ML20237F734
| ML20237F734 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/09/1987 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#387-4246 OL-3, NUDOCS 8708130143 | |
| Download: ML20237F734 (66) | |
Text
---
ORIGINAL Uh11ED STATES c<y-NUCLEAR REGULK'ORY COMMISSION
-IN THE MATTER OF:
DOCKET NO: 50-322-OL-3 l
LONG ISLAND LIGHTING COMPANY
-(Emergency Planning);
(Shoreham Nuclear Pcwer Station, Unit 1)
I i
I
.1 LOCATION:
HAUPPAUGE, NEW YORK PAGES:
17992 18055 DATE:
THURSDAY, JULY 9, 1987 i
1
/QO c' \\
t O
ace-FEDERAL REPORTERS, INC.
e70s: 301 na s ?oiv'?
Official Reporters PDR N >t K x 0 500;: {;'
444 North Capitol Street Washington, D.C. 20001 (202)347-3700 m m m_ _ ___ _
5180'00 00
.17992 marysimons 1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
X 5
In the Matter of:
6 LONG ISLAND LIGHTING COMPANY
- Doc ke t No. 50-322-OL-3 7
(Shoreham Nuclear Power Station, 8
Unit 1)
()
9
X 10 Court of Claims 11 State of New York 12 State Office Building 13 Third Floor Courtroom 14 Veterans Memorial Highway 15 Hauppauge, New York 11788
)
16 Thursday, July 9, 1987 17 The hearing in the above-entitled matter 18 reconvened, pursuant to notice, at 9: 00 o ' clock a.m.
19 BEFORE:
20 MORTON B.
MARGULIES, Chairman 21 Atomic Safety and Licensing Board 22 U.
S. Nuclear Regulatory Commission
[
l 23
- Bethesda, Maryland 20555 24 ACEJFEDERAL REPORTERS, INC.
l 25 202 347-3700 Nationwide Coserage 8 @ 336 4.646
51800000 17993 marysimons,
()
I JERRY R. KLINE,' Member 2
. Atomic. Safety and Licensing Board 3
U. S. Nuclear Regulatory Commission-d Bethesda, Maryland 20555 5
FREDERICK J. SHON, Member 6
Atomic Safety and Licensing Board 7
U. S. Nuclear Regulatory Commission
'8 Bethesda, Maryland 20555 9
APPEARANCES:
10 On Behalf of Long Island Lighting Company:
II JAMES N. CHRISTMAN, ESQ.
U 12 MARY JO LEUGERS, ESO.
13 STEPHEN W. MILLER, ESQ.
O Id Hunton & Williams is 707 East Main Street 16 P. O. Box 1535 I7 Richmond, Virginia 23212 18 On Behalf of Suffolk County:
19 CHRISTOPER II. McMURRAY, ESO.
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 j
O
51800000 17994 marysimons I
On Behalf of the State of New York:
2 RICHARD J. ZAHNLEUTER, ESQUIRE 3
Special Counsel to the Governor Executive Chamber 5
Room 229 6
State Capitol Albany, New York 12224 8
On Behalf of the NRC:
GEORGE E. JOHNSON, ESQ.
10 RICHARD G. BACHMANN,'ESQ.
U. S. Nuclear Regulatory Commission 12
- 7735 Old Georgetown Road 33 Bethesda, Maryland 20814 s.
14 15 16 II 18 19 20 21 22 23 24 25 w
a
________________________J
64000000 17995 marysimons
..i 1
CONTENTS Voir 2
Direct Cross Redirect Recross Dire Board' (Panel) 3 JAMES JOHNSON and 4
SUSAN SAEGERT 17996 17998 18012 5
(Panel)
JAMES JOHNSON, JR.
6 SUSAN SAEGERT MARTIN MAYER 7
EDWARD RADFORD and 8
GREGORY MINOR 18016 18023: 18050 9
EXHIBITS 10 Identified Admitted Suffolk County Exhibits 11 Exhibit No. 15 17998.
17998 Exhibit No. 16 18018 12 f
13
.I
~
14 15 16 17 18 19 20 21 22 23 24 25 r5
b 45000101 17996 I
PROCEEDINGS 2
(9:00 a.m.)
3 JUDGE MARGULIES: ' Good morning.
Is Suffolk d
County ready.to proceed;with the next panel?
5 MR. CASE:
Yes, Judge Margulies, we are.
6 JUDGE MARGULIES:
The two panel members have been previously sworn.
You may proceed.
8 Whereupon, 9
JAMES H. JOHNSON, JR.
10 and SUSAN C. SAEGERT L
12 were called as witnesses by and on behalf of the Intervenor, I3 the' County of Suffolk, and having previously been duly Id sworn, were examined and testified as follows:
l 15 DIRECT EXAMINATION 16 BY MR. CASE:
I7 Q
For the record, would each panel member please I8 identify themselves by name?
l A
(Witness Saegert)
I'm Susan Saegert.
20 (Witness Johnson)
I'm James Johnson.
21 Q
And, Dr. Johnson and Saegert, in front of you is 22 a document dated April 13th, 1987 captioned " Direct l
23 Testimony of James H. Johnson, Jr. and Susan C. Saegert on 24 Behalf of Suffolk County Concerning LILCO's Reception 25 Centers (Evacuation Shadow Phenomenon and Traffic Issues)."
i r0 1
l l
u_____
.1
i, 8 y p
b
[45'000101 17997 suewalsh I
. Was this' testimony prepared-by you or' under your
'2 direction and supervision?
3 A'
(Witness Saegert)
Yes.
d (Witness Johnson)
Yes.
S 5
Q Are.there any corrections or changes yoa'wish.'to 6
make in this bestimony?
7 A
(Witness Johnson)
Yes, there are.
8 Q
What hre those, Dr. Johnson?
9 A
06 Page 8, the top heading, the word 10
" excavation" should be changed to " evacuation.",With*that U
change, it'should read:
"The location of the, reception:
i 12 center and increased evacuation shadow...'
I3 On Page 13, in our answer to the question posed O.
M
.above the second ldne in the answer, the last word should be 15
" spatial" spelled as s-p-a-t-i-a-1 instead of s-p-a-c-i-a-l.
16 And, finally I would,like to note;that I will be I7 sponsoring the testimony which appears on Pages 17 through 18 20.
19 Q
Now, with those changes, is this testimony true i
20 and correct: to the best of your belief and knowledge?
21 A
- yes, 22 MR. CASE:
Judge Margulies, I would ask that 23 this be marked as Suffolk County Exhibit Number 15 and move 24 its admission into evidence.
25 crUDGE MARGULIES:
Is there any objection?
O 1
J
45000101 17998 suewalsh I
MR. CHRISTMAN:
No objection.
But, I would like 2
'a clarification.
On Pages 17 through 20, does that mean 3
that Professor Johnson'is the sole sponsor of those pages?
MR. CASE:
That's correct.
MR. CHRISTMAN:
Okay.
No. objection.
What about 6
21?
Is 21 on sponsored by both, then?
WITNESS SAEGERT:
Yes.
8 MR. CHRISTMAN:
No objection.
JUDGE MARGULIES:
The document will be admitted 10 as Suffolk County's Exhibit Number 15 and'is admitted into evidence.
12 (The document referred to is marked I3 as Suffolk County Exhibit Number 15 for identification and admitted 15 into evidence.)
-16 MR. CASE:
We have no further questions.
I7 -
JUDGE MARGULIES:
You may proceed with cross-I8 examination.
I' LR. CHRISTMAN:
Thank you.
20 CROSS EXAMINATION 21 BY MR. CHRISTMAN:
22 Q
Professor Johnson, if we could talk about your 23 testimony starting at Page 8 where you discus; the effect of 24 the location of the reception centers, is your opinion that 25 monitoring and decontamination centers are ps.;ceived as a 1
J45000101-17999 suewalsh LOL I
eafe refuge in e redio1oeice1 emereency due thee she1eers 2
for people to stay are not?
3 A
(Witness Johnson)
No, d
Q-Both are with regarded, or either could be 5
regarded, as a safe refuge by evacuees?
6
.A Yds, depending on the distance it is from the 7
disaster agent.
8 Q
You'are testifying here, aren't you, that in 9
your opinion LILCO's reception centers are too'far away from 10 the plant, from the nuclear plant?
II A
What do you mean by reception center?
y-12 O
The subject of this proceeding.
i 13 A
Well, the term is used in different ways 14 depending on what fits the bill at one particular point in 15 time.
Do you mean a temporary relocation center?
16 Q
Do you know what LILCO's reception centers are 37 that we are litigating here?
I8 A
Yes.
19 Q
Those three facilities?
20
.g ye,,
21 g
'Do you have those in mind?
22 A
Yes.
23 0
You are testifying here that in your opinion 2d those are farther away than they should be from the nuclear 25 plant; is that right?
O
45000101 18000 suewalsh I
A No.
2 (Witness Saegert)
That mischaracterizes our 3
testimony.
What we are saying is that their location will create certain effects.
