 court reporter, if you wish. '
17 7 m told there was some departure from that I8 practice in the O-5 proceeding. So we can either treat them 19 as exhibits or have them bound into the transcript, as the 20 Board wishes.
21 Let me add that my proposal for the addendum is 22 to bind it right after the written testimony and before the 1
23 attachments and that I would propose to add the two modified 24 maps of the Roslyn reception center as the last two pages of 25 Attachment J which contains all the other site maps.
l 1
-_-_______-_______-_2
51800303 17421 marysimons
(_)s 1
JUDGE MARGULIES: Is there any objection to the 2 admission of the documents into evidence?
3 MR. CHRISTMAN: No, sir, subj ect to this d
qualification, which is that we haven't had Mr. Lieberman up 5 here yet. This document does contain testimony from Mr.
6 Lieberman . Subj ect to him getting up here and swearing to 7 it, we have no objection.
l 8 JUDGE MARGULIES: Subj ect to that condition, the 9
document consisting of the testimony, attachments, addendums 10 and maps will be bound into the record as if read and is 11 accepted into evidence.
12 The testimony referred to was l
l 13 marked for identification as I C:) -
14
~
l LILCO Exhibit No. 1 and 15 admitted into evidence.)
I 16 MR. ZARNLEUTER: Judge Margulies, the State has !
17 no ob]ection, subject to that qualification.
18 JUDGE MARGULIES: Thank you.
19 MR. CHRISTMAN: Thank you, Judge, and we will 20 provide the 10 copies to the court reporter.
21 With that, these witnesses are ready for cross-22 examination.
23 JUDGE MARGULIES: You may proceed to cross-24 examine.
25 l (2)
51800303 -
marysimons 17422
) I 2
CROSS-EXAMINATION 3
BY MR. McMURRAY:
d Q Mr. Crocker, could you please turn to page 6 of 5
your testimony.
6 Let's begin with question and answer 4.
7 Do you see there where you identify the three 8
reception centers as LILCO operation centers at Hicksville, Bellmore and Roslyn?
10 A (Witness Crocker) Yes.
Q The Roslyn facility is located just off of the 12 Long Island Expressway, correct?
q 13 A Yes.
,\/
~~
Id Q What is its normal function?
15 A Well, there are a number of activities that go 16 on there. We have a customer service section where our 17 billing inquiries and things like tilat are handled. We I8 dispatch our maintenance crews out of there. There is a 19 transportation garage where we repair equipment, trucks and +
20 the like and we stored some supplies there as well.
21 Q How many employees work there normally?
22 A Offhand, I don't know.
23 Q Do you know on an average day how many cars park 24 in the parking lot there?
25 A No, I do not.
1 51800303 17423 marysimons
() I Q Do you know how many LILCO vehicles, not 2 ernployee personal vehicles, but LILCO vehicles that are 3 parked there on a normal day?
d A No. It varies, i 5
Q What type of equipment is kept at the Roslyn 6 Operations Center?
I 7 A Well, you are familiar with the LILCO trucks you l 8 see on the road. There are all varieties. There is an 9
assortment like that. . I 10 Let's go to the Bellmore facility, which is just Q
11 off of Sunrise Highway, correct?
12 A Yes.
13 0 What is the normal function of the Bellmore O Id facility?
15 A Much as I described for Roslyn.
l 16 Q There is customer service there?
l 1
17 A Yes, a district office.
18 Q And there is also maintenance done there?
19 A Yes. There are the usual trucks. There is a 20 transportation facility there and there is a small storage 21 space for materials and the like.
22 Q And equipment is stored as well?
23 A Yes.
24 Q How many employees work there normally?
25 A I do not know.
O
51800303 I 42 marysimons I
t Q Do you know on an average day how many cars are 2
parked there?
3 A ' No .
d Q Let's go to the Hicksville facility. What is 5
the normal function of the Hicksville Operations Center?
6 A Well, as you are aware, that is essentially our 7
headquarters. Almost any function LILCO does is done there, 8
everything that I described for the other two centers.
- There is a larger warehouse facility and a lot more trucks l
10 l and the like.
Il Q There is a great deal of equipment stored there, 12
. correc t?
13 A Yes, there is.
7
' " ~ Id Q Can you tell me how many employees are employed 15 there at the Hicksville Center?
16 A No, I cannot, but it's more than the other two I7 facilities.
3 IB A lot more, right? l Q :
19 A Significantly. ~
20 0 On the order of thousands perhaps?
21 A It's a large number. I don't' know the true 22 I answer to that.
23 And can you tell me how many cars are parked Q
24 there normally during the day?
25 A No , I don't have that information.
l l
51800303 17425 marysimons
) I Q By the way, does anybody on the panel have that 2
information regarding how many cars are parked at 3
Hicksville, Bellmore or Roslyn on a normal day?
4 A (Witness Dreikorn) No, I do not.
5 Q Does anybody have any additional information i
6 about the number of employees at any of those facilities?
7 A No, I do not.
8 Q What kind of equipment is stored at the 9
Hicksville Reception Center or Operations Center, Mr.
10 Crocker?
I 11 A (Witness Crocker) As I described before for {
12 Roslyn and Bellmore, we have many, many trucks of all 13 different varietles. That's what we keep there. '
14 O There is also equipment that is not necessarily 15
, mobile, correct, utility poles, transformers and things like 16 that?
17 A (Witness Crocker) It's not mobile to the extent 18 that it doesn't drive around by itself.
]
19 !
Q And there are wires and pipes and things like 20 that stored there?
21 A All the normal supplies you need to operate a j i
22 utility.
23 1
24 25 O
1 l
51800404 17426 suewalsh
) I Q Are they near either of the reception -- either 2
of the two areas, Area A or Area B at Hicksville?
3 A (Witness Crocker) I think most of them are kept
-- I'm j us t trying to orient myself on the map. Towards the 5
southwest corner of the property, which is not near either 6
one of those two areas.
7 Q If you will turn please to Attachment J of your 8
testimony, let's go to the Hicksville reception center 9
diagram.
10 (The witnesses are complying.) i II A Yes, I have that.
12 O Okay. Let me turn your attention to Area B in 13 the lower right-hand corner of that diagram. Do you see
-{ }
'" Id that?
15 A yes, 16 0 Okay. To the left of Area B is a raised 17 platform; is that correct?
I8 A Yes.
19 Q Okay. And, on that raised platform there are a 20 number of barrels and drums and things like that that are 21 stored there, correct?
22
'A As I recall, transformers and other 23 miscellaneous electrical supplies. Drums, perhaps there 24 were. I can't recall for sure. The drums I remember when 25 you addressed the question to me in terms of chemicals are
1 51800404 17427 '
suewalsh
() I down behind the warehouse area to the lower lef t.
? Are there any drums or other containers Q
3 containing chemicals at the top part of Area B, for instance d
where the monitoring stations 11, 12 and 25 would be, around 5
that area?
6 A Not that we recall. Theke were cables and 7 transformers and things.
8 Let's go to the next page, Page 7.
Q 9
A Page 77 10 g yes, 11 A I have that.
12 Okay.
Q Ms. Dreikorn, can I turn your attention p 13 please to the first sentence in the answer to Question 6.
%/
14 The question is, "When did the 12-hour period in Criterion 15 J.12 begin to run."
16 Do you see that?
17 A (Witness Dreikorn) Yes, I do.
IB Q Let me just back up a second. Would you turn 19 back to Page 6? In the middle of that page, Criterion J.12 20 is set out in the middle of that page, that's Criterion J.12 l l
21 of NUREG 0654; is that correct? !
22 A Yes, that's correct.
23 Q Okay. And, that is the guidance in 0654 which 2d refers to reception centers and the procedures that are to 25 take place at those reception centers.
O 1
51800404 17428 l i
suewalsh !
) 1 A That's correct.
l 2
O In the middle of that page also, you mention i 1
3 that J.12 is only guidance. Do you see that?
d A Yes, that is correct.
5 Q Now, you don't mean to imply by that that LILCO 6
doesn't intend to try to meet J.12; is that correct?
)
7 A LILCO certainly intends to meet the Criterion 8
Element J.12.
1 9
Q Do you agree with me that -- strike that. j 1
10 Let's go to Page 7. We will be moving back and j forth between 6 and 7; keep your finger there.
1 12 You state that it's your opinion that the 12-13 hour time limitation in J.12 begins to run when the first
~~
Id evacuee arrives. Do you see that?
15 A yes, I do, i
16 Q Okay. Now, looking at Section J.12, as that's l
17 laid out on Page 6, it doesn't say there that the 12-hour l
18 time limitation begins to run when the first evacuee 19 arrives, does it?
20 A The way I interpret Element J.12 --
21 Q No, I'm asking you whether it says it 22 specifically in J.12.
23 A Would you like me to read it the way it's stated 2d here.
25 Q No. I would like you to tell me whether or not 1 .'
\
J l
l l
i 51800404 17429 suewalsh
() 1 J.12 specifically says that the 12-hour time period begins 2
when the first evacuee arrives?
3 MR. CHRISTMAN: Objection. We are wasting time d
on this. The guideline speaks for itself, f 5
MR. McMURRAY: Judge Margulies, I just have a 6 series of questions. I'm trying to find the basis for the 7 opinion that Ms. Dreikorn and others have stated.
8 I want to go through the language of J.12 and 9
then find that basis.
10 JUDGE MARGULIES: I will permit the question.
11 You may answer the question.
12 WITNESS DREIKOFW: Element J.12 does not say
(- 13 specifically when the time period begins.
()' 14 BY MR. McMURRAY: (Continuing) 15 Q Okay. Are there any HRC decision which 16 interpret Section J.12 the way you interpret it? ,
i 17 MR. CHRISTMAN: Obj ec tion. That's a question )
18 you ask lawyers, not witnesses.
19 MR. McMURRAY: To the extent that she is an 20 emergency plcnner, she may know of such decisions. If she 21 doesn't, she can just say she doesn't.
22 JUDGE MARGULIES: If the witness knows, she may 23 answer.
24 WITNESS DREIKORN: Okay. There are no 25 interpretations that I am aware of, either NRC or FEMA.
l l
l
1 17430 51800404 l suewalsh '
I BY MR. 'McMURRAY: (Continuing)
I 2
Q Okay. Are there any FEMA guidance materials 3
that set out that particular interpretation of Section J.12?
d A There is FEMA guidance for interpretation of 5
Element J.12.
6 Q I'm talking about the 12-hour time limitation, 7
when that begins to run? )
8 l
A Specific to the initiation of the 12-hour time 9
frame, I do not believe there is guidance.
10 0 Okay. Is there any emergency planning !
II literature that you know of that states that the 12-hour 12 time period begins to run when that -- when the first 13 evacuee arrives?
Id A Not that I'm aware of.
15 Q Now, you state that you believe that in the case 16 of Shoreham the 12-hour time period will, therefore, begin 17 to run some two hours after the public is first advised to IB evacuate.
19 Do you see that?
20 A No, I do not. Where are you?
l 21 Q The second sentence. Perhaps I haven't 22 paraphrased it correctly. If you will turn your attention 23 to the second sentence of the answer to Page 6?
24 A (Witness Crocker) It says, "We take this to 25 mean --
l
i 1
51800404 17431 l
suewalsh
() 1 (Witness Dreikorn) On Page 7?
2 (Witness Crocker) We are on the wrong page. !
i 3
O Okay. Let's start all over again. Page 7, d
Question 6.
5 A (Witness Dreikorn) Okay. I found it.
i 6 The second sentence.
O !
7 A yes, B
Q You say there that in the case of Shoreham you 9
take this to mean that the 12-hour time period begins to run 10 two hours after the public is first advised to evacuate.
11 Do you see that?
12 A Yes, that's correct.
13 Q Okay. Now, is it your testimony that no J
14 evacuees will arrive before two hours after an evacuation is advisory?
16 A Based on the calculations that our traffic 1 17 engineering consulting firm has done, it's determined that !
18 evacuees will arrive at the reception centers in 19 approximately two hours.
20 Q Okay. I'm --
21 A If you look at Element J.12 and read what it is 22 saying, is that we need to provide a capability for 23 monitoring when those evacuees arrive at the facility. It's 24 very dif ficult to provide that capability or that service of 25 monitoring until you have the evacuees actually showing up O
~
51800404 17432 suewalsh lf 1
for that service of monitoring.
2 Q And, I'm asking you, is it your testimony -- you 3
say here that that 12-hour time limitation begins to run d
when the first evacuee arrives. Is it your testimony that 5
not one evacuee will arrive before two hours?
6 A As I said, our Traffic Engineer has determined 7
that it will take approximately two hours for the first 8
evacuees to arrive.
9 Q Do you -- independent of what Mr. Lieberman may
'O have advised you, do you have an opinion as to when the Il first evacuee will arrive?
12 A I suppose somebody could arrive before a two 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> time frame.
~
Id Q Thank you.
15 A (Witness Watts) I also think the two hour time 16 frame is a reasonable estimate based on my knowledge of the I7 Shoreham situation.
IB And, I also agree with Ms. Dreikorn that the 19 interpretation of J.12 with the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> starting at the 20 time of the arrival of the first evacuee is a reasonable 21 one. And, I believe it's commonly held in the industry.
22 MR. McMURRAY: Judge Margulies, I'm going to 23 move to strike Mr. Watts' testimony. It was not responsive 24 to my question which is whether one evacuee could arrive 25 before two hours. He has gratuitously given his testimony,
17433 51800404 suewalsh
() I and it was not responsive to the question I have before Ms.
2 Dreikorn.
3 MR. CHRISTMAN: But, it was responsive to d
several of Mr. McMurray's questions, and I think the witness l
5 has indicated he wasn't able to get his response in. He is 6 certainly entitled to respond to the questions.
7 MR. McMURRAY: Judge Margulies, this is Just 8 going to be chaos 11 a witness is just allowed to jump in at 9
any time and give his testimony.
10 Now, Mr. Christman is going to have the 11 opportunity for redirect at some later time. If it's 12 appropriate, then Mr. Watts can address it then.
13 (The Board members are conferring.)
)
14 JUDGE MARGULIES: Back on the record. It would 15 be appropriate to lay down a ground rule at this time. The 16 Board feels that it would assist the Board if other panel 17 members be permitted to supplement the answer of the panel l 18 member that has answered if they had originally been part of 19 the panel that answered that question.
20 In the second or third panel member responding, 21 the response must be relevant and responsive and add 22 something new or additional. And, it cannot be used as an 23 opportunity to make a speech.
24 In this case, we will strike the answer.
25 BY MR. McMURRAY: (Continuing)
O
17434 51800404 suewalsh I
Q Let's go back to the question about the 12-hour 2
time period and when that begins to run.
3 Now, Mr. Donaldson, you have, in fact, expressed d
in previous testimony a different opinion regarding when the 5
12-hour time period begins to run, have you not?
6 A (Witness Donaldson) Yes, I have.
7 Q Okay. And, do you recall testifying in a l e
deposition on March 11, 1987 which was taken by Mr. Case?
A Yes, I do.
10 Q Okay. And, do you recall him asking the -
II question: What I'm getting at is the 12-hour time period 12 starts when the first person arrives?
13 And, your answer was: No. Well, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in my Id mind would be 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from the time an order were publicly 15 given.
16 Do you recall that testimony?
]
'7 A Yes, that was my opinion.
18 Q Okay. You were under oath at snat time, 19 c orrec t?
20 A That's correct.
21 Let's gG to the next -- to the last sentence in Q
22 that answer, the second clause there, it says: -this means 23 that somewhat longer than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to monitor 20 percent of 2d the EPZ population would be acceptable."
25 Mr. Crocker, now let 's just look back at J.12.
51800404 suewalsh
() 1 J.12 doesn't set out any particular percentage of people who 2 need to be monitored at reception centers, does it?
3 A (Witness Crocker) No. It just says all people 4 arriving at the relocation centers.
5 Q Okay. So, for the 20 percent figure I take it 6 from your testimony you are relying on the FEMA memorandum 7
that is attached to your testimony?
8 A The Krlmm memorandum.
9 Q The Krimm memorandum, okay. And, just for the 10 Board 's benefit that is Attachment L, correct?
11 A Yes.
12 O Let's look at Attachment L for a second. This 13 is a memo which states guidance on NUREG 0654, FEMA REP-1, O 14 Evaluation Criterion J.12, correct?
15 A Yes.
16 Q Okay. And, it purports to set out certain 17 guidance interpreting Section J.12, correct?
IB A Yes.
19 Looking at the second paragraph in that Q
20 memorandum, the second sentence says, " Previous experience 21 gathered on evacuation responses to a variety of natural and 22 technological eniergencies is not conclusive."
23 Do you see that?
24 A yes, I do, 25 Q Okay. Do you know specifically the natural and l
l l
/
]
l 51800404 17436 suewalsh I
technological emergencies which appear to have been the 2
basis for this memorandum?
3 A No, I do not.
Q Have you inquired of FEMA which ones?
5 A No, I have not.
6 Q I will open that question up to the panel.- Has 7
anyone inquired of FEMA as to which emergencies were B
evaluated with respect to this memorandum?
9 A (Witness Dreikorn) No, I have not.
10 Q And, I take it, Ms. Dreikorn, going back to Page 7 of the testimony, the two hour estimate when the.first 12 evacuees would arrive is largely based on Mr. Lieberman's I3 calculations, Question and Answer 7; is that correct?
Id A Yes, that's correct.
15 Q Now, has anyone done any analysis to determine 16 how many evacuees might arrive at reception centers prior to I7 two hours, any consultants or LERO personnel or LILCO I6 personnel?
19 A Not that I'm aware of that have any additional 20 consultants other than Mr. Lieberman done any calculations 21 on traffic and traffic flowing to the reception centers.
22 Q Okay. Do you know whether Mr. Lieberman has 23 done any analysis of the number of evacuees who might arrive !
24 before two hours?
25 A I think that would be more appropriate to direct
17437 51800404 .
suewalsh I
to Mr. Lieberman on his analysis.
2 O I'm just asking you whether such an analysis has 3
been done to your knowledge?
4 A Not to my knowledge, no.
5 Okay.
Q And, does anybody else have any different .
6 information?
7 (No response.)
8 I don't hear any yes at all, so I assume that's Q
9 a no.
'O l
n i2 1
.o 14 15 16 17 18 19 20 21 22 23 24 25
518000505 17438 j Joewalsh
-() I Q Mr. Crocker, the reception centers are the 2
places where the people will be directed to go if there is a ;
3 determination that they nee 6 to be monitored, correct?
A (Witness Crocker) Yes. j 5 Q And beyond that, people who may be advised to l 6 evacuate but might not be within that section of the EPZ, 7 told to seek monitoring, but who also need shelter, will be :
8 directed to go to the reception centers, isn't that correct?- -
I 9 A Yes, it is.
10 Q Let's go to page 8 of the testimony .
11 (Panel refers to document. )
l 12 Q (Continuing) Mr. Donaldson, let me focus on you 13 for a while. You state in your answer to Question 8 that {
14 you were part of a three man team that drafted the document 15 that was the precursor to NUREG 0654, is that correct?
I 16 A (Witness Donaldson) That is correct.
17 Q Who were the members of your team.
18 A A fellow named Mr. Ray Priebe, who is an 19 engineer from the NRR, Headquarters, NRC. Mr. Hal Gautt, 20 then with the office of State Programs of the NRC.
21 Q I am sorry. Did you tell us what NRR means?
22 A Nuclear Reactor Regulations, a division of the 23 NRC.
24 Q I assume that you still haven't found a copy of ,
25 your precursor document?
l t
51800050s 17439 j oewalsh
() i A That is correct.
2 Q So, you haven't reviewed it in how long?
3 A The document itself, I would say in about at 4 least five or six years.
5 Q And under what circumstances did you last review 6 it 7 A Under what circumstances?
8 Q Right.
9 A It would have been in my office after the 10 submittal of a document to Mr. Brian Grimes 7of the NRC, in l 11 comparison with the Rev. O of NUREG 0654.
l l
12 Q Let's just back up a minute. When did -- in ,
)
13 what time frame did you draft, you and Mr. Priebe and Mr. )
O 14 Gautt draf t the precursor document?
15 A Let me refer to one of my evidentiary enclosures 16 to my original deposition, so I can get the chronology 17 correct.
18 (Witness refers to document.)
19 In October of 1979, myself and three other 20 individuals from th NRC had requested that current emergency 21 preparedness improvements be halted by the NRC in order to 22 consider some information and concerns that we had regarding 23 lack of criteria that were used by states and licensees of 24 the NRC, 25 In response to that request, the Office of O
17440 518000505 j oewalsh l_( ) 1 Inspection and Enforcement did, in fact, place a moratorium 2 on further improvement and requested that Mr. Priebe, Mr.
3 Gautt and myself draft our feeling of criteria to be 4 submitted to the Federal Steering Committee.
5 We began our work, I believe, in November, two I 6 weeks bef ore Thanksgiving of 1979, using a number of 7 documents that had been prepared in the past, Regulatory 8 Guide 1.101, NUREG 7 5111, other guidance existing in the 1 l
9 emergency preparedness field. Internal submittals from the )l 10 Commission having to do with improvements to Appendix E, 11 10CFR50.
12 We prepared and consolidated comments in the i
_ 13 form of acceptance criteria.
14 That document was submitted to the Committee 15 approximately one day before Thanksgiving, in 1979, Mr.
16 Brian Grimes being the Chairman of the committee, the 17 Federal Steering Committee at the time.
18 Q So, the answer to my question is that you began 19 drafting around November of 1979, is that correct?
20 A That is correct.
21 Q And it was submitted the day before 22 Thanksgiving, to the best of your recollection, also in 23 1979?
24 A In that time frame, that is correct.
25 Q In that time frame. So, it was drafted over the 4
l l
i l
17441 518000505 j oewalsh
() 1 course of two or three weeks?
2 A That is correct; a two week period. Keeping in .
I 3 mind drawing upon existing criteria that were being applied I i
4 within the Commission also.
5 Of course, Revision 0 was published in January 6 of 1980. ,
I 7 Q Mr. Donaldson, just let me ask you to i l
e specifically answer my questions. I was just asking for a 9 time frame then, and this will go a lot faster.
l i
10 JUDGE MARGULIES: I think it would be helpful if I 11 the witness would be directly responsive to the question 12 asked, and should your counsel believe that there is l
l
, 13 additional information that should be forthcoming from you,
~
14 he will have the opportunity to qucstion you further. j 15 BY MR. McMURRAY: (Continuing) 16 Q Do you recall the title of your precursor I 17 document?
18 A (Witness Donaldson) I believe it was titleless.
19 Q Do you remember how big it was?
20 A I would say approximately that thick 21 (gesturing), single sheeted, computer paper.
22 Q You are saying abou t two inches thick?
23 A Abou t two inches thick. Approximately 150 24 pages.
25 Q Did you divide up the drafting chores of this O
17442 )
518000505 '
Joewalsh
_( ) 1 document between you and Mr. Friebe and Mr. Gautt?
2 A In what manner?
3 Q With respect to certain subject matter?
l 4 A I would say it was more of a team effort in the 5 sense that I know Mr. Gautt had access to the Wilber 6 computer within the NRC, and most of the typing was done on l
7 the Wilber System, so he pretty much took care of the 1
8 input.
9 It was pretty much conjunctive. We took the 10 general topic areas and went through them one by one 11 together.
12 O With respect to actual drafting, did you draft 13 the whole document?
-" 14 A Did I do the handwriting, or --
15 Q That is right.
16 A The majority of the documents, handwriting and 17 input that were brought to the session were mine, yes.
18 0 When you say, maj ority, ' over fifty percent?
19 A Well over fifty percent?
20 Q 75?
1 21 A 75 to 80 percent of it, at least. j i
22 O What role did Mr. Priebe and Mr. Gautt play?
I 23 A Mr. Priebe was a representative of NRR, so from 24 the viewpoint of statutory authority of the Commission, Mr.
25 Priebe was that representative of the Commission.
I 1
518000505 17443 j oewalsh
() 1 Mr. Gautt was a representative from at that time 2 the State Programs Group, which was responsible for the 3 Regional Assistance Committee in assisting States in developing response plan. I a
5 Q My question was what role did the play in the 6 preparation of the document? You have given me their titles 7 and responsibilities, l
e A The wrote, they commented, they reviewed, they 9 typed, they copied.
10 Q Was there any particular subj ect matter that Mr.
11 Priebe was responsible for?
12 A Again, as I said, the committee worked pretty 13 much as a holistic group.
.O 14 Q Was the document broken down into criteria, like !
I 15 NUREG 0654?
16 A Yes, sir, it was.
17 Q How many criteria were there?
18 A In the Licensee Section, there were 19 approximately 125, 130. In the State and Local Planning 20 Section, approximately the same number.
21 Q I believe you stated that the draft, once it was 22 completed, -- strike that.
23 How many versions of your precursor document did 24 you and Mr. Priebe, and Mr. Gautt go through before it was 25 submitted to the Steering Committee?
O
i I
l 518000505 j oewalsh
_() 1 A Would you restate that again.
2 O This may make it more complicated. How many 3 draf ts of your precursor document did you go through before 4 it was submitted to the steering committee?
5 A It is really hard for me to answer your 6 question. It wasn't really developed that way. If you I l
7 could rephrase it, I rea13y can't answer it that way, i 8 Q Explain to me how it was developed?
