ML20209E825

Deposition of F Rowan.* Transcript of F Rowan 870106 Deposition in Washington,Dc.Related Correspondence

ML20209E825
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/06/1987
From:	Rowan F SUFFOLK COUNTY, NY
To:
References
CON-#287-3229 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8704300130
Download: ML20209E825 (76)

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OF PRCCEEDINGSSHRC l

~87 APR 28 P4 :27 i

OFFtE O ~

l UNITED STATES OF AMERICA t

GOCdE.ii:.G '. :3 m::

i-NUCLEAR REGULATORY COMMISSION IBA"C" l

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OYG NKL il

___________________x In the Matter of:

Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY (EP Exercise)

(Shoreham Nuclear Power Station, (ASLBP No. 86-533-01-OL)

Unit 1)

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x

[')T DEPOSITION OF FORD ROWAN Washington, D.

C.

Tuesday, January 6, 1987 ACE-FEDERAL REPORTERS, INC.

Stenotyiv Rqvrters 444 North Capitol Street Washington, D.C. 20001 (202) M7-3700 Nationwide Coverage 800-336-6646 8704300130 870106 PDR ADOCK 05000322 T

PDR

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Deposition of FORD R0WAN, Washington DC, 6 January 1987.

s LILCO, NRC ASLB 50-322-OL-5.

. a. :

CORRECTIONS TO DEPOSITION PM Line Correction:

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1 UNITED STATES OF AMERICA 1

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NUCLEAR REGUALTORY COMMISSION

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3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4

- - - - - - - - - - - - - - - - -x 5

In the Matter of:

6 LONG ISLAND LIGHTING COMPANY Docket No. 50-322-OL-5 7

(EP Exercise)

(Shoreham Nuclear Power Station, :

8 Unit 1)

(ASLBP No. 86-533-01-OL) 9

---

x A

10 DEPOSITION OF FORD RON N 11 Washington, D.

C.

12 Tuesday, January 6, 1987

(

\\'

Deposition of FORD ROWEN, called for-examination pursuant 13 to notice of deposition, at the law offices of Kirkpatrick and 4

Lockhart, 1800 M Street, N.W.,

Ninth Floor, at 11:10 a.m.

before WENDY S.

COX, a Notary Public within and for the District 16 of Columbia, when were present on behalf of the respective 17 parties:

18 CHRISTOPHER M. McMURRAY, ESQ.

19 Kirkpatrick & Lockhart South Lobby - Ninth Floor 20 1800 M Street, N.W.

Washington, D. C.

20036-5891 On behalf of Suffolk County.

21 22

-- continued --

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ACE-FEDERAL REPORTERS, INC.

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2

-1 APPEARANCES:

2 KATHY McCLESKEY, ESQ.

DONALD P.

IRWIN, ESQ.

3 Hunton & Williams 707 East Main Street 4

P.O. Box 1535 Richmond, Virginia 23212 5

On behalf of Long Island Lighting Company.

RICHARD J.

ZAHNLEUTER, ESQ.

Deputy Special Counsel to 7

the Governor Executive Chamber 8

Capitol, Room 229 Albany, New York 12224 9

on behalf of the State of New York.

10 11 12

~

O 13 14 15 16 17 18 19 20 I

21 22-ACE FEDERAL REPbRTERS, INC.

j M.347-3700 Nationwide Coverage 800 33M686

5 2

__1 El El 2

WITNESS EXAMINATION 3

Ford Rowan 4

by Ms. McCleskey 4

5 6

7 8

9 10 11 l

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1 P R O_ C E R D 1 H G S, 2

Whereupon, 3

SPENCER FORD HOWAN, JR.

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

was examined and testified as fo))ows:

6 EXAMINATION i

7 HY MS. MC CLESKEY:

)

0 Q

Mr. Rowan, my name is Kathy McCleskey.

I 9

represent Long Island Lighting Company and I am going to be 10 asking you some questions today about the February 13 i

11 exercise of the LILCO plan.

j 12 Would you please state you're name and current 13 address for the record.

14 A

My full legal name is Spencer, S-p-e-n-c-e-r, Ford 15 Rowan, Jr.

Since birth I have been known by my middle name 16 and Howan.

I am currently an attorney and consu] tant, my 3

j 17 business address is 1000 Vermont avenue, Northwest, suite 1

18 1000.

i 19 Q

Were you at the February 13 exercice?

i 20 A

No.

l 1

21 O

Have you reviewed anything about the exercise?

i o i

22 A

Yes.

I have been provided_some documents, f

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1 including, among other things, the original plan, or a t least 2

a copy of it that I have been given, the EBS messages, the 3

news releases of the LERO group, L-E-R-0, the news releases 4

of LILCO, the FEMA assessment of the exercise, transcripts of 5

news conferences have also been given but have not had a 6

chance to look at. videotapes and audio tapes of t.he exercise 7

--- among other documen ts.

That's off the top of my head.

8 0

When you say " transcript.s of news conferences,"

9 what transcripts of what news conferences?

10 A

My understanding, having not looked at them, but

O 11 my understanding is that during the exercise, press briefings 12 were conducted, and that these were taped, and I have both 13 those tapes and a transcript that's been made from the tapes, t

1

]

14 but. that's my understanding.

Since I haven't had a chance to 15 look a t them, I am really not sure what is on them.

1 16 0

While you have received all of this information, 17 you haven't had a chance to look at the tapes or read the 18 transcripts.

11 ave you had a chance to read the plan?

19 MR. MC MURRAY:

I am not sure that fairly 20 characterizes his testimony.

llave you read the tra ns cri pts ?

1 2.1 Tile WITNESS:

No, I have not yet read the

o l

22 transcripts.

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1 HY MS. MC CLESKEY:

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2 Q

Have you read the plan?

j 3

A I have looked at the plan, one quick reading of

)

4 the plan, and I have read the EHS messages, but that was also i

5 one reading of it, and the two news releases, the FEMA i

i 6

report, and there were other documents that were given to N

4 7

me.

Unf ortuna tel y, I only began work on this right before 8

Christmas, and the holiday intervened.

So I am a lit.tJe late 7

l 9

coming to this exercise, the review of the exercise, no I l

10 can't give you definitive answers on all of the particulars, i O 11 I have only had one chance to read each of those things.

i 12 Q

When did you receive all of this information?

13 A

It was about mid-December.

I don't have the' exact j

14 date.

I would say in the context, December 10, somethinq 15 like that.

)

16 Q

Could you estimate about how much time you have i

17 spent thus far looking a t the materials?

18 A

ch, two days at work, I guess, spread over several i

19 !

calendar slays; but, you know, when you add it all up, j

i 20 probably two days of work.

Christmas intervened.

I J

21 Q

Two days' time?

O 1

22 l

A Yes.

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Q Ilave you done anything else other t.han review l

2 these materials to find out what happened at the exercise?

l 3

A No.

I intend to, but have not.

I 4

Q What do you intend to do?

8 4

l 5

A Well, in addition to thinking about it, I intend i

+

6 to try to find out if there was any news coverage of the 7

exercise itself, and to read and review any radio, TV or j

8 newspaper coverage of the exercise, an well as anything clac r

i 9

that was written about it, whether journalia tie or not, to j

10 try to get all the facts I can.

0 l

1 11 Q

Itave you talked with anyone about what. happened at 12 the exercise?

13 A

No, not yet.

14 0

Have you met with any other witnessen?

i i

15 A

No.

t 16 0

llave you ever been involved in developing i

17 scenarios for nuclear plant emergency drills or exercises?

18 A

No.

l 19 Q

llave you ever been an evaluator at that nort of l

20 drill or exercise?

i 21 A

No.

O j

22 O

llave you ever been a participant in that sort of.

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1 drill or exercise?

l 2

MR. MC MllRRAY:

Radiological nuclear responne?'

3 HY MS. MC CLESKEY:

4 Q

Nuclear plant emergency drill.

5 A

No.

6 Q

llave you ever attended, as an observer, any cort 7

of drill or exercise?

8 A

Well, real emergency, yes.

Three Mile Island.

9 Drill or exercise, no.

10 Q

llave you reviewed any ot.her exercise reports or 11 papers?

12 A

Regarding radiological?

i 13 Q

Yes.

14 A

No.

15 Q

Did you bring any documents with you today?

16 A

No.

Q Have you written anyt.hing about the February 13 17 l

10 exerclue?

19 A

No.

I 20 l

Q No memos, Jetters, papera of any kind?

21 A

No.

I intend to d ra f: t my thoughta, but T.

have not 9

22 i

done that yet.

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1 Q

You intend to draf t your thoughts in what form?

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2 A

In t.he form of testimony.

I 3

Q You mentioned TMI and I saw on your resume that 1'

4 you were involved in that.

Could you describe for me your 4

5 experience from beginning to end with the TMI accident.

j i

6 A

We)), I was a reporter for NHC News at the time; j

i 7

and this is from memory now.

I don't have my notes, and I 1

8 don't have any copies of scripts, but. I will try to i

9 reconstruct from memory, i

10 0

Sure.

O 11 A

On the first or second day, the assignment edi tor 12 at NBC told me that I would be heading to Pennsylvania, which i

13 I did, and I can't recall i f. I arrived the accond day or the i

i 14 night of the second day or the earlient, S:30 in the morning i

i 1

15 on the third day, but I was there on, I believe, March 29, l

I r

16 but it may have been March 30.

It's a little hard to t

17 reconstruct from memory and without going back and looking it

)

18 alI up, but I was t.here for three or four days, trom then on, 19 covering for NHC radio and television; and in the course of 20 that, covered news brictings by utility officials, Harold I

I 21 Denton of the NHC and Governor Thornburgh of Pennsylvania and

!O 22 his staff, and interviewed a numbeir of people in the ll i

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community.

2 0

!!ow much time did you spend there doing that?

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3 A

I think it was three or four days but when the i

1 j

4 adrenaline is flowing, sometimes time takes on its own 1

j 5

dimension, but I think it was three or four days.

)

i 6

Q What kind of notes do you have from those days?

j i

7 A

Unfortunately none.

j t

8 Q

None?

j 9

A A]l work product belongs to NBC, and they have 3 t, j

10 and I don't work there anymore, so I have had no reason to

!O 11 ask for it and I don't even know if they have kept i t or T

12 l where, but I didn't keep it.

13 0

So you haven't, in recent memory, you haven't f

14 reviewed these notes?

