ML20237L510
ML20237L510 | |
Person / Time | |
---|---|
Site: | Shoreham File:Long Island Lighting Company icon.png |
Issue date: | 03/31/1987 |
From: | Saricks C AFFILIATION NOT ASSIGNED |
To: | |
References | |
86-533-01-OL, 86-533-1-OL, OL-5-I-SC-011B, OL-5-I-SC-11B, NUDOCS 8708280133 | |
Download: ML20237L510 (206) | |
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UNITED STATES OF AMERICA
'87 AUG 21 P2 :51 NUCLEAR REGULATORY COMMISSION P;
ATOMIC SAFETY AND LICENSING BOA ;
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LONG ISLAND LIGHTING COMPANY . e (Shoreham Nuclear Power Station' (ASLBP No. 86-533-01-OL)
Unit 1) ,
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x
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DEPOSITION,OF CHRISTOPHER L. SARICKS i
Washington, D. C. .
l Monday, November 24, 1986 ,
i ACE-FEDERAL REPORTERS, INC.
Stenotupe Rercrters i
444 North Capitol Street l
Washington. b.C. 20001 (202) 347-3700 Nationwide Coverag' e l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COM'tISSION 2 l I
ATOMIC SAFETY AND LICENSIMG BOARD 3j i
4 __________________, ,
5 In the Matter of [DocketNo. 50-322-OL-5 (EP Exercise) l :
LONG ISLAND LIGHTING CCMPANY 6
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(Shoreham Nuclear Power Station, .
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DEPOSITION OF CHRISTOPHER L. SARICKS Washington, D. C.
10 Monday, Noven' r 24, 1986 11 I i i Decosition of CHRISTOPHER L. SARICKS, called for ,
12 ~
[ examination, cursuant to notice, at the Law Offices of !
13 Kirkpatrick & Lockhart, 1900 M Street, N. N., Washington, D. C.,
20036, Suite 800, at 9:12 a.m., before Garrett J. Walsh, Jr.,
i 15 a Netary Public in and for the Commonwealth of Virginia at 16 Large, when who were present on behalf of the respective 17 I parties:
1 18 . MICHAEL S. MILLER, Esq., and SUSAN M. CASEY, Esq., ;
1 19 Kirkoatrick & Lockhart, 1900 M Street, N. W., Nashington, 20 D. C., 20036, on behalf of the Interveners.
JESSINE A. MONAGHAN, Esq., and LEE B. ZEUGIN, Esq.,
l 21 :
l Hunton & Williams, 707 East Main Street, Richmond, 22
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! Virginia, 23212, on behalf of the Applicant.
l ORESTE RUSS PIRFO, Esq., Nuclear Regulatory Commission, i
2 :
I 9:ashington, D. C., on behalf of the NRC Staff.
3 I
I WILLIAM R. CUMMIMG, Esq., Federal Emergency Management 4
Agency, Washington, D. C., on behalf of FEMA.
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--- CONTENTS s
2 Christopher L. Saricks 3 Examination by Mr. Miller Page 4 Examination by Ms. Monaghan Page 170 4 Examination by Mr. Pirfo Page 174 5
EXH'IBITS 6
FOR IDENTIFICATION
- 7. Saricks Deposition Exhibit Numbe.r 1 Page 59 I
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Saricks Deposition Exhibit Number 2 Page 80 9 Saricks Deposition Exhibit Number 3 Page 111 10 Saricks Deposition Exhibit Number 4 Page 127 11 Saricks Deposition Exhibit Number 5 Page 148 12 l Saricks Deposition Exhibit Number 6 Page 160 V
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l i AG-:?EDERAL 3EPORTERS, NC. I l 3347-T?00 Nanonws;!c C.r..: rase 300l h l
PROCEED!NGS I I
2 Whereupon, 3 CHRISTOPHER L. SARICKS 4
was called as a witness and, having first been duly sworn, )
was examined and testified as follows:
5 i EXAMINATION BY MR. MILLER:
7 Q Mr. Saricks, will you please state your name and 8 kl4 l business address for the record?
9 A Christopher L. Saricks, 9700 Case Avenue, Argonne, 10 l That is the Arbonne National Laboratory. You don't
[ _ Illinois.
11 !
! need a building number, do you?
l 1
Q No, that is fine, I
13 Okay.
) ;
A 14 Q Mr. Saricks, my nane is Mike Miller, and I am an I i
15 : attorney for Suffolk County, which is one of the Interveners 1
I 16 ! in the Shoreham Licensing Proceedings. This is Ms. Casey from j l l 17 my Firm, Kirkpatrick and Lockhart.
t l
,g l We are taking your deposition today for discovery l l purposes, and we are seeking information relating to the l exercise at the Shoreham Nuclear Plant on February 13, 1986, 20 l and let me just say at the outset that if I ask an/ questions 21 i l that you do not under1tand or you want clarific. tion, please 22 ;
Ate-:?EDERAL REPORTERS, :~NC. _
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--- just tell me that, and I will be glad to try to rephrase or 2 I want to make sure you and I understand j clarify the question.
3 each other so we can get to the truth this morning.
4 Let me ask you at the outset, Mr. Saricks, did you 5 bring any documents with you this morning?
! I i
I 6 j A No, I have nothing with me this morning. I have i
7 turned over the documents to counsel. j i
8 Q Do you, at this time, have any documents in your )
j
(
possession, or custody, or control regarding the Shoreham i 9 l l exercise, whether here or at Argonne National Laboratory?
10 l l ! A I have nothing in my possession.
l 11 !
j Q When you say nothing in your possession, where 12 }
l-lwoulditbethen?
13 l ; A With counsel.
l l l
14 l 0 With counsel, Mr. Cumming? l l
15 l A Yes, sir.
16 ! O Do you recall offhand, Mr. Saricks, what documents, 1 l 1
' 17 ! if any, you would have generated during the exercise itself?
18 A During the exercise?
19 ; Q During the exercise.
A The only document generated during the exercise was 20 some personal notes, which I took while in the field.
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i l Q And I assume those are notes reflecting matters that 2! you observed during the day of the exercise?
I t
3I A That is correct.
4 Q Were those notes turned over to Mr. Cumming?
s A Yes.
6 Q Did you generate any documents prior to the exercise and relating to the exercise?
7 8 A No, I did not.
9 Q Did you generate any documents subsequent to the l
1986?
10 lexercseonFebruary13, I A May I understanc, are you asking on February 13, il l l 1986, did I generate documents pertaining to the exercise?
11 i Q Well, let me back up and make sure we understand.
13 -
The exercise ended at approximately five o' clock in the 14 afternoon on February 13th, is that correct?
l 15 !
l A Yes.
16 Q And up until five c' clock on the 13th, the .only 17 documents you had prepared were your notes, correct?
i i l
18 A That is right.
1 19 l Q Now, after five o' clock on February 13, 1986, did i
20 , you generate any documents relating to the exercise?
l 21 '
A But prior to midnight on February 14th, or --
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- - - - . - - 0 Any time after five o' clock p.m., on February 13, 2 1986, did you generate any exercise documents -- related 3 documents?
4 A Yes, I did.
5 0 okay. What doc.uments?
6 A I completed a set of evaluator critique forms.
I I
Q Was there any other documents you prepared?
7 A Nog 8 6 Q Were those critique forms prepared on February 13th?
9 A No, they were not. They were prepared the following 10 i
day.
11 !
! Q On February the 14th?
12 A Yes.
13 Q Were those critique forms prepared based upon the 14 notes you had taken during the day of the exercise?
15 A Information that was on the notes was helpful' in 16 preparing the forms, but they were not entirely transcriptions.
17 It was, in part, based on recollection and judgment.
18 l 0 So, the completed critique form, I assume then, 19 j would be -- would contain more information regarding the l
! exercise than your own personal notes?
20 l A That is correct.
21 ! i l 0 And those critique forms have been turned over to 22 l l
./
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i Mr. Cumming as well?
2 A They are in Mr. Cumming's possession, yes.
3 Q Mr. Saricks, at Argonne National Laboratory, to 4
whom do you report?
A My immediate supervisor is Larry Johnson, 'he 5
Director of the Center for Transportation Research. Within 6
the admini.strative line, as the divisions are organized at 7
Argonne, the Director of my division is Edward Croke, Director 8
of the Energy Environmental Systems Division, 9
Q How big is Argonne?
10 A You are talking employment?
i 11 -
Yes, just roughly. How many empic,yees, would you say?
7 12 A At the Illinois site, there are two Argonne I
13 ! Laboratories., At the Illinois site, there are approximately 14 l 50,000 employees.
15 , O I assume from your answer that you are within the i
16 Energy and Environmental Systems Division of Argonne?
A That is correct.
17 f 1
I O Were any ther persons within that division -- did 18 ,
l any other persons within that division participate in the 19 i l
l Shoreham exercise?
20 l A Yes.
21 l i
O Who would that have been?
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l j A To the best of my knowledge, all of the contracted I
2 i i
Argonne observers at the Shoreham exercise were within the l Energy and Environmental Systems.
3l l
i Q Can you tell me just briefly, Mr. Saricks, what 4
you do as a transportation systems analyst?
5l 1 l A Okay. As I say, within the group called Center 6[
I for Transportation Research, our' primary responsibility is 7 1 doing analyses relating to Department of Energy's transportation 8 i energy conservation, and environmental impact programs. j 9
So, our principal sponsors are the office of l Transportation Systems of the Department of Energy, and the l <
11 ! Office of Environmental Analysis, also within the Department 1
12 of Energy.
I 13 . Q Do you know who solicited Argonne's participation f
! > l 14 at the Shoreham exercise?
I l l l 15 l A I don't know the specific individual. I know that I l
16 j we are under contract to the Emergency -- Federal Emergency i
l Management Agency to provide evaluators for nuclear exercises 17 l
-- nuclear power plant exercises, and have been in this capacity 18 l to
! since 1981.
^"
l 1 l i I don't know the specific individual or individuals !
l 20 l
- who solicited Argonne's participation in this exercise.
21 ;
MR. CUMMING: Counsel for FEMA has no objection to 22 i I
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--- this line of questioning, if it is not going to be extensive.
2 It is not relevant.
3 MR. MILLER: It is just background information, 4 and it is not going to be extensive.
5 BY MR. MILLER: (Continuing) 6 Q Mr. Saricks, prior to becoming a transportation 7 systems analyst, did you hold any other positions at Argonne?
g A No. May I clarify. My actual title within the laboratory is Environmental Scientist. That is for the laboratory's purposes.
10 l l Transportation Systems Planner is a title within 11 ,
l j the group with which I work, and which relates to my specific j 12 I L function within that group. I have never held any other i
13 I position within the laboratory.
14
! Q So you are an environmental scientist?
I U A For the laboratory's. purposes, yes. That is my l
16 title.
1 i 17 l
Q Do you know why you would have been designated as 1 l
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l 18 a transportation systems analyst?
19 l A That is my professional background. The laboratory l
does not have a laboratory-wide title of transportation systems 20 analyst, or transportation planner. It is really a minor point, 1
! but I wanted to clarify what my actual title is in the laboratory 22 .
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Ate-PFDERAL D_POR'1EKS,NC.
. MM7-UDO Nanenwu:e Cmose SCO-33W e-__-_-________-_____-__-______ _ _ _ _ _ _ _ _ _
Q When did you first join Argonne?
2 l A 1979.
3 Q Was that your first job?
4 A No.
5 Where were you prior to joining Argonne?
0 l
Immediately prior to joining Argonne I was with a 6 A 7 firm called Pacific Environmental Services, where I was the 8 group leader for planning and evaluation. Prior to that, I was the Director of Environmental Assessments for the Chicago 9
10 Area Transportation Study, which is the metropolitan planning
" organizations for the six counties in the Chicago metropolitan 11 I area.
12 .
I l Q And what degrees do you hold?
l 13 i A I hold a Master of Philosophy from London School 14 l l of Economics, Political Science. My undergraduate degree from 15 the University of Kansas, and I have additional post-graduate 16 i
work at the University of Chicago.
I 3 #
l ! O I assume, Mr. Saricks, that you have been involved I
1 13 as an evaluator at other exercises, FEMA-graded exercises? l
. i l
19 l A Yes. ]
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20 ! Q Can you just roughly tell me the number of what ]
i 21 other exercises you participated at? l i
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- - - - - A To date, it is in excess of thirty.
2 All as an evaluator?
O 3 A That is correct.
4 Q Have you always been an evaluator with respect 5 to field activities, such.as you did at Shoreham?
6 A No. I have, I believe, served in the capacity of 7
evaluating all aspects of emergency response with the exception of accident assessment, which is dose computation.
l So, I have co vered all other activities.
9 Q During the Shoreham exercise, am I correct that 10 you had responsibility for reviewing, evaluating the traffic 11 impediment free play incidents from the Patchoque staging 12 i sz area, traffic guides out of the Patchoque staging area, and l
13 1 route alert drivers ' out of the Patchogue staging area?
l 14 Il A That is correct.
15 1 0 Now, prior to the Shoreham Exercise, have you ever 16 evaluated, or had responsibility for evaluating traffic 17 l control personnel at other exercises?
18 ; A Yes.
i 19 j Q What about route alert drivers at other exercis<ss?
I A To the best of my recollection, I had not been 20 )
involved in an exercise where I was the evaluator for route 21 !
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- alerting. So, I guess my answer.to that would be, no, not to 22 i
. .. i A u ..-rEDERAL _lEPORTERS, __NC.
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2 0 And what about response to simulated traffic 3
impediments. Have you ever done that prior to Shoreham?
4 A Yes, I have.
5 0 Tell me just, in your opinion, what is it in your 1
6 background that qualifies you to evaluate a response to traffic 7 '
impediment situations?
8 A Well, to be perfectly frank, I don't think my g
professional training has provided specific skills for that I
fun tion.
10 l Certainly it is helpful that I have some knowledge 11 i of the way that traf fic is supposed to work on roads, and 12 l what conceivably could happen when traffic is obstructed.
j 13 l I also have some knowledge of the kind of equipment 14 that would be used in removing impediments, but beyond that 15 Ij I can't say that my professional credentials are specific to 16 that particular responsibility.
l I
17 0 You say you have some knowledge with respect to I
18 l traffic and the equipment that would be used to clear up 19 traffic and so forth. What knowledge are you referring to?
i 20 i A Simply prior experience.
21 i Q From.other exercises?
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i l A That is correct.
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j Q Is your answer the same with respect to your l i
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! expertise in evaluating traffic control personnel?
I 4 l A For the most part yes, although that is supplemented 5 to a very modest extent by- my experience with the Chicago 6 Area Transportation Study, which periodically would perform j 7 various sorts'of field counts and surveys.
8 So -- but that is quite limited and probably much f g
less relevant than my actual FEMA experience. ,
O Field --
10 l
A Just simply doing traffic counts and surveys.
11 Q Traffic capacities?
, 12 ! ,
i A Yeah.
I 13 I j Q Mr. Saricks, I assume from some of your answe'rs q 14 ! j i this morning, you had no involvement in the preparation of the 15 !
j exercise objectives for the Shoreham exercise?
16 That is correct.
A 17 { Q And you had no involvement, I assume, in connection 18 I with the preparation of the exercise scenario?
19 { A That is also correct.
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20 ; Q Did you have any involvement in preparing any of the free-play messages used during this exercise?
21 i A No, I did not.
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Q Now, do you know whom, if anyone, at Argonne was 2
involved in the preparation of the exercise objectives?
l 3 i A I do not know for certain, no. I could only 4
speculate, and I don't think it is appropriate to speculate.
5 0 Well, I will ask you to speculate. Who would
- 6. you speculate it was? ,
7 MS. MONAGHAN: Objection to that.
g MR. CUMMING: Objection. Do you know, or do you 9
n t know?
THE WITNESS: I can give an answer, but based on 10 i ~ speculation, but that would not necessarily be the individual.
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MR. CUMMING: Objection, it is based on speculation
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and he doesn't know the answer.
13 THE WITNESS: In other words, I was not told the i
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I individual. I think it would be something I had gained only 15 through inference.
16
- MR. CUMMING
- The witness testified he has no l
17 ' personal knowledge.
18 MR. MILLER: Okay. We have all the objections, and 1
19 j I am still asking for an answer.
20 ; MS. MONAGHAN: I just want to note my continuing 1
i 21 i objection to this line of questioning.
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MR. CUMMING: I am instructing the witness not to 2l answer.
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MR. MILLER: On what basis?
4 MR. CUMMING: On the basis he doesn't know.
5 MR. MILLER: He'said by inference he could provide
- 6. an answer. I don't think it is proper for you to instruct the 7 witness not to answer, but you are his counsel.
l 8 MR. CUMMING: I cm instructing him not to answer.
9 He testified he didn't know, and he could only speculate.
l l
10 BY MR. MILLER: (Continuing)
! O Mr. Saricks, if you were to answer my question, what i
i would your speculation be based upon?
12 i v i A Telephone conversations.
13 l
' l* Q With whom?
14 j '
MS. MONAGHAN: Continuing objection to this line 15 of questioning. It is total speculation on the witness' part.
16 It is just not relevant.
17 THE WITNESS: With individuals in Region II, FEMA; 18 with other Argonne staff.
i 19 l BY MR. MILLER: (Continuing) l 20 l I Q Did those individuals mention to you who had been l
21 '
involved in preparing the exercise objectives of the Shoreham i
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A No. I was at no time informed who had prepared the 1
3 exercise objectives for the Shoreham Exercise.
4 Q I am confused --
5 A I am sorry. Your cuestion regarded the preparation 6 of free-play messages, I believe.
7 Q Let's ba ck up. Do you have any knowledge regarding 8
who prepared the exercise objectives for the Shdreham Exercise?
A No, I have no knowledge of that. I am sorry. I g
thought your line of questioning pertained to the preparation
,)
f loffree-playmessages.
11 l j Q Do you have any knowledge regarding whom would have 12 '
prepared the exercise objectives for the Shoreham Exercise?
13 MR. CUMMING: I believe counsel is restating the 14 question over and over.
THE WITNESS: The answer to that is no. I really 1
16 lhavenoknowledgeofthat.
17 BY MR. MILLER: (Continuing)
I i
18 j Q What about the exercise scenario?
19 ! A No, I have no knowledge of that.
I I
20 l Q And now to the free-play messages.
I A That is the one in which I could speculate as to who j 21 22 1
i i ACE- ?EDERAL 3EPORTERS, NC.
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i did that, but again, I do not have specific knowledge of such 2
individual or individuals.
3
! Q Okay. Now, with respect to the free-play messages, 4
your speculation would be based upon telephone calls you had 5
I with FEMA Region II personnel, and other Argonne personnel?
i 6L A That is correct.
7 '
Q Now, whom were the personnel you talked to?
8 MR. CUMMING: I have no objection to the witness l
l 9
answering with respect to FEMA personnel, but I do object to 10 l answering in respect to the Argonne personnel, unless he has personal knowledge.
11 ,l l I will instruct the witness to answer with respect 12
.i to the FEMA personnel.
13 l i 4
THE WITNESS: I had at least one discussion with 14 j Roger Kowieski, and I am trying to recollect if there was 1 tg \
j another individual involved in that particular issue.
16 l No, the other conversation that I held was not 17 pertaining to anything regard to that.
18 BY MR. MILLER: (Continuing) l \
19 l Q Now, did Mr. Kowieski tell you who had prepared the l
20 free-play messages for the shoreham exercise?
21 A No, he did not tell me.
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2 What did Mr. Kowieski tell you about the- free play l messages?
3 !
I A The discussions mainly concerned the specifics
> 4 regarding the free-play messages, or what was the content 5
of the messages, and what my estimate would.be -- well, it was 6
, a realistic situation. .
~
i That is really about all I can say about that.
8 0 Okay. I am back to my initial question, then. I l
9 asked if you knew who prepared the free-play messages, and you 10 i said you could speculate, and I asked what was the basis of I
~that speculation, and you said telephone conversations.
,_ A That is correct.
N..
Q You mentioned telephone conversation with Mr.
13 Kowieski.
14 A Yes.
15 0 What is it in your telephone conversation with Mr.
16 !
Kowieski that provides you the ability to speculate about 17 i who would have prepared the free-play messages?
18 ! MS. MONAGHAN: I am going to object to this line 19 l of questioning. It is really pretty far afield from what is 20 at issue here.
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21 j MR. CUMMING: The witness may answer the question, I
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but counsel objects to -- the witness has testified he had no 2 ! ,
! participation of either the scenario or the objectives. ]
3 i i Counsel for Interveners is merely attempting to 4
gather further names. We provided more than enough information '
l 5 concerning additional names of Argonne people who are involved. I l
l 6i In fact, we fully responded to interrogatories of l
I 7 1 everybody who was involved in the issue you are addressing.
i
[g THE WITNESS: The short answer to that question is a name was mentioned of an individual who, in fact, was not 9
a Region II FEMA employee.
10 ; .
i MR. MILLER: I would ask you the name of that person.
11 1 ,
l MR. CUMMING: Counsel for FEMA objects, but witness 12 {
j may answer the question.
13 1 THE WITNESS: The name given was Thomas Baldwin. i 14 ;
- BY MR. MILLER
- (Continuing) i 15 l '
, So, it is your understanding that Mr. Baldwin had 16
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l responsibility for preparing the free-play messages for the 17 Shoreham exercise?
18 MR. PIRFO: Objection. You are characterizing l
19 ;
his testimony. He said he was speculating right along.
20 THE WITNESS: That is my inference and speculation t
21 only.
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l MS. MONAGHAN: We also object to the relevance of 2
that.
3 BY MR. MILLER: (Continuing) 4 i 0 Mr. Saricks, I have asked you about any documents I
5l you prepared prior to the shoreham exercise. Let me ask you l
h 6 more generally: Did you have any involvement regarding the 7 Shoreham exercise prior to the date the Shoreham exercise was 8 held other than the conversation with Mr. Kowieski you have 1
9 n w mentioned?
i 10
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! O So, to the best of your recollection you had one 11 l
' l telephone conversation with Mr. Kowieski prior to traveling 12 l J
to Long Island for t* Shoreham exercise?
~
13 .
i A I received a packet of materials regarding the l
14 l l exercise logistics. My assignment and others were mailed out I
15 :
! the preceding week, so I had information regarding the exercise i
16 j I believe at least a week prior thereto, but it was only in 17 , relation to the kind of exercise, my assignment, the schedule, 18 l ,
and so forth.
19 i I Q And other than that packet of. materials and your I
20 l telephone conversation with Mr. Kowieski, was there anything l ,
21 j else you can recall prior to the date of the exercise? j 1
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1 A Nothing that had anything to do with my involvement, 2 i l no. As I say, my views were asked regarding the free-play
/
i 3
messages on the traffic impediment, and beyond that, no.
4 When you say nothing other that involved you, was Q
5 there anything prior to the exercise that you heard, h
6 F conversations you had with other persons, whatever, that 7 l regarded the Shoreham exercise?
I J
I A I recall nothinc substantive. No participation 8
and no conversations of any substantive -- my recollection on g
i
! that is not perfect, but I would have to say, no.
10 j l
Q When you first received your packet of materials 11 !
I on the exercise, did you look at those materials right away?
12 .
i
' .j A Yes.
13 l So, you would have been looking at some exercise-O I
14 i ! related materials approximately a week before the exercise was i
15 i held?
l 16 A That is correct.
l.
I 17 l Q Who told you that you were going to be an evaluator I
18 at the Shoreham exercise?
19 i A I believe the actual individual who told me that 20 InY participation was being solicited, and did I have any 21 1 bjections to being signed up, was Ed Tanzman, but again, I am 22 l n t entirely sure.
l l
l :
1 Ath-?EDERAL REPORTERS, INC. '
a =.w.n ~- - -
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l Do you recall what was said to you at the time? l
]-- 2 Q
l A I can explain to you what our normal procedure is 3 ) regarding the exercise evaluator selection, and my recollection l
4 is --
5 Q Why don't you tell me.
l A There is for each FEMA Region within the Argonne
- 6. k' 7 Operations, someone called a regional coordinator. In other 8
words, this is a person within the laboratory responsible for g
serving as liaison between the needs of the individual regions with regard to evaluators , and the availability of resources 0
I ~at Argonne.
11 !
At the time of the Shoreham exercise, I do not 12 !
d l recall who was the so-called regional coordinator for Region II.
13 l l That is why I say I am not entirely sure it was Ed Tanzman who 14 contacted them. But that individual would generate a memo i
15 i to Staff that: a, he has been specificly selected; or, b , a 1
larger list.
i 17 l If, for example, the need for evaluators is very 1
18 great, indicating the dates of the exercise, and requesting 19 ! availability.
I 20 ; I had indicated probably at least two months before 21 ; that I would be available during that period of time. j i
p 22 I l
s
{.
AG-rEDERAL 3EPORTERS, EC.