9 A It wasn't that a draft from A to Z were 10 c ompleted, and then it was distributed for review, and then 11 the second draft were done. We worked about sixteen to 12 eighteen hours a day for the two week period. We worked 13 criterion by criterion, and area of responsibility by area
-~
14 of responsibility.
15 So, when that portion was done, it was 16 constantly cross-checked back until we had what we felt was 17 a meaningful product.
18 Q And when the precursor document was completed, i
19 it did not have specific language that was similar to i 20 Criterion J-12 of NUREG 0654, is that correct?
21 A That is correct.
22 Q Now, we have been mentioning a steering 23 committee. What was the steering committee?
24 A The steering committee was formed just prior to 25 January of 1980 when the NRC's responsibility for overseeing
518000505 17445 l j oewalsh
() 1 the Federal response, FEMA was the agency, and the Federal 2 Preparedness Agency.
3 The Federal Preparedness Agency's responsibility a was not invested with FEMA. With the advent of FEMA, the 5 steering committee was formed, and main responsibility for 6 offsite planning then moved to FEMA.
7 So, the Committee came into play right about a that period of time to try and make a cleaner break between !
I 9 the Office of State Programs and the NRC, and the Federal 10 Response from FEMA. )
11 Q Just to get the chronology straight. At the 12 time that the precursor document was completed and you gave 13 it to Mr. Grimes, the steering committee did not exist, is la that correct?
15 A The steering committee was in the process of 16 being formed right about this time. FEMA had been formed as 17 a statutory group, and they were combining this FEMA group.
18 Q And the members of this steering committee are 19 set out on Page i1 of NUREG 0654, isn't that correct?
20 A Yes, they are.
21 Q So, the co-chairmen, were Mr. Grimes and Mr.
22 McConnell from NRC and FEMA, is that correct?
23 A The representative was Mr. McConnell from FEMA.
24 The co-chairman on Page II of the draf t document, which was 25 Mr. Grimes of the NRC and Mr. Ryan of FEMA, who was -- noted
(
518000505 17440 j oewalsh l l()
I their detail from the NRC.
2 Essentially, much of the FEMA group were NRC j 3 people who were associated with the office of State !
l 4 programs, who under the reorganization went with FEMA. 1 5 Q Excuse me for a second while I get the draft.
6 (Mr. McMurray obtains document. )
7 A There were two revisions, Rev. O dated January 8 1980 was the Committee at that time, and that is on Roman 9 Numeral Page II also.
10 Rev 1 of 0654, dated November 1980, with the 11 manuscript completed in October. Rev. 1, which is the one I i 12 believe you are familiar with, is the one that lists Mr.
13 McConnell. This was the one that was sent for comment.
L" 14 Q At the time that the ' steering committee was 15 first formed, you were not a member of the steering 16 committee, correc t?
17 A No.
18 0 You were never a member of the steering 19 committee?
20 A Never a member of the steering committee, that l l
21 is correct.
22 Q Mr. Priebe was not a member of the steering 23 committee, correc t?
24 A No.
25 O Nor Mr. Gautt?
518000505 J oewalsh
]7447 ,
1 O i ^ "o-2 O Now, once your precursor document is submitted 1
3 to the steering committee, you don't know how they consider 4 that document, 1sn' t that correct?
1 5 A Generally, not in detail, no.
6 Q Well, you don't know what procedures they use to l 7 review your document, correct?
l 8 A Generally, not specific. l 9 Q Do you recall testifying at your deposit 1on on 10 March lith, the question was asked: Once your draft 11 document was submitted to the Committee, what procedures 12 were followed, as you recall? Answer: To be honest about I it, I have no knowledge of that.
O 13 14 Do you recall that testimony? 1 15 A Yes, I do.
16 Q Thank you.
17 Q Is it still your testimony that you have no 18 knowledge of that? !
I 19 A No specific knowledge. I l
20 0 The steering committee eventually released a 21 draft of NUREG 0654, or Rev. O of that document, correct?
22 A That is correct.
23 Q Did that draft contain any language which 24 specifically includes the language of Criterion J-12 as it ;
l 25 now exists in Rev. 1, 0654? I O
1 l
l
1 518000505 17440 j oewalsh
_() 1 A Not as it now exists, no.
2 Q Did it have a specific criterion that maybe 3 paraphrases the present language of Section J-127 4 A Not a single criterion, no.
5 Q And after the -- when did the Rev. O of 0654 6 Come out?
l 7 A Approximately January. January of o80.
8 Q And it was open for comment?
9 A That is correct. I 10 Q How long was the comment period?
11 A Not exactly certain on that, but the comments l 12 were all published in a NUREG, public and state comments. ,
i 13 Q Did you provide comments to the steering.
14 committee?
15 A Through the internal NRC chain, yes, we did. ,
l
)
16 Q Did you provide any comments with respect to '
17 what is now Criterion J-127 l
18 A Criterion J-12 did not exist, so there would be 19 no comments -- ,
20 Q Did you provide any comments with respect to the 21 subject matter that is addressed in Criterion J-12?
22 A I wouldn't know that, because J-12 didn't exist.
23 Q So, at the time that the draft document -- the 24 Rev. O of 0654 was released, there was no specific language 25 regarding the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit for monitoring people who
51800050s 17449 j oewalsh
() 1 arrive at reception centers, is that correct?
2 A 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, no.
3 Q Okay. And in neither your precursor document, a nor Rev. O, was there any language regarding specifically 5 the number of people who might be expected to arrive at 6 reception centers, correct?
7 A No specific language, but it was considered when a the original submittal was made under 654.
9 Q My question is there was no explicit language in 10 your precursor document or in Rev. O regarding the number of 11 people who might be expected to arrive at reception centers?
12 A Yes, and I would like to clarify it. Absence i3 does not mean that it was not considered in terms of whether la monitoring capabilities should exist or not.
15 Q Did the steering committee ever consult with you 16 regarding the number of people who might be expected to 17 arrive at the reception centers? l I
la A No. Quite frankly, they took our draf t pretty 19 much literal.
20 Q The -- Was Rev.0 then close to the text of your 21 precursor document?
22 A Aside from appearance, if I could clarify, ours 23 was submitted as a single document, or I should say Parts 1 24 and Parts 2, one being for utilities, and Part 2 being for 25 State.
O
l l
518000505 17450 )
j j oewalsh j J() 1 What they did was more cosmetic in combining the 2 two and putting the lines the way you currently see them l l
3 right now. In n.any cases. Part 1 and Part 2 wording read 4 the same. So, other than that, the wording, including an i
5 error that we later detected, was published along with it, 6 and our review Could not have been that Careful in some 7 cases.
8' Q How long after Rev. 0 was put out was Rev. 1 9 issued?
10 A The publication date is November of 1980, so it 11 would have been about nine months.
12 Q And at that time Critericn J-12 appeared, y-s 13 correct?
i
'" 14 A That is correct.
15 Q In its present form?
16 A That is correct.
17 Q And you did not draft that criterion, correct?
18 A No.
19 Q Do you know who did?
20 A No. In fact the record of comments submitted to l 21 the Committee does not even reflect that there were any 22 public comments against that particular area of monitoring, 23 relocation of evacuees.
24 Q I take it, then, that you don't know exactly how 25 Criterion J-12 reached its present form, correct?
_________________w
i 518000505 Joewalsh A
(]) i I would agree with that Mr. McMurray, yes.
2 I might add to clarify, too, sir, that while I was with the 3 NRC as an inspector in that area involved with the regional advisory committee, when these changes came out we attempted 4
(
)
5 to find out where they came from so we could better '
6 understand and interpret those particular criteria, and to >
i 7 my knowledge we were unable to find an individual i e responsible for that particular criterion, and to this day, 9 in preparation even for this hearing, I have not been able 10 to locate a specific individual.
11 MR. McMURRAY: Judge Margulies, I don't know 12 exactly when the Board would like to take a break, but it i
33 has been traditional in these hearings that sometimes in mid-O 14 morning we take a 15 minute break, or I can go on, or I can 15 break now, whatever the Board would like to do.
16 JUDGE MARGULIES: Let's take a fifteen minute 17 recess.
Is (Whereupon, morning recess was taken at 10:30 19 a.m., to reconvene at 10:45 p.m., this same day. )
20 21 22 23 24 25 0
I 17452 51800606 l
marysimons JUDGE MARGULIES:
_( ) 1 Back on the record.
2 You may proceed, Mr. McMurray.
3 CROSS-EXAMINATION (Resumed) 4 BY MR. McMURRAY:
5 Q Mr. Donaldson, let's turn to question and answer 6 10 of your testimony on page 8. j 7 In the last two lines of that answer you discuss 8 provisions in your precursor document that call for 9 monitoring equipment to be available both onsite and 10 offsite. Do you see that? I 11 A (Witness Donaldson) Yes.
'2 Q With respect to your reference to offsite, did 13 you specify that monitoring equipment was to be available at 0 14 reception centers? ,
)
15 A The term " reception center" at that time was not 16 I would say a defined term that had anything to it. So I 17 would have to answer no to that question. i 18 Q Did you specify at all where monitoring 19 equipment should be available, or did you just leave it to 20 offsite?
21 A Pretty much offsite and limited to the word 22 " provision" still.
23 Q Going on to question and answer 11, the question 24 is asked "How many people did you think would have to be 25 monitored in a radiological emergency," and you state that
~
I 51800606 17453 marysimons i when you wrote the precursor document you did not have a
}
2 specific number in mind.'"We believed, however, that only a 3 small percentage of the EPZ would require monitoring, do you 4 see that?
5 A Yes, I do.
6 Q Who is the "we" referred to there?
7 A "We" refers to the two other members of the a committee as well as the general opinions and holdings of 9 other knowledgeable members of the Commission at the time.
10 Q Do you mean people on the NRC staft?
11 A The NRC statt as well as the Office of 12 Inspection and Enforcement.
13 Q Did you discuss this particular issue with l
O 14 Messrs. Gautt and Priebe during the course of drafting the 15 precursor document?
16 A We did discuss offsite capabilities, yes.
n Q Did you discuss how many people there would have is to be planning for for monitoring in the event of an 19 accident?
20 A To the best of my recollection, we did have a 21 discuss?.on, something to the effect of about how many people 22 are w ;alking about, and is this any kind of a big problem.
23 The outcome of that discussion was no, not 24 really, and consistent with everything else, we feel that 25 it's important enough that there needs to be provisions for i
O
51800606 17454 marysimons i j() I a response, but we did not feel that we should have to 2 specify details as to how it would be implemented.
3 Q Well, with respect to your personal bellets, you 4 don't know, do you, whether or not your particular 5 philosophies and assumptions regarding the number of people 6 that might be expected at reception centers was actually 7 incorporated into the final version J-12, do you?
8 A Into the final version of J-12?
9 Q That's correct.
10 A I can surmise that it was in the sense that we 11 were ---
12 Q Do you actually know. I don't want what you
,c 13 surmise. I want do you know.
'- 14 A I don't know, but I have an opinion, a 15 professional opinion as to that regard.
16 Q Let me just ref er you to your deposition, Mr.
17 Donaldson.
18 In your March lith deposition you say -- the 19 question is asked:
20 "Now you indicated earlier that in drafting your 21 plan or in your draft of the plan, along with two other 22 gentlemen, you incorporated certain assumptions within that 23 plan?"
24 The answer is "Yes," correct?
25 A That's correct.
51800606 17455 marysimons l() 1 Q The question is asked: -Do you know if these 2 assumptions were incorporated within the language of J-12?"
3 Your answer is, "That would be hard to say. I can say from 4 my knowledge of 0654 in general that those assumptions and 5 philosophies are still there. They have not been diluted 6 out. Whether that particular clarification of Item J-12 is 7 contrary to that, I really couldn't say unless I talked to l 8 the individual who wrote it. To my mind it's not 9 inconsistent with the way I read and understand it with the to rest of 0654."
11 Do you recall that?
12 A That's correct.
13 0 Is that your testimony?
14 A And that is my testimony now. In fact, I would 15 say that the content of J-12 or the remainder of 0654 does 16 in fact still support our original philosophy.
17 O And you also stand by your testimony that is whether that particular item, Item J-12 is contrary to that, 19 you really couldn't say?
20 A Again for a fact, no. As a professional 21 opinion, I could give you another answer.
22 Q Let's go over to the next page, page 9. There 23 you discuss your experiences as an NRC inspector, correct?
i 24 A That's correct.
25 0 Were you on what is known as the Regional O
1
)
51800606 17456 marysimons l_( ) 1 Assistance Committed known as a RAC?
2 A That's correct. I was Co-Chairman of Regions I, 3 II and III RACs.
4 Q Now in the RACs various members of the committee 5 represent various agencies; is that correct? '
6 A That's correct. i 7 Q And those various members are also responsible 8 for evaluating specific criterion within 0654, correct?
9 A That's correct. l 10 Q And you were not responsible for evaluation of !
i 11 these primarily for J-12; isn' t that correct?
12 A Not, not quite correct. As the Co-Chairman of 13 the committee, it was our chartered responsibility to
'= 14 oversee the evaluations of all participating members. So in
- l 15 that sense we did have input and review and essentially 16 approval of those reviews.
17 Q As far as front line responsibility for I 18 evaluating J-12, that was not one of your sections, correct?
19 A No.
20 Q Have you seen the LILCO reception centers?
21 A Yes, sir, I have.
22 Q When did you see them?
23 A June 8th I believe it was.
24 Q Now also in this answer in the second sentence 25 you say "I am specifically referring to the preplanning as
+
51800606 17457 marysimons
() 1 it relates to organization procedures, facilities and 2 equipment, and I say basic in the sense that extreme detail
? if far less important than clear pre-coordination of the 4 responsibilities."
5 Do you see that passage?
6 A Yes.
7 Q It is important, though, wouldn't you say, that a there should be adequate facilities and equipment for 9 monitoring members of the publiC?
10 A Restate your question.
11 Q You say " extreme k\ eta 11 is far less important l
12 than clear pre-coordination of the responsibilities." Is it 13 your testimony that it is unimportant to have an adequate O 14 facilities and equipment?
15 A I believe my testimony is that it is less 16 important.
17 Q So it is important to have adequate facilities is and sufficient equipment, correc t?
19 A When you need it, yes.
20 Q Would you say thst determining whether there is 21 sufficient equipment and whether there is sufficient 22 personnel is an extreme detail in a planning stage?
23 A Again, I would have to say that it is less 24 important than establishing the pre-coordination for 25 mustering those resourcesyis applicable.
O l
l
r 51800606 marysimons
_() 1 Q Would you say though that it is extreme detail? ,
2 a If you give me a particular scenario or a degree 3 of implementation, I think there is a cut-off point where 4 you reach a degree of detail. Maybe yes; maybe no. If you .!
)
5 would care to give me an example, I would be happy to 6 answer.
7 Q Mr. Watts, let's go to the second paragraph of 8 the answer to question 12.
9 There you and Mr. Donaldson state that from a 10 planning standpoint a plume is generally considered to 11 impact a down-wind sector and also the sectors on either j 12 side of that.
13 Do you see that testimony?
14 A (Witness Watts) Yes, I do.
15 MR. McMURRAY: Judge Margulies, at this time I 16 am handing out a one-page document which is a map of the 17 EPZ. It's from the LILCO plan, and I would like to have i 18 this map identified as Suffolk County Exhibit No. 1 or a whatever designations we are using.
20 JUDGE MARGULIES: It will be marked Suf f olk i 21 County Exhibit No.1 for identification.
22 (The document referred to j 23 was marked Suffolk County l 1
24 Exhibit No. 1 for 25 identification.)
1 l
l
)
51800606 17459 l marysimons j 1
() 1 MR. CHRISTMAN: Judge Margulies, let me off that )
l 2 we have a large-scale copy of a map of the EPZ that is very l i
3 similar as I think is this one. If it would help anybody, i 4 we can bring it into the courtroom. It's right next door.
5 It may not be the same one, but it shows the zones if there l
)
6 are going to be a lot of questions. If it would be helpful, i 7 we can provide it.
8 MR. McMURRAY: We can work with this one for the 9 time.
10 JUDGE MARGULIES: Well, I don' t know thc.t anyone 11 has a problem. If a problem develops, then we will take the 12 time to get the other one.
13 MR. CHRISTMAN: That's fine. I just wanted to O 14 you to know that it's available.
15 JUDGE MARGULIES: Thank you. j i l l 16 BY MR. McMURRAY: l 17 Q Mr. Watts, let me show you a document which I'll is represent to you was taken from the LILCO plan, but I have in drawn certain numbers at the er.$ of the various sectors l
20 radiating from the plan.
21 Other than what I have handwritten onto the map, 22 do you recognize this map as a map of the EPZ?
23 A (Witness Watts) Yes, it looks familiar.
24 O And this maps shows the 19 sub-zones that the 25 EPZ divided into; isn't that correct?
O
I 51800606 17460 marysimons I
1 A Yes, I believe it does.
2 Q And sub-zones are designated the letter 3 designations, correc t?
4 A That's correct, A through S.
5 Q "A" through what?
6 A "S".
7 Q Now, from the Shoreham site there are lines 8 radiating out at 22 and a half degree angles, do you see 9 that?
10 A Yes, I believe they are 22 and a half degree? I 11 would have to take your word on that one.
12 Q Do you have any reason to doubt that these are 13 the 22 and a half degree angles ---
y dw 14 A No, it looks approximate the wide that you 15 described.
16 Q And just for clarification, I have numbered the 17 sectors beginning with the sector on the left that is above 18 the horizontal axis there. It starts above the horizontal 19 axis and then numbered them counterclockwise around to the 20 right. Do you see that?
21 A Yes, I do.
22 0 I will be referring, and my intent is to be able )
i 23 to identify these various sectors by a number designation. I 24 So when I'm referring to Sector 1, I'll be referring to the I 25 sector that is next to the No. 1. Do you have any problem D
51800606 17461 marysimons 1 with that?
2 A No, that sounds fine.
3 0 Now let me show you a document, and let's j ust 4 go over the sub-zones here that are in Sectors 1, 2 and 3.
5 If you will focus your attention on Sectors 1, 2 and 3. Sub-6 zone A is within that sector, is it not?
7 A Could you repeat that, please? I am looking at 8 a colored version.
9 Q Of the same map?
10 A Yes.
11 12 ,
O ,,
15 16 17 18 19 20 21 1
22 23 24 25 o
V .
51800707 suewalsh !
l O I would like to identify the sub-zones that are
[ ('I} 1 2 within Sectors 1, 2 and 3. Sub-zone A is within those 3 sectors, correct?
4 A (Witness Watts) Yes.
5 Q Sub-zone F7 ,
1 6 A Yes.
J 7 Q Sub-zone G7 8 A Yes.
9 Q K?
, )
10 A Yes.
11 Q L?
j 12 A Yes.
13 Q And Q, in the upper left-hand corner?
-' 14 A Yes.
15 0 Okay. And, R?
l 16 A Yes.
17 MR. McMURRAY: Judge Margulles, we are now 1B handing out another document, also from the LILCO plan, 19 which I would like to have marked for identification as 20 Suf f olk County Exhibit Number 2.
21 JUDGE MARGULIES: It will be marked as Suffolk 22 County Exhibit Number 2 for identification.
23 (The document referred to is marked ;
24 as Suffolk County Exhibit Number 2 25 for identification.)
51800707 17463 suewalsh I) 1 BY MR. McMURRAY: (Continuing) 2 Q Mr. Watts, this is a map from the LILCO plan 3 which purports to set out the Summer and Winter populations 4 estimated for 1985.
5 Do you see that?
6 A (Witners Watts) Yes, I do.
7 0 Okay. Do you have any reason to dispute these .
, g population figures?
l 9 A No, I don't.
to MR. McMURRAY: Okay. Let me hand out a document i
n which I would like to have marked as Suf folk County Exhibit 12 Number 3 for identification.
i3 This is a document that says " Population of Sub-o 14 Zones in Sectors 1, 2 and 3 of EPZ."
15 JUDGE MARGULIES: Is there any obj ection?
16 (No response.)
17 JUDGE MARGULIES: It will be so marked. l 1
l MR. McMURRAY:
l 18 Thank you.
19 (The document referred to is marked 20 as Suffolk County Exhibit Number 3 l 21 for identification.)
22 BY MR.' McMURRAY: (Continuing) 23 Q All right. Now, Mr. Watts, I've noticed one 24 error on here. ,
l 25 A I've noticed it, too, Mr. McMurray.
l l
l
51800707. I suewalsh .
1 Q Okay. Down at the bottom of the exhibit where
)
2 it says percent of total 1985 Summer population equals 8 3 percent, it should be 68 percent.
4 A Right.
i 5 MR. McMURRAY: I would appreciate if everyone 6 would mark that into their copies.
7 BY MR. McMURRAY: (Continuing) 8 Q Do you see any other areas on here, Mr. Watts, 9 that are immediately -- that immediately jump out at you?
10 A Well, I think I have the responsibility to point 11 out to you that Zone M is also intersected by those three i
12 sectors.
13 Q Okay. Any other zocas that are in those three t la sectors?
15 A Well, potentially C, a little edge of C.
16 Q All right. Now, I have derived the population 17 figures from -- they are on Suffolk County Exhibit Number 3 ;
18 from Suffolk County Exhibit Number 2.
1' A Could you -- could we review which number is 19 20 which again?
21 Q Suffolk County Exhibit Number 3 is the table; 22 Suffolk County Exhibit Number 2 is the map with the l l
23 population figures on it. )
24 A Okay.
25 Q Now, for Sub-zones A, B,'F, G, K, L, R and Q, I
u i
17465 51800707 suewalsh ,
i
() I the total Summer population is 109,209; is that correct?
1 2 And, .I will give you a calculator if you would 3 like to do the math yourself? Do you have any reason to I 4 dispute that?
5 A I think I -- if you will give me just 30 6 seconds, I think I can check it.
{
i 7 (The witness is looking through documents.) j s Q Okay.
9 A I Come up with an answer that is pretty Close.
10 It 's not exactly on, but it 's close enough. I will accept 11 your --
12 Q Okay.
13 A --
figure.
14 Q Okay. Have you also calculated the percentage 15 of those sub-zones represented on Suf folk County Exhibit 3, 16 the percentage of the total Summer populations?
17 A Yes. I get roughly 68 percent also. l 18 Q Okay. Now, if we were to add Sub-zones M and C 19 onto Suffolk County Exhibit 3, we would be adding 5,296 20 people for Sub-zone C, correct?
l 21 A Yes.
22 O Okay. And for Sub-zone M we would be adding .
I 23 7,593 people; is that correct?
)
24 A Yes, that's right.
25 0 And, to figure out the percent of the total q
51800707 174gg suewalsh
_() 1 Summer population with those sub-zones compared to the 2 others, we would add those population figures to the 109,209 3 and divide that total by 160,000, correct?
4 A That's right.
5 Q And, what number do you come up with, what 6 percentage figure?
7 A I haven't double-checked it, but I get something 8 like 76 percent.
9 Q All right, 76 percent?
10 A Yes. What number do you get?
11 Q I haven't done it.
12 A Oh, okay.
1 13 0 I will take your word for it. Let's look at Sub-
- O 14 zones 2, 3 and 4, Mr. Watts.
15 A Would you repeat that, please?
16 0 2, 3 and 4, as I have marked them on Suffolk 17 County Exhibit Number 1. Let me just go over with you the 18 sub-zones which I've been able to identify as being within 19 these three sectors.
20 Sub-zone K is within those sectors, correct?
21 A Yes.
22 Q And, A?
23 A Yes.
24 Q L?
25 A Yes.
51800707 17467 suewalsh O 1 O o 2 A Yes.
3 Q B?
4 A Yes.
i 5 Q M?
6 A Yes.
7 Q R?
8 A Yes.
9 Q F7 10 A Yes.
11 Q Any others?
12 A Did we mention C?
0 I don't believe we did. C is also within those (q/ i3 14 sectors?
15 A It appears to be, yes.
16 Q Is H also within those sectors?
17 A It appears to be. .
I 18 Q And, to determine the total population within 19 those -- the zones which are within those three sectors, 1
20 again we could go to Suffolk County Exhibit Number 2 and add !
1 21 up the population figures represented for the sub-zones we have just named; isn' t that correct? 1 22 l )
23 A Yes, using a similar technique. Yes.
24 Q Okay. And, we could also use a similar 25 technique then to determine the percentage of the EPZ 4
l L.__________________ . _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ __ _ __ ___.m.
l 4
51800707 17400 suewalsh I
I population within those three sectors?
_( )
2 A Yes.
3 MR. McMURRAY: Judge Margulies, at this time I 4 would like to move Suf f olk County l'xhibits 1, 2 and 3 into 5 evidence.
6 JUDGE MARGULIES: Is there any objection?
7 MR. ZAHNLEUTER: No objection.
8 MR. CHRISTMAN: No obj ection.
9 JUDGE MARGULIES: All right. They are admitted !
1 10 as Suffolk County's Exhibits Number 1, 2 and 3.
11 (The documents previously marked as 12 Suf f olk County Exhibit Numbers 1, 13 2 and 3 for identification are
' \'# 14 admitted into evidence.) ;
15 BY MR. McMURRAY: (Continuing) 16 Q Mr. Donaldson, do you -- let's go down to 17 Question and Answer 13.
18 (The witnesses are complying.)