15 A

Oh, no, i

j 16 Q

Or the scripts?

t I

17 A

No.

4 l

18 Q

What was your work product from your days at TMI?

I 19 A

Work product would f all into several categories, 1

i 20 including on-the-air radio reports, on-the-air television c

21 reports, and interviews which would be used integrated into

!O 22 other reporters' radio und television reports, information s

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1 that was provided to producers for inclusion in bulletins; 1

2 and I gueun that's it.

There may be other things that don't I

3 come to mind, but the standard things that reporters do, 4

report, write, funnel i n f orma ti on, that sort of thing.

I i

S Q

You own copies of none of this?

l r

r 6

A No.

7 Q

Do you intend to rely on that experience in your H

testimony?

i t

9 A

It's impossible to divorce my experience from my 10 perception of Low reporters respond in both real emergencies i O t

i 11 and exercinen.

I i

12 Q

Do you intend ta review t he notes and scripta that i

i 13 NBC may have before you file your tes timony*?

l 14 A

I had not planned to ask for them.

[

15 Q

Did you write anything about TMI af ter it 16 happened?

1 17 A

For publ3 cation, in a printed document?

I i

l I

10 Q

Hight.

t 19 A

No.

j 20 Q

What. is your imprennion of how the emergency news 21 disucmination was handled at TMI?

O 22 A

In a word, badly.

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Q Would you describe in a little more detail why you 2

think it was bad?

1 3

A Well, for starters, the personnel connected with i

i 4

the utility were perceived as -- perceived by reporters, i

5 including myself, as covering up.information, of painting a i

6 rosier picture of events than was accurate, and of giving out 1,

j 7

mi s.i n f orma ti on.

That was the immediate first impression, 1

1 j

0 which was never, in the time I was there, shaken.

That

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9 impression stuck with me throughout.

1 s

1 10 Q

Since TMI, have you followed trends in the nuclear i

i O j

11 field in terms of changes in regulations that might aftect 12 emergency news dissemination?

]

13 A

Yes.

1 l

14 Q

What have you done to follow those trends?

1 l

l 15 A

Well, beginning with reading and following closely 16 the Kemeny Commission report, beginning with the Kemuny

]

17 Commission, and thereafter reading articles tha t appeared in i

i

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18 the popular press and in the journals of opinion, j

19 l

Q Ilave you ever read any NRC regulations or i

t f

20 guide.1ines about --

I 21-A Several years ago, yes.

'O 22

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Q Do you recall what they were?

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A No, not offhand.

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Did you read them -- when did you read them?

In j

l 3

connection with the TMI accident?

)

4 A

No, afterwards, out of persona] curiosity, rather a i

j S

than assignment by NBC.

i 6

0

'Are you aware of any changes coming out of the TMI

/

j 7

accident to those regulations?

8 A

My understanding is that the industry has t.ried to 1

j 9

institute many of the recommendations that the Kemeny j

10 Commission made.

That's my impression, yes.

O 1

11 Q

Can you describe for me what you know of what i

J 12 those changes and recommendations were?

13 A

Well, there are a number of them.

Off the top of 14 my head, the one that comes to mind first, because it's 1

15 apropos of our discussion today, is an effort to plan for i

l 16 emergencies, and prepare for them, so that one would be i

j 17 better prepared to cope with them in the event an emergency i

18 occurred.

t i

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Do you recall any specific changes regarding j

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20 dissemination of emergency information that may have been i

21 made?

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22 A

Well, I am afraid that it's difficult to respond i

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1 unless I know whether you are talking about the whole 4

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universe of changes or any that IIave been done by specific 3

companica or power plants or whatever.

I mean, I am not sure 4

4

-- I have a general impression.

Would you like me to share i

i S

that?

$I i

6 Q

Yes.

h 5

7 A

That many nucJear power facilities have indeed 11 instituted improvements in their abili ty to communicate with l

9 the surrounding communi ty and wi th the preau, that's my

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10 perception.

11 I have not been in a position as a reporter, or l

j l

12 former reporter now, to cover other nuclear plants, so I j

i i

i 13 can't say t. hat I have tested that perception.

i i

14 Q

Ilave you done any work, consulting or with any i

l l

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15 ot her nuclear plantu, about dissemination of newn?

i 1

i 16 A

No.

l z

i l

17 i

Q Aino on your resume t.here 's a men ti on of the New i

l lll Oricana hurricane.

j 19 A

Yeu.

4 20 0

Can you dencribe for me that experlence?

4 l

21 A

I covered two hurricanes in New Orleanu.

They IO j

22 involved, in both cases, evacuations, and they involved, in 4

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at least one of the cases, loss of lice and clooding, which 2

in nort.cd of an occupational hazard for the City of New

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3 Orleans, since it.'s below sea level.

1 4

0 Y e r;.

Which two hurricanes did you cover?

l l

1 5

A Illida and DeLuy, if my memory serves correctly.

I l

6 Itack t. hen they only named t. hem after women.

1 1

q 7

Q When were those?

i l

8 A

'64 and, if memory serves,

'65.

f 9

Q What were your duties in covering those?

j 10 A

The dittien included radio reporting during the O

11 period of the nighttime when, in both cases, electrical 12 ieaera tion died, and we had to go on a generator, and going 13 outside and covering eve nLa and working with cameramen to i

l 14 film what was happening and covering followup and i

i i

r j

15 interviewing people and interviewing public officials.

The 16 whole range ut reporting in both litutarices, al t.liough in tiie

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j 17 Ciral ins tance, I was a junior cub reporter, new hire, so I l

18 wan not, anywhere near as visible as the second hurricane.

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1 19 i

that time I was on the air guile a bit.

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20 0

Wat: 1111da in ' 64 a nd lie t a y i n '65?

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21 A

Well, you know, that's a good question, but I get j

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them mixed up, i

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1 Q

In tha t case, my hurricane lore in a-little weak, i

2 Lo t. 's take the first one, the 1964 hurricane.

What waa the i

3 official source of information for that emergency, in your 4

view?

i j

S A

We)), there were, an i n a l.1 emergencies of t.ha t 1

6 uort, a variety of uources of information.

That's true in i

j 7

every kind of nituat. ion from a natural disaster to any kind i

O of crisiu I have ever covered, t.here's been a variety.

In l

9 terms of official.i nf ormati on, we had the Weat.her flureau, we l.

i 10 had the mayor, we had police chiefs of the various

! O 1

11 jurisdictions, we had the Cuaut. Guard, we had the ci ty i

12 council president. was making comments, the archbishop of New I

j 13 Oricanu, because they run the necond larqcat school in the

]

14 diutrict, was decidine on whether to une t.h.

uchoolu as j

l 15 evacuation centers, I guess that could be quaniof ficial, but i

j 16 the llat could go on and on.

17 Q

What in your perception of how the emergency news j

1 11 diuseminal.lon was handled during the 1964 hurricane?

?

j 19 A

It was handled pretty well.

l 20 Q

Could you contrau t it to your TMI experience for j

i j

21 me?

!O i

22 A

Well, there are a number of important i

4 i

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i differences.

The threshold difference is that it's hard to 2

blame anyone for a hurricane.

It's an act of God and most.

3 people aren't yet willing to denounce him.

In torma of an

[

I 4

induutrial dinauter of any kind, peopl e immediately turn t

5 their a ttention to how did in come to pass and why do we havo l

l 6

thin danger in our midst.

7 So you are talking about animala of a different l

T H

variety, although there are some oimilaritica.

Hut the major 9

aimilarity la that in one you are dealing with an act of i

10 nature that junt happenu; and in the other you are dealing O

11 with nomething that people want. l.o know why.

That ques tion i

12 comen up from the 1Irnt moment that a reporter la covering 1.1 something.

It's a question that never goes away, why; and 14 yet in a hurricane, you know there 18 no answer to that 15 question.

I j

Q fio what do you concentrat.e your ef f ortu on

(

16 17 reporting in a hurricane that would be a different focus from I

10 l

an industrial accident?

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19 i

A Well, there are a number of things, but., again, i

t i

'20 t.h e first thing that pops into mind la that when you-are l

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When you are dea 1ing with an industrla1 f

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1 disaster, you are asking those questions plus a wholo not of i

j 2

other questions, including what if it worsens; and the i

j 3

what-iC questions are much more likely to be asked with an i

j 4

induuteia) nucicar emergency than with an act of nature.

3 i

5 Q

You cald that in TMI the information dissemination i

6 was handled badly, and that in the 1964 hurricano that it was j.

7 handled pretty woli.

i I

O A

Yen, i

i E

j 9

Q could you describe for me the elements of a newn i

l i

l 10 dinaemina tion syn tem that make it good?

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l 11 A

What maken it good.

Well, without reference to 12 the hucricane, becauuo that's a long time ago, and you are

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13 aoking me ta remember t hinga that have nort of i:aded from f

j 14 view.

The impresuion, however, remains, that the public i

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IS of f leialu were forthcoming, exercine leadorphip, made i

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j 16 themselvou available to the preas, were t i me ly i n o f.' L'o r i ng L

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information, coordinat ed their activi tica wi th other pubile i

1 i

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ofCiciala and with those in the private sector that were i

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19 involved in t he emergency and that they wer e honent.

l l

1 20 Q

!a it yout viaw that theno elementa could be part I

j 21 of emergency newn diuueminalion f or an industrial accident.?

a 22 A

Yes.

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1 Q

Other than t.he two hurricaneu and TMI, have you f

f l

2 covered any other emergencico?

3 A

Yes, f

4 0

Which are thoce?

-l S

A Well, LL dependa on how you define " emergency,"

l 6

because I have covered everything from bridgou collapaing 7

into the. fames River, to transportation emergencies where I

O tr ucks overturned and chemicals were spilled and firco l

l l

9 erupted, to political emergencies like Watergate and CIA 10 investigationn, wars, like in Lebanon.

So it dependa on how O

I 11 you define " emergency."

12 Q

Let's exclude the pollt.ical emergencieu and waru 13 and include disantern of any weather or Industrial nort.

14 A

Sure, j

t 15 Q

You have covered how many?

16 A

I am at. a lona t o give you an entimat e.

It ucemu f

i 17 lika a lot.

Off the t.op of my head, I can remember, a t least t

18 a dozen of what we would probably refer to an i

19 ILCo-threatening attuationa that were not wara.

TC ask you 20 me to name them all, I will probably draw a blank, junt.

21 hecause I didn't uit down and review that before I walked in O

t 22 l

here.