. 2 2-347 3'00 Nanoomce Ca..: rge 300-3364em66
l l
__ __ __ i
. l Then, during I believe the month of January I was 2
approached by someone and indicating they would like to have my participation, and I agreed to that, and then shortly there-4 after I was informed as to what my assignment would be.
5 Then, really, except for the phone call which I
)
6~
mentioned, I had no other communication regarding the exercise l 7 until receliing the exercise packet, the week prior to it.
8 Q Do you know who the regional coordinator for 9 Region II is today? At Argonne?
)
10 A I believe the individual serving in that capacity 11 n w is Bill Gasper, at Argonne.
O Is it fair for me to assume from your previous f
/~- 12 ,
v answer of a few moments ago that you believe Mr. Tanzman would 13 l have been regional coordinator at the time of the Shoreham j
14 :
! exercise?
15 !
! A He may have -- well, no, I don't think he was ever I
16 1 i actually regional coordinator, which is the reason why I think 17 lthereisapossibilitysomeoneelsemighthavementionedit, j
18 l but he did have some specific organizational responsibilities l
19 regarding the Shoreham exercise that he may have been the one 20 i to approach me.
l 21 Again, you are getting me lost in this area of 22 !
1 1
! ACE-3EDERAL 3EPORTERS, ENC.
I W "47
> N Nanonww1e Co. erase 800 336-oo*6
speculation, and I would like to say that I know for sure that m,
2 it was Ed Tanzman, but I can't answer honestly that it was he 3
that said: We need you for the exercise.
4 Q I am not trying to get you lost in the area of speculation.
- 6. A okay. .
7 Q Mr. Saricks, I believe you said that under the general 8 process either a memo would be written specifically indicating l
9 who would serve as evaluators, or a larger list would come 10 out for the Shoreham exercise. Which was it?
~
A I believe that initially there was a general memo 11 that came out saying this exercise would be scheduled, but uj the distribution was not covering all of the individuals who 13 l l
h'ad, at one time or other, served as FEMk contract evaluators.
14 '
So, it may, in fact, have been a shorter list of 15 people who were presumably being targetted because of their 16 ,
i specific background and knowledge, or abilities.
17 But there was a memo generated.
18 Q Targetted by whom?
19 l A Again, I don't know. I presume the regional i
20 coordinator at the time. Perhaps the person -- again, there 21 ! is a slight difference in our relationship with Region II, also, 22 j
- l AG-:?EDERAL lEPORTERS, SNC.
! E* A7500 Nanonmos C r.caer 300-3Wied6
p-- eu
]-- 2 from the other regions.
Thomas Baldwin, who is an Argonne employee, is 3
located here in the New York area, rather than at the 4 '
laboratory. He maintains much closer ties with the r egional 5 office in New York than we~ maintain with, say, the other
- 6. regional offices around the country.
7j So, it is quite possible that he, in this particular-8 instance, was the person -- !
9 MR. CUMMING: Don't go any further. Either you know or you don' t know.
10
^
. THE WITNESS: Well, I don't know, but it is possible 11 ;
that -- the memo was generated.
11 s_/ i MR. CUMMING: You don't know.
13 l THE WITNESS: That is true; I don't know. j 14 I l-B I know about a system, but I am speculating about what went 15 on within the system.
16 i MR. MILLER: Are you through, Mr. Saricks?
17 THE WITNESS: I think so.
18 MR. MILLER: Are you through , Mr. Cumming?
I i
I 19 i MR. CUMMING: I hope so.
20 i BY MR. MILLER: (Continuing)
I 21 , o Mr. Saricks, you said that ap' proximately two months
! I 22 '
1 s
l l
( !
l I i AcT-3EDERAL REPORTERS, .NC. !
l *
. CWT-3M Nanoomoe Ccursat M3M
.__. -_______ - - D
m before the Shoreham exercise, you indicated you would be 2
available to serve as an evaluator at that exercise?
3 A Yes.
4 0 To whom did you indicate that?
5 A To the best of my recollection I can't remember 6-the individual. I can give you one of three people it might '
7 well have been. Can I do this, or not?
8 MR. CUMMING: Either you know or you don't know.
9 Please don't speculate.
THE WITNESS: Okay --
. 10 BY MR. MILLER: (Continuing) gl I
Q You said it was one of three people.
12 s.)
A But I don't know which.
13 hR. CUMMING: You don't know. The witness' testimony 14 i '
is that he doesn't know. f 15 i j BY MR. MILLER: (Continuing) 16 0 Who would'those three people be, Mr. Saricks, that 17 it could have been?
i 18 MR. CUMMING: You may answer the question.
19 l THE WITNESS: Al Smith, Tom Baldwin, or Ed Tanzman.
I 20 l .BY MR. MILLER: (Continuing) l
... " 21 [ Q Mr. Saricks, is it fair to say that the first contact 22 l l s l l \
! Au-3EDERAL REPORTERS, :NC.
I l22 347-FOO Nanenwide Ceg 900 r446e6
l 28 l
- ~ ~ ~
ThA you would have had regarding the Shorehan exercise was your 2
indication some two months prior to the exercise that you 3
would be generally available to be an evaluator?
4 A Yes.
5 Now, subsequent to that time you have indicated 0
6 [ that you received a packag e of materials about a week'before i
7 the exercise, and then you had a telephone call from Mr.
8 , Kowieski some time before the exercise?
l 9 A Yes.
10 ; Q Now, is there anything else that you did prior j to the exercise regarding the exercise that you can recall i
! and can tell me about today?
w>
12 l ,
1 A No. There is nothing.
13 !
I Q When you were informed of what your assignment at 14 j the exercise would be, did you do anything in response to 15 !
i that?
16 !
A Only reviewed my experiences in past exercises, 17 and simply brushed up on what I did know in that area. I made 18 ~ no specific preparations related to the f act that the exercise 19 was going to be on Long Island.
20 Q How did you review on what you had done at cther 21 l exercises?
22 ACE- FEDERAL 32FORTERS, 'NC. _
} 2 4.c-TTOO Nanonwme Co. case 300 336.o6 4
29 l
l A Well, I have notes and reports from prior exercises 2 i l
in which I participated as an evaluator. I simply looked at 3
the way certain issues had been addressed and resolved, and 4
5 0 But you have no'such notes for Shoreham?
- 6. I A The notes ' -- as I said,, the notes which I took on 7 the day of the exercise I turned over to counsel.
8 O Mr. Saricks, did you evaluato any areas at the 9
Shoreham exercise other than rcute alert drivers, and traffic l.
10 i guides , and the traffic impediment?
l -
A No, that was the extent.
I Q Did those three activities take the entire day on v
- 12 j i February 13th?
13 l A My recollection is I completed the last -- my L4 l l last assignment with the traffic control point -- I completed 15 l
! the last traffic control point roughly an hour to an hour and 16 I 1 s half before the official termination of the exercise.
l 17 So that would have been roughly three-thirty in the l 0
, i 18 ! afternoon?
19 : ,
A Three-thirty to four o' clock.
20 ! O And when did you begin that day, in terms of your l
21 ! evaluation?
22 Aa-:?EDERAL 3EPORTERS, NC.
- m.m.m s _ _, -
30 j l !
1 i
- A I didn't write anything further that day.
2 i I
Q When did you begin the day, in terms of your 3
evaluation?
4 A Oh, I am sorry. By instruction from my team leader, 5
l I arrived at the Patchogue' staging area some time between 1
6 j' seven-thirty and eight prior to declaration of site area 7 l emergency, so I was essentially in place and ready to deploy 8 withthefirstassignmentbysehen-forty-five.
9 0 Who was your team leader during the exercise?
A Robert Reynolds.
10 l ;
j Q Is Mr. Reynolds a FEMA employee?
A Is - 1 12 )
J i Q Is Mr. Reynolds a FEMA employee?
13 l l A Mr. Reynolds was a FEMA employee at the time, yes, 14 !
sir.
15 I Q He is no longer with FEMA 7 l
16 i i A I don't know. I have been told that is the case, but l ,e
- I don't know.
I 18 : 0 Did you ever ask the person who informed you of -l 19 , your exercise assignment why you were chosen for that i
20 l assignment?
21 A No, I didn't, because it was logical to me, given what 22 !
I p
- Ath-3EDERAL DORTERS, ENC.
I =:-m-rmo sw.e m c ca.ea ,
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g--
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T-- I had done in some prior exercises, that I would be certainly on 2
a short list of people that would be asked.
3 I can say that prior experience in Region II, I think, 4
had some effect on my being selected.
b All right. -
Q l
6- A No specific rearons given to me at'the time.
7 0 My question was: Did you ever ask?
8 A No, I did not.
9 Q Did you ever inquire as to why you were 7.ssigned to the Patchogue staging area?
10 l A No, I did not.
l 0 Could you gone. rally describe to me, Mr. Saricks, 1
12 the nature of your assignment as an evaluator at the Shoreham
, 13 1 l
exercise?
14 l A Okay. There were three types of assignments I :
]
15 was to complete during the course of the exercise. I l
16 l l The first was to either accompany or follow a driver i
l 17 ! of a back-up notification route and area where -- a siren had i
l 18 ! presumably failed. To observe this person's procedures, and 19 ltoaskanyquestionsthatImightfeelpertinentrelatingto 20 this individual's actions and his training.
I 21 ! My second assignmant was to observe the response i
22 ;
.i I
L ACE-FEDERAL lEPORTERS, :NC.
1 --as 8- .- -
32 l l
to a simuleted road impediment in terms of equipment dispatched, 2 l l and again, knowledge and training of the responders. Any my )
1 third assignment was to visit a total of nine traffic control 1
l 4 po nts, a number of which were essentially co-located at 5 individual intersections, to interview the traffic guides at 6 those locad ons regarding what the procedures would be, not 7 only with respect to traffic control, but also informational g functions in their protection as emergency workers.
I Q Did you do anything to prepare for this deposition, 9
i 1
Mr. Saricks?
i -
A I looked over my notes again, and I read the ,
11 ! l l exercise report.
12
'~
j Q The exercise report is the FEMA report?
13 !
A Yes. The final report. j L4 1 0 I note it is Post Exercise Assessment. We call it 15 I the FEMA Report. So we are on the same wave length.
1 16 A Yes.
17 0 When did you review t. hat FEMA Report last?
18 j A I suspect within the last 72-heurs.
19 0 Did you read the entire report' i
20 A No, I did not'. l Q Just those portions relatine to the Patchogue I 21 I !
22 { staging area?
I
\
1 l Ath-3EDERAL REPORTERS, '.NC.
- =.w.- -- u -, -
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i 33 l
l l A Yes.
2l 0 Jnd your notes, Mr. Saricks, when did you review 3
those notes?
4 A Also within the past 72-hours.
5 I assume they were provided to you by Mr. Cumming?
C
- 6. I A Yes.
From your review, your recent review of your 7} O 8 notes and the FEMA Report, did you see anything in the FEMA 9 Report regarding the Patchogue staging area -- let me back 10 up.
g Did you see anything in your notes that was not i
- f. .
reflected in the FF.MA Report regarding the Patchoque staging u.c area?
A I must say that I am not qualified to talk about 14 the Patchoque staging area because I was only there for about 15 i
forty-five minutes. The rest of the day I was in the field.
16 ! .
l So, the information regarding the Patchoque
)
17 l staging area is largely based on evaluations or information 18 that is prepared at the time when I was not there.
19 Q I should clarify. You reviewed the FEMA Report f l
20 l with respect to the field activities from the staging area? j l l 21 l A That is correct.
22 ! l i !
ACE-:?EDERAL :D. PORTERS, INC. l i '!E-34*-r'00
. Nationwuse Co..:: age KX).u&ooa, j u________
34 l
[
l l
- -~ -
l 0 The field activities you had responsibility for, 2
correct? Now, did you see anything in your notes that was 3
not reflected in those sections of the FEMA Report dealing 4 with field activities out at the Patchogue staging area?
5 MS. MONAGHAM: I am going to object to that line 6 j' of questioning as to the relevance of that line of questioning i
I 7 I in respect to the issues in this litigation.
I 8
MR. MILLER: Well, your objection is noted. It l must be relevant. My question goes to whether or'not Mr. I 9 l Saricks, as an evaluator, observed things that were not later 10 1I l
reflected in the FEMA Report. That is clearly relevant.
11 l MS. MONAGHAN: I think what we are litigating here 12.
is what ultimately ends up as the FEMA Report, and not what 13 occurred prior to that time.
14 MR. CUMMING: Okay. Counsel for FEMA notss the objection. The witness may answer the question as stated.
16 ' If you want the question restated --
17 l MR. MILLER: I will just rephrase it. It is i I
l I
18 , faster.
l SY MR. MILLER: (Continuing) 19 l 1
20 l 0 My question, Mr. Saricks, recently you reviewed your l
3 { notes from the exercise and the FEMA Report. Now, I am asking i
g ) in that review did you notice anything in your notes that was I
ACE-3EDERAL 3EPORTERS, INC.
, n.w.- > - - a . ,. . ~
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i
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! not reflected in the FEMA Report in those sections of the FEMA 2 l l Report regarding field activities out at the Patchogue staging 3
area that you had responsibility for observing?
4 A My reaction to that initially is no, but I am not 5
I sure. j 6
O Mr. Saricks, I want to back up to the three assign-7 ments you generally described for me. Let's start with your i
8 first one, which was the route alert driver that you had 9 responsibility for evaluating.
\
I i i l You said that you either were to accompany or l
10 l l
yy l follow the driver when he went around his route. Which did you do in the case of the Shoreham exercise?
l 1
4 i A I followed in my own rented vehicle for the reason 13 i t
l ,
that at the time of the completion of the route, there was 14 l l not going to be adequate time for me to return with the route 15 !
alert driver to the Patchogue staging area, and then get in 1 16 :
l vehicle and go to my next assignment, so I had to have my 1
17 own vehicle.
i Q And you mentioned in connection with the route alert
\
l \
19 i driver evaluation you conducted, that you were to observe 1
20 whether he followed the procedures under the LILCO Plan?
A That is correct. j 21 l 22 l
i I
i
'. l l ACE-FEDERAL :REPORnZS, NC. !
l
__ __ __ l Q In your opinion, did the driver that you observe 2l l
follow such procedures?
3 l I
A Yes.
4
, O Any exceptions to that, or is that a, 'yes.' l a
1 5 ~
A The procedures regarding -- yes. The route alerting, l I
6 i he followed according to the plan.
I I 7 0 Are you f amiliar with the speed that under the 8 LILCO procedures is to be driven during the course of route 9 alert procedures?
10 ! A My recollection is five miles an hour.
l 0 Did the driver on the day of the exercise that 11 y u f 11 wed, drive at approximately five miles per hour?
12 I A Yes, he did.
13 I l Q How long did it take that driver, approximately, 14 l l to complete his route?
15 l i A From the start point on the route, I did make 16 specific note of that in my notes, and it was fifty-one l
17 !
- minutes.
18 MS. MONAGHAN: I object to that last question 19 { as irrelevant. The speed with which the route alert driver l
20 l completed his route is an issue that was decided in the prior 21 plan litigation, as not being something that is of concern in 22 4 emergency planning of an exercise. It is totally irrelevant.
I i
i AG-3EDERAL D_ PORTERS, :_NC.
1 =. a.n .~_ -. -
l 1
~ ~~ --
I MR. MILLER: Your objection is noted, but it is i
21 3 j a little late, though.
I 3
l MS. MONAGHAN: I would like to clarify my objection 4
if there is a problem with specificy. I am objecting to the .
I 5 line of questioning concerning the speed with which a route 6 L alert driver completes his route as being totally irrelevant either to the exercise litigation, or to emergency planning 7l 8 , in general. As a back-up means of notification, route alert i
9 driving does not have to be accomplished in any specific time peri d.
10 !
i l MR. MILLER: I understand your objection. I was 11 l f just commenting on the f act that we were about two questions 12 {
, beyond that when you made your objection. '
13 l l BY MR. MILLER: (Continuing) 14 l f
- O Mr. Saricks, how long approximately did it take the 15 lroutealertdrivertobeginhisroute?
'6
^
i A Following deployment from the Patchogue staging area ,
17 I to arrival at the start of the route?
18 ' O Yes.
1 19 A It was nineteen minutes. I l
23 O Mr. Saricks, is it fair to say that it took j 21
! approximately seventeen minutes from the time the route alert 22 i ace-:?EDERAL .3EPORTERS,
, _ m. ~
INC.
, = .-- ;
I 38 i
~ - -
! driver was dispatched from Patchogue to complete his assignment 2
route?
3 A Yes.
4 MS. MONAGHAN: Objection to that question.
5 (Continuing)
BY MR. MILLER: l 6 Now, Mr. Saricks, did you observe the actual O ,
7 dispatching of the route alert driver from Patchogue staging i
l 8 I area?
l 1
9 i A Yes.
1 10 ;
O What did you observe in that regard?
I
!~ MS. MONAGHAN: I am going to object to that question.
11 ,
! There is no contention in the litigation at this point regarding m
12 l , ,
l the dispatching -- the speed at whien route alert drivers were J 13 '
dispatched.
14 MR. MILLER: I understand the objection. This is l
15 i discovery deposition, 16 i l l MR. CLMMING: The witness may answer the question. J
, i I THE WITNESS: Are you asking for the description of l
l 18 4 1
the procedure that was followed at the time the route --
l 19 l It is not clear te me the meaning of, ' dispatching.' l l
20 i BY MR. MILI.ER: (Continuing)
J 21 0 That is my next question, then. When I asked you if i
22 ,
1 3
i A -3EDERAL 3_ PORTERS. INC.
202-347- D D Nanenwice Cm.: rage 633W l
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l you had observed dispatching, you said yes. What did you 2 I understrad by my use of the term, ' dispatching?'
3 l A That the individual who was to drive the route was 4
singled out by the staging area coordinator, and told to 5
proceed to run the route, was given a map showing the area 6~
where the siren failure had presumably occurred, and also the 7 map had an indication of the route to drive and the instructions.
8 i Then the individual went to a storage area, obtained 9 a bar-type public address system to attach to the top of a 1
vehicle. He then took that out and attached it to the top 10 l l'
11 f the vehicle, and demonstrated its operation, and_then went i
back and.got final approval, and departed.
w 77 l i
! Q Now, do you recall approximately how long that 13 i process took, Mr. Saricks?
14
! MS. MONAGHAN: I am. going to object to this whole 15 i line of questioning, and a continuing objection, so I don't 16 !
. have to keep interrupting. The only possible relevance on i
17 l any of these questions on route alert drivers might be to 18 E As to any other issue, those issues are training contention.
19 Thev are not in controversy in this f not in the litigation.
20 ! litigation based on the contentions that have been admitted.
21 j I just want to note that continuing objection.
22 BY MR. MILLER: (Continuing) t Ae-FEDERAL : REPORTERS, ~'\IC. _
I E 347 6 00 Nanonmce Co'... age 300 D6-o6e6
40 I
I l
Q How long the process of dispatching, as you defined 2 i j it, took from your observations?
I 3
A A total of ten minutes.
4 You ar3 telling me Q Let me make sure I understand.
5 that dispatching, as you understand it, the driver was singled 6 out, he went and got equipment, the equipment was carried to a 7 parked automobile. The equipment was placed upon the automobile.
8 The equipment was tested or demonstrated to you. The person then went back and received final instructions, and that was ten l 9
I m nutes?
10 A Ten minutes, The parking lot was immediately
! adjacent.
N.
12 l I l Q Do you know, Mr. Saricks, if the driver you observed 13 !
i h'ad received dosimetry briefing prior to his dispatch?
14 l l A Yes, I observed that.
I 15 l Now, did the driver go through any other process i
O 16 prior to being dispatched from the Patchoque staging area i
17 that you observed?
18 A No.
19 l 'Q Had the driver received dosimetry briefing prior I
20 to the equipment being placed in the automobile, and the 21 actual dispatch?
22 I
A3-W A -3EDERAL 3EPORTERS, NC.
~
, Nanonwice Co.=2se 3 @ D 6 <>6-6
~61 l
l
~~ ~~ ~~
A Yes. That briefing took place before.
t 2 !
l Q How long, approximately, was that briefing?
3 A I did not get in at the start of the briefing. The 4
portion that I saw was roughly ten minutes.
5 0 Do you recall, Mr. Saricks, or do you know how many 1
l 6 L route alert drivers were dispatched from the Patchogue staging l
1 7 area?
8l A To my knowledge, the one that I followed was the J
9j nly one actually dispatched. Was the only siren, presumably, l l that had failed.
10 O Do you know if the driver dispatched knew beforehand l
11 l l if he was going to be chosen to be dispatched to drive that 12 ,
l particular route?
13 !
- A No, I do not know that.
14 l j Q You don' t know one way or the other.
15 l I don't know if he was notified in advance, no.
- A 16 l Did you ask the route alert driver any questions !
Q 17 l during the course of your evaluation of him?
13 A At the completion of the route, I cid, yes, sir. i l
19 ) Q And what questions did you ask? !
l i l 20 A The questions I asked him pertained to his j 21 ! understanding of personal protective procedures. ]
22 ,
AmM m)0-?EDERAL 3EPORTERS, ENC. -
.Nanonmar Cee. ass - #D336-co o
[ 42
~ ~ ~ - -
l Q Do you recall any more specifically what those 2 j j questions would have been?
3 A Yes. I recall asking him who would authorize him I 4
to stay in the field and incur exposures in excess of 3.5 R, 5 and he did answer that question satisfactorily.
6 0 He did? .
7 A Yes. I also asked him if he knew how he would be 8 informed that the authorization had been given to ingest a 9 . thyroid-blocking agent, potassium iodide, and his answer to i
1 10 l that question was generally correct, but was not entirely i
~ consistent with what is in the procedures as written.
l Q What is your understanding about what LILCO 12 ;
'~
j procedures say about ingestion of potassium iodide? 1 13 ! i A For route alert drivers, .9 of Attachment 1 to 14 l the specific procedure, and I don't remember exactly what l
15 !
! number it is now, says that as applied specifically to route 16 alerting drivers, when they hear the announcement of general t
1 ,'
emergency on an EBS broadcast, they are automatically to take 18 l their potassium iodide.
19 ! Q And what is your recollection as to the arswer i
i 20 l the driver you observed gave you, when you inquired into this 1
21 area?
22 ,
/
Ath-:?EDERAL lW_ ORTERS, :NC.
~3 LW-374 .Nananmoc Ca.mse 30MWh
i 4J l
l 1
l A (Pause.)
2 j Q Do you know the answer?
3 A Yes. The answer is he thought he would be specifically 4
informed in the text of an EBS message that route alerting 5 i
! drivers were to take K-I.
6 Q Do you recall asking any other questions of the 7 l alert drivers being evaluated?
8 A Those were the only ones I recollect asking.
9 Q Do you recall, Mr. Saricks, how you, evaluated the I
performance of this route alert driver that you evaluated?
10 l 11 What conclusion did you reach?
A I think in general my conclusions was that he --
12 I MR. CUMMING: Objection to this line of questioning, because it is post-exercise. The witness may answer the question.
i THE WITNESS: I may answer?
16 i MR. CUMMING: You may answer the question.
17 THE WITNESS: My conclusions were that his procedures 18 regarding route alerting were performed in accordance with the 19 Plan. That he, perhaps, needed some additional information 20 regarding his own radio protective procedures, and that the i
21 i information that she had should be consistent with what appears 22 Ae-FEDERAL 35_ PORTERS, LNC.
t =.w.n , _ n. , -
[ _ _ _ - _ _ . . _ _ _ _ _ _
! 44 l
I
__ __ __ l I in the written procedures.
2 j 0 Mr. Saricks, is it fair to say that your evaluation i
3i j of this route alert driver was pursuant to a specific exercise 4
objective?
5 A Yes, it is.
6' Q And were you asked during the day of the exercise 7 to determine whether, in your opinion, specific exercise i G 8 objectives were met or not met?
9l i A Was I asked to make a dete' utination on the day of the exercise, is that your question?
10 l 11 . Q Yes.
A No, A was not instructed to make that determination 12 s_- !
I on the day of the exercise.
Q Did you ever make that determination?
14 i ,
A Yes.
15
! O When did you make that determination?
16 l A When I prepared my exercise evaluation on the 17 l l day following.
18
~
Q And what was your conclusion with respect to the 19 f exercise objective involving this route alert driver?
i 20 , A That the objective regarding route alerting procedures 21 ; .was met. That the objective regarding radio protective
} .
22 procedures for emergency workers in the Tield was partly met.
Ath-:?EDERAL 3EPORTERS, INC.
, = -347. m .Nanonwuse C '.arase 500 336 c64
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~~ ~~ ~~
l I am sorry, let me amend that.
2 The -- I did make a specific not_ification of the 3!
f act that the route -- time of completion of the route was 4
somewhat excessive, but that it did not occur to me that that 5
lwouldbeaproblem, if for' example, two drivers were dispatched 6
rather than one.
