ML20206D412

Deposition of Rj Watts.* Transcript of Rj Watts Deposition in Washington,Dc Re Emergency Planning.Related Correspondence

ML20206D412
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/12/1987
From:	Watts R RICHARD J. WATTS, INC.
To:
References
CON-#287-3044 OL-3, NUDOCS 8704130327
Download: ML20206D412 (133)

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UNITED STATES OF AMERICA 0

BRANC" NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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

Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY (Emergency Planning)

(Shoreham Nuclear Power Station, Unit 1)

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x DEPOSITION OF RICHARD J.

WATTS i

l Washington, D.

C.

Thursday, March 12, 1987 ACE-FEDERAL REPORTERS, INC.

Stenotypeikporters 444 North CapitolStreet Os Washington, D.C. 20001 (202) 347-3700 5D%

l Nationwide Coverage l

800-336-6646 8704130327 870312 PDR ADOCK 05000322

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CR30157.0 KSW/sjg UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION 2

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 4

In the Matter of:

Docket No. 50-322-OL-3 5

LONG ISLAND LIGHTING COMPANY (Emergency Planning) 6 (Shoreham Nuclear Power Station,

. Unit 1) 7 8

l DEPOSITION OF RICHARD J.

WATTS 9 >l 1

W shington, D.

C.

0 Thursday, March.12, 1987 11 Deposition of RICHARD J. WATTS, called for examina-12 tion pursuant to notice of deposition, at the law offices.of 13 Kirkpatrick and Lockhart, 1800 M Street, N.W.,

Suite.900, South 14 Lobby, at 1:40 p.m. before KATHIE S.

WELLER, a Notary Public within and for the District of Columbia, when were present on j

behalf of the respective parties:

16 l JAMES N. CHRISTMAN, ESQ.

77 MARY JO LEUGERS, ESQ.

l Hunton & Williams 18 !.

707 East Main Street

[

Richmond, Virginia 23212 19 On behalf of Long Island Lighting Company.

20 CHRIS McMURRAY, ESQ.

21 Kirkpatrick & Lockhart 1800 M Street, N.W.

Suite 900, South Lobby 22 '

Washington, D.

C.

20036 On behalf of Suffolk County.

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CONTENTS 2.

WITNESS EXAMINATION 4

i Richard J. Watts 3

i by.Mr. McMurray' 3

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EXHI B I-T S 6

l WATTS DEPOSITION NUMBER IDENTIFIED 7

Exhibit 1 41 l

8I Exhibit 2 52 9

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P. R O C,E E D,I N G S 1

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Whereupon, 3

RICHARD J.

WATTS L

4 was called as a witness and, having first been duly sworn, 5

was examined and testified as follows:

i 6

EXAMINATION 7

BY MR. MC MURRAY:

l 8

Q Will you please state your name and address?

i 9

A Richard J.

Watts.

404 Bloom Road, Fairport, New 10 York.

(}

11 Q

Where are you employed?

2

]

12 A

I'm self-employed.

I 13 Q

Where?

i 14 A

The firm is Richard J. Watts, Incorporated.

j 15 Q

What is your title?

I 16 A

I'm president.

17 Q

Where is your business located?

18 A

In Fairport, New York.

19 Q

Is that near Rochester?

20 A

Yes.

21 Q

And what is the nature of your business?

i l

22 A

I provide consulting on emergency planning, health 1

1,

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physics and radioactive waste management issues.

2 Q

How long have you been self-employed?

3 A

For approximately one year.

4 Q

I take it, Mr. Watts, that you are going to be a 5

witness testifying about LILCo's new reception centers?

6 A

Yes, that's true.

7 Q

Just so that we are all operating on the same 8

wavelengths, when I use the term " reception centers" I'm 9

talking about the three facilities located in Hicksville, 10 Bellmore and Roslyn?

()

11 A

Yes, I do.

12 Q

Have you been to those sites?

13 A

Yes, I have.

14 Q

What documents did you review in preparation for 15 the deposition?

16 A

I have looked at procedures for monitoring, and 17 these are procedures known as OPIPs, used by the LERIO.

18 Q

Do you know the numbers, 3.9.27 19 A

That's one, yes, sir.

20 Q

4.2.37 21 A

That's correct.

22 Q

Any others you can think of?

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1 A

I think I did a general review of the procedures 2

that the radiation health coordinator would be utilizing.

I-l 3

don't recall all of the numbers right now.

4 Q

Are the two we have mentioned the ones you have I

5 primarily reviewed?

{

6 A

Those were included among all'of the procedures 7

that I looked at, yes.

8 Q

Did you review also portions of the LILCO plan i

j l

9 other than the procedures?

j 10 A

Yes, I did.

1 ()

11 Q

Which portions were those?

12 A

The portions having to do with monitoring and 13 decontamination of the general public.

14 Q

Did you review appendix A of the plan at all?

i 15 A

I don't recall if it was appendix A.

f i

i 16 Q

That's the part of the plan that generally deals j

r 17 with traffic matters.

Did you review that?

l 18 A

I'm not sure that I did.

19 Q

Did you review OPIP 3.6.1 regarding plume exposure i

20 pathway protection recommendations?

21 A

I believe I did.

22 Q

For any particular purpose or just for general I

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1 knowledge?

2 A

Just general knowledge.

3 Q

What other documents did you review?

4 A

I have looked at information on types of 5

instrumentation, commercially available, for performing 6

monitoring.

I have looked at notes that I have had generally 7

about monitoring and decontamination.

8 Q

Not necessarily specific to the Shoreham reception 9

centers, but --

10 A

Not necessarily specific, that's correct.

I have

()

11 looked at general plans and procedures used for that type of 12 operation.

13 Q

Anything else you can think of?

Let me see if I 14 can jog your memory.

Did you review any of your time trials 15 for monitoring?

16 A

Yes.

Correct.

17 Q

Anything else?

18 (Discussion off the record.)

19 BY MR. MC MURRAY:

20 Q

I think we were discussing any documents you may 21 have reviewed.

22 A

I believe I reviewed a portion of the New York Ace FEDERAL REPORTERS, INC.

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State plan that addressed monitoring and decontamination 2

methods.

I believe I looked at a state procedure on 3

monitoring and decontamination, and I looked at a couple of 4

county plans also on how that process was done.

S Q

Where were those counties?

6 A

One was Monroe and one was Wayne County.

7 Q

Both in New York?

8 A

Yes.

9 Q

Any other documents you can think of?

10 A

No, I think I have covered what I described to f)

11 you.

v 12 Q

Have you reviewed any correspondence between you 13 and anyone at LILCO or LERIO regarding the reception centers?

14 A

Between -- would you repeat that again?

15 Q

You and anyone at LILCO or LERIO?

You understand 16 the term LERIO, right?

17 A

Yes, I do.

18 Q

Or LERIO.

I will include that as well.

Have you 19 reviewed any correspondence between you and those 20 organizations or anybody at those organizations?

21 A

I think to the extent that I described it in my 22 items that I gave you.

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Q Did you bring any documents with you today?

i 2

A No.

3 Q

Do you have a copy of the plan at all, or the 4

procedure?

5 A

Not with me, no.

6 Q

Have you prepared any testimony yet?

4 7

A No, I haven't.

8 Q

Now, let me just establish the issues that you are 9

going to be testifying on, Mr. Watts.

In answers that we got 10 to interrogatories, it says that you are expected to testify

()

11 on LILCO's plans to monitor and, if necessary, decontaminate 12 membere of the public at the reception centers; is that j

13 correct?

4 l

14 A

That's correct.

15 Q

And you also will be testifying about the

)

16 containment of wash water from the decontamination process?

]

17 A

To the extent that relates to radiological 18 concerns, yes, I believe so.

I 19 Q

Have you been informed that you might be i

20 testifying about the containment of waste water?

21 A

I would like to consult with my counsel on that.

22 (Discussion off the record.)

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THE WITNESS:

I guess in terms of my answer, 2

concerning radiological aspects of the collection of that 3

waste water, yes, I would be addressing questions in that 4

area.

I would not expect to be addressing questions on 5

physical capacities and dimensions of the collection devices 6

and so forth.

7 BY MR. MC MURRAY:

8 Q

Do you know which member of the LILCO panel would 9

be addressing the physical capabilities of the storage tanks?

10 A

I am not entirely sure.

I am assuming it would be

(}

11 Mr. Daverlo.

12 Q

And you will also discuss the procedures, 13 equipment and staffing for monitoring and decontamination; is 14 that correct?

15 A

As it relates to radiological monitoring and 16 decontamination, yes.

17 Q

And you will be discussing LILCO's proposal to 18 transport evacuees traveling on buses to the Hicksville 19 facility and whether that procedure is workable?

Will you be 20 addressing that?

21 A

Could you define what you mean by " workable"?

22 Q

Well, I'm using a term that apparently was used by ACE-FEDERAL REPORTERS, INC.

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1 your attorneys.

Do you understand the term " workable"?

2 A

I'm not sure what you mean by " workable."

3 Q

Okay, well, let me ask you what the word 4

" workable" means to you and we can try to build on that.

5 A

I think I can best address that by saying if we're 6

talking about workable in terms of the monitoring and 7

radiological aspects, I expect I would be addressing those.

8 The other transportation aspects, I would guess that would be 9

someone else on the panel who would address that.

10 Q

Is it your understanding that people without

()

11 vehicles who are evacuated will be taken to one of the 12 reception centers?

13 A

Would you repeat that?

14 Q

Is it your understanding that in the event of an 15 evacuation of the EPZ, people without vehicles will be taken 16 to one of the reception centers?

17 A

Yes.

18 Q

Do you know which reception center that is?

19 A

The Hicksville reception center.

20 Q

Now, in what respect will you be addressing the 21 proposal to transport evacuees traveling on buses to the 22 Hicksville facility?

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1 A

In terms of what is done once they arrive at the 2

Hicksville facility for monitoring or decontamination.

3 Q

Will you be addressing whether the LILCO proposal 4

as set out in the LILCO plan to send evacuees to LILCO 5

parking lots for monitoring and, if necessary, 6

decontamination, would be implemented so as to protect the 7

public health and safety?

8 A

Yes.

9 Q

Mr. Watts, could you describe for me briefly how 10 the monitoring of the evacuees from the EPZ -- strike that.

(}

Could you describe for me how you understand the 11 12 monitoring procedures will be carried out at the various 13 reception centers?

14 A

Once a car carrying members of the general public 15 arrives at the reception center, the car will be directed to 16 one of many monitoring posts where there will be a team of 17 two radiation monitors and one traffic guide.

Monitoring 18 will be performed of all evacuees in the vehicle by those 19 radiation monitoring personnel, and each evacuee will remain 20 in the car and have his or her feet, hands, shoulder and head 21 monitored, and at the same time, the car exterior will be 22 monitored as well, using a swipe method on the hood and wheel Acit-FEDERAL. RiteoRn:Rs, INC.

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1 well.

2 Q

Is it the traffic guide who takes that swipe?

3 A

It is my understanding it is one of the monitors 4

who will take that swipe.

The traffic guide will be 5

recording information and providing information.

I might 6

also add that the logic is that if there's any indication of 7

contamination either on the exterior of the car or on any of 8

the passengers in the car, that car and passengers will be 9

directed to another portion of the reception center where 10 more detailed monitoring will be performed and

()

11 decontamination if necessary, so it is -- the logic is if 12 there's contamionation on the car or any of the passengers, 13 then everyone in that car will go for more detailed 14 monitoring and the car will be monitored as well.

15 Q

The procedures that you just described are the 16 procedures that are set out in what we have been calling the 17 February 20 draft of the LILCO plan.

Is that your 18 understanding?

19 A

That's my understanding, yes.

20 Q

Revision 8, which was the version before that, was 21 somewhat different, correct?

22 A

Yes.

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1 Q

And how was it different?

i j

2 A

To the best of my recollection, I believe we had 3

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3

-- I know what the intent of the revision was, that the car i

j 4

would pull up in a similar fashion, the driver would be j

j 5

monitored, my inclination was that the question would be I

j 6

asked by one of the members of the monitoring team whether i

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7 all members of that vehicle were coming from the same area.

i i

8 If the answer was no, then that additional person would be i

9 monitored as well, and in addition, if anyone else had a l

10 concern that they wanted to be monitored, they would be i

11 monitored as well.

The exterior of the car, in a similar 12 fashion to the current draft procedure, was going to be done I

j 13 using the swipe method.

i 14 Q

So in your mind, is the primary difference between 4

i 1

15 revision 8 and the February 20 draft the fact that all of the i

16 occupants of the vehicle will be monitored?

[

17 A

Yes.

I 18 Q

Mr. Watts, let's put aside the February 20 draft l

t f

19 for a second and look at revision 8.

Did you have any role 1

j 20 in developing revision 8 insofar as it deals with the t

)

21 reception centers, monitoring or decontamination?

i 22 A

I had some input into discussions that occurred O

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regarding the type of monitoring method to be used, yes.

2 Q

Could you describe that input for me, please?

3 A

I had input as to the reasonableness of the 4

method, the type of instrumentation to be used, and the j

5 general way in which the method would be conducted.

6 Q

I think when you were deposed about the end of I

7 last year, you stated in your deposition -- and I can show i

8 you the deposition, but let me see if you recall this -- I 9

believe you stated that you were asked to look at various 10 procedures for the new facility that might be used at the new

(}

11 facilities.

Do you recall saying that?

12 A

Yes.

13 Q

What were the various procedures that you 14 reviewed?

15 MS. LEUGERS:

I would like to instruct the witness 16 to answer that question only if he is able to recollect your 17 exact words at that time.

Otherwise, I would like to request 18 that he see his deposition if you are asking him to respond 19 to what he said at that time.

i 20 MR. MC MURRAY:

No, I'm asking him what the 21 various procedures were that he reviewed.

22 I'm going to show the witness a copy of a document C:)

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which states on the front it is the deposition of Richard J.

2 Watts taken December 3, 1986.

I will refer you to page 109, 3

where you answer a question that was actually asked on page 4

108.

I would just have you look at that.

I am referring to 5

the paragraph that begins on line 3 and goes down through 6

line 8.

1 7

THE WITNESS:

Yes.

8 BY MR. MC MURRAY:

9 Q

So you do now recall stating that you were asked 10 to look at the availability of various monitoring methods

(}

11 that could be utilized at various facilities?

12 A

What I said was the various monitoring methods and 13 the equipment that was available from different vendors, and 14 I did that, yes.

15 Q

Let's just look at the methods and set aside the 16 equipment for a second.

17 What were the methods that you looked at?

18 A

I looked at a variety of different techniques that 19 could be used.

I looked at what was said in the New York 20 State plan, what was used by other counties in their plans, 21 different strategies for doing either a partial scan of a 22 person or a complete scan of a person, and I found that a Ace FEDERAL. REPORTERS, INC.

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1 variety of different approaches were being used throughout 2

the industry.

As far as equipment is concerned, I discovered 3

that in practice, the same type of -- the same basic type of 4

instrumentation seems to be used at other facilities, a 5

Geiger counter basically.

6 Q

Prior to the issuance of revision 8, back when the 7

reception center was the Nassau Coliseum, evacuees got out of 8

their cars and were monitored inside the Nassau Coliseum, 9

correct?

10 A

That was one approach, yes.

()

11 Q

And their whole body was monitored, correct?

12 A

For the Coliseum, that's correct.

We had a 13 supplementary method as well, an expedited method that was 14 also provided for in the procedure.

15 Q

And the expedited procedure was what?

16 A

That was basically a driver-only monitoring 17 approach where we were checking the driver and the exterior 18 of the car.

19 Q

Under what conditions would the expedited 20 procedure be used, if you recall?

21 A

If it was felt that significantly more than, I 22 think -- if a significant number of additional evacuees OV ace-FEDERAL REPORTERS, INC.

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1 should arrive at the reception center than originally 2

provided for.

3 Q

What was originally provided for under the plan 4

then?

5 A

I believe it was something on the order of 20 6

percent of the EPZ population.