I i

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Q What period of time would this coverage be?-

2 A

We are talking over a 20-year period from, say, 3

'64 to

'84.

I basically stopped doing coverage in about i

4

1983,

'04.

That was the last of the times that I went out 5

and real.ly covered stories.

Go we are talking a 20-year 6

period.

{

7 0

I)uring that 20-year period, did you normally keep 8

notes of things tha t you covered?

9 A

The notes that I kept., and I didn't keep all 10 notes.

I mean, it was routine, throwing things away.

In t.he O

11 current age of 13 tiga tion, maybe people don't do that.

12 anymore.

But when I was doing this, whatever notes I kept, I 13 kept in the filen, of the placeu where 3 worked and Icft them 14 when I left, and thank God have not been a pack rat that 15 keepu all thin kind of stuff.

So maybe i t would be nice to 16 have an a rchiveu, but I don't have one.

17 0

So you don't have any kind of portfolio of t il "exci ting events I have covered over t.he years" nort ot i

19 l thing?

i i

20 '

A No.

I l

21 O

No?

O 22 A

i have kept. some videotapen.

i l

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1 Q

You have kept some videotapes.

l 2

A Dut I don't know - they are in a box somewhere.

3 But I think:every reporter keeps videotapes of some of the-4 stories that he has done, but I wouldn't say they were i

1 5

because they were the most exciting.

Usually you keep them i

i 6

because you are thinking about when you might have to apply

)

)

7 for the next job and you might have to show those tapes to i

8 someone who might hire you, so there are a variety ot reasons 9

for keeping them.

10 0

Right.

You said that you do intend to rely on

!O 11 your emergency news experience in your tenLimony.

Do you 1

ij 12 intend to go back and review any documents, vi deo t.a pes, news l

l 13 articles, from your experience, before you prepare your 1

)

14 testimony?

1 p

{

15 A

Well, I might.

I hadn' t really thought about i t.

(

1 16 You kind of hit me cold.

It's not one of my plans a t the t

i 17 moment to go back and look for all that stuff, because I 18 don't have much of it, if any, and I don't even know what's a

]

19 on those tapes.

They are in a box.

Unt)) this moment I f

i l

20 hadn't thought about doing it.

l 1

i 21 Q

Ilave you ever testified before?

I i

l 22 i A

Hofore Congreau, yes, Congressional committees.

i l

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1 Q

On what subject?

2 A

I testified before the - i f my memory serves, I i

3 testified before the Senate Judiciary Committee, the Senate 4

Intel.ligence Committee, that was a Select Committee on 5

Intelligence, the House Intelligence Committee and a 6

subcommittee of the House Judiciary Commi ttee on a number of 7

matters involving news coverage.

The one that I remember 8

foremost was the Intelligence Agents Protection Act, although 9

that's not the right name for it.

It's the one that made it J

10 a federal offense to reveal the identities of CIA operatives

, O

^

11 with the intent to impede American intelligence activities, i

12 Also test.ified on other press matters in the course - but 13 those are the committees.

14 0

llave you ever testified in court or bef ore an 15 administrative body?

16 l

A Tes ti fied, no.

Senate Commerce Committee too.

6tO1T 9{/l 17 i

There may be others, I jus t.w mt-reca ll them all.

l i

l Q

Do you intend to rely upon any of this previous 18 i

4 l

19 Lestimony in your draft?

4 1

l 20 l

A I don't think it's applicable to this proceeding, i

21 no.

I O

t 22 i

Q Was any of this testimony that you have iinted j

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i related to emergency news coverage in any way?

2 A

No.

Assuming you exclude ccveralle of CIA t.ype 3

covert opera tions, then the answer is it was not related to 4

energencies.

3 5

0 Ilave you seen the contentions that have been filed 6

by suffolk County in this proceeding?

x 7

A Some-of them.

8 Q

Can you describe for me what you have seen.of %e 4.

9 contentions?

You don't have to.give me numbers.

y 10 A

I am trying t.o remember the numbers.

U 1

11 Q

You don't have to give me-(hhNn u mbe rs..

12 A

I don't iemember the numbers.

I hade,seen-the 13 contentions that relate to thei' training aspects, to the 14 dissemination of information and the operation of the ENC, t

15 among others.

It seems to me I have seen threri or four.

ENC 16 is the Emergency News Center.

You know that better than I e

17 do.

18 Q

Could you describe for me, in general terms, your understanding of the gis t of the contentions-that you have 19 i

20 seen?

21 A

Well, my understanding of i t, and I wouldn't want 22 to give this as the complete answer, but the impression that ACE-FEDERAL REPORTERS, INC.

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~

1

'is left with me, upon reading the several' contentions, is 2

that the Emergency New's Center did not operate in an 4

i 3

, effective way, that flaws in the-exercise revealed the plan 4

to be flawed, and that the. training was alleged to be r

5 insufficient in dealing with the news media, in handling

.6 rumor control, in jroviding consistent and clear s

7 information.

s 1

8 Q

Do you Jgree with those contentions?

'Q 9

A ' '

ses.

I do agree with those contentions, although 10 I would like,to put a caveat on that.

If you would like me-O 11 to look at the contentions specifically, I can tell you 4

12 precisely what I agree with regarding those, rather-than just s

4

13 doing it from memory.

But the way I have characterized it, I 14 am in agreement with those points of view.

15 Q

When did yov first see the contentions?

s 16 )

A Early on -

1

'l 17 MR. MC MURRAY:

This has been asked and answered.

3 N18 Tile WITNESS :

Yes.

I thought early on. December

-7 19 10, December 15.

20 BY MS. MC CLESKEY:

21 Q

I thought when he had lis ted -

o 1

22 A

Inadvertent omission.

There were Xeroxed pages.

i

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p>) COX 29354.0 25 1

Q So you received tha' informa tion about the same 2

time you )eceived the other bundle you mentioned, in l

~

i j

3 December?

{

4 A

Yes, I received a bundle,.I can't remember if i t.

. as in the first bundle or the second bundle.

5 w

6 0

Who did you receive the information from?

7 A

Karla Letsche and I cannot spell her last name, j

8 It's Karla with a K though, but I don't remember the spelling 9

of her last name.

10 Q

Did you participate in writing any contentions?

O i

11 A

No.

j i

i 12 Q

Do you know who wrote the contentions?

j l

l f

13 A

No.

l Ii 14 Q

When were you first approached to be a witness in i

i 4

i i

j 15 this proceeding?

l

?

16 A

In mid-November I received a phone call from Bob, j

t l

a j

17 Robert Belaire, B-e-1-a-i-r-e, who's a member of this firm, l

18 Kirk pa trick & I,ockha.rt.

He in an old friend.

It was just a 19 casual conversation.

He suggested that I make an appointment 1

l[ to see Tip, Karla I,e tsche, which I did, 20 k

21 Q

When did that meeting take place?

22 A

Time flies when you are busy, but it seems like it i

l i

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was either the last part of November or the first part of 2

December, right in that time period there.

l

{

3 Q

When did you agree to serve as a witness for 4

Suffolk County?

4 5

A 1 don't remember if.it. was at the first meeting or 6

a subsequent meeting.

7 Q

Was it before you received the packages of 8

materiais?

1 9

A I don't recai.l.

I read some of the stuff, but I 1

10 don'L remember if it was before I said I will do it, or if i t-

O 11 was after.

I just don't recall.

1 l

12 Q

Other than th&L meeting with Tip, have you had any i

13 other meetings about the contentions or your participation in i

14 this proceeding with anyone?

l 15 A

Outside of the law firm?

The answer is no.

j 16 MS. MC CLESKEY:

Chris, would you mind if he 17 looked at your copy of the contentions?

i 4

la MR. MC MURRAY:

Pine.

19 THE WITNESS:

This is a good point.

Could we take l

20 a break?

i 23 MS. MC CLESKEY:

Certainly.

O 22 j

(Recess.)

4 1

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BY MS. MC ChESKEY:

2 Q

When we talked about your TMI experience and I 3

asked you how the news dissemination, went you said the word l

1 4

" badly" and you focused on the uti.13 ty dissemination, would l

5 you also give me your view on -- I believe you listed liarold

)i 6

Denton and the NRC's pa rtici pa tion in news dissemination, and 7

you also listed Governor Thornburgh.

Could you tell me how j

O you thought they did.

9 A

I thought tha t the federal officials.wcre 10 deficient in providing clea r, consistent and accurate O

11 information.

]

l 12 O

What about Governor Thornburgh?

13 A

I would give him a slightly higher score, but it's 14 a little unfair to score people this late in the game, it's 15 been so many years.

But the impression that I currently hold 16 is that there were many voices saying different. things, and 17 tha t crea ted conEusion.

I 18 0

You had said that you were generally familiar with

)

19 the changes that have taken place in the NRC regulations t

s 20 regardi ng -

21 A

some.

!O 22 Q

Do you think that those changes in your view have

]

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1 addressed some of the difficulties you ran into at TMI 2

requiring -

3 A

I don't know.

4 Q

Could you take a look at Contention 38.

Now, I 5

have a different version of the contentions than you do, so 6

my page numbers don't match, but that has a table of contents

}

7 which should make it easier for you to find it.

1 8

A 38?

I 9

0 Hight.

In this one of the contentions that you l

10 have read before?

O 11 A

Yes, I have read this.

12 p.

Could you just glance it over for a minute just to

(

13 refresh your recollection about the details of it, and then 14 tell me what the basis of your testimony on Contention 38 15 wil] be?

16 A

I agree with this contention.

Among other things, 17 the news center was late in opening and in briefing the 18 press.

Some of the news releases that were made by the 1,EHO 19 group contaisied outdated information.

Some of the material 20 l that was in EDS inessages was not released in a timely fashion i

l 21 at the news ceitter.

Apparently there were photocopying O

i 22 delays tha t usef ul (;raph.i cs, maps and displays were not 1

4

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available.

That the EBS messages that were released 2

contained information that was irrelevant. or extraneous; and, 3

among other things, I could go down the list if you like, but I

4 I agree with these contention'.

s S

Q Why do you think the news center was late in 6

opening?

7 A

I assume because the plan'was flawed, or it would 1

8 have opened, knowing it was a drill, it would have opened on i

9 time.

i

'a 10 Q

What time do you consider on time for the news j '

11 center opening?

4

,l 12 A

When the reporters ga ther at a scene, j

13 Q

When did that happen at the exercise?