5 In fact, some of the ways in which this is a 6
good distance from the plant in that it's perceived as safe 7
will increase the number of people who should be expected 8
~ here, because it is perceived as safe.
t O
Well, either one of you, then.
How close do you 10 think they should be?
A (Witness Johnson)
That is not the purpose of 12 our testimony to give you answers to how close they shduld 33 if >.
be.
14 Q
Well, but I'm asking --
15 A
Our testimony is designed to assess the 16 consequences of them being where you have designated them.
I7 Q
But, my question for you is, what is your
'8 opinion about how close they should be?
I' A
(Witness Saegert)
I will tell you, I think that 20 what you are asking us to do is to resolve a problem that is 21 not resolvable.
It is created by the geography and roadways 22 of Long Island.
23 Any place you place the reception centers will 24 have some effect probably on the flow of traffic, which is 25 already problematic to a very extreme extent in this C
45000101 18001 suewalsh (q
I
_/
situation.
Now, for us to try to resolve that is impossible 2
I think.
3 0
So, there is no location that would be l
acceptable?
d l
l 5
A That's not the issue.
The place where you have 6
placed them is acceptable in the sense that people are 7
likely to use them, which seems positive.
That seems within 8
the intent of placing them at 40 miles.
9 Whether or not Long Island roadways can then l
10 handle the traffic is another issue entirely and I don't 13 think one that we can resolve.
12 O
Whether or not you think it's the issue, can you 13
/-s answer the question?
Or, are you saying that you have no
(
Id opinion?
15 MR. CASE:
Judge, I would object to this line of 16 questioning.
These witnesses -- their testimony is very 17 specific.
They are not emergency planners.
They are not IB here to testify as to where locations of reception centers 19 should be.
20 They are merely testifying on the consequences 21 of their location at this time.
And, they are not offered 22 as experts on emergency planning.
They are simply 23 indicating, based on their expertise, what the consequences 24 are of where they are presently located.
25 MR. CHRISTMAN:
That obj ection has been made by s
45000101 18002 suewalsh-bl I
d Suffolk County many times in the past, that it's not their 2
witnesses ' job to do emergency planning.
And, it may not be 3
their job to do emergency planning but that objection has uniformly been overruled in the past on the grounds that I'm 5
entitled.to ask their opinion on that question which is 6
clearly relevant to the issue at hand.
7 MR. CASE:
Judge, I think that mischaracterizes 8
the testimony here, because these experts are experts on issues that go to what are the consequences on evacuation 10 shadow and traffic, and they simply haven't tire expertise and aren't offered as experts on what is the ideal location 12 within Suffolk County or Nassau County or anywhere else for 13 p
these reception centers.
y Id JUDGE MARGULIES:
It's a concomitant part of 15 their assessment that 40 miles creates problems.
I will 16 permit the question.
I7 BY MR. CHRISTMAN:
(Continuing)
I8 Q
Can you answer the question?
A (Witness Saegert)
Would you restate the 20 question, please?
21 Q
You are testifying that the location of the 22 reception centers as designated by LILCO is a poor one, 23 aren't you?
24 A
No.
That's not really what our testimony reads 25 if you look at it carefully.
What it reads is that these N
v
45000101 18003 suewalsh I
are the consequences related to the placement at 40 miles.
2 I think if you look at the testimony that we 3
litigated yesterday, you will see that our belief is that d
these will be highly used.
Now, from a publ.ic health and 5
safety point of view, that would be good 'if people could get 6
into them.
7 I think our testimony here is just describing.
8 the consequences of this.
Now, it is possible -- it would 9
be the job of the planners and facility providers to then 10 try to mitigate the consequences.
Every action you take has II consequences.
That's part of the planning.
It's not 12 something -- there is no. magic solution where you can dg 13 something with no unexpected or, you know, otherwise O
Id unproved consequences.
15 Q
Given those consequences that you foresee and 16 that you are testifying about, can you tell me what would be I7 a better location for anyone of these reception centers?
18 A
I feel that I've answered the question to the I9 best of my ability.
If Dr. Johnson wants to add anything, I 20 think.he;should.
21 g
- Well, I would like you to try to answer the 22
-question again, because I'm not sure I've gotten an answer.
23 And, the question is --
24 A
The answer that I gave you is that any action 25 you take in emergency planning or anything else has O
J 45000101 18004' suewalsh j
h
' consequences.
And, those consequences have to be taken into 2
account, if possible.
And, if not possible, then some
~3
' alternative plan would'have to be developed.
d Q
Okay.
Let me ask you a yes or no question, 5
then.
Can you tell me a better location for any of these 6
reception centers --
7 MR. CASE:
Judge, I would --
8 BY MR. CHRISTMAN:
(Continuing) j Q
-- taking into account these consequences that 10 you are ' testifying about?
.MR. CASE:
Judge --
12 WITNESS SAEGERT:
No.~
It is neither within my 13 expertise.nor within my knowledge of Long Island.
t Id BY MR. CHRISTMAN:
(Continuing) 15 Q
Okay.
Dr. Johnson, same answer?
16 A
(Witness Johnson)
I concur with it.
I7 Q
Professor Johnson, do you think that the I8 relocation center, let's call it the shelter, at Hershey, I9 Pennsylvania during the TMI accident was under-utilized in 20 part because"it was perceived to be too close to the 21 threatened reactor?
22 A
Yes.
23 24 25 0
45000202 18005 joewalsh O
o Profeeeor achneon, on Pege 11 of vour teeeimonv 2
you cite Perry, Lindell and Greene's book called -- that's 3
Perry, Lindell and Greene's book -
" Evacuation Planning in d
Emergency Management."
Now, that study focused on floods in 5
four western U.S. communities, didn't it?
6 A
(Witness Johnson)
Yes.
7 Q
I have a copy of the book here.
Could you tell 8
me the precise citation that you are referring to for the proposition that the ability to confirm official warnings 10 through direct sensory evidence is a critical determinant in II determining the extent of evacuation from natural disasters?
If I give you the book, could you find that$*
12 13 passage?
O Id A
I could look for it.
15 (The witness is looking at a document he was 16 provided by Mr. Christman.)
37 I don't think they make that statement i
18 specifically, but I know that the citations that they cite I9 on Page 30 and 31 refer to the notion of having confirmation j
i j
20 of the warning source itself.
It reads as follows:
The 21 importance'of establishing a situation or definition of real 22 threat is underscored by the existence of considerable 23 empirical literature dealing with ways in which people go about confirming disaster warnings that they have received.
24 25 They cite Drabek, Drabek and Stevenson.
- And, O
1
45000202 18006 joewalsh
' [e l what that refers to is one of the ways that people go 2
outside in a flood or hurricane or whatever and they see --
3 they look for. environmental cues.
Now, if you go back-and look at the paper which was published prior to this book in 5
'7 9, Perry's paper on which this book sort of is based on, 6
all of that kind of literature is discussed.
7 If you look at my own work, you will'see better 8
citations that support that view.
O So, you are actually citing to the Drabek and j
10 Drabek and Stevenson work rather than the Lindell book per se, I take it?
.12 A
Well, to my way of thinking, Ronald Perry is one' I3 p
of the leading disaster experts in the country.
And, I Id think this is just one of the general texts.
If you look at 15 the real research articles, you will begin to see that kind 16 of material.
I7 Q
Professor Johnson, you say on Page 15 of the 18 testimony that at TMI the evacuation shadow began to fall I9 off only gradually with increasing distance from the 20 accident site.
21 Didn't the Rutgers' groups denote a sharp break 22 in the percentage of the voluntary evacuees at a 10-mile i
23 radius?
Do you recall that?
24 A
I recall their study.
I don't know that they 25 specifically concluded that.
IN
i l
l' l
45000202 18007 joewalsh
(~
l \\}
I It is also important to realize that when you.
2 talk about the evacuation falling off gradually, you have to 1
3 look.at the distance at which within the advisory.that
]
d evacuation was ordered.
Now, at TMI evacuation was 5
ordered.
A selective evacuation advisory was issued for a 6
five mile area.
Within 10 miles, there was a high rate of 7
evacuation.
8 Now, depending on the population within that ten
)
miles and the proportion of the population that evacuated, 10 you could be talking about a very large number of people.
II You are talking about an evacuation shadow at TMI 12 encompassing an area of about 15 miles.
13 Q
The question was -- and I think you answered it, Id but let's make sure -- that Cutter and Barnes, at least in 15 my reading of one of their papers, reported a sharp break in 16 the percentage of voluntary evacuees at the 10-mile radius, I7 and you say you have no recollection of that particular j
18 finding?
19 A
I said they could have said that.
I know that 20 we say in our work that there was a drop off after about 10 21 to 12 miles, which would be consistent with that view.
22 Q
Uh-huh.
2?
A Most of the studies that were done after TMI, 24 including the NRC study, including the Rutgers' study, 25 including our own work, all confirm basically the same 0
i l
l 45000202 18008 I
findings in terms of the spatial behavior of the evacuees.