7 0 Under the LILCO procedures, is it one driver, two 8 drivers, or more that are to be dispatched in the event of an 9 emergency at Shoreham?
l 1 l l
10 A There is no specific indication. They can dispatch i l ,
i 11 j as many drivers as they feel are necessary.
l i
! ! G But on the day of the exercise they dispatched one l 12 !
lu l
- l ! driver?
13 i
l j A That is correct.
_l4 !
j Q And that one driver was not able to complete the 15 route within an acceptable amount of time, is that correct?
16 l MS. MONAGHAN: Objection to the question as vague.
i 17 i l
l THE WITNESS: I am not sure I would agree with the l
13
- use of the term, ' accept able . ' There is guidance that says I
19 that such routes should be completed within forty-five minutes.
20 BY MR. MILLER: (Continuing) 21 Q And on the day of the exercise, did the driver -- the 22 driver you observed, he did not complete that route within AU--3EDERAL DORTERS, INC.
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! forty-five minutes, is that correct?
2 i A That is correct.
3 !
O Mr. Saricks, the second matter you mentioned with i
4 '
respect to your assignments the day of the exercise was you 5
reserved the response to presumably a road impediment. Do you l
6 recall that?
l 7 A Yes, sir.
l 8l 0 Which road impediment did you have responsibility j f l i
9 l for?
10 l A Okay. There was an accident involving a gravel truck 1 l
yy j with a broken drive train, and three other vehicles that was
- simulated to have occurred Middle Island Road, just north of L2
1 1 the intersection of Main Street, in Brook Lane.
13
! So, immediately following my securing of the route 14 i alerting driver, I went to that location, and the forty mile 15
! location into LERO EOC --
16 Q If it is okay with you, I will refer to that as 1
7 ,
the gravel truck impediment.
13 A Fine.
19 0 Do you recall approximately what time you arrived 20 , at the location of the simulated gravel truck impediment?
21 A Yes. It was about ten-thirty.
22 Q Do you recall about what time the impediment was AG-?EDERAL 3EPOR1ERS, 7_NC.
=- M7- 3~0 Nanonwice Cat sag: 3CG3h4 L _. __ _ _
- 47 l
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l to occur on the exercise scenario?
2 !
l A I believe a window of time was provided, but no 3! l specific time. Some time -- my recollection on that is not 4
good, but I knew that it was to have occurred some time during 5 the general alert.
6 0 Do you know if you arrived at the designated area 7I of the gravel truck impediment prior to the time that LERO 8 was actually informed by way of a free-play messsage of that 9
impediment? i A Yes, that I do know. Because the specific procedures 10 and instructions we were given that there would be no free-play l
l message passed until I had phoned in that I was in place and 12 ,
u- l was ready to reserve the response. j l
13 0 How long were you at the location of the gravel 14 1 j truck impediment?
15 l A From ten-thirty a.m., until about twelve-fifty.
16 l So, approximately two hours and twenty minutes.
l Q 17 What response did you observe by LERO to this simulated gravel 13 i truck impediment at that location?
19 l A I observed that LERO had discatched a large utility-l 20 type truck, probably a Class VI vehicle, equipped with a hook, 21 not in the standard tow truck configuration, but capable of 22 towing vehicles, and certainly a heavy vehicle.
- ACE-3EDERAL 3EPORTEPds,7_NC.
E.M7.ru) Nancmwice C r..nse KG3M L __ _ _ _ _ _ _ _ _ _ _ _ __ _ __
,o I
l l
l
__ __. __. i
- And that arrived at my location at approximately 2l I twelve-forty.
3 Q Did you observe any other response by LERO to this 4
impediment prior to approximately twelve-forty, when this large 5
I utility truck showed up?
6 I did not observe any,other response, no.
A 7 Q So you waited somewhat over two hours without seeing 8 any response, is that correct?
l 9 A From the time that I arrived at the site?
10 Q Yes.
! A Yes, that is correct.
I,t i
i ! Q Is it your understanding, Mr. Saricks, that after l 12
,s._.
you telephoned in your location at the -- where the gravel 13 ltruckimpedimentwastotakeplace--thatat that point in 14 I time the free-play message regarding that impediment was given 15 l to your people?
16 i l A I do now know if it happened immediately thereafter, i
17 or some time thereaf ter, but I knew it could not be done until
,3
, I had notified my contact.
19 Q Do you have any knowledge at all regarding when l 20 the free-play message regarding the gravel truck was actually l
21 i put into play during the exercise?
i 22 i
Ae-FEDERAL REPORTERS, INC.
I 49 l
A From my own observation, no. Only from documented i
2 report.
3 Q What does the report say?
4 I believe the Report -- can I answer this?
A 5 MR. CUMMI?TG : You may answer, if you remember.
6 THE WITNESS: That the message was injected 7 sometime between ten-forty and ten-forty-five.
l 8 j BY MK. MILLER: (Continuing)
I Q Now, if your recollection is correct, Mr. Saricks, 9
and the free-play message was injected some time between 0
l
~ ten-forty and ten-forty-five a.m., and you saw no response 11 (
l until approximately twelve-forty a.m. ,
12 !
A P.m.
{
I 13 \
Q Twelve-forty p.m., I am sorry. You waited l
14 approximately two hours from the time the free-play message was 15 l put into play, until you saw a response, correct?
16 A Hypothetically, yes. If that initiating time is 17 ! correct.
I 18 : Q Did you draw any conclusions regarding the need for 19 ; that response, given the two hour time period?
20 A Yes. I drew the conclusion that information regarding l
my 1 cation had somehow not been transmitted. Can I explain the 21 i
22 l j,
i .
Ae-:?EDERAL hPORTERS, NC.
I n.w.n , _ . - -
t
7 l
l l l
si:uation now, or should I refrain?
2 MR. CUMMING: You can answer.
3i BY MR. MILLER: (Continuing) )
4 Q I will ask you, Mr. Saricks, to explain the situation.
l 5
A Okay. Let me pref ace it by saying that one of our l
6 j instructions was to observe all Suffolk County ordnances and j 7 regulations during the conduct of the exercise.
8 Upon my arrival at the specific location where the 9 impediment was to occur, I found that it was a no parking area.
l 10 S , there was no place to park my vehicle and wait legally in conformance with the ordnances.
l l l Therefore, I relocated to the nearest public parking I 12 l-l, "
area, which was a lot immediately around the corner on Main
- 13 ,
~
j l
'. Street, within fif ty yards of the intersection, and parked my l 14 l vehicle and made the phone call.
l And in my message to the LERO 15 1
{ EOC, I gave a description of my vehicle, including the license.
I 16 l l
plate and the fact that I would have my evaluator arm band 17 l: prominently displayed. _
l l 18 So, this was additional information that had to be 1
19 l communicated in order for the response personnel to link up ;
1 l l 20 with me , because I was unable to be at the exact site of the 21 ; impediment. So, when the response did not take place, my l 22 l
l l
l l Ac r-FEDERAL lEPORTERS, :NC. . i
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f I i 51 l inference was that somehow the information regarding my location 2i i had not been transmitted.
3 Q Do you know, Mr. Saricks, if your inference proved 4
to be correct?
5 .
A I do not know that for a fact.
t 6 l' O Now, let me ask you: .From the location that you were ;
7 l
waiting to observe this traffic impediment, . could you see the I
8 actual location of the traffic impediment, where it was l
i 9 supposed to have occurred?
l 10 A I believe it was just out of my line of sight. I i
11 could see the intersection of Main and the middle islandlof 12 Plar.k Roads collectively, but as the impediment was actually 13 lfiftyyardsnorthoftheintersection, I believe that was just i
beyond my line of sight.
j Q Would any LERO response had come through the inter-15 t i section that you could see?
16 :
- A Yes.
17 !
, O Did you watch that intersection the entire two hour i
18 '
time that you were waiting?
19 -
A For all but about ten minutes. At one point, 20 realizing that there must be a problem with my visibility, 21 I did relocate to a location which would have been completely 22 visible from that site. But again, I witnessed no response AG-3EDERAL REPORTEPJ5, INC.
- =.m.m ,_ ._, -
1
52 from there, so I returned to the parking lot.
2 l 0 Did you ever witness any response from your view i
3 of the intersection while you were waiting, where you finished 4
your telephone call?
5 A I saw LILCO vehicles going through the intersection,
- 6. which.may have been on normal call, normal duty, They never
( 7 identified themselves to me as response vehicle, and they never stopped at that particular location.
8l Again, the vehicle that actually responded was not 9
Configured as a TOW trt1Ck, so I would not have identified it as a tow truck, just seeing it going through the intersection.
l Q Did you see any LILCO vehicles going through the
'~~
intersection that could have been responding to that impediment?
13 l A I would have to speculate.
Q Did you see any LILCO tow trucks go through that I
15 . .
l l Intersection?
A 1 saw no tow trucks go through the intersection.
17 ,
Q Did you see any of the LILCO utility trucks go 18 l through the intersection, such as the one that actually ended 19 up respending to the impediment?
20 l A I do not recall such a vehicle go to the intersection l 0 Did you see any LILCO vehicle that had any sort of l 21 I
! crane that could have been used in removing a traffic impediment 22 ACE-:?EDERAI 3EPORTERS,:NC.
- E347-3 00 Sanonmac C.r...sse 300 336-eene C _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _
- 53 I
i A You mean orior to twelve-forty?
Q Prior to twelve-forty.
2l I
3 i
A Not to my recollection. ,
l 4 Q Now, once there was a response to a simulated traffic j i
5 impediment, gravel truck impediment, Mr. Saricks, tell me what I
you did?
6 A The vehicle pulled into the lot where my automobile i
was. I walked to the vehicle and asked the driver if he were 8 ,
i I
i there in response to the accident. i 9l l
The driver responded, yes. I asked him what he had 10 been informed regarding the impediment. He said there was a i 11 I
truck out here with a broken drive train, and he was to remove l '- I sg it from the road.
13 l I asked him if he had information regarding other l 14 j vehicles involved in the accident, and he said no.
15 ,
Then he proceeded to show me how the vehicle would i
I 16 be used as a tow truck to clear the impediment from the road.
I 17 I asked him how long in his estimation it would take to clear i
that impediment, and he said no more than ten minutes to clear 18 [
, the truck. i 19 ! !
l
- I then asked him to speculate regarding other 20 i vehicles involved blocking the road, and he said probably thirty minutes. He didn't volunteer any information that he 22 l l
- Ae-?EDERAL 3EPORTERS,
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WE I would radio into his depot regarding support equipment.
2! '
And then I proceeded to ask him and his co-responder, 3 l; who was on the passenger side of the vehicle, the same sort i 1
1 4 i
~
l of questions I had asked the route alert driver regarding radio 5 protective measures and their dosimetry.
l 6[ Q Do you recall any other questions you would have l 7 , asked these two individuals?
8 ; A I believe that is the extent of the questions I 9
asked them.
I Q Did you ask the driver, or for that matter, the 10 !
! co-passenger, why the time delay in responding to the impediment?
11 l 1
l A I asked when they had been dispatched. He told me
~~
he had been dispatched at eleven-fifty. That he had passed
-B the location, had not seen me, the FEMA Evaluator, and had 14 i; '
gone to a point further north, and then returned to this 15 1 l location. He alco stated he was dispatched from a LIE depot 3
16 ! which was considerably closer than the Patchogue staging area.
i 17 i 0 Do you know if his dispatch from the depot on the 18 ; Long Island Expressway, and not the Patchogue staging area ,
19 ! was consistent with the LILCO procedures?
i 20 A I do not know that. From my reading of the procedures there is no inconsistent cy, no.
21 ,
MR. CUMMING: Can we take about a five minute break?
22 ,
MR. MILLER: Let me just get through this line of Ax.w.n
-rEDERAL REPORTERS, ..NC.
. n- -, -
55 i
questioning.
) ~
2 BY fir. MILLER: (Continuing) 4 3h Q Mr. Saricks, if in fact the response that was made
) 4 if in fact there was a response in terms of dispatching at
) 5 eleven-fifty, as the driver told you, and if in fact the
, 6 free-play message had been put into play at ten forty-five a.m. , would you have considered that an adequate response to t y simulated accident impediment? In other words, an hour and I 9 five minutes from the time of notification to the time of
) dispatch.
g 10 A
l If you are asking for my judgment --
I 11 I Q I am asking for your opinion.
12 l
A I Can I answer on the question of opinion?
13 I l MR. CUMMING: Yes.
14 THE WITNESS: My opinion is that given the fact i
15 I that that road was a designated evacuation route, that that 16 l was not sufficiently timely to prevent extreme traffic 17 flow difficulties at that location.
I '
ig l LY MR. MILLER: (Continuing)
O
.r. 9 l
Do you know, Mr. Saricks, how long it took the 20 i vehicle that responded to the gravel truck impediment to g
21 ;
i arrive -- strike that.
Do you know how long it would have taken the vehicle i I i , I i
AG-3EDERAL
- n. -
3EPORTERS,7.NC.
>- - u. - - 1
that was dispatched to have arrived at the location of the 2 -
I simulated gravel truck impediment from the depot it was l f
dispatched from, if it were to come directly to that location? l 4 A I do now know from my own observation. I can only l
5l report what the driver told me. j 6l' 0 What did the driver tell you about that? i I
i i 7
A He said it took him initially ten minutes to reach l I 1 1
e 8 that site, or less. j l
l Q Did you ever verify whether that information was, l 9l 1
, indeed, correct.
10 :
l A No, because I was not given the specific location f 11 '
{
of the depot.
12
, Q Do you know how long it would ordinarily take for 13 a vehicle such as the large utility truck you describe to 14 respond from Patchogue staging area to the location of the I
15
~
simulated impediment? i 16 A No. My knowledge of that area is not good enough to 17 determine average travel sneeds over roads of that distance.
13 Q Did you ask the driver why it took approximately 19 , an hour and five minutes to -- from the time the message was 20 put into play, until the time of dispatch?
A I did'not ask the driver that cuestion because 21 given the chain of command information that are in the LERO 22 ACE ?EDERAL 3EPOR'1ERS, :NC.
. D' A7-3*T Neonmce Co..nge K43h
l 57 l
l
! plan, he would not have had access to that information.
I' 2l Q Did you ever make inquiry to anyone else as to why i
3 there was this delay in the dispatching of the response 4 vehicle?
5 A During the course of the evaluation, I obviously 6.
conferred with people who had responsibilities at the Command Center regarding the chain of events.
7 g
And again, from my own observation, I have no
! specific information. What I have is heresay, and discussion I
9 among some other individuals.
10 0 Well, I am going to ask you during those discussions 11 1
! what were you told regarding the delay of the response 12 l v ! vehicle?
l 13 l i MR. CUMMING: What was he told by who?
14 l BY MR, MILLER: (Continuing) l I
15 j Q What did you generally learn, Mr. Saricks, about 16 l the response, the delay, and the delay in that response?
17 MR. CUMMING: Objection as to form. During the 18 i exercise, or post-exercise?
MR. MILLER: At any time.
19
! THE WITNESS: You are asking me what I learned about 20 ;
- it on the day.
21 ,
i BY MR. MILLER: (Continuing) 22 l l
- Aa-:?EDERM. 3EPORTERS, INC.
. - -- 8 - . - c.,. ,. ~
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i 58 l
-- __ __ ! Q We will break it down. On the day of the exercise, 2
l did you learn anything further regarding wh'j. this delay in 3 j response by the LERO drivers to the gravel truck impediment?
l 4 A I learned nothing specifically. I learned what 5 had happened regarding my own communications to the LERO EOC,
' .and the f acr that the scope of the -- the full text of the 6
f
! free-play message, apparently, was not communicated down and 7
up the line.
Beyond that, I don' t have any -- on the day of the j l 9 l
l' exercise, I gained no knowledge about who was contacted, at 10 !
Lwhat time, and for what reason. \
\
11 l Now when you say the full text of the free-play l
Q i 12 !
s..
i message was not communicated up and down the line -- )
13 Yeah, but specifically down the line to the dispatch A
L4 l f -- the depot from which a tow truck was dispatched, which was l l 15 of concern to me.
i 16 : Q Did the free-play message, to your knowledge, get 1
17 I put into play at the LILCO EOC -- LERO EOC -- as it was supposed l
18 t have been under the exercise scenario?
A What I learned, again, from repcrts of others, is l
l 19 l :
! that the message that went into play was not a complete version
! 20 l l l
of the message that had been prepared prior to the exercise.
l 21 i
! Only a subset, or a limited amount of the information 22 i l
l
- ACE-3EDEML 3EPORTERS, INC.
i .m x .- -
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l that was in that message was communicated.
_ i 2l 0 Did you learn who was at fault in not getting the i
3 l entire message put into play?
1 4{ A No. I did not learn either an individual or a role l title as being at fault.
5 f
60 0 Was it LERO or was it FEMA that was at fault?
A Again, I don't know.
7 MR. CUMMING: Would it be possible to take a break?
MR. MILLER: I would like to finish this line of 9 ,
i questioning. We are close, r Let' me mark this as Saricks Exhibit No. 1.
l 11 1
(Above referenced document is l
12
,. . . marked Saricks Exhibit No. 1, 13
^
gINDEX for identification.)
14 I It is a two-page document, at the top stating: This LS is an Exercise, in big, bold, all capitalized letters. Under l l
16 '
that: Shoreham Exercise, Impediment to Evacuation Route l l
i 17 Message. Mr. Saricks, have you ever seen this document before? i l ,
l 18 ! THE WITNESS: I have seen this text before. I have
( !
19 l n t seen this -- the bottom part of the document.
1 l BY MR. MILLER: (Continuing) j 20 !
\ l j Q Now the text you are referring to is where it has i 21 j '
i'
- that paragraph
- Message?
22 l I ,
l; ACE-NEDERAL 3EPORTERS, :NC.
E-3CJt00 Nanonwme Cohrage 300 336-6 sus l l
l i 60 1
i f A Yes, correct.
2 i 0 Now, is that the free-play message regarding the 3 '
gravel truck impediment that you understand for the shoreham j 4
exercise?
5 A That is correct, yes.
6 l' O CIs that the message that was supposed to be used ,
7 during the exercise, to your knowledge?
8 A Yes. ,
0 Is this the message that was, in fact, used to 9l l
your knowledge?
A To my krowledge, which again i not based on personal ,
observation, the information that was transmitted in at the point 12
' " where you have a closed paren, 124, close paren period.
13 ,
i O So, it is your understanding that this is-a multiple 14
- vehicle accident also involving three passenger cars that are 1
l'e 1 blocking both the north and southbound shoulders of the road.
16 l There are no injuries to any individuals.
i That information was not contained in the free-play 17 l l 18 lmessageput into play on the date of the Shoreham exercise?
19 i A I know that that information was not included in i
20 the message or information which reached the dispatcher at the LERO depot.
21 Q Oh. That is a different matter.
! Ae-:?EDERAL 3EPORTERS, ~NC. _
I 2 W-TOO .Nanonmoc Cou age 800 336 4 4
_ = - =
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ __...______________________________.l
61 i
A Yes. I can only speak to that, because I only spoke 2l to that one driver.
3 .
O Vith respect to the free-play message -- let's back 4
up, I
5 i i What is your un'derstanding as to where this free-
! play message would have been put ,into play?
l 7 i A At the LERO EOC was my understanding. I, in fact, i
8 j have to say that I do, because I know that on my call to the 9 LERO EOC, I was told that, okay, stand by, we will get this i
10 ! going.
[
I didn't observe it, course not.
i l 0 Mr. Saricks, is it your understanding that a message like this message would have been actually handed to the 13 i 1
i l LERO players during the exercise?
14 l A In the discussions on Monday, the training session, 15 l it was mentioned that that was the way free-play messages are i
16 l j injected.
17 l Q You are talking about Monday, February the lith? l 13 , A Yes, right.
19 Q Now, It is fair for me to say that what you are 20 l testifying is that to your knowledge the entire text of this 21 ,
free-play message was put into play at the LERG EOC, but the l
22 entire text did not make its way to the depot where the response f
i AG-3EDERAL ,__ c
- DORitRS, NC.
- - ..m.m
i
- - - - - - i vehicle was dispatched from, in response to the gravel truck 2i impediment?
I.
3 l A That is my conclusion. But that is not based solely I
4 on my observation. It is based on my observation in conjunction 5 ,
w ith discua-t'ns with others, who were observers.
I j g Q What conclusion would you draw then, Mr. Saricks, as l
to who would have been at fault in not getting the entire text 7
of the message transmitted to the depot, as between the sources 8
, being FEMA or LERO?
9l l A I don't have enough information to draw that l
10 !
I conclusien, because I was not tracking the course of events 11 at the EOC.
12 I t Q Did you understand that FEMA was going to hand the l
13 text of the message to the depot?
l 14 A No. I am sorr'J. My understanding was that the I
15 l text of the free-play message would be handed to a responsible i
16 l individual at the LERO EOC by a FEMA evaluator or controller in i
17 this case, and then that response would commence there.
ig There was never any indication that that would be i
g handed to someone at FEMA.
! O And is it your understanding that once the message 20 .
i ;
was handed in at the LERO EOC by FEMA, FEMA's role was over, and it was to then evaluate LERO's response?
22 l
\
Au-?EDERAL lEPORTERS, iNC.
. =.w.n 8-- un. -
as i
~~ -- --
A You are exactly right.
I 2 I Q And you draw no conclusion as to how it is that the l
i 3
entire text of the message would not have gotten to the depot 4 driver, in terms of fault being LILCO, LERO, or FEMA?
5l MR. CUMMING: The witness has stated he doesn't know.
I 6 BY MR. MLLER: (Continuing) 7 ; Q Is there any possible reason, Mr. Saricks, that 8
you can think of that woald lay the f ault --
i i MR. C U211NG: Obj e ction.
9 I l
! (Continuing)
BY MR. MILLER:
10 [
- 0 Let me finish my questions, and then you can make 11 !
i your objections. That would lay the f ault at FEMA for not l 12 l l ! getting the entire text of the message to the depot driver?
13 1 1 4 A I am sorry. FEMA had no interaction with the 1 \
14 l
- depot driver.
1 15 l The last point of FEMA interaction on this was l
I l 16 supposed to be when the message was handed to a responsible 17 i individual at the LERO EOC. Then the LERO chain of command l presumably would take over in getting the information to the l
18 .
19 appropriate persons, and dispatching the appropriate equipment.
Q S , is it a fair conclusion then, Mr. Saricks, that 20 it is the LERO's chain of command that broke down in gettina the ~
21 l 22 ACE-3EDER-\L D_ PORTERS, INC.
I 202-34~-r 2 Naucowics C.r. case 800-336 6 4
64 l text of this free-play message to the depot driver?
l 2 I I have not personally observed does l A Evidence which 3 support that conclusion.
l l l
4 0 Mr. Saricks, when you say that the driver of the l l I 5 vehicle that did eventually respond showed you how the vehicle 1
6 would be used to remove the gravel truck -- do you remember
' l 7
saying that to me?
A Yes.
g l
Q What did he do to show you that? !
9
} {
A He manipulated controls within the cab, and showed 10 ;
i I how the hook on the back would hook to the front or rear of the l
11 !
! truck as appropriate, and used to haul him.
12 l
' I then asked him, well, suppose this would not 13 1 I
- function, how would you remove the truck? He said, well, we )
i 14 '
- would just push it off the road. !
l 15 And I had no reason to dispute that as an answer l
l 16 i because of the size of the vehicle involved. He could have l l 17 l done the job.
I 18 , 0 Is it your opinion, Mr. Saricks, that the vehicle 19 that responded was suitable for actually removing a loaded 9 ^"* #"
j 20 A It could have performed that, ves.-
It was at least 21 a 20,000 pound truck.
1 Ati-:?EDERAL 3HORTERS, :NC.
I LT. M7 3'00 Namenwee Co. rage 300 336 6o.4
I i
, O Could a regular tow truck perform the task given-i 2
under this free-play message? That is, removing a loaded )
I 3l gravel truck?
I 4 MR. PIRFO: Vague. What is a regular tow truck?
i t 5l BY MR. MILLER: (Continuing) 6 Q Do you know what I mean when I say a regular tow I l l truck, Mr. Saricks. The kind of tow ruck you would bee at 7
l
- a gas station.
3 i i
l MR. PIRFO: The question is still vague.
9 i i
l THE WITNESS: In my mind, I have seen these large 10 tractor units which you normally see with very heavy duty --
11 l Class A trucks used as tow trucks. I mean they are configured 12 I
% i for that purpose, because they have to haul other tractors out i
13 l of there, and I would say certainly one hg those vehicles would 14 l have been able to remove it.
15 A regular tow truck that you see at a gas station, l
16 again, there are a variety of tow trucks that are au a gas 17 i station.
ig >
BY MR. MILLER: (Continuing) 19 ,
Q Are you familiar with the equipment available to
' ' O #** ' ' * # # *E* **" " " * * * * " #"
20 l actual emergency at Shoreham?