]

14 A

W e 1.1, I have to review the notes-more carefully to 15 give you the precise hours of the day; but as a general rule, f

16 an Emergency News Center is only useful if it's open when the 17 reporters show up, which means it has to be open in a very 18 timely fashion.

I mean, I recognized the difficulties 19 involved in this, in the best of a31 possible worlds, you 1

20 would open it immediately..

21 But it seems to me, from what I have seen and 22 heard, that it was not. open in a timely fashion.

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1 Q

You say it seems to to you from what you have seen 2

and heard that it didn't. open in a timely fashion.

Are you f

3 referring to the representations in the contention about when 1

4 it opened?

i 5

A Yes, also from the other document.u that I 6

mentioned that I have had a chance lo review once.

7 Q

llave you looked at any, logs from people who were l

0 players in the exercise?

9 A

I am not. sure if that's what I was looking at..

I 2

10 have seen some sheets with times on it.

It may have been O

11 logs.

I will have to te)) you that I am not sure.

12 Q

ilave you seen any typed time lines?

13 A

I don't. recall.

i 14 Q

Is it fair to say that you are taking as true the 15 representation of facts in these contentions?

l 16 A

I have seen nothing to indicaLe to me tha L the i

17 representation of facts and content. ions are not true.

10 l

Q Do you intend, for example, lo do any further i

1 l

19 explora tion to determine whether the ENC was declared j-20 operational at a Lime other than 0:2S?

l 21 A

Yes.

O 22 O

You do.

What do you intend to do?

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i, 29354.0 COX 31 1

A I intend to look at everything I can in great 2

detail.

The intervention of Christmas prevented t.ha t.

I am 4

sorry the deposition isn't being held after I have had a 3

j i

4 chance to go through everything.

r i

f S

Q Sure.

What is the basis for your agreement with 6

the sentence in 30-A that the HNC provided no information at 7

all to the media until almost three hours after the emergency i

4 l

8 was declared?

4 9

A Well, in J oaking through the material that I have j

10 had a chance to review briefly, I found no indication that

O j

11 any information was disseminated from the ENC wit.hin the j

12 first three hours, i

i 13 Q

Your conclusion from that in 'that the media got no 1

l 14 information the first three hours of-the accident?

15 A

Oh, no, I wouldn't say that at a)).

i 16 Q

You wouldn'L conclude that?

f i

17 A

1 might conclude that t. hey got no information from j

l 18 the ENC.

But the press is notorious from getting intormation l

l 19 i from any uource it. can, t

f 20 Q

Hight.

Do you know what NRC requitec in terma of i

21 giving in forma tion to the press?

22 A

In detali, no.

l l

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a 1

Q Let's go on to 38-0.

l 2

A

Okay, i

3 Q

I take it you agree with 38-U?

I f

4 A

Yes.-

i 5

0 What. is the baulu of your agreement wit.h 30-H?

I 6

A In the materials that I have had a chance to look 1

7 at, there is nothing there that would contradict, this

[

8 allegation.

I have not had a chance to read everything I l

9 have been given, and so I would withhold a final judgment. on f

10 i t., but everything I have seen so far indicates that this is

!O j

11 accurate, that the allegation is accurate, the content.lon.

I 4

j 12 Q

And what impact on public safety, in your view, 13 would there be, assuming this allegat3on is accurate?

i

}

[4 MR. MC MijRRAY:

Do you understand the question?

5 j

15 THE WITNESG:

I a tti sorry, I am reading it. again 1

16 anu listening to you a t the same time.

Could you repeat the 17 question.

I 18 IlY MU. MC CLMbiWY:

I 19 Q

My question was what impact on public safety would d

70 there be, in your view, ausuming that 30-it is accura te.

j 21 MR. MC MilRRAY:

I am going to object to the form iO 22 ot the ques tion.

I am not sure what you mean by " impact on

{

1 i

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4 29354.0 COX 33 j

1 public safety," but if you can answer the question.

l 2

THE WITNESS:

Well, several things could' happen.

i i

3 Speaking from the perspective of a reporter, Ict me give an 1

4 answer.to this that I think gets.to what you are asking, and 5

I may not be right, but I will try.

l 6

If reporters feel information in not being given i

i 7

to them in a timely fashion with up-to-date information, it i

l 8

accelerates their tendency to diabelieve what'they are told

)

9

.t nd to nearch out other unoilficial source:i of informa tion, i

j 10 which can 1 cad to confusion, sensa ti onali sm, inaccurate

O j

11 transmission of information to the public.

Tha t really is 12 the heart of the problem with a number of thcac content.lonc j

13 that go to the delay in the transminulon at information or 14 the transminulon of outdated information or t.he like.

+

f 15 BY MS. MC CLBSKEY:

j 16 0

Could you describe for me briefly, based on your j

17 review of the materials thus far, your understanding of the i

1 l

18 l

newa dinnemination program an outlined in the 1,ILCO plan?

3 19 l

A In summary, I would have t.o say t.ha t i t was a i

j 20 two-t. rack opera ti on which I found curioun, because of the i

21 crea tion of the LERO entity, which wau an artifact or an O

22 l

ar ti fi cial entity that I found puzzling, and I think many 4

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reporters would respond the same way to it, as a puzzling

_2 entity, one that, seemed nei ther fish nor fowl.

3 Q

What was puzzling about.it to you?

4 A

Tha t i t was, in a word, " incomprehensible" an an 5

entity.

6 Q

In what fashion?

7 A

That it was no obviously artifietal that it didn't 8

match anything anyone would expect to run into when covering 9

an emergency.

10 Q

What would be your expectat.lona during emergency?

O 11 A

My expec ta tion, if I were utill a reporter and 12 covering an emergency, would be that public officials, 13 county, m un ic i pa l, s ta te, would exercine their legal 14 authorit.y t.o advise citizenn regarding such things an shelter 15 and evacua tion and precautions and the like; anti that IE, in 16 my role an a reporter, I ever ran into a bunch of employeen 17 Crom a utility simulating the activities of public oCCicials, 10 I would find it. curious and i ncomprehens i bl e.

19 Q

So the incomprehensible aspect of LF.R0 Lor you as 20 a reporter to be 1. hat there sun't a government i nvo.1 ved?

21 A

That's part of it, yes.

22 Q

What clue?

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.29354.0 COX 35 4

5 1

A Oh, there are other things.. I mean, a number of j

t 2

things come to mind regardiig the artificial nature of this i

{-

3 entity, and the fact that ils credibility and reliability

'4 would be suspect simply because of the divided -- strike 5

that.

I 6

Simply because of the loyalties that peopic in 7

LERO might exhibil.

)

8 Q

Loyaltien to what?

t 9

A All reportera perceive that peopic are loyal to i

l 10 those who pay them, an a general rule.

And so the LEHO

!O i

11 people would be perceived au being loyal to the utility that i

1 12 signed thei r checka,

j i

j 13 Q

In your view, Mr. Rowan, could an emergency newn i

j i

14 disnemination program that includes only a utility in the l

)

15 form of LERO or LILCO or whatever one might choose to call i

j 16 i t, ever provide clear, conalatent information to Lhe public f

i 1

17 to make up a good emergency news diunemination program?

l l

l i

1 18 l

MR. MC MIJRRAY Excuse me, are you talking about i

J

\\

i 19 i

whether LILCO can ever do 3 L or whether any utill ty can ever

)

j 20 l

do it?

I I

21 IlY MS. MC CLESKEY:

i 22 l

Q Whether any utiLLLy, without thin element of t

l i

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government participation.

2 MH, MC MilHHAY:

I am going to object and say it, i

3 calla for the witneau to speculate.

If you can anuwer the i

1 l

4 ques tion, go ahead.

2 l

}

5 THE WITNEGG:

There in no queulion in my mind that.

i j

6 utilitica in general can do an eCCective job of communicating

}

}

7 with the public before, during and after un emergency j

8 situallon; but that an enuential ingredient of effective j

9 communicatiori lu the participation in planning, training, 10 exercluing and implement.ing by elected and appointed O

i 11 government of ficialu, and that absent that. element, it'n very

)

i l

12 difficult, if not impounible, to imagine ofCectivu l

a i

13 communicationu, and I will look more at this in t.he 14 prepara tion of the testimony, but tha t_'s a u trolig Leell:19 oli i

l 15 my part that that cooperat.lon in enuential, i

16 HY MG, MC Cl,EGKEY:

f i

17 i

O Now, let's go back to what got up off on the pide 4

til line, which, Lu, I auked you 10 you would deucribe your i

j 19 underntanding ut the I,ff,CO plan'u emergency newn l

disuomina tion program.

Yott deucribed itaua two-1, rack l

20 i

l 21 program and t. hen we utarted talking about. I,ERO.

I take it 4

I i

22 f,ERO lu one of the two tracks?

3 1,

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29354.0 COX 37 i

1 A

We l 1, maybe I misunders Lood the quos Lion.

I i

2 thought. you were anking me to describe the disseminat.lon of?

i 3

ini'o rma tion in the exercise, which I have read once, and I 4

didn't know the question was only au to LII.CO's.

I wan going 5

on the assumpt. ion --

[

i 6

Q Okay, we are mincommunicat.ing because of. terms.

)

7 When I say "tho LILCO plan," I am talking about the off-uite O

emergency plan that wan the subject of. the exercise, and your i

l 9

underat.anding of my quention, I think, in accurate.

Could i

i 10 you describe ior me what your underntanding of the emergency i O J

11 news diunemination program under the plan tha t was exorcised i

12 la?

t i

13 MR. MC Militll AY :

Including both 1,liHO and LILCO l

1 2

}

14 functiona?

15 11Y MU. MC CLF:UKl?Y :

1 1

j 16 Q

liig h t.

I f

17 A

Well, I have read the newn releases of' the two 1

l 10 entitleu, the util1Ly, LILCO, and thin organizallon whono 19 name i n 1.F:ito.

Go thune two groupu were bot.h dioceminatinq j

20 information, au 1 u tule rn la nd it, during thu exercine.

j i

l 21 0

Could you doncribe Ior me, to the extent that. you

) O j

22 know, in what form that informat. ton was dianeminated?

l

}

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29354.0 COX 38 l

1 MR. MC MURRAY:

You meati whether it wau wsItteli or 2

hriefings?

I 3

TilH WITNESS :

Well, what I have neen la in written 1

^

4 form.