7 Q

Why was it necessary to consider a different 8

procedure for the three new reception centers than the one 9

that was used at the Nassau Coliseum?

10 A

I'm not real sure what you mean by "different."

I 1

(}

think we were using basically the same kinds of equipment and 11 12 the same basic techniques.

13 Q

Well, at.the Nassau Coliseum, the primary 14 procedure was to give the individuals -- number one, the 15 evacuees would enter the Nassau Coliseum, correct?

16 A

Yes, if it was less than the 20 percent.

17 Q

And then they would be given a scan of basically J18 their whole bodies, correct?

19 A

Yes.

20 Q

And they would be given a thyroid scan too, 21 correct?

I 22 A

Yes.

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1 Q

And under rev. 8 of the plan, the procedure was i

2 that sust the driver would be monitored and the monitoring 3

would be done in the cars, correct?

4 A

Well, no, not exactly.

I think what I mentioned 5

before is the driver would be monitored and the additional 6

ques' tion asked whether other people in that car were from the 7

same location or not from the same location.

If there was I

8 any doubt, they would monitor more than just the driver.

9 Q

Nevertheless, there's a distinction now between 10 the procedures used at the Nassau Coliseum and those used in

()

11 rev. 8, correct?

12 A

I'm not sure I would draw a real clear 13 distinction.

It is a variation on the same basic types of 14 methods, same basic types of equipment.

15 Q

Why was it decided that a whole body scan would 16 not be given to the individual being monitored in rev. 8, 17 whereas that was done in Nassau Coliseum?

i 18 A

I think in terms of -- we felt that there are a 19 number *ct diff rent approaches to it, and one way in'which we 20 could keep the traffic pattern flowing fairly smoothly was to 21 do that type of monitoring in the car, which I felt, anyway, 22 was equivalent and perfectly suitable for doing a checking of ACE-FEDERAL REPORTERS, INC.

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the public.

2 Q

So the reason that the scope of the monitoring was 3

changed from whole body to, at that time, hands and feet of 4

the driver was because of considerations of smooth traffic 5

flow through the sites?

Is that your testimony?

6 A

Well, that was the initial monitoring phase that 7

was going to be done, which as I mentioned before, if there 8

was any indication of contamination on the car or driver, 9

more_ detailed monitoring dould be done.

10 Q

Did you have any discussions with anyone at LILCO 11 or LERIO as to whether or not it would be appropriate to do a 12 whole body scan at the three new reception centers?

13 A

There are a lot of different definitions of what 14 "whole body scan" means.

I will give you one example --

15 Q

Let me define'it as the type of scan that was done 16 at the Nassau Coliseum.

Using that definition, was there any 17 discussion with anyone whether that type of scanning method 18 should be used at the three new facilities?

19 A

It was recommended to do that, as I mentioned, if 20 there was any indication on the initial monitoring phase that 21 there was contamination on anybody in the car or on the car 22 itself; so we wanted to maintain consistency as far as the Os V

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basic operation that would have to be done.

If there was any 2

detection of contamination then we would do the full body 3

scan, thyroid monitoring and decontamination.

So we did keep 4

consistency with that part.

We felt that was appropriate.

5 Q

Did you have any discussions with anyone regarding 6

whether or not the same type of scanning that was done at the 7

Nassau Coliseum should be done at the new reception centers?

8 A

I think I just answered that.

9 Q

I'm asking whether you had any discussions?

10 A

Yes.

()

11 Q

With whom?

12 A

With the planning people in the LERIO group.

13 Q

And those are --

14 A

Mr. Crocker, Mr. Aidikoff, Mrs. Dreikorn, 15 Mr. Daverio.

16 Q

The goal, at least, for monitoring at the Nassau 17 Coliseum was that monitoring for each individual to be 18 completed within 90 seconds; is that correct?

19 A

I believe that's correct, yes.

20 Q

Were there any discussions that you had with 21 anyone to the effect that if that same procedure was used at 22 the new reception centers, that the flow of traffic through ACE-FEDERAL REPORTERS, INC.

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1 the reception centers would be slowed?

2 A

That wasn't my primary concern.

I think traffic 3

flow was a general concern, but I was asked to propose a 4

method that I thought was appropriate for protecting people, 5

and that was workable and equivalent to what is done 6

elsewhere.

7 Q

Were you asked to propose a method that would be 8

faster than the procedure used at the Nassau Coliseum?

9 A

If I felt it was defensible, yes.

10 Q

And who asked you to propose a new procedure along

()

11 those lines?

12 A

Again, the LERIO people who I referred to before.

13 Q

And did they tell you why they thought a faster 14 procedure was necessary or desirable?

15 A

Just basically in the context of NUREG-0654 16 requirements, the 12-hour monitoring criterion.

17 Q

Could you.reelaborate on that a little bit more, 18 please?

19 A

I'm not sure what you want me to say.

20 Q

My question is whether anyone discussed with you 21 why it was necessary or desirable to come up with a faster 22 procedure.

Now you have mentioned there's a time constraint, i

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1 NUREG-0654.

Was the concern expressed to you that without a 2

faster procedure LILCO could not meet the requirements of 3

NUREG-0654?

4 A

What you are referring to was not a new idea at 5

all.

In fact, we had addressed that for the Coliseum with 6

the expedited approach that I referred to.

I think the 7

context of the discussion was can we take that particular 8

type of approach and apply it to the new reception centers, 9

do we suffer at all in terms of not providing sufficient 10 monitoring capability.

()

11 Q

But you will agree with me, won't you, that the 12 procedure used in rev. 8, that is monitoring the driver, the 13 hands and feet of the driver, was the backup procedure at the 14 Nassau Coliseum, but became the primary procedure for the 15 three new facilities?

16 A

As far as rev. 8 is concerned, the general type of 17 approach that you refer to was in there, yes.

However, I 18 also mentioned that there were additional questions and 19

' qualifications added to that, and because of that I felt it 20 was defensible.

21 Q

With that understanding, that was the backup 22 procedure at Nassau Coliseum, correct?

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A Yes.

4 2

Q And it became the primary procedure for the three 3

new facilities, correct?

4 A

Yes, with those distinctions that I just made.

5 Q

Those additional questions asked of the occupants 6

were not going to be asked at the Nassau Coliseum?

7 A

I'm not sure.

I don't remember.

8 Q

Were you involved at all in the preparation of the 9

February 20 draft revisions?

10 A

I was asked to review the draft before it was

{}

11 released.

12 Q

Who prepared those revisions, do you know, with 13 respect to monitoring and decontamination?

14 A

Members of the LERIO staff.

15 Q

Anyone in particular responsible for the areas of 16 monitoring and decontamination?

17 A

I'm not sure I can answer your question 18 specifically.

I know there were two or three people who were 19 actually doing the writing, and I'm not sure which person 20 actually did-the writing.

21 Q

Why don't you then tell me who the two or three 22 people are.

()

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1 A

Mr. Aidikoff, Mrs. Dreikorn and Mr. Sobotka.

2 Q

And these February 20th procedures, I think we've 3

established, differ from revision 8 primarily in that all of 4

the occupants of the vehicle are monitored; is that correct?

5 A

Yes.

6 Q

That's true only up to a certain number of people 7

coming to the reception centers, correct?

8 A

Yes, I believe so.

9 Q

At some threshold point, isn't it true that the 10 procedures revert back to the driver-only procedure?

()

11 A

Well, not directly, no.

There's another 12 contingency provided for, and that is to get more people to 13 the reception centers to assist in performing monitoring of 14 everyone.

15 Q

Why don't you give me your understanding of what 16 happens as more people come to the reception centers 17 regarding the procedures that are used?

18 A

My understanding is, as more people arrive, such 19 as personnel from INPO, that they would be directed to form 20 additional monitoring teams and proceed with the monitoring 21 of incoming personnel and vehicles.

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process INFO is contacted and asked to provide more monitors?

2 A

I can't tell you the specific point, other than if 3

there's a recognition -- my understanding is if there's a 4

recognition that we're expecting significantly more than 20 5

percent of the EPZ coming to the reception centers, that we 6

would probably put INPO on notice that we would need 7

additional help.

I think with the equipment and the staff we 8

probably have we can probably handle about 30 percent with 9

that first method that I described; so if it looked like we 10 were going to go well beyond that then we would certainly

{}

11 call INPO.

12 We would probably draw upon the resources of the 13 federal government and anyone else from the private sector 14 that could help in this thing.

If it then looked like we 15 still needed additional capability, we could revert to the 16 expedited approach, but we would request help early on if it 17 looked like we were going to go well beyond 20 percent.

18 Q

Are you aware of how promptly INPO is able to 19 provide additional monitors for reception centers?

20 A

I have some information in that regard from the 21 exercise that we did back in January of

'86.

22 Q

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that was the estimate of time, wasn't it, for INPO to 2

respond?

3 A

I think within six or seven hours we would have 4

had somewhere around 100 people from INFO, and another 5

hundred I know were on their way that would have been in 6

after that; so there were a lot of people coming from INPO, 7

and I was actually delighted by the response and the 8

timeliness.

9 Q

Now, at some point in the emergency, I take it 10 that if there's a decision made that even with the INPO

()

11 personnel, additional INFO personnel, the original procedures 12 will not be able to monitor all incoming evacuees, then you 13 revert back to the procedure used in rev. 8; is that correct?

14 A

Yes.

15 Q

What's the trigger point for reverting back to the 16 original revision 8 procedures?

17 A

I can't give you a specific trigger point.

That's 18 something we would be discussing back at the LERIO emergency 19 operation center and we would be doing an assessment of the 20 advisability of doing that, and I know that would be in the 21 exercises and the drills that we have.

There's' constant 22 discussion among the director, manager, radiation health

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coordinator, health services coordinator, decontamination 2

coordinator about that.

I think that would be a decision 3

that would weigh all the factors available at the time.

It 4

seems to me that that's a good three-tiered approach and it 5

is consistent with what I have seen in FEMA where you do 6

detailed planning to 20 percent of the EPZ and you can 7

provide the rest on an ad hoc basis.

I think we're going 8

well beyond that and I don't think it is ad hoc.

I think 9

we're providing more detail than is really being asked for.

10 Q

I believe you said a little earlier that there are

{}

11 a variety of different approaches used throughout the 12 industry.

Do you recall saying that?

13 A

There are different approaches, but the equipment 14 is basically the same.

15 Q

With respect to the approaches, when you said the 16

" industry," what were you referring to?

17 A

I'm referring to the emergency planning response 18 people in the industry, whether it be utilities or off-site 19 agencies.

20 Q

Okay, and do you intend to testify that the 21 procedures used at the three reception centers under the 22 current plan are similar to other plans?

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A They are comparable, yes.

2 Q

In what way?

3 A

In terms of determining the presence of 4

contamination, and with that the logic in providing for more 5

extensive monitoring and decontamination should the initial 6

monitoring indicate any problem.

7 Q

Are you saying that it is common practice to 8

conduct less than the type of whole body scan that was done 9

at the Nassau Coliseum?

10 A

As I mentioned before, there are different

()

11 variations of doing whole body scans.

12 Q

What are some of the variations?

13 A

As an example, a state procedure, the Division of 14 Military Naval Affairs, refers to monitoring the periphery of 15 a person who is standing upright at a speed that is about 30 16 percent faster than the speed that we use for monitoring.

17 That is considered, quote, "whole body," but it is really 18 looking at the periphery of the person and focusing on the 19 head, shoulders, hands and feet.

I have noticed the same 20 type of language in some other county implementing procedures 21 where the language has been transferred from the state plan.

22 I have talked to other people and some equipment

(./

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(-)

1 vendors.

One equipment vendor told me that he was aware of 2

one agency out of state that was using an X pattern approach 3

on people, where they crisscross the person, the front and 4

back of a person within about 40 seconds using a sodium 5

iodide probe, and again that was being considered.

That's 6

called whole body, but I think it depends on how you define 7

"whole body."

8 Q

Is it a common approach to monitor individuals 9

within their vehicles?

10 A

No, I don't think so.

It is a common approach to

(~'}

11 focus on the head, hands, feet, shoulders.

s_-

12 Q

When you say " concentrate," does that mean 13 scanning the other parts of the body, but doing the hands, 14 feet, head and shoulders more carefully, or ignore the other 15 parts of the body?

16 A

As I mentioned before in the procedure I referred 17 to, the state procedure, where they looked at the periphery 18 of the body and focusing on those particular areas at one 19 foot per second.

20 Q

So they were not ignoring other parts of the body, 21 they were just focusing --

22 A

It would seem to me, based on the literal reading rNU l

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of that procedure, that there are parts of the body that are 2

not looked at directly.

3 Q

And based on this review, then, it is your 4

judgment that doing less than the type of scan that was done 5

at the Nassau Coliseum was appropriate?

6 A

Partially based on that review, and just partially 7

based on common sense.

8 Q

Give me the common sense.

It is not always 9

apparent to the layman.

10 A

The common sense is when we were thinking about

()

11 the areas of the body that are most likely to be i

12 contaminated, we have people walking through contamination or 13 touching contaminated surfaces with their hands or if they 14 are standing outdoors and there's a plume overhead, most 15 likely they would have deposition on the top part of their 16 body, the head and shoulders, and so in even thinking about 17 it, separately from the review, I think that in our 18 discussions at LERIO we concluded that those areas were by 19 far the most likely areas of the body to be contaminated and 20 would be the best indicators, and by looking at some other 21 procedures, we noticed that other people had apparently come 22 to the same conclusion.

4

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Q Are you aware of any health physics texts which 2

support the approach that you recommended for monitoring at 3

the reception centers?

4 A

The exact approach?

No.

5 Q

Well, just look at it, not-in a literal sense but 6

in the sense that less than the type of scan done at the 7

Nassau Coliseum would be appropriate and adequate.

8 A

I'm not sure I know what you mean, f

9 Q

Okay, I take it with your health physics 10 background, you are aware of the literature out there in the 11 field.

i 12 A

Yes.

j 13 Q

Is there literature out there in the field 14 regarding monitoring techniques to be used other than in a 15 nuclear accident or -- well, let's confine it to a nuclear 16 accident.

Is that a yes?

i 17 A

The techniques that I have referred to-are in the 18 literature.

The use of the frisking probe and so forth.

19 This is an application of those techniques that are 20 available.

21 Q

Can you point to any texts which provide in 22 substance that it is okay to monitor people in their cars?

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A Not here today, no, I can't.

2 Q

Do you recall any literature at all that addresses 3

that issue?

4 A

Monitoring people in the cars?

5 Q

Whether it can be done effectively in their cars.

6 A

Yes.

7 Q

What's that?

8 A

A paper that was done by the State of California, 9

provided by someone from the State of California, using a 10 completely different type of instrument.

()

11 Q

All right, what was the conclusion drawn in that 12 paper?

13 A

Just a general statement, this is what they do in 14 the State of California.

15 Q

What is what they do?

16 A

They have an instrument set up by the side of the 4

17 road, I believe at a weigh station, and vehicles as they pass 18 by this particular probe can be monitored as they drive by at 19 speeds up to 15 miles per hour.

20 Q

Is this for use in nuclear emergencies?

21 A

Yes.

My understanding is that it is used for 22 nuclear emergencies.

It was primarily put forth to also ACE FEDERAL REPORTERS, INC.

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survey waste trucks, but the context of the comment, I 2

believe, was nuclear emergencies.

We took a look at that in 3

detail and determined that we felt that it would be better to 4

do a more hands-on approach of people in the car.

We saw the 5

precedent being presented, but we felt that a more manually 6

intensive monitoring of personnel in the car would be better.

7 Q

Did the California approach actually provide 8

information about whether people inside the car might be 9

contaminated, or only whether the car itself was 10 contaminated?

(~

11 A

I think it implied that it could check both at V}

12 once.

13 Q

Do you have a copy of that paper?

14 A

I don't have it with me, no.

15 Q

Do you have it in your possession or control 16 somewhere else?

17 A

I think it is accessible.

18 Q

Do you know the title of the paper?

19 A

No, I don't remember.

20 Q

Do you know its author?