A No, I was not shown the inventory or a site where 22 l
Att-3EDERAL 31PORltRS, .NC.
, 3317 3*C0 Nanenwuie Cm enge &&336-oM5 !
l
! 66 i
1
- - - - - - - i that equipment could be examined.
2 So, you saw one vehicle, and that was the vehicle Q
3 that eventually responded to the message?
4 A That is correct. -
5 . Q Did you agree with the driver's statement that a l
I 6 loaded gravel truck could be removed within ten minutes, and 7
no more that ten minutes?
g A Yes, that was an (acceptable answer.
I Q And in your opinion, given the actual text of the free-play message that there was a loaded gravel truck and 10 j l three passenger cars involved in the incident, was one response 11 4 vehicle sufficient to remove that sort of impediment?
( 12 I
- L- A Not in a timely fashion, and not in the event that 13 i there was gravel spilled on the road.
! l 14 What other vehicles would you have wanted to see l
0 13 f respond to make this -- demonstrate an adequate response to the 16 free-play message?
l l 17 i A Minimally, I would like to have seen a vehicle 18 ; equipped with a front-end scraper to remove the gravel.
19 ; Ideally, two tow trucks and scraper equipment.
ru s and a scraper.
20 A Yes.
21 O Okay. You are saying two tow trucks, one of which Au-?EDERAL 3EPOR~1tiRS,7_NC.
- - . . . - ......-.~.- ,n, __
i i
l could have a scraper in the front, or is that three separate 2
vehicles?
l 3l A Well, I would have preferred, obviously, three 4 separate vehicles.
'5 MR. CUMMING: You can have five more questions, or 6 you are going to have somebody peeing on the carpet.
7 MR. MILLER: Let's take a break. We can't go on 1
after that.
8l I
I (Recess.)
9 l l MR. MILLER: Let's go back on the record.
10 l '
l- BY MR. MILLER: (Continuing) 11 l l 0 Mr. Saricks, we were talking about the recponse by 12
- LERO to the gravel truck impediment. I just have a few more 13 lquestionsinthatregard.
1.4 r ; Your questions to the driver of that vehicle, and l l 15 l j the co-passenger regarding radio protectiveness, do you recall 16 generally what those questions were?
l 17 i A Yes. I first asked them regarding the equipment 18 which they had. I asked them to show me what they had. They 19 did have the full complement indicated in the LERO plan. I 20 asked them if they knew how to use them. They understood l
the two different scales, and what thev were to do with their 21 ,
,2 u
l thermo-luminescent dosimeters. They also knew to read and 1
s A -2EDERAL:MORTERS, :NC.
X M1-r00 Nanonunce C.;r..m. e 300 3*4eo46
gg i
i
_ _ _ _ _ _ _ ! record the information at regular intervals, and they had the I
2 correct information regarding authorization for incurring i
3 ' e:: cess levels of exposure, and potassium iodide was not an 4 issue at that time, because they had both simulated ingestion l
1 5 per instructions before they had departed.
{
Q S with respect to radio protective measures, were 6
there any areas where you concluded an inadequate response by ,
7 the LERO personnel?
1 l l A No. Not at that location.
9 I O Do you know if there was any simulation of rerouting 10
- j. traffic at the location of the gravel truck impediment?
11 l 1 A I observed none.
I 12 l '
- u. O Given the text of the free-play message, Mr. Saricks, 13
, that there had been this accident involving a loaded gravel truck I :
14 landthreepassengervehicles, and that both the north and south-I 15 ) bound shoulders of the road were blocked, in your opinion, would l
16 l it have been necessary to have rerouted traffic at that i
17 I location in the event of an actual accident of that scale?
i 18 j A Yes. During the period of the impediment.
i yg Q Could traffic, in fact, actually be rerouted at that location? '
20
- A While there , I saw a means by which traffic could 21 ,
- be diverted onto another street, and around the impediment.
22 4
I ACESEDERAL. 3EPOR'1El<S, :NC.
.w.~ ~ - . . , -
69 Q But you did not observe--
2
- A I did not observe that that was the procedure that
, I j would have been followed.
4 Now,.'o you recall, ft. Saricks, what you generally Q
i 5 concluded about the response by LERO to this gravel truck l
! l 6 : impediment? !
l 7 ,
A I believe my own conclusions did not make specific 8 ,
reference to delay in time, because I was not in a position to i
! know the cause of that. My own conclusions were that the l 9 l I
l 1 equipment that was actually dispatched was not adequate to 10 ! e i
- clear the impediment in a timely fashion.
11 !
l So, my own conclusions, based on ny observations,
- 12. j i relate only to the adequacy of the response in terms of 13 ,
physical equipment.
14 i 0 Am I correct then, in what you are telling me, is 15 ! that your conclusions did not address the issue of the 16 f adequacy or inadequacy of the response time? j 1
17 j A I made a note of the fact that the response time l 18 was substantially delayed, but my difficulty was in not being 19 ; able to ascertain it was due to the result of the depot which 20 dispatched the vehicle, g O Under your understanding, Mr. Saricks, of your
! evaluation responsibility, if the delay was attributed to LERO Ae-?EDERAL 32 PORTERS, INC.
i 3M7 37CO Nar.cewide C.r.asse 300 3%6>4
i 1
- -- personnel other than the actual response unit from the depot, m i 2
did you have any responsibility for drawing any conclusions as 3 to that?
4 A No. I was not in the position to make those 5 conclusions, because I did.not observe any other LERO personnel 6 i other than the responding driver.
7 0 So, because you could not determine why they had 8
been delayed, they being the driver of the response vehicle, you made no conclusions regarding the adequacy or inadequacy g
of the response in terms of the rime?
l A Other than making note of the fact that it was 11 i ,
late, I did not base my conclusions of adequacy or inadequacy 12
- of response on the time delay.
13 l Mr. Saricks, in terms of making a judgmedt with i 0 l
14 l l respect to the adequacy of the response, does it matter in your 15 opinion who was at fault, or what the fault was?
i 16 A From my position as an evaluator, I do not feel it !
17 i is important to assign blame for the function in which I was l ...
1 18 ! performing. Only to see that it was performed satisfactorily, i
and the fact that it was lacking in some particular area is 19 i what I made note of, and what I was responsible. for doing.
20 i :
So, you are telling me you are simply responsible for Q
y noting factually what occurred, and not making judgments about t1 l
ACE- ?EDERAL : REPORTERS, INC.
- C 347 7*D0 Nanonm/:Cm.. age 300 3m
_ _ _ _ ._ _ _ . . - _ _ _ . _ . _ _ . _ - _ _ _ . l
l adequacy of that?
2 ,
! A Indead, I made a judgment about the adequacy of the 3
response, and I said in terms'of the equipment available, it 4 i i was not adequate.
I 5 '
That was all th'at I was able to observe.
6 Q I am looking at the issue of.the timeliness of the 7 response. As to which you made no judgment as to adequacy, 8 is that correct?
9 A I did not explicitly indicate that the response was 1
10 l inadequate because of time delay.
i yy 0 And I am trying to understand why that would offend I -- my ques tion is : In terms cf trying to determine whether a 12 i i
! response is adequate or not adequate, does it make a difference 1
13 ,
wilat the reason was?
14 !
l A It should make no difference. My difficulty was
! 15 in determining whether there was culpability on my part for not 16 l lbeinginthepreciselocation, and because that was a possible 17 I l
contributing factor, although I do not know at this time that 18 '
that was, in fact, the case.
19 ; I felt it was not upon me to make a judgment call l,
20 on the time delay involved.
21 <
Q I understand that. But you also -- you testified that 22 i
ACE-:?EDERAL 3EPORTERS, NC.
- E* AtrDO Nanonwice Cr. cage 500 3364446 L _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
um i
~ ~~ ~~
you also asked the ' response vehicle drivers when they had 2 f lactuallybeendispatched,andtheyrespondedeleven-fifty?
3
! A Yes.
l 4 i 1 Q Now, given the fact that that was still over one 5
hour from the time of the free-play message, why did you not l
- i 6 [ make any judgments regarding the , adequacy of the response time?
l I
7l A Had there been no indication from any other location 1
8 that there was a problem with the delay in response time, I g would have so indicated.
10 However, that portion of the evaluation was being yy handled from the LERO EOC, and they fully documented the events that occurred there, which explained to my satisfaction better 12 l than I could have personally done, why the delay occurred.
13 Therefore, I was satisfied that the inadequacy in 14 l the response time was deemed fully handled by other evaluators, 15 ,
I
- and it was not necessary for me to also take that into 16 ! t consideration in my evaluation.
17 '
Q You learned all that after you had actually observed i ,
18 this response , correct?
19 l A That is correct. It is in my personal notes, the l l
20 times that I have given ycu, and certainly those times being l 21 there would have been the basis for my indicating that there I 22 ACE-3EDERAL 3EPORTERS,7_NC.
- 2 M7 3 00
. Naconince C.:r..: rase KO 3~h l !
_. __ __ i was inadequacy. Had it not been co indicated on some other l
2l evaluations.
3l 0 At the time you actually made your observation of l 1 4 l! the response, you did not know what had been evaluated at the I 5
EOC though , isn't that correct?'
I i
A At the time -- I am sorry --
6
! O That you actually made your evaluation of the 7i l response to this gravel truck impediment, you did not know I
8 i l ! what had been evaluated at the EOC regarding that impediment, 9l l
isn' t that correct?
10 l A I did not make an on-the-spot evaluation of what had
! 11 l l ; occurred on the day of the exercise. On the day following the l'
exercise, I did confer with other evaluators to determine the 13 sequence of events. That is when I performed the totality 14 4 of my evaluation.
i 15 0 But the time you actually performed your evaluation 16 was the day af ter the exercise?
! A Yes.
t7 i
^g
, Q You had discussed this matter of the gravel truck l respor33e with evaluators at the EOC, is that correct?
A The evaluators at the EOC the preceding day, yes.
20 Q And you had in your cwn inind determined then why I 21 it is there had been a delay in the response time, is that i
l i ACE-:?EDERAL REPORTERS, INC.
} ::n-M A Nanoamas C.:n.:nse 100 336/ne j
L- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ . _ _ _ __
~
- se I
i correct?
l 2
A Yes. We were able to construct why that occurred.
1 Q And what is it that you were able to construct 3
regarding that delay?
4 A That, again, I cannot -- this is simply from
! discussion with others, and not from my own observation, that 6!
there had been some difficulty in communicating the entire text 7l j of the message both with respect to the time of the message 8 l l transmittal, appropriate location, and the completeness of the 9
transmission.
10 I . G Did you conclude that those problems were problems 11 that had occurred at the EOC?
12 l A My personal conclusion was that they were problems
'- l .
13 ! which had originated, perhaps, at the EOC, but may in fact have i
14 been propogated elsewhere in the field.
15 l 0 Where else?
A I cannot speculate.
l Q Well, under the LILCO plan, other than the EOC, where 17 l else could such problems have occurred with respect to this 1G particular response, to this gravel truck impediment?
19 j MS. MONAGHAN: Objection. He is asking the witness 20 l to speculate as to where it possibly might be that some things 21 4 could have happened. It is not based on his observations on 22 l what, in fact, occurred.
ACE-:?EDERAL 3EPORTERS, INC.
! E 347-3 00 Nanonwice Co.arage 300-3h
i
__ __ __ THE WITNESS: I do not have direct knowledge of 2 l where this chain of command broke down.
i Or chain of l
3 i information broke down, i
4l BY MR. MILLER: (Continuing)
I 5i O Let's go on to your last task, Mr. Saricks, which.
i i
g is your observation of the traffic guide. You mentioned that 7
f you observed nine traffic control points, correct?
i i
i A Yes, air.
8l
! Q How many total traffic guides at those nine posts 9 I l did you actually observe?
10 l A I can only estimate on that, because some vehicles 11 had two occupants, some had"only one. I think there were 12 i -
(s l probably about twenty total individuals.
i 13 1 I am sorry. About fourteen total individuals.
14 Q Did you interview each of these fourteen traffic 15 guides?
16 ; A Yes.
17 Q Can you tell me the nature of the gnestions that i
you asked during the interview?
13 ,
A My questions pertained to their procedures at their g ,
assigned locations. What their knowledge was of what they 20 were supposec to be doing. Obvicusly, they were not positioned 21 i
exactly where they would be in an actual emergency, because of 22 Ac +-?EDERE lEPORMS, LNC.
1 E M 74 00 .tuonwwe Co. cage 50 0-3 64
76 1
I i
- -- -- the restrictions on that, and they couldn't physically get out 2
and direct traffic.
3 So, I can simply ask them regarding the performance 4 of their procedure. I did not observe them actually carrying 5 them out.
l l
6 So, I asked them about what they did at each location.
7 , I asked them regarding the information that they had about the l
i l -- they were given concerning the event, and what informatiore 8
1 they might be able to pass along to motorists who would stop and a.sx them what they were supposed to be doing, and I also 10 asked them about the radio protective procedure.
11 !
T-3 ? ; O Could you tell me any more specifically the types 12 l '
lki I of questions you asked regarding traffic control functions?
13 i!
A Yes.. I asked such questions as to where would you 14 be positioned? How would you be directing traffic coming off i
15 this road? Would you have cones out here to change traffic 16 I direction? And then I asked about what would you say if a 1
17 l motorist would ask you where they were supposed to go?
13 ,
Q Okay. That last part, is that what you characterized yg i earlier as informational functions you would question them l'
about?
20 ;
l A Yes.
21 O How would you characterize the response of the Ae-FEDERE lEPORTERS, ::NC.
2::Z 347 3700 Nanenwme Ca.erage 800 336 oN6
I i
i
___ ! traffic guides you interviewed to the informational-type I
i 2l questions that motorists might present to them?
l 3 A Well, I was concerned that apparently the traffic 4
guides had not been informed that the evacuees, or the 1 persons who were in evacuation traffic, were to be directed 5
to a registration center in Nassau County that has been designated. Apparently they did not have any specific informatio:
7 of that nature to give to motorists, and they had not been 8
directed to tell motorists to turn on the EBS station to get 9
the lastest information either.
10 One individual told me that he would send the people 11 j who asked to the emergency examination facility at Brentwood.
i
~
12 l So, that was the nature of the questions.
13 I O. So, what conclusions did you draw about the adequacy I
14 l of response by these traffic guides regarding information i
15 functions they would pe'rform in the field?
16 j A That the information they had at their disposal in 77 l that respect, that was incomplete, and incorrect, in fact.
Q If you wanted to characterize, based on your 1
interviews with traf fic guides, their responses are either
! adequate or inadequate, how would you conclude?
20 ,
A With recpect to directing traffic, it was adequate.
21 MS. MONAGHAN: Objection as to vagueness in terms of 22 Au.-:?EDERAL 3E3ORTERS, :~NC. .
.w.n u_~ ~
I
)
- - - - - - - i what adequate or inadequate means in this context.
I
,, ~.
2 THE WITNESS: I guess I would like a definition I would have to say their traffic control 3
l of, ' adequate.'
I 4 functions were adequate.
BY MR. MILLER: (Continuing)
) 5l I Q
What about informational purposes to motorists?
6 I That was incomplete.
A 7
g Q Adequate, or inadequate? l
) 8 .
A Inadequate in that respect, yes.
9 Q Now, with respect to radiological protective measures g
10 ,
l I
} could you indicate to me the questions you would have asked thes 11 i y
l individuals, these traffic guides?
/~ - 12 My questions were essentially identical to 'thos
(- A Yes.
13 l
} which I had asked the route alert driver, and the impediment 14 I l response crew. I asked them about their instrumentation. Did I asked them to show me how they
) 15 l they know how to use it.
l 16 I would use it, and what the scales meant, and what they were 17 doing with the cards and so forth.
l I 18 Again, their answer with regard to their dosimetry i I
correct. There was one instance -- I guess the point I
! Were 19
)
ant to make is that I did not observe any actions regarding 20
, i potassium iodide ingestion, because they e.ll reported they I 21 '
had been instructed to take it before deploying from the ;
22 ,
- AG-3EDERAL 3EPORTERS, SNC.
- n.w.n . , - ~ . - --
79 l
- - - - _ _ Patchogue staging area, and I was not at the Patchogue staging area at that time. So, I did not observe them.
2l !
3 Q What other radiological protective measures did you 4 inquire about? What about excess authorization?
A Yes, I did ask them if they knew who was responsible f'
6 f r authorizing excess exposure, and two of the traffic control i
I points -- well, I should say that seven of the traffic control 7 i points the , answers given was the correct one; at two, there I
was an indication they might question the authority of the lead 9
traffic guide to authorize excess exposure.
j Q At the two traffic control points where the issue 11 !
j was raised as to questioning authority, can you recall how many 12 l traffic guides raised that issue with you?
sj i i
13 A At one of the traffic control l Two individuals.
14 l points there were two people in the car, and one individual l
l 15 ; raised the issue. At the other, it was a single person in 1
i 16 ! a car.
I 17 l 0 Are you saying, Mr. Saricks, that these individuals I
i did not know that the lead traffic guide could authorize 18 l 1
, excess exposure, or did they question the authority of the 19 !
-! lead traffic guide to give them that sort .of information?
20 !
- A The latter.
21
- O Did they indicate that they would not abide by the 22 ,
Ae-FEDERE :lEPORTERS, ::NC.
, - .- .< _ u . - -
, e i
i recommendations or instruction of the lead traffic guide?
2 l A No, they did specifically say that. They did 3 '
indicate that they might ask to speak to someone higher in 4
authority for verification. l l
5 0 Did the traffic guides you interviewed, Mr. Saricks, '
i 6 ,
l know themselves that the lead traf fic guide could authorize l
7i l excess exposure, or was the position of lead traffic guide I
8 I
involved in your question to the individuals?
M . ONMHM : OMecdon to de form of de pesdon 9
as vague.
10 l l MR. MILLER: Do you understand my question, Mr.
11 j Saricks?
- 12. ,
L THE WITNESS: I understand the question. I did not 13 l l
put the question in the form: Are you aware the lead traffic 14 i
{guidecanauthorizeexcessexposure. I believe my question 15 was simply: Do you know who authorizes excess exposure?. Who 16 l will tell you, over the radio, that you are authorized to 17 excess exposure?
18 BY MR. MILLER: (Continuing) 19 ; Q Now, if that was your question, Mr. Saricks, isn't l 20 it true that traffic guides only speak with the lead traffic guide over the radio?
- A According to the LERO Plan, that is the case.
g ACE-:?EDERAL lEPORTERS,7_NC.
- c:. m .y co .sanon m c4 c m...au soo.nm J
l 81 i
i
__ __ __ f Q Mr. Saricks, you said earlier that you were at the 2 Patchogue staging area itself about forty-five minutes at the i
3 I beginning of the exercise, correct? What did you observe during 4 that forty-five minutes in general?
5l I A As I said, I ob. served one dosimetry briefing which 6
inv lved both evacua tion bus route drivers -- primarily evacuation bus route drivers. A few other emergency response 7 ,
personnel, and route alerting driver who was later identified.
8 >
l I observed other response personnel arriving. It 9
was clear to me when I was there that the staging area was 10 :
j fully operational with respect to the activities that were 11 l j going on at the time.
(_.,,
12 I l However, beyond that I did not perform additional l
13 evaluation functions because they were already at least two 14 FEMA evaluators assigned specifically to that location.
i 15 0 Who were the FEMA evaluators assigned to the
, 16 i Patchogue staging area location?
l 17 l A I know the team leader, Robert Reynolds, was one, l
18 and I believe initially Ed Tanzman was the other. There were
, other FEMA evaluators at that location who went out with buses, 19 ,
I guess. They weren't, as far as I know, assigned to that i
staging area specifically.
21 ,
O Mr. Saricks, during your evaluation of these 22 l
! Ae-:?EDERAL 3EPORTERS, :~NC. _
> , m. - s _m. mum I
i 82 1
various functions, traffic guides, route alert drivers, traffic
~
2 impediment, at the day of the exercise, did you travel alone?
A No, I did not.
3l i
4 0 Who were you with?
i
! A There was an observer in my ' vehicle.
5 ' ,
I O Who was that?
6 A I am sorry, I don't remember his name.
7l l MS. MONAGHAN: It is not relevant <who the observer 8l l was. What we are talking about here is Mr. Saricks evaluations i
9 i l of what went on during the day of the exercise.
10 i L MR. MILLER: Objection noted.
11 ! THE WITNESS: I don't remember his name.
12 ! . BY MR. MILLER: (Continuing)
' I I
13 I Q Was he another FEMA employee? l 14 A No.
I 15 O Was he an Argonne National Laboratory employee?
A N
- 16 i
O Was he LILCO?
17 A I don't honestly know if he was LILCO.
18 Q LILCO or LERO?
19 I A He was identified to me as being someone from LERO.
20 0 And what did this person do during the day of the 21 exercise?
22 l
ACE-?tDERAL DOR 1 HRS, TNC.
. w. , ~_ - u.- -
l 83 i i
A Nothing. I mean he chatted amiably. He did not 2 !
- have his own radio communication equipment. He was not taking 3 i i
! notes. I!e simply was along for the ride.
4l l Q The entire day he was just along for the ride?
5 A That is right.
6
- O Did you ask this person any questions regarding the 1
7 I exercise, and the function's you were performing as an I
8 i evaluator?
9 MS. MONAGHAN: Objection as to the relevance of i
10 l this line of questioning. There are no admitted contentions j I
11 about the functions of the evaluator as might have been I
y2 I questioned by somebody who was there solely as an observer.
l
.v l THE WITNESS:
13 l To the best of my recollection, we l
\ had no discussion whatsoever regarding the conduct of the 14 g exercise.
Tnis individual apparently was just there to see what I j was going on, and didn't have any other function. In fact, 17 l he apparently had no knowledge of what was going to happen during 18 the exercise.
1 9! ;
MR. PIRFO: Move to strike, i
i 20 '
BY MR. MILLER: (Continuing) 21 Q You say the person who was riding with you, Mr.
22 Saricks, took no notes?
i AG-3EDERAL REPORTERS, INC.
, =.97 7 00 .Nancamce Ca..nst NUM
l 84 i
i '
- - - - - - - A I observed him taking no notes.
2 Mr. Saricks, at other exercises you participated in, l Q i
3 ' had you ever been accompanied by other individuals along for the 4 ride, as you say this person was?
5! MS. MONAGHAN: Objection as to relevance as to what 6 happened at other exercises with respect to whether observers 3 1
7 accompanied Mr. Saricks.
MR. CUMMING: The witness may answer the question.
8 THE WITNESS: Yes. I believe on one previous l occasion, and the observer was not in any way materially 10 4 s
-connected with that exercise.
11 f l BY MR. MILLER: (Continuing) 12 s O I am confused. The last part of your answer. The l 13 observer was not materially connected with that exercise. Are 14 i
- you referring to at the other exercise the observer -- you have I
15 l lost me in your answer.
16 l A Oh. The person who accompanied me in the prior l
17 I exercise was not an exercise participant, or another evaluator.
18 0 Were you told, Mr. Saricks, the purpose of this 19 : person who accompanied you on the day of the Shoreham exercise, what his purpose was?
l MS. MONAGHAN: Objection. It is totally irrelevant as to what the purpose of the observer was.
22 ,
- AG-3EDERAL REPORTERS, INC. i
- T. 347 N NauenwWe C.r..m. e M33&&4
l WD l
- MR. PIRFO: I might add that it has been asked and
, i 2 l answered about four times. The witness has said he had no
)
3 idea what the purpose of the observer was.
4 THE WITNESS: I should point out that my permission g was asked, and I said I had no objection.
i e
l.
i In other words, the individual was not forced upon me.
7l BY MR. MILLEP: (Continuing) 8 0 Who asked your permission to let this person 9 l l accompany you?
10 l MS. MONAGHAN: Objection as to relevance.
11 I j THE WITNESS: I don't recall specifically. It may l'
I
- l have been the staging area coordinator, but again, I don't 13 l <
remember.
14 f BY MR. MILLER: (Continuing)
I 15 j I
Q Was it a LILCO or LERO person, to your knowledge?
l 16 l MS. MONAGHAN: Continuing objection as to relevance 37 l to this line of questioning. !
g THE WITNESS: The person did not identify himself as a LILCO or LERO employee. I can only infer --
l j BY MR. MILLER: (Continuing)
Q Was it a FEMA person that requested your permission 21 l 1 to have this person accompany you?
22 1
- @ l Ae-FEDERAL lEPORTERS, NC.
n.w.n ~ - - ~ . . , -
l 86 I
\
. j A No, it was not.
2 I
Q Was it an Argonea National Laboratory person?
3 A No.
4 3 Q Was it any other Federal person to your knowledge?
5 .
A To my knowledge, no.