19 A (Witness Donaldson) Yes.
20 Q Okay. Did you have anything to do with the 21 development of the Krimm memorandum?
22 A No, sir. ,
l 23 Q Have you discussed it with anyone at FEMA? l 24 A Not at FEMA, no, sir.
25 Q Mr. Watts, have you discussed this memorandum i
_ _ __ a
51800707 suewalsh .{74gg 1 with anyone at FEMA?
2 A (Witness Watts) The Krimm --
3 Q The Krimm memorandum?
4 A No.
5 Q Did you have anything to do with the development 6 of the Krimm memorandum?
i 7 A No, I did not.
8 MR. McMURRAY: Judge Margulies, if you would 9 just indulge me for a minute?
10 JUDGE MARGULIES: Sure.
11 ( Paus e. )
12 BY MR. McMURRAY: (Continuing)
.j3 Q Let's go to Page 10 of the testimony.
14 (The witnesses are complying.)
15 There, Mr. Crocker, you refer to a passage from 16 NUREG 0654, Page 15 of that document, correct? I 17 A (Witness Crocker) Yes.
l 18 Q Okay. And, this is Guidance -- strike that. j i
19 What's the purpose of this passage? l 20 A The passage identifies the various types of l 21 releases considered in emergency preparedness from the most 22 significant to the least significant.
23 Q Now, when it refers to volatile solids, that 24 includes iodine, doesn't it, Mr. Watts?
25 A (Witness Watts) Yes, it does.
O
1 51800707 17470 suewalsh !
'C'd 1
Q Okay. What other volatile solids are there?
2 A One example may be cesium.
3 Q Any others that you can think of?
4 A Basically, those are the most predominant ones 5 we are concerned about.
6 Q When you say then in the first sentence after 7 the passage from NUREG 0654, you say, "The guidance, then, )
l 8 addresses itself primarily to noble gases and iodine I I
I 9 releases."
10 Do you see that?
11 A Yes.
12 Q And, this could be iodine releases in solid
{ 13 form, correct?
14 'A You are talking about iodine that could be 15 emitted in a possible variety of forms.
16 Q Including solid?
17 A Particulate, gaseous, yes.
18 Q Okay. In the exercise that took place in l
19 February of 1986 -- strike that. Let me go back. !
20 There was an exercise of the LILCO plan in 21 February of 19 86, correct?
22 A Yes.
1 23 Q Okay. You took part in that, didn't you? l 24 A Yes, I did.
25 Q Okay. So, you are familiar with the accident eG e J
___ _. _____ _ _____ _ _ _ o
51800707 17471
() i scenario that was used in that exercise, correct?
2 A Yes.
3 Q And, it's true, isn't it, that it was simulated 4 that one of the types of materials released during the 5 accident was iodine in its solid form; is that correct? l 6 A There was evidence of particulate iodine used in 7 the scenario, data, yes. i l
l 8 O So, it lodine were released from the Shoreham )
9 plant during an accident, it would not only be released in l
10 gaseous form but it could be released in solid form, 1 11 correct?
12 A In particulate form, yes, possibly. We would ,
i3 not expect it, however, because of the numerous removal
)
14 mechanisms that occur. That exercise scenario was a rather ,
i 15 extreme one to test all f acets of the plan, including off-16 site radiological monitoring capabilities. ;
I l 17 We would expect -- and there is a lot of is information that has been gathered from experience with TMI
- 9 that for a lot of physical and chemical mechanisms that r
20 would prevent substantial releases of iodine.
21 Q Nevertheless, solid iodine in its particulate 22 form is one of the solids that NUREG 0654 sort of ranks in 23 second place as some of the material that should be 24 considered in emergency planning, correct?
25 A Yes.
O
17472 51800707 I suewalsh 1 O Would you go to Page 11 of your testimony?
2 (The witnesses are complying.)
3 Look at the top paragraph. In the second 4 sentence you discuss, "In the situation in which the release l
5 was delayed several hours, the evacuating public would have !
6 left prior to the arrival of the plume, regardless of 7 whether it contained particulate contamination," correct? l I
8 A Yes.
9 Q Okay. In that sort of circumstance, there would 10 be no advisory to people to seek monitoring, correct?
11 A Yes, that's very possible. That's a situation l i
12 where we have in our procedures. As an example, the plant 13 reaches a general emergency status and even if we don't have L 14 a release, we don't have substantial core failure, we may 15 advise the public to evacuate --
16 Q Right.
17 A -- out to a two mile radius normally. But, the 18 reason fcr that would be really a precautionary evacuation 19 to avoid exposure to the plume should one occur at a later 20 time.
21 Q Let me just clarify my question --
22 A Okay.
23 0 -- and get a specific answer to it. In the 24 event that there was an evacuation called for prior to the 25 particulate release, there would be no need to direct the i r
i l
l 51800707 17473 '
suewalsh
() i evacuees to seek monitoring, correct?
2 A Those -- over and above the evacuation 3 recommendation in certain zones, that's right.
4 0 Okay. At the bottom of that paragraph, you 5 state that, "When people relocated they might pick up small 6 amounts of contamination (e.g., on the soles of their 7 shoes), but this would not present a health-threatening a situation that required immediate monitoring or 9 decontamination."
10 Do you see that?
11 A That's right.
12 O Okay. Are you testifying that J.12 does not 13 apply to the situation where a plume has passed and then 14 people are asked to evacuate?
15 A I'm not sure I understand your question.
16 Q Well, you seem to be drawing a distinction here 17 between health-threatening situations that require immediate is monitoring or decontamination, let's say within the 12-hour 19 time limit of J.12 and other types of released, and I want
]
20 to know whether in the situation under the circumstances 21 that you spell out in this last sentence, Criterion J.12 is 22 nevertheless applied; that is, that there be monitoring of 23 all evacuees who arrive within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
24 (The witness is looking through a document.)
25 A You are talking about two situations here, and j O
51800707 17474 suewalsh
) 1 I'm not sure what you are driving at as far as 2 applic abili ty.
3 0 Do the requirements of.J.12 apply.to the 4 situation where people pick up. contamination on the soles of 5 their shoes or wherever after the plume has passed and then 6 they have been told to evacuate?
7 A I would invite other members of the panel to a share their opinions on.that.- I don't see why we wouldn't 9 set up our reception centers and staff them to accommodate 10 evacuees who we suspect would be contaminated.
11 I don't see why we wouldn't follow our normal 12 procedures. Whether J.12 applies in a legal' sense, I'm not 13 sure. But, I don't -- I think that's moot.. I think we
'" 14 would set up our reception centers and provide for 15 monitoring anyway.
16 Q Do any members of the panel have a different 17 response?
18 A (Witness Dreikorn) No. I agree with Mr. Watts.
19 (Witness Crocker) As do I.
20 Q Now, when you say the people then relocated 21 after a plume had passed they might pick up small amounts of 22 contamination, e.g., on the soles of their shoes, '
I 23 contamination could also be kicked up. on other parts of the 24 bodies; isn't that true?
25 A (Witness Watts) Tha't's very possible, yes. To
51800707- 17475 suewalsh
]
() I give you an example of someone who had been sheltered and i'
2 then goes outside and does whatever is necessary to leave 3 the area. We suspect that, you know, the most likely -
4 location of contamination would be on the shoes, assuming 5 that they are walking.
6 Q But, they could bump into their cars and some 7 Contamination that was on the car might end up on the body, e correct?
9 A They could touch the handle of a car that was 10 outside and exposed to the plume, get it on their hand, 11 that 's true.
12 O Or get it on other parts of the,1r body, correct,
(] 13 if they happen to brush against the car?
%)
14 A Yeah. There may be other locations, but we -- I 15 have a hard time understanding how they would do that 16 without getting it on their hands and their feet.
17 18 19 l
20 21 22 23 24 25
)
C:) .
51800808 17478 Joewalsh lj) 1 Q So, in other words, you have the people
{
2 relocated after a plume has passed, there are other parts of 3 the body that could be contaminated other than Just the 4 soles of their shoes, right? You weren't Just limiting the 5 areas of contamination in this testimony to the soles of the 6 shoes, right?
7 A (Witness Watts) I believe the shoes would be 8 the primary location that would be affected. I mentioned 9 the hands. There is also the possibility of other areas of 10 the body, but I suspect that those primary locations would 11 be the ones of most concern.
12 Q And 11 those others -- for instance the hand,
-s 13 the arms, or whatever brushed up against a car or whatever,
'/
\
" 14 became contaminated, that could present a health threatening i 15 situation, correct? l 16 A I don't think so as a health physicist. I think l
17 typically when we deal with contamination, it is my l 18 experience it has not been a health threatening situation.
19 It is a nuisance. It is a heightening type concern, but not 20 an immediate threat to the health ot the individual. ;
21 O Under no circumstances could contamination on 22 the hands or the legs or other parts of the body be a health 23 threatening situation, is that your testimony?
24 A I think given the spectrum of accidents that we 25 are talking about here, I believe that it would not be an
51800808 17477 joewalsh
( 1 1mmediate health threatening situation.
2 As I say, we would be concerned and want to do 3 verification of the. contamination. We would activate our a reception centers and do monitoring. We would' follow the 5 health physicist practice here. But I do not see it as an 6 immediate health threatening situation.
7 Q When you say, 0immediate health threatening 8 situation,' what do you mean?
9 A Where we are likely to have immediate clinical 10 systems occur because of the contamination. Maybe Dr.
11 Linnemann would like to add to that.
12 ,
O Let me just follow up with you for a second, and
{} 13 Dr. Linnemann can then follow up. You have been saying 14 there won't be any problem or change in the white blood 15 cells immediately resulting from such contamination, 16 correct?
17 A That is correct, and I don't see an immediate is problem with the skin either based on some calculations that 19 we have done.
20 Q Nevertheless, such contamination is something 21 that should be monitored within the time limits of J-12, 22 correc t?
23 A Within a timely manner, and I am not sure that 24 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is a magic number with respect to a health i
25 concern. You want to get at it in a timely manner. You -
.O .
51800808 17478 j oewalsh
) I want to do the monitoring in a timely manner, and not delay 2 many, many day.s, but I don't think 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is a magic 3 number with respect to doing the monitoring from a health 4 point of view.
5 Q Nevertheless, J-12 sat that at approximately 12 j 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
7 A It is a regulatory piece of guidance, yes.
8 Q Lets go down to the third paragraph. The last 9 sentence. Where you talk about the most probable case for 10 only those people requiring congregate care would be i
11 expected at the reception centers. I 12 Mr. Crocker, do you see that? j 1
c 13 A (Witness Crocker) I am sorry. Can you point me j 14 in that direction again.
15 Q Okay. Last paragraph of that question and 16 answer is on Page 11. Mr. Crocker, on Page 11, the last 17 paragraph, Question and Answer 14, the last sentence of that is paragraph that discusses the most probable case, were only 19 those people requiring congregate care would be expected at 20 reception centers, do you see that?
21 A Yes, I do.
22 Q Can you tell me first how many -- what 23 percentage of the population in the EPZ is expected to 24 require congregate care under the LILCO Plan?
25 A Somewhere in the order of 15 to 20 percent, at
51800808 j oewalsh 17479 i I
o)
(_ 1 the outside.
2 Q Now, in the event of an accident at Shoreham, 1
3 and in the event of an evacuation, it is possible, is it 4 not, that not all people who are evacuated would be advised 5 to go seek monitoring? Some subset of those people advised 6 to evacuate would also be advised to seek monitoring?
7 A Depending on the situation, our procedures are a such that we would make every effort to evacuate before 9 there is any exposure to contamination.
l 10 In that case, only those people requiring 11 congregate care would go to the reception centers.
12 Q In the event of an accident, requiring l
(q J
13 monitoring, a segment of the population, is it possible that 14 there could be an evacuation, and for some subset of those 15 people have to evacuate, also that subset would be advised 16 to seek monitoring. Is that possible?
17 A Yes, it is.
is Q Is it possible that everybody advised to 19 evacuate could be also advised to seek monitoring?
20 A Yes, that is possible. Unlikely, but it is 21 pos sible.
22 Q It is more likely that some subset of those 23 asked to evacuate would be advised to seek monitoring, is 24 that --
25 A It is most likely that none of them would have
51800808 17480 joewalsh
_() I to go there if we do it right. ,
1 2 Q Assuming that there is monitoring called for, is 3 that correct? I 4 A Yes, I believe so.
I 5 Q So, the number of people expected to arrive at 6 LILCO's reception centers would at least include those 7 people advised to seek monitoring, as well as those people 8 who are advised to evacuate, but have no shelter is that 9 correct? l 10 A Yes, it is.
11 Q Now, is it your testimony that because in your 12 opinion the most likely case is one where no monitoring is required, that the appropriate planning basis should be D
13
'- 14 based only on the number of people that need monitoring?
15 A I am not sure I understood that, I am sorry.
16 Q The implication of the sentence that I am 17 looking at, and correct me it I am wrong, is that LILCO's le planning basis is based on what it considers to be the most 19 probable case, which is that no monitoring is required, l 20 therefore the planning basis is based on only those number I l
21 of people who need sheltering in the event of a radiological 22 emergency?
l 23 Is that your testimony?
24 A No. Our plan covers the spectrum of accidents, 25 and that doesn't focus on one single case.
51800'808 17481 joewalsh
() 1 Q Covers a spectrum of accidents?
2 A Yes.
3 Q Well, on Page 12 of your testimony, you state 4 that one need only develop capabilities to cope with a l
5 portion of the range. Did you change your testimony?
6 A Will you show me the reference?
7 Q It is on the 4th line down on Page 12.
8 A Is that the sentence that reads: Instead, one 9 should develop local emergency response capabilities to cope J 10 with a portion of the range?
11 Q That is correct.
12 A Yes.
13 Q Did you change your testimony?
14 A No, I haven't. We cope with a portion of the l 15 range, the spectrum. Not one single event.
16 Q What you seem to be saying there is that you are 17 planning for only a portion of the spectrum, is that j is correc t? Range and spectrum there are used synonymously, ,
19 isn't that correct?
20 A Our planning basis is the 20 percent referenced 21 in the Krimm memorandum, our plan allows us to expand the 22 response capability to cover more than that.
')
23 Q That is not my question; let's get back to my j i
24 question.
25 A I am trying to answer it.
l l
I
'l l
51800808 17402 j y j oewalsh !
,5 i
k L_) 1 Q You say that NUREG 0654 is based on the i 2 capability to respond to the spectrum of accidents, correct?
- a. 3 A Yeah, 396 and 654.
1 4 Q Now, you go on three sentences later to say one 1
5 should develop local emergency response capabilities to cope 6 with a portion of the range.
I 7 Does that mean that you are developing a plan 1 8 that is designed to deal only with a portion of the range of 9 possible accidents? '
10 A The planning basis aims at the most likely 11 accidents. The facilities are sized, equipment purchased, l i
12 and training is conducted to deal with the most likely 13 events. -
14 *cwbver, this basis also provides the ability to is expand , and our plan provides that, so if you get the more 16 severe accidents, we can accommodate it, and handle it 17 properly.
1B Q But, nevertheless, the testimony is that you are 19 developing capabilities to cope with only a portion of the 1
20 range, is that correct?
21 A That is what it says.
22 O Would you agree with me that the plan is i
23 supposed to be able to respond to the spectrum of accidents, l 24 that is referenced in 0654, correct? !
l 25 A Yeah. As the testimony says around that J rm l l
l 1
l 51800808 17483 l j oewalsh I
.r x
- (_) i sentence you have been reading, it says to identify one f 2 particular accident or type of accident as the basis for 3 emergency planning is inappropriate. Instead, one should 4 develop local emergency response capabilities to cope with a l l
5 portion of the range. These capabilities must be capable of 6 being augmented it required by the demands of an emergency.
7 Q What is the basis for your interpretation of 8 0654 that one needs to develop the capabilities of only a 9 portion of the range?
10 Does it state that anywhere in 0654?
11 A In our opinion, as planners, it is most 1
12 appropriate to focus on the most likely events as the most l 13 useful' allocation of resources. .
)
14 The language here reflects that, and as I 15 pointed out, we can handle all the accidents.
i 1
16 Q Let me go back to my question, which is does .
\
l 17 0654 state that one needs to develop local emergency 4
is response capabilities for only a portion of the range?
19 A Let me check the document, if I may.
20 (Witness peruses document.)
l 21 A (Continuing) There is language about the ;
22 spectrum of accidents on Pages 6 and 7 of 0654, and there 23 may be other references as well. I am not sure.
24 A (Witness Donaldson) May I answer part of that 25 question.
O 1
I 51800808 17484 j oewalsh 1 Q I want an answer from Mr. Crocker first.
2 A (Witness Crocker) Bear with me for a moment. I have to find the citation. '
3 I think the answer to the 1
4 question you have asked, if I remember your question l 5 correctly, I don't recall it explicitly stated in 0654, or l 6 in its related document, such as 396, which was the l l
7 predecessor, or base document for 654, does discuss the need
)
I 8 to base your planning basis on a spectrum of consequences, l l
9 tempered by the probability considerations.
10 Q Does it say how it should be tempered?
11 A Prudently, I assume.
12 JUDGE MARGULIES: We are having difficulty r
\]/
'd 13 hearing the testimony. Will you both please speak up?
14 WITNESS CROCKER: Yes, sir.
15 BY MR. McMURRAY: (Continuing) 16 Q Other than prudently, which I won't dispute with 17 you, is there any specific guidances to how the probability i 18 factor should be factored in, specifically within the 19 document?
20 A (Witness Crocker) There is further guidance 1 21 further down the page in Appendix 1 to this document, which 22 is 396. It talks in general terms.
23 Q Let's back up a second. Isn't it true that the 24 planning basis on which 0654 is founded rests in part on the 25 accident release categories in WASH 1400, the RAC Safety
. J
51800808 1 j oewalsh 17485 l
() 1 Study?
l 2 A I am not sure of the answer to that myself. My l I
3 colleague, Mr. Donaldson, could shed some light on that. l 4 Q Mr. Donaldson?
5 A (Witness Donaldson) As far as the spectrum of 6 accidents per current planning, 10CFR50, Appendix E, is the ;
7 emanating requirement which addresses the first regulatory I
\
s requirement in relation to scope, where it specifies that 9 licensee shall have plans to cope with the scope of )
io accidente defined in, and I believe the reference leads you 11 to 396, in which Appendix E was revised, of course, in 12 conjunction with all these documents.
i3 So, by going to 396, which was the precursor to u 0654, it does discuss, as Mr. Crocker has pointed out, that 15 you do temper that response.
16 654 further amplifies the scope of accidents by 17 defining those areas that should be covered, and by 18 including as an attachment what was NUREG 0610, which 19 specifies a series of initiating conditions, which ties 20 specifically to predetermined accident response sequences in 21 certain kinds of accidents which encompass this spectrum or 22 range.
23 Therefore, if the initiating conditions are l
24 covered in the emergency action levels by the utility, and 25 the corresponding responses which are recommended by that I
51800808 17486 j oewalsh 1 piece of guidance are in position, then the spectrum of 2 action set forth by the Commission is, therefore, determined 3 to be covered.
4 Q I refer you to Page 7 of NUREG 0654. The first 5 paragraph, last sentence, do you see where it says, Mr.
6 Donaldson: Although the selected planning basis is 7 independent of specific accident sequences -- I will wait 8 until you get it in front of you.
l 9 Do you have it in front of you, Page 7?
l 10 A I have page 7.
Il Q The las t sentence of that first paragraph, 12 starting with the word, "Although," it says: Although the l J ) 13 selected planning basis in independent of specific accident d 14 sequences, a number of accident descriptions were considered i
15 in the development of the guidance, including the core melt 16 accident release categories of the reactor safety study.
17 Do you see that?
18 A I sure do.
19 Q The reactor safety study is also known as tPe a 1
20 WASH 1400, correc t?
- l 21 A Yes.
22 Q And those core melt accident release categories l
23 include accidents that could result in the release of 1
24 particulate, correct? l
{ 25 A In the RSS?
r(S)
J
)
1 l
51800808 17407 goewalsh l
l 1 Q Reactor Safety Study, yes.
l 2 A That is correct. My point being,'that,is l
3 included. In answer to your question, spectrum is defined 4 by specifically the Appendix 1, Emergency Action Level 5 Guidelines, which also appears as NUREG 0610, I believe.
6 So, that portion of the reactor safety study, or 7 WASH 1400, which was determined to be appropriate, those a elements to cover the spectrum which Mr. Crocker speaks, is 9 embodied in this, you are absolutely right.
10 Q And that spectrum of accidents then, you would 11 agree, includes core melt accidents resulting in the release 12 of particulate?
i3 A It includes a sequence involving a core melt.
[}
14 Release of particulate. Difference there.,
15 Q I will focus on your last qualification there.
16 WASH 1400 didn't just discuss accident sequences. It 17 discussed consequences, didn't it?
18 A That is true.
19 Q And those consequences, as part of the input of 20 determining consequences, postulated certain release 21 characteristics, correct?
22 A And also postulated the lack of certain 23 safeguards which exist in current plans.
l 24 O Those release characteristics included the 25 release of particulate, correct?
O
51800808 Joewalsh 17488 1 A That is correct. )
2 Q Mr. Watts, let's go to your testimony on Page 4.
3 I think this is your area, and I just want to ask you about 4 it even though you don't sponsor this testimony.
5 At the top af page 4, you talk about highly 6 improbable radiological releases, where it might be 7 necessary to monitor more than 20 percent of the 8 population. Do you see that? You don't say that, but that !
9 1s what the testimony says. Do you see that? l l
10 A (Witness Watts) Are you asking me a question in j 1
11 regard to Question 2, of which I am not a sponsor? l 12 O That is right. j A I will be happy to try to answer, but I --
g{]) 13 t _J Maybe I should ask Mr. Crocker this first.
14 Q 15 Let's look at that sentence, Mr. Crocker, which begins:
16 Highly improbable radiological releases.
17 A (Witness Crocker) I have it.
l 19 20 21 22 23 24 25 r0
. J
l 51800909 suewalsh h I Q Do you know anything about PRAs that have' been I 2 done for Shoreham?
3 A (Witness Crocker) I'm not an expert in PRA.
4 Q Consequence analyses?
5 A I understand what the term means.
6 Q Okay. Can you tell me how much less probable an 7 accident is affecting 30 percent of the population than one 8 affecting 20 percent of the population?
9 A Only to the extent that it's less. But, I can't 10 quantify it for you. .
11 O Okay. Mr. Watts, can you quantify it other than 12 saying it's less?
13 A (Witness Watts) I can't quantify it ;
14 specifically.
15 0 Okay. Can you quantify how much less probable l 16 an accident effecting 40 or 50 percent of the population is 17 than one affecting 20 percent of the population?
18 A No, not specifically. No.
19 Q Mr. Crocker, I would like to go over the changes I
20 you made today just so I understand them. At least one of 21 these was a surprise to us, so I wanted to just discuss them 22 with you for a second.
23 First of all, do the changes that were made to 24 the chart personnel, total number of personnel -- I forget 25 which attachment that was that you made those corrections --
I
51800909 17490 1 A (Wi tness Crocker) Okay. That would have been 2 Attachment P --
3 Q Attachment P. .
4 A --
to OPIP 4.2.3, Page 15 of 29.
5 Q Now, do those changes now reflect the fact that 6 there are 63 monitoring stations?
7 A Having told you what it was, I have to find it a myself now. Bear with me a moment.
l 9 (The witness is looking through documents.)
10 Okay. I have it in front of me now.
11 Q Okay. Does that now reflect that there are 63 12 monitoring stations? 1
() 13 A YeS.
And, how many monitoring stations have been 14 Q 15 added to Bellmore since Attachment P?
16 A It should be just one.
17 Q And, two have been added to Roslyn?
18 A Yes.
19 0 Okay. And, two have been added to Area B in 20 Hicksville?
21 A Yes, we did.
I 22 O One of the changes you made also dealt with the 23 back-up procedure used at the reception centers. Do you 24 recall the page?
25 A Hang on a moment. Which change?
51800909 suewalsh 1 Q The change to the procedures to the backup --
2 the back-up monitoring procedures. I think on Page 53.
3 A Yeah, at Page 53, Question 119. l 4 Q Yes. It's now your testimony that regarding 5 monitoring and the back-up procedure, the areas erbodied to 6 be monitored would be the head, shoulders, hands and feet? I 7 A Yes, that's the proper correction.
8 0 When was that change decided upon?
I 9 A (Witness Crocker) Are you asking us when we #
10 changed the testimony or when we made the decision to add 11 head and shoulders?
12 Q That's right, when you made the decision to add 13 the head and shoulders?
i .
' 14 A The head / shoulders addendum was also in the
)
15 Fdoruary 20th material. If you note, there was a second 16 change on the same line where we cilanged the reference to 17 Revision 8 of the plan to Attachment P. Okay. Attachment P 18 was that February 20th material, and the head, shoulders, 19 hands and feet I believe is consistent with Attachment P.
20 So, somewhere prior to February 20th. If you 21 look at Attachment P, Page 9.C, you will see the reference 22 to the head and shoulders.
23 Q Mr. Crocker, if people from outside the EPZ 24 proceed to the reception centers and seek monitoring there 25 is no way to distinguish, under the plan, those people from O
. J
l 51800909 17492 I suewalsh l
Os 1 people from within the EPZ, correct? j 2 A Only if you ask them where they came from, 3 otherwise no.