21 A

I don't remember the name.

22 Q

Who would it be accessible through?

1 l

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A I believe one of the LERIO staff.

2 Q

Do you intend to rely on that paper in any way in i

3 giving your testimony on this issue?

4 A

I wasn't intending to, no.

5 Q

Are you aware of any texts or other literature 6

which would not support the approach now taken under the 7

LILCO plan as far as monitoring procedures go?

8 A

No, I'm not aware.

]

9 Q

I take it that it is your opinion that it is 10 adequate to monitor the head, hands, feet and shoulders, and

()

11 not necessarily monitor the rest of the body because those 12 are the areas most likely to catch deposition?

13 A

Yes.

We're talking about people, but I also-mentioned that we do a good, effective monitoring of the 14 i

15 vehicle also, which is another indication of any deposited i

16 material.

And again, to reemphasize, for the initial 17 monitoring we're looking at the occupants of the car as well 18 as the exterior of the car, and if there's any indication or 19 any doubt whatsoever, the monitors are directed to send 20 people in for more detailed monitoring and possible 21 decontamination if necessary.

i 22 Q

But it is possible, isn't it, that people could be 1

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i i

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30148.1 KSW 35 1

contaminated on areas other than their head, shoulders, feet 2

and hands?

3 A

Other than?

4 Q

Other than.

5 A

In addition to, possibly.

6 Q

You don't think they could be contaminated on 7

areas other than to the exclusion --

8 A

No, not with the total absence of contamination on 9

the other areas.

I have a hard time following the reasoning, 10 and with a total absence of contamination on the car, I just 11 have a very hard time conceiving of that.

12 Q

Well, people can be contaminated by methods other 13 than just deposition from the atmosphere, right?

14 A

What do you mean?

15 Q

Well, they might -- a part of the body might come 16 in contact with something that's been contaminated, correct?

17 A

But that's from deposition.

18 Q

Well, how do you define deposition?

Maybe it is 19 just a problem in terms.

20 A

Well, how did you mean it?

I think I know what it 21

means, 4

22 Q

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you.

Then we can go back and do this over again.

2 A

Deposition is the radioactive material from a 3

plume that has settled on some surface'.

Is that what you 4

meant?

5 Q

No.

I was talking about the process of it falling 6

from -- at least that's what I thought you were talking about 7

-- is it falling out of the atmosphere.

8 It is your opinion, then, that parts of the body 9

other than the head, hands, feet and shoulders could not 10 become contaminated without contaminating those specific

()

11 parts of the body that -- the head, hands, feet and 12 shoulders?

13 A

That's correct, and in addition I cannot see how 14 the car could be excluded from that as well.

That's why 15 we're looking at the car as well as those areas on the 16 people.

17 Q

Well, for instance, people could be contaminated 18 before they get into their cars, right?

19 A

Possibly, yes.

20 Q

And it could be that they might be in a 21 contaminated area before they reached their cars and 22 therefore the car might not be contaminated; is that correct?

)

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A I have a hard time with that hypothesis.

2 Q

Is it your opinion that if an individual-is s

3 contaminated.that his car would necessarily show 4

contamination?

5 A

Say that again, please.

6 Q

If an individual is contaminated, then his car 7

woulc necessarily show contamination?

8 A

I think it is pretty likely.

9 Q

What's the basis for that opinion?

1 10 A

That the individual is going to be in an area 11 where there's contamination, that the car either is parked in

[

12 already or will drive through.

13

.(Discussion off the record.)

14 MR. MC MURRAY:

Back on the record.

15 BY MR. MC MURRAY:

[

16 Q

Mr. Watts, is it your understanding that under 17 neither revision 8 or the February 20 revisions, draft 18 revisions, that a thyroid scan was to be performed of the 19 arriving evacuees?

20 A

That's correct.

Only the thyroid scan was going 21 to be done if there was evidence of contamination, and the i

22 people then went for the detailed monitoring to first insure ACE-FEDERAL REPORTERS, INC.

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30148.1 KSW-38 1

that if there was contamination it was removed before a good 2

thyroid measurement could be taken, and so the thyroid 3

measurement would be taken as a second phase.

4 Q

In your opinion, is it possible that someone could 5

suffer thyroid contamination without'having contamination on 6

the outside of their bodies?

7 A

No, I think the logic that we're using here is 8

that we would likely see contamination, evidence of 9

contamination before we would have any problem with the 10 thyroid receiving a dose.

()

11 Q

So in your opinion, it is not possible to have a 12 thyroid contamination in the absence of some other 13 contamination on the outside of the body?

14 A

I think it is pretty.unlikely that you would have 15 a total absence of contamination yet have a significant dose 16 to the thyroid.

My understanding in looking at other 17 approaches used by other emergency planning organizations, I 18 have not really found anyone who is doing thyroid monitoring, 19 at least I'm not aware of anyone else.

We felt that it would i

20 be an appropriate follow-up method to do.

21 Q

What's your basis for your opinion that it is 22 unlikely to have thyroid contamination without some c:)

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contamination on the outside of the body?

i 2

A The fact that we.would' expect iodine, if it.was 3

released, to be released in gaseous and/or particulate form 4

and even -- my-understanding on the behavicr of iodine is 5

even if it is in gaseous form, some of that can attach itself 6

to other particles in the atmosphere, so we have a 7

combination of particulate iodine, particulate form of iodine 8

and iodine that is chemically reactive and would attach 9

itself to other particulates in the atmosphere, and our 3

10 indicator is to look at contamination on the person,.first'

{}

11 make sure that there's no other evidence of contamination 12 before a good legitimate thyroid scan can be done.

We just 13 thought that that was an appropriate method.

Again, we were 14 not told to do that.

We were -- it has been in the plan one 15 way or another for some time.now.

16 Q

Let me just try to clear up a bit of confusion 17 that maybe you can help me with, maybe you can't.

18 Let me show you a diagram which I believe is part 19 of rev.

8.

Although it says rev. 6 in the lower right-hand 20 corner, it apparently survived rev. 8, and it does show a 21 thyroid scan being conducted.

1 22 A

What is this?

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1 Q

I'm sorry, this is OPIP 3.9.2.

It says up in the 2

upper.right-hand corner that it is.

3 A

But it is rev. 6?

4 Q

Well, as you know, rev. 8 may contain pages from 5

many revisions, from rev. 1 up to rev. 8.

It is my 6

understanding that this page survived the revision process.

7 MS. LEUGERS:

For the record, I would indicate it 8

is page 25 of 49, attachment 3 which I guess is page 2 of 9

4234 attachment 3.

10 BY MR. MC MURRAY:

()

11 Q

Assuming that's part of rev. 8, is that just a 12 mistake?

13 A

I'm not sure if it is a mistake.

I think if it is 14 looked at as cart of the detailed monitoring and 15 decontamination procedure, then that is still being done.

16 That's the follow-up measure that is taken after the initial 17 monitoring is done, so I can't answer your question with 18 certainty, but my understanding is the thyroid scan is done 19 as part of the detailed monitoring and decontamination 20 process, not as part of the initial.

21 Q

And the detailed process is gone into only if 22 there's an initial indication of contamination, correct?

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1 A

Yes, on the people and the car.

2 Q

Currently, the estimate for the time necessary to 3

monitor a vehicle and its occapants is about 100 seconds; is 4

that correct?

5 A

I believe we have'that in the plan at this' point, i

6 yes.

7 Q

And is it your understanding that that time was 8

the basis for the estimate that under the current procedures 9

LILCO could monitor 30 percent or so of the EPZ population?

10 A

I believe so, yes.

(}

11 Q

Now, the basis for that 100 second figure is some 12 time trials that you were involved in; is that correct?

3

]

13 A

The hundred second?

Yes.

14 Q

When you asked if it was the hundred second, are 15 you aware of any other guideline right now?

16 A

No.

i 17 MR. MC MURRAY:

Will you identify this as Watts

)

18 Exhibit I?

I 19 (Watts Exhibit 1 identified.)

i 20 BY MR. MC MURRAY:

I.

21 Q

Mr. Watts, let me show you now a document that's i

22 been marked as Watts Exhibit Number 1.

It seems to be a i

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30148.1 KSW 42 1

memorandum from you to D.

Crocker dated January 5, 1987.

Do 2

you see that?

3 A

Yes, I do.

4 Q

The subject is " Summary of time trials for vehicle 5

occupant monitoring."

Do you see that?

6 A

Yes, I do.

7 Q

Have you seen this document before?

8 A

Yes.

9 Q

You prepared it, correct?

10 A

Yes, I did.

()

11 Q

Can you tell me briefly what this document 12 represents?

4 13 A

As it states in the introduction, it summarizes 14 the time measurements that were performed to determine how i

15 long it would require to monitor all vehicle occupants, 16 considering different vehicle designs.

1 17 Q

Why were the time trials reflected in this i.

)

18 document conducted?

i 19 A

To arrive at a realistic time estimate for 20 performing those types of measurements, recognizing that we 21 would be encountering different types of vehicles.

We wanted i

22 to do our homework.

j j

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Q Can you tell me who was involved in conducting i

2 these time trials?

3 A

Myself and other members of the LERIO staff.

i-4 Q

Who is that?

5 A

The other members?

6 Q

Yes.

7 A

Present that day?

8 Q

Involved in this time trial.

9 A

Okay, Mr. Sobotka, Mrs. Dreikorn, Mr. Aidikoff, 10 and I believe another person was there that day.

I believe

(}

11 Mr. Moss was there that day.

12 Q

Who is Mr. Moss?

13 A

Mr. Moss is a consultant who provides training and 14 other emergency planning assistance to LERIO.

15 Q

Who actually performed the monitoring for these 16 time trials?

17 A

I believe Mrs. Dreikorn, Mr. Moss, I believe they l

18 were the two that did it.

19 Q

Are either Mrs. Dreikorn or Mr. Moss designated to 20 be monitors in the event of an accident at Shoreham?

I 21 A

No, but they are instructors that teach the 22 radiation monitoring people the methods.

i l

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Q So none of the actual LERIO monitors were involved 2

in this particular time trial?

3 A

Not this particular one, no.

4 Q

Was the time trial conducted at one of_the three 5

reception centers?

6 A

No, it was not.

7 Q

Where was it conducted?

8 A

It was conducted at the LILCO training center in 9

central -- Hauppauge.

I'm sorry.

10 Q

How were the various cars -- strike that.

()

11 The memorandum shows that the trials involved a 12 Chrysler LeBaron, a Subaru four-wheel drive and a Dodge 13 Caravan; is that correct?

14 A

Yes.

15 Q

How were those three vehicles chosen?

16 A

Well, that was my recommendation to get at least a 17 sampling of different styles of vehicles that happened to be,.

18 available at that facility that day.

We thought that that 19 provided a pretty good initial range of the kinds of vehicles 20 that the monitoring people might be encountering.

21 Q

Can you briefly describe how the trials were f

22 conducted?

.C)

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A Would you like me to read the data?

2 Q

No, I don't want to you read the data.

Maybe it 3

would be better for me to ask a specific question.

4 Did you monitor all of these cars in series or did 5

you just monitor one car and then take the time, record the 6

time and then see how long it took to do the second car and 7

then record that time?

Do you understand my question?

8 A

These were done individually.

9 Q

Individually?

10 A

Yes.

(}

11 Q

Were there any trials done to determine how long 12 monitors could keep up the pace that's reflected in these 13 various trials?

14 A

Not specifically, no.

15 Q

I notice that in some cases, one of the activities-16 timed was the vehicle pulling up to a cone.

Do you see that?

17 A

Which trial are you referring to?

18 Q

Let's look at trial 4.

19 A

Okay.

1 20 Q

That is one of the activities that's timed, 21 correct?

22 A

Correct.

^h (G

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Q Can you describe how that activity was conducted 2

-- strike that.

3 How far away was the vehicle before it -- when the 4

time started before it came up to the cone?

5 A

I recall it was anywhere from 10 to 20 feet from 6

the cone.

That's my recollection.

7 Q

And at what point was the time stopped during this 8

particular trial?

9 A

When the car pulled away.

10 Q

When it pulled away from the cone.

(}

11 At the various reception centers, isn't it true 12 that monitoring bases will be set up in series?

Do you 13 understand what I mean by "in series"?

14 A

Actually in series and in parallel.

15 Q

In parallel and in series?

Okay, did you conduct 16 new trials to determine the effect of monitoring-cars in 17 series, that is, having.them pull up in series?

18 A

No, I have not done that.

19 Q

Has anyone done that?

2 0

A I am not sure.

21 Q

That might have an affect on the overall time; is 22 that correct?

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l' A

I'm not sure.

2 Q

Have you had any discussions with anyone about 3

whether that would be a factor in the overall time required 4

to monitor?

5 A

Not specifically.

My only discussion-has been the 6

larger-type vehicle, recreational. type vehicle, that it would 7

be useful to divert those to a separate lane, recognizing we 8

would have fewer of those types of vehicles; and I can't 9

speak quantitatively, but qualitatively if we were to have 10

.tsrge size recreationaA vehicles and vans and so forth we

()

11 would put those in one lane, the other types of standard cars 12 would be channeled through the other lanes.

That would 13 enhance the traffic flow.

14 Q

Is that suggestion reflected in any of the 15 versions of the LILCO plan out now?

16 A

I'm not sure if it is that specific, but it is 17 being discussed in training.

I'm aware of that.

18 Q

Do you know o[ any plans to conduct any drills or 19 exercises at any of'the three reception centers?

20 A

I'm not aware of any specific cchedule, no.

21 Q

Have you had any discussions with anyone about 22 such drills or exercises even in the absence of a specific

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I schedule?

2 A

I'm not sure I have had a specific discussion 3

other than my assumption that, since drills have been 4

performed before to look at monitoring when it was being done 5

at the Coliseum, that a similar type of thing would be done 6

at some point in the future for the other centers, but I 7

don't have any specifics on any plans to do so.

8 Q

You haven't discussed with anybody whether such 9

drills or exercises will take place?

10 A

Whether they will take place or when will they

()

11 take place?

12 Q

Whether they will take place.

13 A

I'm assuming they will, but again, as I say, I 14 really don't know when.

15 Q

But have you had any discussions with anyone about 16 whether they will take place?

17 A

In the context of training sessions, yes, I know 18 that there will be training conducted outside where the areas 4

1 19 are set up.

I don't know when that will happen.

That's a j

20 common approach that's used in the emergency plan training at i

21 LILCO.

l 22 Q

Will this training involve actually setting up the b

%/

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1 reception centers?

2 A

I would expect so, yes.

I don't have any other 3

information on the total scope, but if the general approach 4

is that that was used for the Coliseum, I would expect that 4

5 there would be some set-up done.

6 Q

Now there's a limit to how quickly a probe can be 7

passed over a body and still obtain an accurate reading; is 8

that correct?

9 A

I think you don't want to move too quickly to that f

10 extent, yes, that's correct.

()

11 Q

How quickly are monitors.under the LILCO plan 12 trained to move a probe over the body or around the head, 13 neck and shoulders?

14 A

I believe that the rate that I was told was 15 something in the order of eight to 10 inches a second.

16 Q

Do you know whether that rate was maintained 17 during these time trials which are reflected in Watts Exhibit 18 1?

19 A

I think approximately, yes.

I was watching it 20 being done.

21 Q

Were you watching specifically to make sure that 22 the probes were not moved faster than the required time?

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(

l 30148.1 KSW 50 F-1 A

Well, I was watching -- I think in some cases, I 2

was seeing the probe moving more slowly than that.

I was 4

3 watching to insure that in my judgment that it did not appear 4

!that they were scanning too quickly.

I even feel that they i

5 were doing it more slowly.than eight-to 10, but --

6 Q

Are you aware of whether that rate was exceeded at 7

any point?

i 8

A I don't think it was.

I have noticed other plans, j

9 and the state procedure that I refer to recommends one foot 10 per second or 12 inches per second, so I think we were 4

()

11 keeping well under that.

12 Q

How is monitoring done when people are in the 13 cars?

Can you explain to me?