They have given me tapes, but I don' t know what lu on l

1 1

}

S the tapes, because I haven't had a chance to look at them 1

6

yet, f

7 IlY MS. MC CLESKHY:

i

-l 0

Q Go far as you are concerned right now, what you I

l 9

know 10 that 1.HRo and LII,CO disueminated newn releaucu?

l 1

10 A

News releauen, HHS meauages, and answered O

11 questions.

I danumo a t the Emergency Newu Center, and on j

i 12 telephone banku, among other things, which I haven't had a

}

l 13 chance yet to read or view.

I f

}

14 Q

You aluu liuted an one of the difficulticu that I 7

I i

15 naw with the program an it wau implemented at t.he exerel00, l

l 1

16 that the mapu and diuplaya weren't uneful.

Could you j

i 1

l 17 I

dencribe f or me what dif ficult ieu you have with the mapa and i

j 10 diuplaya?

r 19 A

i am baning my utalement on the inf ormation that J

20 la provided in the contention.

Thiu in one of the onin that i

21 I want to t.ake a clouer look at, but 1 do know the unfitulnettu

O 22 in general ot mapa, charta, graphs and the ren t, in the 4

l ACE-FEDERAL REPORTERS, INC.

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29354.0 COX 39 l

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I conveying of detailed information oE the nort involved in

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2 thiu exercise; and in the absence of Ihoan kindu'of dinplayn i

j 3

you have more diCCiculty in communicating informa tion.

i 4

0 Could you take a look at 30-E?

I i

5 A

Yes, j

6 0

la the baula of your statement that the mapa and l

7 displays woron ' t tianf ul, this sentence, "insuf:ficient and i

8 inadequat.e maps and dinplays An t.he media bricting room I

l j

9 contributed to the contuaing and unclear information heing I

10 dinaeminated by 1,ERO personnel"?

!O 11 A

Well, that's part of it.

The other part in in 3

12 reading t,hrough the informat.lon that I have had a chance t. o j

13 look at t.o date, there 10 nothing to disputo thin; and, in i

j 14 fact, the confuulon that I senued indicaten that thin in an i

I

{

15 accura to n La toment.

nut you are auking me to evaluate 16 nomet.hing that I have not complet.cly had a chance t.o do, l

i 17 l'

which I intend I.o do in great detail in Lho nea r Cut.ure.

(

)

1 11 Q

Right.

I understand that.

lla ve you looked at. the 19 mapa or diaplayn?

i 4

l 20 A

No.

I have not had a chance to do t hat.

1 i

i 21 Q

You atuo mentioned the copying delaya and 4

o 1

l 22 difflenitieu au part of your concern about. how thingu were l

i i

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1 implemented.

Do you intend to Cile tes timony concerning that j,

2 aupect af 1he exerciun?

i 1

3 A

I have relied on the PEMA poutmortem for my viewn 4

regarding the availability of copying machines.

t j

5 Q

You said that you had reviewed the EHG mennagon.

1 i

t 6

A I have read them once, i

I j

7 0

You have read them once.

0 A

I read what.'s been given to me.

I don' t know 10 I t

i 9

have them all, I anoume I do.

I have read them, the onen I

1 i

10 that have been given to me.

O

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11 0

Do you know about. how many you have niten?

j j

i i

12 A

No, I don't.

j 13 0

I know you nald you agree wi th the slutement in i

l 14 30-F, that t he Ells meauages were unclea r, cont'uning and i

I l

1 IS I

i nconni s tent.

l j

16 Could you give me any more upecifica yet baned on f

i I

l 17 l

your review Lhun f:ar about how they were unclear or i

til inconnintent?

I i

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19 A

Yen.

I do believe t hey ar e unclear; and the l,

4 reason I believe that la I read them cold, and then I stopped 20 l

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21 and I anked myuelf, do I know what they meant?

If I was a j

]

22 reporter read i ng an HilU monnaye in written Corm or hearinq 4

l l'

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29354.0 COX 41 1

it, it's a li t.t.le dit f oren t.,

it's hardor when you hoar L L, j

2 would 1 understand what I had heard?

My impreunion was that 3

the meauayou were a litt.lu dif ficult to follow, wore 4

difficult io follow, not a little, were very diificulL.

In 5

some cauou a lit.tle difficult, in other caneu, and confuutng 6

at times.

7 Q

Why did you find them difficuit to Lollow?

1 11 A

Well, you are auking me lo diuuoct an impresulon, 9

and yet the Jmprenulon in really more unoful than taking a 10 mesuage apart uentence by sentonce, becauuo people don't havo O

11 time to do that in an emerooney.

It'n the impresulon t. hat 12 counto, not the disuection of the entire text.

I mean, I 13 will go through that. exercino if you want, but I am just 14 Lolling you how I telt. at ter I road it cold.

I uaid, would th you, tha t 'n conf uuing.

4 16 0

Wau it confuning becouno you didn't. underutand 17 wordu in it?

t l

10 A

It. wau the sum total of the exportence of reading j

19 them, and reading them, incidentally, aloud, no I road it at l

i 20 t.he right pace.

I read the EHti moupagen aloud no I wouldn't I

21 upoedread or anything like that, and the Jmprouulon wau, if I O

22 won a woratny reporter at Wal,x radio, or ror a nowanapur or j

ace-FEDERAL REPORTERS, INC.

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29354.0 I

COX 42

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i j

1 television, radio p la t.lon, I would have to say, give mo that

(

1 2

again, wha t wiin tha t.

.t 11 abotit., let's go througli tiiit. attai n.

1 j

3 1 didn't quito graup IL.

That was my improauton.

i I

4 0

Could you tell me your understandiini of the l

5 purpose of the HOG mounagon and what in done with t.hom?

1 l

6 A

Well, ny understanding la that the EHG monnagou i

f 7

are douigned to communicato directly with t.he public.

i H

Q What. In your underutanding of what in done with

)

i

(

9 the HilG mensagou?

I I

i j

10 A

My preliminary feeling in that there 1p a very l

i O 11 danqurous emphaulu on HilS moupagna, that. I f: Wo juut look at a

f l

12 the Mils mouungeu, wu mino the fact that the public Wl))

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j 1.1 receivet lla information irom a myriad of nourcou that thoue t

14 EDS moundges will be i nwri t ten by inurtiall u t.u, Inter pr eted by

[

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15 journalintu, commented on by diuk jockeyu, announcorn, el i

t 16 cetera; and that the inf or mation t horoin will be received by i

)

17 the public in condenued, revlueil and ex tra pola ted i:orm.

l l

]

1H Q

What la the pouulble concer n wi th tha t happening?

)

19 i A

That if thu HilG mondayn llatelf 10 nol crystal I

j 20 i

clear, you aio almout quaranteed that. by the time it han been l

\\

1 j

21 l

reported on by the oluetronic prosa, that the meaning i O i

22 orlylnally intended will be altered or misunderstood.

I

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i ACE-FEDERAL REPORTERS, INC.

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O 29354.0 COX 43 i

4 1

Q What could be donc l.o minimian that, kind of i

2 minunderutanding or al Loring?

l i

4 i

3 A

I haven' t mado an ef f ort. to rewri te your EllG l

I 4

mousagen.

i t

j S

Q inut you wou.1d want to reconuidor the t. ext. of. the j

d I

l 6

mesuayou?

?

l I

7 A

The text 10 only one of coveral problemu.

I l

0 Q

What an e uomo of the olhoru?

I 9

A Wo.11, we could go on about the philouophy of how l

10 to communleato Lo the public in an emergoney.

I think there O

11 lu an overemphaulu on Enti monnagen an a main 1orm ot l

l i

12 communica ting.

13 0

What would you emphaulzu?

l 1

14 A

I could have a laundry llut ot a number of.'

i I

I IS thingu.

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16 O

Why don't you liut them for me.

17 l

A 1 don't., off tho top of my head, know that I WI11 I

{

remember them all, but one of the crticial thlnyu, in lu 19 communicallny with the public durtny.in omorgoney, tu the

'0 aval I thili t y t o report oru and t o the live teloviulon arnt

/

radio hookupu that will quickly becomo outabituhod, Lu Lho 21 i

i 22 pr ovipion of indunt.ry, governmental and academic exportu, who i

I ACE-FEDERAL REPORTERS, INC.

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29354.0 l

COX 44

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l l

l 1

can communleate on a f aco-to-face hau ts with working memberu l

l l

l 2

of the preau and through the pr eau wi th the audience, to i

I 3

provide t,imely, accurate, crediblo information.

I j

4 g

In the ultuat. ion that we are djucuuning, which i

l 5

would be a nuclear accident, what uort of information would l

6 you want thoue people to be providing that waan't provided l

7 during the exerciou, in your view?

O A

J wouid have to witnhold judgment on thatJ 9

becauno, well, I uunood uomo gapa in what was being provided, f

10 alul I know that there are examplou of a lack of t.lmoly flow O

i 11 oC in t;orma t ion.

I wouldn't give you a list of all oc thu t

l 12 thinqu that I would put in if 1 was tr ying to hulp you do lho l

i f

13 plan.

I know there are uomo thingt! minuing, but thny kind of f

l 14 hit me without having walked through that mentally yet.

IS Q

Do you lutond to filo Leu timony on 3H--I?

i 16 A

Yeu, i

17 i

0 Could you doucrlhe f or me the glut of. the f

l l

l 10 totit.imony you intend to f~ 1 10 on 30+I?

f I

l l

19 A

Au ! underutand it, the people al 1,HHO who ar'e i

f l

communicating with the pecun, worn toid to take the notauulum l

20 I

21 I ud I(IU and yel dld nol Iniof m the pr ellu J alld t httfl Wholl (hOy lhecano,andII O

ot

>^< ew d 22 did.wgtheprouu to cover it up.

If that tu j

r l

ACE-FEDERAL REPORTERS, INC.

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O COX I

45 293S4.0 1

have no reauon, from what I have seen, t.o believe it'u not 2

the coue, then you have juut neon a demolition of 3

credibility, which would make LL very dif ficult 1:or reportoru 4

to take neriously the statementu of the I.HHO peoplo 5

thornaClor.

6 Ilut, ao I uay, thlu 19 one of thoue aruan wSuic !

7 want to do uomo dl<pling on my own la Cind out p.octuoly what 11 the information wau.

11u t thl u J u -- I have no reauon to 9

hollove it inn't.

Ilu t I t thiu allmp tion to accurato, yott 10 have got nerioun credibility pr oblemu.

O 11 Q

I tako IL for 30-J tha t you havon ' t ye t, looked at 12 the preou coniesence tapeu?