6! Q When you were asked permission to let this person 7 accompany you, is that all that was asked? Can this person 8 accompany you, and you were introduced, and you got in the car i ~
? and you went. Is that what happened?
10 ,
A Yes.
L 11 O You made no inquiry as to why that person was 2 lg ing to accompany you?
s.'
! A I think I might have asked the question is this 13 l person going to perform any particular function today, and l they said no, he was simply going along for the ride.
15 :
l MR. MILLER: I am going to mark this as Saricks 16 i Exhibit No. 2.
17 i '
(Above referenced document is I
la 4
! marked Saricks Exhibit No. 2, INDEX 19 for identification.)
l 20 MS. MONAGHAN: Just as a procedural matter, I l
l 21 l don't think Exhibit 1 was ever marked for identification.
I 22 '
i i ACE-3EDERAL DORTERS, INC.
I E 34-37 0 Nanonmas Cy case M3 64
, di
_ . _ _ _ _ . t
_s ! MR. MILLER: I thought it was.
2 i BY MR. MILLER: (Continuing) l 3
O Mr. Saricks, what we are going to mark for 4
identification as Saricks Exhibit No. 2, is a two-paged document.
5 l! At the top it says: Shoreham Exercise - Evaluator Assignment /
l 6
Location Instructions.
7! Page 10 of 28, and page 11 of 28, in the upper right 8 hand corner. Have you ever seen this document before?
l 9l I A Yes. I have seen another copy of this document. I I
10 haven't seen this one.
1 =
l yy j Q Can you tell me what this document is?
! A This was included in the materials that were s-12 ! ,
! distributed on the Monday, the so-called training session, for 13 the pre-exercise, describing in more detail the specific 14 i
, assignments that each of the evaluators would have, and the i
LS -
i procedures they were to follow.
16 0 It was distributed on Monday, February the lith, 17 i correct?
i A Yes.
19 0 Is that the first time you saw what has been marked
\
l l 20 l as Saricks R>hibit 2?
21 A It is the first time I saw it yes, this completeness 22 of information, and it was this form.
1 ACE- ?EDEML 3EPORTERS, TNC.
j m.97.m Narxnnnee C,:...as 300 3M
l i
l MR. PIRFO: Just for the record, I believe February 11 l
2 Iwas Tuesday.
3 THE WITNESS: No. February lith was Monday. 1 4
MR. PIRFO: Well, according to my calendar it says 5 the 10th was on a Monday, but you may have other information.
6 BY MR. MILLER: (Continuing) 7 '
O Let me back up, Mr. Saricks. February 13th was 8 a Thursday. So, when you are referring to February lith, do 9 you mean Tuesday?
A No, I mean the training day, which was the 10th.
10 I am sorry, the lith, yes.
i I'll explain the reason for my difficulty here. Most 12 1\ .
l exercises are held on Wednesday, so the sequence in my mind 13 l l begins on Monday and runs to Thursday, rather than Tuesday 14 j to Friday, i
15 l
! O Okay. For Shoreham, the sequence began on Tuesday.
16 A And ended on Friday.
17 i i 0 So, you first saw this on Tuesday, February the llth?
13 '
A Yes.
19 l 0 Is what has been marked as Saricks Exhibit 2, a fair i
20 1 description of your evaluator responsibilities on the day of the
{ i l
21 Shoreham exercise, Mr. Saricks?
A Yes.
22 l w
! A -
s_ u.- _
m l
1 l
l Q Now, I assume that given your previous testimony
_ l 2 j that the start time for your traffic control point evaluation 3
began after twelve o' clock noon, as stated on this form?
4 A Yes.
5 0 And that is because you were delayed at the traffic l
6! !
impediment scene?
7 A Correct.
8 0 a nd I assume from your previous tegtimony, Mr.
l l
g Saricks, that in performing these functions as reflected on Saricks Exhibit 2, you took your personal notes that you referred to earlier today?
11 A Yes.
12 1 d Q Now, if you look down under this impediment to 13
! evacuation, under Description of Activit*J, it says you are l
14 1
! to evaluate the LERO person in simulating the setup of traffic 15
- control, if any, and removal of traffic obstruction.
'6 Do you see that?
l 17 A Yes.
i 18 1 O Now, I take it that you did not observe those 19 l functions by the LERO personnel?
1 20 .
A There was no actual setup of traffic control at l
t that location. There was a demonstration of how an impediment I i
,, j would be removed, but it was not donc at the actual location l
l
. .. s An~-r- EDERM. . REPORTERS, .NC.
m.m s _ _m. ,. mum
l 7 -- -- of the impediment. It was in the parking lot adjacent to my 2 I
! vehicle, i
3 Q And where it says: The LERO person should assess the i 4I i situation and request for an actual arrival of emergency i
l l l 5 i equipment, did you observe- that?
6[ A My belief is that this refers to a LERO route 7l spotter, rather than the response individual.
g Q Well, did you observe a LERO route spotter?
g A Yes, I observed the LERO route spotter who actually l
arrived at my location at about eleven-forty.
10 L
~~
i Q Did you talk to that person?
11 l 1 l A Yes. I asked that person if they were there in )
12 '
i
. l 1
- any way connected with the impediment. ~
13 l . .
l 0 And what was the response?
14 l A They said they had been instructed to come and find l
15 l
! me.
i 16 i i O Did you have any other conversation with this route l l l
17 l spotter?
18 i A Well, given that I wasn't interested in providing 19 i information to prompt this individual to_do anything more than 20 he was supposed to do, and I really limited my remarks to him 21 to just the question regarding what he was doing there.
22 ! _
AG-3EDER-\L 3EPORTERS, :.NC.
i *E '47-r00 2 Nancomde Ca. . asje 300 336 6646
l 1
l i i !
{~~~~ Q Let me go back to my initial question. Did you 2l observe this LERO person, this route spotter, assess the 3
lsituationandrequestforanactualarrivalofemergency I
4 equipment?
5 A He did not do that in my presence.
6 Q so, you don' t know if he did that or not?
7 A That is correct. Again, the person who was the 8 route spotter, it was not necessarily clear to me that that 9 was going to be the person who would, in fact, radio for 10 the assistance.
I Now, if you look over to the second page of the Q
11 l document, Mr. Saricks, under the traffic control points l discussion, did you ask the traffic control personnel how 13 I l they would interact with State or County police should they L4 arrive?
15 I i i A Yes, I did ask that question. I I
I 16 i 1
- O And what was their response? '
l 17 A I think in all cases they indicated that they would 13 ! relinquish their specific traffic direction responsibility at 19 l that location to the official. However, they would remain i
20 ! at the site with their dosimetry and answer any questions that i
21 the official might have.
I 1
22 ,
Q When you questioned these traffic guides from your
- i Aw.w.n-?EDERAL DORn.RS, ::NC.
~ _ w .. ,. - '
i l
i
__ __ __ i
! interviews that we discussed earlier, what were they doing at 2! I the time? Here they. generally sitting in their cars?
3 A Yes, sir.
4 i
O Mr. Saricks, moving up to the route alert assessment l
5I of the document, Subsection 1.b says that you are to follow the 6
route alert driver, noting instructions, if any, given to the 7 I public, as well as whether the recte that is followed is l
8l correct according to the Plan, i
9 Did you observe any LERO persons, route alert driver, 10 give any instructions to the public?
l yy f MS. MONAGHAN: I am going to object to this line of questioning, because it deals with route alerting, and is i not relevant td contentions that are admitted. If it has 13 l l
j any relevance, it is limited to training contentions.
14 l l THE WITNESS: I had been informed before we left 1
15 I the staging area that the public address system would not be 16 activated actually while on the route. And I understood the i
17 ! reason for that perfectly.
j i
33 Sc, what I observed during the course of the route i
19 l was that when the driver stopped, he would simulate picking l
20 l up the microphone, and talking into it.
i 21 l ;
BY MR. MILLER: (Continuing) 22 !
~
a A=.w.n-3EDERAL DORTERS, TNC.
> _ - ~ . - -
g i
- -- ~~
l Q Did you ask any questions of the route alert driver 2 !
I you observed about how and what instructions would be given i
3 i to the public in the event of an actual emergency at Shoreham?
4 l A I had seen the text of the message that he was 5 to read. He was reading from a prepared text.
6 j Q Did you discuss with this route alert driver the 7 jpossiblescenarioofsomeonememberofthepublicapproaching I
8l the vehicle and asking for additional information?
I g l A Yes.
l 10 j Q What did you talk about in that regard?
A I believe the question related to an individual l wanting to know what is going on. It wouldn't necessarily 12 ! i l be based on wanting to know any particular fact, but just 13 l I
some one coming out of their house and hearing this wanting 14 l l to know more.
i 15
! And s his response to that was substantially corre ct ,
t r l' i ,
j he said he would inform the individual to tune in immediately 17 to the EBS station or further details, and follow the 18 { instructions that were given.
19 Q Mr. Saricks, the text of the questions that you ,
i i
20 l used in your interviews with these various individuals, the j gi route alert drivers, traffic guides, response to the traffic i ,
22 impediment, were those questions that you created? !
3 Att-3EDERAL DORhMS, :NC.
i =. ,.87 3 00 Nancemde Co. age M 336-co.6
i
__ __ __ j l A Yes. They were based, again, on my prior experience 2 li in exercises.
3 Q So, is it fair to say that you, yourself, came up 4
with the questions you asked during the interviews?
5 A That is correct. I was given the scope of the 6
questions tnat should be asked. .The actual text of the questions 7
if you will, were mine.
8 And who gave you the scope of the questions to be Q
9 asked?
10 A Well, they are given here, essentially.
0 Is there anything in addition to what has been 11 l 1
12 marked as Saricks Exhibit 2, that gave you the scope of the l
questions to be asked?
13 ;
I l A To my recollection there may have been statements 14 I i
i made on Tuesday of the training session regarding other 15 I types of questions that might be asked, but I don' t think it 16
! substantially goes beyond the scope of whar is described here.
17 !
I will say that the question to the traffic control 18 '
point personnel regarding information they would provide to 19 ! motorists was my own question, and I was not directed to ask I
20 '
that question.
21 l Q And that is one of the questions that you referred 22 l I s AG-rEDERAL 3EPOR~1EKS, :NC.
. =. w. -
. -- u-, --
l 1
l to earlier where the response was inadequate, is that correct?
2 i A Yes, that is correct.
3 MR. MILLER: Off the record.
4 (Off the record discussion ensues.)
5 BY MR. MILLER: (Continuing) 6 Mr. Saricks, I am showing you what was an exhibit Q
7 in Mr. Hugh Lane's deposition last Thursday. This is Lane 8 Exhibit 2. And it is entitled: Itinerary for Shoreham 9 Exercise, February 10 through 14, 1986. Have you ever seen 10 this itinerary before?
yy A Yes.
O And do you recall when it was given to you?
A This was in the packet that reached me at the 13 laboratory during the week prior to the exercise.
14 Q And I take it from your prior testimony, Mr.
L5 Saricks, that you would have traveled to the Shoreham site 16 on February 10th, which was a Monday, is that correct?
i 17 I ; A That is correct.
I IB l Q And you started your meetings in preparation to 19 perform your task as an evaluator on February the lith, or i
20 Tuesday, correct?
I 21 A Correct.
l 22 I
A -rEDERAL 3, HORTERS, J.NC.
F.-347-r/00 Nacounce Cm. rase NSD6&*6
! 96 l
l l
~
l Q Looking at the first page of Lane Exhibit 2, Mr.
2l lSaricks,didyouattendthatFebruarylithjointtraining 3
session for FEMA evaluators?
4 A Yes, I did.
5 . -
! O Do you recall who spoke at that training session?
6 A I can remember only three individuals specifically.
7 I know that there must have been others -- I don't have a mental i i
8 of their talking, so I can't say for sure.
9 Who were the three that you remember?
10 A Roger Kowieski, then the RAC Chairman; Joseph
[
11 Keller, and Dick Donnolly, who was the Region X RAC coordinator 12 l fr m FEMA.
Q Dick Donnolly or Donovan?
I
' l A I am sorry, Donovan. I 14 l
! O Do you recall generally what they said during that 15 '
I training session? .
16 l -
l A I think -- my recollection is that Kowieski's 17 l '
remarks pertained to general conduct of the exercise, trying to 18 l outline the sensitivity of certain issues. Essentially l l
19 '
establishing the ground rules for what we were to observe and 20 lconformtoduringtheexerciseitself,andabasicdescription 21 of what would follow the exercise in terms of evaluation.
22 i
A_
-3EDERAL 3EPORTERS,7_NC.
7 ,
. 4 i
~ Then Keller spokr regarding the scenario, and also 2lf j regarding what we were suppose to see in the area of dosimetry, and radio protection.
4 And I believa Donovan was concerned with making sure 5
we understood that a chronolagy of events would be assembled I
6 .
from everyone's observations at some point after the exercise.
7l FR. CUMMING: Counsel from FEMA objects to this 8 line of questioning, but with respect to this witness only, 9 will allow the counsel for Interveners to continue.
10 BY tiR. MILLER: (Continuing) 11 Q Mr. Scricks, would you look, please, at page 5 of 1
12 Lane Exhibit 2. At the bottom of that page there is a s.. I mecting from seven-thirty to eight-thirty p.m., $nd this v
would be on the day of the exercise, February 13th, and it is I
! noted the purpose of that meeting was to develop an event 15 ! I i i time line. l 16 l )
l A Yes.
17 i '
I i Q Is that the matter that Mr. Donovan spoke to on 18 February the lith, when you say he was concerned with 19 l assemblying a chronology of events?
i 20 A Yes.
21 Q And, in fact, I assume that such a chrono]ogy of 22 i
- Att-?EDERAL 3EPORTERS, :NC.
- n.ui 3 00 Nanomnde Con.sge 6003 6
i i
___ j events or time line was put together the evening of the exercise, 2
is that correct?
3 A Yes.
4 Q Did you attend this meeting on February 13th, from 5
seven-thirty to eight-thirty p.m?
6 A Yes.
7 0 What role did you play at that meeting?
8 A My only role was to provide times from my own record 9 of events as they occurred in the field that I observed.
10 '
O So, you simply based upon your notes from that 11 ,
day provided times to someone?
i 12 l A Correct.
u- !
g l Q Was that someone Mr. Donovan?
! A Mr. Donovan, I believe, was the person in charge of 14 j l actually reporting times on the display board in front of the 15 !
I -
i room.
16 Q Was that meeting generally a meeting where the l 17 l evaluators stand out in the audience, and as times were provided, 18 i they were noted on a large board so at the end of the meeting j 19 ; tnere was a co:t. : ete time line from beginning to the end of the 20 l exercise?
l i
21 A Yes , that was the purpose of the meeting.
I 22 94 4 ep
! ACE-rEDERAL .D_ PORTERS, _NC.
=.w.- 8 - . ., -
l Q Did you take any notes at that meeting on February 2 ;
the 13th?
3l
! A No, I took no notes. I simply provided the 4
l information from the notes I had taken earlier in the day.
5I Q Did you take any notes at the February lith initial 6
! meeting, training meeting?
I 7 i
! A I believe I took some rather sketchy notes, j l \
8l particular in relation to phone numbers that we were supposed i
9l to have, or specific contacts. People in the field, obviously, 10 had that information.
11 l Q I am referring back now to the first page of Lane 12 i Exhibit 2. l l
A Yes.
13 i Q Do you know where those notes are today? The notes l
l that you took at that meeting on February the llth?
l 15 i l A All notes that I took during the conduct of the 16 i I
exercise that I still had in my possession at the time that 17 I
! these proceedings were notified,were turned over to counsel.
18 :
Q So, the notes were in your possession when l 19 l you received the notice of deposition to come here today,
^
j 20 l is that what you re saying? l I
21 A No. They were in my possession for a period !
22 1
1 ,
l l
n j i
ACE-FEDERAL 3.EFORTERS, i.NC.
l . :lC2 M7-3 00 Nanonmce Co..nge 300 D6h i
____________________.__o
1 100
___ i i thereafter.
2l i The point that I am trying to make is that if I 3
took additional notes on that day, they were no longer in my 4 i possession at the time that these proceedings -- there was the 5
l possibility that I would be deposed, and that actually preceded my actual notice.
- 7) I have no recollection of discarding any materials. t 8
{ However, if there were cotes I took on that day, they were n 9 in my possession at the time proceedings --
l 10 . 0 You keep referring tt., 'these proceedings.'
1 I,
11 l A Well, I guess I don't know --
12 0 Are you talking about your deposition, or are you talking about the broader -- the Shoreham exercise litigation
[ proceedings?
14 l l A I was first notified that I might be deposed in the 1 15 l '
proceedings about a month ago, so it was prior to the end i 16 l '
l of October.
17 l l Q When you finished serving as an evaluator and
^8 '
were departing Long Island to go back to Illinois, did you 19 take notes, or anything in writing regarding the exercise, 20 with you at that time, or had you turned it in at that time?
I 21 A No, I still hcd my personal notes with me at that time 22 l
l l
Ac2.-:?EDERE REPORTERS, TNC.
lol Q And you would have had any notes from training 2 ;
j sessions at that time with you as well.
3 i
! A At that time, yes, sir.
4 O So, approximately a month ago you turned those 5
notes in?
i 6 i:
A Within the past month, yes.
7 And you turned them in to Mr. Cumming?
Q ,
4 8l A That is correct.
9 ,
Q Mr. Saricks, on Page 2 of Lane Exhibit 2, there 10 ! is a meeting -- another training session with FEMA evaluators i
11 and controllers, f rom one-fif teen to three o ' clock , p.m. , do
- you see that?
72 j A Aga.i.n, February lith. I am sorry.
O February lith. On the second page of the exhibit.
I A Yes.
i 15 1 Q Did you attend that meeting?
16
! A Yes.
17 I i Q Do you recall who spoke at that meeting?
18 A Yes. This s the presentation by Roger Kowieski 19 '
that I recall. I see a name here Bernard Weiss. I cannot 20 form a mental image of that individual, therefore, it was not i
21 , in my recollection that he spoke. l 1
i 22 I
Att-:?EDERAL REPORTERS, :NC.
n.w.n ,_ -.- . -- ,
l
j 102 i
__ __ __ j l Q Are you on the second page of the exhibit?
2 i i
l A I am sorry.
3 I see. One-fif teen to three o' clock. I flipped over 4
i and saw one-fifteen to five o' clock.
1 5
Q One-fifteen to three o' clock on Page 2 of "ane 6 '
Exhibit 2, training session of evaluators. Did you attend 7
I that meating?
8 A Yes.
l 9 0 Now, do you recall who spoke at that meeting?
l 10 A Yes. This was the presentation by Joseph Keller, 11 who I spoke of earlier, and I do have now a recollection that l, 12 Thomas Baldwin also spoke, but I can't remember the specifics l<J ,
of his presentation.
l 0 Do you know if you took any notes at that meeting?
14 l
l A I believe this was the period of time I took the i
15 i i
- notes.regarding the phone numbers to be contacted.
16 f Q Okay. On Page 3, Mr. Saricks, of this exhibit, at 17 l the top of the page there is a training session for the 18 I simulators.
t Did you attend that meeting? .,
i 19 l A No, I did not attend that meeting.
20 Q And right below that it says : Three o' clock to 21 five o' clock p.m., evaluation team meeting.
1 22 ,
A Yes.
l em a **
i ACE-rEDERAL REPORTERS, ..NC.
i m.m.m s_ .- -
i I
103 l
- Q Who is your team leader again? Mr. Reynolds?
2 :
A Yes, Mr. Reynolds.
3 j j Q Do you recall who else was on your team?
4!
! A I cannot recall the FEMA evaluators. I know there l I 5 ~
must have been at least one or two others. I can recall 6
Argonne personnel. Ed Tanzman, Sue luus Curtis come to mind.
7 I can't say for certain. There is another individual, and i
8l 1 I can't be sure that he was on my team. As I was in the 9 field all day, my sense of being as a member of e team was not 1 I l 10 ! particularly strong other than my responsibility to the i-l 11 l team leader.
! O Do you recall attending this meeting as basically j
12 l ,
I a meeting with the team to discuss your eva3uator assignment, 13 !
1 l 1s that correct?
l L4 !
l l A Right. l l
15 l )
l Q Right beneath that, there is another training i 16 I
, session indicated for FEMA controllers. I see you did not I
17 l attend that meeting, is that correct?
18 A No, I did not attend that.
19 ! 0 okay. On Februa ry the 12 th , Mr . Saricks, it is 20 ' indicated that from eight-thirty to eleven-thirty in the 21 morning evaluarors were to travel to the locations in the field.
l 22 AcT-3EDERAL lEPORTERS, :~NC. _
j Ic2-347.T00 .Nancumce Ca... age M3M
104 l
- i Did you do that?
I A Yes.
3l l Q Did you travel -- tell me where you traveled to?
4 A Well, I believe I took these in the sequence that l
5 '
I was going to be doing the following day, to make sure that 6l I knew the route from one to the other.
7! So, I went first to the route alert location. Drove 8 to that area , and then went to the impediment location, and I
9 ' then I went to the traffic control points in what seemed a 10 ! logical sequence based on their proximity to that site.
I i
11 l 0 Did you go to the Patchogue staging area?
I l< 12 l I
A Yes, I did that.
s- ;
i O Did you go inside?
13 l ,
i A No, I did not go into the building. We had, I 14 i believe, been instructed that it pas not going to be available 15 i
l to us until exercise date. But I clearly identified it.
16 I l
0 Did you say you actually drove the route alert routes, 17 l l the route alert driver routes, the day before the exercise?
l 18 - '
. A I did not drive the entire route. I drove a sub-19 set of streets in that area to satisfy myself as to trhat the 20 ; nature of the neighborhood was. What appropriate procedures --
l 21 ; procedures that would be appropriate to notifying that area.
I 22 ,
AG-rEDERAL 3_ H>ORTERS, __NC.
=.w.n s-- u. -
l luo I
__ __ __ j
_ No, I did not drive the entire route ,
2
- Q Were you by yourself when you were making these 3I trips around?
4 A I was.
5 i
-B Q Later, on February 12th, if you look at Page 4, i I !
i 6
Mr. Saricks, from one to four in the afternoon, it says that 1
7 evaluators were to study their assignments. Do you recall 8 doing that?
9 A Yes.
1 10 j 0 Do you recall looking at the items listed on the l .
11 l! far right; the LILCO plan procedures, exercise objectives, i assignment sheet?
12
- l 1 A Yes, I recall that.
13 j '
Q Is the assignment sheet, what we earlier marked 14 I for identification as Saricks Exhibit 1? l 15 :
l A Yes, it is. There was no other assignment sheet.
16 i
- O Do you recall studying anything in addition to I
17 i 4
I these four items listed on page 4 of Saricks Exhibit 2?
18 A The only other document I might have examined was 19 i the NUREG 0654 guidelines for evaluation. FEMA Rev 1, Rev 1.
l 20 I Q How did you know which sections of the LILCO Plan 21 to review? i f
22 1 AG-:?EDERAL 3EPORTERS, INC.
l h E.347.m N m on e Co'. a se M33W
._~
l 106 i
{
l A The procedure numbers had been provided to us for 2 ,
each of the objectives that we were to observe.
3 O was that material accumulated for you and included 4
in your informational packet?
5 A Yes, it was.
l 6'
Q Did you look at any sections of the LILCO Plan or 7 i procedures other than those sections put together in your 8
informational packet?
9 A Previously I had read a LERO Plan. Not all of the J
I 10 i procedures, but I had read the overview plan.
i 11 d The first volume is -- I cannot say that I read I
12 l it word-for-word, but I did go through that document.
g Q Was that right before the exercise?
]
A I believe it was within a week prior to the 14 !
! exercise.
15 ! i Q And that document was reviewed at Argonne I 16 l
l Laboratories in Illinois? j 17 A Yes, it was.
18 '
0 With respect to the implementing procedures of the i
^9 1 !
, plan, those procedures that you looked at would have been the i
20 l ones included in the informational package, is that correct?
21 A That is correct.
22 l l
Ac-: FEDERAL :MORTERS, INC.
.a:.u .rm sanone cm..w soo r m l
L _ _ . _ _ . . _ _ _ _ _ _ _ _ _ _ _ _
tv,
[i ;
1 l
i
~ Q Is this the first time you would have seen the 2
exercise objectives?
3 i A Yes, stated as objectives for purpose of -- actually 4
let me say, I cannot recall if in another form, the fact that l l
5 we received it the precedi'ng week, their was a list of objectives 6
to be satisfied. j 7 It is customary at FEMA exercises to receive prior 1
8 to the exercise the list of objectives that are to be satisfied 9 by other cases, State and local government, and that is why --
10 it may well have been in the packet, and I can't separate in my mind whether it was, in fact, for the Shoreham exercise or for other exercises.
12
'~
Q Mr. Saricks, you told me earlier today that you 13 .
l received a packet of materials about a week before the L4 Shoreham exercise, correct, and you could have had the 15 l l objectives in that packet?