14 A

The doors are opened, and a monitor gets on both 15 sides of the car, explains to the person what they need to 16 do.

They do have the person lift their feet.

The feet are L

17 monitored.

The rest of the person, the person is in place, 18 he is asked to hold his hands out, the hands are monitored.

19 The shoulders are monitored across the back or in front and j

20 then the scan is continued up the side of the neck and up to I

21 the head.

~

22 Q

How is the monitoring --

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1 A

Excuse me.

It is actually a fairly continuous 2

process, and in fact, in thinking about it, we're covering 3

more than just those areas just to get from one point to 4

another.

We're scanning over other portions of the body to 5

get from one part to the other.

It is one continuous motion.

6 Q

How is monitoring done of a person in the back 7

seat of a two-door car?

8 A

The seat is pulled forward.

We have the HP 260 9

probe also that has a larger handle, has approximately an 10 eight-inch handle on it that makes the accessibility on it a

()

11 lot easier than the HP 210 or 270, so'in looking at what we 12 had to do, we recognized that the situation called for a 13 slightly different configuration of the probe.

It is the 14 same sensitivity as the HP 210 probe that we were using 15 before, but it makes it a little bit more accessible.

In the 16 feedback I got back from the training, the monitoring people 17 have been quite happy with that.

18 Q

Are you aware of any trials which have been 19-conducted where there were problems with the monitoring 20 people in the back seat?

21 A

Yes.

I believe in some subsequent trials that 22 were done in, I think it was a Ram Charger, that they

(

)

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/V) 1 realized that the people in the front needed to get out 2

briefly so that we could get at the back seat people.

We 3

expected that there would be certain isolated situations like 4

that, and we wanted to identify it upfront so we could factor 5

it into our planning.

I think we are doing that.

6 Q

There was an additional drill held on February 20, 7

is that correct, a time trial?

8 A

I'm not sure of the date.

I think that's 9

possible..Do you have --

10 MR. MC MURRAY:

Let's have this marked Watts O'r..J 11 Number 2.

12 (Watts Exhibit 2 identified.)

13 BY MR. MC MURRAY:

14 Q

Let me show you a document that's been marked as 15 Watts Exhibit Number 2, which is a February 20, 1987 memo to 16 file.

Have you seen this document before?

17 A

Yes.

18 Q

And this document appears to reflect time trials 19 conducted on February 10 of 1987; is that correct?

20 A

Yes.

21 Q

These are seven additional trials similar to the 22 trials conducted on January 5; is that correct?

)

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1 A

Yes.

2 Q

Were you present at the February 10 time trials?

3 A

No, I wasn't.

4 Q

Have you had any discussions with anyone regarding 5

the February 10 time trials?

6 A

Yes.

7 Q

Who did you have discussions with?

8 A

Mrs. Dreikorn.

9 Q

When did you have those discussions?

10 A

I think at some point between -- well, actually

/'

11 before the time trials, to discuss the scope of the trials

\\,j) 12 that were going to be conducted, and subsequent to the trials 13 I believe between February 10 and February 20, but I don't 14 remember the exact date.

15 Q

Can you tell me your discussions, the substance of 16 your discussions with Mrs. Dreikorn regarding the scope?

17 A

Yes.

I wanted to make sure -- I wanted to expand 18 the data base, and I wanted to cover an even wider range of 19 cars with a larger number of monitoring personnel to make 20 sure that our 90-second or 100-second estimation was valid.

21 Q

How did you decide on the four vehicles that were 22 used in these time trials?

,_sL]

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A I did not decide on the vehicles.

I indicated 2

that I wanted different vehicles other than those that were 3

used in the initial trial.

4 Q

Why did you want a wider data base?

5 A

Because our. January 5 trial was really the first 6

time that we had focused on doing specific timing with this 7

specific monitoring method, and I wanted to really do a 8

sanity check on the data.

I just wanted --

9 Q

A sanity check?

10 A

Excuse me?

()

11 Q

Did you say sanity check?

12 A

That's a technical term that we use to make sure 13 that it is reasonable.

14 Q

It says in the first paragraph here that the 15 trials were timed from the time the vehicles stopped at the 16 monitoring station to the time it was directed to proceed 17 away from the monitoring station; is that correct?

18 A

That's what it says, yes.

19 Q

So the trials did not include the time it would 20 take to drive up and drive away from the monitoring station; 21 correct?

22 A

I'm not sure of that.

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Q Were the trials conducted individually?

2 A

I believe they were, yes.

3 Q

Can you tell me what discussions you had with 4

Mrs. Dreikorn subsequent to the February 10 time trial?

5 A

only to hear from her what the results were.

I 6

also confirmed with her my desire to take into account other 7

pieces of equipment or other articles that would be in the 8

car that might make the monitoring more difficult, you know, 9

for accessing people, and she assured that when these trials 10 were being done that the types of materials in the car would I~)

11 simulate luggages or other materials that an evacuee would be L./

12 carrying along.

I wanted to make sure that we tried to 13 simulate the condition of the inside of the car with 14 additional things that might get in the way.

I wanted to see 15 if our monitoring people could deal with that, and she told 16 me that they did provide that type of material in these 17 trials, and that the monitors were able to work around those 18 particular obstacles.

Again, we were trying to do our 19 homework as best we could.

20 Q

Was anyone from outside the LERIO organization 21 present at these time trials, the ones on February 10?

22 MS. LEUGERS:

You mean February 20?

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1 MR. MC MURRAY:

No, February 10.

The memo is 2

dated February 20, 3

MS. LEUGERS:

Oh, I'm sorry.

4 THE WITNESS:

From outside?

5 BY MR. MC MURRAY:

6 Q

Yes.

7 A

I don't know.

8 Q

Do you know who was present at the February 10 9

time trials?

10 A

I don't remember the names.

I know that a class

()

11 was being conducted with radiation monitoring and 12 decontamination personnel, and as part of that class, they 13 did the time trials.

I don't know the names of the people, 14 but these would be people, presumably, who could be called 15 upon to perform this at the reception centers.

That was my 16 understanding.

17 Q

Do you know whether any practice trials were 18 undertaken before these trials were done?

19 A

I believe that the method was discussed and tried 20 a couple of times, yes.

That's my understanding.

21 Q

And it is your understanding, though, that the l

22 monitoring in these trials was conducted by actual LERIO l

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1 monitoring personnel?

2 A

Yes, and that's also reflected in the first 3

sentence of the memo.

4 Q

Did you have any discussions with Mrs. Dreikorn 5

about whether any activities other than monitoring should be 6

measured in order to get an idea of exactly how long it is 7

going to take to push people through the sites?

8 A

Only that people would be spoken to as they were l

9 going by the monitor, to discuss what the activity was going 10 to be.

I don't recall if there were any other discussions.

(}

11 Q

Do you know whether during the trials conducted on 12 February 10, part of the activity that was being looked at, 13 included instructions from the monitoring personnel to the 14 people inside the cars as to what to do?

15 A

As to what to do in what sense?

16 Q

As they were being monitored.

17 A

Yes.

18 Q

It did include that?

19 A

Yes.

20 Q

How about -- is that true for the January 5, 1987 21 test?

22 A

Yes.

We had gone about it in a way that the i

i

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1 people were sitting in the car, presumably unaware of what 2

was going to be asked of them, and we wanted to insure that 3

the types of directions and -- well, the types of directions 4

were being asked and understood.

5 Q

Was the February 10 time trial conducted at the 6

Hauppauge training center as well?

7 A

I don't know.

I don't recall at the moment where 8

it was conducted.

It was a LILCO facility, but I'm not sure 9

which one.

10 Q

Was it one of the three reception centers?

()

11 A

I'm not sure.

12 Q

This time trial didn't simulate monitoring cars in 13 series, did it?

14 A

I don't think it did.

15 Q

In your mind, are there any other factors which 16 were not timed which might lengthen the amount of time 4

i 17 required to monitor a car and its occupants?

18 A

I'm really not sure.

19 Q

Was anything --

i 20 A

It was directed at the monitoring process.

That 21 was the scope of this.

22 Q

Have you had any discussions with anyone at LILCO ACE-FEDERAL REPORTERS, INC.

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30148.1 KSW 59 C\\

U 1

or LERIO regarding whether additional factors might add to 2

the times reflected in these time trials?

3 A

I'm not -- not specifically.

I was interested in 4

knowing what the time in motion numbers were for doing the 5

monitoring.

6 Q

You say "not specifically."

Have you had general 7

discussions with anyone regarding additional factors that 8

could add to the time necessary to push the people through 9

the sites?

10 A

A general one of answering questions from the

()

11 driver, for instance.

12 Q

So you have discussed with someone the fact that 13 answering questions from the driver might take some 14 additional time?

15 A

No, no.

That's just another ongoing activity that 16 could be occurring at the time, and the fact that we have 17 both the monitoring people doing the people and the car and 18 we have the traffic guide taking down information on the car, 19 and the traffic guide can be answering those questions in 20 paralegal, so I asked about that, and I received an 21 explanation.

22 Q

Who did you ask?

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A I asked some of the people within LERIO how the 2

process would occur.

3 Q

Who did you talk to about that?

I 4

A I think it was either Mr. Aidikoff or 5

Mrs. Dreikorn.

6 Q

And what was their explanation to you?

7 A

Just what I mentioned, that those activities could i

8 be going on at the same time.

9 Q

Did you have any discussions about whether those 10 activities could add to the amount of time required to get a

()

11 car out of the monitoring station and on its way?

12 A

Yes.

Yes, and the answer satisfied me.that 4

I 13 because the times in the time trials.were looking favorable 14 and the explanation could be given simultaneously, I didn't i

15 think that our time estimates were invalidated.

16 Q

What sort of questions were you concerned about a j

17 driver asking to the monitoring personnel?

1 18 A

Basically, where do I go next.

Not the monitoring l

19 personnel, but the traffic guide.

20 Q

Are those the only types of questions that could 21 be asked of the traffic guide is, where do I go naxt?

i 22 A

I don't know.

That's what came to mind when I was l

}

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1 asking the question.

2 Q

.There could be a wide range of questions on the 3

mind of a driver going through a monitoring station, couldn't 4

there?

5

-A I suppose.

6

-Q And do you know whether or not the traffic guides f

7 have been trained to respond to the types of questions that a 8

driver might ask at a monitoring station?

a 9

A I believe in terms of the question that I was 10 reflecting, where do I go next, yes, they are and will be i

f ()

11 trained on providing directions.

12 Q

Will they be given any other information to f

i 13 disseminate to drivers?

14 A

I don't know.

j l

15 Q

Did you discuss with anyone the possibility that a

{

16 driver's questions or concerns might not be answered within i

)

17 the 100 seconds in which the monitoring was going on?

i I

18 A

No.

19 Q

Mrs. Dreikorn was or was not one of the monitors j

1 20 involved in the February 10 trial?

21 A

I don't think she was actually doing the

!(

22 monitoring.

I think she was supervising the operation.

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1 30148,1 KSW 62 I

was the instructor for that training session.

I don't 2

believe she was one of the actual monitors.

3 Q

Do you know whether the monitors were being 4

supervised or advised while the trial was -- time trials were 5

going on?

i i'

6 A

I asked for the same type of approach to be used i

7 that was used on January 5, and although I was not-there that i

~

8 day, assuming that the same type of approach was used, we 9

were not coaching the monitors as they were doing the 10 activities.

()

11 Q

But you didn't ask that question of Mrs. Dreikorn 12 as to whether there was coaching or not?

j 13 A

I did not ask that specific question.

14 Q

But you are assuming that-there was no coaching?

i 15 A

I'm assuming there was none, that -- well, that's 16 my answer.

17 Q

Trial 2 on Watts Exhibit 2 involves a Dodge Ram 18 Charger with five passengers in it, and the total time there 19 was 65 seconds.

It is noted that the front passengers had to i

20 get out of the vehicle.

Do you see that?

21 A

Which trial is this?

22 Q

Trial 2.

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, n v

1 A

Yes.

2 Q

Do you know why that trial, which had more people 6

3 and more activity, that is with people getting out'of the 4

car, took less time than trial 1?

5 A

I believe it is just the different configurations 1

i 6

of the vehicle.

7 Q

Trial 1 involved only four passengers, and it does i

8 not appear to have involved any people getting in and out of 9

the car; right?

10 A

That's right.

i

(}

11 Q

You assume it is because of the different 12 configuration that the times are different?

13 A

Yes, apparently the approach of the monitors at 14 that time, that was a common sense action to take for-that 15 particular type of vehicle.

I 16 Q

Do you know how the six radiation monitoring i

17 personnel were chosen?

18 A

Not specifically, no' 19 Q

Do you know generally how they were chosen?

20 A

Generally, I believe we were interested in taking i

21 a group of, quote, typical radiation monitoring J

22 decontamination personnel, t

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Q You didn't have any discussions with Mrs. Dreikorn 2

about how the six that were used in these time trials were 3

chosen?

i 4

A I had a discussion with her that I wanted her to 5

get people who would be performing that type of operation 6

involved in the time trials and not to just use instructors k

7 to do that.

4 8

Q Do you know whether these six radiation monitoring 9

personnel were the tops in their class or the midrange, or 10 was that not a concern?

You can think about that question

()

11 while we go off the record.

12 (Discussion off the record.)

i 13 THE WITNESS:

I think Mrs. Dreikorn understood my 14 general concern, and I'm sure her response to my concern 15 would not be to take the top of the class but to take a group 16 of people who probably represented the spectrum, and I'm i

t 17 assuming that's what she did.

I I

18 BY MR. MC MURRAY:

j 19 Q

But you have not discussed with her whether she

]

20 did that or not, subsequent to the trial?

j 21 A

No, I have not confirmed it.

i 22 Q

Were there any tests conducted on February 10 to

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determine how long the monitoring personnel could keep up the 2

100 second or less pace?

3 A

No.

l 4

(Discussion off the record.)

l 5

MR. MC MURRAY:

Let's take a short break.

6

-(Recess.)

7 MR. MC MURRAY:

Back on the record.

8 BY MR. MC MURRAY:

s 9

Q Mr. Watts, the 100 second figure which was derived 10 from the time trials, that is the basis for LILCO's assertion

(}

11 that it can monitor about 30 to 35 percent of the EFZ 12 population in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; is that correct?

13 A

Yes.

i 14 Q

How does one draw that conclusion?

Is there a 6

i i

15 calculation involved?

16 A

I believe one of the LILCO -- the LERIO staff went 17 and factored the number of monitors available and the number 18 of seconds per vehicle that would be expected and backed the 19 number out over the 12-hour period.

20 Q

You mentioned two factors involved in this 21 calculation.

One being the number of monitors, the other 22 being the 100 seconds.

/\\CE FEDERAL REPORTERS, INC.

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30148.1 KSW 66 s-1 A

Yes.

2 Q

Are you aware of any other factors that went into 3

this calculation?

4 A

The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

5 Q

The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />?

Anything else?

6 A

I think that was it.

7 Q

Is this a written calculation somewhere?

8 A

I have not seen a written calculation.

I'm aware 9

generally of how that calculation is done with those factors 10 but I have not seen the written --

()

11 Q

Have you discussed this calculation with anyone?

12 A

In terms of what?

13 Q

In terms of what factors went into it or whether 14 it is accurate.

15 A

No, not really.

I'm not sure I understand what 16 your intent is.

17 Q

Have you had discussions with anyone as to whether 18 or not these calculations support the conclusion that LILCO 19 can monitor 30 to 35 percent of the population in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />?

20 A

I guess to the extent that I was involved in 21 looking at the 100 second estimate, I would have been 22 involved in a discussion, f}

u ace-FEDERAt REPORTERS, INC.

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30148.1 KSW 67 1

Q Do you know who conducted this calculation?

2 A_

I could probably narrow it down to one of two 3

people, 4

Q Who would those one or two people be?

5 A

Mr. Sobotka or Mr. Aidikoff, the LERIO group.

6 Q

Well, you may not have seen anything in writing.

7 Did you -- do you know whether that calculation has been 8

reduced to writing?