13 A

I plan to do theil, but havo not done tha t ynt.

14 0

00 yotar agreement with 3ft-J lu baued on a reading 15 ut the contentionu?

f 16 A

And the ot her,i nf or mation I havo seen which l

17 indicaten that iL la an acetitalo reprouent.at. ion.

I 900 l

I 3

Ill nothing that would indicate to me it'u not.

The nnuwor 10 I 19 agree with the contontionu, but I havo morn work to do i

20 I regardIno Iindino out. the i nf or ma t.lon.

21 Q

Well, int's take a look a l.Ill-N, tot examplo, O

22 which nayu t ha t LHHO per unnnel I's equent ly minuta t ed l'act o and ACE-FEDERAL REPORTERS, INC.

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293S4.0 l

l COX 46

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1 provided inaccurate i n t o rma t. i o n.

Are you ablo, at thin timo, l

2 to ylve me any ot.her exampleu of how fact.u were mluutated or l

l 3

Information given was inaccurato?

(

4 Mit. MC Millill AY :

Other than what. lu in thlu S

contention?

6 IlY MG, MC CISUKHY:

7 Q

Othor than what, la in thiu contention.

O A

I have to paun on that..

I can't give you an 4

anowor right now, becauun I haven't had.: chance to do all 10 the work that lien ahnad.

O 11 Q

CouId you tel1 mo under 30-0, do you agt no wi th l

12 part 3fi-Q of the contentlonu?

l I

l.)

A Yea.

14 l

0 Could you tell me why replacement of copying j

15 machinou wouldn' t nolvo the copying dirticull. lou?

16 A

Well, we have to deal with what we have got.

l l

17 mean, you aro auking mo to nvaluate Lho exorcino, and I am in i

l 10 the pr occuu of doing that.

If you want,

.I will be glad to go I

i 2

1 19 l oft and talk about what could be dono to improvo thu plan in l

20 the future, and that ueemo to be the t.hrunt of the qunntlon.

21 If you want mo to got oft on to that.

O 4

not haned upon what nannoned in tnn exe,cion, u n

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i 29354.0 i

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that'u what you want me to work with, it uuomo like it wau a 2

deficloney.

I tion't know if you want to not of f on nomethitgl 3

01u0.

t 4

0 I underatand that copyino diffIcultIcu have been l

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identiftett from the exorcino, anil 30-0, which you pay you 6

agree with, ihat Haya that replacement of copying machincu l

1 wou lti not take care of t.he copying d1Cricultion that woro I

il iden t i f l ed.

l 9

My queution tu, why wouldn't --

l l

l 10 M it. MC Militit AY:

Excuue me, I think that'u a

! O 11 miucharacterization of the cont.ention.

The contention payu 12 that replacement of the copylny machinou would not allovlato

.l 'I all of the problemu that. exluted at. the ENC.

I think it doen l

14 not mean that. the problem in tha t I,II.C0 wouldn ' t thereby he i

15 able to make morn coplon.

l l

16 l

I)Y M:1. MC Cf.R!iKHY l

17 i

O Well, my flaut qunut.lon to you wau, wotild more I

10 j

copying michineu isolve the copylinj diftleulttoo?

l l

l 19 l

A I tiuoup H0.

I don't. know.

l l

Q Okay.

Now, wha t problomu would iL not univo, i

20 i

21 uince Mr. McMurray'u reading of the contention la that thoto j

O t

22 are many prohloma that copying machintut wouldn't uolvo, i

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293S4.0 l

COX 40 i

1 1

1 A

Wel1, apparently, copying la only part ot tho 2

deficioney of tranumitting information.

Whether you do it by i

3 uummary, by onlino computer linkup or lho roul.

I recognizo

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f 4

that this pointu to copying, but thorn ano other ulomontu of t

i l

S i t., too, that one would 900 an a prohlom iti thtu.

11u t I i

i i

6 would like to once again uay, and I apologlun that I-haven't l

j 7

had a chanco to do all t.h u rosioarch that I would like to do l

1 f

H to be able to olvo you a comprohonnivo anuwer to thlu, but 5

i j

9 the problem utomo 1: rom t.ho fact that work wau begun in l

1 10 m i d-Docomlier.

O 11 0

1.ot'n go on to Contention 39, whleh dealu with the l

12 rumor control program, i

1 i

13 A

H i g h t..

i l

)

14 0

Would you take a minuto juut to glance over it.

1 A

Ok.ly.

i j

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16 I O

Would you doueribe for mo your underutanding or i

i 17 i

the rumor control program that wau unod at the exoreluo?

E 4

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A My pr el imi nar y under u t.atull ny of 1t lu ihat phono t

1 (9

hanku Woro not up, amonQ olbor lhknqu, lo deal WIlh CakkU

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20 rrom poopio that worn concerned, that had heard rumorn, that i

21 j

w.inted quantionu anuworod, and my expeclation in any l

Q t

22 t) I k lla k i till Would Ilo LIla L tinott o phorio banku, or iho phone r

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29354.0 COX 49 I

l I

numberu involved, would be uued both by the gonoral publie l

l 2

and by the preuu.

Now, thero may be more to it that I have l

3 not yet found out, but. that'u what I read into thiu.

4 0

Let tre juut. make uuro I underpland your annwor.

S Your underutanding Lu that the public and t.hu pronu would bo 6

calling the rumor control numbers to got information.

7 A

You.

l i

il Q

Could you uummar 1xo f or me the dif f icult.ica t ha t.

t 9

you uno with t,he rumor cont.rol program au it. wau implemenLod i

10 durino the excreiaa?

O 11 A

Wo11, the telephone pluu the ENC - I may have 12 lofL out the olomunL of the RNC quoultonn and anuweru face lo 13 face.

1 didn't mean to uay it wau juut phoncu.

Let mo juut.

l 14 uay I think I. hat any t.nlophono nyatom that tu doulgned tor l

15 the general pubile will be uund by the prous.

16 0

What dif,ficult. Lou did you von with t.he rumor l

l 'l control program au it wan implemented at the exerclue?

10 A

Well, thoto are a number of: allegallonu that woro i

19 mado, and I haven't had a chance to do the kind of reucarch l

20 that would give me an indopondent judgment au to wholhor l

f 21 t hetto ar e accurole, although I agree with t.ho allegationn and

)

22 the cont.onLlonu that have boon given to me.

I juul haven't i

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293"4.0 COX S0 1

had a chance to do all of the research.

2 But, having uaid that., let me say that. my overall 3

conclusion on looking at this is that people answering 4

questions have t.o be able to give answeru in a more timely 5

f ashion than apparent.ly occurred here.

For example, juut one 6

of several, but JL really struck in my mind, a caller asked 7

10 the plant had been taken over by Arab terrorista.

Now, 8

Lhin in t.hu kind of rumor that if a reporter heard and used 9

Lhin telephone ayulem to call in, and what he was Lold wan I 10 will get. back to you, and a 40-minute delay occurred, a O

11 reporter might jump to the conclusion that the utility indeed I

12 had been overtaken by terroriulu and there was an ef f ort.

13 under way I.o keep tha t Cact uecret.

14 Now, I wich reporteru would not uue that kind of 15 information because it's a rumor.

But unleau a rumor is 16 quashed quickly, t.he unfortunate thing in t. hey have a way of 17 Cinding themuelven repeated on the air, because it'u not juut.

i 1H hard-working journalist.u t. hat will be using these phones, 19 it's radio dink jockeys.

I remember during the llanati Muslim 20 uc3zure which I covered here in Washington, radio plat.lonu 21 were phoning the Muulima and putting them on the air live and 22 a.11 manner of rumoro were on the air.

If. you don't have a ACE-FEDERAL REPORTERS, INC.

2037 37m Nationalde roverage mn34tM6

a O 29354.0 COX 51 f.

I rumor control system that works better than this one i

2 apparently did, with more timely information.regarding what 1

3 isn't true, you might have a situation in which fear runs a

4 rampant.

1 5

Q So, in your view, using the example'that you chose 6

which is subpart 8 of 39-8, if someone calls in and asks if 7

Arab terrorists have taken over a plant, if a reporter calls 8

in and asks if Arab terrorists have taken-over the plant, to 9

the rumor control board, and the answer is we wil] get back 10 to you, and the answer comes in 40 minutes,. that it is likely O

11 that the reporter is going to report in that 40 minutes 12 before he gets his answer, that Arab terrorists have taken 13 over the plant?

14 A

It's possible.

It's_possible he will get on the 15 two-way radio and advise his desk he is checking tha t.

16 Someone else wil] hear that two-way radio transmission and 17 believe it to be a s tatement of fact and repeat it to a third 18 or fourth person who then takes i t as the gospel-and repeats 19 it to another reporter who reports it on a different news 20 radio broadcast.

I mean, all manner of things are possible.

21 We can sketch a scenario that'makes one shiver.

The key O

22 element is effective, timely, rapid quashing of inaccurate ACE-FEDERAL REPORTERS, INC.

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/] 29354.0 L/ COX S2 s

1 rumors.

I use that example because it jumped off the page at J

2 me.

But there are others here too.

You have to have a 3

system that does that.

You can't wait 40 minutes for a no 4

answer.

Things get out of hand.

5 Q

I take it from your answer that one of the things 6

you think any reporter would.do is seek other sources for the 7

answer to his question?

8 A

There is no question that reporters will search t h eat, that the sources 9

for sources anywhere they can find 10 will range from the wc]I-informed to the man on the street.

11 g

Q Could you give me a range of time which you think 4

to these rumor control

.12 would be acceptable for a response 13 calls?

14 A

On the example given?

15 Q

Sure.

16 A

Five seconds, llave Arab terrorists taken control 17 of your plant?

No.

18 Q

Have you looked at the rumor control message 19' forms?

20 A

I can't recall if I have looked at those or not, d

21 I am afraid when one looks at information, tight deadline and 22 trying to get prepared for today so that I could respond, in i

ACE-FEDERAL REPORTERS, INC..

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2 9 3 5 4. 0 COX 53

^

1 part, I can't recall if I looked at those or not, offhand.

2 Q

Could you turn to Contention 44.

Just read the 3

first sentence.

Have you seen that before?

4 A

Yes.

5 Q

Do you intend to file tertimony on the evacuation 6

shadow phenomenon?

t 7

A I haven't decided yet.

The first time I saw this 8

contention was yesterday.

9 Q

During a meeting?