4 Q Okay. And, are LILCO monitors trained to ask 5 where they came from?
I 6 A (Witness Dreikorn) No, they are not.
7 (Witness Crocker) No, they are not.
8 Q So, that those people would be monitored if they l l
9 came from outside the EPZ and asked to be monitored?
10 A Certainly. l 11 Q And, the same would be true for people from --
12 within the EPZ that may be outside the area that has been
(} i3 advised to seek monitoring, they would be monitored if they 14 showed up as well?
15 A All the arriving evacuees would be monitored. i 16 Q Whether they came from inside or outside the 17 EPZ?
is A Yes.
19 Q And, it's possible, isn't it, that people from 20 outside the EPZ might receive monitoring, without getting 21 into numbers?
22 A It's possible, but we don't think it's too 23 likely.
24 Q We will get into that a little bit later.
25 MR. McMURRAY: I believe that for the moment at
51800909 17493 suewalsh f)4
(_ 1 least I am finished with cross-examination of Sections 1, 2 2 and 3 of the LILCO testimony.
3 Mr. Case will be proceeding with the next few 4 sections. Since we are about at lunch time now, I would l
5 suggest that we are at a good breaking point. I would I 6 suggest that we take our lunch break now unless there is 7 objection. l l
8 MR. CHRISTMAN: There is no obj ection. l l
9 JUDGE MARGULIES: We will recess until 1:30.
10 (Whereupon, the luncheon recess is taken at 12 11 o' clock p.m., to reconvene at 1:33 p.m., this same day.) i 12 m ,,
15 16 17 18 19 20 21 22 23 24 25
51801010 17494
( ) AFTERNOON SESSION 2 (1:33 p.m.)
3 Whereupon, 4 DOUGLAS M. CROCKER 5 DALE E. DONALDSON 6 DIANE P. DREIKORN j l
7 ROGER E. LINNEMANN ]
8 MICHAEL K. LINDELL 9 DENNIS S. MILETI to and 11 RICHARD J. WATTS 12 having been previously duly sworn by Judge Margulies, were l
13 further examined and testified as follows: '
la JUDGE MARGULIES: Back on the record.
15 As a matter of logistics, the matter of binding 16 in the prefiled testimony as against putting it in as an 17 exhibit amounts to something like $10,000 for all the is prefiled testimony that is involved here, that is both 19 applicant's and intervenor's prefiled testimony.
20 The costs involved do not justify laying it in 21 and we will treat it rather as an exhibit. So in terms of 22 applicant's testimony that was laid into the record this 22 morning, rather than laying it in, we will put it in as 24 LILCO's Exhibit No. 1. ,
I 25 Under those circumst'ances, all that the parties O .
17495 51801010 1 need furnish the reporter are three copies. So it is a 2 savings in that area as well.
3 Is there any Objection to proceeding in that 4 manner?
5 MR. McMURRAY: No, sir.
6 MR. CHRISTMAN: No, sir.
7 MR. ZAHNLEUTER: No, sir.
8 You may proceed with cross-examination, Mr.
l 9 Case.
l 10 MR. CASE: Thank you, Judge Margulies.
11 CROSS-EXAMINATION (Resumed) 12 .
BY MR. CASE:
()
13 Q Dr. Linnemann, if I could ask you to turn to 14 page 15 of the testimony.
15 A (Witness Linnemann) Yes, sir.
16 Q In response to question No. 21, you discuss the 17 number of people who reported after Three Mile Island for l
l 18 whole body counts and thyroid counts. What is a whole-body i 19 count?
20 A A whole-body count is the measurement of a 21 radioactivity inside of the body from basically head to toe 22 or the major part of the torso.
23 Q And how is that done?
24 A That is done with a counter called a whole-body 25 c oun ter, and in the usual or the ones at least used in those
\
[
1 l ,
l
51801010 17496 marysimons
) 1 days you have a large detector in a lead shield, and the 2 detector looks downward and there is a bed on a screw 3 drive. The patient lies on the bed and it slowly brings him 4 under this detector which looks at the head, and then his l
5 chest moves under, the abdomen and the legs. And as it's 6 doing that it measures not only the type of radiation in the 7 body, but the amount of each isotope.
8 O Is that the most accurate method of measuring 9 the amount of radiation in the body?
4 10 A Yes, it is.
11 Q Are such whole-body counts routinely done af ter 12 industrial accidents, or on-site accidents, do you know?
13 A They are done routinely for many situations in
}
14 normal operations at a nuclear power plant or 15 radiopharmaceutical firms. For people who handle loose 16 radioactivity, whole-body counts are generally done when 17 they come to work periodically and then when they leave is work, or leave the employment.
19 Q How long does it take to perform a whole-body 20 count?
21 A Today about two or three minutes for a scan, and 22 if you wanted to do an accurate follow-up, it might take 23 eight minutes.
1 2d Q When you say accurate follow-up, what are you 25 referring to?
(
i j
l 51801010 17497 marysimons I i A well, if you find anything, what we call an 2 investigational level, then you use a scan where the body ,
(
3 moves under the detector and get a more accurate j 4 measurement.
5 Q Now in your testimony in response to Question 6 No. 21 you specifically talk about thyroid body counts af ter l
7 the Three Mile Accident; is that correct?
8 A Right, sir.
9 Q Is it true that at the time of the accident at 10 Three Mile Accident that there was no order issued directing 11 members of the public to report for monitoring for let's say 12 surface contamination?
13 A Not that I know of. Do you mean immedi'ately "9 14 following the accident or during the time of the releases?
15 Q During the time of the releases was there any 16 order directing members of the public to report anywhere for l 17 monitoring or surface contamination?
18 A I'm not aware of that.
19 Q Now, Dr. Linnemann, isn't it true that at the 20 time of the Three Mile Accident there was no order issued 21 directing members of the public to report for thyroid 22 c ounts?
23 A Not that I am aware of, no. Not until later you 24 realize.
25 0 And when you say "later," two weeks later?
O
, J l
51801010 17498 marysimons i A Ab ou t two weeks later, yes. These were offered )
i 2 to the public.- They were directed to get them.
3 Q When you say offered to the public, do you 4 recall the exact message that the offer was made?
l 5 A No, I don't. They were made available to the
{
l 6 public and about that many as it turned out of the public I 7 showed up for these counts.
B Q In this offer two weeks after the accident, do l 9 you know how that offer was disseminated?
10 A As I recall, it was disseminated in notices in 11 the local newspapers and I believe on the radio.
12 Q Were people advised to get whole-body counts?
() 13 A No. It was more in' terms of it's available to l 14 them. It was made available to them.
15 Q Now at the time of the accident at TMI was there 16 any order directing people, members of the public to report u for whole body counts that you are aware of? ,
l 18 A No, not at the time of the accident and even 19 later. It wasn't a matter of having them report because as 20 it turned out, and the analysis of the accident there was 21 reason to believe that any radioactivity released from the 22 plant would have gotten into the body, but these were 23 offered to the public at any rate as more of a reassurance, 24 as I recall.
25 Q Now, Dr. Mileti, your familiarity with Three O
l 51801010 17400 marysimons 1 Mile Accident, isn't it true that during the accident at 2 Three Mile Accident there was never any radio announcements l
4 3 that people should go to a reception center for monitoring?
4 A (Witness Mileti) Not that I recollect.
5 Q Now, Dr. Mileti, isn't it true that during the 6 accident at Three Mile Island there was never any radio 7 announcements that members of the public should report 8 anywhere for monitoring? i 9 A Not that I recollect. 4 10 Q Now there was, Dr. Mileti, wasn't there, during 11 Three Mile Island an advisory by Governor Thornburg of 12 Pennsylvania advising that pregnant women and preschool J' 13 children within a five-mile radius of the plant should i t;
' 14 evacuate?
15 A Yes, that did exist, as well as a lot of other 16 public information.
17 O Now within the five-mile radius of the plant 18 there were only approximately 5,000 preschool children and 19 500 pregnant woment is that correct?
20 A I don't remenber the figure specifically, but it 21 was about that, as I recall.
22 Q And isn't it true that 144,000 people within 25 23 miles of the TMI plant actually evacuated? Is that true?
24 A That is one of the estimates that currently 25 exists, yes.
. J
51801010 17500 i marysimons 1 Q Now, Mr. Donaldson, you would agree that people 2 on Long Island would behave similarly in the event of an 3 accident at Shoreham to the way people behaved at TMI?
4 A' (Witness Donaldson) Under similar 5 circumstances?
6 Q Would they behave similarly?
7 A In similar circumstances?
I 8 Q All right, let's start out with similar 1
9 circumstances.
10 A Yes.
11 Q Now if we could turn to page 20 of the 12 testimony. .
13 Dr. Mileti, in response to question No. 29 you
[}
a refer to tourist activities in Las Vegas during atomic bomb 15 testing in Nevada. Do you see that testimony?
16 A Yes.
17 Q Now were potential tourists ever told to stay j 18 away from Las Vegas?
19 A I can't say I would know the answer to that 20 question, but I would guess that they weren't. 1 21 Q Were potential tourists ever told that if they l
l 22 went to Las Vegas they would be exposed to radiation?
23 A I don't know the answer to that question, but 24 again I would guess that they were not told that.
I 25 Q Were potential tourists ever told that certain O
1 4
17501 51801010 marysimons "T]
i Ls k 1 portions of Las Vegas might need to be evacuated?
2 A Again, I don't know. I don't have an answer for l 3 that question, but I would guess not. I do know that some 4 of the explosions were quite visible to the tourists in Las 5 Vegas.
6 Q Were people told in Las Vegas,that they would l 7 need monitoring, do you know?
l l 8 A I would bet not.
9 0 Was any part of Les Vegas ever ordered evacuated 10 as a result of the bomb tests?
11 A I don't know, but I would guess not.
12 Q Were people in any part of Las Vegas every
/' 13 ordered to report for monitoring as a result of bomb tests?
14 A My answer would be the same.
15 Q In fact, Las Vegas has attractions that are 16 found nowhere else in the United States, at least until l l
17 recently, including gambling; is that true? l 18 A If you're talking about legal gambling ---
19 Q Legal gambling.
20 A --- aside from the new centers,I've heard about 21 here on the East Coast, like Atlantic City, I think that is 22 probably true, but I can't say I know that for sure.
23 Q Well, isn't it true also that Las Vegas actively 24 promotes itself throughout the United States as a desirable 25 spot for tourists to go to?
l . J l
l l
51801010 marysimons
/"
' A I don't know that, but I would bet that that was 1
2 true. As I recollect, Howard Hughes had a large investment 3 in Las Vegas during these tests, and he was actively 4 involved in promoting tourist behavior there.
5 Q Now you also referenced in response to question 6 29 property values in the Three Mile Island area. Property j 7 values are affected by a number of factors, correct?
1 A As a property owner, I would have to say yes.
~
8 9 Q And among those factors which affect property 10 values are proximity to effective transportation. Is that 11 one of the factors? I 12 A I seem to recollect that from an undergraduate 33 class. But I would have to say I guess that, but I don't f]
l ia know for sure.
15 Q Does your testimony on Three Mile Island here l
16 take into account proximity transportation and how it l 17 affects the property values in that locality?
18 A I believe my testimony is based on empirical 19 research that was done by the Governor's Office for Policy 20 Research and then by the Policy Board of Realtors in and 21 around the Three Mile Island area and some of my own 22 research, and it would have taken all factors into account.
23 C When you say taken factors into account, what do 24 you mean?
25 MR. CASE: If I could have marked as Suffolk O
l I
I 51801010 17503 marysimons 1 County Exhibit No. 4 the following document that purports to j J
2 be on the cover page a large "R" and says " Realtor - Greater i 3 Harrisburg Board of Realtors e Inc." i 1
4 JUDGE MARGULIES: The document will be marked as 1
5 Suf f olk County Exhibit No. 4 for identification. l I
6 (The document referred to was t 7 marked as Suffolk County Exhibit i
e No. 4 for identification.) )
9 WITNESS MILETI: In answer to your question ---
10 MR. CASE: I don't think there is a question j 11 pending right now.
12 WITNESS MILETI: I'm sorry, I thought there was, s'] 13 ' MR. CASF: Well, let's clarify it by doing this
%)
'd 14 since we have a document in front of us and you can refer to 15 the document.
16 BY MR. CASE:
17 0 Do you recognize what has been marked for 18 identification as Suffolk County Exhibit No. 4?
19 A (Witness Mileti) No one gave me a copy, but I 20 brought along a copy of what I sent you during discovery.
21 (A copy of Suffolk County Exhibit 4 was placed 22 before Witness M11eti.)
23 Q As far as I know, it's the same document.
24 A It sure looks like it.
25 Q What is Suffolk County Exhibit for
/"%
51801010 17504 marysimons 1 Identification No. 4?
2 A This was a report 6cne by the Greater Harrisburg 3 Board of Realtors, Inc., regarding community impact study on 4 real estate in the Three Mile Island nuclear accident as 5 it's titled.
l 6 Q Now would you show me where in this report 7 proximity to effective transportation is analyzed as a s factor of property values?
9 A (Witness Dreikorn) Excuse me, could we have a 10 copy down here?
11 (A copy of the exhibit was placed before Ms.
12 Dreikorn.)
{) 13 A (Witness Mileti) As I recollect, this was a 14 comparison of the values and the number of sales of property 15 and factors like that of houses in and around the Three Mile 16 Island area, and it was basically a comparison of real 17 estate activity and values in the zero to five-mile area.
18 Excuse me, let me find the table. It's on page 19 8, the O to 5-mile radius, the 5 to 10-mile radius, 10 to 15-l 20 mile radius and the 15 to 20-mile radius, and it was done 21 across time. i l
22 As far as I know, transportation as a variable l
l
\
23 didn't change across the time intervals that were being l 1
l 24 examined, and therefore comparisons about change regarding l
. l 25 average sales, for example, would have controlled for j
(
4 1
I
51801010 17505 marysimons
) I transportation.
2 Q Do you know if the availability of 3 transportation changed over that period of time? '
4 A I don't have the sense that it did. I can't say 5 that I've seen detailed transportation reports that it 6 hasn't.
7 Q Do you see any analysis of it in there?
8 A No, I don't, except to the extent that I just 9 described the way it would be included.
10 Q One of the factors which affect property values 11 is the quality of the school system, correct?
12 A I would imagine the quality of the school system
- is could be a factor that could affect property values, yes.
)
LJ And does your testimony take into account how 14 O 15 school system quality affected property values around TMI?
16 A My answer would be the same in the sense that l l
17 comparisons were made across time, and I don't think that it 18 was likely that there would have been appreciable changes in tv things like the number of roads that are there or 20 transportation routes since those things take a long time to 21 build.
22 O The question was about school systems.
A 23 And the same would be for school systems.
24 O Do you know what the reputation of the school 25 systems were around Three Mile Island at the time?
rt:)
51801010 17506 t A At what time, before or after the accident?
2 Q At any time.
3 A No , I don't know that, but I don't have the 4 sense that they changed.
5 0 You don't know at any time what the reputation
- 6 of the school systems were around Three Mile Island? I 7 A No.
8 Q Now.one of the factors that affects property 9 values is the health of the local economy in terms of job to availability; is that correct?
11 A I could speak with firsthand experience with 12 that living in Denver. Absolutely, yes.
i3 Q Does this analysis take into account the health 14 of the local economy at Three Mile Island? Do you see any 15 analysis of that in your Suffolk County Exhibit No. 4?
16 MR. CHRISTMAN: That was a compound question and 17 I object. We should have one question at a time.
18 MR. CASE: I'll rephrase the question, Judge.
l 19 BY MR. CASE: '
I 20 Q In Suffolk County Exhibit No. 4 for 21 identification is there any analysis of the local economy l l
around Three Mile Island?
22 23 A (Witness Mileti) Only to the extent that it 24 would have been included in the same way that all those i 25 other factors would have been included. I O :
1
l 51801010 17507 I marysimons 1 Q My question is is there any analysis of the 2 local economy around Three Mile Island in Suffolk County 3 Exhibit No. 4?
4 A No. It was focused on real estate values.
5 Q Now, Dr. Mileti, also on page 20 you rcference a 6 fire and a small release of radiation in Sydney, Australia 7 on March 18th. Do you see that portion of your testimony?
8 A Yes, I see it.
9 Q Do you know whether any members of the public l
l 10 were ordered to evacuate in the Australian accident? '
i 11 A I don't believe that they were, and my 1
12 conversations with a colleague who is head of the Disaster j 13 Research Center at Caufield Technological Institute, his
' 14 account of it was that they were not.
15 Q My question was do you know whether any members 16 of the public were ordered to evacuate? !
17 MR. CHRISTMAN: I object to interrupting the 18 witness' answer. He had finished it yet.
19 BY MR. CASE:
20 Q The question was a very specific and pointed 21 out, and the answer was unresponsive.
22 The question was do you know whether any members 23 of the public were ordered to evacuate?
24 MR. CHRISTMAN: It was unresponsive because you 25 cut off the last part of his answer and I would like the O
51801010 17508 1 witness to be allowed to finish his answer.
2 JUDGE MARGULIES: Let's start over again.
3 You've heard the question. Now would you 4 proceed to answer it.
)
5 WITNESS MILETI: The answer is no, and the basis
)
, 6 for my knowledge was a conversation with a colleague I know l
7 who is the Director of the Disaster Research Center at the a Caufield Institute of Technology.
9 BY MR. CASE: 9 10 Q Do you know if members of the public were 11 ordered to report for monitoring in the Australian accident?
12 A No, they were not.
13 Q Now, Mr. Crocker, would you turn to page 21 and -
[}
l 14 your testimony there at the top of the page concerning 15 population and property value decline around the 10-mile 16 EPZ? Do you see that testimony?
17 A (Witness Crocker) Yes, sir, I do.
1 IB Q And what is the basis for the testimony on 19 property value decline?
20 A The basis, is that the question?
21 O Yes.
22 A There were two bases for the statement. The 23 first one was a question that we directed to the LILCO Real 24 Estate Department, and they in turn took. an informal poll of 25 various appraisers familiar with the Shoreham EPZ area. The l b
l 51801010 17509
!_ 1 infomation that they gathered and was related to me 2 verbally was that quite to the contrary, prd.ces have been 3 going up as much as they have all over Long Island. The l 4 experience of my staff out at Shoreham confirms that. They 5 are having a hard time finding a house they can afford. ;
6 The second basis for this was a subsequent study we 7 commissioned and I believe was turned over to you a short i a time ago when we got it, and that was a study that compared 9 recent changes in property values for the Wading River 10 School District and the Rocky Point School District, both of I 11 which are close to Shoreham, and it co:npared it to the rest I
12 of the Town of Brookhaven which includes part of the EPZ and 13 extends well away from the EPZ.
'" 14 So that was the basis for the position on 15 property values.
16 MR. CASE: If I could have marked as Suffolk 17 County Exhibit No. 5 for identification a document with the 18 first page indicating a " Summary of Real Estate Study 19 Comparing Price Changes in Shoreham Vicinity Versus the Town 20 of Brookhaven.
21 JUDGE MARGULIES: It will be so marked for 22 identification.
23 (The document referred to was 24 marked Suffolk County Exhibit 25 No. 5 f'or identification.)
o
51801010 17510 marysimons r
I 1 BY MR. CASE:
2 Q Do you recognize what has been marked as Suf folk 3 County Exhibit No. 5 for identification, Mr. Crocker?
4 A (Witness Crocker) Yes. It appears to be the 5 second report I referenced.
6 Q Did you have any role in preparing this 7 document?
8 A No, I didn't.
9 Q Do you know what the source of data is for this 10 document?
11 A At the bottom level is a data base that is 12 operated by the company preparing the report, in this case 13 the Albert Appraisal Company?
14 0 Do you know what is included within that data 15 base? i l
A 16 Generally it includes sales and property values 17 for any given area of interest.
is O Do you know if it includes seller finance sales?
19 A I don't know the answer to that one.
20 Q Do you know where the data base is derived from?
21 A It's a data base that the company scintains. I l
23 don't know where they get it from.
23 Q Do you know if they obtain it f rom ta:: records?
24 A Perhaps they do.
25 0 You don't know.
51801010 17511 marysimons
} 1 A I j ust don' t know.
2 Q Do you know this data base includes all sales 3 made in a given geographic district?
4 A That's the intent. They believe it does.
5 Q Do you know?
6 A I've made no comparison of sales records versus 7 this report myself, no.
8 Q Well, if you would explain a bit of this 9 document to you. On the third page of the document mid-way 10 down it says annual and cumulative change and there appears 11 to be a handwritten chart that says 1983, and as you move 12 across from left to right, minus 11.32, minus 8.57 and minus 13 11.32. What do those numbers refer to?
L 14 A Okay. Let me give you a little background on is this company as a necessary preface so you understand what 16 this means.
17 This is a firm that has for the most part been 18 doing studies and comparing the assessed values of .
1 19 properties to their sales values.
20 Now their typical focus of interest is they 21 prepare these report for cases contesting the assessed value 22 of property. ?.f an industry feels that it has been assessed 23 unfairly relative to the base in the community, they will 24 ask this type of company to prepare an evaluation of how do 25 the assessments historically compare. ,
r0
51801010 17512 marysimons l
() 1 Consequently, these numbers are ratios for a 2 given area, for example, in the Rocky Point School District 3 it's the ratio that describes that area, and on this page 4 it's the ratio of the assessed Values to the sale pr1Ce as 5 the change you see. So these would be percentages.
6 For example, if you look in the first column, if 7 you can follow with me, and look at the row in 1983, that a would be a decrease in the ratio of assessment over sales 9 price of 11 percent.
io So what it is telling you is as the sale price '
11 has gone up, the denominator of the fraction has gone up.
12 O I see.
13 A Then you see the values would change as you go 14 down through time.
15 Q Now you would also agree, I assume, with me that 16 there are a number of f actors that affect property values; 17 is that correct?
18 A Undoubtedly.
19 Q Among those factors would be, for example, the 20 reputation of school systems; is that correct?
21 A Yes.
22 O Is there an analysis of how the reputation of 23 school systems affects property values in these localities 24 within this document, Shoreham Exhibit No. 5 for 25 identification?
O
51801010 17513 marysimons Id 1 A No. The only that was studied was the cost of 2 housing and assessments.
3 Q Among the factors which affect property values 4 is the health of the local economy; is that correct?
5 A I would assume so, yes.
6 Q Is there any analysis in Suffolk County Exhibit 7 No. 5 concerning the health of the local economy and how 8 that affected these property values?
9 A No, there is not.
10 Q Another factor which affects property values is 11 the availability of government services; is that correct?
12 A I would assume so, yes.
, 13 Q Is there any an.alysis of how the availability of O 14 government services affects property values in Suf folk 15 County Exhibit No. 5?
16 A No, there is not.
17 Q Does the location near j obs -- let me back up on i 18 that question.
l 19 The location of a piece of property near j obs or 20 a community near jobs affect property values; is that 21 correct?
22 A Are you referring perhaps to commuting times or 23 something like that?
24 Q Yes.
25 A CerLainly it's a consideration.
51801010 17514 marysimons i Q Is there any analysis in Suffolk County Exhibit 2 No. 5, to use your word, how commuting time affects property l
3 values?
4 A No, there is not.
5 Q Have you ever worked as a realtor?
6 A Fortunately, no.
7 Q Do you have any training as a realtor or'in real a estate?
9 A No, sir. 2 l
10 Q Have you ever published any papers analyzing the 11 factors which influence property values?
12 A No, sir.
13 Q Have you ever led any seminars or discussions on
)
14 what factors influence property values?
15 A No.
16 Q Mr. Watts, also on page 21, you discuss an 17 accident at "Ginna," is that correct?
18 A (Witness Watts) Ginna.
19 Q At Ginna was there any order given to the public 20 to report for monitoring?
21 A No, there Sas not.
22 Q At Ginna was there any order for the public to 23 report to reception centers?
24 A No, there was not.
25 Q Was the emergency at Ginna an onsite emergency?
O
1 f
51801010 17515 marysimons.
1 A It was an onsite emergency. However, there was 2 a release of radioactivity into the atmosphere which 3 traveled offsite.
1 4 Q But there was no directive to the public to 5 report for monitoring; is that correct?
6 A I believe I answered that before. a 7 Q Dr. Linnemann, on page 21 you discuss four 8 nuclear bombs that were accidently lost over Palomares 9 Spain.
10 A (Witness Linnemann) Yes, sir.
11 Q Was anyone ordered to evacuate at Palomares in 12 response to the loss?
13 A No.
d 14 Q Was anyone at Palomares told to report for 15 monitoring?
16 A Yes.
l 17 Q Who was told to rspurt for monitoring?
18 A The citizens of the Village of Palomares.
19 Q How many citizens were there? i 20 A Approximately 2,000.
21 Q Now this incident was prior to Three Mile 22 Islands is that correct? <
23 A It was January 1966.
24 Q So is that prior to Three Mile Island?
25 A Oh, yes, 13 years. Three Mile Island was 1979.
I )
. J
51801010 17516
() 1 Q And this incident at Palomares was prior to the 2 accident at Chernoby1; is that correct?
i 3 A Ch, yes.
4 Q Now you indicate in the last sentence there that 5 you saw no evidence of Spanish residents fleeing the area; 6 is that correct?