9 A

I don't know.

10 Q

What discussions have you had with Mr. Sobotka or

(}

11 Mr. Aidikoff -- strike that.

12 Let's just concentrate on Mr. Sobotka.

What 13 discussions have you had with Mr. Sobotka on the issue of 14 LILCO's ability to monitor 30 to 35 percent of the population 15 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />?

16 A

My discussion, I think, in that regard took place 17 on the day that we were conducting the January 5 time trials, 18 during which he was a participant.

It was basically how I 19 wanted the time trial testing to be done that day.

20 Q

What discussions have you had with Mr. Aidikoff in 21 that regard?

22 A

Basically the same.

The other discussion that we ace FEDERAL REPORTERS, INC.

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I had, I think, is that we wanted to add a margin above the one 2

and a half minutes that we were starting to settle on on l

3 January 5, and we wanted to add some margin on top of that at i

4 that particular time, so that if we were looking at something i

5 like 90 seconds, we wanted to add another 10-second margin j

6 anyway, which is how we came to the 100' seconds, and the 7

discussion then was the desire to follow up with additional 8

testing to validate the results of the initial trial.

I 9

Q So it is your understanding, then, that the 100 10 seconds has two constituent parts, the 90 seconds to do the

()

11 monitoring and the 10 second buffer or margin?

i 12 A

Yes, that was the original discussion that I had 13 on the basis of the 100 seconds.

14 Q

How is the 10-second margin decided upon?

15 A

It seemed, I believe, it seemed to be a reasonable j

16 consensus at that time that might encompass other activities I

17 beyond monitoring that would happen.

18 Q

What other activities would that encompass?

i i

19 A

The serial placement of the vehicles.

1 l

i 20 Q

Any other activities that that would cover?

F l

21 A

That was basically -- I think it -- the general I

5 22 motion of cars through.

i

?

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1 Q

Was there any discussion about whether the 2

10-second margin was an adequate margin to cover the general 3

motion of cars through the lines?

4 A

At the time, it appeared to us to be reasonable, 5

and as I said, we wanted to follow it up with additional 6

testing at a later time.

7 Q

Well, have any tests been conducted to confirm 8

that 10 seconds is a reasonable margin to cover the 9

additional activities such as moving cars?

10 A

I think, in fact, that when the results came back

()

11 from the second series of trials, and the average was 12 something on the order of 68 seconds, that we were encouraged 13 that we had perhaps even more margin on the average than 10 14 seconds.

15 Q

Were there any other activities that you can think 16 of that the 10-second margin was intended to cover?

17 A

Not at that time, no.

I don't recall any.

18 Q

Mr. Watts, we have been discussing the arrival of 19 evacuees at the reception centers.

If evacuees from outside 20 the EPZ seek monitoring, what is your understanding of how 1

21 those evacuees would be treated under the LILCO plan?

22 A

I'm not sure I understand the basis of your Acu-Fennnai. RisponTrins, INC.

202 347 3700 Nationwide Coserage Mxk33MM6

30148.1 KSW 70 O

1 question.

2 Q

Well, if people from outside the EPZ went to a 3

reception center because they wanted to be monitored, even 4

though they may not have been told to do so, is it your 5

understanding that they would be monitored, or would they be 6

turned away, or do you have any understanding?

7 A

I'm not sure we would have the ability to 8

distinguish whether they were from inside or outside the EPZ, 9

and because of that, I believe they would be monitored.

10 Q

The plan doesn't make any provisions to

()

11 distinguish between people from inside or outside the EPZ; is 12 that correct?

13 A

Not that I'm aware of, no.

14 Q

You have stated you have been to the sites 15 themselves; correct?

l 16 A

Yes.

17 Q

Were you at all involved in the selection process 18 which eventually led to the selection of these three cites as 19 reception centers?

20 A

I was involved in some early discussions on cites 21 that could be used, but I was not involved in the final i

22 decision on those three particular cites.

ACE-FEDERAL REPORTERS, INC.

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30148.1 KSW 71 0

1 Q

What were the early discussions that you were 2

involved-in regarding cites?

3 A

Just what cites were available to use as other j

4 reception centers.

5 Q

When did this discussion take place?

6 A

I don't recall exactly when, but it was around the 7

time frame that it didn't appear that the Coliseum would be l

8 available any more.

9 Q

With whom did you have these. discussions?

10 A

The same personnel from LERIO that I described 11 before.

1 12 Q

So that would be Mr. Sobotka, Mr. Aidikoff and 13 Mrs. Dreikorn?

i j

14 A

Yes, and Mr. Crocker and Mr. Daverlo.

l l

15 Q

And what was your role in.the discussions?

i 16 A

It was mainly -- I was mainly there in a listening 17 mode to hear about the problem and to offer whatever input I 18 had regarding the processes that were available for handling 19 the radiological issues.

20 Q

What was the inpui that you gave at that time?

21 A

I don't recall exactly.

I believe that part of my l

22 assignment at that time was to think about the types of I

f

/\\CE FEDERAL REPORTERS, INC.

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/9 v

1 monitoring methods that were available that could be applied 2

to this particular situation.

3 Q

So your responsibility was to consider procedures, 4

not cites?

5 A

That's basically true, yes.

6 Q

Have you reviewed the three cites to determine 2

l 7

whether or not they are adequate to serve as reception i

8 centers?

j l

9 A

Yes.

10 Q

What are your conclusions in that regard?

()

11 A

I believe they are adequate to serve as reception 12 centers.

13 Q

Why is that?

i 14 A

Because I believe that provisions can be made for i

15 the monitoring and decontamination of evacuees in a manner 16 that is equally effective as any other type of reception 17 center that's used elsewhere in the state and in other parts 1

i 18 of the country.

19 Q

Is it common for monitoring to bb conducted 20 outside?

4 21 A

It can be, yes.

22 Q

Monitoring of persons?

ace-FEDERAL REPORTERS, INC.

202 347-3700 Nationwide Coverage 800-336 4 46

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I 1

A Yes, in some cases.

2 Q

'What cases?

3 A

I believe in my review, and I don't remember which 4

organization did it, but I believe I was made aware of a 5

situation where monitoring would be done outside, and, in 6

fact, field showers would be used outside.

7 Q

Is that a military plan?

8 A

No.

9 Q

What plan was it?

10 A

It is a county plan.

(])

11 Q

Is that a county plan in New York?

12 A

Yes.

13 Q

Which one is that?

14 A

I don't recall exactly.

15 Q

Have you reviewed the sites to determine whether l

16 or not they are big enough?

17 A

Big enough for what?

'18 Q

For monitoring of decontamination.

And to handle i

19 the number of people who are going to come through them?

20 A

Yes, my conclusion is that they are adequate, and 21 I described to you earlier what the provisions of the plan l

22 are, and I;believe with the tiered approach that we have

(

4 I

/\\CEJFEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336-(M6

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which is consistent with recent FEMA guidance, that the 2

reception centers are more than adequate.

3 Q

Well, have you conducted any analyses to determine 4

whether people can be moved through those sites in times that 5

are consistent with those that the LILCO plan relles upon?

6 A

We have been discussing time trials.

7 Q

Those were not conducted at the sites, right?

l 8

A That's true, they were not.

I'm not sure about 9

the second type trial.

The first time trial was not 10 conducted at one of the sites.

The second one I'm not sure 11 of.

12 Q

Do you know of any analyses that have been 13 conducted to determine whether the sites are physically 14 capable of handling the number of people who would arrive at 15 the cites?

16 A

I believe thos'a analyses have been done, Not by 17 myself.

18 Q

By whom have they been done?

19 A

I may be mistaken, but I believe KLD Associates 20 has done that.

21 Q

Have you had any discussions with KLD about that?

22 A

Not directly.

/

( s) 1 ACE-FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336-6M6

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Q Do you know when those analyses were.done?

2 A

Not exactly.

I believe within the last year.

I'm 3

not sure I understand -- as I think of your question I'm not 4

sure of what you were asking.

Could you repeat that?

5 Q

We have gone through a few questions and answers.

6 Why don't we read bact: the question we're discussing here.

's A

I believe KLD Associates has done traffic studies 8

to analyze how people would get to the reception centers.

9 I'm not sure how far beyond that they have gone as far as the 10 flow through the sites.

()

11 Q

Are you aware of anyone else who has done an 12 analysis ofithe flow through the sites?

13 A

I'm not sure.

14 Q

Have you had any discussions with anyone regarding 15 whether the sites are physically big enough to handle the 16 functions that they are supposed to be handling?

17 A

I have discussed with the LERIO people on what the

~

18 layout of the site would be and what the traffic patterns 19 would be.

20 Q

Have you looked at the traffic patterns?

21 A

Yes.

i 22 Q

You have?

J ACE FEDERAL REPORTERS, INC.

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30148.1 KSW 76 i

1 A

I have.

2 Q

Have you compared them with the sites?

3 A

I have looked at the traffic patterns proposed for 4

the individual sites.

5 Q

Then --

6 A

Through the sites.

7 Q

In going to the sites, did you try to determine 8

whether those traffic patterns could be maintained?

9 A

When I went to the sites, I had copies of the 10 layouts and the proposed placement of monitors and proposed

()

11 flowing of traffic, so I was looking at it in that context, 12

yes, 13 Q

Did you see anything at the cites that would lead 14 to any concern that the sites maybe could not handle the 15 traffic flow as set out in those charts?

16 A

No.

The traffic flow, once I went to the sites 17 and understood how it would go, looked like it would work.

18 Q

Did you see any physical impediments to the 19 traffic flow?

20 A

I'm not aware of any, no.

21 Q

You went to all three sites and checked the 22 traffic flow?

l Ace FEDERAL REPORTERS, INC.

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1 A

Yes.

My primary focus was to look at the entire i

2 site, the layout of the site, where the trailers would be 3

placed, where the cars would be going, and I was looking at 4

it in a really overall sense.

5 0

At Hicksville, I think in area B, the monitoring 6

is actually going to be conducted in pathways between piles 7

of utility polls and transformers; is that correct?

8 A

If we could look at a map, I would like to refresh 9

my memory as to where area B is.

10 Q

Unfortunately, the graphs that are in the LILCO

(}

11 plan don't reflect those utility polls and the transformers, 12 but maybe if I show you the graph, it will jog your memory 13 anyway.

14 A

Okay.

15 (Discussion off the record.)

16 BY MR. MC MURRAY:

17 Q

Let me show you a document, which I will give to i

18 you as it has been received by us, which we have been told 19 are the February 20, 1987 draft revisions to the LILCO plan, 20 and let me refer you to a graph which is on page 21 of OPIP 21 4.2.3, and purports to be a graph of the Hicksville reception l

i 22 center.

I don't usually do this, but if you will let me ace. FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336-6646

_~

30148.1 KSW 78 i

1 stand next to you we can both look at this.

2 A

Yes.

3 Q

Have you seen this diagram before?

4 A

I believe I have, but I don't believe I have done 5

a direct comparison of this diagram and the previous diagram 6

in revision 8.

I have not walked through the site subsequent 7

to February 20.

8 Q

Even in revision 8, though, there was an area A 9

and an area B, correct?

10 MS. LEUGERS:

Do you have a copy of rev. 8?

()

11 MR. MC MURRAY:

Sure.

12 MS. LEUGERS:

It might be easier, rather than all 13 of us hovering in one spot, if we could have a copy of this 14 also.

15 BY MR. MC MURRAY:

16 Q

Mr. Watts, is it your understanding that under 17 rev. 8 monitoring was to be done at two separate areas of the 18 Hicksville site?

19 A

May I see rev. 8, and I can tell you how many 20 areas.

21 Q

Sure.

Let me give you what is my own copy of rev.

22 8, and you can ignore my writing.

I am showing you OPIP b.s ACE-FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336 & 46

j 30148.1 KSW 79 l

1 4.2.3, page 21, which is also a diagram of the Hicksville 2

reception. center.

3 Now, have we forgotten the question, Mr. Watts?

4 A

I would like it repeated, if you wouldn't mind.

5 Q

Under both rev. 8 and the February 20 revisions, 6

monitoring at Hicksville is to be done in two areas, area A 7

and area B; correct?

8 A

It appears to be, yes.

9 Q

And with respect to area A, that is in the 10 left-hand side of the diagram, and area B is on the

(}

11 right-hand side of the diagram; correct?

12 A

Yes.

13 Q

Now, with respect to area B, on the right-hand 14 side of the diagram, there are seven series of monitoring 15 bays; correct?

16 A

Which version are you referring to, rev. 8 or the 17 draft?

'T 18 Q

Let's look at rev. 8.

There are seven series of 19 monitoring bays, correct, each bay having two monitoring 20 stations?

21 A

I'm not sure what you mean by " bays."

Let's look 22 at it.

ACE FEDERAL REPORTERS, INC.

202-247-3700 Nationwide Coverage 800-336-6646

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30148.1 KSW 80 0

1 Q

The bay, let's look at the top line here on area A 2

-- area B.

There's a square which says "M" and then there's 3

a "R."

What's your understanding of what "M" means?

4 A

Monitor.

5 Q

And the "R" means what?

6 A

Recorder.

7 Q

And then there's beyond that another'"M," correct?

8 A

Yes.

9 Q

And another R?

10 A

Yes.

()

11 Q

Let's define that right now as the two series of 12 monitoring stations as being a bay.

Is that all right with 13 you?

14 A

For instance here you are referring to M --

15 Q

M.11 and M.12 would be a bay with two monitoring 16 stations.

If you are used to using another term, we can use 17 another term.

18 A

No I'm just trying to understand your 19 terminology.

So "M" is a monitoring location.

M.11 is a 20 monitoring location,, correct?

21 Q

That's my understanding.

Is that your 22 understanding?

ACE FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800 336 4 16

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- O 1

A Yes.

2 Q

Now, there are, using my terminology, seven bays 3

of monitoring stations; correct?

4 A

Well, for instance in this particular grouping 5

right here, we have four monitoring stations.

6 Q

Right?

7 A

And we have four groupings of these monitoring 8

stations.

Some have four, some have two.

9 Q

There are four groupings, the top three have four 10 and the bottom one has two; is that correct?

()

11 A

Yes.

12 Q

And it is your understanding, isn't~it, that there 13 is some sort of physical entity between, for instance, the 14 second series of monitoring stations and the third series of 15 monitoring stations going from the top to the bottom?

16 A

I believe so.

T 17 Q

Okay, do you know what it is between the second 18 and third monitoring stations, lines of monitoring stations?

19 A

I'm not sure.

I believe there's.some equipment 20 down in that particular area.

I don't recall exactly.

21 Q

Do you know what there is between the fourth and 22 fifth monitoring stations?

ACE FEDERAL REPORTERS, INC.

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30148.1 KSW 82

.O 1

A I don't recall.

2 Q

Do you recall what there is between the sixth and 3

seventh line of monitoring stations?

4 A

As I say, I believe it may be some type of utility 5

equipment, but I don't recall exactly the amounts or the 6

types.

7 Q

Do you know whether anyone has measured the alleys 8

between the utility equipment to determine whether there's 9

adequate space to run two series of cars in parallel through 10 those spaces?

()

11 A

I don't know about specific measurements, but the 12 people who laid this out first walked through the site to 13 make sure that there was enough area to fit these monitoring 14 stations.

15 Q

Who were the people who walked through the area 16 and laid out these diagrams?

17 A

I believe Mr. Sobotka and Mr. Aidikoff.

18 Q

Was Mr. Daverio involved?

19 A

In the layout?

20 Q

Yes.

21 A

I don't believe he was involved in the specifics 22 of the layout.

I think he may have reviewed the layout, as I-ACE FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336-6M6

30148.1 KSW 83 sj 1

did.

2 Q

When you went to area B, did you look to see 3

whether there was enough space to perform the monitoring as 4

set out in area B?

5 A

I didn't make specific measurements.

I looked 6

over area B in general to see where it was and to have a 7

general understanding of the flow patterns, and I did this at 8

all of the facilities, but I did not make detailed physical 9

measurements, no.

