ML20237G773

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Intervenor Exhibit I-SC-108,consisting of 870306 Transcript of Deposition of Jh Keller,P Mcintire,Iw Kuzar & TE Baldwin Re Emergency Exercise
ML20237G773
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 06/17/1987
From:
LONG ISLAND LIGHTING CO.
To:
References
OL-5-I-SC-108, NUDOCS 8709020405
Download: ML20237G773 (12)


Text

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'87 fig 25 A9 :23 UNITED STATES OF-AMERICA

ri NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the Matter of:

Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY (ASLBP No. 86-533-01-OL)

(Shoreham Nuclear Power Station, Unit 1) 1

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x DEPdSITION OF JOSEPH H.

KELLER, PHILIP McINTIRE, IGOR W.

KUZAR, and THOMAS E.

BALDWIN New York, New York Friday, March 6, 1987

~j ACE-FEDERAL REPORTERS, INC.

Stawtype Reporters 444 North CapitolStreet Washington, D.C. 20001

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8709020405 870617 (202) 347-3700 PDR ADDCK 05000322 Nationwide Coverage o

PDR 800-336-6646

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Mr.

McIntire, I understand that the 2

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pensel will be addre3 sing that issue, but that will be 3

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Is that r.

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WITNESS McINTIRE:

Yes.

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y; 7 Q.

Can you tell me right now what you i

Jrl 3 e mect your t e s t 4. m o n y will be o,7 the lasue of the ff i

[pr. 9 shadow phenomenon?

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/10 WITNESS McINTIRE:

No, I can't.

Only in i

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( 11 the bec,adese out1ines.

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[ 12 Q.

Can you tell me, then, to the extent you

"'13 can, your opinions regarding the issues that have r

t jid been raised about the shadow phenomenon as they

}?,15 re). ate to the reception centers?

.A 16 WITNEGS McINTIRE:

I do, as a renult of jl7 the history of this procesa nn Long Island and Mr.

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[18 Baldwin and I have had numerous discussions on this, to; i;19 since he lives on Long Island, is familiar with the te

' 20 public perceptions out there, the public feelings, 1

following the political campaigns.

O 22 My generai conclusion at thi.e point in 4

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time is, i t,'

trere were en acc ide:ic, the content of

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2 any emergency broadcast messaces and the individual wnc would be civing direction to r.'h e general pubtlo q

3 would be crucial to a successful evacuation.

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0, You have stated two factors which, in

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6 your reinion, are crucial to a successful evecuation.

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j 7 One is the content of the m e s e. o g e n.

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g you believe these factors will have an impact on

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whether or not: thero w '. L 1 be a shadow phenomenon?

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f' 10 WITNfdSS Mc1NTIRE:

What I believe is W

k -11 unlike most c l a a s ':; e r occurrences, where the general j

,c 12 public has very low perception of

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% 13 the efore, they are much more apt to,,and history han

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'14 shown that they will follow the c'irect ions of the

~.15 emergency manacers, ucualle via radio and televlaion t

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t 17 What. seems to have occurred on Long

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58 Inland is a public perception of the Shoreham t-situation is'very hich among the general public and, o

therefore, perp*,t woulg be con'scious of it and the g

21 word of an accidecit-6t Shoreham, for instance, that

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uould get a much hidher recognition.

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9 public, I believe have made up their own minds to a 1

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degree, much more than in other areas, about the

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lovel threat to them and what they, an individual 3

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Given that higher perception of risk, if Gi

.5 we can call it that, what is your opinion as to the 6

result) of that higher perception?

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MR. CHRISTMAN:

Objection to

'f8 c h a'r a c t e r i z a t i o n o t' hicher perception o f' risk.

9 MR. CUMMING:

Objection to the line of kl0 11 questioning on the shadow evacuati.on to the extent of

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p S,-12 the relevancy to the OL-3 proceeding.

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However, to the extent the witness hac 5

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, ? 14 knowledge, he may in fact answer the questions, l

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Y 15 knowledoe or o p i n i. o n.

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MR. CHRISTMAN:

Applicant will second

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3 17 that objection on r e l. e v a n c y.

Y WITNESS 'McINTIRE:

Can you repeat the rp 18 C,

19 question?

20 MR. McMURRAY:

Can you read it?

21 (Record Read.)

22 WITNESS McINTIGE:

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percentage of the families would be predisposed to T

taking emergency actions, in this case, evacuation, 3

than in a notmal situation.

They would not have to l

4 be convincea that there was a threat.

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In other wordsf that some people who 6

were not advised to evacuate would evacuate?

7 MR. CUMMING:

My objeotion continues and l

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the instruction holds.

The witness, to tne extent he

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has knowledge or opinion, may answer.

j 10 WITNESS McINTIRE:

Can you read it back, 11 please7 l

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12 MR.

McMURRAY: You can have a standing I

1 13 objection, M r'. Cumminc.

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14 MR.

CUMMING:

I just wanted to point out

) 13 continuina obj.tetion.

a 16 (Record Read.)

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WT.TNESS McINTIRE; I am convinced of 2

'.. 18 that.

That tends to happen in any type of emergency A

. 19 and it would p r'o b c b l y, due to the situation out i

7 20 there, occur at a higher level than normal, in my 1 21 Judoment.

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In your opinion, will the shadow

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chenomenon have an impact on the ability of the

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reception centers to perform their function?

3 WITNESS McINTIRE:

This has to be f

4 answered hypothetically because if there were en

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5 accident, obviounly, the apecific circumstances of l

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6 the accident would determine this factor.

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It could conceivably have both.

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L t her -e was word put out that there was a pr*cblem at

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9 Shoreham but there was no release, then you could t.