16 I A It may well have been there, yes.
17 : 0 Now, I was assuming that the materials chat you l l
l 18 l reviewed on February the 12th were the same materials provided i
19 to you the week before in this packet. Am I wrong in that l l
l 20 ! assumption?
A N The material provided for us in the packet, 21 l .
22 plus additional materials that was distributed at the Tuesday
! I
' i .
j An -rEDERAL REPORTERS, 7.NC.
i :::T. 347-I 00 Sanonwide Ce. case 300 336-ood6
lue l
1.
- meeting were the ones that I reviewed on the 12th.
2 0 Were you given any materials on February the 12th in 3
addition to materials that were given to you approximately 4
before in the informational packet?
5 A I am sorry, on Tebruary the lith, during the training 6
session. .
7 '
O Let me back up. Were you given any materials 8 regarding the Shoreham exercise upon your arrival at the area 9l of the exercise, other than those that were given to you 10 ,
approximately a week before in this packet of materials?
l g l A Yes. As I said to you, all of this information in totality was given to me at the training session, not in the l packet I received.
13 1 l
Q Saricks Exhibit 1 is what you are referring to?
14 A Yes, that is correct.
15 Q Other that Saricks Exhibit 1, can you think of any 16 other information given to you when you actually arrived for 17 the exercise as compared to a week or so before the exercise?
13 MR. MONAGHAN: Just a point of clarification. I thin}
19 it is Saricks Exhibit 2 that you are referring to. Just to l l 20 keep the record straight.
I 21 MR. MILLER: Okay, that is right. Thank you.
22 l THE WITNESS: Right up to the exercise on Monday 1
1 ,- . ..
I :
ACE-rEDERAL REPORTERS, J.NC.
n.w.m s_ w, num a-_ - -_--____-__--_-_-_______ __.
l 109 i l l night, nothing transpired at that time.
2 The following day, Tuesday, that is training 3 i j session. I assume that is what you are referring to. We 4
ll were given additional materials. I recollect receiving a I'
5 ' l map that showed all the locations that I was responsible for, i
and the numbering scheme that was to be used for the traffic
)
7 control points and so forth, in order to translate from the i
8i written. I also seem to recall that there was -- we did receive I i i !
l 9 copies of the procedures that were relevant to our areas of 1
l l
l 10 j observation. They may have been duplicative material. In 11 ther words , we may have received the same copies we may have 12 g tten the week before, but certainly this and the maps were
~
material we had not previously examined.
Q This is Exhibit 2. l l '
14 i i A Yes. Sorry.
15 l l O From four to five o' clock on the 12th, Mr. Saricks, l
16 at the bottom of page 4, there is a general meeting for 17 j evaluators. Did you attend that meeting?
18 A Yes, I attended that meeting.
19 -
Q And it says the purpose of that meeting was the l 20 resolation of any problems. Do you recall any problems that 1
l 1
21 were discussed at that meeting?
22 Am.m.m-?EDERAL REPORTERS,7_NC.
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A It may have been at this meeting that the specific 2
\
l issue of parking restrictions arose, or something within that 3 ! !
j general area, and what mock occasions we were to make to our )
procedures if we ran into such a problem, and I think my I 5 I recollection was that we would notify and contact either the j 6 l
-- at the LERO EOC or who ever had been designated as our i
7 contact if those problems had developed, and to await further 8
instructions.
9 O Do you recall any other problems that were discussed
! 1 1
10 at that meeting?
1 11 { A No, I don't.
12 l 0 Did y u take any notes at that meeting?
- m. ! .
! A I do not recall taking any notes at that meeting, 13 t I
i no.
14 1
!' MR. MILLER: Mr. Saricks, I would like to hand to I 15 l 4
j you what was previously marked as Lane Exhibit 3, when Mr.
16 ;
l Lane was deposed last Thursday. I will represent to you that 17 !
i this is a list of objectives from the FEMA Report for the 18 Shoreham exercise.
19 And what I would like to ask you is if you have ever I l 20 seen these objectives before' I 21 i THE WITNESS: Before this moment?
l - 22 .
BY MR. MILLER: (Continuing) s l
l Ae-?EDERAL 3H3ORTERS, NC. i l 2 97 3 C0 .Nanonwme Co -age MUW
I
, ! Q Right.
2 i I
j A Yes.
3 l '
l Q Can you tell me by looking at this document, Mr.
4 Saricks, which onjectives you have responsibility for 5 l reviewing on the date of the exercise?
l 6
A Yes, I believe I can. They would all be under 7 field. Field 1. Field 5. Field 8. And Field Field.10.
l 0 8 11.
9 Q So, that was Field 1, 5, 8, 10 and 11?
10 A Yes, sir.
11 l 0 Mr. Saricks, I am showing you a nine page document i l g j which we.will mark as Saricks Exhibit 3, the first page of
~
which-is entitled, Exercise Evaluation Critique Form,.and l 13 l you have in the upper right hand corner Page 62 of 219, 65, i 14 l ,
l 80, 81, 109, 110, 111, 135, and 137.
15 l A Yes.
16 :
INDEX l (Above referenced document is 17 marked Saricks Exhibit No. 3,
- 8 1 ,
! for identification.)
19 i BY MR. MILLER: (Continuing) l 20 l Q Can you tell me, Mr. Saricks, if you have ever seen i
l 21 , this form before?
i
. 22
/
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- ACE-3EDER-\L DORTERS, INC.
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. ,. A Yes, I have.
2 -
1 e
i Q Where would you have seen this form?
A This was the form we were instructed to enter our 4
evaluations on for purposes of the exercise.
5 -
0 Now, was that the day of the exercise, or is this 6 L l the form you completed the day subsequent to the exercise?
7 A Subsequently.
8 Q And is this the form you completed based upon the 9 notes you took during the exercise itself?
10 A Based upon the notes, and based upon discussions with l l 11 j ther evaluators to determine the sequence of related events
! 4 and exercise objectives.
73 O And based upon your own judgment and experience?
I A That is correct.
O When you completed these critique forms, that would 15 i l have been on February the 14th, is that corre et?
16 A Correct.
17 j Q Which was a Friday. When you completed these forms, 4
18 l Mr . Saricks, did you write any comments under the column to the 19 far right entitled, Comments and Recommendations?
20 MR. CUMMING: You may answer.
l 21 i TEE WITNESS: Yes, I did.
I 22 l Ate-?EDERAL 3EPORTERS, ZNC.
I M* 7-7700 A Nancomde Cmanse MEW l
r 113 l' i
Q And the forms that you completed, the critique j forms you completed, are they still in your possession, or 3 ,
l custody, or control? j 4 !i l
l j A They are in the custody of counsel.
5 I j Q And you, I am talking about you, Mr. Saricks, 6 ;
l custody or control?
7 A No, they are not. l 8
Q They have been given to your counsel.
9 A I had not been in possession of the original of 10 j these for some time.
11 I Q Once these forms were completed on February the
! i 12 l 14th by you, did you turn them in to someone?
i
! A Yes.
13 ;
Q Who was that?
14 !
A They were turned in to my acting team leader.
1 i 0 Who was?
l 16 l A Robert Reynolds was officially the team leader. He l
l 17 ;
l had other responsibilities at the time, and the acting team J 18 ;
leader at that time was Sue Ann Curtis.
19 O So you turned these forms, once you completed them, i
20 l into Ms . Curtis . Did you keep a copy of them?
i 21 A ;;o ,
. 22 i I
I Ae-:.;EDERAL REPORTERS, NC.
- 2 347300 Sanonm :e Co'..~. ge 500 33 6
__ __ __ 1 i
i Q So since you turned them in to Ms. Curtis, 2 ! i 1
l
) l seen these forms again?
3 !
\
l A Have I seen the originals again?
4 !
r j Q The forms that you filled in, completed , w:
i 5 I I
! comments upon, have you seen those forms since they we I
6
! in to Mrs. Curtis?
l I A Yes, I have.
0 ' When was that?
Q 9 A Within a month and a half af ter the exerci:
l 10 ll-Q And who showed you the forms then?
l 11 A Ed Tanzman.
I 12 Q And what was the purpose of Mr. Tanzman shc s.-
the completed version of the forms at daat time?
13 j A I think predominantly to verify that, yes,l 14 ;
i' were my forms, and that this was my entries, and they I . e 15 I
been changed or tampered in any way.
16 l
i Q The ones you were shown by Mr. Tanzman, dig 8 have handwritten . comments, or were they typewritten?
I A It was my hand printing. I actually wrotei 19
- Q Now, subsequent to a month or half ago or
, i 20 l ; you seen your version of the completed critique forms 21 that time?
I 22 _
l 1 AG-rEDERAI. _DORTERS, ..NC:
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p 115 i
t l A I had not seen the original that I put my hand to.
2!
I had seen a copy.
3 Q You had seen a copy with your handwritten comments.
4
, A Yes.
Q When was that?
I 6
A It has been within the past month?
7 Q What was the purpose. Why were you shown this form?
l 8! A Basically, to again make sure that I was satisfied 9 that this was a copy of what I had done, and they had not l
10 l, changed in any way, and to help me refresh my memory regarding 11 l the events of the exercise.
i O Who served you the forms?
l ' l A Again, I believe it was Ed Tanzman.
13 l
l 0 And subsequent to that time, approximately a month 14 ! '
I ago, Mr. Tanzman showed you a copy of your critique forms.
15 !
l Have you seen the forms completed by you?
16 !
! A Yes.
17 I i, O And when was that?
18 A Within the past week.
19 0 And who showed you the forms that time?
l 1 \
l 20 ; A Well, as a matter of fact the forms were in my 21 possession.
22 !
I ACE-PEDERAL DORTERS, T_NC.
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I i 16 0 Originals or copy?
2l A Copies.
3
- Q They were in your possession? Had they been in your 4l possession since Mr. Tanzman showed you -- how did the forms come 5I
! to be in your possession a week or so ago?
i 6
- A When it became clear that we were to be deposed for 7! this croceeding. We were given the opportunity to get the 8 f copies of our forms again to refresh our memories regarding the 1
9 I events that transpired.
10 0 Who gave you that opportunity?
I 11 A It was a joint decision that was taken at Argonne.
I 12 l It was authorized by Terry Searles, and Tanzman actually s- !
l provided the copies to us.
13 i
- Q Who is Terry Searles?
A He is the Director of the Integrated Assessment 15 I j Policy Evaluation Branch of the Environn;ntal Systems Division.
16 l Virtually all of the contract FEMA evaluators at Argonne report 17 I i to him administratively, either directly or through an 18 entity.
19 Q So, a week or so though you saw your completed forms 20 so you could refresh your recollection for today's deposition, 21 is that correct?
f 22
- ACE 5EDERAL DORTERS, INC.
- r 3.c.3 X) Nanoemde Cy.nge 300 33646 w5 i
l l
^ i A That is correct. l 2l l 1
Q Do you still have those completed forms in your ,
3j l possession? l 4 l I. No, I do rot.
i 5
l Q Where are they now?
6! A They are with counsel.-
i 7 '
O Mr. Cumming?
O j A Yes, sir.
9l i 0 So, you have not seen your completed forus for 10 ; approximately the last week or so? -
i i
11 l A No, I would say for the last three days.
l i
ul Q You have seen those within the last week?
a l ,
A Yeah.
13 0 Mr. Saricks, will you take a moment to look through lwhatwehavemarkedasSaricksExhibit3. In the upper left 15 .
I
! hand corner there are certain objectives noted. They are 16 l 1 l Objectives 5, 6, 7, 8, 10, and 11, correct?
17 l A I seem to have -- let me see. Okay. Yes; -- I have 18 i two copies of 7. I was just curious, but I see it is for 19 '
- different functions. Yes, I have all of those.
20 Mr. Saricks, just to sae if we are on the same wave Q
21 '
lenth again. You mentioned to me that you thought the objectives 22 s
ACE-?EDERAL 3EPORTERS, ENC.
, = 347-3 00 Nanonwics Co.. nae MTM
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118 i
_s you had responsibility for based upon your review of Lane 2 !
Exhibit 3 were five objectives, Objectives 1, 5, 8, 10 and 11.
3 l These forms would indicate that perhaps you had responsibility 4 )
for reviewing objectives 5, 6, 7, 8, 10, and 11. '
5
, A Yes. I have to say I do recollect quite explicitly
'6 that I had a responsibility under Field 1. I think I may 7
have neglected to mention 6 and 7, because when I looked at 8 them it was obvious that in each case, due to problems in the I
9l field, I was unable to evaluate those ob 3ectives.
l 10 l Q Am I correct then, Mr. Saricks, that you now think 11 that your responsibility included Field Objectives 1, 5, 6, 7, i
12 8, 10, and 11, is that correct?
w-A Yes. I would concede that 6 and 7 should have been 13 i
! in there, but I think my answer was based on what I actually 14 '
l was able to evaluate. 6 and 7, I was not able to evaluate.
15 ,
O Let's look at Field Objective 6, which is page 2 16 !
j of Saricks Exhibit 3. Demonstrate that access control points 17 l l can be established and manned by Traffic Guides in a timely 18 i . .
manner.
19 That is the objective.
20 A Yes.
l 21 Q Now, you are telling me that you were unable to 22 observe that objective?
s ACE-FEDERAL lEPORTERS, NC.
i = ,4L3700 Nancomde Cm.Tage M3364&%
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i l
~ i A That is correct.
2
- Q Why is that?
3! '
A Because those Traffic Control Points were staffed 4
I during the period when I was still at the impediment site 5
! waiting for the response vehilce.
I l
6 i i Q Okay. Field Objective .7 is Demonstrate the 7
i ability to supply and administer potassium iodide once the 1
8 I, decision has been made to do so, and that is for the route i
l 9 lalertdrivers.
10 I And you are telling me that you were unable to 11 bserve -- well strike that question. Let me ask you, for 12 -
Field 7 I have two sheets; one for the impediment, and one s !
l for Route Alert Drivers. Which one were you unable to l
! evaluate?
14 i
! A Well, the impediment -- I cannot say I physically 15 I
observed the order to ingest K-I. It was reported to me by 16 l the driver that he had been told to do that prior to departure 17 l from the depot. I don't count that as an observation. '
18 -
In the other instance, there was no instruction i
19 ! to that driver to ingest K-I at the time he ran the route, 20 ' becau.se there was not release in progress.
21 I should point out that during the period of time 22 ACE-3EDERAL MFORTERS, UNC.
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j 120 l
l the route was being run, the general energency was declared, 2 !
j but he didn't get this information.
3 i l Q Should he have been given that information?
4l A The information would have come over the radio, l
l 5l ; WALK, but of course if he had turned on WALK he would have 6' "
l heard normal programming, and the only contact that he had 7 then with the staging area was by telephone. He had no radio.
8 Q Mr. Saricks, to try to save time in this deposition, 9 ,
I would like to ask you some questions about the pages that 10 make up the Saricks Exhibit 3, the critique forms.
11 If we can d it on a generic basis, I would like
~ to try that and see how it goes. With the exception of Field 2
- l l Objectives 6 and 7, Mr. Saricks, is it fair to say that you j 13 l j did evaluate the other objectives listed in Saricks Exhibit 3?
14 j j A Yes, it would be fair to say that.
15 O And to your recollection, did you in each case, for 16 l j each one of these pages of Saricks Exhibit. 3, comment in the 17 ! '
column headed, Commands and Recommendations section?
18 A Yes, s ir .
19 Q At the bottom of one of these forms , Mr. Saricks, l
i 20 l there is an indication that deficiencies are identified or l
21 ,
corrective actions are recommended. The evaluator is to write 22 -
I l
AG-rEDERAL REPORTERS, _NC. l
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I 121 l
_ __ __ I l on the following pages. Do you see that?
2 ,
4
, A Yes. .
3 )
Q Did yce ever do that in filling out these forms?
4 A Yes. Those pages are not part of the exhibit.
5 l
- O I will represent that is because they have not 6l been provided by counsel for FEMA. I l
7!
Do you recall which objectives you would have 8
written comments on the following page regarding deficiencies 9 or corrective actions recommended, for which objectives you ,
10 ! noted needed comments? {
I 11 A First of all, I was following the instructions l ' .
12 given here. If an objective was partly met, but I believe ss j 13 ! corrective action be necessary,.I so indicated.
H wever, I c uld n t, owing to this instruction, 14 indicate there was a deficiency. I indicated a need for 15 corrective action under Field 8, for route alerting drivers 16 due to this problem on command and control. Chain of command 17 l i ra ther . I did not indicate a problem on Field 8 for impediment 18 , !
evacuation. j 1 19
^
l I am sorry. For the first two under Field 8, there O
was no problem. It was on Traffic Control Points on Field 8 21 that I indicated a problem.
22 i 1
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Ae-FEDERAL 3HORTERS, INC.
, *02-M*.7"00
, Nanonwme Co .::sge 300-3M l
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^- i All right. Field 10, I also indicated a need for 2 !
corrective action regarding the adecuacy of the equipment 31 -
dispatched.
4 ,
I
- Field 11, there was no problem. The resources 5l l demonstrated were adequate to the purposes at that location.
I 6 !
Q Field 8 and Field 10 are the ones you re call actually 7
l having written recommendations for corrective actions?
l 8l A That is my recollection.
9 Q What about Field 5, the route alert driver demon-10 l )
stration?
11 l MS. MONAGHAN: Again, a continuing objection as sj 3 12 l to the relevance of the route alert driver issue, except to the 13 { extent that it may relate to training.
4 THE WITNESS: My recollection that I did indicate j that 45 minutes criterion was not met in this instance, but i the corrective action was recommended, and was simply to provide 16 ;
! additional driver for the route.
17 l I think that is understood, isn't it, that all I am 18 l discussing now is information that was put on these forms on 19 i the day following the exercise. There was no information entered 1 20 I on any of these forms by me on the day of the exercise. !
21 BY MR. MILLER: (Continuing) l 22 ! I
., 1 i
Ae-?EDERAL 3EPORTERS, _NC. ;
i 2234 700 Nanonwide Co. erase 100-33646d6
^
l t O You filled out these forms following the day of 2j the exercise?
3 i f A That is right.
l 4 l'
! Q Mr. Saricks if you will look at the first page 5l l regarding Field Objective 5, the Route Alert Drivers, we have 6 1 l discussed your observations of route alert drivers. Is there I
7 anything further you can tell me in response te question what 8
was observed with respect to this objective on the day of the 9 : exercise by you, other than what you indicated earlier today?
10 l A I believe my impression of what transpired is 11 i thorough. Again, to my knowledge only one route alert driver 12, j was dispatched from Patchoque, and I followed that driver.
J ! 1 13 Q What was your understanding of these points of i
review that lists some of these objectives. What were they?
i A These were the specific actions and responses that 15 l we were to be sensitive to and make note of as part of our 16 i evaluation.
17 So, in the first instance, for example, we wanted 18 to make sure the procedures were following a working system 13 with the specific OPIP. Secondly, simply to indicate where the 20 siren failure had occurred. I was satisfied that that had 21 occurred. Prompt dispatch of vehicles with public address 22 systems. I felt that given what had to be done during that perioc
.A CE-3EDERAL REPORTERS, INC.
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, l of time, ten minutes was an adequate response.
2 i And completion of route within forty-five minutes 3 .
I after LERO learns of siren failure. That was not achieved.
4 '
O Can you recall anything further, Mr. Saricks, 5
lregardingyourevaluationofthisFieldObjective5thanwhat 6
l you have discussed with me today?.
1 7i 1 A I think everything that I provided you in the I
8 ' O chronology is complete as I recollect. Can you be more 9l specific?
i 10 0 Well, is it fair to say if you had your notes on 11 the day of the exercise, or your completed critique forms 2j on the day af ter the exercise, that would help you recall s
Ior refresh your recollection regarding any matters regarding 13 . 1 i
Field Objective 5?
14 ) '
A I can certainly say with respect to my notes they 15 would not, because I do recall the times sp~ecifically that 16 ;
i are on that, and in fact that is all there is in my notes, 17 an entry of times of dispatch, times which he started the 18 route, time the route was completed, and a notation regarding 19 driver response on the K-I.
20 0 What about with respect to your completed critique 21 form? Is it fair to say your recollection could be refreshed 22
)
1 I
Ae-:?EDERAL :~UEPOR'1 HRS, .NC.
=.w.n 8--a- -~ !
I
0 i 125 I
__ __ __ l s ; by having those completed critique forms with you today in 2l
! response to my questions?
3l A I believe at this time it would not be enhanced by 4 I having them. Again, our instructions were to be as complete 5! as possible regarding discussion of these objectives, but also 6 !
I as concise as possible in discussing problem areas.
7! O So, you think you have told me today everything that I
8 you would have written on the comments and recommendations in 9 respone to Field Objective 5?
l 10 ; A I think I substantially covered everything that was 11 there.
0 And when you say, 'substantially covered everything 12 i ws that would have been there, ' is it possible that there would 13
! have been other points that would have been written by you, 14 1
! under the column Comments and Recommendations, that have not 15 l been discussed today?
16 A I suppose I would have to say it is possible. My 17 i recollection is just not pe rf e c t . What I have done is 18 reconstruct the situation in my mind, supported by my review 19 of the critique form, and I can at this time think of nothing 20 to supplement what we discussed.
21 Q Mr. Saricks, the conclusion at the end of the report 22 ACE-:?EDERAL 3EPORTERS, :NC.
, m.m.m s_ . -
i
___ i
% I in response to this Field Objective 5, we.s that the objective 2 j
) )waspartlymet?
3 A Yes.
4
! O Was that your conclusion?
5 I . '
I Yes, it was.
l A And identified the required corrective
) 6 I action.
I I 7 ' Do you know how many route alert drivers were at the Q
8 lPatchoguestagingareaduringthedayoftheexercise?
9l MS. MONAGHAN: Objection as to the relevance of the g 10 lissueofroutealertdrivers,howmanytherewereat
- the Patcho.
11 ! staging area. That is not at issue in this litigation.
l l 12 ; THE WIT!ESS: I do not know how many ware there. I
- v. l
! know that one was dispatched.
13 '
l BY MR. MILLER: (Continuing) 14 i i Q Do you know how many are called for under the LILCO 15 Plan to a at the Patchogue staging area?
15 1
! A No, I don't recollect at this time the exact number 17 that was supposed to be there.
I Q Does the number twenty sound right to you?
i 19 '
A It sounds like it could be right, yes.
20 0 Do you know who made the decision to dispatch only '
21 one route alert driver of the number that were at the Patchogue 22 l
l
- ACE-:?EDERAL 3EPORTERS, :NC.
32347-3 00 NanonmceCr. rase 300 336-o6 4
l 127 l
___ i m l staging area?
2 A The individual who was identified as the staging 3 li area coordinator, who had pointed c'It the route alert driver 4
to me, was the one who told him he would be the one that 5 ?
goes out.
i 6' i I observed no consideration of sending more than 7
one driver on this particular route.
8 You observed no consideration of that?
0 ,
9 A That is right.
10 l 0 Will you look at page 2, Mr. Saricks, of Saricks 11 l Exhibit 3, Field Objective 6. This is the objective which 12 y u say you were not able to observe, correct?
) !
! A That is correct.
13 0 Now, the field report has concluded that this 14 !
objective was partly met, is that correct?
15 A I don't know if they can make that statment at the 16 Patchogue staging area. Other staging areas the FEMA i
17 '
l evaluators were available to. go to these sites in advance of the 18 arrival of traffic guides. I was not in that situation.
19 f MR. MILLER: Let me mark this as Saricks Exhibit 4,
- +
20 some excerpts from the FEMA Report.
(X INDEX 21 l (The above referenced document 22 is marked Saricks Exhibit No. 4, s i for identification.)
l ACE-:?EDERAL 3EPORTERS, :~NC.
=. - s_ m -
128 s MR. CUMMING: It would be easier in the course 2
- of the deposition to just enter as an exhibit the Post 3
! Exercise Asses ment.
4l l MR. MILLER: Well, there are only certain pages 5
l I want to ask Mr. Saricks about.
I 6l ' What I am handing the court reporter are excerpts i
- 7. from the FEMA Report, specifically page Roman Numerals XVI, l
8 That is what XV, pages 60 through 70, and pages 129 to 132.
9
- we have marked as Saricks Exhibit No. 4.
10 BY MB. MILLER: (Continuing) l l ll Q Now, Mr. Saricks, I will represent to you that these 12 j are copies from the FEMA Report, the final FEMA Report, and these are the pages that relate specifically to the Patchogue staging 13 area, including the summary from the up-front section of the ;
14 l
, 1 1 Report, and the pages 60 to 70 are the pages from the report i 15 regarding the Patchogue stac,4 nct area, eid pages 129 to 132, are
! the pages that relate to the summary of deficiencies and correct-17 !
ive actions at the end of the report.