10 A

Well, we had discussed this general subject, so it 11 was not a surprise, don'L misunderstand.

It'c' just the exact i

12 wording of this is new to me.

13 L

Can you describe for me what you mean by 14

" evacuation shadow"?

15 A

My understanding of this particular phrase is that 16 it involves people evacuating who were not being advised to 17 evacuate.

Now, I would have to do a lit.tle bi t more work on 18 this, because the word is basically one I haven't used in my 19 own work.

It's a term of jargon that I don't use every day 1

20 ever.

21 Q

Right.

You heard it for the first time yesterday; O

22 is that fair to say?

ACE-FEDERAL REPORTERS, INC.

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29354.0 COX 54 1

A We talked about-the concept, yes, before i

2 yesterday.

But in terms of. the precise wording, I think that 3

the precise wording of Contention.44 is fresh to me.

I have 4

heard the term " shadow" before, yes.

Before that,- but not in.

5 relation to this particular exercise.

6 Q

In connection with what did you hear that term 7

before?

8 A

Evacuation procedures in general involving 9

evacuation planning.

10 Q

For what emergency?

O 11 A

Emergencies of a variety of sorts.

In other 12 words, the phrase is not new to me, but its use in this 13 sentence is something I haven't had a chance to evaluate 14 because I only saw it yesterday.

15 Q

You are not sure whether you will be fi. ling 16 testimony on this particular sentence or not; is that. fair to 17 say?

l 18 A

Probably is a fair answer.

19 Q

You probably will?

20 A

Yes.

21 Q

In that case, could you describe for me to the O-22 extent that you know right now what the gist of your ACE-FEDERAL REPORTERS, INC.

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1 testimony on that sentence would be?

2 A

Well, I am going to say, among other things, that 3

if people are at home listening.to news reports on radio and 4

television, and they hear about problems at a nearby nuclear 5

power plant, that depending on how the reporters relay the 6

information, many people may decide that safety is the bust 7

policy and hop in the car and leave, even though they haven't 8

been urged to do so.

I.mean, other things might come along, 9

but I guess I have not done a very good job of summing it up, 10 but that's the idea behind what we are talking about.

O 11 Q

What is your bauis for that view?

4 12 A

Well, several things.

Among other. things, 13 watching people do it a t Three Mile Island.

1 14 Q

What else?

15 A

The fact that I have had to broadcast during real 16 evacuations involving natural disasters and trying to explain 17 what people should do which isn't the easiest thing in the 18 world; and to do it in a way that prevents panic is 19 extraordinarily di fficult.

20 Q

In your experience in covering the emergencies 21 that you have covered, in your view, has the emergency news 22 dissemination generally been wha t you would term as good in ACE-FEDERAL REPORTERS, INC.

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getting public response that was aimed for by the emergency 2

information?

3 MR. MC MURRAY:

May-I have that question read 4

back, please.

5 THE WITNESS:

Yes.

6 BY MS. MC CLESKEY:

7 0

Let me rephrase it.

Are you unclear, Mr. Rowan?

8 A

I wasn't sure what you were asking about,'the 9

LILCO incident or past incidents I have been involved in or 10 what.

O 11 Q

No.

I want to know based on your experience in 12 covering other emergencies.

Have you run up an emergency 13 news program that, in your view, was adequate for providing 14 information to the public in the emergency?

l 15 A

Well, I have been involved in several of them.

16 Let me give you the one that is adequate or I thought at the J

i 17 time that was adequate, involved a natural disaster, 18 hurricanes, where it was pretty clear which people should l

19 evacuate and which ones shouldn't.

Yet even with that, there j

20 were examples of people who refused-to leave.

There were 21 examples of people who left from areas that didn't need to be l

22 evacuated.

Here you are talking about several days' notice, i

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which is a little different than the situation at hand.

I am 2

not sure if it translates to what we have got in front of us 3

in this instance.

4 Q

In that adequate program, could you list for me 5

the major elements in your view of the program that made it 6

adequate?

7 A

I am not sure I will get them all off the top of 8

my head, but clarity is one essential element, timeliness is 9

another, the credibility of the people doing the advising is 10 another, the ques tion of whether the information represen ts O

11 officia] advice or is strictly a recommendation.

There may 12 be other aspects of it too.

I wouldn't want to characterize 13 that as the entire li s t, but it's -- there are a number of 14 things that make something more credible than something 15 else.

16 Q

Have you read any previous testimony on shadow 17 phenomenon tha t has been filed in this proceeding?

18 A

No.

19 Q

Have you read any sociological articles published 20 in trade journals or anything of that naLure on this s ub j ec L?

21 A

Yes.

A 22 Q

What have you read?

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A I wish I could remember.

I read a lot of things, 2

and my shelf is filled with a couple of books on Three Mile 3

Island, on problems relating to mass psychogenic illness, to 4

retrospectives on Bhopal, and you have just hit me.at a time 5

when I draw a blank on the names of the articles.

But I have 6

done extensive reading on problems involved with industrial 7

accidents and crisis management.

We can get you a 8

bibliography or something, but I can't tell you off the top 9

of my head and cite chapter and verse.

10 0

Do you intend to rely on any of that sort of O

11 literature in your tes timony?

12 A

Possibly.

I don't know how useful it will be, 13 because I am talking about particular aspects of this, but 14 possibly, yes.

15 0

When do you int.end to start preparing your-16 Lestimony; do you know?

17 A

As soon as possible.

18 Q

Could you turn to 22-F.

19 A

Yes.

22?

20 Q

22-F.

21 A

Could you give me just a second?

t 22 Q

Oh, sure.

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COX 59 1

Mr. Rowan, have you seen Contention 22-F before?

2 A

Yes.

3 Q

Was that recently or in your December packet?

4 A

I don't recall if it was in the December packet, 5

but I read it a day or two ago for the first time.

No, not 6

for the firs t time.

I read it a day or 'two ago for the 7

second t.ime.

8 Q

Do you intend to file testimony on this 9

con ten tion?

10 A

Probably, yes.

O 11 Q

Could you describe for me what the gist of that 12 testimony will be?

13 A

I haven ' t wri tten i t yet, and on this one I would 14 like to say I plan to give it serious thought before I draft 15 anything.

It's fair to say that I wouldn't want to 16 characterize the gist until I had a chance to sit down in 17 front of a typewri ter and do it.

18 Q

Is it fair to say tha t you haven' t really turned 19 your attention to 22-F yet?

20 MR. MC MURRAY:

Off the record.

21 (Discussion off the record.)

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BY MS. MC CLESKEY:

2 O

Have you'seen that contention before, 22-F?

3 A

Yes, indeed.

I have look_at this one several 4

times.

5 Q

Do you intend to file testimony on it?

i 6

A Yes.

7 Q

Could you describe for me what you know right now 8

of what the gist of that testimony might be?

9 A

I intend to say several things about the way 10 information would be transmitted to the public via the news 11 media.

Among other things, immediate efforts would.be 12 launched by radio and television stations to commence live 13 coverage; and part of that live coverage wi13 consist'of 14 doing what radio and television s tations do very well on a 15 daily basis, which is to send helicopters aloft to report on i

16 traffic conditions and to film or videotape whatever is 17 available for public view from the sky; and in the course of 18 covering events from the sky, both on radio and TV, the j

commentary will naturally' include information about traffic;-

19 s

1 20 and that when coupled with information being given by LILCO;_

21 or in your scenario from LERO, that'this information could O

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people leaving the area and that such speculation, although 2

unintended by the peopic.that drew up the plan, would have 3

the effect, cumulative effect, of encouraging people to 4

voluntarily evacuate before that was intended by the 5

officials involved.

6 Now, I want. to make it clear that in trying to 7

give you the gist, you know, I am not sure that tha t is all-. I L

8 am going to say or that I might not augment that with other 9

ideas, but trying to be responsive and yet you have caught 10 me, in effect, at an early stage in the research that I am O

11 doing.

12 0

Gure, I understand.

In your professional view, 13 based on your experience, what could be done to the emergency 14 news dissemination program to counteract this effect of 15 people responding to news reports by leaving when they 16 haven't been asked to do so?

17 A

It would be premature of me to render a judgment 18 on that.

I haven't analyzed the problem to the extent 19 necessary before-you s tart talking about are there ways that 20

-it could be solved.

You just got me at the beginning of my 21 search for answers rather than at the end of it.

1 22 Q

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at the emergencies that you have covered during your 2

reporting carecr?

3 A

Yes, I believe so.

I have also seen it'in some 1

4 that I have just watched on television as,an observer.

The 5

helicopter coverage aspect was only part of it.

It is a 6

growing phenomenon.

We didn't have that back when.I started 7

out in 1964, but I have seen it on te.levision.

8 I am trying to divorce what I have done from what 9-I have seen.

Sometimes that's not the easiest thing.on the i

10 spur of the moment.

But there are other aspects of it too.

'O 11 Even if no he]icopters flew because it was a cloudy, 12 wind-swept, horrible night and no one could go aloft with 13 fixed wing airplanes or anything else, I think the contention 14 sounds awfully logical to me.

I agree with the way this is f-15 laid out.

16 Q

In your experience and_your postulation that 17 people would leave in response to reports from the news 18 people about traffic and what is going on from helicopters, 19 can you describe for me the effect on the safety of those 20 people that you think that would have?

21 A

You mean if the people left?

O I

i 22 Q

Right.

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A Voluntarily?

2 Q

Right.

3 A

And clogged the roads, prevent.ing those who were 4

supposed to evacuate from evacuating, you are asking me to 4

5 speculate on the danger of.those who would be unable to move 6

from the area of real' concern because of the voluntary 7

decision of people who didn't need to move, you are asking me 8

to carry that line of logic down to its ultimate conclusion?

9 Q

No.

I was asking you to define what the safety 10 problem would be, and you have just done tha't.

WhaL you have

, O i

11 said is that in your view, the safety problem would be that 12 people would voluntarily leave, making it impossible for 13 people who are supposed to Jeave, to get out; is that a fair j

14 assessment of wha t you have just said?

15 A

Well, I don't know if I would have chosen the same 16 words, but, you know, it's an assessment of it, yes, I i

17 guess.

i I

18 Q

Well, is it 1. rue that the safety concern t. hat you 19 have is that people may respond to news reports by leaving 20 and making it difficult for those who are supposed to be l

21 leaving to get out?

i 22 A

WeJ1, that's part of it.