(Witness Saegert)
It's also important to note l-3 that when you are thinking about the realistic implications of percentage drop that you have to consider what it's a percentage of.
And, in Long Island since the population 6
increases to the west, it becomes more dense, even if the 7
percent is lower the actual numbers can be higher.
8 MR. CHRISTMAN:
That's all the questions I have 9
for this panel.
10 JUDGE MARGULIES:
The State of New York is not j.
here.
We will go to Staff.
12 MR. CUMMING:
I have one question, Judge I3 q
Margulies.
b~d ja JUDGE MARGULIES:
Go ahead, Mr. Cumming.
IS CROSS EXAMINATION 16 BY MR. CUMMING:
II Q
On Page 8 of the testimony, there is a question 18 and answer.
The question is, "What effect will the location l'
of the reception centers have on the evacuation shadow in 20 the event'of a Shoreham accident?"
And, the answer is, "In summary, locating the f
21 22 reception centers approximately 40 miles from the Shoreham 23 plant will expand the area which Long Island residents will
]
24 perceive to be within the zone of risk in the event of a Shoreham accident.
The result of this enhanced risk I
25 O
45000202 18009 joewalsh.
I perception'will be to increase both the magnitude and 2
geographical extent of the evacuation shadow phenomena."
3 This is for either Dr. Johnson or Saegert.- Is d
your understanding of the perception of risk documented 5
based on your studies or based on the secondary references 6
which LILCO has used before to bring your attention to some 7
prior literature on the subject?
8 A
(Witness Johnson)
I'm afraid I don't know what references you are referring to that LILCO has brought to 10 cur attention.
II Q
Well, your own personal studies with respect to 12 risk perception, including the '79 Three Mile Island study.
13 A
Well, my colleagues, Professor Brunn and Zeigler Id and I are responsible for the notion of the evacuation 15 shadow phenomenon.
And, we developed that concept in 1979 16 and it has been variously referred to as the shadow effect, I7 the evacuation shadow phenomenon and spontaneous evacuation 18 behavior.
19 And, what we did was operationalize it in a 20 spatial context, talking about geographic behavior.
So, 21 when you begin to talk about risk and assign a spatial 22 dimension to'it then you have a spatial risk surface and 23 that spatial risk surface in terms of evacuation behavior 24 manifests itself in terms of an evacuation shadow.
That is, 25 you define a zone of risk -- officials define a zone of risk O
45000202 18010 joewalsh pmt I
and what we say is because of the low level of credibility 2
of LILCO and people's fear of radiation that around that 3
risk zone you will have a shadow, a shadow effect, encompassing a population that also perceives themselves to be at riskt and, because of their fear and their high level 6
of distrust of utility company officials -- in this instance, LILCO -- they, too, will evacuate.
8 It's a kind of, what psychologists call, hypervigilant behavior.
10 0
And, it is your -- based on your understanding
'I and the statement that you just made that you attempted or 12 you believe you have accurately modeled that phenomena?-
'3 7
A Yes.
^'
Id Q
And, in modeling that phenomena the only known 15 data you have calibrated that to is the Three Mile Island 16 incident?
'7 A
I calibrated it to a number of data sets, I8 including TMI, including the 1982 survey that was done on Long Island on behalf of Suffolk County by Professor Cole 20 and his research firm.
I calibrated it using Yankelovich, 21 Skelley and White data which was gathered in 1983 on behalf 22 of LILCO.
23 We are in the process of doing some more 24 calibrations for other sites around the country.
25
{
p-O i
i
64000303 18011 marysimons l')
(_/
I Q
But other than public opinion 2
surveys on Long Island, the known data that it has been 3
calibrated to is Three Mile Island?
A (Witness Johnson)
That is where you begin.
5 That is the only emergency we have ever had.
6 Q
And you believe that is the only relevant I
emergency for this purpose?
8 A
I'm not sure what you mean by relevant 9
emergency.
30 0
With respect to calibration of your model.
II A
Well, I have detected in my very careful review 12 of both the natural hazards and technological hazards 13 literature that the models from the natural hazard school do Id not work.
They do not explain what happened at TMI.
15 What we are trying to do is develop forecasting 16 models, models that enable us to predict how people are I7 likely to behave.
If you base it on models that don't work 4
I 18 already, then you are not advancing the science of I9 understanding human behavior in crisis situations.
l 20 What we are trying to do is advance our 21 understanding of our how humans respond in response to l
22 technological emergencies because we know that there are 23 some differences, some very salient differences between 24 technological emergencies in general and natural disasters, 25 but more specifically between nuclear power plant accidents O
64000303 18012
,__ marysimons I
and other kinds of emergencies.
2 I would be happy to summarize those dif ferences 3
for you if you would like.
Q No.
I just want to ask once niore.
The known 5
data points for Three Mile Island are'the reference points 6
other than the public opinion surveys to which you attempted 7
to calibrate the model and nothing else?
8 g.
7,m not sure what you mean, nothing else.
I just listed four other surveys or three other surveys that to we have used to try to calibrate the models.
MR. CUMMING:
I have no further questions.
12 MR. BACHMANN:
The staff has no cross-I3 79 examination of these witnesses.
14 MR. CASE:
Judge Margulies, we would simply ask 15 for a short five-minute break before any possible redirect.
16 JUDGE MARGULIES:
We will take a five-minute I7 recess.
18 (Short recess taken.)
I9 JUDGE MARGULIES:
Back on the record.
20 MR. CASE:
Judge, just two questions on 21 redirect.
22 REDIRECT EXAMINATION 23 BY MR. CASE:
24 Q
Dr. Johnson or Dr. Saegert, is the purpose of 25 your testimony to identify were. reception centers should be
!O
64000303 18013 marysimons I
located?
2 A
(Witness Johnson)
P 3
Q What is the purpose of-your testimony?
A The purpose of our testimony as stated in the 5
published version is to assess'given the designated location 6
of the facilities and to assess the attendant negative 7
consequences of them being located there.
8 And if I might, I could briefly itemize those 9
negative consequences that we have addressed.
10 One, we believe very firmly that ---
II MR. CHRISTMAN:
Obj ection.
This goes beyond the 12 scope of the cross.
13 MR. CASE:
The question went to their purpose, Id Judge Margulies, and he is simply indicating ---
15 JUDGE'MARGULIES:
It has been asked and 16 answered.
It's right in their direct testimony.
In terms 17 of enumerating the negative points, it's all set out.
18 MR. CASE:
Very well, Judge.
j I'
I have no further questions.
20
. JUDGE MARGULIES:
Is there anything further of 21 the' witnesses?
22 MR. CHRISTMAN:
No, sir.
23 MR. BACHMANN:
No, sir.
24 MR. CUMMING:
No.
25 JUDGE MARGULIES:
This panel is excused.
O
64000303 18014 marysimons y -4 d'
I Thank you.
(The panel consisting of 3
Witnesses Johnson and Sacgert were excused.)
5 MR. CASE:
Judge, as to the Suffolk County panel 6
that is next in order dealing with monitoring and 7
decontamination, Suffolk County could be prepared to present
'8 that panel at 12:30 today or 1 o' clock, and I think that is j
agreeable to all counsel.
10 MR. CHRISTMAN:
It's agreeable to the applicant.
JUDGE MARGULIES:
Is it agreeable to the other>
12 parties?
13 A-MR. BACHMANN:
It's agreeable to the staff and 14 FEMA.
15 JUDGE MARGULIES:
We will recess until 1 o' clock 16 to hear the panel on monitoring and decontamination I7 procedures.
I8 (Whereupon, at 9:28 a.m.,
the hearing recessed, to reconvene at 1:00 o' clock p.m.,
the same day.)
20
,.4,. n.,,
21 22 4
23 24 25
,J
64000303A.
18015 marysimons 1
AFTERNOON SESSION 2
(1:00 p.m.)
3 JUDGE MARGULIES:
Please come to order.
d Before we start with the matter of the new 5
panel, Mr., McMurray, have you made a decision in regard to 6
Exhibit No. 4 that was admitted as LILCO's exhibit?
7 MR. McMURRAY:
I have not yet.
8 JUDGE MARGULIES:
Will you do so before the 9
panel departs, or how do you expect to handle that?
10 MR. McMURRAY:
I will do so before we break II today.
12 JUDGE MARGULIES:
Is Suffolk County ready to 13 proceed with their next panel?
O.
Id MR. CASE:.Yes, Judge Margulies, Suffolk County 15 is ready to proceed.
16 l
JUDGE MARGULIES:
I will now swear those 17 witnesses who have not been' sworn.
18 Please stand and raise your right hand.
19 Whereupon, 20 JAMES H. JOHNSON, JR.
21 SUSAN C. SAEGERT 22 MARTIN MAYER 23 EDWARD P. RADFORD 24 and 25 GREGORY C. MINOR O
l
\\
{
'64000303A 18016 marysimons I
l
(
were called as a panel of witnesses on behalf of Suffolk County and Mr. Radford, having been first duly sworn by 3
Judge Margulies and Messrs. Minor, Mayer, Johnson and Ms.