7 A That's right.
8 Q But as you testified just a moment ago, there 9 was no order to evacuate; is that correct?
10 A That's right.
11 Q You also refer there to U.S. personnel not 12 fleeing the area. Are you referring here to U. S. soldiers i3 and airmen?
14 A That's right.
15 Q Aren't there penalties for soldiers and airmen 16 who flee their stations or assigned duties?
17 A I would assume that some punishment would be in is order.
19 Q You were an officer in the United States Army, 20 weren't you? ;
21 A That'{sright. ,
22 O Isn't it a fact that desertion is subject to 23 court-martial?
24 A I believe during wartime not doing your duty i 25 wou. 't something less than that serious an offense.
(Ji ! .
51801010 17517 marysimons 1 Q But you would be subj ect to some punishment if i
2 you did? l I
3 A I would assume so.
4 Q Now if you will turn, Dr. Mileti, to page 22 of !
5 your testimony, Question No. 31.
6 A (Witness Mileti) Yes, I'm there.
l 7 Q Now as I understand this testimony in the first 8 paragraph here, some people at Kiev Icft Kiev even though 9 they were advised not to evacuate; is that correct?
10 A Yes, that is correct. l 1
11 Q And it is also your testimony there that people 12 acted in Kiev, to the best information you have, based on 13 their perception of risk; is that correct?
.]
' 14 A People in all emergencies act on the basis of 15 their perceptions. l 16 Q And the people at Kiev are no different in your 17 estimation than anyone else in terms of acting on their 18 perceptions first?
19 A Without firsthand knowledge, I would have to 20 hypothesize that that would hold.
21 Q Now, Dr. Linnemann, on page 22, question No. 3 0, 22 there is testimony there concerning your meeting in Vienna 23 with the USSR State Committee on Atomic Energy.
24 Do you see that testimony? j l 25 A (Witness Linnemann) Yes, sir.
i j l
. J 1
j
1 I
i 17518 I 11801111 suewalsh 1 1 Q And, to your knowledge, Dr. Linnemann, in the l
2 Soviet Union are there government restrictions on internal
{
l 3 travel?
4 A (Witness Linnemann) I wouldn't know that.
5 Q Dr. M11eti, do you know if in the Soviet Union 6 there are government restrictions on internal travel?
7 A (Witness Milet1) I don't know.
8 Q Dr. Linnemann, you would agree with me, wouldn't 9 you, that the Soviet's society is certainly not as mobile as 10 that in the United States?
11 A (Witness Linnemann) Not necessarily.
12 Q Well, let's break it down a little, then. Is
(}
33 the transportation system, in terms of roads, as well 14 developed in the Soviet Union as the United States?
l 15 A I don't know. I've never been to the Soviet 16 Union so I couldn' t tell.
17 Q Do you know what percentage of Soviet citizens 18 own cars as opposed to the percentage of the United States' 19 citizens that own cars? j 20 A I have no idea.
21 Q Dr. Mileti, do you know if the road system 22 within the Soviet Union is as well developed as it is within 23 the United States?
24 A (Witness Mileti) I have no. idea.
25 Q Do you know the percentage of Soviet citizens O
4 17519 j 11801111 suewalsh L ; I who own cars?
I 2 A I don't know, but I would guess that they are 3 more inclined to own cows than cars. But, that's just a l
l 4 guess. I have no basis for that.
5 Q Dr. Linnemann, is Chernobyl within the Ukraine?
l 6 A (Witness Linnemann) Yes, it is.
l 7 Q Are you familiar with the force collectivisation l
8 in the Ukraine after the Soviet system was initially 9 established?
10 A I'm familiar that collective -- what did you 11 say?
12 O Collectivisation.
I
- { } 13 A Co11ectivisation occurs in the Soviet Union in
' "i 14 the Ukraine, but it would be my impression that it's not 15 total. There are some private farmers.
16 Q Do you know what sort of coercion was applied to I
17 get Ukrainian f armers to leave their private land and join 18 collectives? j 19 A To join Collectives?
l l 20 Q Yes. )
21 A Oh, nc, I wouldn't. I just know -- I thought l
22 you were referring to, they had a difficult time getting 23 them to leave this area of contamination.
24 0 ,
Well, I'm talki ng about, let's say, the early 25 stages of the Soviet system. Are you familiar with the r coercion that was used to force Soviet -- excuse me,
17520 11801111 suewalsh
(.,
\ 1 Ukrainian peasants and f armers to leave their land and join 2 collectives?
3 JUDGE MARGULIES: Mr. Case, how is this' relevant
- 4 to the issues before us? 1 5 MR. CASE
- I think, Your Honor, it's clearly l 6 relevant. This is a totally different society here that we l 7 are talking about, and there is a historical bases in the 8 Ukraine. It's a different culture and the ties to the land 9 are so intense that, in fact, over time it would surprise me 10 also if anyone left the land in an evacuation.
11 JUDGE MARGULIES: Well, accepting as true where 12 your questions are going, that brings ur up to 1940.
(} 13 MR. CASE: All right.
14 JUDGE MARGULIES: And, it has been a long time 15 since 1940. )
16 (Laughter.)
17 MR. CASE: All right. Well, the point is well 18 taken, Judge Margulies. Thank you.
19 WITNESS LINNEMANN: I think if I might just add 20 a point there, I think it was -- at least from the I l
21 discussion with the Russians impressive that the citizens I i
22 followed their directions after this accident and were quite l l
23 orderly. It was quite impressive. l l
24 BY MR. CASE: (Continuing) 25 Q In other words, citizens evacuated after the
I l
11801111 17521 suewalsh 1 accident?
2 A (Witness Linnemann) When they were told to 3 shelter first and they sheltered; and, then they were told 4 to evacuate and it seemed as their presentation as a very 5 orderly process.
6 Q So, how did this-last sentence relate to what 7 you just described, your sentence in Question Number 30, "In 8 fact, he explained that they had a problem persuading some 9 people to leave...?"
I 10 A That's -- well, there are two different types of 11 population. One was the population in the larger cities l l
12 such as Pripyat, a large city of 45,000, and probably I 13 guess you would say a little more educated or as workers in
' these plants.
14 And, what I was referring to here and they' 15 were referring to were individual farmers who had their 16 small farms. They just didn't want to leave their farms.
17 Those were the ones they had a difficult time 18 persua" ling to leave.
19 Q So, in other words, the people in a more 20 urbanized arr a followed the evacuation?
21 A 13eemed to, right. Seemed to be more responsive 22 to understanding the situation.
23 Q Now, Dr. Lindell, when -- during an emergency 24 people respond to physical cues . Is that your experience 25 as a -- in your profession?
O
. J
17522 11801111 .
suewalsh i A (Witness Lindell) Yes, that's very often the 2 _ case.
3 0 In other words, they analyze physical cues in 4 assessing a situation during an emergency?
5 A Frequently, but that's not the.only source of 6 warning confirmation.
7 Q But, that is one source of warning confirmation e in emergencies is the analysis of physical cues ?
9 A That's Correct.
10 Q Okay. And, physical cues , just so we are clear 11 on the term, include as an example, if you look out the 12 window and see the winds as a hurricane approaches and the
[]} 33 strength of the winds; 1s that a physical cue?
14 A That would be a physical cue, yes.
15 Q Similarly, in a flood those physical cues , you 16 can observe the water level at some point in time. Is that 17 a physical cue also?
18 A It may not be perfectly reliable, but that is a 19 type of physical cue.
20 Q Now, in a nuclear emeigency radiation is 21 colorless; is that correct?
22 A To the best of my knowledge, yes.
23 Q All right. And, radiation is also odorless; is 24 that correct?
25 A That's also true.
O
17523 11801111 suewalsh
) 1 Q Okay. And, radiation does not provide a 2 physical cues; is that correct?
3 A No, but an accident would.
4 0 You say an accident would. What do you mean?
1 A Well, the radiation or more properly speaking, 5
)
6 radioactive materials are carried by the wind and so the 7 wind direction and wind speed would be a physical Cue in a 8 radiological emergency, the same as it would be in most 9 other kinds of toxic chemical emergencies.
1 10 0 Well, as a citizen, in the event of an accident 11 I can't make a determination myself simply by observing my ,
j 12 body or area outside my house whether radiation has reached
_ 13 me just on the basis of that information; 1s that correct?
' A l
14 Well, I'm not really an expert, complete expert, 15 in that area. I've been told that there are, for example, i 16 certain kinds of -- I guess there is a certain kind of 1
17 flower, a spider wart, that is sensitive to radiation and i 18 that it can be told by camera film whether you have been in 19 a radiation exposed area. So, I guess I'm having a little 20 bit of difficulty responding to your question.
21 Q I guess, assuming I don't plant my garden with 22 flower warts or --
23 A Spider warts.
( 24 Q -- spider warts or similar flowers --
l 25 A I think it's a great idea.
n
.)
l l
11801111 17524 j 1 0 -- can I observe with my own two eyes, with my 2 sense of smell or any other physical senses whether I've 3 been exposed to radiation?
4 A No. If the wind is blowing in your direction, 5 you wouldn' t be able to tell whether there is radioactive 6 material in it.
l 7 Q Now, the reception centers, Bellmore, Hicksville 1
e and Roslyn, Docter Lindell, have you visited those reception 9 centers?
10 A Yes, I have. i 1
11 Q Okay. And, when they are not in use during an 12 emergency as reception centers they are used for the 13 ordinary purposes that they were designed for --
)
14 MR. CHRISTMAN: Obj ec tion. Asked and answered l
15 this morning.
- 16 MR. CASE: It was asked of Dr. Crocker what they 17 were used for, and that's not my question to Dr. Lindell.
18 MR. CHRISTMAN: It sounded like the same 19 question to me.
20 JUDGE MARGULIES: I will permit the question as 21 an introductory question.
22 MR. CASE: Thank you, Judge.
23 BY MR. CASE: (Continuing) 2d Q When they are not being used as an emergency, 25 reception centers have other fun'ctions for LILCO; is that O
11801111 suewalsh 17525 1 correc t?
2 A (Witness Lindell) I can only surmise that they 3 have them there for some other reason. They have lots of 4 other equipment and buildings, and it would -- I can't
\
5 conceive of any reason for having them there other than some 6 normal daily function.
7 Q Okay. You don't -- other than what Mr. Crocker 8 told the Court this morning -- know what their normal daily.
9 function is?
l 10 A Other than what I saw when I was there, which 11 was the material that was in place in the yards, the 12 buildings. That's the extent of my knowledge about what 13 kinds of activities take place in those facilities.
'd 14 Q Now, is it your understanding that in the event is of an emergency which would cause the activation of 16 reception centers, they would used as sites for monitoring, 17 Dr. Lindell?
18 A Yes. I think that's what the emergency plan 19 calls for.
20 Q Do you know if that monitoring would be 21 conducted by workers in protective clothing?
22 A On the day that I observed a training session, 23 the radiation monitors did don protective clothing.
24 O Ms. Dreikorn, maybe you can help us out on 25 this. Does monitoring occur -- when it occurs, do the O )
~
I
0 11801111 17526 I
( 1 monitors wear special clothing?
2 A (Witness Dreikorn) When you are discussing i
3 special clothing, what exactly are you referring to, please?
4 Q Do they wear some sort of protective clothing?
5 A There are several articles of protective 6 clothing that could be donned when you are exposed to an 7 environment containing radioactive material. So, I'm 8 interested in what specific articles of protective clothing 9 you are referring to.
10 Q Well, I'm interested in what the plan calls 11 for. What does the plan call for in terms of specific 12 articles of clothing?
13 A Initially, the workers would be donning u protective clothing consisting of gloves and booties. In 15 addition, they may be requested at some time when it has 16 been determined that there is truly a particulate release 17 that it is necessary to don additional protective clothing, is and at that point they would be instructed to dress in !
)
19 protective clothing consisting of the white coveralls.
20 And, that would be something that would be told 21 to them by their decontamination leaders.
22 Q So, in the event of a particulate release the 23 monitors would don protective clothing consisting of white 24 coveralls in addition to their gloves and booties?
25 A That's correct.
O
.--_--.-._____.-_-__-____-._--w
i 11801111 2 suewalsh
!_() 1 Q And, monitoring is done, Ms. Dreikorn, in the i
2 event the reception centers had to be activated with 3 specialized equipment; is that correct?
I 4 A Yes, that's correct. i
)
5 Q Now, Ms. Dreikorn, you are familiar with each of )
6 the reception centers; is that correct?
7 A Very well.
8 MR. CASE: Judge, if we could have Just a moment 9 to cet up a stand.
10 JUDGE MARGULIES: It might be helpful if you 11 could set that up further back, because you are not letting 12 all counsel see it.
13 JUDGE SHON: In the past, we've used the area
'" 14 between the witness table and the Intervenor's counsel is table. It works pretty well. Then, everyone can see it.
16 (An easel is being set up.)
17 MR. CASE: Judge Margulies, we are handing out 18 copies of this photograph which I would request be marked 19 Suffolk County Exhibit Number 6.
20 MR. CHRISTMAN: I want to object to even marking 21 it until I know what this document is and whether we've had 22 notice of, whether we've had a chance to examine it and that 23 sort of thing.
24 I assume the County is going to say what these 25 pictures are and whether they were served on the parties in O.
11801111 suewalsh 17528 1 advance.
2 MR. CASE: Judge, I will represent to you and 3 subj ect to verification by Mr. Christe.an that these are a copies taken from the direct testimony of David G. Hartgen 5 and Robert M111spaugh submitted on April 13th, 1987.
6 In fact, you Can see in the copy that is handed 7 to counsel and the Court, it's marked Exhibit 6, Hicksville 8 Area B in the upper right-hand corner. And, in fact, this 9 is Exhibit 6 from that direct testimony.
10 MR. CHRISTMAN: That's what I thought they are.
I 11 And, if that's the case, if it's those color pictures that 12 were served with the State's testimony we don' t obj ect to
() 13 them being marked. -
14 JUDGE MARGULIES: It purports to show Hicksville 15 Area B; is that correct?
16 MR. CASE: That's correct, Your Honor. And, we l 17 can ask Ms. Dreikorn about specifics.
18 WITNESS DREIKORN. I'm having a very difficult 19 time visualizing from the exhibits I've been given and also 20 from your photograph. I'm just trying to get my bearing.
21 JUDGE MARGULIES: The document will be marked 22 Exhibit Number 6 for identification.
23 Let the record reflect that there is an 24 l cnicrgement of the exhibit posted on a board that has been 25 made available for all of the parties to see. l C:)
11801111 suewalsh 1 (The photograph referred to is 2 marked as Suffolk County Exhibit 3 Number 6 for identification.)
4 BY MR. CASE: (Continuing)
I 5 O Ms. Dreikorn, it might help you, this is taken 6 from New South Road basically west.
7 A (Witness Dreikorn) Okay. Fine.
8 Q Okay. Does it look familiar now?
9 A Yes, it does.
10 Q Okay. Is this, in fact, generally the 11 Hicksville reception center, focusing specifically on Area 12 B?
13 A Yes. It is a portion of the Hicksville L 14 reception center known as Area B in our plan. .
I 15 0 And, in the upper left-hand corner, is that some 16 commercial buildings that surround Hicksville or near, how 17 about that?
18 A I would like to take a closer look.
19 Q Sure.
20 (The witness is looking at the photograph.)
21 A Okay.
22 Q Are those commercial buildings that are near the 23 Hicksville reception center in the upper left-hand corner?
24 A Are they commercial buildings?
I 25 0 Yes. l I
. )
11801111 17530 1 A They are buildings for some of the -- are you 2 referring to these buildings here?
-3 Q No. I'm sorry. I'm talking about buildings not -
4 on the facility itself but on the upper portion of the
$ photograph?
6 MR. CHRISTMAN: I would like to object unless 7 counsel is going to describe for the record what part he is a talking about. I don't think this is going to be 9 intelligible in the written record unless we do a more 10 careful job of specifying about what we are talking.
11 MR. CASE: All right. I will attempt to make a 12 more careful specification. ,
13 BY MR. CASE: (Continuing)
(}
14 0 You will notice on the upper left there are 15 white buildings, they appear to be one or two-story I i
16 buildings, and behind those white buildings other )
17 buildings. Do you see those?
18 A (Witness Dreikorn) Yes, I do.
19 Q And, are those commercial buildings that are 20 near the Hicksville reception center?
21 A Yes. I believe those buildings are off the 22 Hicksville property line.
23 Q Okay. Maybe we can make this clearer by looking 24 at another photograph of the Hicksville reception center.
25 (A photograph is being distributed.)
O
17531 11801111 suewalsh lk )
1 MR. CHRISTMAN: I take it this is also one of 2 those photographs that were served with the State's 3 testimony.
4 MR. CASE: Yes.
5 JUDGE MARGULIES: Do you wish to have that 6 marked, counsel?
7 MR. CASE: Judge Margulies, yes. I would 8 request that this next photograph be marked as Exhibit 7 for 9 identification, Suffolk County Exhibit 7 for identification.
10 It bears the heading, "Hicksville Area A." And, 11 it also has Exhibit 5 on it whi':L is the exhibit number from 12 the direct testimony of David Eartgen and Robert M111spaugh.
JUDGE MARGULIE3:
O J
$1 14 It will be so marked.
(The photograph referred to is is marked as suffolk County Exhibit 16 Number 7 for identification.)
17 i BY MR. CASE: (Continuing) 18 Q Ms. Dreikorn, do you recognize Exhibit 77 19 A (Witness Dreikorn) Yes, I do.
20 Q And, is that another photograph of the 21 Hicksville reception center?
22 A It's another photograph of a portion of the 2- Hicksville reception center.
24 Q In the lower one-third of that photugraph, there 25 appear to be houses, residential dwellings in the
.O.
w_ _- - - __- -_ _ _ - __ - ____ __ _ - _ _ _ - _ . . . - - . ~. - . _ _ - - . - _ - - _ _ _ _ . _ . _ - _ - - _
11801111 17532 suewalsh O > photoarepa. Taer h=ve white roofe. xose of taem eppeer to 2 be painted white.
3 Do you recognize those?
4 A would you indicate specifically waere you are 5 referencing?
6 Q Yes. The lower third of the photograph. Is 7 that a residential area next to the Hicksville reception 8 center?
9 A Yes. There appear to be some homes there.
10 11 12 O
1.
15 16 17 18 l 19 l
l 20 21 22 )
23 2:
25 O
51801212 17533 joewalsh k,( ) 1 Q Do you know what the density is of the 2 residential area?
3 A (Witness Dreikorn) Not offhand, no.
4 O Have there been any studies done of the density 5 of that residential area?
6 A Not that I am aware of.
7 Q I would like to have the next exhibit marked --
8 JUDGE MARCULIES: Before we move on, is there 1
9 any inter-relationship between what is pictured on Exhibit 10 No. 7 f or identification, as contrasted to Exhibit No. 6 for 11 identification? Are they two separate areas, not connected.
12 BY MR. CASE: (Continuing) 13 0 What is referred to as Exhibit 8, Area A7
'" 14 A (Witness Dreikorn) Area A is an area where we 15 will be doing initial monitoring at the Hicksville Reception 16 Center, and I will show that to you on the diagram now.
17 This area in here (Pointing). And this area 18 here (Pointing), will be utilized for monitoring 19 individuals.
20 0 The record should reflect, and correct me if I 21 am wrong, you pointed to an area -- parking lot area and the 22 grassy area in front of that parking lot directly in the 23 center of this photograph?
24 A 11 I pointed to a grassy area, I didn't intend l
25 to. What I am pointing to is the parking areas where there 1
17534 l 51801212 joewalsh
() i is ample space between the cars, for additional cars to 2 travel through and be monitored, as well as the people in 3 those vehicles.
4 Q So, Area A is limited to the parking lots there 5 in the center of the photograph, is that correct?
6 A That is correct.
7 JUDGE MARGULIES: My question was, is there any 8 inter-relationship between Exhibit No. 6 for identification?
9 MR. CASE: Judge, Exhibit No. 6, if we can put to that back up there for a moment.
11 (Exhibit No. 6 attached to easel.)
12 BY MR. CASE: (Continuing) 13 0 Now, if we can look at this photograph, what has 14 been marked as Exhibit No. 6 for identification, would you 15 point out where Area A is on that photograph for the Judge?
16 A (Witness Dreikorn) You would like me to point 17 out Area A on this photograph?
18 Q Yes. First.
19 A Okay. Area A is quite in the distance from the 20 perspective that this photograph has been taken, but I will 21 attempt to show you Area A.
22 Area A would be the area up here (Pointing), in 23 the upper right hand corner.
24 Q Would you show us where what is referred to as 25 Area B of the plan 1s?
O ,
..--...__-_-------______m
51801212 17535 Joewalsh l( }
1 A Area B is a lot clearer, although not very well 2 visible. It is this area here (Pointing.) Where monitoring 3 will also be taking place of people as they arr4ve in their 4 vehicles.
5 JUDGE MARGULIES: Am I correct that the 6 residential area would be off that picture? We don't see 7 it?
8 WITNESS DREIKORN: That is correct, Judge. The j 9 residential area is off that picture.
1 10 JUDGE MARGULIES: And as we heard before, the 11 commercial buildings, or what was indicated as commercial 12 buildings, would be to the left on that picture?
13 WITNESS DREIKORN: The commercial building are
14 located up here, the white buildings, and they are well 15 beyond the railroad tracks that are beyond the LILCO 16 property line. 4 I
17 BY MR. CASE: (Continuing) I 1B Q Do you know if there is a residential 19 development that would be in the lower -- below the lower l 20 portion of this exhibit?
21 MR. CHRISTMAN: I am going to cbj ect to that 22 question, which is a continuation of earlier question, 23 absent any showing of relevance. I don't think that any 24 relevance has been shown for this whole line of questions, 25 or for these pictures, compared to the admitted issues in I
l 51801212 Soewalsh 17536
() 1 this case, that is.
2 MR. CASE: Judge, one of the issues that is 3 thoroughly developed in this case, and has been developed 4 both in the direct testimony of Suffolk County and the 5 testimony of LILCO, is what is referred to as evacuation 6 around the reception centers, because they are local land 7 uses, and this testimony goes directly to that.
e The fact that there are residential areas around 1 i l 9 reception centers as well as commercial developments, and it !
l 10 bears directly on whether there is going to be an evacuation 11 surrounding reception centers.
12 MR. CHRISTMAN: I withdraw the ob]ection to that 13 question.
14 BY MR. CASE: (Continuing) 15 Q Do you recall the question?
16 A (Witness Dreikorn) Could you please repeat your 17 question?
18 Q All right. Is there a residential development, 19 to your knowledge, any residential development, that is not 20 pictured on this photograph that would be right below this 21 grassy area at the bottom of the photo?
22 A Yes. To the best of my knowledge there are 23 residences in the lower portion of the photograph that you 24 are showing me here.
25 I would also like to point out that this is not O
51801212 17537 joewalsh
.k ) 1 unusual or unique approach of reception center planning.
j 2 O Judge, I would have to obj ect.
l l 3 MR. CHRISTMAN: I would like f or counsel not to 4 interrupt the witness.
5 BY MR. CASE: (Continuing) 6 Q The question was: Were there. residential 7 developments, not whether it was unique or unusual for this 8 plan.
9 JUDGE MARGULIES: I think it is quite clear l 10 where the answer was going, and it wasn't non-responsive, 11 and you may want to come back to that, Mr. Christman, and go 12 into it on redirect.
13 MR. CASE: Judge Margulies, I would like to have
)
'" 14 marked as 'Suf f olk County Exhibit 8 for identification, the 15 photograph, copy of which counsel and Board received, with 16 the heading: Roslyn Reception Center. It is indicated as 17 Exhibit 3, and it is from the direct testimony of David 18 Hartgen and Robert M111spaugh.
19 JUDGE MARGULIES: It will be marked as Exhibit 20 No. 8, for identification.
21 (The above referenced document is 22 marked Suffolk County Exhibit No. 8 23 for identification.)
24 BY MF. CASE: (Continuing) 25 O Mrs. Dreikorn, do you reccgnize Exhibit No. 8 r0,
51801212 j oewalsh I for identification?
2 A (Witness Dreikorn) Yes, I do recognize this
{
3 photograph.
4 Q And is this photograph -- well, what is this a 5 photograph of?
6 A What I would really like to see is a drawing of 7 the plan for the Roslyn facility so I could compare it, if s this is, in fact, Roslyn, it would in fact help me if I had 9 a reference of our plan diagram.
10 0 Do you know if this is the Roslyn facility?
11 A It appears to be Roslyn, although all the Roslyn l 12 LILCO buildings are not in this photograph.
13 Q Taking that as a given, does this appear to be a i 14 photograph of at least a portion of the Roslyn facility?
15 A As I said, it appears to be Roslyn, although not 16 all the LILCO Roslyn buildings are in the photograph.
l 17 O Are there residential developments, or housing is surrounding the Roslyn facility?
19 A Yes, I think it is clear on the photograph that 20 there are some houses beyond the facility boundary lines.
21 Q Do you know what the density of the housing is 22 around the Roslyn facility?
23 A No , I do not.
24 Q Do you know if any studies have been made of the 25 density of the housing around the Roslyn facility?
O
17539 )
51801212 l j oewalsh I I. ( ) 1 A I am not aware of any studies on that.