10 Q

Did you even look at whether two rows of cars

()

11 could go through the spaces between the utility equipment?

12 A

I don't believe I was actually counting spaces, 13 but I was looking at the overall feasibility of moving cars 14 through those general areas.

15 Q

Okay, obviously it would be important for the 16 working of the plan for there to be enough space to have two 17 rows of cars going through those spaces, correct?

18 A

Well, it appears that that is the assumption, both 19 in rev. 8 and the draft version of the procedure.

20 Q

Do you know whether the diagrams we're looking at, 21 OPIP 4.2.3, page 1 of rev.

8, and the February 20 revisions 22 are to scale?

ACE FEDERAL REPORTERS, INC.

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30148.1 KSW.

84

.O 1

A I'm not sure if they are.

2 Q

As a matter of fact, the-utility equipment that i

3 you described is not reflected in scale on either of the 4

diagrams we're looking at; is that correct?

5 A

I don't recall exactly.

I can't say.

I can't 6

completely agree with you.

7 Q

I'a going to take back revision 8.

Let's look at 8

the diagram for the Roslyn reception center in.the February 9

20 revisions located at page 25 of OPIP 4.2.3.

Do you have 10 that in front of you?

f 11 A

Yes.

12 Q

Actually, there's also a diagram on the next page 13 also reflecting the Roslyn reception center; correct?

14 A

Yes.

15 Q

Can you tell me why there are two diagrams showing 16 traffic flow at the same reception center?

17 A

I'm not sure I know why.

18 Q

Have you discussed that with anybody?

19 A

No, I have not.

20 Q

Now, when you went to the Roslyn reception center, 21 did you actually look at the traffic flow and compare it to 22 the actual site and look and see whether traffic could. flow O

i l

/LCE FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336-6M6 m

... _.,.,_.. _,.__,,_..,_ - ~ _,. _ _

30148.1 KSW 85

('i V

1 the way it is laid out in the diagram?

2 MS. LEUGERS:

Which page are you looking at of the 3

two diagrams?

4 MR. MC MURRAY:

I think we're looking at the first 5

page.

6 MS. LEUGERS:

Page 25?

7 THE WITNESS:

I didn't have the draft layout with 6"

8 me at the time.

I had a copy from revision 8 with me.

9 BY MR. MC MURRAY:

10 Q

Did you check to see whether the diagram which you

()

11 had with you could be implemented at the Roslyn reception 12 center?

13 A

I had the diagram with me.

I looked at the 14 overall entrances and exits and flow patterns through the 15 facility.

I did not make detailed measurements of each 16 particular area, but I looked at-the overall workings of the 17 site, including the facilities that were there.

18 Q

Well, you will agree with me, won't you, 19 Mr. Watts, that, for instance, if traffic cannot flow into 20 the Roslyn reception center or flow out of the Roslyn 21 reception center, at the rate at which LILCO relies upon, 22 that there could be a delay in providing monitoring services ACE FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336-6646

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30148.1 KSW 86

((_)

1 to the public?

2 A

Would you run that past me one more time?

3 Q

Sure.

There's an assumption.that LILCO can 4

monitor 30 to 35 percent of the population within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 5

using the procedures set out in this February 20 draft; 6

correct?

7 A

Yes, I believe so.

8 Q

And that assumption is based on a 100-second 9

monitoring time, correct?

10 A

Yes.

()

11 Q

And isn't it true that a lesser percentage of the 12 population would be able to be monitored in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if 13 traffic was somehow delayed either in getting into the site 14 or getting out of the site?

15 A

Yes, that is possible.

16 Q

Have you made any analyses as to whether or not 17 the entries to any of the reception centers create any 18 obstruction or bottleneck which would reduce the flow of 19 traffic through the sites?

20 A

I have not.

21 Q

Have you made that analysis with respect to the 22 exits from the reception centers?

ACE FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336-6M6

~,.

30148.1 KSW 87

)

\\

I 1

A No, I haven't.

2 Q

Are you aware of any physical obstructions on the 3

sites which might slow down monitoring process?

4 A

I'm not aware of any physical obstructions that 5

would hamper the flow, f

6 Q

You have been to the Bellmore site?

7 A

Yes.

8 Q

Let's look at page 17 of the February 20 draft.

9 This is a diagram of the Bellmore reception center.

Do you 10 see that?

11 A

Yes.

12 Q

You see the legend " Sunrise Highway" running 13 across the top?

14 A

Yes.

15 Q

And you see traffic entering the driveway --

16 strike that.

Do you see the diagram showing two lines of 17 traffic entering the driveway on the Sunrise Highway at the 18 same time one line of traffic is leaving through that same 19 exit?

20 A

Yes, with the traffic cones dividing the entrance 21 and exit vehicles, yes.

22 Q

Right.

Have you done any measurements to

/~T 4

V ACE-FEDERAL REPORTERS, INC.

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30148.1 KSW 88 1

determine whether that road or that driveway can accommodate 2

three lanes of traffic?

3 A

I have not.

4 Q

Has anyone done that?

5 A

I would. assume that those people who did the 6

layout, those people I mentioned before, have looked at that.

7 Q

Why would you assume that they had done that?

8 A

Because they prepared the layout with the lanes 9

designate as they are.

There was nothing when I went to 10 these facilities that indicated to me that there was a

(}

11 fallacy in that assumption..

I did not confirm it 12 specifically, but nothing occurred to me that something was 13 wrong with that assumption.

14 Q

While you may not have measured it,.did you 15 actually take a look at that entrance on Sunrise Highway?

16 A

I looked at the entrance, yes.

17 Q

Let's look over at Newbridge Road.

You see 18 there's an entrance at the top of the diagram, actually on 19 the right of the diagram, Newbridge Road, and then at the 20 bottom there's an exit with traffic going out to Newbridge 4

21 Road.

Do you see that?

22 A

Yes.

)

ACE FEDERAL REPORTERS, INC.

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1 Q

Did you determine whether or not traffic could 2

actually enter the driveway reflected there and take a 3

left-hand turn down towards the monitoring bays?

4 MS. LEUGERS:

I would state for the record that

~

5 the witness has stated that when he did go to the facilities, 6

he had the rev. 8.

He did not have the February 20th, so at 7

this point, it could only be speculation as to the 8

differences between this diagram and that in rev.

8.

9 BY MR. MC MURRAY:

10 Q

Okay, with that having been said, did you

()

11 determine whether or not traffic could take a left-hand turn 12 from that driveway down towards the monitoring stations?

13 A

I don't remember.

14 Q

Let me show you what I will represent to you is 15 revision 8, page 17, of OPIP 4.2.3, also a diagram of the 16 Bellmore reception center.

Again, off Newbridge Road there's t

17 traffic entering a driveway and taking a left-hand turn down 18 to the monitoring bays; correct?

19 A

Yes.

20 Q

Is your answer different in any way now that you i

21 have looked at the rev. 8 diagram?

i 22 A

No.

O ACE FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage ax)-336-6646 j

l

30148.1 KSW 90 m

(v) 1 Q

Did you notice any large physical obstructions 2

c might prevent the turning of traffic or the flow of 3

traffic at any point through the Bellmore reception center?

4 A

I don't recall exactly.

I remember some general 5

discussions I had about placement of some offenses somewhere 6

and was told that there would be a -- there could be an 7

opening, but I don't remember exactly if it was at Bellmore 8

or somewhere else.

9 Q

Do you know of any plans to modify the physical 10 layout of any of the reception centers right now in order to 11 accommodate more traffic, and I'm not talking about cones,

}

12 I'm talking about actually changing structures?

13 A

I think there may be plans.

I'm not sure I can --

14 I would not want to speculate on specifically what those are 15 or where they are.

I believe that there may be some plans, 16 but I'm not involved with those.

17 Q

What is the basis for your, at least, 18 speculation?

Have you had discussions with someone about 19 this?

20 A

Only in being updated by one of the LERIO staff 21 did I hear that there may be the need to provide access 22 through a fence.

That's what I understand, but I'm not ACE-FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336-6646

30148.1 KSW 91 k_,)

1 exactly sure where that is exactly.

2 Q

Which LILCO personnel are you talking about that 3

you had a discussion with?

4 A

I'm not even sure who it was.

5 Q

Do you know which reception center was being 6

discussed with respect to putting an entrance through a 7

fence?

8 A

I don't remember.

9 Q

Were there any other physical changes to any of 10 the reception centers that you may be aware of?

(~)';

11 A

No, I'm not aware of any others.

That's not to 12 say that there might not be some physical changes, but I'm 13 not aware at this point of what they are.

14 Q

Under the LILCO plan, it is true, isn't it, that 15 if there is a backup at the decontamination trailers that 16 people waiting for decontamination will be waiting in certain 17 buildings at the reception centers?

Are you aware of that?

18 A

Would you repeat that again, please?

19 Q

In the event that there's a backup at the 20 reception centers, the decontamination trailers, is it your 21 understanding that people waiting for decontamination who 22 cannot yet go into the trailers will be waiting in certain

[ 'i

%s ACE FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-33M/>46

4 30148.1.

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buildings at the reception centers?

7 2

A I'm aware that other buildings are available for 3

that purpose should the need arise.

4 Q

Well, are you aware whether specific buildings 5

have been designated for that purpose?

6 A

I'm not aware that that's been done in the plan 7

specifically.

I am aware that other buildings are available, 2

8 and I'm also aware that in the training, there has been 9

discussion about that as a contingency.

10 Q

Well, is it your understanding that, for instance,

(}

11 at the Hicksville site, people would be waiting in the 12 transportation building?

13 A

I believe that is an option that is available.

14 Q

And at the Roslyn site that people would be i

15 waiting in the warehouse?

16 A

Not necessarily the warehouse, but that is one of 17 the buildings that is available that is close by to the 18 trailers.

i 19 Q

What's another building that would be used to 20 store people?

21 A

There is another office building, I believe, in i

i 22 proximity to the trailers at Roslyn.

/\\CEJFEDERAL REPORTERS, INC.

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30148.1 KSW 93 1

Q How about at Bellmore, are you aware that the 2

transportation garage there would be an area where people 3

waiting for decontamination would be stored?

4 A

I believe that's a building that is available too.

5 Q

Have you looked at those buildings to determine 6

whether or not they are adequate to hold people while they 7

are wait following decontamination?

8 A

On a temporary basis, yes, I have looked at them, 9

and I think they are adequate.

10 Q

What is it about the transportation garage at 11 Bellmore that you find adequate?

{}

12 A

The fact that the doors can be closed, that it is 13 protected from the elements, that it has lighting, and I 14 believe it has heat.

15 Q

Do you know it has heat?

16 A

I believe -- the day I went there, I believe I 17 noticed that it was heated.

There are people that have to be 18 working there all the time to work on vehicles, and I believe 19 my recollection is correct.

20 Q

Does it have any seating for people?

l 21 A

There is no permanent seating, but that doesn't 22 preclude the possibility of bringing in chairs.

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Q Are they available on site?

2 A

There are some chairs available on site.

I don't

{

3 remember how many, but I don't think that would be a' problem.

4 Q

Did you determine whether there_are adequate r

5 sanitary facilities on site?

0 A

I have not specifically counted the number of 7

sanitary facilities, j

8 Q

Has anyone determined whether or not there is j

9 sufficient sanitary facilities for people who might need such I

10 facilities at the reception centers?

{}

11 A

I don't know.

12 Q

We have been talking about a 12-hour time period 13 set out in, I think, it is part J.12 of NUREG-0654.

That is i

14 the time limit set out in J.12, correct?

15 A

There's a reference to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, yes.

16 Q

I think it says about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, correct?

17 A

About~12 hours.

18 Q

Are you aware of when the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> begins to run?

19 A

My understanding of that is from the time that the 20 evacuees arrive at the reception center.

21 Q

Okay, and what's your basis for that 22 understanding?

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1 A

I think ever since I looked at NUREG-0654 several 2

years ago, that type of question has come up, and I can't 3

recall specific conversations with other people, but through 4

that time, that particular interpretation has been reinforced 5

with discussions I have had with other utilities and other 6

emergency planning people, and that appears to be the common 7

interpretation that I'm aware of.

8 Q

Are you aware of any authoritative interpretations 9

of that time limit?

10 A

No.

I guess I don't.

11' Q

You are also going to be discussing

[}

12 decontamination procedures, correct?

-13 A

Yes.

A 14 Q

I think in the plan there is the assumption that 15 for those needing showering, it would take about 15 minutes

)

16 for a full body shower; is that correct?

17 A -

I believe that number is in the plan, yes.

18 Q

What is the basis for that number?

Was this a 19 shower time trial?

20 A

No, I think that was based on experience that we 21 have had in a number of contamination incidents.

Being a 22 health physicist in a nuclear plant for a long period of C:)

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1 time, I saw several contamination incidents.

Most of them i

2 didn't require showering at all, but when showering was done, 3

I really did not notice the total time for showering to take 4

more than -- certainly more than 15 minutes continuously.

5 Q

Are there any -- other than your personal 6

observations, are there any other studies or analyses or 7

research that would support that time frame?

8 A

No, I think that just reflects common experience.

9 Q

Your common experience?

10 A

My experience and-the judgment of other emergency 11 planning people who I have discussed this with in the LERIO

{}

12 organization.

13 Q

Have you reviewed the decontamination trailers?

l 14 A

I have reviewed the layouts, yes.

15 Q

Diagrams?

16 A

Yes.

17 Q

Have you actually seen the decontamination I

18 trailers?

19 A

I have not seen those decontamination trailers.

I 20 am aware that that design originally was based on a I

21 decontamination trailer that is c,n the Shoreham site that is i

22 used for emergency workers from the site, and I believe that 2

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1 was the starting point for the design of these new trailers 2

that we're talking about.

I'have seen the decontamination 3

trailer at the Shoreham site.

4 Q

Is the Shoreham site decontamination trailer.an 5

exact model of the ones that are going to be at the reception 6

center cites, do you know?

7 A

I believe there are'some differences.

I'm not j

8 sure I can remember all of them, but I think the basic I

9 provisions for an area for doing monitoring an area where-10 some simple washing could be done, an area for showering and l {'}

11 providing paper clothing, that type of concept applies to 12 both cases.

13 Q

Are they the same in size?

14 A

I'm not sure they are exactly the same in size.

15 The best of my recollection is, I think, the ones for the

}

16 reception centers are larger.

1 17 MR. MC MURRAY:

Let's take a short break here.

l 18 (Recess.)

19 BY MR. MC MURRAY:

I, l

20 Q

You are going to be discussing the equipment-to be

{

21 used in the monitoring process, correct?

i 22 A

Yes.

j l

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1 Q

What are the monitors and the probes that will be 2

used for monitoring evacuees?

3 A

The initial monitoring?

4 Q

Yes.

4 5

A The RM 14 radiation meter, which is a count rate 6

meter, and the HP 260 pancake probe.

7 Q

Are those the only pieces of equipment that are 8

going to be used for the initial monitoring?

j 9

A Yes.

J 1

10 Q

When you say " initial monitoring," you are talking 11 about the monitoring that is conducted to determine if people

(}

r 12 are contaminated or not?

13 A

In the cars?

i 14 Q

In the cars, right.

15 A

And used in conjunction with the swipes that are

(

1 16 taken of the outside of the cars.

17 Q

I thought you mentioned another piece of equipment j

18 with a long handle?

19 A

That is the HP 260.

I 20 Q

Okay.

Who makes the RM 14?

21 A

The Eberline Company, E-b-e-r-1-i-n-e.

22 Q

Was it your decision that the RM 14 meter should

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1 be used?

2 A

It was my recommendation that the RM 14 meter be 3

continued to be used.

4 Q

And why is that?

5 A

Because of its adequate performance 6

characteristics.

7 Q

There are more state of the art monitors available 8

on the market; is that correct?

9 A

Depends what you mean by " state of the art."

Do 10 you mean digital readout and that type of thing?

11 Q

Yes.

12 A

Yes, that's correct.

13 Q

Is it your opinion that the RM 14 is just as 14 accurate as more modern pieces of equipment?