Saegert having been previously duly sworn, were' examined and 5
testified as follows:
6 JUDGE MARGULIES:
Please be seated.
I DIRECT EXAMINATION 8
BY MR. CASE:
O Will the members of the panel please identify
'U themselves for the record starting with Mr. Minor.
11 A
(Witness Minor)
I am Gregory Minor.
12 A
(Witness Radford)
I am Edward P. Radford.
I3 A
Witness Mayer)
Martin.Mayer.
Oi t
A (Witness Saegert)
Susan Saegert.
15
-A (Witness Johnson)
James Johnson.
16 0
And in front of each of you is a copy of a set I7 of testimony entitled " Testimony of Edward P. Radford, I8 Gregory C. Minor, Susan C. Saegert, James A. Johnson, David Harris and Martin Mayer on behalf of Suffolk County 20 Concerning,LILCO's Reception Centers (Monitoring and 21 Decontamination Procedures) April 13, 1987."
i 22 Was this testimony prepared by you or under your 23 direction or supervision?
24 A
(Witness Minor)
Yes.
25 A
(Witness Radford)
Yes.
Id-
'U
64000303 A 18017 marysimons 1
A Witness Mayer)
Yes.
2 A
(Witness Johnson)
Yes.
3 A
(Witness Saegert)
Yes.
d Q
And are there any corrections or changes you S
wish to make at this time in the testimony.
i 1
.6 A
(Witness Minor)
Yes.
There is one 7
typographical error that we need to correct, and it is on 8
page 30, the fourth line up from the bottom.
The first name
'at the left should be Millopaugh instead of Willopaugh.
10 It's a misspelling of the name.
II Q
Are there any other corrections or changes that 12 you are aware of at this time?
i 13 A
Not to my knowledge.
o Id A
(Witness Johnson)
No.
15 A
(Witness Saegert)
No.
16 A
Witness Mayer)
No.
I7 A
(Witness Johnson)
No.
18 0
With that correction, is this testimony true and 19 accurate to the best of your belief and knowledge?
20 A
.(Witness Minor)
Yes.
21 A
(Witness Saegert)
Yes.
22 A
Witness Mayer)
Yes.
23 A
(Witness Radford)
Yes.
l i
24 A
(Witness Johnson)
Yes.
25 MR. CASE:
Judge Margulies, I would ask that O
o
l 64000303A 18018 this be marked as Suffolk County Exhibit No. 16, and I would 2
move its admission into evidence.
3 (The document referred to was marked Suffolk County Exhibit 5
No. 16 for identification.
6 JUDGE MARGULIES:
Is there any objection?
7 MR. CHRISTMAN:
Subject to the swearing to it by 8
Dr. Harris in the future, we have no objection to most of 9
the testimony, but I do have an objection to two small 10 passages.
Those passages are footnot:e 19 on page 36 and 12 footnote 4 on page 15 starting with Dr. Roger E. Linnemann.
33 Thcse two footnotes are cases in which Dr. Linnemann's p
deposition has been simply cited in support of this panel's 15 testimony.
16 Now my objection is that these two portions have
'7 an inadequate foundation, are unreliable and inadmissible
'8 hearsay and that these witnesses are incompetent to sponsor I9 that portion of the testimony.
20
.My basis for the objection is that the witness, 1
Dr. Linnemann, was not confronted with those statements when l
21 22 he was on the stand and could have been confronted last i
week.
Therefore, the testimony about his deposition is
)
23 i
inherently unreliable.
)
24 25 My precedent is my understanding of the practice pm C
1 i
64000303A 18019 marysimons
/~-
(_)
I in the 0-5 proceeding and my knowledge of the practice.in 2
the O-3 proceeding earlier a couple of years ago as follows.
3 My understanding of the O-5 practice has been d
that when one party cites another party's deposition and his 5
testimony, it is not to be relied until the deponent has 6
been confronted with the statement at hearing.
7 That was, I believe, the case where LILCO 8
attached parts of depositions of FEMA witnesses.
9 My precedent from the 0-4 proceeding, this 10 proceeding a couple of years ago was that on Contention 64 LILCO attached portions of depositions by State of New York 12 witnesses and those were stricken because the witnesses had I3 g-)
been withdrawn and were not going to appear at hearing.
'~
Id Now throughout all of these discussions in the O-15 5 proceeding and in the oral argument the justification for 1
l 16 using deposition testimony in this was is always that well, j
1 I7 the deponent will be present at the hearing and can be cross-18 examined.
l 19 As I say, in the O-3 proceeding those witnesses 20 were not being presented at hearing af ter all and could not i
21 be cross-examined, l
22 What is happening here is precisely the same l
23 situation in a different form.
That is, by declining to 24 confront the witness with these two statements the County 1
25 has made it impossible for the witness to confront the i
I lw___________
'64000303A 18020 marysimons r
4 statements because the applicant could not go beyond the scope of the cross-examination on redirect.
So the witness was not allowed to explain the statement.
I should note that we are not objecting to the similar use two other passages that I can recollect, 6
footnote 3.on pages 14 through 15 arid footnote 15 on page 28 7
because in those cases the witness was confronted with his 8
statement or at least asked questions about the subject and had a chance to explain it.
10 I should note that we could not have of course II known before last week t. hat this objection would arise 12 because only then did we know that the witness would~ not be 33 allowed a chance to explain those passages.
I#
That's my objection.
15 Other than that, we have no objection to the 16 rest of the testimony coming in.
17 18 19 20 e
21 a
22 23 24 25 10
45000404 18021 suewalsh' I
JUDGE MARGULIES:
May I have the footnotes 2
again?
3 MR. CHRISTMAN:
Cer;ainly.
Footnote 19 on Page d
36 and Footnote 4 on Page 15, b.it only the portion of 5
Footnote 4 that starts with Di.. Roger E. Linnemann and runs 6
to the end of the footnote.
I 7
(The Board members are conferring.)
8 JUDGE MARGULIES:
Do you wish to respond?
MR. CASE:
Just briefly, Judge Margulies, we 30 believe th.at the motion to strike should be denied on II several grounds.
12 First, LILCO brought extensive motions to 13 strike, particularly one dealing with this -- with all our Id testimony.
They could have raised it at that time.
They 15 did not.
16 They made the tactical error of relying on us to 17 bring it up in cross-examination.
And, they can't make 18 amends for that tactical error now.
19 They made no effort to rebut this testimony.
20 And, additionally, just like any other expert, Dr. Radford, 21 to the extent he cites Dr. Linnemann's testimony, he can 22 rely on Dr. Linnemann's statements in reaching his 23 conclusion.
And, it's the equivalent of relying, like Mr.
24 Donaldson did, on the statements of Mr. Falk Kantor in 25 reaching his conclusions or any other academic piece of
1 l
45000404 18022 i
suewalsh I
work.
2 So, on that ground also it should not be stricken.
To the extent that LILCO wants to test the weight and.the extent of that reliance they can do so on cross-5 examination.
But, it certainly should not be stricken.
6 JUDGE MARGULIES:
Does Staff wish to be heard?
MR. BACHMANN:
Having only been on this case 1
8 since the beginning of the year, I do not have Mr.
Christman's years of background as far as the rules and the I0 law of this case.
It appears to me though that if this is not stricken that it is the type of testimony that should 12 not be granted particular weight by the Board since, asLMr.
33 r
Christman pointed out, it has not been tested through cross-14 examination.
15 So, I generally support Mr. Christman; however, 16 as I said, in the evcnt that it is not stricken that I don't
'7 believe -- the Staff does not believe that it should be
'8 given particular weight.
I' (The Board members are conferring.)
20
. JUDGE MARGULIES:
Mr. Christman, would you be 21 able to proceed with your examination should the Board defer 22 ruling on that until the next break?
23 MR. CHRISTMAN:
Yes.
24 JUDGE MARGULIES:
The Board will defer ruling.
25 You may continue with your cross-examination.
O
t 45000404-18023 suewalsh I
MR. CHRISTMAN:
Thank you.
2 CROSS EXAMINATION 3
BY MR. CHRISTMAN:
1
- d Q
Professor Sacgert, on Page 23 of the testimony 5
you say.that the evacuees may not be able to comprehend 6
routing instructions --
7 A
(Witness Saegert)
Yes.
8 Q
-- given to them by LILCO guides.
What guides 9
are you talking about?
10 (The witness is looking at a document.)
II Page 23.
12 A
Yes.
I just wanted' to see the wording of the l
13 sentence.
Guides would be giving traffic instructions, Id O
Traffic guides, then?
i 1
15 A
Traffic guides.
16 Q
Do you think people won' t be able to follow
'7 simple hand signals that the traffic guides give?
f 18 A
In combination with the traffic flow 19 requirements of the situation, yes, I think that might be 20 problematic.-
21 Q
They couldn't follow a hand motion directing 22 them in a certain direction?
They wouldn' t be able to 23 comprehend that or to follow it?
24 A
I think that if it's extremely siniple and it's a 25 straight road there might be no problem.