- it 10 have a positive benefit, I believe, by peocle y

' ~i 11 evacuating before there wea any release, getting to l

12 the reception centers and being clean.

13 However, perhaps the oppoulte would hold 1

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14 true.

If there were a sudden release and the people

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15 wer'e told to ahelber and they did not follow that i :l 15 instruction but did in fact evacuate and then became 1

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17 expo,ed.

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13 Qe Could it 'also result in a third 3

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19 possibility the--that is, people not advised to l,

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l 20 evacuate going to the reception centers to which

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21 other people have been advised to go end, therefore, 22 taking up available road capacity or capacity at the E

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receptLon c e n t e r s'?

t WITNESS McINTIRE:

That could be a 2

possibility and that goes back to the other point I 3

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made about the content and the wording of the message 5

of why it is so important in my Judoment.

1 Q.

Do you have an opinion right now on the 6

7 content of the messages under the LILCO plan, whether 3

or not they will have an effect during on accident?

MR. CHRISTMAN:

I WLil o b,' e c t to this on 9

10 the same grounds as FEMA objected in a continuing 11 fashion, which is that the EPS messages have alreadr 12 been litigated and will not be rei. sed in this 13 proceeding.

MR.

McMURRAY:

This has been raised by f

14 l '5 the w i b n e a n, and I have a right to follow up.

MR.

CUMMING:

To the extent the witneon 16 17 haa on opinion he may answer, or knowledge.

WITNESS McINTIRE:

Could you read it?

18 (Record Read.)

19 WITNESS McINTIRE:

No, I don't.

20 21 C.

Another factor that you mentioned was 22 the individual giving the m e s, s c o e.

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1 WITNESS McINTIRE:

Yes.

2 0.

Can you tell me what you meen by that?

3 WITNESS McINTIRE:

In most cases, 4

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testimony by a public official that would be 6

attributed to the source for making e ciir ec t i ve to 7

evacuattt, the governor, county executivo.

8 In this c a r.,e here, the plan calls for 9

LERO to make that det t erm ina t ion, since the state end 10 local governments are not ' participating.

I think 11 there is a concern in my mind about the credibility L,ILCO spokesman giving a direction to the 12 of a 13 generai public about 'a n accident at a LILCO plant.

li Q.

I take it that your concern translates t

j 15 into a concern a b o u t: a higher poquible shadow 36 phenomenon?

17 WITNESS McINTIRE:

That: is one of the la concerns.

That is possible.

My main concern is that 19 the people might not follow the direction of a 20 privete organizational person as opposed to a public 21 official.

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to get it qlear.

Do you have any opiniona right now 1

as to how the shadow phenomenon might effect the ability of the reception centers t h em:se lve s to 3

function?

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4 MR.

CUMMING:

I believe that is asked 5

6 and answered.

To the extent the witneon han an 7

opinion he may restate, or to the extent he has i

3 k n ow l e m;e.

WITNESS McINTIRE:

I am trying to 9

10 recall.

I believe I answered that it could have 11 different effects.

12 Q.

The t.hree offecta we already discussed?

WITNES3 McINTIRE:

Right.

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14 Q.

All right.

There ia no need to go into j

j 15 it.

Mr.

McIntire, I don't know it you are 16 17 the right per son to a d d r et a n this question to but you 18 seem to be the one who is sort of involved in the 19 human behavior a r et a.

We have discussed the procedure earlier, 20 21 with Mr. Keller, under revision eloht of the plan, 20 where only the driver would be monitored when a COMPUTER AIDED TRANSCRIPTION / keyword index

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vehicle arrives, 1

e Do you have any opinions regarding 2

3 potential behavioral problems which might r e s u l, e iy 4

passengers were denied monitoring and wanted to be 5

monitcred?

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6 MR. CUMMING:

Objection to the form of i

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the question.

To the extent the witness has j

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knowledge or opinion or understands the c;ue s t i o n, ne 1

9 may answer.

1 10 WITNESS McINTIRE:

I believe it could be 11 of concerri if peopla in the car, some were mon i t:or e d 12 and some were not, I would think there would

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13 de. finitely be a reason that those not monitored i

14 should be concerned and might be apprehensive.

l 13 Q.

Do you think that that apprehennt.ii s -

16 cnu'd translate into delays in the monitoring of the 5

17 whole populatton if conflicta resulted from their 13 concerns?

lo WITNESS McINTIRE:

I suppose that's a 20 possibility.

I can't 90 further than that.

21 Q.

At this time, do you have any other 2?

oplatons regarding the shadow phenomenon an it COMPUTER AIDED TRANSCRIPTION / keyword index

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relaten to the three reception centers?

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t WITNESS McINTIRE:

No, I do not.

2 Q.

Will you offer any testimony on the 3

4 issue of whether the location of the reception 5

centers mignt increase the shadow phenomenon, or 4

6 would that be part and parcel of what we've already i

7 discussed?

s WITNESS McINTIRE:

I don't anticipate 9

any new information regarding this.

I think that, i

10 you know, what we have already testified before 11 rtJarding the Nassau Coliseu,m will probably be pretty

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-e 12 much the same testimony, 'since we are talking about

,N 13 locations basically the same distance from the EFZ li and from the plant.

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Do you have any opi.nions at this time 16 regarding the possible scope of the evacuation shadow L7 phenomenon 11' there were an accident at Ghorenam, 18 beyond the qualitative description you have already

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19 given?

20 WITNESS McINTIRE:

No, I do not.

I 21 Q.

Gentlemen, can I ask you who han primary 22 responsibility for eddressino the staffing issue that 8

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