2 MR. CASE: I ask that the following picture be 3 marked as Suff olk County Exhibit No. 9 for identification.
4 The copy the Board and counsel have received is with the ,
l 5 heading: Bellmore Reception Center, Exhibit 4, and it 1
6 refers to Exhibit number of David Hartgen .and Robert l 7 M111spaugh.
8 JUDGE MARGULIES: It will be marked as Suffolk 9 County Exhibit 9 for identification.
10 (Above referenced document is l 11 marked Suffolk County Exhibit 9 l l
12 for identification.)
13 BY MR. CASE: (Continuing) l L- 14 O Do you recognize, Mrs. Dreikorn, what has been l
15 marked as Exhibit 9 for identification?
16 A (Witness Dreikorn) Yes. This appears to be the 17 LILCO Bellmore facility.
I 18 Q And are there housing developments around the
, 19 Bellmore facility?
l 20 A Again, I think it is clear from your photograph 21 that there are houses that are in the furthermost portion of 22 the photograph, and they are well off the LILCO boundary.
23 Q Do you know what the density is of the housing 24 around the Bellmore facility?
25 A No, I do not.
r0 -
l
1 17540 51801212 Joewalsh G
(_) i Q Do you know if any studies have been done of the
]
2 density of the housing around the Bellmore facility?
3 A N6, I do not know of any studies.
4 JUDGE MARGULIES: Is that tNe entire Bellmore 5 facility?
6 WITNESS DREIKORN: Actually, Judge, no, it is 7 not the entire Bellmore facility. There is a portion that s is cut off from the photograph that is the western most 9 portion of the facility.
10 It is an additional parking lot area, and also 11 there is an area of field also to the west that has been cut 12 off.
i3 BY MR. CASE: (Continuing) ja Q How much of the area has been cut off, do you I 15 know?
16 A I would have to approximate that maybe eight to 17 ten percent has been cut off.
le Q And that is primarily paved parking lot area 19 that has been cut oti?
20 A It is a parking lot area, and also a portion of 21 field.
22 O I don't have any further questions about uhis.
23 Dr. Mileti, if you would turn to Page 25 of the testimony.
24 A (Witness Mileti) Yes, I am there.
25 0 If you will look at the second paragraph, second
( .
17541 51801212 joewalsh
.() 1 sentence. It indicates there the main relocation center at 2 Three Mile Island was approximately ten miles from the 3 reactor.
4 Do you see that portion of your testimony?
5 A Yes, I see that.
6 Q Was the relocation -- let's backup on that 7 question. Were people at Three Mile Island ordered to 8 report to relocation center for monitoring at Three Mile 9 Island?
10 A No. I think I already said that no one was 11 advised to get monitored during Three Mile Island as I 12 recollect what occurred.
- 13 0 At Three Mile Island, the relocation center was
- 14 used for sheltering,' for people that didn't have anywhere 15 else to go, is that correct?
16 A As I recollect, it had that capacity, and it 17 also had other capacities.
18 Q Now, you indicate in the -- I guess it is the 19 fourth sentence of that paragraph, that such centers are i
20 little used in any evacuation. I 21 Do you see that portion? l 22 A Yes, I sure do.
23 Q Is there any instance that you are aware of 2a where relocation centers were used as monitoring centers for 25 radiological emergencies?
17542 51801212 joewalsh
() 1 A To the best of my knowledge, no. Absolutely. I 2 just know of no event like that.
3 MR. CASE: Judge Margulies, this is a good 4 stopping point then in this examination. We can take our 5 mid-afternoon break now. It would be a logical point.
6 JUDGE MARGULIES: Is there any objection?
7 MR. CHRISTMAN: No ob]ection.
8 JUDGE MARGULIES: We will recess until three 9 o' clock.
l 10 (Whereupon, afternoon recess was taken at 2:45 11 p.m., to reconvene at 3:00 p.m., this same day.)
l 12 O "
\
i 1
l l I 15 16
\
1 18 19 20 21 22 23 2A 25 0
1 1
17543 !
51801313 I marysimons i l_( ) 1 JUDGE MARGULIES: Back on the record.
2 The air conditioning in this room can be 3 somewhat uneven. So it counsel want to remove their jackets l l
4 at any time during the hearing, it is perfectly permissible.
5 CROSS-EXAMINATION (Resumed) 6 DY MR. CASE:
l 7 Q Dr. Lindell, isn't it true that during an 8 emergency people react on the basis of their perceptions of 1 l
9 the risk?
10 A (Witness Lindell) Yes, that's true, their 11 perceptions of risk based on the information that they have 12 at the time.
_ 13 Q Now, Dr. Linnemann, isn't it true that delays in
'" 14 monitoring cause psychological anxiety?
l 15 A (Witness Linnemann) Not necessarily. I think 16 that also is a function of the inf ormation which people ,
17 receive or their perception of the risk of contamination.
le Q Well, is it possible that delays in monitoring, i
19 is it possible that they cause anxiety?
20 A Again, I think it's very much a function of the 21 information they receive, and I think 11 they receive the 22 proper information, that contamination basically under these 23 circumstances is not a limiting factor in any action they 24 take. It's not the major health problem.
25 Q Do you recall tes'tifying at a deposition I took no.
1 1
17544 51801313 i marysimons
]
() 1 back on March 5th of 1987?
2 A I recall that we did a deposition, yes.
3 Q And do you recall the following question: "In 4 other words, some delay -- referring to monitoring here --
5 some delay is conceivably psychologically detrimental, 6 although it may not be biologically detrimental, causing 7 anxiety or whatever?
8 Answer: "I'm certain there would be anxiety in
\
this, yes."
10 Do you recall that answer?
A I recall the answer, but again I think it's il
)
l l 12 qualified by that it depends on the information they i i
I l
l () 13 14 received about the contamination.
Q So back on March 5th, 1987 under oath you were l
l 1
15 certain there would be anxiety? Wasn't that your testimony l 16 back then?
17 A Right, but again I would quality that if I is didn't then now that it certainly is a function of what they 19 are told about contamination as to how much anxiety there 20 would be.
21 Q So you do acknowledge there would be some 22 anxiety, and the question is how much?
23 A I think it's a function of the information. In 24 some cases -- in an understandable case it may be very 25 little, and in others with no information, it could be a O
l l
17545 51801313 marysimons
_( ) I very high degree of anxiety. I've seen it both ways.
2 O Now, Mr. Donaldson, remember we discussed 3 whether people in Suffolk County would behave the same way l
4 people did at Three Mile Island should there be a disaster l 5 at Shoreham. Do you recall our discussion Just today about j 6 that?
7 A (Witness Donaldson) Yes. I remember you had 8 asked me a question, yes.
i 9 Q Your testimony, as I recall it, was that people I 10 would act the same today in Suffolk County as they did at 11 Three Mile Island under similar circumstances; is that 12 correct? ,
i 13 A I believe that was my response, yes, with 14 similar information and similar circumstances, yes. +
15 Q Do you recall the deposition you and I had back it on March lith of 19877 l 17 A Yes.
IB Q Imd do you recall the following question: "So 19 as with Three Mile Island, you expect that people will 20 behave in radiological disaster such as might happen at 21 Shoreham as they did at Three Mile Island?"
22 Answer: "Yes. I have no reason to expect 23 otherwise."
24 Do you recall that?
25 A Yes.
1 1
17546 51801313 marysimons
() 1 Q And that testimony was under oath?
2 A That's correct.
3 O And your answer there was unqualified?
I a A Yes. l 5 MR. CASE: Judge Margulies, at this time I would 6 move the admission of what have been previously marked as 7 Suffolk County Exhibit No. 4 for identification, Suffolk 3 County Exhibit No. 5 for identification, Suffolk County 9 Exhibit No. 6 f or identification, Suffolk County Exhibit No.
10 7 for identification, Suffolk County Exhibit No. 8 for 11 identification and Suffolk County Exhibit No. 9 for 12 identification.
13 JUDGE MARGULIES: Is there any objection? !
14 MR. CHRISTMAN: No objection as to 4 and 5, no 15 objection on the photographs subject to the condition that 16 the proper foundation be provided when the State's witnesses 17 are made available. I note that the foundation may be le necessary because photographs can be misleading, particular 19 aerial photographs from a particular angle, particularly 20 photographs that cut off part of the picture and 21 particularly in light of the fact that we have diagrams that 22 show a much better or allow a much better picture of what 23 goes on at these reception centers.
24 But subject to that qualification, no ob]ection.
25 MR. CASE: Judge, I would respond to that O
1 1
i 17547 51801313 marysimons
_( ) 1 objection or qualification by saying a sufficient foundation 2 has been laid. Under the Federal Rules of Evidence or any 3 rules, photographs are admissible if they depict the area.
4 The accuracy in terms of angle of the photograph merely goes 5 to the weight and not the admissibility of that evidence, 6 and these were identified by Ms. Dreikorn I believe.
7 JUDGE MARGULIES: Exhibits 4 and 5 for 8 identification will be admitted into evidence.
9 (Suffolk County Exhibits 4 and 1
10 5, previously marked for 11 identification, were admitted )
i 12 into evidence.)
I 13 JUDGE MARGULIES: As to Exhibits 6, 7, 8 and 9, j l --
14 the witness identified the areas and testified specifically i
l I
15 about the areas. They, too, will be admitted into evidence. '
16 (Suffolk County Exhibits 6 through i
17 9, inclusive, previously marked for I 18 identification, were admitted into 19 evidence.)
I 20 MR. CASE: I have no further questions on these '
21 three sections of the LILCO testimony.
22 Mr. McMurray will now examine the witnesses. I 23 BY MR. McMURRAY: l 24 Q Mr. Crocker, you and I had a discussion early 25 this mo;ni:9 regarding whether there were any barrels of
17548 51801313 marysimchs 1 substances on the property close to Area B. Do you recall
(} ,
2 that? .
3 L (Witness Crocker) Yes, I do. !
l 4 0 Let me show you the color photograph which has 5 been marked and admitted as Suffolk County Exhibit No. 6, 6 which is Hicksville Area B.
7 (Counsel McMurray approaches with a large a photograph the witnesses.)
9 I think this would be the most efficient way to 1
10 do this.
11 In the middle of the photograph ---
12 JUDGE MARGULIES: Do you wish to say something, 13 Mr. Christman? l 14 MR. CHRISTMAN: No. I'm going to let him get is his question out before -- no one can see it except the one 16 witness, and it needs to be I think put up so that we can 17 see what we are talking about.
18 MR. McMURRAY: Unfortunately, we only have one 19 color photograph, and what I'm going to be pointing to is 20 small detail. If there is a problem, I can show the Board 21 exactly the portion of this photograph that we are referring 22 to, but I would just like to ask my question and get it out 23 first.
j 24 JUDGE MARGULIES: You may.
25 BY MR McMURRAY:
O i
51801313 1754S marysimons 1 Q In the center of the photograph there seem to be 2 some rows of what I think are barrels which extend across l
3 the middle of the photograph right there and around here.
4 Do you know what those barrels contain?
5 A (Witness Crocker) I think those barrels are 6 transformers.
1 7 Q Those are transformers? I 8 A Yes.
l 9 What abou t these items right here?
Q 10 A Some of those are transformers and some look 11 like plastic containers that are cylindrical barrel shaped, 12 and some of those might be barrels, but we're pushing 13 photography.
'(
14 Q But you don't know then whether those are i5 barrels or not? l
)
l 16 A I'm not sure. The gray ones are generally {
17 uniformity transformers. Things that are other colors, some le of them may indeed be barrels. I l
19 0 Okay. Has anybody checked to see whether there 20 are barrels containing harmful substances in and around Area i
21 B?
22 A I'm glad you asked me that. We make a practice 23 of storing the harmful stuff, if you can see that, over in 24 this corner, as I referred to before.
25 JUDGE MARGULIES: Would you describe for the l
l m _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . . . _ .
17550 51801313 marysimons j
() i record which corner you're pointing to?
2 WITNES3 CROCKER: Okay. In the photograph it's 3 the top left-hand corner. In terms of compass directions, 4 it's the southwest part of the property. As you know, 5 sometimes in transformers we have quantities of PCBs or 6 something like that, and it's my understanding that we keep 7 that stuff in this remote corner of the property.
8 BY MR. McMURRAY:
9 0 Okay. You say remote corner. Under the j 1
10 expanded version of your monitoring scheme, isn't it true 1
11 that there would be some monitoring stations on the road leading to that corner that you just pointed out? I 12 j i
13 A (Witness Crocker) Let me find my layout, if you la will. i 15 MR. CHRISTMAN: Judge, we do have an enlargement l l
16 of those layouts in the back of the room which we can t i
17 display at any time it it will help.
l 18 MR. McMURRAY: I think he is turning to a page 19 in the testimony, Judge Margulies, that everybody has and we 20 can just refer to that I think.
21 WITNESS CROCKER: Bear with me while I find it.
22 (Pause.)
23 The monitoring that you alluded to, as I l
24 understood the question, and I'll try to point this to you,
{ 25 Judge the monitoring takes place in this region right here O .
17551 51801313
_( 1 where it's the south end of this loading platform or storage 2 area, if you will. My understanding is they keep those 3 wastes further down this road here. I 4 Now there is, as you see, a road going through 5 the area and we would have vehicles transit that, buy the 6 actual monitoring is away from the area up here. So vehicles 7 would be traversing the road along which are stored these 8 toxic chemicals.
9 JUDGE MARGULIES: Before you go forward, Mr.
10 McMurray, you spoke in terms of one question involving that 11 photograph.
12 Is counsel for the applicant satisfied with this 13 procedure or do you want it up on the board?
L" 14 MR. CHRISTMAN: I take it you are about through 15 with your questioning.
16 MR. McMURRAY: I have one more question.
17 BY MR. McMURRAY: 1 i
18 O The question is that cars would be traversing 19 the road along which these chemicals are stored, correct, 20 which is the road on the photograph that runs from roughly 21 the center lef t of the photograph up to about three quarters 22 of the way up to the photograph?
23 A (Witness Crocker) It's generally stored in this 24 area and, like I said, it's our practice to keep it 25 removed. So you won't find it immediately adjacent to the
17552 51801313 marysimons road I don' t believe. But, yes, the road does traverse the
({} 1 2 area where we store these chemicals.
3 Q Let's go to page 40 of the testimony. This is 4 the section that concerns monitoring.
5 Now, ME. Dreikorn, do you see the response to 6 Question 66 where there is a discussion of the primary 7 method of monitoring at the LILCO reception centers?
e A (Witness Dreikorn) Yes, I do. What this is 9 referring to is the initial monitoring phase of our 10 reception center.
11 Q And that monitoring of the individuals or the 12 evacuees is to be done while those evacuees are seated in i3 their automobiles; is that correct?
(:) -
14 'A That is correct.
15 Q And that is correct even for two-door cars; is 16 that correct?
17 A Yes, that is correct.
18 0 And where passengers then are seated in the back 19 seat of a two-door car, the monitoring would still be done 20 while they are seated in the back seat, correct?
21 A Yes, that is correct.
22 Q With respect to monitoring. evacuees inside their 23 cars, this method is not used in any other plans, is it?
24 A There are many variations to how monitoring is 25 conducted at general public reception centers, and from my 0
17553L 51801313 marysimons
_() 1 knowledge in speaking with other people in the emergency 2 planning field, there are situations where people are being 3 monitored in vehicles, yes.
4 Q Can you tell me where and at what plants or for 5 what reception centers monitoring is conducted as a primary 6 method while people are in their vehicles?
7 A I am aware of a couple of plans in New York 8 State, in operating nuclear power plants in the State where 9 this is done as a screening process of individuals as.they 10 drive into a facility, and that is a similar approach as we 11 are doing a screening process at our initial monitoring 12 stations at our reception centers.
13 Q Mr. Watts, are you aware of the identities of 14 any other plants where monitoring is done of individuals 15 while they are in their cars as the primary method of 16 monitoring?
17 A I can think of a couple of situations. One in 18 which the initial screening is done of the exterior of a car 19 with people inside the car, and in that particular case 20 there is a check done of the outside of the car 21 contamination. If it's determined that there is 22 contamination on the outside of the car, then that car and 23 its occupants are directed to another portion of the 24 reception center and in that case more detailed monitoring 25 1s done of everyone in the car and the car.
r0
_. _ _ _ _ _ . _ _ . _ . _ _ _ _ ______a
17554 51801313 marysimons
() 1 There is another situation that I'm aware of ---
2 Q Excuse me. Let's identify where that first 3 method that you described takes place?
4 A That's Orange County in New York State.
5 There is another situation that I'm aware of 6 where both the car and at least one person in the car, or at 7 least one passenger is monitored while in the car. And, e again, if there is an indication of contamination, then a 9 more detailed survey is done at another location than the io reception center. There is a wide variety of how this is 11 done nationwide and we have done our best in formulating our 12 our approach and procedure to look at a variety of dif f erent 13 instruments and a variety of different techniques.
O 14 MR. McMURRAY: Excuse me, Judge Margulies, just 15 one second.
16 (Pause.)
17 BY MR. McMURRAY:
is 0 You would agree with me, wouldn't you, that 19 monitoring evacuees in their cars is not a common practice 1
20 in the industry? l 21 A (Witness Watts) I don't know how to answer that i 22 question other than referring to my previous answer that 1
23 there is a range of different methods used, and that is one 24 of them. That is one of the approaches.
25 Q Do you recall when I asked you that question at O
l - - - - - -
1 i
)
I; 17555 51801313 marysimons
_( ) 1 your deposition on March 12th, 1987, Mr. Watts?
2 A Could you refresh my memory?
3 0 . The question was asked: "Is it a common 4 approach to monitor individuals within their vehicles?"
5 Answer: "No, I don't think so. It's a common i
I 6 approach to focus on the head, hands, feet and shoulders."
1 7 Do you have any testimony that is different from 8 that? l 9 A I think that is consistent with what I'm saying.
10 0 So it's not a common approach then to monitor 11 individuals within their vehicles, correct?
12 A I'm saying there is a wide variety of different 13 approaches that are used.
.' k/
14 Q You stand by the testimony in your deposition?
l 15 A I'm standing by both, l l
16 Q Ms. Dreikorn, are you aware of any health l 17 physics texts that discuss the approach of monitoring IB individuals within their automobiles?
19 A (Witness Dreikorn) No, I am not aware of any 20 health physics texts that specifically address that.
21 Q Do you know of any health physics literature of 22 any kind, publications, that discuss monitoring people 23 within their cars?
24 A No, I do not. What I am aware of is in speaking 25 with other people in the emergency and planning field, other
17556 51801313 marysirnons O i emerseacv 91emmere, the aittereme engroecaee ead tae 2 variations taat Mr. Watts is referring to taat are out there 3 being done and practiced at reception centers.
4 5
6 7
8 9
10 11 12
" ~
O 14 15 16 17 1
18 19 20 21 22 23 24 l
25 i O
I I
51801414 17557 suewalsh 1 Q Let me refer you, Ms. Dreikorn, to the -- your' 2 testimony where you state that the traffic guide will take a 3 swipe of one-quarter of the front hood and a wheel well, 4 holding the swipe for one of the monitors to monitor.
5 Do you see that?
6 A (Witness Dreikorn) Could you indicate 7 specifically where you are?
8 0 I'm at the answer to Question 66.
9 (The witness is looking at the document.)
10 A Okay. I've found where you are I believe.
11 O Isn't it possible that there could be hot spots 12 or contamination on areas other than the one-quarter of the 13 hood and the wheel well that would be monitored?
' 14 A Could you repeat that question, please?
15 Q Isn't it possible that there could be what I 16 think in previous deposition testimony has been called hot I 17 spots or contamination on areas other than the front' quarter 18 of the hood or the wheel wells where the swipe is taken 19 from?
20 A I suppose it's possible. But, we are 21 concentrating on areas that had there been a vehicle in an 22 area where particulate were deposited and the vehicle t 23 travelled through, that those particulate would have rested 24 on the surfaces or been thrown up into the wheel well area 25 of a vehicle and we would detect them by this monitoring
51801414 suewalsh 17558
(} ) method.
l 2 (Witness Watts) We actually, when developing 3 the monitoring method, had considered the tact that the 4 typical industry practice is to do a smear over an area of 5 100 square centimeters, which is a square four inches on the 6 side. We determined that going a lot more than that in area 7 would substantially increase the likelihood of catching 8 contamination which we would suspect would be more diffuse 9 and uniform from plume deposition.
10 So, we feel that we are doing a suitable 11 sampling of the car by looking at an area of the hood. And, 12 we figured one-quarter of the area of a hood was sufficient.
13 O Mr. Watts, what's the purpose of monitoring a u vehicle?
15 A Checking for the -- as an indication of exposure 16 to the plume --
17 0 Okay.
18 A -- of the occupants or the vehicle.
19 Q And, you will agree with me that you monitor a 20 vehicle to determine whether it's contaminated so that it 21 won't contaminate something else, correct?
22 A Well, we are using it as one of the indicators 23 of whether the occupants potentially could have been 24 contaminated having travelled through the plume. i l
25 O Isn't another reason though to determine whether l
l I
51801414 17559 suewalsh I
_( ) the vehicle itself is contaminated so that it won't in turn 2 contaminate other people or things?
3 A I think that's a secondary reason. But, our 4 purpose here is to use at as an indicator of contamination 5 of the occupants.
6 Q Okay. Wouldn' t it be prudent then, given that l 7 there is the second purpose that we just discussed, to 8 monitor the cars where people might actually come in contact 9 with them such as door handles?
l 10 A That's why we are looking at the hands of people 11 in the car.
1 12 O Well, but what about the door handles 13 themselves? Don't you want to determine whether they might D
L -
14 be contaminated?
15 A Well, we are covering that by monitoring the l
16 outside of the car and the occupants inside the car, looking 17 at the hands of those people. If we find any indication of 18 contamination then we will do a more detailed monitoring of 19 the car or the occupants.
20 We are using it as an initial screening 21 procedure which we think is reasonable. l l
22 O But, you will agree with Ms. Dreikorn, won't 23 you, that it's possible that the contamination could appear i
24 on other parts of the car other than the hood and the wheel 25 well?
l l
l j
51801414 17560 suewalsh i A I think it 's extremely unlikely.
2 Q But, possible?
3 A Without touching it first? I have a hard time 4 visualizing that.
5 Q Why is that?
6 A Because, as I mentioned before, the way in which 7 we are doing the swipe of the car, we are taking a major e area of the car, of the surface area on the hood, swiping 9 that and also looking at the wheel well. The wheel well is 10 one of four wheels.
11 And, it's hard for me to visualize that 12 contamination would end up in any of the other three and not 13 in one of them that's travelling over a contaminated
( 14 surface. -
15 Q Well, it's hard for you to visualize but what's 16 the basis for your difficulty in visualizing that?
17 A Well, I think I've just explained that. It's is the uniform deposition basically on the surface area that is y traversed by the car.
20 0 The car could be contaminated by someone 21 touching it, right, or brushing up against it by someone who 22 is contaminated?
23 A At what point? What are the circumstances that 24 you are talking about?
l l 25 Q Someone who is contaminated or something that is O
l l
l'
51801414 suewalsh 17561 I
1 contaminated coming into contact with the car?
2 A And the car is not contaminated?
3 Q That's right.
4 A How would that be?
5 Q Something contaminated would be coming into 6 contact with the car. You can't visualize that?
7 A It's ditticult for me.
8 O Let's go to Question and Answer 67 which I 9 believe has been modified. Ms. Dreikorn, this refers to 10 monitoring bus evacuees.
11 Do you see that?
12 A (Witness Dreikorn) Yes, I do.
13 O Okay. Now, the modification, I take it from Mr.
'O 14 Christman's letter which informed us of this modification, 15 took -- was decided on on June 23rd; 1s that correct? Some l l
16 time last week?
17 A Yes, some time last week we made the change in 18 testimony.
1 19 Q Okay. And --
20 A I would like to add that we have been 21 contemplating that change for some time.
l 22 0 Okay. The bus evacuees will now be monitored by 23 having them stand and then the head, shoulders, hands and 24 feet will be monitored as well as X's run across the front 25 and the back, correc t?
, (
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___...-_---._m_- - - - - - _ - - - -
51801414' suewalsh 17562' 1 Is that now the procedure?
2 A- That's correct.
3 Q- Okay. When you say an X pattern, how does this.
4 run across the body? Is it from the -- in the front, is it 5 from the shoulder to the hip?
6 A On the front of the body, the X pattern would be 7 started at the shoulder and carried down to the foot. And, e then it would traverse back up across to the other foot and 9 then back up to the opposite shoulder.
10 And, then the same would be done on the back of 11 an individual travelling to the reception center by bus.
12 Q And, you estimate that this method of monitoring 13 bus evacuees would take about 60 seconds; is that correct?
14 A That is correct.
15 Q And, you further modified the procedure by 16 stating that now the thyroid will not be monitored in the 17 initial monitoring phase, correct?
18 A It was not the intention to monitor' thyroids on 19 individuals as they sat on a bus. So, that is not a change 20 that has occurred. It's actually an oversight that was left 21 in when we revised the procedure and prepared the draft 22 materials.
23 Q You will agree with me though that prior to this 24 change last week the plan did call for -- as written, it did 25 call for a thyroid monitoring of bus evacuees; 1s that O
51801414 suewalsh 17563 I
1 correct?