I think judi,ing O
45000404 18024 suewalsh
,3 d
I from the lay-out and the flow, as I've seen it in LILCO's 2
plan, I think there could be some problems.
3 0
You think they could follow a straight line but not make a turn, for instance, in response to a traffic 5
guide's motions?
6 A
I think that you have to take into account what the person is doing when they are routing themselves through 8
here.
They are not simply trying to follow traffic guides.
If that was their only job, if that was their mental set, 10 then they probably could do it.
II But, they have goals themselves.
They have'the 12 idea they are supposed to get to a certain point and they, 33 r^a will be competing with other cars to get to that point.
Id And, I think under those circumstances they will have 15 trouble deciding where to go.
16 I think that there also will be occasions, probably quite a few occasions, when people ask for 38 instructions and I think those conditions will be more l9 likely to be confusing to people.
20 21 22 23 24 25
/C u
i 1
l 45000605 18025
()
I Q
Well, which of the three facilities do you think 2
makes -- is the most complicated or represents the worse 3
problem in regard to people not being able to make these --
d follow these directions,.make these movements?
I 5
A (Witness Saegert)
It depends to some extent on 6
the number of people arriving there.
The more people there 7
are, the more problematic it's going to be.
8 Q
Right.' But, which of the three facilities is 9
the worst in your judgment?
10 A
I real]y don't feel that I can answer th'at.-
I II think all of them will present problems for different l
12 reasons.
And, I think that the biggest issue is going.to be 13 handling the crowds that are being received a: those Id locations.
15 Q
Well, if I would show you & diagram of the 16 Roslyn site, the one that you've seen before, could you tell O
17 us where it is in particular that people will have trouble,
,i 18 negotiating the turns or --
),,
19 A
No.
I think that you are preceeding on the view 20 that' people /are going to do exactly what they are told, and l
j 4
21 that's not my view.
f 22
' You are assuming that your litt.le dotted lines 23 are going to be the car flow.
I'm assuming hat it's not l
going to be quite that neat and simple.
I 24 1
25 Q
No, I'm not assuming.
I'm asking the question, O
1 f
i l
45000505 18026
'j oewalsh r'A I
(_)
and I guess you answered it.
2 The question is, you can't tell me, if we would 3
show you a diagram, which of the -- which turns the people would have trouble making or wouldn' t be able to maker or, 5
can you?
6 A
No, I-can't.
I think, however, that if you 7
follow this issue up with traffic police, as we have done in 8
previous proceedings, that they would back up my statement 9
from experience, and I'm drawing on my research here, that to under crowded conditions and conditions of stress people in 11 automobiles have trouble and do not follow instructions of 12 traffic guides that easily and correctly and quickly.
13
,r~1 Q
Have you been to the reception centers?
b2 j4 A
No, I have not.
I've seen aerial photographs of 15 them and the diagrams provided by LILCO.
16 Q
You say again on Page 23 that people may not I7 accurately or quickly follow the instructions of the I8 monitors.
A Yes.
20 g.
gWhat instructions do you think they won't be al 21
[p -
able to follow?
i 22 A
I'm not sure exactly what instructions the 23 monitors are going to give them.
I'm relying on my research 24 and on other people's research about behavior under stress.
25 It suggests that people process information t-9
'h
l I
45000505 18027 I
slowly, don't hear things, ask questions, do not respond 2
automatically, and do not comprehend necessarily the 3
information.that they are being given, particularly if it's d
in a time pressure kind of situation which it must be if 5
these monitors expect to perform t
- tasks in 100 seconds.
6 0
Well, if a monitor told an evacuee to lift his 7
feet, lean forward or hold out his hands for monitoring, do 8
you think they couldn't -- people would not be able to 9
follow those instructions?
10 A
No.
I think that may sound silly to you, but if II you think about behavior under stress, people -- you ask 12 them to raise their right hand.
They don't always raise 33 their right hand; they sometimes raise their left hand.
O Id People don't always behave -- there is a fairly well, in 15 fact one of the more well established principles in 16 psychology is the idea that people narrow their raage of cue-37 utilization when they are under stress.
18 And,'what that means is that they might not 19 hear, they might lean forward rather than raise their feet, 20 that there~is a kind of inability to respond accurately and 1
21 quickly..And, to the extent that a person is really 22 focusing on responding, which I doubt is going to be the 23 mind-set of these people, they would perhaps be able to do 24 it correctly but slowly.
25 And, to the extent that people have other things O
45000505 18028 I
on their mind, which they will, they may respond inappropriately or. simply fail to respond at all.
Q
_So, you think they just might not be able to hold out their hands at all?
A I think some people are going to do the wrong 6
thing, yes.
I'm not saying --
Q Do you think that people --
l 8
A
-- that someone can't hold out their hands.
I'm saying that if you were doing this in a realistic situation, 10 you would see inappropriate behaviors --
Q People would not be able to, --
12 A
-- and slowness also.
13 Q
-- for instance, would not be able to lean Id forward or would not be able to raise their feet?
15 A
I'm not saying they can't raise their feet.
I'm 16 saying that the situation in which you are expecting them to I7 do this within a 100-second framework appropriately with no 18 stops, mis-starts, questions or just simple non-I' comprehension is inappropriate assumptions about human l
20 behaviors. ^
21 Q
Do you think if a person were asked to hold out 22 his hands for monitoring and didn't do it the first time 23 that if he were asked a second time he still might not be 24 able to hold out his hand?
i 25 A
He probably would do it, but that would take an D
l 45000505 18029 joewalsh I
additional five or six seconds.
If everybody in the car did
]
2 that three times, your time estimate would be really off.
il 3
Q I see.
Did you happen to see the videotape d
LILCO made of a' training session of using the Hicksville 5
facility on June 8th?
6 A
No, I did not.
l Q
Dr. Saegert, do you think people are likely to 7
8 be sitting in lines in their cars at these reception centers 9
for long periods of time?
10 A
Yes, I think that's very likely.
Il Q
Do you think that while they are sitting in; 12 those lines, people will likely have their car radios-on?
13 A
Most likely.
Id Q
Do you think they are likely to keep their car 15 radios on all the way from the EPZ boundary out to the 16 reception centers?
I7 A
Yeu, I think that's likely.
I 18 Q
Dr. Saegert, on Page 22 of your testimony you 19 say that research has established that time passes more 20 slowly while. waiting and stress increases as time passes.
j 21 And, you cite Osuna.
And that I think should be O-s-u-n-a 22 rather than m-a, right?
Osuna.
23 That article presents no empirical data, does 24 it?
25 A
No, it doesn't.
It relies on the accumulation O
45000505 18030 joewalsh
%I.
.(
of data in cucing theory research and attempts to present a'.
2 model.
3 Q
It's a mathematical model?
(No response.)
Professor Saegert, were people anxious and 6
. fearful during the Three Mile Island accident, do you think?
A Yes, I think they were.
8 Q
What evidence was there of diminished ability to l
i follow instructions or aggressive behavior during the TMI 10 evacuation, do you know?
Noonewasonthesitedoingthatkindof'{
A 12 research; however, afterwards there.were studies done oh I3 73 exactly the kind of behavior that I'm talking about.
5
'd Now, when we are dealing with a narrow time 15 estimate like 100 seconds I'm not talking about, you know, 16 becoming comatose.
I'm just talking about behavior that I7 will slow down or interfere with the time estimates that 18 LILCO has presented.
You are probably familiar with the research of 20
,.Andy Baumanng and his colleagues that shows that even quite l
21 7 ong time lafter the accident people who were still 1
3 distressed 'liout it were less able to perform simple mental 22 a
23 tasks and made more mistakes and were -- could do fewer in 3
24 the same period of time; also reports of sleeping disorders 25 and other kinds of things.
C
)
l l
l
'l
l l
l 45000505 18031 l
joewalsh l
r) l
'V I
Q That was how long after the accident?
l 2
A It extended up to at least six months and I 3
believe a year after the accident.
And, I want to say that d
that is not to make -- all that that should be taken to 5
indicate is that the effect was probably less serious than 6
would have occurred in the situation itself.
7 Q
But, you said there was no evidence of that sort 8
of effect during the evacuation because no one was there?
9 A
No one was studying it.
You can't have evidence 10 if no one is doing research.
II Q
Professor Johnson, haven't you said that the 12 evacuation from TMI was orderly?
13 r~
A (Witness Johnson)
I said he spatial pattern Id reflected an orderly process.
15 Q
An orderly process?
Do you know of any evidence i
16 of increased traffic accidents or aggressive behavior during 17 that evacuation?
l I8 A
As Dr. Saegert indicated, no one was doing 19 research.
There has been some research on what are called 20 unobtrusive indicators but they are very subjective kinds of 21 indicators.
22 There is no hard empirical evidence to my 23 knowledge.
24 Q
Dr. Saegert, can you cite an actual case of a 25 natural or a technological disaster in which hostility or i
i l
l 45000505 18032 l
I aggressive behavior interfered with an evacuation?