15 A

Yes.

16 Q

What's the basis for that?

17 A

The way it would be used, we looked at the other 18 types of equipment manufactured by Eberline and other 19 manufacturers.

One concern that we had was the really just 20 basically the human factors aspect, and we found, for 21 instance, with digital readout equipment that not only 22 trained monitoring people, but also health physics

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1 technicians in nuclear power plants who I talked to, did not 2

like -- in all cases did not like the digital readout.

3 Q

Why is that?

4 A

Because of the difficulty of interpreting a 5

fluctuating number on the digital readout.

Although there 6

would be some fluctuation on the analog readout, they felt i

7 more comfortable with it, and I believe we did not want to 8

throw a curve at our LERIO people and introduce something 9

totally different that if a health physicist technician feels 10 uncomfortable with, how could we expect somebody else to, feel i,

11 comfortable with.

}

12 Q

What are the other pieces of equipment that will 13 be used for subsequent monitoring?

14 A

The RM 14 and either the HP 270 or the HP 210 15 probes.

16 Q

But they will not be used in any way for the 17 initial monitoring, the HP 210 and HP 270?'

18 A

I don't believe so.

The advantage of the HP 260 19 over the HP 210 is basically the handle, the length of the 20 handle.

Other than that, they have basically the same 21 performance characteristics.

22 Q

Can the equipment to be used in the initial

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,1 monitoring in the parking lots be used adequately outdoors?

2 A

Yes.

I 3

Q Under all conditions outdoors?

4 A

In terms of temperature, we have looked at that.

5 The manufacturer has represented that they can operate under 6

a wide range of temperature, and humidity conditions, and my 7

own experience, where I have seen that type of i

8 instrumentation used in foul weather, it has performed 9

adequately.

10 Q

When you say " foul weather"'are you talking about 11 rain?

{

12 A

Talking about winter conditions where it is a 13 combination of snow or wet snow.

14 i

Q Do you have to make any adjustments in 15 interpreting the readings between good weather and foul 16 weather?

17 A

No.

18 Q

Have you considered whether or not monitoring in 19 the parking lots could be conducted adequately in snowy 20 conditions?

21 A

My own conclusion is, yes, it can be conducted 22 under snowy conditions and rainy conditions.

I have seen it O

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done that way.

2 Q

And when was that that you saw it done that way?

I have seen It done in an emergency situation.

3 A

4 Q

Where?

5 A

Up at Ginna station.

6 Q

Is that on sith emergency or off site emergency?

7 A

Both.

8 Q

And who was being monitored, the public or.--

9 A

Evacuees from the power plant.

10 Q

Under snowy conditi~ons, isn't it possible that (V

^

T 11 contamination could settle under the snow and make it 12 difficult to determine whether the car was contaminated or

~

13 the ground was contaminated?

14 A

You mean close in to a plant?

15 Q

Well, no, let's look at a reception center.

If 16 you had a car that was contaminated, some of that 17 contamination came off, fell onto the snow, and another car 18 pulled up, isn't it likely that you would be unable to tell 19 whether or not you were getting an accurate reading of the 20 second car due to the contamination that had been deposited 21 on the ground?

1 22 A

Well, the HP probes that I'm talking about are O

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1

' basically, sensitive to beta radiation,-and when you are 2

taking a close reading, a half inch to an inch away, you look 3

at the beta radiation coming from that surface itself, so I-4 believe you could make the distinction.

5 Q

You said you believe you_could make the s ti.

6 distinction, but you have to have some knowledge of -- would 7

.you have to have some knowledge beyond what the LERIO 8

monitoring personnel get in their training in order to make 9

that distinction?

10 A

No, I don't think so.

11 Q

douldn't the contamination deposited on the ground 12 raise background levels?

13 A

It may.

14 Q

And couldn't --

15 A

There are contamination criteria, background 16 criteria in the procedure.

17 Q

Does the equipment run on batteries?

18 A

Yes, it does.

It also also charged through AC, 19 but there are rechargeable batteries.

r 20 Q

How long does a battery last?

21 A

I believe -- depending on the type of battery, I 22 believe they can run anywhere from 40 to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

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1 Q

40 being the lowest range?

2 A

I think there's'a type of battery which would run 3

40 to'50, but I believe there's another rechargeable battery 4

that extends beyond that.

5 Q

How about the batteries LILCO is using?

6 A

I think -- they are probably 40 to 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> is my 7

understanding without needing to be recharged.

8 Q

Are you going to be_ talking about~the adequacy of 9

the staffing at the reception centers?

10 A

The staffing for performing monitoring and 11 decontamination?

{

12 Q

Yes.

13 A

I will be able to comment on how many people are 14 available in the plan.

i l

15 Q

How many people are available in the plan?

16 A

I understand that there is approximately 116 17 radiation monitors 1for general. initial monitoring, and 18 approximately 12 others for buses, and a 50-percent excess 19 over that.

20 Q

Are you saying that the reception centers when 21 fully staffed would have 116 radiation monitors at the l

22 various stations being set up at the reception centers?

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1 A

Yes, but initially, my understanding is 150 2

percent of that staffing level would be called upon to 3

report, depending upon the situation.

Some would be sent.

4 home and some would be asked to stay, depending on what the i

5 level of the problem would be.

6 Q

Have you done any analyses to determine how 7

quickly monitoring personnel can arrive at the reception 8

centers?

1 9

A I have not.

10 Q

Has anybody at LERIO?

11 A

I am not sure.

12 Q

Has anyone determined whether the reception 13 centers will be fully staffed by the time evacuees arrive?

14 A

Are you saying has anyone determined that?

15 Q

Has anyone determined that, or analyzed that?

16 A

Well, my awareness of the way the plan works is 17 that full reporting of the reception center staff would 18 happen at the site area emergency.

Typically at a site area 19 emergency, there are no protective actions at all that are i

20 recommended for the general public, so given that, we would 21 have an evacuation criteria for staffing the centers in 22.

advance of any order that's given for protective actions.

. )

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Q But you don't know of any analyses which have been 2

done to determine how quickly the reception centers can be 3

brought up to full staff?

4 A

I'm not aware of any analyses, but.just the logic 5

of what I.have just said underlies the approach taken.

6 Q

Apparently you are going to be testifying on the 7

monitoring of the people who are coming in on buses to the 8

Hicksville center; is that correct?

9 A

I believe so, yes.

10 Q

Now those people are going to get a more complete 11 scan of the body than the people in the cars; is that 12 correct?

13 A

What do you mean by "more complete"?

14 Q

Well, we can go to the --

15 A

Will you show me the procedure?

16 Q

Let me refer you to OPIP 3.9.2, and this is as 17 that is reflected in the February 20 draft procedures.

Do 18 you still have that in front of you?

Yes, you do.

Page 9-B 19 of 49.

If you look under section 5.6.7, there is a scan of 20 an individual which should take about 90 seconds.

Do you see 21 that?

j 22 A

Yes.

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1 Q

The 5.6.7 sets out the procedures for monitoring 2

people arriving by bus; correct?

3 A

Yes.

4 Q

The 90-second scan is a longer amount of time than 5

individuals arriving by car are scanned; correct?

6 A

Yes.

7 Q

And why is that?

8 A

I believe the reason that was carried over from a 9

former procedure was that the 90-second period was a number 10 in duration that monitoring people were familiar with, and I

{}

don't see any problem with the fact that that's any longer at 11 12 all.

We're still focusing, as you can see, on the same areas 13 of the body.

We have tried to maintain some continuity with 14 what was being done before.

15 Q

Doesn't the longer scanning time indicate that 16 there's a more -- that will there are more areas of the body i

17 being monitored?

18 A

Possibly.

As I said before, even with the other 19 car occupants that we are effectively monitoring more than 20 just the hands, feet, head and shoulders by virtue of how we 21 are doing the monitoring.

90 seconds is conservative.

I 22 don't see any problem with either method.

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Q Does it concern you.that the monitoring of the 2

individuals arriving by bus is more complete than the 3

monitoring being given to people arriving in vehicles?

4 A

I_think both are acceptable.

5 Q

Are you-going to be testifying at all about I

6 whether or not the bringing the evacuees without cars to the 7

Hicksville center will-have any impact on the time required 8

to monitor the people arriving by car?

9 A

Would you repeat that again?

I'm not sure I 10 understand.

11 Q

Yes.

There are two functions I'm talking about

{}

12 that are going to be conducted at the Hicksville facility.

13 One is to monitor and maybe decontaminate people arriving by 14 bus, and the other is to monitor and maybe decontaminate the 15 people arriving by their own private vehicles.

Do you 16 understand that?

17 A

Yes.

18 Q

Okay, will you be giving any opinions on whether 19 one function may have an impact on the effectiveness of the 20 other function?

21 a

I guess I don't see a problem in bringing both 22 types of evacuees there.

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Q Do you know where the bus evacuees are going to be 2

monitored?

4 3

A Well, in the vehicle.

4 Q

-In the bus?

5 A

As you see right there in the procedure.

t 6

Q Where in the Hicksville site is this going to be 7

done,_do you know?

8 A

I believe it is reflected in the map that we were 9

looking at before, north of -- I think it was north of the 10 transportation garage.

11 Q

I'm looking at page 21 now of the February 20 12 draft revision.

Is it going to be conducted at the place 13 that is marked bus stop on that diagram?

14 A

That's my understanding.

15 Q

By the way, Hicksville, where are contaminated 16 cars going to be parked, looking at this diagram?

17 A

The initial parking area would be north of where 18 you see the decontamination trailers, and west of the 19 transportation garage.

20 Q

Is that indicated on this diagram, or you just 21 know that?

l 22 A

That's the explanation that was provided to me by ACE FEDLmAL REPORTERS, INC.

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the LERIO staff.

-2 Q

Do you know how many cars that particular area can 3

handle?

4 A

I don't know exactly, no.

5 Q

Is it more than 10?

6 A

Yes.

J 7

Q More than 100?

8 A

Possibly.

9 Q

Are there backup cites for parking contaminated i

10 vehicles?

11 A

I have discussed that with the LERIO people, and

(}

12 when I was out there, they indicated the presence of the 13 balance fields, the lawas that you see, one lawn you see i

14 indicated to the east and to the west of the recharge basin, 15 and there's another lawn next to area A, and I believe there 16 are some -- there's an additional lawn in front of the main 17 office building, and when we walked around, there were some 18 very, very large areas that were pointed out in these 19 vicinities where backup areas could be designated.

l i

20 Q

Let's move back a page.

There's a diagram of the 21 Bellmore reception center.

Can you tell me where j

22 contaminated vehicles would be parked at the Bellmore 1

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reception center?

2 A

I believe in the vicinity of the decontamination 3

trailer, north of it.

4

-Q Do you know how much area there is there for 5

5 parking cars?

6 A

Not in terms of numbers of cars, no, I don't.

7 Q

It is not as big as Hicksville, correct?

j 8

A That particular area?

It may be a bit smaller.

9 Q

Can you give me a ballpark figure of about how 10 many cars you think that area could hold?

11 A

No, I can't.

12 Q

Have you determined whether that area is 13 adequately large?

14 A

I don't know what you mean by adequate.

i 15 Q

Do you have any estimates in your mind of how much 16 parking space is needed for storing contaminated vehicles at 17 each one of the reception centers?

l 18 A

I don't have specific numbers of cars, no.

When I i

19 went to the facility and I asked where the location would be, 20 it was pointed out to me, and it looked like there was space f

21 for contaminated vehicles there.

It looked fine.

I asked l

22 where could additional vehicles be placed, and it appeared O

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that areas designated for LILCO vehicles could be made 2

available, so extra area on the site could be made available 3

if need be for additional car space.

4 Q

Well, the area that you have pointed out is next 5

to the transportation garage; is that correct?

6 A

North of the decontamination trailer, yes.

7 Q

Does it concern you that contaminated cars would 8

be stored next to the place where people are waiting for 9

decontamination?

10 A

No, not as long as the people weren't routed 11 directly through the area where the cars were.

I see no

{}

12 problem in being able to designate a pathway to and from if 13 the transportation garage was needed.

14 Q

Well, are there any provisions that you know of 15 for providing a safe route between the transportation garage 16 and the decontamination trailer?

17 A

Well, I believe in the training that's being done, 18 if there was a necessity to use any additional buildings, 19 that our LERIO people have been through this a number of 20 times and have gotten quite good at designating controlled 21 areas, and I'm not sure the procedure reflects the specific, 22 but in knowing how they operate, they are good at keeping

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1 people from walking through contaminated areas.

2 Q

How much space would you want between a path for l

3 people to traverse between the decontamination trailers and-4 the transportation garage and contaminated cars?

5 A

Well, I would like to see them segregated by 6

stanchions and ropes so they are not directly walking through 7

it.

8 Q

How much physical space would be, like, between 9

those areas?

10 A

I would be looking through a pathway of several 11 feet across where people could obviously walk that would be-12 separated by a rope and stanchions from another contaminated 13 area.

I don't think it would necessarily take a large amount 14 of space at all.

15 Q

Where are the other available areas for parking 16 contaminated cars at Bellmore that you know of?

17 A

That I know of, one option may be where the LILCO 18 vehicles would be parked.

There are some designated parking, 19 I believe, east of the decontamination trailer that has LILCO 20 vehicles, but those vehicles could be moved out.

My 21 understanding of the concept in talking to the LERIO people 22 is any LILCO vehicles that are on site can be moved out to O

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1 other locations to make additional space for contaminated 2

vehicles.

3 Q

Let's look at the Roslyn site, which is three or 4

four pages back.

I'm looking now at page 25, I believe.

5 Where are the contaminated vehicles going to be parked at 6

Roslyn?

7 A

I believe in the vicinity of the decontamination 8

trailer.

9 Q

When you say "in the vicinity," where do you mean, 10 north or south of it?

11 A

I believe south of it.

12 Q

So between the warehouse and the decontamination 13 trailer?

14 A

I believe that's one location that's possible for 15 them to go, yes.

16 Q

When you say south, are you talking south of where 17 i' says " storage," or right between the warehouse and the 18 decontamination center?

19 A

Between the warehouse and the decontamination 20 trailer.

21 Q

Isn't that, though, doesn't that directly cut 22 through the path people will take from the warehouse to the

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decontamination trailer?

2 A

If they were to use the warehouse and 3

decontamination trailer, that's true.

I was also referring, 4

there are other buildings pot.3ible such as the Prate office 5

building that could be used.

6 Q

Are you familiar with what spaces in the Prate j

7 office building are available for holding people?

8 A

I have walked through it.

There appear to be I

9 rooms, locker rooms available, places where people can sit.

10 It is heated.

It is lighted.

)

11 Q

How many monitors are going to be available to 12 monitor people coming in on buses, do you know?

13 A

At Hicksville?

14 Q

That's right.

15 A

I believe 12, with extra available if needed, as I 16 said, there's 150 percent capability.

J 17 Q

I believe one of the issues that, at least in the 18 answers to interrogatories, you are to be an expert on was i

19 whether the proposal to send evacuees to parking lots could 20 and would be implemented in a way that.would protect the j

21 public health.

Do you recall that?

22 A

What do you mean by that," sending evacuees to the

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1 parking lots"?

l 2

Q Let me show you page 3 of answers to 3

interrogatories submitted to LILCO and answered by LILCo.

4 The bottom paragraph states that you are going to be 5

testifying on a number of issues, and one of them is that the 6

proposal to send evacuees to LILCO parking lots could and 7

would be implemented so as to protect the public health and 8

safety.

Do you see that?

l 9

A Yes.

{

10 Q

Are you going to be testifying on anything more 11 than we've already discussed regarding the monitoring

(}

12 procedures and the decontamination procedures, or is there 13 some other issue that's involved there that we have not 14 discussed yet?

i 15 A

My understanding is that I would be testifying i

16 basically on the radiological aspects of the reception 17 centers, and in my mind that relates t' the monitoring and i

18 decontamination procedures that are being done.

19 Q

Are you going to be discussing the issue of the 20 20 percent planning basis that LILCO sets out that's in its plan 4

]

l 21 and the rationale for that planning basis?