18 If you would look, Mr. Saricks, at Page 64, which 19 i is now marked Saricks Exhibit 4. That deals with Field 20
, Objective 6, the Patchogue staging area, and it states that the 21 ,
objective of demonstrating that access control points can be 22 established and staffed by Traffic Control Guides in a timely wav l .
ACE- ?EDERAL 3EPORhKS, INC.
x :.~,c .5 co ywas ca. m .. m-um
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129 I
s was partly met. Do you see that statement?
2 l
l A Yes.
3 l Q Do you agree with that statement?
4l '
A I am not in a position to disagree directly with 5!
that statement. I ras not the person to observe when they 6 i were dispatched from the staging area. I know that all was j 7 )
l fully staffed when I arrived at them, and my arrival at first j i
8
- location was roughly one o' clock and that location was there.
! )
9! Q The next sentence of the report says all nine TCPs 10 '
evaluated were fully staffed in a timely manner. I 11 Did you make any observations regarding the staffing l
"- 12 , f these.nine traffic control posts?
.)
A I mad a bservation that they were staffed.
3 O When you got there?
14 l
{
i A Yes.
15 '
O Now as to staffing in a timely manner, did you 16 make that observation?
17 A It was not possible for me to make that observation.
'S
^
Q Do you know if anyone did mIake such an observation?
19 A I don't have a recollection that it was done out l 20 !
j of this staging area.
i 21 0 So you are telling me, Mr. Saricks, that to your 22 knowledge there was no evaluation made as to the timeliness of
~
ACE-3EDERAL 3EPORTERS, .NC.
- n
. 347 3 00 Naneumce Ce.,=3p 300 376-66 4
- 130 i
1 m the staffincJ of the nine traffic control points out at Patchogue 2 i I
i staging area?
3 i MS. MONAGHAN: Objection. I don't think the witness 4
can answer a question like tha.t. You are asking him to 5 j i speculate.
6 l MR. MILLER: I am asking for his knowledge. That i
7 i .
was my questton.
]
8 THE WITNESS: In each case I did ask the traffic 9 control guides when they had arrived, and they gave me a time.
l 10 If it had been consistent with timely arrival, but again, that I
11 is their information. It is not my observation.
i i
7 12. Certainly I did not observe the staffing of all J ;
1 traffic Control points under FEMA ideal circumstances.
l BY MR. MILLER: (Continuing) 14 ;
I O So are you suggesting, Mr. Saricks, that this 15 statement about timeliness of staffing of these nine traffic 16 ,
control points,if based on anything, is based upon response 1
17 <
of the LERO traffic guides?
18 MS. MONAGHAN: Objection as to relevance.
19 ! MR. MILLER: Your objection is noted.
20 MS. MONAGHAN: It is appropriate to permit me to 21 make the objections on the record that I wish to make.
22 ,
MR. MILLER: I thought you said your objection was ACE-3EDERAL REPORTERS, INC.
"02
. M7-IZO Nancemce C.r..: rage 300 33&co4
l 131
___ j
^
as to relevance.
2 1
i Is there anything else?
3 ;
j MS. MONAGHAN: And as to the form of the question 4 '
also. We need to phrase these questions in terms of what 5l l Mr. Saricks has knowledge of, his own personal knowledge, and 6
the way these questions are being phrased has nothing to do 7
with what Mr. Saricks has personal knowledge about , and that is 8
all that he can testify to.
I 9
MR. MILLER: The objection is on the record.
I 10 , THE WITNESS: What is the question?
11 , BY MR. MILLER: (Continuing)
] 12 i 0 Let me rephrase -- I will repeat, o,r try to repeat.
13 l Is it fair to say that any evaluation made as to the timeliness i
74 l of the response -- timeliness of the staffing of the nine traffic control points from the Patchogue staging area was 1
based upon the response of the LERO traffic guides themselves?
16 i 1
A To my knowledge, that would be the only source 17 '
I of such information, yes.
18 ,
O Mr. Saricks, whatever information you had regarding 19 l i the issue of staffing of the traffic control posts, would 20 ithat information have been noted in your comments on your 21
! critique form, your completed critique forn, regarding Field 22 ,
Ae-:?EDERAL :DFORTERS, .NC.
l 22 3.c.3 00 Nacenwice Cr.asse 300 336oed6
132 R Objective 6? {
l 2
l A Yes, and in the conment s I tried to be as complete 3
\
j as possible about what I observed, and what transpired. j 4
Q Would such information had been reflected in your 5!
f personal notes from the day of the exercise?
6 A My recollection of my personal notes on the day 7 ! questions I put of the exercise is the responses to the l l
I 8 I to the traffic control personnel regarding their radio protective 9 ! measures and the . authorization issue, and I was satisfied 10 by their description of what they would do. I didn't see the 11 need to make any additional notations on that.
12 So, there would be no informatio n on my personal
' l 13 ,
n tes beyond the recording of the response to the questions. l 1
I O Mr. Saricks, look at page 3,please,of Saricks Exhibit j l
This is Field Objective 7, and it relates to route alert drivers.
16 Now this is the objective that was partly met, is 17 that correct?
13 A Yes.
19 Is that your conclusion?
0 20 A I did witness the distribution of potassium iodide 21 to this route alert driver at the staging area.
22 s
At-FEDERAL 3EPORTERS, INC.
3347-3"C0 Nanormce C.r..:3e 300 3 M
l 133 3 MS. MONAGHAN: As I noted before, I am going to 2 !
object to a line of questioning on route alerting, particularly 3 l
{
j to administration of K-I. There is no contention in this {
4 l l litigation that deals with this in any respect.
5 MR. MILLER: Me could save time if you would 6 i i just make a standing objection to any question as to route l
7I alert drivers. I understand you have an objection to it.
)
l 8
l MS. MONAGHAN: I think I have made a continuing i
9 objection, l
10 ; MR. MILLER: I know. But you keep repeating it.
1 11 l BY MR. MILLER: (Continuing)
~.
g Q Now, Mr. Saricks, if I remember correctly, this v
is the objective which you said earlier the route alert driver 13 '
I did not understand the procedure for authorization of use of 14 4 j the potassium iodide, is that correct?
15 A For this particular objective, and notice the way 16 it is stated, the ability to supply and administer K-I was l 17 4
demonstrated. But the issue regards the instruction to the --
13 or the knowledge of the instructions in the appropriate procedure 1
19 '
for the route alerting driver had regarding when he was to 20 ingest K-I. He had the K-I on his person during the route 21 alert trip, so it was available to him. He did not have the 22 precise information as to how he would receive instructions when j l
- ACE-PEDERAL :?GPORTERS, NC.
a 3r-97 3 00 5aconwwie Co.. rage 300 3M .
I
134 1
l !
__ _ _ i s l to take it.
1 2 l
3 t ll Q So you -- from the Patchogue staging area, to your knowledge, one route alert driver was interviewed regarding 4
potassium iodide, and that one person did not have the 5 l information, or a complete understanding of how that potassium 6I I iodide would be authorized to be -taken?
A That is a correct interpretation.
8 Q So, is it fair to say, Mr. Saricks, that when the l
9! FEMA Report concludes that this objective was partly met, that 10 that conclusion goes to a scope of emergency workers broader 11 l than just the route alert driver you interviewed?
12 j A Well, I was only to look at it in the context of the 13 person that I was to follow, the route alerting driver. And indeed, given the points of review you will note under here, l' K-I was available at the staging area, it was given to this 15
! route alerting driver, and he had it on his person as he 16 !
drove the route.
i 17 l Q Even though he didn't understand fully the procedures, 18 I you concluded that the objective was only partly met? l 19 A The ability to supply and administer K-I was 20 .
demonstrated.
21 Q So, literally the objective was complied with, but 22 i AG-3EDERAL 3EPORTERS,1NC.
, n.w.n 8 - ., -
135
! l you felt that there was not a complete understanding by the l 2 !
people you interviewed as to the procedure for taking potassiurt 3 l
- l. iodide?
4!
I A When he was authorized to take it, that is correct.
5!
! Q And that led you to conclude that the objective i
6 should be characterized as partly met, is that correct?
7 A Yes, sir.
O Now, Mr. Saricks, looking at Page 4 of Exhibit 3, O
l 9 ; that is the potassium iodide with respect to the traffic 10 impediment. That is the objective you were unable to observe 11 l during the exercise?
q A I am sorry. Field 7, Impediment to evacuation?
12 v' i .
l Q Right.
13 A I could not observe the administration of K-I. I l'
was inforned that the K-I had been taken -- he and his companion 15 l were instructed to take it prior to leaving the depot.
16 :
O And you were informed of that by the personnel 17 i at the impediment that you interviewed?
18 l ;
A Correct.
i I
19 Q Was your conclusion regarding Field Objective 7, l 20 with respect to the impediment, based upon anything over 21 than the response as to the question of consumption of potassium 22 Ae-:?EDERAL DORTERS, INC.
m .. , _ _ , -
eee i
- . - - - - , i w iodide?
2 A The equipment they had with them also included a 3
l simulated K-I container -- simulated K-I tablets, so that 4 .
I they also had them on their person, but they had in fact
- l 3 '
~
taken the K-I, and based on the fact -- you can generally get 6 i j
twelve hours protection from the. tablet, they would not have to 7
necessarily have another dose of K-I while in the field on this 8 response.
9l !
0 Could you look please at Page 5 of our Exhbit 3, 10 Mr. Saricks? This if Field Objective 8, which again is route 11 alert drivers.
12 Now, if I remembE correctly, in response to this ob-13
- jective, which was to demonstratethat the workers understood who can authorize exposure in excess of the general public protective action guidelines, some -- did the route alert driver 15 '
you interviewed understand this excess exposure amount?
16 A He understood the procedure as provided to him.
17 Tt was a slightfy'different chain of command from the one 18 regarding lead traffic -- he understood the one that was 19 l written for him.
20 0 Now, the field report on page 69, which is 21 Saricks Exhibit 4, indicates this objective was partly met, 22 is that correct?
An.w.n-3EDERAL lEPORTERS, :NC.
8-n -. -
i 137 I
A Yes.
2 ,
! O Is that based upon the response given to you in l l
3 'l l l your interviews of the traffic guides? I 4
A That is correct. !
l
> i .
j Q So, is it fair to say that the route alert driver 6
that you interviewed, and the personnel at the impediment, 7 l both performed satisfactorily in response to this objective?
1 8; A Yes, they did.
9! !
Q It was the traffic guides where there was a l
10 l problem?
i A Yes, sir.
11 l Q The traffic guides, Mr. Saricks, Page 7 of Saricks
- Exhibit 3, in evaluating that objective for the traffic guides, 13 i Field 8, did you look at anything other than whether or not 14 1
, they knew how to implement this procedure, OPIP 3.9.1,that L5
- is referenced here?
16 i A Of course, the statement of the objective is quite i
17
precise. That they understand who can authorize, so once they 13 indicated who their contact is they accept the authorization i
19 from, that essentially satisfies the objective, and that that 20 '
answer is consistent with what is in that OPIP.
21 , 50, my scope of questions on this issue did not go 22 s
ace-:?EDERAL REPORTERS, INC.
i MM7-3%0 Nanonwice C r. erase 300 336 /;6 6
g_g. ,
i i
s ! beyond this specific question.
2
- Q How did you determine, Mr. Saricks, whether an 3 i i objective should be characterized as partly met, or not met?
4l l For exareple, in this case you have two of nine 5 l l traffic control points do not --
i 6
MR. CUMMING: Objection. That goes to the l
l 7 .
, evaluation process.
3l MR. MILLI:R: Let me finish my question. In this i
9 l case, you have two of nine traffic control points that did not i
10 understand the chain of command for excess at.' theorization. Why is it that that led to a partly met conclusion, rather than 11 g a not met?
1 MR. CUMMING: Objection restated. The witness is 13 j instructed not to answer the question.
14 .
- MR. MILLER
- You're claiming privileges as to that 15 information?
16 l MR. CUMMING: Yes. Evaluation process.
~
I l
17 !
- You may be able to restate it to get around my objection. I l 18
^
have no objection to your trying to restate your question. j 19 BY MR. MILLER: (Continuing) 20 Q Well, my question goes to what led Mr. Saricks to )
21 draw conclusions about whether objectives were characterized as 22 1
1 ACE-rEDERAL .hPORTERS, ..NC.
%C 347 3700 Nanenwuie Ca. cage 300-3M
_ _ - - - _ _ . - _ _ _ _ _ _ _ _ - _ - _ - _ ~
l l
1
^
Set, partly met, satisfied, not satisfied. I can't restate my 2 .
l question to make it a different question. That is the goal of 3 ,
l
!my question.
4l l I want to know what Mr. Saricks based his conclusions 5l lupon in making conclusions about --
6 ,
I MR. CUMMING: He stated that for the record already. l 7
j MR. MILLER: I am talking specifically about his
! objective, Field 8. Is your instruction not to answer?
e 9
MR. CUMMING: My instructions are not to answer. j i
10 i BY MR. MILLER: (Continuing) 11 Q Mr. Saricks, looking please at page 8 of Saricks 12 Exhibit 3, this is the Field Objective 10, sample of resources 13 :t deal with impediments.
14 ! No$, page 65 of the FEMA Report concludes that
- t. t
,this obj ective was partly met. Do you see that?
A Yes.
16 i 0 Can you tell me, Mr. Saricks, why -- well, first of tall, was it your conclusion that this objective, Field Objective 13
.'10 for Patchogue,was to be rated as partly met?
19 -
MR. CUMMIMG: Go ahead and answer it.
20 THE WITNESS: Yes.
21 BY MR. MILLER: (Continuing) 22 i
1 1
Ac >--:?EDERAL : DOR'1 EMS, :NC. l J E
- A7 3 00 Nanonmca CJ.,: age M336 6616 l
}
140 )
^ : Q Now, tell me why it is that you made that 2 i i determination that this objective was partly met?
31
- A A sample of resources was presented. The resources 4 l l
i presented could have removed the impediment, but not in a 5l The sample of resources was incomplete with
- timely manner.
6 ,
l respect to the potential problem at that location, which may I
7 '
! have removed spilled gravel, but never ascertained.
i 8 i
, Q Is there anything else?
9 There was consistency with at least portions of A
I 10 these points of review. Now, again we were instructed regarding l
11 ! rerouting traffic that it was subject to a legal contention, 12 or legal issue at that point, and we would not necessarily i i .
bserve that rerouting occurring.
13 l .
I 14
- O Okay. Well, Mr. Saricks, the points of review l j under this objective , rerouting of traffic was not observed, l 15 l l and you don't know if it was performed by the LERO personnel, 16 .
! correct?
17 A That is correct.
18
, Q Appropriate equipment dispatched to deal with 19 obstruction. Your conclusion was that that was not met, 20 correct? Appropriate equipment was dispatched.
21 A I an going to have to dispute this idea of, l
22 Ate-:?EDERAL REPORTERS,1NC.
l E 347. FOO Nanoew.2 C.r.mg= K43 od6
! 141
~ ! ' appropriate.'
2l I I would say adequate equipment was not dispatched 3
to deal with the impediment in a timely fashion. The 4
equipment that was dispatched would have been able to remove 5
the defined impediment in the complete message, but not in
- 6. I a timely fashion. .
I 7l 0 My word, ' appropriate,' was the word on the form.
8 A Well, again that was my interpretation of what 9I that means.
10 0 And is it fair for me to say that in making your 11 l evaluation of this Field Objective 10, you did not take into s
y consideration the timeliness of the response?
! A I did not take it into consideration directly for 13 i i
evaluating the field performance.
14 11 l Q If you would have taken into consideration the 15 ! l timeliness of response, would your conclusion have been the 16 I i same?
17 l That is, that this objective was partly met?
18 '
A Again, the statement of the objective would have 19 lcompelledmetoat least acknowledge that there was a sample 20 ,
of resources demonstrated. There isn't anything in the 21 objective statement regarding time of deployment or time of 22 i A -5EDERAL 3EJORTERS, ENC.
2 347 7*00 Nanonwice Cmerage 300 D&%%
i 142 i
% i arrival at the site.
2 ,
I
- Q You read these objectives very literally, don't 3
I i you, Mr. Saricks?
4 A Well, I attempt to keep .y observations within 5
I the constraint. ,
l 6 l'
! O Mr. Saricks, let me.give you a hypothetical. There 7I is a traffic impediment that requires twelve tow trucks to 8 remove in a timely manner. One tow truck is sent to the 9l scene.
i 10 l This is your objective. Demonstrate a sample 11 l of resources.
i
^
12 W uld you conclude under that hypothetical that
! the objective was partly met?
3 i
i A If all of the information regarding the nature 14 1 of the impediment was available to the responding personnel, 15 i
\ 1 and they still only sent one tow truck, the answer would be, i 16 i l
no, that the objective was not met.
17 i i The difficulty I have here is that I do not believe 13 !
that the responding individual was in possession of all 19 l necessary information to determine what was an appropriate --
l 20 : sorry, an adequate sample of resources.
21 Q And even if it is because LERO itself was to blame 22
- ACE- ?EDERAL :D_ PORTERS, :NC.
E 347-7700 Nanoemde Cy =2g= 3C4336<%46
i I
~
l in not getting such information to the dispatch response 2 ;
I j team, that would make no difference in your judgment, is 3 i that correct?
4 A It would not be my call on that one. That would 5
be another evaluator's determinationthat a breakdown in 0
\
communications in LERO led to a failure to protect the public l
7 l 1
in some way.
8 i Now, indeed, if I had that responsibility, that i
I 9l would be my finding.
10 0, If you had what responsibility?
l l
11 A The responsibility to determine the cause of the J i
12 failure to respond to the site in a timely f ashion.
I Q okay. What you are telling me is if there was 13 ' t l
g an objective to demonstrate the ability to respond in a i
I timely fashion to the traffic impediment?
la, ,
1 j .
, A Yes.
16 l i i Q Your conclusion for this exercise at the Shoreham 17 l j plant would have been that objective would not have been met?
18 i A That is correct.
19 i j Q The last page of Saricks Exhibit 3, this deals 20 I with the sample of resources necessary to control access to f
21 ' >
an evacuated area by traffic guides.
22 i
l ACE-3EDERAL 3EPORitRS, TNC.
x.w.n 8_ ~ ~
i 144 l
~' Mr. Saricks, FEMA concluded that this objective was met, is that correct? If you would look at page 65 --
3 l
A Yes.
O Is it fair to say, Mr. Saricks, that in looking 5
j at this objective, Field Objective 11, that essentially you 6
were making an equipment check?.
7 A The equipment check was part of it. Part of it l
3 was a procedural check as well, and a logistics check.
9f Q What was the procedural?
l 10 { A In some cases, the only resources would be the i
11 traffic guide, him or herself with directing cones or 12 some other equipment. So, it was the positioning of that driver and -- the guide, and the procedures that he or she 13 would follow was irportant in the determination.
74 0 If I understand you, your conclusions were then 13_ l -
also based on not just equipment, but answers given during 16 i l your interview about where cones would be placed, or where a 17 l vehicle would be positioned, and things of that sort?
l 18 ,
- A Where the personnel would be, yes. The knowledge 19 i of how to run that particular location.
l 20 MR. MILLER: Mr. Cumming, at this time , I am l
21 ' going to request formally again on the record that you produce 22 l I
i i
AG-3EDERAL REPORTERS, :NC.
, ::32-3C 3'00 Nnionmde Co;.me 300 336/iA6 i
! 145 i
i i
j
, the completed versions of the critique forms filled out by Mr.
2 <
Saricks on the day of the exercise, which we have marked 3
as Saricks Exhibit --
4
, MR. CUMMING: Once again I will object on the 5 l record to anything produced subsequent to the close of the 6
l exercise.
I I would like an explanation though, and it doesn't 0 have to be on the record,later on of exactly the nature of l
9 your request that was answered by previous FEMA counsel l
l 10 i with respect to these documents.
11 l We don't need to get into that now.
MR. MILLER: No. What I am requesting is, we 12 l have marked for identification today Saricks Exhibit 3, which 13 is the critiqua forms that we have been provided by you, which 4 l I
, l are the redacted versions of that form. We have established 15 l i from Mr. Saricks that there are completed versions which 16 contain his comments.
j 17 i l MR. CUMMING: That is correct. The testimony 18 f was they were completed post-exercise, i
19 MR. MILLER: That is right. The day following the 20 '
exercise. 1 71
'~
We are objecting to that production.
l MR. CUMMING:
{
1 22 i
ace-:?EDERAL D_POR~1tRS, lNC.
- z.m.m s__m, -
l 146 l I i i i
___ ; I
! MR. MILLER: On the basis of what? l 2l l j MR. CUMMINGS: Deliberative process.
3 l MR. MILLER: Are you objecting on the basis that 4
l it is the day after the exercise? j l
5 l MR. CUMMING: Yes. In fact that they reflect l
6
! something other than the actual events of the day of the 1
7 I . i exercise. ;
o 8
! MR. MILLER: I am also requesting production of 1
l 9
l the notes referred to by Mr. Saricks during the course of l 10 ! this deposition, notes that were taken on the day of the
! exercise, and I would ask for that production forthwith.
11 l
l 17, Do you have an objection to that?
l
, 13 { MR. CUMMING: Actually, I have no objection to i
3 g that.
MR. MILLER: Are those notes here, available to you right now?
l . MR. C t24 MING: Yes, sir.
i 17 !
MR. MILLER: Could I please have those.
18 MR. CUMMING: You can make copies for other 19 ,
counsel.
i 20 (Mr. Cumming hands documents to Mr. Miller.)
l 21 ;
BY MR. MILLER: .(Continuing) 22 ,
ace-:?EDERAL 3EPORTERS, INC.
"02- M 700 Nanonwide Co...24e M3364W
147 d
i I
i l Q Mr. Saricks, earlier we marked as an exhibit 2 ;
I think that was marked as l l the exercise message forms.
3 '
Saricks Exhibit 1. The one dealing with the traffic 4
impediment.
5 A Okay.
6 l Q Do you have that in. front of you, sir.
I 7 '
A Yes. The message.
8 Now, on Page 2 of Saricks Exhibit 1, at the Q
9 bottom of the page, there is noted, Road crew unit evaluated l
10 at the field location, and then there is a space for the 11 field evaluator to sign off, and there is a twelve-forty-i 12 five noted.
}
! Is that you that would have been the evaluator?
13 I i A Yes, that would have been me.
14 l i l Q Do you recall signing this form?
15 l l A I do not specifically recall signing this form.
16 0 You see the column headed, Comments?
17 j A Yes.
18 i Q Do you recall writing in any comments with respect 19 to the road crew unit evaluated at the field location for l
20 Patchogue?
l 21 i A I don't have any recollection of putting any -
22 ,
1 l t 1
AG-3EDERAL 3EPORTERS, ENC. l l E34.r00 Nanonwide O. case 800 3364sd6
j 148 s i comments. 4 2 i j i
- Q So you just don't recall one way or the other 3l l whether you filled out the form?
4 1
\'
A That is right.
5 .
Q Do you recall even seeing this form on the day l
I 6
l of the exercise?
I 7 '
A My recollection of material on this form only 8 extends to what ends at the end of the message.
9 MR. CUMMING: He has already testified with l 10 i respect to this form of his knowledge.
i i
11 MR. MILLER: Mr. Cwmming, I will request at this 12 time production by FEMA of the completed unredacted message j 13 j f rm for the gravel truck impediment.
l I
Do you care to make any response?
14 i l MR. CUMMING: Counsel will diligently search 15 l
for the original form, unredacted. I do not presently have l 16 l l that form with me.
l 17 l l MR. MILLER: Let's mark as Saricks Exhibit 5 18 two documents, each two pages.
19 (Above referenced document
< Index 20 I is marked Saricks Exhibit No. 5 I
21 i for identification.)
22 l
! Ath .?EDERAL 3EPORTERS, NC.
- m.m . s- cm.m. mm
i 149
-_ i MR. CUMMING: While people are reviewing the 2 fl l document I might state on the record that counsel will 3
review the Board's Order of November 19, 1986, and determine 4
whether it requires any modification with respect to the 5 ;
Government's position of production, or answering interroga-l 6 :
I tories.
l 7 ' '
I received that order this morning at the law l u 4
l 8 firm of Kirkpatrick and Lockhart, and there h=.d not been 1
9 prior receipt of that Order.
l 1,
10 l MR. MILLER: And the firm of Kirkpatrick and I'
11 Lockhart was pleased to cive it to Mr. Cumming.
m gl ~'
BY MR. MILLER: (Continuing)
Q bir. Saricks, we have marked as Saricks Exhibit 5 l i l l two two-page documents. The first is entitled at the top:
lA l i
! This is an Exercise - Shoreham Exercise, Route Alerting 15 l l
Message (Simulated Siren Failure); and the next two pages 16 !
I are entitled at the top: Shoreham Exercise, Traffic Control 1
17 <
Point Message.