2 A
(Witness Saegert)
The reports on that are in 3
general gathered in an extremely unreliable manner by the d
Hans and Sell people I think that is the most widely cited 5
of that type, and what they did was to write the people who 6
I were in charge of the evacuation and say:
Were there any 7
problems.
8 And, the characteristics of the disasters are not reported nor their location.
It is my contention, and 10 always has been, that the density of Long Island created by I
the configuration of the Island and the traffic conditions 12 are one of the major issues.
I also would like to say that I3 there are certainly reports of such incidents that have not
'd been documented through research but having lived through, 15 for example, the second New York City blackout in which you 16 had people trying to leave the city under stressful
'7 conditions you had a lot of the kinds of behaviors that I
'8 think would be very likely to occur in these kinds of
'9 incidents.
20 They were widely reported in the press and 21 photographed and so on.
It is not as if these behaviors 22 never occurred.
23 (Witness Mayer)
For example, the effect of the 24 gasoline lines.
Remember the gasoline shortage?
I 25 personally witnessed fist fights on gas lines, people
45000505 18033 joewalsh-( )'
I forcing each other to get a gallon of gas.
2 Q
Standing in gasoline --
3 A
No.
Cars lined up in gasoline lines, attacking d
each other, fighting their way in.
5 Q
But, that wasn't during an evacuation, was it?
6 A
No.
It was just to get a gallon of gas.
7 Q
Professor Saegert, on Page 21 in Footnote 7 you 8
cite some papers.
One of them is called " Honking at the 9
Intersection."
10 That experiment was one in which they used --
Il they stopped cars in the street and measured how quickly and 12 how often people, other motorists, honked at those cars'when 13 they drove up behind them, didn't they?
O Id A
(Witness Saegert)
Right.
15 Q
They concluded, didn't they, that people honked 16 more at women drivers than at men drivers?
17 A
That was one of their conclusions.
18 Q
It had to do with the status of the honky and 19 the status of the honker, didn't it?
20 A
That's true, but one of the main imports of this 21
-- all of this research that's cited here, taken together --
22 is that people do honk at drivers who slow them down and 1
23 that this is a measure of aggression.
24 Q
Okay.
Well, let me just get the facts on the 25 record.
That wasn't during an emergency though, was it, O
45000505 18034 that the people were honking at the women drivers?
A No, it was not.
3 Q
Do you know if those researchers found the drivers demonstrating their hostility in any ways other than 5
honking?
6 g
7 don't recall in that particular article 7
whether they had any other measures.
8 Q
Now, you mentioned the Doob and the Gross papers.
That was a similar experiment, wasn't it?
j 10 A
Yes.
Q About honking at intersections and testing the I
status of the people and how that affected honking,'again 33 m
not during an emergency I guess.
14 A
None of the honking studies have been during an is emergency.
16 Q
Okay.
How about that -- that short-circuits one I7 of my-questions.
" Ambient Temperature and Horn-Honking,"
18 another article you cite there, that -- what they proved there was that as the weather gets hotter in Phoenix people 20 are more vigorous honkers; isn't that right?
21 A
'All right, that's what they proved.
Now, what 22 is the.. underlying import of that?
23 Q
That wasn't my question.
24 A
I know, but I think it's worth getting on the i
25 record as long --
ry
}
v
45000505 18035 j oewalsh h.
I Q
Okay.
Why don't you --
2 A
-- as you are bringing this'up.
I think the 3
point made there'is that honking is used here as an d
indicator of frustration and aggression, and there are other 5
studies besides Lue one cited here that attempts to'look at 6
the relationship with hostility in other ways, and self-i I
7 report studies with how drivers express aggression and so
]
8 on.
9 And, the importance of the heat study is that in 10 addition to the stress felt by what people feel because of U
waiting, other stressers such as heat increase that tendency 12 to behave aggressively and express frustrations to other 13 drivers.
I think that has some bearing on this even though e
Id it's a much less serious kind of stress.
15 Q
Dr. Radford, have you, in your practice, treated 16 patients with radiation injury or radiation exposure?
I7 A
(Witness Radford)
No, I have not.
i I8 Q
he ye7 Board certified in any medical 19 speciality?
20 A. 7 yim a member of the American College of 21 Epidemiologir.
22 Q
Epidemiology?
23 A
Yes, sir.
24 Q
Not the American Board of Radiology or the 25 American Board of Nuclear Medicine?
j O
45000505 18036 joewalsh Q
Dr. Radford, still, have you read NUREG 0654?
3 A
Yes, I have.
O The whole thing?
5 A
Well, I can't guarantee-I've read every page but 6
I've read most of it.
7 Q
And, how about NUREG 03967 8
A I don' t believe I've read that.
O Have you had occasion to review emergency plans 10 for other nuclear plants other than this one?
I' A
Yes.
12 0
which ones?
13 If ~
A Specifically, the one on the Hudson River.
14 Q
Indian Point?
15 A
Indian Point, yes.
16 0
And, was that in connection with an NRC
'7 licensing case?
I8 A
Yes.
19 Q
Have you ever participated in creating or 20 writing or drafting an emergency plan for a nuclear plant?
21 g
- yes, 22 Q
What plan was that?
23 A
That was for the Shoreham nuclear reactor at the 24 request of the Suffolk County.
25 Q
Yes, the draft radiological plan that was
45000505 18037
(.~joewalsh
\\/
I subsequently rej ected by the legislature, that one?
2 A
I was not aware of its rejection.
3 Q
You don't know what happened to it; you just d
submitted it and lost track?
5 A
That's correct.
6 Q
Dr. Radford, what is the approved treatment for 7
contamination of the thyroid by radioisotopes?
8 A
Well, if the thyroid has already accumulated 9
iodine, then there is not a great deal you can do except 10 simply to allow it to decay.
II Q
Okay.
What -- how about preventing the uptake 12 of radioactive iodine, and you can use potassium iodide for 13
(}
that purpose, I take it?
Id A
Yes..
If, in other words,.you have reason to 15 suspect that there is the possibility of additional uptake 16 either from material already present in the body or likely 17 to be taken into the body, then one of the techniques that I8 has been used is to give potassium iodide.
19 Q
Is there a dose level, I guess that would be a 20 projected dose level, at which you, a doctor, determines 21 that he should give potassium iodide to the patient?
22 A
You mean a dose level already existing in the 23 thyroid gland?
24 Q
No.
You've just said that if it has been 25 already absorbed it's too late. - But, that's why I said m
45000505 18038 I
proj ected dose.
Is there some trigger point where the doctor 3
would decide that -- or, whoever is making the decision
'would decide to administer potassium iodide?
For instance, this patient is going to get, we proj ect, a dose in the 6
future of 10 rads to the thyroid?
I Is there anything like that, any trigger point 8
that you know of?-
9 A
Well, no.
I think you misunderstand.
The point 10 is that if you are concerned about people taking up the II iodine from the environment already present, then you might 12 want to block it by using potassium iodide.
=,.
I3 Now, the question of how effectively you could
'd block it if the iodine is already in the body, it's not very 15 effective in that situation.
16 Q
And, in any event, potassium iodide doesn't help-
'7 with the effects of exposure to other elements like noble
'8 gases, does it?
A That's correct, i
20 Q
It's just radioactive iodine?
21 A
That's right.
22 O
Is there -- it's true, isn't there, that there 23 is considerable controversy among health physics experts 24 about whether potassium iodide should be taken in a nuclear 25 emergency?
U 1
l
l l
45000505.
18039
~j oewalsh :
()'
I A
Yes, there is controversy.
2 Q
And, is that because the taking of potassium 3
iodide itself may have bad health effects?
d A
It may have:certain risks' associated with it, l
.5 that's correct.
l 6
Q What are the risks?
7 A
Well, iodine is a' sensitizing element.
That is, 8
it can produce a kind'of allergic response.
And, so if'you 9
give it on a mass basis to a large number of people there'is 10 a distinct possibility that certain allergic reactions will II develop as a result of this exposure.
12 Q
Could those allergic reactions cause death in 13 some cases?
Id A
Well, I suppose they could if they weren't 15 treated.
But, that's quite a rare circumstance.
16 17 l
18 19 20 21 22 23 24 25 i
i
)
l f
i
(.
64000606 18040 marysimons r1 I
V Q
And I guess you said, and let's see if I'm 2
correct about this, the potassium iodide is most effective 3
in blocking uptake if it is taken at about the time of
')
exposure or before the exposure rather than after the l
exposure occurs?
6 A
(Witness Radford)
That's c'orrect.
7 Q
And I guess it follows that the effectiveness of 8
administering potassium iodide diminishes the longer after exoc'1ure it's taken; is that right?
10 A
Well, that's true, yes.
Q I have a figure here and tell me whether it's 12 true or not.
Is it true that if potassium iodide is taken 13 three to four hours after exposure the protective effect I'
drops to perhaps 50 percent?
15 A
That sounds reasonable, yes.