2 A What I would like to point out, there is a 3 change that has occurred between the manner in which bus 4 evacuees are being monitored at Hicksville. In Revision 8, 5 the evacuees came into a facility and received external 6 whole body monitoring' and a thyrold check once it has been 7 determined that there is no external contaminants present.
8 We have changed with the draft materials that 1
9 are now presented to bring individuals in by bus and 10 monitoring them on the bus. When that change occurred, it 11 was never our intention to include a thyroid. monitoring 12 process on the bus af ter we had completed external surveys 13 for contaminants.
() 14 Q My question was, in those draft materials though 15 as written they called for a thyroid monitoring of bus 16 evacuees, correct?
17 A As I indicated, that was an oversight that 18 occurred when we changed the procedure to the draft 19 materials.
20 Q In Revision 8, the plan did call for thyroid 21 monitoring as you just stated, correc t?
22 A That's correct. The individuals were coming off 23 a bus into a facility for an external and then once it was 1 24 determined there were no external contaminants it was 25 followed up by a thyroid check for internal contaminants.
<<' \
l '\_)
l d
1 51801414 17564 I suewalsh fs 1 Q Okay. And I assume at that time, it was your N~) :
2 opinion that such a thyroid scan was a prudent thing to do? -
3 A The performance of a thyroid scan at that point i 4 would be a very conservative approach. 3 1
5 Q Is that what Mr. Watts just told you? j l
6 A Mr. Watts and I have been discussing thyroid l 7 monitoring for some time.
}
8 Q But he just whispered that in your ear, didn't i 9 he? l 10 A (Witness Watts) Yes. And, I will say it on the 11 record, too.
12 Q Fine.
13 A We have felt that it is a very conservative
() 14 approach. We have asked a number of organizations l 15 nationwide whether thyroid monitoring is done. The LERO 16 plan committed to do thyroid monitoring in some fashion a 17 few years ago.
is We are -- with the exception of the State of 19 Illinois, we are the only organization that I know of that 20 does it routinely.
21 .Q And, is it your opinion now'that such 22 conservatism is inappropriate?
23 A We have preserved the thyroid monitoring .
24 technique where it is done should there be contamination 25 detected from people or in the case of people coming in O
51801414 17565 i
suewalsh l i I cars. Whether it's on the car or on the person in the car,
.(:) 2 they go in for detail monitoring and a thyroid check is then 1
i 3 done. l I
i 4 0 Well, it is possible, isn't it, that someone i 5 could have internal thyroad contamination and not show l
6 outward signs of contamination? j l 7 A That is possible. But, the case is that it )
8 takes time for the iodine to accumulate in the thyroid. It 9 may be too early possibly by the time we measure it. That's 10 one of the reasons a lot of the states and the counties 11 don't do that. They don't contemplate it.
12 I3 r1 o ,,
15 16 17 IB i
19 l
20 21 22 23 i
2A 25 r
.r l
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51801515 '
jotwalch 17566 j Q Let's go to Attachment P, OPIP 3.9.2, Page 9b.
2 Ms. Dreikorn, in the procedures set out in the draft 3
materials prior to their being revised last week, how was a 4 bus evacuee to be monitored?
5 A (Witness Dreikorn) In the February draft j materials, a bus evacuee is monitored as they stay seated on k 6
7 a bus. l g Q Okay.
9 A Monitors --
10 Q Go ahead. I'm sorry.
11 A Monitors would board the bus and monitor each i
12 individual on the bus, using an RM-14 count rate meter with j 33 an HP-260 probe attached to it. They would scan the 1
[ ja individual, paying particular attention to hands, feet, head
]
15 and shoulders.
16 Q Okay. Was the -- I'm sorry, you may have said 17 this. Was the bus evacuee to remain seated, or was he going ig to stand up?
j9 A As it said in our testimony, the bus evacuee 20 would remain seated.
21 Q Okay. And, I think you stated in your testimony '
22 as well that the bus passenger would be monitored in a 23 manner similar to the way that passengers in cars are 24 m nitored; isn't that correct?
25 A That is correct.
O
l 51801515 joewalsh 17567 I I
, , 1 Q Any major differences in the way that bus
() 2 evacuees would have been monitored as compared to automobile 3 evacuees?
4 I'm sorry. That was a bad question. Strike j 5 that one.
6 Looking at the procedure prior to its recent i 1 7 revision last week, were there any major differences between a the monitoring procedures for bus evacuees and auto l
9 evacuees?
l 10 A I would like you to repeat that question once i 1
11 again.
12 Q You mentioned in your testimony that bus i3 evacuees were going to be monitored in a manner similar to I
ja the way that passengers in cars are monitored. Do you j3 recall your testimony on that?
16 A That's correct.
l 17 Q Okay. I just wanted to know how similar? Were l
is there any major differences in the monitoring procedures? l 39 A No. The methods are very similar. The 20 monitoring approach is similar. The instrumentation is the 21 same. The areas that we are concentrating on, looking for 22 contaminants such as the hands, feet, head and shoulders are 23 the same on each individual.
24 Q The probe is moved over the body at the same 25 speed?
I
51801515 joewalsh 17568 i A That's correct.
2 Q Now, for that procedure you estimated, did you 3
not -- and I'm referring to Page 9b of 3.9.2 -- that that 4
scan should take about 90 seconds, correct?
5 A That's correct. What it says there is that the 6 scan should take about 90 seconds.
7 Q Thank you.
g A What I would also like to point out is that at 9 that time the procedure addresses not only arriving bus, but io it says, .../special facility evacuees."
ii The additional time frame that was left in 12 there, the 90 second time frame, accounts for the special 13 facility evacuees that would arrive on buses at the a Brentwood Operations Center or the Emergency Worker 15 Decontamination Facility for monitoring.
16 There was an overlap of general population bus y evacuees and special population bus evacuees there.
la Q Let me ask this: Do you treat the two j9 categories differently in terme of monitoring?
20 A We recognize that the special population 21 individuals may have special needs, and it may be more 22 difficult and take a little bit more time to accomplish our 23 monitoring techniques with those individuals.
24 Q You don't draw that distinction on Page 96 of 25 OPIP 3.9.2 of the draft materials, do you?
O
51801515 joowalsh 17569 1 A The distinction is reflected in the time that we
( 2 have allowed to accomplish the monitoring activity.
3 Q That's not my question, Ms. Dreikorn. It's not 4 reflected here on the written page, is it?
5 A Not as of yet, no.
6 (Witness Watts) I have something to add, Mr.
7 McMurray, if I may.
l 8 Q Is it relevant to my question about whether or 9 not the distinction is reflected on the written page, Page 10 9b?
11 A It's another reason for the distinction.
12 Q Well, my question is whether it is reflected on i3 the page. I think if you have anything more to add, it can L ja be brought out on redirect. Or, if I ask another question
)
15 that's --
16 A Fine. I was just trying to provide some other 17 background for why we are doing it that way, is Q Now that the procedure has been revised, Ms.
l 19 Dreikorn, are you monitoring any less areas of a bus 20 evacuee?
21 To put it another way, is the monitoring less 22 complete or is it just as complete as the monitoring set out 23 in the draft materials at 3.9.2, 9b?
24 A (Witness Dreikorn) As we state in the change to 25 our testimony, in addition to monitoring hands, feet, head
51801515 joewalsh 17570 i and shoulders of each bus evacuee we will now do an X 2
pattern on the front and back of each individual.
3 Q So, it's your testimony that you are actually a doing more of a scan?
5 A I guess you can consider we are covering more of.
6 the surface area of an individual's body at this point.
7 Q Yet, your time estimate now is 60 seconds;~is g that correct?
9 A That is correct.
10 Q Ms. Dreikorn, with respect to monitoring people ti in their cars you will not be scanning in an X pattern over 12 the back of the body, correct?
13 A That is correct. The monitors are trained to 14 sweep across the shoulder area.
15 Q The top of the shoulder?
16 A That is correct.
17 Q So, the back area is not monitored at all, 18 correct?
19 A In the action of sweeping the probe across the 20 shoulder area, the monitors are careful to include the upper 21 back portion of the body.
22 Q Other than the upper back portion, the back of 23 the body is not monitored, correct?
24 A A portion of the back is monitored.
25 Q And, that's the portion that you just described?
51801515 jo:walsh 17571 i
-l 1 A That is correct. l r ~T j
\ t 2 Q And, no other part of the back is monitored, !
l 3 correct? {
4 A Other than the portion I've indicated.
5 Q And, that is the portion along the top of the i l
6 shoulders, correct?
7 A Are you referring to the area that is now being g monitored?
9 Q That's right.
10 A Yes, that is correct.
l 11 Q With respect to bus evacuees, I take it you 17 consider it a prudent practice to scan the back of the bus 13 evacuees in the X pattern that you described; isn't that a 14 correct?
15 A That's correct. And, maybe it would be helpful 16 if I explained to you how our bus evacuation process works 1
17 to help clarify that.
is Q Well, let me just ask the questions. And, if I 39 that comes out, that will be great, j 1
20 You state that every -- I'm sorry. In the j 21 answer to Question 68, you state that, ...everyone in the 1
22 car will be directed to a decontamination trailer for i 23 additional monitoring and, if necessary, decontamination." l 24 Is that your testimony? I'm sorry -- yes, you l
25 do sponsor that, l /
' N.$]
51801515 17572.
joewalsh A If any individual in a vehicle is found to'have i
)
O 2 contamination on them above acceptable values all 4
i 1
d 3 individuals would be directed to the decontamination a facility for follow-up monitoring.
5 Q Is that true for bus evacuees as well? If one 6 person on the bus is contaminated, everybody is sent to the l 7 decontamination facility?
8 A No, that is not true.
9 Q Why is that? Why are they treated differently?
10 A That is one of the reasons why we have added the
]
ij additional X pattern to monitoring of bus evacuees.
12 Q I'm sorry. I don't get the connection.
33 Q Well, if you would like me to explain how our y bus evacuation process occurs, it might help clear up the 15 confusion.
16 Q Well, can you describe for me why or the i7 connection that you are trying to draw to explain the reason 18 why bus evacuees are not all sent to decontamination j
39 trailers if there is contamination found on one while all 20 automobile passengers will be sent to decontamination 21 trailers if there is contamination found on one?
22 A I w uld be glad to.
23 Q Thank you.
24 A The people that arrive in their personal 25 vehicles are treated as a unit. In most instances, they O
51801515 joewalsh 17573
.]
1 have come from one location and travelled to the facility 2 together.
3 That's not the case in bus evacuees. What we l
4 have in our bus evacuation plan is approximately 47 transfer j 5 points. People are picked up in their neighborhoods and ,
)
6 bussed to these transfer points at which point, at the l 7 transfer point, individuals are mixed from various zones and a boarded another bus so that they can travel to the general 9 public reception center. )
I 10 Therefore, we have individuals who may come from j 11 effected areas that might have particulate materials in 12 their areas with those individuals who are coming from areas i3 that might n,ot be effected. For that reason, when I
14 individuals arrive on a bus at the general public reception
{}
15 center, we have added the monitoring of an X 9attern to 16 those individuals to account for those situations of cross-17 contamination possibly occurring because of the way we have is mixed individuals from various zones at our transfer point 19 location. ;
20 So, individuals arriving on bus are treated as 21 individuals, whereas individuals that arrive in a vehicle 22 are treated as a unit.
23 Q Thank you. Let's go to Attachment P. I would 24 like to go to the last page of Attachment P but keep -- also 25 g to Page 41 of the testimony. We will be switching back s
I
$1801515 joewalsh ^7574 1
j and forth between the two pages.
2 (The witnesses are complying.)
3 Mr. Watts, that's -- let me refer this to you.
4 On Page 41 of the testimony, the answer to Question 71, you 5 state that LILCO monitors are trained to move the probe over 6 the body at about eight to ten inches per second.
7 Do you see that?
g A (Witness Watts) Yes, I do.
9 Q Okay. Now, the RM-14 meter, if we go to the 10 last page of Attachment P, has a response time in the fast 33 mode of approximately two seconds.
12 Isn't that correct?
- 3 A What are you looking at?
() y Q I'm looking at the specs for the RM-14 radiation 15 m nitor which I think is the last page of Attachment P.
16 A Yes. Okay, I see it, i7 Q Let me start over again. The RM-14 meter is the 3g meter that's used to read the number of counts per minute 39 when a particular body is being scanned, correct?
20 A Yes.
21 Q Okay. And, when evacuees are being scanned the 22 RM-14 is going to be in the fast mode; is that correct?
23 A Yes.
24 Q Okay. Can you explain the difference between 25 the fast mode and the slow mode?
l l
l
y 51801515 17575 ,
joswalsh
,j 1 A It has to do with the electronics of the 2 instrument itself. And, one will provide a more rapid 3 response to radiation. The other will have more or less a 4 dampening effect on the signal. It will tend to have a very 5 slowly increasing meter reading and slow response which may 6 have some more fluctuation.
7 Q In the fast mode, there is more fluctuation of l
8 the needle, correct? j j
9 A Yes, typically there is. !
io Q I'm sorry. I can't hear you. Is your mike on?
11 A Yes, it is. In addition to the meter, of i 12 course, we turn the volume on full as part of the meter set- l 33 up and we set the alarm set point.
i
{]} 14 Q Now, in the middle of the specs for the RM-14 15 which is the last page of Attachment P, it says that the 16 response time in the fast mode is approximately two seconds.
17 Do you see that?
l 18 A Yes. !
19 Q Okay. What does response time mean?
20 A It's typically the time to reach a certain 21 percentage of the full value.
22 Q Generally, that percentage is about 67 percent, 23 correct?
24 A It's quoted by_different vendors different 25 ways. I think in this case this was 90 percent.
!(:b -
51801515 joewalsh 17576 :
1 Q 90 percent, okay. So, here you will get 90 !
2 percent of the full reading in two seconds; is that correct?
3 A yes, approximately, a Q Okay. Now, does that mean that the probe has to 5 be held over the source of the radiation in order for -- for 6 two seconds in order for the reading to come out on the I
7 meter? I g Or, does that just mean a delayed time of two l 1
l 9 seconds? l l j 10 A Excuse me? i
{
ij Q I'm trying to find out what the response time )
12 means. Does it mean that there is a two second delay in the 13 reading, or does it mean that you have to have the probe )
y over the source for two seconds in order to get 90 percent 15 of the reading of that source?
16 A In proximity to the source.
17 Q Okay. So that when you are moving a probe over ig the body at eight to ten inches per second, you can be 10 or 39 20 inches away from the source of the contamination before 20 you get even 90 percent of the reading, correct?
l l 21 A Would you repeat that again?
22 Q I'm having a hard time figuring out, if you are 23 m ving the probe along the body at eight to ten inches per 24 second and you testified that you have to have the probe 25 over the source of the contamination for two seconds --
O l
l
51801515 17577 jotwalsh I
,l ! 1 A Or in proximity to. i
/N
' l
) -- or in proximity to --
2 Q 3 A The probe is sensitive to beta as well as gamma ;
l 4 rays. ;
i 5 Q Okay. Let me ask you this: What's the range at l 1
6 which the probe can detect contamination? '
7 A If it's gamma, the gamma -- gamma has a very e long range. If it's beta, possibly ten feet, five to ten ,
9 feet.
10 Q But, it's true, isn't it, that if you are moving l
11 the probe along at, let's say, ten inches per second you 12 could be as much as 20 inches away from the source of l l
l 13 contamination before you get a reading on the RM-14 meter; i l /) x-ja is that correct?'
- 15 A That's true if you are considering a small speck g or a small point source of contamination, which we don't 17 consider to be likely in this case. We would expect diffuse is contamination for major areas of the person.
19 Q Well, but it's not impossible that you could 20 have limited areas contaminated on the body, correct?
21 A It is possible for -- you could have limited 22 areas over several areas of the body.
23 Q Okay.
l 24 A We are looking at feet, hands, head and 25 shoulders as being those areas most likely to be exposed.
I .O'
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51801515 17578 joewalsh j JUDGE MARGULIES: It might be appropriate to I
O 2 take a 10-minute stretch break at this point. It's somewhat 3
of a departure from the OL-5 proceeding, but we don't have 4
to be in lockstep. 1 5
(Whereupon, a recess is taken at 4:00 p.m., to 6
reconvene at 4:08 p.m., this same day.)
I 7 j 8
9 j 10 11 12 13 14 l
15 l
16 17 18 19 20 21 22 23 24 25 O
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51801616 175't9 marysimons l l
- l. ; 1 JUDGE MARGULIES: Back on the record.
2 CROSS-EXAMINATION (Resumed) 3 BY MR. McMURRAY:
4 Q Mr. Watts, before we broke we were discussing 5 your answer to question 71. Now there you discuss a 6 document published in July 1982 by State of New York 1
7 Division of Military Naval Affairs Radiological Intelligence ]
8 Section.
9 Do you see that?
10 A (Witness Watts) Yes, I do.
11 Q And you say that that document recommends paying 12 special attention to the head, shoulders, hands, feet 13 including the soles and any moist areas.
{}l 14 Do you see that?
15 A Yes. I 16 Q So the procedure set out there does not say 17 monitor only the head, shoulders, hands and soles of the 18 feet, but rather pay special attention to them, correct?
19 A Well, in the same answer we quoted the 20 monitoring speed, which is one foot per second, and also 21 indicating around the entire perimeter of the person. So 22 that's correct. It's monitoring around the perimeter of the 23 person and focusing attention on those particular areas.
24 It's those particular areas that we also are 25 focusing attention on.
I l D
V 1
51801616 marysimons 17580 1 Q You don't move the probe around the entire
) 2 perimeter of the person, do you?
3 A No, we don't. The rationale in both cases for a those particular areas is the same.
5 Q Well, the answer is no, you don't, correct, Mr. l 6 Watts?
7 A The rationale is that we are looking for those 8 areas.
9 Q If you want to bring it out on redirect, Mr.
10 Watts, then ask your counsel to bring it out on redirect, 11 and let's not have any speech making. ]
i 12 A I wasn't aware I was making any speeches, Mr.
13 McMurray. I was trying to be responsive to your question.
u Would you like to ask the question again, and
{~ )
15 I'll give you ---
16 Q No. I've got the answer. Thank you.
17 A Okay. l 4
18 Q Does the LILCO procedure call for monitoring any 19 moist areas?
20 A No. I'm frankly not sure what that means.
21 Q LILCO personnel then are not instructed to look j 22 for any moist areas and monitor them?
l l
23 A Not specifically, no. !
24 Q Let's go to page 42.
25 Mr. Watts, there you state that you estimate it
^
51801616 marysimons 17581
_; I takes 100 seconds to monitor a vehicle used in a primary
(~~)
\- 2 method, correct?
l 3 A Yes, that's right.
l 4 Q Dr. Linnemann, would you agree with that '
5 assessment?
l 6 A (Witness Linnemann) Yes, I would.
7 Q And what is the basis f or your agreement with 8 that assessment?
l 9 A Because I have surveyed people with 10 contamination and we could do it in that time frame.
11 Q Do you recall being deposed on March 5th, 1987 12 by Mr. Case?
13 A Yes, I do.
i j) 14 Q Do you recall the question on.the same subj ect 15 of monitoring, that if you had four individuals in a car, in 16 an automobile and we did this initial triage system you've 17 described, how long would it take roughly to triage those 18 individuals in the automobile, that initial scan, checking 19 the hands and feet of the individual, and the answer was 20 minutes?
21 Question: " Minutes?" l 22 Answer: "Yes. For probably all four of them 23 you would just check hands and feet."
24 Question: "So if you just checked hands and 25 feet for the four of them it would take minutes you I
_..____________.___________.__._._J
51801616 marysimons 17582 1 believe?"
2 Answer: "Yes."
3 Do you recall that testimony?
4 A I do, but could I just see that to refresh my 5 own memory on that?
6 (The document referred to was placed-before l 7 Witness Linnemann.)
8 MR. McMURRAY: For the record, it begins at the 9 bottom of page 40 and goes on to page 41. ,
10 WITNESS LINNEMANN: Yes, I'do recall that 11 deposition. When he asked me the question, I was assuming 12 that I myself was doing the monitoring and if I had to do 13 four people in a car, it.would probably take a few minutes.
(]) 14 If you have two people, it would probably take half that 15 time. So I think that's in line with about the 100 seconds 16 they are talking about for two people to monitor a car of 17 four people.
18 BY MR. McMURRAY:
19 Q Let's go to page 43, Ms. Dreikorn. Let's go to 20 question 77. The question is "What monitoring equipment 21 will LERO use? And the answer is, "The Eberline RM-14 count 22 rate meter with either an HP-210, HP-260 or HP-270 probe."
23 Do you see that?
24 A (Witness Dreikorn) Yes, I do.
25 Q With respect-to monitoring individuals in cars, O
51801616 17583 marysimons I
1 are all of those probes going to be used?
_O 2 A No, they will not be all used. The most 3 appropriate probe f or mor.itoring individuals in the car 4 would be the HP-260 probe, which is a pancake shaped probe.
5 It's highly sensitive to beta particles and gamma rays, and j l
6 it has an extension handle on it that extends the detection 1 7 portion of the GM-2 about eight inches. l 8 Q You say the most appropriate. Does LILCO have I 9 enough HP-270 probes for all the monitoring stations that 10 would initially be set up, all 63 monitoring stations? i l
11 Q Did you ask me about 270 probes?
12 Q That's right. 260 is the most appropriate, you 13 said?
() 14 A Yes, that's correct.
1 j
15 Q Do you have enough HP-260 probes for all 63 of 1
16 the monitoring stations that you intend to initially set up? l
( 17 A Yes, we do.
18 Q Do you have them in stock?
19 A Yes, we do.
20 (Witnesses conferring.)
1 21 Q Is your answer any different now that you've 22 spoken to Mr. Watts?
23 A No , it's no different.
24 A (Witness Crocker) I can clarity that, if you 25 will. I'm the guy who signs the purchase orders, and we l
's
51801616 17584 marysimons 1 have signed purchase orders for all that equipment and I 2 believe it has all arrived.
3 0 But you don't know if it has arrived?
4 A. I think some of it happens to be out at Shoreham l 1
5 for calibration right now. I think we have it all. If not, 6 we'll have it within the month. )
7 Q Let's go back to the RM-14 meter.
8 Mr. Watts, I=think you said earlier, and let me 9 just get back on track here, that under the fast response-10 mode the RM-14 needle would fluctuate more than it would 11 under the slow response moder'is that correct?
12 A (Witness Watts) That's correct.
i 13 Q And how wide can the needle fluctuations be to I i
the fast mode?
(]) 14 15 A Just off the top of my head I think I've seen 16 fluctuations of 50 counts to 100 counts per. minute.
17 0 Is that in either direction? '
18 A In either direction, yes.
19 I would ask Ms. Dreikorn if she would agree with 20 that. <
21 Q Ms. Dreikorn?
22 A (Witness Dreikorn) Yes, I agree with that.
23 Q And what is the threshold level above background 24 where you determine that an individual contaminated, Ms.
25 Dreikorn?
1
51801616. 17585 marysimons I
1 A With the HP-260 probe?
2 Q Correct.
3 , A The acceptable level or the level at which we 4 determine that contamination is present would be 360 counts 5 per minute above bachground. I 6 Q When you set the alarm on the RM-14, given that 7 threshold, what do you set it at?
8 A The way alarm scale is set on . the back of the 9 instrument, you would set it between the numerals 3 and' 4 10 towards the upper end in the proximity --well -- I'm sorry, 11 I have to backtrack here.
12 You are initially taking your background 13 measurement. Background commonly with the RM-14 and the 260 14 probe is at 40 to 50 counts per minute. Our action level is 15 360 counts per minute above background. So our monitoring 16 personnel are instructed to add those two values together 17 which would give you on the order of 400 counts per minute.
18 So when you are setting your alarm setpoint, you are setting 19 it at the numeral 4 on the alarm set on the back of the 20 instrument.
l 21 Q And basically when they were looking at the 22 meter they would consider someone contaminated if they I
23 judged that the counts per minute were about 400; is that 24 correc t?
25 A That would be 360 counts per minute above l-
51801616 17586 marysimons i background. At that point the alarm would go off and it
(}- 2 would indicate that we have exceeded that value of the 3 setpoint.
4 Q And does the alarm go off any time the needle 5 fluctuates beyond that alarm point?
6 A Yes, it would. When that alarm point is 7 exceeded, the instrument would alarm.
8 Q And what is a monitor instructed to do if the 9 alarm goes off?
Io A If the alarm goes off, the monitor would direct 11 the individual to proceed to the decontamination facility.
l 12 I would like to also add that our monitoring l 13 personnel are trained that it they have any question at all
() 14 about the level of contamination that they are detecting, 15 that they would send the individual to the decontamination 16 facility.
17 Q And you'll agree with me, won't you, that given is the needle fluctuation we have just spoken about, that the l 19 alarm might go off even though contamination levels were 20 below the threshold level?
21 A No, I don't really think that is true.
22 Q Well, let's back up then. You said that the 23 alarm goes whenever the needle goes beyond that you've set 24 the alarm at, correct?
1 25 A That's correct.
A U
51801616 marysimons 17587 J
_ ,; 1 Q And the needle can fluctuate maybe 50 counts U 2 what the actual reading is, correct?
3 A That is correct.
4 Q So isn't it true then that someone could have, 5 for instance, say, an actual reading of 300 or 250 counts 6 per minute? What is the threshold level, 3607 7 A The threshold level is 360 counts a minute above l 8 background.