I mean, people may 1

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respond in ways they are not supposed to respond.

I mean, 2

they may stay.when they should go.

They may go when they-3 should stay.

They may get scared and do irrational things.

4 I mean, the list doesn't stop with clogging highways, 5

although that's an obvious problem.

6 Q

Ilave you seen these behaviors in the emergencies 7

that you have covered?

8 MR. MC MURRAY:

Objection, asked and answered.

9 Tile WITNESS:

I am sorry.

10 BY MS. MC CLESKEY:

O 11 Q

Have you seen the behaviors that you just listed 12 of people doing irrational things?

)

13 A

Oh, yes.

14 Q

People leaving, people staying, when they weren't i

15 asked to leave or stay?

Have you seen that?

16 A

I saw some of that at Three Mile Island, sure.

17 Q

Any of the other emergencies that you have 1

l 18 covered?

19 A

Doesn't instantly come to mind.

My memory just i

20 isn't triggered at this moment.

i 21 0

22-F, the contention that you were discussing that i

22 you say you are going to file tes timony on, references

+

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Chernobyl.

Do you intend to discuss Chernobyl in your 2

testimony?

3 A

Maybe.

3 4

Q Could you describe briefly for me what kind of S

work you have done on Chernobyl thus far.

t 6

A In the course of teaching part-time at the Medi1],

7 M-e-d-i-1-1, School of Journalism of NorthwesLern University, 8

we have a course in government and the press.

For the last 9

Lwo quarters I have asked students -- this quarter that just 10 started and the last quarter, I have asked students to do 11 research papers on the flow of information at Chernobyl, and 12 I don't mean to characterize that as having in-depth 13 knowledge of the subject, but these are graduate students, i

14 the papers have been very interesting, and they have 15 augmented the atuff thal I have read, in the course of j

l i

16 f o]Iowing it in the press and in articles and in magazines i

17 and the rest.

18 Q

Do you have copies of these papers?

19 A

No.

They were returned to the students with the 20 usua] things teachers write on the margins.

21 Q

When you say "the information that was given," do 22 you mean availabic in Russia or in America?

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A Both.

2 Q

Both.

What sources are your students using to 3

write these papers?

4 A

Primarily journalistic, but there are other - I 5

am at a loss at this moment to remember all the sources.

6 They have access to the library at the NRC.

I don't know to.

}

7 what extent or recall to what extent they have accessed 1

t 8

that.

These are graduat.e students, and they are good 9

investigators, some of them.

Some of them have done 10 first-hand interviews with people in Washington who are aware

' O 11 of events in the fields of nuclear preparedness.

So while I 12 wouldn't want to rely entirely on that, you asked me what do 13 I know about Chernobyl, and I have tried to give you my_ idea 14 of where some of the information I have coming has come 4

15 from.

16 0

Have you reviewed any of the sources?

17 A

I have reviewed a paper by David Rubin comparing 18 coverage of. Chernobyl and Three Mile Island, that was 19 presented, if my memory serves correctly, at the Annenberg 20 School of t.he Universi ty of Pennsylvania, joint program wi th l

21 the University of Pennsylvania and the University of Southern i O 22 California.

Mr. Hubin, I believe, if 3 am right, was on the t

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staff of the Kemeny Commission or contributed to that 2

commission, and has also been a professor at New York 3

University, and he did an interesting paper on that.

4 Q

Do you intend to re]y on that paper in your E.

testimony?

6 A

I haven't decided, but it's fresh in my memory, j

7 Q

Do you intend to look into other literature about 8

Chernobyl and writings about Chernobyl in preparing your 9

tes ti mony?

10 A

I may have.

I haven't decided.

You asked me, O

11 will I be discussing Chernobyl, I said maybe, and I may not.

12 I don't know.

i 13 Q

Do you have any idea when you might know whether 14 you are going to go into Chernobyl or not?

IS A

I intend to begin draf ting at the conclusion of'a i

16 very accelerated research period which begins probably this f

I 17 Friday, and so drafting will start in three weeks, but my I.

a 18 calendar is not set in concrete and the sad truth is i

l 19 sometimes deadlines slip.

20 Q

Yes, we know.

4 21 A

Hut, in a)) honesty, I hope I get to it fast.

i t

22 Q

Could you take a look at Contention 42.

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1 A

42.

2 0

llave you had a chance to glance-at. that?

3 A

Yes.

q 4

0 11 ave you seen this one before?

5 A

Yes, I believe 30.

I 6

0 Do you intend to file testimony on it.?

7 A

Probably.

8 Q

Cou]d you describe the gist of your testimony as 9

well as you know it now?

10 A

Well, once again, I am sorry to have to tell you, I 0 11 it's an awfully preliminary stage to give you a clear outline 12 of what I intend to write.

I just have not gotten that far 13 along in the research to where I think I can give you an j

14 accurate reflection of it at this time.

15 Q

Could you turn to contention 50.

Would you take a 16 minute to look at the preamble to 50 and then part.s E and F 4

17 and tell me if you have seen those before.

i 18 A

E and F?

19 Q

Yes.

Have you seen those before?

20 A

Yes.

I 21 Q

Do you intend to file testimony on them?

O 22 A

Probably.

i i

l 1

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l 1

Q Do you intend to file testimony on any other parts s-I 2

of Contention 50?

3 MR. MC MURRAY:

1 don't think we have identified l

l 4

Mr. Rowan for any other parts.

l t

i 1

l I

5 THE WITNESS:

Thank you.

That's the answer.

i

)

6 BY MS. MC CLESKEY:

\\

i 7

Q Have you reviewed any training materials from l

ii

{

8 LILCO's training program?

1 l

9 A

No, I am hoping to do that.

10 Q

Have they been provided to you?

O i

11 A

I do not believe that at this time they have been i

12 provided.

l l

13 Q

I take it you agree with contentions 50-E and 14 50-F?

l 15 A

Hased upon what I have seen, absolutely.

But what I

a 16 I have seen is the assessments, the end results, some of the 17 other material.

I have not seen the training materia]

10 itself.

19 Q

Right.

20 A

So I am concluding, based on what I have seen.

21 Q

Could you -- based on what you have seen and on 22 your experience in your professional view, could you describe ACE-FEDERAL REPORTERS, INC.

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for me what kind of training program would produce the sort i

2 of news dissemination that you would like to see in an

)

3 emergency?

4 A

This is a difficult area, and I would rather take 5

a systemic view that in terms of crisis management, the j

6 communications component is only one part, that in crisis 7

management one has to s tress 166alch, mi tiga tion,

8 prepa ra ti on, response and recovery.

To focus only on 9

communication during the response period is to shortehange 10 the trainees.

Now, I don't want to sit here and give you a 0

11 dissertation on what I think people ought to do to be trained t

12 properly, although I enjoy talking about that, because I 13 think it's a productive and constructive thing to do, but to 4

l 14 just 1ook at thal narrow s1 ice of. training procedure for the 15 response part would be an inadequate view of the overall 16 training requirements for emergencies of the kind we have 17 heen discussing.

18 Q

Can you identify for me any elements, generally, l

19 :

theoretically, any elements that you think are missing from i

20 the training program that the exercise participants were i

}

21 trained in?

! O

]

22 A

I can't. give you a definitive answer on that, i

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1 because all I have been able to see is some indications of a

2 the outcorre, rather than the input.

So I am at a loss to say 3

wha t w-is missing f rom the input, having not looked at the l

4 4

training itself, but looking at those things I have aircady 4

i S

had a chance to look at, which indicates an assessment of how 6

they did, I would say something serious was missing.

Ilut T 7

would have to look at the training materials themselves 8

before I could identify with any degree of assurance those 9

things that should have been done that weren't done or those 10 things that were done that. shouldn't have been done.

O 11 Q

Then could you identify for me the behavior during 12 the exercise that suggests to you that there is a problem in i

13 the training program?

14 A

Well, a number of things come to mind immediately 15 and there are probably more, but the lack of timely 36 responses, the failure to control rumors, the inabi]ity to l

17 disseminate clear, concise and consistent information, the 18 delays in telling people that an evacuation have been i

19 ordered.

For example, aL the news eenter, the informaLion i

20 l

wasn't released in a timely fashion.

If a reporter was at 21 the news center and found out that the radio messages from

' O l

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should evacuate and they hadn't been told at the news eenter, 2

most reporters would be mad, angry.

But I wouldn't want t.o 3

say tha t that is the sum total of all of the feelings I have 4

about this; but you look at it and say those are pretty J

S important symptoms of a problem, among other things.

That I

6 just pops into my mind.

1 7

Q Is it your view that those sorts of problems could 8

he remedied by training?

9 A

Adequate training could help in some regard, 10 sure.

But whether it could remedy, cure all the

, O 11 deficiencies, is something that I would have to look at 12 before I would be able to give you a sweeping answer.

13 Q

Are there any other contentions that you reca]1 14 seeing right now that you intend to file testimony on tha t we 15 haven't discussed?

16 A

I haven't read all of the contentions.

I have 17 only read the ones that we have discussed today.

I don't 18 have any plans to comment on.any'of the others.

19 MR. MC MURRAY:

I think you have covered what we

.i 20 have identified before, Ms. McCleskey.

I don't intend to 21 provide him with any others.

22 MS. MC CLESKEY:

I have no other questions.

i I

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Thanks a lot, Mr. Roman for coming today.

2 MH. ZAHNLEUTER:

No quest. ions.

3 (Whereupon, at 1:07 p.m.,

the deposition was 1

4 concluded.)

S hW

/

6

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7 SPENCER FORD ROWAN i

8 9

10 O

11 12 13 14 15 16 I

17 1

18 j

19 1

20 i

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21 a

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CERTIFICATE OF NOTARY PUBLIC & REPORTER 74 I,

WENDY S.

COX the officer before whom the foregoing deposition was taken, do hereby certify

that, the witness whose testimony appears in the j

foregoing deposition was duly sworn by me; that l

the testimony of said witness was taken in shorthand and thereaf ter reduced to typewriting by me or under my direction; that said deposition is a true record of the testimony given by said witness; that I am 1

neither counsel

for, related to, nor employed by any of the parties to the action in which this deposition was taken;

and, further, that I am not i

a relative or employee of any attorney or counsel O

e 91oved hv the parties hereto.

nor financia117 or otherwise interested in the outcome of this action.

4 1.

1 l

Notary Public in'and for the Distrie:t of Columbia i

My Commission Expires 11/14/87 i

O 1

l

.