16 Q
Suppose a person is exposed and the person doesn't get potansium iodide and the radioactive iodine is I
'7
'8 absorbed by the thyroid, is it possible that it would take a substantial amount of time before that absorbed iodine would 20 be detectable, say as much as 18 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?
21 3
.No.
I think it would be detectable very 22 quickly.
23 Q
Very quickly?
I 24 A
As soon as it is in the thyroid gland, yes.
Q But after exposure how long does it take to be 25 1
.N
i-64000606.
18041 marysimons (3
I
(_/
absorbed in the thyroid gland?
2 A
Well, my recollection is that the uptake rate is 3
rather quick from the pulmonary circulation, meaning by that d
in a matter of hours, a few hours.
5 Q
A few hours?
6 A
- yes, 7
Q Mr. Minor, let me ask you about the Eberline RM-8 14.
You are familiar with that instrument I think.
9 A
Yes, I am generally familiar with that 10 instrument.
Il Q
It has an audible alarm, doesn't it, that you 12 can set?
13 A
It does, yes.
g-]
C/
Id Q
And it also clicks when radiation is present, 15 doesn't it?
16 A
It has an audible count.
17 Q
So that means that when the radiation level is 18 higher the clicks come faster I guess; is that right?
19 A
That's correct.
20 Q
Dr. Radford, on page 33 of your testimony you i
)
i 21 talk about the health consequences of a whole body dose of 22 15 rads caused by unremoved surface contamination.
23 Do you have that page?
24 A
Page 35?
25 Q
Page 33 I think 1
i l
l l
i
64000606:
18042 marysimons gi n1 I
A.
- Yes, 2
Q Okay.
There you talk about a whole body dose of l
4
~3 d
15 rads.
What level of exposure in the radioactive plume 5
would you have to get to get a dose of 15 rads from
)
6 l
unremoved contamination?
A Well, that's almost impossible to answer, and 8
the reason is that it depends on the mix of radionuclides that are present in the plume.
Some radioactive species are 1
10 extremely high energy emissions and penetrate readily II through the whole body and others less so.
They have 12 different half lives and so'forth.
I3 0
Well, did you base this dose of 15 rads on any ld particular mix of isotopes or'any particular accident is scenario?
16 A
Well, yes, to some extent.
The issues before
~
I7 this hearing deal with a whole range of possible accidents, I8 and it is my understanding that the purpose of the emergency
'9 planning is to plan for all possible kinds of accidents that 20 could occur at one of these plants.
21 So in this case the assumption is made that 22 there could be very significant body contamination in this 23 case.
l 24 Q
How did you get the 15 rads?
Is that just an 25 assumption?
C U
\\
1
64000606 18043 marysimons O-3 O
I A
No.
In the development of the emergency plan 2
that I referred to earlier Dr. Finalyson went through the 3
computer procedure of estimating how much exposure might d
occur at varying distances away from the Shoreham plant 5
depending on the nature of the accident and the total amount 6
of radionuclides released.
f 7
In some circumstances the possibility that there 8
could be total exposures in the order of 30 rads at 20 miles 9
away was one possibility.
10 Q
An exposure of 30 rads?
II A
Yes, but that's total.
This is from body 12 surface contamination.
13 Q
So you cut the 30 in half and came up with ---
Id A
Yes.
15 Q
How did you get the factor of 2 to reduce it?
16 A
This was really presented as an example, and I 17 was simply trying to get a ball-park figure that would 18 enable the point to be made.
19 Q
How about on page 34 where you discuss the 20 contamination that would result in 5 rads after 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, 21 how did you get the 5 rads in 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />?
22 A
Well, again, I was simply taking a case which I 23 hoped would be readily intelligible and could then be used 24 to illustrate the point.
Q On that same page when you say that exposure to I
25 I
1 i
E 64000606-18044 a certain level of contamination over 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> doubles if 2
you go to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, the isotopes you must have been 3
considering there were not such things as I-132, I-133, 134 d
and 135 which decay quickly; is that right?
~A That's correct.
6 Q
It was a different mix of isotopes?
7 A
Right.
8 0
Isn't iodine one of the principal radioisotopes that one is concerned about in a radiological emergency?
10 A
It certainly is, yes.
~
Q Dr. Radford, Three Mile Island was a meltdown 12 accident, wasn't it, a core disruptive accident?
13 A
Yes.
O
,d Q
That is, there was substantial core damage?
15 A
Yes.
16 Q
Radioactive iodine was one of the important I7 radioisotopes released from the fuel during that accident,
'8 wasn't it?
A Well, I think there is considerable question 20 about whether the iodine actually did go.
21 Q
I'm not asking about the environment now.
I'm 22 asking 'about it being released from the fuel.
There was a 23 good deal of radioactive iodine released from the fuel, 24 wasn't there?
25 A
That particular reactor of course had not been
64000606 18045 marysimons I
in operation very long and I -- well, I would assume that 2
the amount of iodine in proportion to other radionuclides 3
would have been quite significant and therefore would be an d
important element in the nuclides released.
5 Q
Do you know how many curies of nobel gases were 6
released, not from the fuel, but to the environment, to the 7
world at large?
8 A
I can't give you that number at this time.
9 Q
Do you know how many curies of radio-iodine were 10 released to the environment?
II A
Well, the estimates are that it was a relatively 12 small proportion; that's correct.
13 p
Q Does 15 curies sound about right?
v
'Id A
About 15 curies is the number I recall.
15 0
Was there any detectable skin contamination on 16 members of the public after the Three Mile Island accident?
I7 A
Not to my knowledge.
18 Q
Dr. Mayer, what is the Suffolk County REACT 19 team, do you know, R-E-A-C-T?
20 TA Witness Mayer)
I'm not sure what you mean.
21 g
Iem asking if you know.
You never head of the 22 Suffolk County REACT team?
23 A
I'm not a member of it.
I don't know.
24 Q
I'm not asking if you're a member.
I'm asking 25 if you ever heard of it or know what it is?
O
64000606 18046 marysimons
(~A I
A I think I've heard of it, but I really have no 2
idea what it is.
3 Q
You don't have any idea?
It has to do with radiological' things, doesn't it?
5
.A I don't know.
6 Q
Dr. Mayer, have you ever seen the Red Cross set I
up a shelter in an emergency?
8 A
No.
Q Do you know what functions they perform at 10 shelters in emergencies?
A In general terms.
12 Q
Do you know whether they typically set up first-33 aid stations?
Id A
I believe generally the Health Department 'or the 15 Red Cross supplies at least a nurse in most of their 16 shelters.
I7 Q
At least a nurse?
8 A
At least a nurse.
t l'
Q Dr. Radford, when you quoted Dr. Linnemann in 20 Note'4-on page 15, did you talk to him about what he meant 21 before you wrote that testimony?
22 A
No.
23 Q
You just read the deposition?
24 A
Yes.
25 Q
Did you read the whole deposition?
Pu 4
64000606 18047 marysimons O
\\-)
I A
I believe so, yes.
2 Q
You read more than just the parts given to you 3
by counsel?
d A
That's correct.
5 Q
Dr. Mayer, when you quote Dr. Linnemann in 6
footnote 19 on page 36 did you talk to him first before you 7
wrote that?
8 A
No.
i 9
Q Have you ever talk to Dr. Linnemann?
10 A
No, I have not.
U Q
Did you read his whole deposition?
12 A
No.
I only read the part that I quoted.
{
1 13 Q
How did you know ---
j
)
Id A
It was given to me by counsel.
15 Q
This will repeat something I asked yesterday 16 perhaps, but as to a different passage.
I7 Drs. Saegert and Johnson, on page 20, note 5 you 18 cite our witness Dr. Lindell again.
You didn't ask him 19 whether he agreed with what you said about his work, did 20 you, before,you wrote that?
21 A
(Witness Saegert)
I'm sure we didn't ask him 22 about what he said.
23 Q
That's the only question, did you talk to him, j
24 and you're interpreting his work yourself, correct?
25 A
I'll have to read this, but I think we are (S
x/
l l
64000606 18048 marysimons lb 1
s' interpreting it pretty closely to the text, however.
t Q
There is quote.
A Yes.
We are not really interpreting him.
We are quoting him.
MR. CHRISTMAN:
I have no more questions of this 6
panel.
7 JUDGE MARGULIES:
We will take a short recess to 8
discuss your obj ection.
(Recess taken.)
10 11 12 f~}
b-z i,
15 16 17 18 19 20 21 22 23 24 i
I 25 R
kA 1
45000707 18049 suewalsh p
(_)
1 (1:55 p.m.)
2 JUDGE MARGULIES:
Back on the record.
The Board 3
will deny the motion to strike on the basis that it is d
untimely.
5 Applicant had filed a number of motions to 6
strike at the time the prefiled testimony was initially 7
filed.
No motion to strike was presented at that time.
8 The Applicant could have presented rebuttal testimony on the 9
same subject.
No rebuttal testimony was presented.
10 And, Applicant could have raised the matter 31 while the witness was present but did not do so.
It is 12 Applicant's own witness and you took no steps to raise the 13 matter with the Board when your witness was present.