9 0 okay. Well, somebody could then have 340 or 350 10 counts per minute contamination and still the alarm would go 11 off because of fluctuations that would send the needle 12 beyond that point maybe 50 or 60 counts?
13 A No, I don' t believe that is correct. I believe 14 the instrument has in itself a correction for that type of 15 activity.
16 Also, you have to bear in mind that monitors our
,1 l
17 monitors are -- if there is any question again of the level j
$ 18 of contamination, they will direct the individual in for
, 19 further detailed monitoring. I 20 Q Mr. Donaldson, do you agree with that?
21 A (Witness Donaldson) Just to clarity and help 22 you understand needle fluctuations, on the fast response 23 time the reason the needle fluctuations is because 24 spontaneous emission of radioactivity is not a precisely 25 timed event like a drum beat. It does happen in bursts or I{
51801616 marysimons I counts that may exceed in a short period of time.
2 The needle fluctuations that you're seeing 3 represent a bound of released radioactivity over a period of 4 time, and when in fact you read a meter, if you did not have 5 an audible alarm, you would look at the swing of the meter l 6 from high to low as it fluctuated, and the reading that 7 would be recorded would be the center reading about which is l a roughly swings back and forth. I 9 The meter on slow response still -- the probe to still detects the same number of disintegrations per second ,
l 11 or counts per minute, if you will. It's the slowness of the l
12 electronics in transmitting that and in reading those pulses 13 and transmitting it to the meter portion that smooth the O ie re ro=ee out-15 In other words, that makes it easier for the 16 person to read it. There is less interpretation involved.
17 Now there is also built in on field instruments, is a built-in error of plus or minus 25 percent which is taken 19 into account in the calibration.
20 So I think what you are saying about could it be 21 25 higher, sure it could be 25 counts higher or it could be 22 25 counts lower because of this built-in natural phenomenon l
23 of the way decay takes place.
24 Q Let me pose the same question to you that I 25 posed to Ms. Dreikorn, isn't it possibl'e that the alarm O
i 51801616 marysimons 17589
, 1 could be tripped given the fluctuations in the fast mode on
\- '
2 the basis of the more severe fluctuations that one 3 experiences in the fast mode rather than the fact that the 4 person actually has a reading that indicates contamination?
5 A I'm not sure I really understand. Boil it down q 6 a little for me. f 7 Q Is it your understanding that whenever the 8 needle goes beyond the point that the alarm is set at that 9 it sets the alarm off?
10 A That's correct. In fact it sometimes even i
11 precede it slightly in that instrumentation because it's 12 internal circuitry, the alarm circuit is slightly 13 different. So, in other words, the needle may lag slightly l
l L() 14 behind the alarm. I 15 Q Well, isn't it possible then that someone might 16 be sent off for decontamination because they have been i 1
17 determined to be contaminated even though they are not I 18 contaminated or have not reached the threshold level for 19 contamination?
20 A It's possible, but again when dealing with 21 contamination, it's a standard health physics practice that 22 you do apply judgment. The fact is that if the needle does 23 exceed beyond that portion, then because of built in error )
I 24 in field instrumentation, it could be plus or minus 15 j
)
25 percent anyway, and it's very unlikely that you're going to I I
'[)s
(_ )
l l
)
51801616 marysimons 17590 i find where somebody is right on the borderline.
O 2 Normally if you have a question and you are a 3 health physicist, you send them anyway. When in doubt, 4 punt.
5 Q So more people might be sent off for 6 decontamination than are actually contaminated, correct?
7 A Well, I think if you get any reading -- oh, 8 contamination is relative. I think she is referring to an 9 action level where decontamination would be warranted.
10 Contamination is merely defined as being'having 11 radioactivity somewhere where you don't want it.
12 0 Well, more people may be sent off.for )
i3 decontamination than have crossed that threshold at which j
() 14 they are considered contaminated, correct?
15 A I wouldn't think so. It would be unlikely that )
16 you would have so many people that would be just 17 borderline. My experience is that when you. are looking for l
18 contamination and you have an action level, you don't run 19 into a lot of cases where people are borderline and you say, l 20 well, are they or aren't they. If you have any question, l
21 you send them. It just work that way. This is quite common 22 in the plant, the way they do their individual frisking of 1
1 23 themselves.
24 Q Well, I think we are on the same wavelength.
25 Your response is if there any doubt you send them off to the
( '
51801616 marysimons 17591 1
y 1 decontamination trailer, right?
_f\' ) 2 A Exac tly, and I believe that is built into their l
l 3 procedure.
4 Q So that in fact more people may be sent to the ;
5 decontamination trailer than are actually contaminated, 6 correct?
7 A Well, back again, contamination is 8 contamination, and to say that because they have an action 9 level of 360 counts above background that that person should 10 exactly be sent at this time, they are trying to build in 11 the flexibility and fluctuation because we are dealing with 12 numbers that do have variation like the needle varies.
13 So it wouldn't result in more people. It's
) 14 taken into the overall numbers.
A (Witness Linnemann) 15 I think there is another 16 point to be made. It may be that way, that you get a 1 17 falsely high reading, but they don' t go to get 18 decontaminated. They would be resurveyed before you would 19 decontaminate them and it would be probably picked up there l 20 that it really wasn't the case. So there is a backup check 21 on that.
22 Q But that means then, Dr. Linnemann, doesn't it, 23 that the resources which LILCO is using for this secondary 24 monitoring function may have to cope with more people than 25 the number who may actually be contaminated or run pass the
!A v
51801616 marysimons 17592 1 threshold level? !
2 A That's probably true, but I don't think it would l 3 be significant of the utilization. of those resources. I i
4 don't think you are talking about a lot of people in that ,
5 category.
6 0 Why is that?
l 7 A Because Just by the nature of the statistics. ,
8 They are either going to be contaminated or not. I don't 9 think you are going to catch a lot of them just on the 10 borderline.
11 A (Witness Watts) I would agree with Dr. '
i 12 Linnemann.
13 0 Why is that, that you 're not going to catch a 1
e 14 lot of them just on the borderline?
15 A (Witness Linnemann) Well, I think in a sense we 16 are really cutting a moot point here. When you talking 17 about Contaminated, these are very, very low levels of is contamination. And when you have a situation which you are ' ll \
l !
19 describing here, it's usually a unifom contamination and !
l 20 it's usually not a question, at least again in my l 21 experience, of it's doubtful whether this is contaminated or 22 not. Usually you can pretty well tell if it's contamination 23 or it isn't. s 24 And if you have any doubt, as you explained on 25 the needle the first time, do it again and 'that will clarity' O '
4 1
51801616 17593 marysimons l ;i i
1 it f or you. I don't think you are talking about a lot of 2 time and resources in delineating this problem. It's not as 3 big a problem as I think you perceiving.
4 A (Witness Watts) That has been my experience 5 also.
6 Q Is the secondary monitoring at the l 7 decontamination trailer done with the RM-14 meter set on the 8 fast or slow mode?
9 Do you know, Ms. Dreikorn?
10 A (Witness Dreikorn) I would like to just 11 reference the procedure for a second, please.
12 (Pause.)
- . _ , 13 Yes, it would be conducted in the f ast response
! i 14 mode.
15 Q With the same needle fluctuations in the fast !
I 16 mode as one has in the initial monitoring procedures, '
'l 7 correc t?
1e A Yes, that's correct, but at this point we are 1
19 trying to quantify the levels of contamination, and when the 20 survey is being conducted, the monitors are instructed and 1
21 they have information that is mounted to the card on top of 22 the instrument that explains to them that should the needle 23 fluctuation erratically as it would with the random decay of 24 radioactive materials, that they should then switch to slow I
25 response and resurvey the area so that they can quantify the l l 1evels of contamination.
O
51801717 L7594 ;
riuowalsh 1
I
-/ Q The LILCO monitors are trained to switch to slow 2
response, you are saying?
3 A (Witness Dreikorn) That is correct.
d Q Ms. Dreikorn, when the monitoring is done --
5 strike that.
6 As I understand it, there is a probe and there 7
is the monitor, correct? They are two different pieces of 8
equipment?
A That's correct. And, they have a coaxial cable 10 that connects the two.
II Q And, how long is the cable?
12 A We have ten foot cables available. We also have 13
, I believe five foot or three foot cables.
Id Q Under the LILCO plan, when the monitoring of the 35 individuals in their cars is being done, where is the RM-14 ,
16 going to be?
I7 A Some of the monitors prefer to hold them.
I8 Others have set them down in their area that they are working in off to the sides of the monitoring area.
20 Q Okay.
21 A We are working on adapting some type of handle 22 or strap to the instruments to make them so that they can 23 hang on to them nearby.
24 Q Okay. Now, when someone is monitoring 25 individuals in their car and they enter the car and they are i
I l
-_ -_-____--__Q
17595 51801717 ..
I suewalsh l
1 probing around in the back seat, they are also keeping their 2
eyes on the monitor; is that correct, on the RM-14 to 3
- determine needle fluctuations? I I
4 A No. At that point they are listening to the I 5
response of the instrument by -- they have an audible volume 6
control turned up full. They are listening for the alarm to 7
go off at the set point. So, they are concentrating more --
8 what we are doing in initial monitoring stations is more of 9
a, is there contamination or is there not contamination, )
10 screening process.
M Q Well, at the reception centers there are going 12 to be car engines running; isn't that correct?
f 13 A That's correct.
14 Q Okay. And, there's going to be other ambient 15 noise; is that correct?
16 A I didn't catch the -- your next question.
17 Q Mr. Watts was talking to you. There is going to 18 be other ambient noise, isn't that correct?
19 MR. CHRISTMAN: Judge, Mr. McMurray is making a i 1
20 point of noting whenever the witnesses consult. I would !
21 like to note that the witnesses are perfectly entitled to 22 consult with one another and always have throughout the 1
23 course of five years of this proceeding. l 24 MR. McMURRAY: Well, I don't --
25 MR. CHRISTMAN: And, comments by counsel are l
~
l
17596 51801717 nucwalsh i I
yy I generally inappropriate.
2 MR. McMURRAY: Well, it's not appropriate for 3
Mr. Watts to talk to her while'I'm asking my questions so she has to ask for it to be reasked. That's just not 5
polite.
6 If he wants to talk to her, he can do it some 7
other time. That's the reason I made the comment.
8 BY MR. CASE: (Continuing)
Q Now, Ms. Dreikorn -- ,
10 l
l A (Witness Dreikern) Mr. Watts and I are both II sponsoring the issue on the instrumentation.
12 Q I understand that. Now, there is going to be
'3 other ambient noise; isn't that correct?
Id A Normal outdoors noises. But, that's really not 15 a problem. You can certainly hear the instrumentation in 16 j that type of environment.
I7 Q Well, has anybody determined whether or not when I8 l
a monitor is inside a car and there is engine noise and
" whatnot, other ambient noise, whether or not the monitor can 20 be heard?
21 A Well, I for one could attest that I clearly 22 heard the instrumentation operating when we've done 23 training, monitoring individuals in vehicles that are 24 running.
25 (Witness Watts) And, so have I.
l 51801717 b outwalsh
/ I I
7_s Q Have you checked whether or not all of the )
\.) 2 monitors are able to set the monitor close enough to 3
themselves so that they can hear the alarms? Is this d
something that the monitors are trained to do?
5 A (Witness Dreikorn) Believe me, the alarm when l 6
it sounds, you are very well aware of that sound. And, if 7
you would like I will demonstrate that for you.
8 Q In the monitoring sessions that you've had, in 9
the training sessions with LILCO monitors, have the RM-14s i
10 actually been turned on?
II A yes, they certainly have.
12 Q Mr. Watts, you state in the answer to Question 13 79 that, "The RM-14 is usable under a wide range of
() 14 temperature and humidity conditions."
15 Do you see that?
16 A (Witness Watts) yes, i
17 Q Okay. Have you or anyone else at LILCO or LERO 18 tested the RM-14 and the various probes under extreme 19 weather conditions?
20 A Well, I've seen them used under extreme weather 21 conditions in the winter time.
22 Q What sort of conditions?
23 A During the Ginna accident which occurred in the 24 winter time when it was snowing. I don't recollect any 25 problems with the instruments. It was the same variety that
17598 51802717 cunwalsh l I
we are talking about, a slightly different probe but we used the RM-14 and the HP-190 probe. Also, a GM-2 end window.-
3 It was a Geiger-Muller 2, end window, a.very similar probe I and identical meter.
5 So, in my experience they have worked well under 6
rather severe conditions. We also contacted the vendor, I 7
Eberline, and asked several questions about' experience with 8
the probe and design of the instrumentation to withstand )
1 environmental. conditions.
10 And, it appears that under the design they can II withstand a wide range of humidity conditions and 12 temperature conditions.
13 Q What sorts of questions di'd you pose to the Id people at Eberline? j 15 A Well, Ms. Dreikorn talked to them directly. If 16 you would like to ask her, she has the specifics.
(Witness Dreikorn) I spoke with the gentleman I0 at Eberline who is the Technical Advisor in Radiation Safety I9 Officer for Eberline Corporation. And, I discussed with him 20 the environmental suitability of the RM-14 count rate meter 21 and the various probes that we are utilizing. And, what Mr.
]
22 Little told me is that the instrument can withstand a 23 significant temperature range, that being the range that we j 24 have stated in our testimony here.
25 I'm sorry, we haven't stated it. The range is l
i; 51801717 17599 l l
suewalsh j 1
1
,_ minus 20 degrees Fahrenheit to approximately 140 degrees 2
Fahrenheit. In addition to that, the instrumentation can
]
3 withstand very high humid conditions, that in excess of 95 d
percent relative humidity. 1 5
In addition, the gentleman explained to me that 6
the instrument has been widely used by clients in 7
precipitation and the easiest thing to do is to just put the 8
instrument in a plastic bag and that will provide 9
appropriate protection for the instrument, and the 10 instrument has operated properly in those conditions with no i
Il problem. I 12 Q When you put it in a plastic bag, it does not 13 l effect the reading or the ability to read the instrument?
Id A They would be clear plastic bags, so you would 15 be able to certainly see the scale on the instrument.
16 Q Turn to Page 45.
17 (The witnesses are complying.)
IB In response to Question 86, I believe you state 19 that, Ms. Dreikorn, it's not plausible that elevated 20 background levels would be caused by the plume itself.
21 Do you see that?
22 A Yes, I do.
23 Q Are you saying it's impossible for the plume to 24 travel 40 miles?
25 A I'm saying it's highly unlikely or not
1 1
1 51801717 17600 )
nuewalsh I )'
I I
plausible.
2 Q Well, a plume can travel a long distance, can't it? It can travel more than 40 miles, can't it?
A But, it's also being dispersed at the same time 5
that it's travelling distance. So, there is a lot of mixing 6
going on.
7 Q And, while the concentration of radioactive 8
material in the plume taay go down, nevertheless it could 1
raise background levels as far as 40 to 50 miles away, 10 couldn't it?
II A I guess in a very severe accident scenario, that 12 might be a possibility.
1 I3 Q Mr. Watts, let me refer you to your answer on Id Question 87. And, this time I would like an explanation 15 i where you say that the instrument reading relative to 16 l background would tend to maximize.
1 I7 I don't understand what you mean by that.
I8 A (Witness Watts) As Ms. Dreikorn was talking about before, the instrument is particularly efficient for 20 beta radiation. If we have background levels slightly 1
21 clevated because of a plume which I really feel is unlikely 1 22 in this case because we are in the predominantly upwind or --
23 yes, upwind area', what we are doing is taking readings 24 essentially one-half inch away from any potentially 25 contaminated surface area.
l
51801717 17601 sucwalsh I
If we are looking at beta radiation and we are
>)
V 2 getting right up close to it and that is the type of 3
radiation that we are most efficient for, then I would say d
that we would maxinize the signal to the instrument greatly 5
relative to the gamma and possible slight amount of beta 6
radiation in the background.
7 Q You are saying then that the plume would not be l 8 able -- would not have an affect on the reading --
9 A There may --
10 Q -- if it did pass over the reception center?
II A There may be some effect on the reading, but
( 12 what I'm saying is because we are taking our -- we are using 13 a frisk procedure, using an instrument that is highly
() Id efficient for beta radiation, and we are in close proximity 15 to that beta radiation, that the background is going to be 16 trivial compared to the reading directly from the source of 17 contamination and beta.
IB (Witness Donaldson) I've done some studies on 19 that particular instrument back in the late 70s, around the 20 Three Mile Island time, because this was a common instrument 21 that was used in the nuclear industry to evaluate air 22 samples taken in the environs.
23 And, to back up what Mr. Watts has said, the 24 background contribution would be minimal for that particular 25 instrumentation. In fact, a ten minute air sample taken in O
51801717 17602 suewalsh i
J I a plume directly, it would require at least a ten minute air i
'. 2 sample and concentrated on a charcoal cartridge to give a 3
minimum detectable amount on that cartridge which would be d
equivalent to some level or where some actions in the 5
environs would have to take place.
6 What I'm saying in short is that if the level l 7 I were high enough to effect background, then the levels 8
already would be high enough that protective actions would ;
9 have been implemented and they wouldn't be there in the 10 first place, because that instrument is so insensitive to 11 high level beta from direct cloud shine. )
12 Q Mr. Watts, you state in the answer to Question 13 88, the last sentence of that paragraph, you say, " Periodic
- Id background checks are performed, in part to watch for this, 15 at least every 15 minutes."
16 Let me back up. Strike that.
17 In Question 88, you are talking about the IB possibility of instruments getting contaminated; isn't that 19 correct?
20 A (Witness Watts) Yes.
21 Q And, in order to watch for this, you state that 22 periodic background checks are performed at least every 15 23 minutes, correct?
24 A That's right.
25 0 Now, let's assume that your estimate of 100 l
O
l i
l 51801717 17603 suewalsh l seconds is correct, 100 seconds to monitor a vehicle and the
[
2 occupants, a monitor could monitor about nine vehicles in 3 that time; isn't that correct, in about 15 minutes?
4 A Yes.
5 Q If contamination on an instrument is discovered 6 under the LILCO plan, is there any provision for calling i l
7 back cars or individuals who may have been monitored phile j i
8 that instrument was contaminated? l I
9 A I don't see the logic of your question, because )
10 if you have contaminated the instrument that means that 11 there has been contamination in proximity to the monitor 12 which would have been picked up.
13 Q It might be on the instrument, correct?
14 A From an individual or from a vehicle which would 15 have been s topped.
l 16 0 Right. And, after that time, let's say 15 17 minutes passes and another nine cars are monitored, will 18 those nine cars that may not have been contaminated be 19 called back or those individuals?
20 A I think what is very likely to happen is if you 21 contaminated the probe, you may get some false indications 22 of contamination on subsequent vehicles and people in which l 23 case you are going to stop them.
24 Q Right. And, you may send them on to 25 decontamination or whatever, right?
51801717 suewalsh 1
- J 1 A Well, possibly, yes.
I 2
Q So, again there could be more people going off I 3
l to decontamination than were actually contaminated? !
d A Well, in this isolated case, possibly. I 5
wouldn't characterize it as being what we would expect as a 6
common occurrence. You postulated a potential situation, 7
but I don't believe it would cause undue problems to the j i
8 other portions of the reception center. )
9 Q Let's go to Page 46.
10 (The witnesses are complying.)
II In response -- strike that.
12 Question 92 states: "What if a driver requested 13 a whole body scan?
n Id l Q And, you state, Mr. Watts, that that person 15 would be directed to the decontamination area for detailed 16 monitoring.
l 4
17 Do you see that?
I8 A Yes.
19 Q Okay. In what sense is the term "whole body 20 scan" being used? I know you didn't ask the question; you 1
21 answered it. But, do you know what sense "whole body scan" I 22 is being used in?
23 A Well, I think it's my impression -- and you 2d asked Ms. Dreikorn also her impression -- that it the driver 25 wanted the type of scan that we do in the decontamination I
r
,V
51801717 1.7605 suewalsh I trailers, taking 90 seconds or something of that nature, or 2
anything else that he feels is necessary above and beyond 3
what we are doing, we would not refuse that person.
d (Witness Dreikorn) I would like to add that I 5
agree with Mr. Watts' description that he just gave. We 6 would Certainly monitor that individual at the initial 7 monitoring station, monitoring hands, feet, head and 8 shoulders. And, if the individual was not satisfied with 9
that type of monitoring technique and requested an 10 additional technique, we would send him into the 11 decontamination facility.
12 O In your response to Question 93, you discuss 13 whether or not contaminated objects in the trunk of a car
() 14 would cause a problem.
15 Do you see that, Mr. Watts?
16 A (Witness Watts) Yes, I do.
17 Q Okay. Let me ask you this: Are personal 18 articles within a car going to be monitored in the initial 19 monitoring stage?
20 A Not at the initial monitoring stage. But, at 21 the -- as part of the detailed monitoring that would be done 22 if the initial monitoring indicated contamination.
23 Q Is it your testimony that it's impossible for 24 personal articles to be contaminated without the individuals 25 in the car being contaminated?
O i
1 l
51801717 suewalsh 17606 i
I r 't A No. I think if you look at the words, I said it t
( ) l
' 2 was unlikely. !
3 Q There you are talking about articles in the d
trunk. I'm talking about articles in the car, in the 5
passenger compartment of the car.
l 6
A Okay. I didn't understand your question. j 1
7 Q Let's go back. In the initial monitoring stage, l 8 I the personal articles in the passenger compartment of the 9
car, are they going to be monitored during the initial 10 monitoring phase?
i
'I A Are you referring to articles that would have 12 l been carried into the car?
l 13 Articles that may have been there when the
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l >j Id windows were down or whatever, just articles that are found 15 in the car when it drives up to a monitoring station.
16 A No. The reason is that we assume that the likely 17 situation is if there's personal articles in the car they 18 probably would have been carried in by a person.
19 We are checking the people. We are checking the 20 hands of the people who would have carried them in.
21 It's not possible that the article could have Q
22 been in there beforehand?
23 A Ch, it's possible but again it would have been I 24 would say fairly effectively covered from the deposition.
25 What if the windows were open?
Q Id V
51801717 17607 suewalsh l
eS 1 A Well, potentially. l b >>,
2 Q So, it's possible that articles in the car could 3
be contaminated without the people actually being j d
contaminated?
5 A Well, yeah. But, also the car is being checked 6 itself. Again, I have to rehash this philosophy, that we i
7 1 are checking the car, we are checking the individuals in the {
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car.
1 9
If we have indication of contamination, either l 10 outside or inside we do detailed monitoring and everything.
11 12 13 !
1
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20 21 22 23 24 25 l 1 ($)
i 51801818 Joewalsh 17608 I l
! I I
./ Q What's your basis -- let's go to the articles in (g 2 the trunk. What's your basis for stating articles in the 3
trunk, "It is unlikely that the articles in the trunk would j I
d be independently contaminated?"
5 A (Witness Watts) In my mind, what that means is i i
6 that the articles would have been placed in the trunk by a 7
person who was contaminated or not contaminated as the case 8
may be, depending on who is in the car. )
i 9
Q You are assuming then that articles in the 10 trunk would only be contaminated it they had come into II contact with a contaminated person? j 12 A I think that's basically what I'm saying. They 13 have to get there some how. If they are in there to begin Id with, that means -- normally, car trunks are kept closed.
I 15 So, if they are in there to begin with I don't think we 16 would have a contamination problem.
17 Q Couldn't they become contaminated by means other 18 than their contact with a human being?
19 A I don't -- you would have to give me an 20 example . I mean, I can't think of one right now.
21 Q Without me giving you an example, you would say 22 it's impossible?
23 A I can't think -- what I'm saying is I can't 24 think of the circumstance. I hate to use the word 25 " impossible."
I
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51801818 17609 )
joewalsh g 1 MR. McMURRAY: Judge Margulies, it's one minute 2 to 5 I guess. I'm at a point now where I could break off.
3 I think we did say the normal hearing day would be 9 to 5. l 4
I mean, I Can ask one more question but I think I'm at a 5 point where I can break off now. 1 l
6 JUDGE MARGULIES: This clock is six minutes fast 7 by my watch. But, we are not going to deal with seconds.
8 If this is an actual breaking point, we will break at this 9 point.
10 MR. CHRISTMAN: Let the record show that your il watch is closer to right than that wall clock.
12 MR. McMURRAY: I'm sorry. I've been following 13 the wall clock.
() id JUDGE MARGULIES: We will recess until tomorrow 15 morning at 9 o' clock.
16 (Whereas, the hearing is recessed at 4:55 p.m.,
17 Tuesday, June 30, 1987, to reconvene at 9:00 a.m.,
19 Wednesday, July 1, 1987.)
l 19 20 21 22 23 24 75 O
CERTIFICATE OF OFFICIAL REPORTER l
This is to certify that the attach'd eproceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in-the matter of:
k NAME OF PROCEEDING: SHOREHAM NUCLEAR POWER STATION, UNIT 1 l DOCKET NO.: 50-322-OL-3 i PLACE: HAUPPAUGE, NY I
DATE: Tuesday, June 30, 1987 were held as herein appears, and that this is the original i transcript thereof for the file of the United States Nuclear Regulatory Commission.
M. WALSH g g T WALSH (TYPED)
Official Reporter Reporter's Affiliation J
U]. [dA4!c/O W -
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