If not, we won't 1

22 get into it.

If you are, then I have some questions on it.

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A I don't believe I'm designated as the key expert 2

on the 20 percent as the basis.

3 Q

Are you familiar with the rationale behind the 20 4

percent basis?

5 A

I'm familiar with the rationale _provided in the 6

FEMA letter that came out in late 1985.

7 Q

What's your understanding of that rationale?

8 A

That la a variety of different natural and 9

technological disasters, that a range of percentage can occur 10 of people who would be seeking shelter, and there was a 11 comment made that that would range anywhere from about 12 3 percent, I believe, to about 20 percent, and it was felt 13 that because of a radiological emergency it might create some 14 concerns among the public to seek shelter and want to be 15 monitored, that it would be prudent for planning purposes to 16 use a figure toward the upper end of that range or around 20 17 percent.

Furthermore, above that, then arrangements could be 4

18 made on an ad hoc basis, drawing upon federal and other 19 resources to do more extensive monitoring if necessary, 20 Q

Well, regarding the 20 percent figure, are you in 21 agreement that the rationale stated by FEMA supports a 20 I

22 percent planning basis?

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1 A

I think that's a reasonable number in my own view.

}

2 Q

My question is, does the rationale set out by FEMA 3

support the 20 percent figure?

4 A

I believe so.

5 Q

Do you believe that the rationale set out by FEMA 6

constitutes a reasonable basis for establishing a 20 percent 7

figure?

3 i

8 A

I believe it is reasonable, yes.

j 9

Q Well, you will agree, won't you, that the I

10 functions of monitoring and the functions of sheltering are 11 two different things; correct?

[}

12 A

But they are very much connected in the context of j

i 13 what we're talking about, i

i 14 Q

Is sheltering going to be provided at the 15 reception centers?

16 A

No.

17 Q

And in fact, isn't it true that under the LILCO 18 plan, people who are in a particular zone where there may 19 have been some sort of deposition of radionuclides will be 1

20 ordered to go to the reception centers for monitoring before 21 going on their way elsewhere; correct?

i 22 A

If there's a determination that there was

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significant deposition, yes, there may be designation of 1

2 specific zones to be sure they go to the reception centers.

3 Q

And they will be told to go to the reception J

4 centers regardless of whether they need shelter; correct?

5 A

Over and above sheltering?

Possibly, yes.

6 Q

Well, under the LILCO plan, people are not told to 7

go to the reception centers only if they need shelter; right?

8 A

Say that again.

9 Q

Understand the LILCO plan, people will be told to 10 go to the reception centers not just for sheltering but for l

11 monitoring; correct?

12 A

If they need monitoring, yes.

13 Q

If they need monitoring, and the plan does not say 14 that only people who need sheltering should go to the 15 reception centers; right?

16 A

Please repeat that one more time.

17 MR. MC MURRAY:

If you would read that bacc, i

18 please.

19 (The reporter read the record as requested. )

20 BY MR. MC MURRAY:

21 Q

Let me restate the question.

4 l

22 The plan calls for people in the zone at risk,

(

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where there may be deposition, to go to the reception centers 2

regardless of whether they need shelter; correct?

3 A

If they are told to do so.

It depends on the 4

situation.

-5 Q

But there's'not a distinction made between whether 6

they need shelter or they don't need shelter, correct?

7 A

In a situation where there is a clear indication 8

that there may be deposition in some of the downwind zones, 9

then there would be a follow-up message that states that 10 people would go to the reception centers for monitoring.

i 11 Q

Okay, and it would not --

I 12 A

Initially that's not the case.

13 Q

It would not exclude from that message people who I

14 don't need shelter, correct?

1 l

15 A

That's correct.

I 16 Q

Now, given that, how does FEMA's rationale, which 17 is based on sheltering behavior, support a 20 percent 18 planning basis for people who require monitoring?

f 19 A

Because the basic approach used in the LERIO plan 20 is consistent with any other plan.

That is, once an 21 evacuation order is given, people are advised as to where the 1

22 reception centers are, and it is very likely that a much

(:)

i l

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smaller fraction of the total EPZ population will really 2

arrive at the reception centers.

3 Q

Is that because -- go ahead, i

4 A

No, go ahead.

5 Q

Is that because less than the total EPZ population 6

may be in an area where there was deposition; is that what 7

you are saying?

8 A

Just following the general evacuation order.

The 9

order is given for people to leave the areas that they are 10 in, and to advise them that these reception centers are 11 available, okay, and people would then go to those reception 12 centers to be monitored prior to needing any other 13 sheltering.

14 Q

Are you talking about a situation where there was 15 not a direct order to go to the reception centers and seek 16 monitoring?

17 A

The general plan is to announce to the public that 18 the reception centers are there, to point out where they are, 19 and make them available for the public to come to for 20 registration and monitoring, and then with additional help, i

21 to get them to congregate care centers if they need them.

22 Q

That's regardless of whether or not there's an O

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[

1 actual order to the people to go seek monitoring?

Is that i

2 what you are talking about?

1, 3

A Yes, the initial action is a general announcement 4

to evacuate, period, of all of the zones, and the assumption 5

is that of that total number of people who are evacuating, 6

about 20 percent,'20 percent or possibly less, would be 7

actually showing up at the reception centers to De registered 8

and monitored.

9 Q

That forms the basis for the 20 percent figure in 10 your mind?

i 11 A

Basically, yes.

}

]

12 Q

Well, you are aware, though, that an initial or an 1

i 13 evacuation order may be coupled under the LILCO plan with a l

14 specific recommendation to people in specific zones to go to 15 the reception centers; is that correct?

16 A

For the condition where there's an indication of a l

17 large particulate release, yes.

I think that's quite i

f 18 prudent, and I have not seen that done in 64ery plan.

19 Q

so that the LILCO plan itself can, by ordering

{

20 people specifically to go to the reception centers, can l

21 create circumstances where more than 20 percent of the l

)

22 population is going to show up at the reception centers; is i

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1 that correct?

2 A

That is possible.

3 Q

Do you believe it is unlikely?

4 A

Yes, I believe it is unlikely.

5 Q

Why is that?

6 A

Because I don't believe in the realm of accidents 7

tisat we're talking about that we're likely to have large 8

amounts of particulate or iodine released.

I believe that we 9

will not get into that type of a release situation.

10 Q

You have been involved in the exercise litigation 11 in this overall Shoreham proceeding, haven't you?

12 A

Yes, but I was just thinking of my last answer, 13 too, and I wanted to add one more thing.

In the 14 decision-making process, even for a large-scale release where 15 there might be some particulate, the decision-making is 16 attempted to happen early enough before a release is to take 17 place to avoid evacuating people through the plume to begin 18 with, to get them out early and --

19 Q

Which has what result?

20 A

Has what result?

It has -- if we can get people 21 out early before the release, then we don't have to follow up 22 with the specific recommendation of having them go to the O

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reception centers for monitoring.

2 Q

In your opinion, is it possible that people from 3

outside the EPZ could go to the reception centers seeking i

4 monitoring even though they might not have an objective 5

reason to seek such monitoring?

6 A

I don't know.

7 Q

Do you believe that that's a figure that should be i

8 factored into LILCO's planning basis?

i 9

A From my own experience?

I don't personally think l

10 it is a problem significant enough to have to worry about, t

11 but that's as far as I want to comment on it.

{}

12 Q

You are basing your answer on your personal 13 experience, which doesn't involve a large scale nuclear 14 emergency, does it?

15 A

It involves a nuclear emergency with releases 16 off-site, and seeing very rational general public respond to 17 it.

18 Q

Are you talking about Ginna?

19 A

Yes.

20 Q

And was there an off-site -- was there a i

21 deposition of radioactive material off-site there?

22 A

Yes, there was.

I.

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Q What were the people advised to do this?

2 A

Basically nothing.

3 Q

Were they advised to report to reception centers?

'4 A

No.

5 Q

Did that emergency get up to a general emergency?

6 A

No, it did not.

7 Q

Site area?

8 A

Yes.

9 Q

You mentioned before, I think, that LILCO's 10 monitoring staff might be supplemented by INPO?

(~g 11 A

Yes.

V 12 Q

Do you know whether the sites are physically 13 capable of handling additional monitoring stations?

14 A

I believe they are.

15 Q

How would -- are there any plans for where INPO or 16 monitors from other organizations would set up?

17 A

Are there any plans existing?

I don't think so.

18 Are there plans in the works?

I'm not sure.

19 Q

Are you aware of whether there have been any 20 further revisions to the February 20 draft of the LILCO plan?

21 A

Am I aware of any revisions to that?

22 Q

Yes.

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1 A

No, I'm not aware.

2 Q

Have you discussed with anyone whether revisions i

3 are contemplated to that draft?

4 4

A Just in a very, very general sense.

i.

5 Q

And what is that general sense that you have?

l 6

A Since it is a draft, that revisions may happen.

i 7

Q But that's the extent of your knowledge?

8 A

Yes.

9 Q

Do you intend to visit the sites again?

i 10 A

I have not decided.

i 11 Q

When do you intend to begin writing your 12 testimony?

13 A

I believe within the next couple of weeks.

14 Q

Can you tell me whether there are any particular a

15 documents, other than the LILCO plan and procedures, that you 16 intend to rely on in preparing your testimony?

17 A

I'm not sure about that yet.

18 Q

Do you intend to perform any additional analyses l

19 or studies before you prepare your testimony?

20 A

I don't know.

i 21 Q

It is possible?

22 A

It is possible.

l J

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Q.

Are any more time trials in the works?

t 2

A Not that I'm aware of.

3 Q

Is there any particular piece of literature that 4

you would intend to rely on in your testimony?

5 A

Not that I can think of at this time.

6 MR. MC MURRAY:

I have no further questions, 7

Mr. Watts.

Thank you.

1 8

MS. LEUGERS:

I have no questions.

9 (Whereupon, at 5 :35 p.m., the deposition was 10 concluded.)

11 12 13 14 15 16 17 i

l 18 19 20 l

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CERTIFICATE OF NOTARY PUBLIC & REPORTER 128 O

I, KATHIE S. WELLER the officer. before whom the foregoing deposition was taken, do hereby certify

that, the witness whose testimony appears in the foregoing deposition was duly sworn by me; that the testimony of said witness was taken in shorthand and thereafter reduced to typewriting by me or under my direction; that said deposition is a true record 4

i of the testimony given by said witness; that I am i

neither counsel

for, related to, nor employed by any of the parties to the action in which this i

deposition was taken;

and, further, that I am not i

a relative or employee of any attorney or counsel employed by the parties

hereto, nor financially i

or otherwise interested in the outcome of this action.

t 3

asA;}Lh m Notary Public in and for the District of Columbia l

l l

l My Commission Expires NOVEMBER 14, 1989 i

i I

l i

i e

l

.i l

i i O i

f

. / e 2 -- 2 e - e r FRI 00332 SNPC EOF p,og 1

February 20, 1987

(~m.

)

Memo To File On February 10, 1987 a group of six (6) LERO Radiation Monitoring /

Decontamination personnel and myself conducted evacuee.and vehicle monitoring trials.

Monitoring was nerformed by two (2)c.conitoring personnel of the hands, feet, head and shoulders of each vehicle passenger, and a large area swipe of the vehicle hood and one 4

wheel well.

The trials were timed from the time the vehicle stopped at the monitoring station to the time it was directed to oroceed away from the monitoring station.

Position assign.

ments for all oersonnel involved in trials were rotated.

Time trials were performed on the following vehicles:

1982 Nissan Station Wagon (4-door) 1985 Dodge Ram Charger (2-door) 1986 Yugo (2-door) 1971 Oldsmobile Cutlas (2-door)

Trial 1 Vehicle Type:

Nissan Wagon (4-door)

Number of Passengers:

4 Passenger Arrangement:

2 in front, 2 in back Total Time:

100 seconds Trial 2 Vehicle Type:

Dodge Ram Charger (2-door)

Number of Passengers:

5 Passenger Arrangement:

2 in front, 3 in back Total Time:

65 seconds Note:

Front passengers had to get out of vehicle, monitors had to get inside vehicle to monitor passengers in back seat.

, Trial 3 Vehicle Type:

Yugo (2-door)

Number of Passengers:

4

?assenger Arrangement:

2 in front, 2 in back Total Time:

57 seconds Trial 4 Vehicle Type Olds Cutlas Number Of Passengers:

3

()

Passenger Arrangement:

2 in front, 1 in back Total Time:

65 seconds Exeeemer 1

w rs

Acv 6s EFi.

• i t-c. e. r.-

64V 4 4 46-:.

.:::4.:;a e2-20-e7 FRI 00:U3 CNPO EOF P '. O s c,-

l 2-C Trial 5 Vehicle Type:

Olds Cutlas Number of passengers:

1 Passenger Arrangement:

1 in front Total Time:

55 seconds Trial 6 Vehicle Type:

Dodge Ram Charger Number of passengers:

3 Passenger Arrangement:

2 in front, 1 in back Total time:

85 seconds Note:

One front passenger had to get out of vehicle, monitor had to get inside to monitor back passenger.

Trial 7 Vehicle Type:

Nissan Wagon (4-door)

Number of passengers:

2 Passenger Arrangement:

2 in front Total Time:

45 seconds The average total time for these trials was 67.5 seconds.

(

Diane Driekorn DD/1jy cc:

J. Christman R. Watts B. Aidikoff 1

O l

l

g **:

2 ExHe#8T i

i

/

l LJ rQ

\\<"

January 5, 1987 cc. B.Aidokoff D.Dreikcen To: D.Crocker R.NattsfWe From:

Subject:

Summ.a'ry of Time Trials for Vehiclo Occupant Monitoring

/

i This memo summart:es the time measurements performed today to determine how long it would require to monitor all vehicle occupants, considering different vehicle designs. Timo trials were performed on the following vehicles:

a. 1986 Chrysler LeBaron (4-door) b.

1985 Suburu GL 4WD (2-door) c.

1985 Dodge Caravan (2-door, with sliding sido door)

TRIA

---

L

-1 :'

Vehicle typer Suburu, 2-door Passenger Arrangement: 1 person in front, 1 person directly in back Areas Monitored:

Both feet, both knees, both hands Activi ties Ti.ned:

Monitoring only Tetal Time:

1:15 (Monitor A) 1:16 (same repeatec by Monitor B)

IBIBL 2:

Vehicle type:

Suburu, 2-door Passenger Arrangement: 1 person in front, 1 person directly in back Areas Moni tored:

Both feet, both hands, sweep ci shoulders, neck, head

()

Activities Timed:

Monitoring only Total Time:

1:00 (Monitor A) 1:09 (same repeated by Monitor B)

I If l

~

s\\

pA IBl& 2:

1 Q

Vehicle type:

Dodge Caravan, 2-door w/ slidir.g door Passenger Arrangement: 1 passenger in front, 1 person in second back seat (driver side), 2 people in third back seat.

Areas Monitored:

Both feet, both hands, swaep of shoulders, neck, head Activities Timed:

Monitoring only Total Time:

2:12 (Monitor A, all 4 r.icerc) 1:36 (Monitor A, 3 back riders only) 1:34 (Monitor A, 3 back riders only, using ruler to simulate HP-260) 18186 di Vehicle type:

Chrysler LeBaron, 4-door Passenger Arrangement: 1 person in front, 1 person dire =tly in back Areas Monitcred:

Both feet, both hands sweep of shoulders, neck, head Activities Timed:

Vehicle pulls up to cone, open dcor, perform monitoring in car, closa coor, car pulls away Total Ti me:

1:22 (Monitor A)

IBIBL 5:

Vehicle type:

Suburu, 2-door Passenger Arrangement: 1 person in front, 1 person directly in back Areas Monitored:

Both feet, both hands, sweep of shoulders, neck, head Activities Timed:

l (]h Vehicle pulls up to cone, cpen door, have 2 people step out of one side, i

monitor 2 people, 2 people get back in, close door, car pulls away Total Times 1:29 (Monitor A)

.