Id Further, Applicant faults the Intervenor for not 15 cross-examining the witness so that it would not be an 16 orphan document, so to speak.
The Interveners had no reason I7 to cross-examine the witness for the reason that they are 18 accepting the witness' deposition testimony and are agreeing 19 with it.
20 For those reasons, the motion is denied.
Do you 21 have anything further, Mr. Christman?
Do you want to 22 examine further on those portions?
23 MR. CHRISTMAN:
No.
24 JUDGE MARGULIES:
Is the State ready to proceed?
25 MR. A. JOHNSON:
The State has no questions.
(-
45000707 18050 suewalsh I
A-JUDGE MARGULIES:
The Staff?
2 MR. BACHMANN:
One moment, sir.
I'm conferring 3
with the counsel for FEMA.
(Mr. Bachmann is conferring with Mr. Cumming.)
5 MR. CUMMING:
We have no questions.
6 MR. BACHMANN:
The Staff has one question, Your 7
Honor.
8 CROSS EXAMINATION 9
BY MR. BACHMANN:
'O Q
Addressing this to Drs. Saegert and Johnson, on Page 31 of your testimony, the second paragraph, third 12 sentence, which reads:
"In our opinion, many evacuees will 33
(?
reject these procedures and insist on showering, which is M
14 what will be viewed as being complete decontamination."
15 Did you base your opinion on any empirical data?
16 A
(Witness Saegert)
I can't recall at this moment I7 any empirical data that were employed there.
18 Q
Dr. Johnson?
19 A
(Witness Johnson)
No.
20
,MR. BACHMANN:
That's all I have, sir.
21 JUDGE MARGULIES:
Mr. Case.
22 REDIRECT EXAMINATION 23 BY MR. CASE:
24 Q
Dr. Radford, there was some questioning about 25 TMI and its relevance to an analysis of dosage from r~r
?Y
45000707 18051 suewalsh-1 iodine isotopes.
2 Do you recall that questioning?
3 A
(Witness Radford)
Yes, I do.
k Q
All right.
Is the fMI accident the only l
1 incident relevant to such an analysis of iodine isotopes?
5 A
No, it isn't.
I 6
7 Q
What else would be relevant, what other 8
incidents?
9 A
Well, the --
10 MR. CHRISTMAN:
Objection.
I think this is Il beyond the scope of the cross.
l 12 JUDGE MARGULIES:
Could you go back to the 13 question, the initial question on cross-examination?
Id MR. CASE:
I believe the initial question i
15 concerned Mr. Christman's examination of Dr. Radford about 16 iodine isotope releases from TMI and curies and also the 17 amount of deposition on the public tied into a line of 18 questioning on Dr. Radford's dose calculation.
I' And, I believe to the extent TMI is not the only 20 incident Dr. Radford believes is relevant to those 1
21 calculations, this question is clearly within the scope of 22 cross.
23 MR. CHRISTMAN:
May I address that?
24 JUDGE MARGULIES:
Go ahead, Mr. Christman.
25 MR. CHRISTMAN:
I asked a few basic facts about O
E45000707 18052 suewalsh t"'\\
I
(/
what happened at TMI, and then the question was asked is that the only accident that's relevant.
Launching into a 3
discussion of what other accidents might be relevant, that seems a classic case of going beyond the scope of the questionsthatwereabkedoncrossinanattempttoexpand 5
6 the direct testimony I think.
7 JUDGE MARGULIES:
From your statement, Mr. Case, 8
and from Mr. Christman's statement, it does appear that the witness was only questioned about TMI and he responded 10 specifically about TMI, and the Board will sustain the obj ec tion.
12 MR. CASE:
Very well.
I have no further I3 p
questions, Judge Margulies.
14 JUDGE MARGULIES:
Does anyone~else have anything l
15 further of the panel?
16 l
MR. CHRISTMAN:
No, sir.
MR. BACHMANN:
No, sir.
I 18 JUDGE MARGULIES:
Dr. Shon.
BOARD EXAMINATION 20 BY JUDGE SHON:
21 Q
I have sort of a question for Dr. Radford or Mr.
22 Minor perhaps as to the sequence in which the business of 23 monitoring and possible treatment for iodine exposure might 24 take place.
25 Throughout your testimony and particularly at D
l 1
___.____-__-a
a l
r
? 50007 d7
~ 180 3' suentsih Y
I Pages 14 and 15, there is soun stress laid on the notion 2
tha t monitoring should br;' timely, vary early.
However, if 3
that monitoring is done very early.. the iodine won' t have d
ac tinulated in the thyroid; and, correct me if I'm wrong, ^ I 5
think it's only the fact that the radiation ccmeo fror;the 6[
thyroid that concludes the fact that it's iodina.
The 1
7 Eberljne instrument can't tell iodine from anything else.
J C
So, if ycu counted so early that it's not in the 7
thyroid yet, you don't know that it has happened.
And, if 10 you count it after it gets into the thyroid, then you can't
'1 do anything about it because the blocking agent will no e
J Il longer block it; is that not correct?
13 A
(Witness Radford)
That is correct.
ob Id Q
Ow I guess I don't utilerstatid what the entire 15 sequence of monitoring and treatment ir'in this case.
16 A
(Witness Minor)
Dr. Shon, I. agree with you that 37 the uptatc of iodine has to occur before you can actually 18
- detect it vith the Eberline instrument, and it also is true 1
19 that you can't tell if it's iodine.
You can tell that there 2(
is an emission from that area and you assume that it's 21 iodine.
22 But, the other part in my thinking is that in 23 writing tnis testimony I envisicaed these people being 2d contaminated at some point from within the EPZ where they 25 live and then driving this 40 miles through traffic that n
1
_ _ _ _ _ _ _ _ _ _ _ _ _ _ ~
l j.
')
n 1
45000707 18054 suewalsh f'
4
'?
could.take them several hours during which time you probably.
J 2
have absorbed enough to be detectable.
h 3
Q But is it not true then, according to.the
,.!{
testimony Dr. Radford gave a few minutes ago, that once it's l
1 in the thyroid and you can detect it there and you know it's uf 6
iodine, it's too late to give them potassium iodide?
7 A
(Witness Radford)
Not entirely so, because (a) 8 there will still be some potential for further uptake into
.the thyroid; and, this will be the -- the proportion might 10 well be a function of how long they've been in the queue..
I If they were in the front part of the queue, they might have 12 considerable opportunity to take up more.
And, under those I3 r
circumstances then perhaps blocking therapy would'be useful.
14 For those that come much later, the scenario you 15 have just outlined is correct.
So, you are in a situation 16 where you don't know where you stand and you don't know what
'7 the time sequence has been for that particular individual in
'8 every caser and, therefore, you are doing your best first to determine whether in fact iodine is present in the thyroid 20 glands, and that can be detected at fairly low levels.
- And, 21 then secondly the question of, okay, what further do you do 22 about it is then dependent on further investigation.
23 JUDGE SHON:
Thank you.
24 JUDGE MARGULIES:
Has Judge Shon's questioning 25 prompted any other questions?
~ 450007 07 18055 suewalsh
(
1 MR. CASE:
Not by Suffolk County, Judge 2
Margulies.
3 MR. CHRISTMAN:
No, sir.
d MR. BACHMANN:
No, sir.
5 JUDGE MARGULIES:
Before we dismiss the panel, o
could you tell us, Mr. McMurray, what you have decided in 7
regard to making a motion as pertains to Exhibit Number --
8 LILCO's Exhibit Number 47 9
MR. McMURRAY:
We will make no such' motion.
10 JUDGE MARGULIES:
Thank you.
The panel is dismissed.
^
11 12 (The witnesses stood aside.)
13 JUDGE MARGULIES:
The Board assumes the parties
,/ }
Id expect to proceed as outlined in their agreement next week 15 in their presentation?
16 MR. McMURRAY:
Yes, sir.
17 MR. CHRISTMAN:
Yes, sir.
18 JUDGE MARGULIES:
We will recess until Tuesday 19 morning at 9 o' clock.
1 20
. $(Whereupon, the hearing is recessed at 2:07 p.m.,
Thursday, July 9, 1987, to reconvene at 9:00 o' clock 21 22 a.m.,
Tuesday, July 14, 1987.)
23 24 25 l
J
CLP.TIFICATE OF OFFICIAL REPORTER r\\
LJ This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING:
LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
DOCKET NO.:
50-322-OL-3 (Emergency Planning)
PLACE:
HAUPPAUGE, NEW YORK O-DATE:
THURSDAY, JULY 9, 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt)<
'O /
(TYPED)
MARY C.
SIMONS Official Reporter I
ACE-FEDERAL REPORTERS, INC.
Repor er's Affiliation l
f f J ft Y
)
V
~y p
GARRETT F. WALSH LJ i
g Au n don MYRTLE SUE WALSH f
l
_ _.. _ _ _. _ _ _ _ _ _ _. _ _ _. _ _ _ _. _ _ _. _ _ _ _ _ _ _ _ _ _