18 A I am sorry. I have this one -- sorry -- these 19 !
^
are two together?
20 ! O That is correct. Do you recognize these two 21 ; exercise message forms, Mr. Saricks?
22 .
ACE-:?EDERAL 3EPORTERS, INC.
a E*A 7-3~00 Nanonwxie Ca.e: age 800-3* M
150 1
, l l
l
^ l A I recognize this one.
2l 0 Which one are you referring to?
A The second one regarding interview times for 4
traffic control guides.
5 !
4-B l 0 The first form regarding route alert drivers you 6
do not recognize?
7I A I do not recollect.
O Let's look first at the Route Alert message, Mr.
9l Saricks.
10 A All right.
11 0 It has various points at which the exercise was going to evaluate the simulated ciren failure in Route 12 l i
13 l Alert driver, do you see that?
14 l A ves.
O And it has evaluator sign off column, and then 15 .
l l there is an area there for the evaluator of that to sign 16 !
off.
17 A Yes.
18 l
. O Is it your testimony that you do not recall {
\
19 whether you signed off on this exercise form?
20 l .
l A I do not recall affixing my signature in those l
21 i j locations. However, the information which is represented here 22 i
I ACE-rEDERAL .lEPORTERS, ..NC.
_ ___ __ i
151 i
l 2 l is substantially accurate, to my recollection.
l MS. MONAGHAN: For the record, I am just going
! to enter an objection.
4 !
BY MR. MILLER: (Continuing) 5 -
! O Do you recall, Mr. Saricks, if you entered the 6l times noted at the bottom of the first page of Saricks 7! '
Exhibit 5? There are two times that are noted. Eight-forty, l
8 i i and nine-fifty.
I 9l i A I recognize that as my hand, yes.
l 10
- 0 You just don't recall having done it?
l 11 A That is righ .
12 Q- Is it your understanding, Mr. Saricks, from looking 13 at this form regarding route alert drivers that the route 14 ! was completed at approximately nine-fifty a.m?
! A Yes.
15 l
y a se n page, please? Have 16 you ever seen this form before?
17 {
A No, I have not seen this form.
18 1
0 Do you see the statement in the middle of the 19 l l
page. There is a redacted name, apparently, and it has ten-20 I
- twenty-one. Has complted his route alerting assignment.
21 l At the top, it refers to Patchogue - Route Alerting.
22 Ac 1-?EDERAL lEPORTERS, :NC.
E-34~-3700 Nanonwice C r.4 rage En3364o#2
153 A Y***
2 l
! Q Between the two times, ten-twenty-one and nine-3 ii fifty, which do you recall as the correct time as the 4
completion of the route alert at the Patchogue staging 5 j i area?
6 i
! A Okay. The information contained on the second i
7 '
> sheet would not have been available to anyone besides myself l
8 i
- until I phoned in that I had relocated to my next assignment.
9 So, my conjecture is that this information is i
1 \
10 l based on my notification that I had completed the assignment.
11 Q Based on your telephone call?
t l 12 i A Yes. And there was a delay, obviously. I didn't
.: i 13 I make that notification until I got to the next location.
0 Now, looking at the second two pages that 14
- * * " " ** * *9" " **# * '
- l 15 i
as part of Saricks Exhibit 5.
I A Yes.
17 !
O Is this your handwriting regarding the traffic 18 l control post numbers, and the time interviewed?
I 19 i l A Yes, I do recollect making these entries.
20 :
Q And these times reflect the beginning or the end 21 I Do you recall?
of the interview sessions?
22 1
1 Ae-:?EDERAL REPOR'1 HRS, NC.
j N 347-R00 NanonsucCr.,=2se 300-33 W
~
g I
AS 00 Nanonmc4 C.7..-nge 304336-66 4
j 158 i 1
I
I A No. I was not a team leader, so I was not required 2!
l to attend that meeting.
3I O Did you attend the exit meeting for the controllers 4 I . i
' I and simulators?
5
, A No, I did not. I filled neither one of those roles.
' I 6
0 Okay. Look at page .7 of the exhibit. Eight-thirty I
7 in the morning until two in the afternoon?
8 A Yes.
9 0 Completion of the exercise e~ valuation forms by 10 the evaluators. Is that the exercise critique forms that i 11 l that is referring to?
12 A. That is correct.
l Q Did you spend your time on the morning of the 14th 73 I completing the critique forms as indicated here?
14 i l
1 A Yes, the morning and probably part of the afternoon 15 :
I as well.
16 i
! Q I know I have asked this , and I will apologize, 17 {
i but your form, once completed, was given to whom?
18 ! The person who at that time was Acting Team Leader, A
19 who was Sue Ann Curtis.
20 -
Did you attend the briefing of LILCO at three o'cloc Q
21 that afternoon?
I 22 l J
i
]
Asm 7.rtoo
-rEDERAL MPORTERS, .NC.
sanonwice co. 3:e soo.33f-i646
i lov l
__ __. __. i s I A Yes.
2l Q Did you participate at that meeting in any way?
A No, I don't believe that my input was requested.
4 There was a mention of the impediment situation at the 5
meeting, but my specific comments or critique was not 6
solicited.
7 Q Did you take any notes at that meeting?
8 A liy recollection is that I did not.
9 Q Do you recall who spoke at that meeting?
10 A "o, I do not.
)
11 l 0 There is an indication Mr. Saricks, that evaluators 12 l were to.be released to leave once their critique forms were turned in to the team leaders.
1, l
Is that, indeed, when you left to go back to i Illinois?
l 15 l A The team leader had to be satisfied with the 16 !
comment. I was released as soon as my forms were examined, 17 i
and it was determined that there was an adequate amount of 18 I '
information on them, and that it was clearly orovided.
19 i
- Q Was that on February the 14th?
20 A Yes, it was.
21 Q Do you recall Locut when that was?
22 1
ACE-FEDERAL REPORTERS, 7_NC.
=.m.m .,_._ e. ~~
1 lbu l
l i
s l A I would say it wasn't much before five o' clock.
2!
j Probably about the time it says here.
3l MR. MILLER: Let's mark as Saricks Exhibit 6 4 i l a four page document, the front and cover which says:
5 Patchogue Controller Logs'. And it is stamped with the numbers 60000286 at the bottom of the pa.ge.
l 7! l (The above referenced document l
l: Index 8: isbarkedSaricksExhibitNo. 6, 9l for identification.)
l 10 l THE WITNESS: Okay.
BY MR. MILLER: (Continuing) 11 I
! Q Mr. Saricks, have you ever see:i this document 17 .
l before?
l 13 i l A No, I have not.
14 i l 0 Do you know who the Patchogue Controller was?
15 ! i A The Patchogue Controller was never identified.
16 O Will you look at page 3 of this document, Mr.
17 Saricks, there is --
13 MS. MONAGHAN: Just for clarification on the 19 record, are these consecutive pages from the logs? We have 20 no idea.
21 BY MR. MILLER: (Continuing) l l 22 1
l l
Ae-FEDEFAL :REPOR1ERS, NC.
l E 347-3700 Nanonwide Ca.mge 300 3h
! 161 O On page 3 of the exhibit, Mr. Saricks, there 2 '.
I i is a notation, Overall Impression, and there is some redacted 3 i l material.
4l Do you see that?
5 i A Yes.
6 0 Is it fair to say you have no information regarding 7
what overall impressions the Patchogue Controller would have 8
made?
9l !
A No. I didn't confer with the Patchogue Controller 10 on this.
11 ; O So, you don't know what his overall impressions l 12 l would have been?
I A No.
13 l MR. MILLER: Mr> Cumming, I am sure we have l 14-l requested before, but we will request again, the unredacted version of this Log, which from all indications was prepared on the day of the exercise.
17 i MR. CUMMING: Counsel will diligently search 18 ,
for the unredacted forms.
19
- BY MR. MILLER: (Continuing)
'O
^
Q Mr. Saricks, did you have any involvement in the 2^' '
drafting of FEMA Report? .
22 i
\ i
\ l A -3EDERAL 3EPORTERS, INC.
E 347-I"00 Nanonmce C.r...2;c 300 3h 1 l
162 i
s A No.
2 i
- Q Did you review the FEMA Report before it was 3 ;
j put into final?
4 A Yes, I had the opportunity to review the report, 5!
l specifically to sections pertaining to my involvement.
6 l 0 When was that review conducted?
i 7 i 1 A I believe there were phases of review. The l
I 8 first review of a draft was some time in March, again I l
i 9 believe either April or May.
i 10 ! O Who asked you to conduct the review?
i 11 ! MS. MONAGHAN: I object on the basis of the i
12 ' relevance of that inquiry.
_- j THE WITNESS: I was asked to review the material 13 by Ed Tanzman. )
14 ,
BY MR. MILLER: (Continuing)
Q When you conducted your review of the FEMA draft report, Mr. Saricks, did you indicate any changes to be made j 17 l l 4 to the draft report?
18 i MR. CUMMING: Objection. That is privileged l 19 information. l
!l 20 Are you instructing the witness not MR. MILLER:
t 21 to ansver?
22 ,
J Ae-FEDERAL 3EPORTERS, ENC.
l 3 -347-U DO Neonwid: Co ...2ge 300-336-66.%
l 163 2
- MR. CUMMING: Instructing the witness not to answer.
2l
- MR. MILLER
- And the basis for your objection, 3l l Mr. Camming?
4[
! MR. CUMMING: Deliberative process.
5 !
) BY MR. MILLER: (Continuing) 6' fi Q Mr. Saricks, other than your reviewing -- how 7
many times did you review drafts of the FEMA Report, do you 8 ' recall?
9 A I recall that I was given two opportunities to
- 1 10 ) review successive versions. It may have been more than that, 11 but I recall two opportunities.
12 l Q. Do you recall any comments you made in your l review of the draft reports were taken into account in the final FEMA Report?
A Could you restate that a little? You are asking --
15 l Q I am asking you if any comments you would have 16 l i made in reviewing the draf t FEMA Report were actually taken '
17 ,
i into account in the final FEMA Report?
18 i A I was satisfied that my reactions or comments or )
l'-
whatever there were to the draft materials were carried forward i 20 in the final report.
21 l Q And reflected in the final report? l l
i 22
{
e I i
l l
AG-3EDERAL REPORTERS, TNC.
- . m.m.m s__ - -
I l@6 )
i i
, A Yes. Again, I am not entirely sure how many or i 2 I i
l how substantive those comments were. I think they were 3!
i relatively minor.
i 4 j i Q Is there anything in writing that you prepared 5I .
l to reflect your comments to the draf t FEMA Report?
6 l A If anything exists,.it would be my marginal I
l notation and mark-up of a copy of the draft that was provided i
8 I to me.
9I O Uho would have that document now?
l 10 l A I don't know who would have it now. I think that i material was returned to Region II. I 11 i
MR. MELLER: Mr. Cumming, we would request 12 l '
a ! l l production of the --
13 '
i MR. CUMMIMG: Counsel will diligently search 14 '
l for mark-up drafts to determine whether they should be 15
- objected to. j 16 i If not, we will so release them.
17 l l BY MR. MILLER: (Continuing) 18 I Q Mr. Saricks, did you observe any simulated ;
t
'9
~ '
notification of the deaf during the exercise?
20 t MS. MONAGHAM: Objection.
21 MR. CUMMING: Objection, based on relevance.
22
.)
AG-3EDERAL MFORTERS, INC.
j E347-3~00 Nanonwula Co.. age M 33 M 6 4
i 165
-- l s
THE WITNESS: Should I answer it?
2 4 -
MS. MONAGHAN: There is no contention in the 3 !
litigation based on notification of the deaf. I have also 4
a relevant objection.
)
5!
MR. MILLER: It is a route alert driving function, 6~ i and that is the basis of why I am asking the question. I
{
7 ! have noted the objection, and the witness can answer, I O
assume.
l 9 j MR. CUMMING: The witness may answer the question.
4 10 j THE WITNESS: Were specific provisions made by 11 l the route alert driver to notify the deaf, is that the i
question?
12 l i
! BY MR. MILLER: (Continuing) 13 i 0 I am asking you if you observed any route alert 1.4-l
! driver performing any deaf notification function on the 15 i
- date of the exercise?
16 l A None that could be expressly identified as deaf i
17 notification functions, no.
i 18 Q Do you know if LERO demonstrated deaf notification i
l"o -
functions on the day of the exercise?
20 '
A I do not.
21 MR. CUMMING: Can you approximate how much more 22 ACE-3EDERAL 3EPORTERS, :NC.
x.w.- 8.- - u - -
j 166 i
I
.s l time you have?
2 !
MR. MILLER: I am almost through.
I 3 'i BY MR. MILLER: (Continuing) 4
! Q Mr. Saricks, is it true that during the exercise, 5
only one traffic guide out of fourteen interviewed in the l
Patchogue staging area knew the, location of the Nassau 1
7 Coliseum Reception Center?
l 8 A That was my observation. Oh, excuse me. Would I
I 9! you restate that question, please? Knew the location of the )
i Nassau County staging center?
10 f l V l Q Knew the location of the Nassau Coliseum Reception 11 : i Center?
~' 12 ; ]
t i A I am sorrv, tha+. was not the question which I J
)
~
13 1 asked.
14 j
- Q What was your question?
15 I A My question was: Where would you send these l l 16 l individuals? They did not know, they did not provide an 17 accurate answer as to where to send them.
18 They may well have known the location of the 1 19 Nassau Coliseum Center, but didn' t know that that is where 1
I 20 '
the evacuees were to be routed.
i 21 - , Q The traffic guides you interviewed were unable to 22 I
\
l 1.
ACE-rEDERAL REPOR1hKS, __NC. '
3I2-M7-T'00 Nanonmde Ce.nage 300 3h
167 1
' i identify the reception center designated by the LILCO Plan, 2 l
(
! is that correct?
3l i, A That is the case, yes.
4j Q Is it fair to say, Mr. Saricks, that during the 1
5 j i l
exercise, traffic guides observed and evaluated by you were 6 1 l not aware of the chain of command for authorization of i I 4
7 i
- exposures in excess of the general public PAGs, Protective 8
Adien Guidelines?
9 A It would only be fair to say that two individuals, I i
10 at two separate traffic control points, indicated that they l l
11 : might question the authorization to exceed from the lead l
l 12 l traffic, guide, and would request verification from a higher l l y3 ; authority.
g l 0 Is it fair to say that during the exercise the l l triffic guides observed and evaluated by you were not aware j that exposure in excess of the general public protective action guidelines would be a voluntary act on their part?
1.7 A No. In fact, it was clear to me that they all 18 knew the forms they had signed represented a voluntary act 19 i on their part.
l 20 I
Q Did you ask that question during the exercise? I i
91 i
A I did ask if they had signed the form, and 1
22 '
I also asked if they were aware prior to signing the form l
l s
ACE-3EDERAL 3EPORTERS, TNC.
i m-347-3700 Nanonwide Ca... -age SC4 3 M coao l j
I, 168 i
__ __ __ j
, if they had any known iodine sensitivity, and they were all, 2 l l
accurately or not, confident that they had no such sensitivity.
3 j l Q Mr. Saricks, have you seen any of the projections 4
involved in this proceeding, tre Shoreham proceeding on the 5 i exercise, by the State of New York, the County of Suffolk, b
6 i l or Town of Southampton?
I 7 A Yes, I have had an opportunity to look at the 1
8l most recent, or revised version, of the contention.
9 f Q Have you seen LILCO's copy of it?
I presume so. If I have seen anything specifically 10 l !
A identified as State of New York, I didn't recognize it as such.
11 12 .
Q Y u have seen the LILCO version?
~
A Okay.
13 Q It is a little bit different than our version.
14 l
! A Okay.
15 i O Let me ask you if you would be in a position to 16 ,
I comment upon the respective merits of any, or all, of those 17 contentions at this time?
18 l MS. MONAGHAN: Objection. This witness is not 19 qualified to answer that question.
20 MR. CUMMING: Objection based on competency. I 21 '
THE WITMESS: No, I really don't feel confident 22 AG-:?EDERAL 3EPORTERS, INC.
d 147-r00 Nanouwide C.r.. rage 300-336 6 6
l 169 h
~ ! that I can say one way or another what those are.
2 !
l l BY MR. MILLER: (Continuing) 3 Q Have you had any involvement with the LILCO 4
Plan for Shoreham since the exercise, or let's say since your i
5 !
{ review of the Post Exercise Assessment Report?
6 :
MS. MONAGEAN: Objection as to the form of the 7l : question; it is vague.
I 8
I BY MR. MILLER: (Continuing) i
! l 9 Q Have you had any involvement, Mr. Saricks, with 10 any revision of the LILCO Plan subsequent to Revision Six, l 11 '
which was the exercise of February 13th,1986?
1
^
12 j MS. MONAGEAN: Objection as to form of the 1 o*'
question. It is vague.
13 ,
l THE WITNESS: Well, I can answer, no. I have 14 i, i had no involvement with any activity or document pertaining f to the Shoreham situation since my review of the final draf t 16 of the exercise report.
17 i I ; MR. MILLER: Mr. Cumming, this will complete my 18 .
questions of the witness. I will note for the record that 19 i
, we may need to recall Mr. Saricks if any of the documents 20 >
that have been withheld by FEMA are subsequently reduced 21 which would indicate a need.
22 ACE-:?EDERAL lEPORTERS, ::NC.
m2.s7-3too sanenwsce co.aase sconwee
i 1
l l
! MR. CUMMING: FEMA counsel notes for the record 2
that we don't waive the right to signature. We would like the 3 ' >
witness to review his transcript.
4 MS. MONAGHAN: We have a few questions, Mr.
5 Saricks.
6 L EXAMINATION Index l 7 BY MS. MONAGHAM:
8 Q Mr. Saricks, in the context of interviewing 9 traffic guides, in your interview of the day of the exercise, 1
did you ask the traffi'c guides if they knew where people who
~
10 l l
11 l were evacuating from the emergency planning zone, should g : report?
l' l~ A Yes. That is substantially the way in which I l '
framed the question.
14 l
~
Q Do you recall what their response was to that 15 l question?
16 i j A Except for the one instance in which the individual 17 l l responded the Nassau County Coliseum, the answers were either 18
~ i they did not know, or in the one instance the answer was 19 they would send them to the contamination facility at Brentwood.
l 20 0 In the course of your interviews with the traffic 21 ! guides, did you ask them whether they knew where the reception 22 AG-3EDERAL REPORTERS, :NC. l 1 lr2 347 7700 Natenwide Ca'.aage 300 336 6646 j
2,2 f
l i
_l
, ! center was?
2 '
I A I am not certain that that is the w'ay I framed 3
the question.
4 i Q Let's discuss the gravel truck impediment that 5 .
you discussed with Mr. Miller earlier. I believe that you 6
stated that you relocated on two occasions. Is that a 7 correct recharacterization of your testimony?
8 A Yes. For a period of approximately ten minutes 9 I went to a location in full view of the impediment site, 10 ! hoping that the LERO response team would spot me better. When I
that did not occur, I then returned to the parking lot.
11 !
j ._ 12 Q. Was the parking lot in which you spent most of 1 - 1 l
the time while you were waiting for the appropriate vehicles 13
- to reach the impediment site, in view of the impediment site?
14 1 l MR. MILLER: Asked and answered.
15 i
, l THE WITNESS: I did provide that information 16 earlier.
17 BY MS. MONAGHAN: (Continuing) 18 Q You can go ahead and answer.
t 19 .
Okay. The specific Location which was supposedly j A 20 about fifty yards north of the intersection, would have been 21 '
just beyond -- a building cut off the line of sight to that 22 )
i s . 1 l
a % i
! ACE-rEDERAL REPORTERS, INC. I
- adm3 oo sanonw w c.r.saec m3m
I .L / /.
I i
~ specific location.
2 I was in view from the corner of the intersection 3
Itself, however.
4 Q In connection with the gravel truck impediment, 5
when you asked the driver'and his companion of the vehicle 6 i I which then arrived to clear the , impediment, how long did it l
7
~
take them to remove the truck and other vehicles, which they 8l were not aware of when they came to the intersection, but which 9 ;
you then apprised them of were there, did you ask whether they l would call in for additional equipment?
10 j 11 lI MR. MILLER: Asked and answered. Objection to g form.
BY MS. MONAGHAN: (Continuing) 13 Q Mr. Saricks, did you ask the driver of the vehicle 14 which came to the gravel truck impediment whether he would 15 [
l call in for additional equipment?
16 l j A I think the way I asked the question is: Well, you
[
17 l were not informed about other vehicles. If there were other 18[l i vehicles here, what would you do?
1' 19 I believe, again, his response was that it would
{
i 20 take us thirty minutes to clear the impediment, as opposed to 21 his origina), esti' mate of ten minutes. l 22 C Mr. Saricks, in connection with the gravel truck l
. l i
. Lt- EDERAL 3EPORTERS,7_NC.
- i. ,
. - .n -- _
Aia j
i i
l impediment, was rerouting one cf your assigned tasks to 2
observe?
3 A On the points of review it was specifically noted 4
that traffic routing as a function to be performed was under 5
some sort of legal, if not proscription, then it was an issue, 6 ,
l and that, in fact, it would not.necessarily be known until the I
7 day of the exercise whether route alerting.would be seen.
a 8 j *I made a note of the fact on my evaluation sheet i
9 the following day that rerouting. wts not demonstrated at that 10 location, but it is not included in my finding regarding that 11 l site because of the nature of the legal issue that had been 1
I identified earl.ier.
s '
12.
l
~5-A 0 On the day of the exercise, did you talk to 13 i traffic guides in the vicinity of the gravel truck impediment 14 i i j and ask them if they had received instructions to reroute 15 i i traffic?
16 j j A No. I did approach traffic guides. I didn't 17 !
- know that they were tP ~ ~e. as traffic guides. I did notice 18 l the LERO identification on the aerial. It was probably forty
^9 1 !
minutes or more after I had arrived at the site, and I was j
20 curious why no response had yet been exhibited. I asked the l
21 individuals if they were there in connection with a traffic 22 l
/ .
i ACE-3EDERAL REPORTERS,1NC.
i "C2-W-TOO
. Nanon*xte Cr.c4e 30L2 3M o6d6
. o. -
l I
I s impediment, and they said they had no knowledge of a traffic
\
impediment.
3 MS. MONAGHAM: Thank you. I have no further 4
questions.
5l EXAMINATION
' Index 6
I BY MR. PIRFO:
7 Mr. Saricks, my name is Russ Pirfo. I apologize O
8 for not having the pleasure of meeting you earlier, and maybe 9j Mr. Cumming explained to you why it was. I just have a couple i
of questions. I represent the NRC Staff.
10 l 11 This person that accompanied you as an observer i
Did he only 12 l I
in your. rental car, clear up one thing for me.
l a company you for the fifty-one minutes, I believe you said 13 l it was, while you followed the route alert driver, or was 1.4 I\
l he with you the whole day?
15 ! ,
A He was with me the e.ntire day.
16 !
O Did he ask you any questions about your evaluation 17 l l I during the course of the day? a 18 l A No. l l
r 19 l Q Did he talk to any of the traffic guides during the j 4
l !
l l
20 l
course of the day that you observed?
21 A My recollection is he had no discussions whatsoever l
22 ,
l l Ae-:?EDERAL . REPORTERS, :'NC. _
i 3::-347-3700 Nanonwuns Ce,: rase 300 L W ode
--_ i
.s l with LERO personnel at the site.
2 Q So, he didn't talk to the route alert driver either 3
Did he give you directions in any form to get to particular 4
places?
5 l That was' entirely my responsibility.
A No.
6 Q Is it possible he was a member of the NRC Staff?
7l NRC personnel? Is that at all likely?
8 A No, I think that is highly unlikely. His presence 9 and demeanor struck me as someone who was a trainee, or 10 whatever, who had maybe no experience, whatsoever with the LERO plan. He was simply along to see how the operation 11 l
i was being conducted.
- p. l
! Q Did his presence in any way affect or inhibit ycur 13 ! -
i evaluation of the exercise?
14 A None whatsoever.
15
! MR. FIRFO: Thank you. That is all I have.
16 l i MR. CUMMING: Are there any further questions 17 l l
that Intervener would like to ask?
18 '
MR. MILLER: No further questions. We would 19 like to thank you very much for your time today.
I 20 ! THE WITNESS: Thank you.
21 j 22 I
- ACE-:?EDERAL REPORTERS, INC.
l M -347-T!DO Namormce Ca.. rase 300-33m
i l 176 i
__ _ _ i
^ (Whereupon, at 1:27 p.m., the taking of the 2 :
l l deposition was concluded.)
3l 4
5 6 CHRISTOPHER L. SARICKS 7
8 1
9 1
10 11 I 1 u1 i l l
13 14 I 1
15 l ,
16 i l
l 17 l l
18 i 19 l l
20 21 22 :
- l l
- Ae-
- ?EDERAL REPORTERS, :INC.
.- 8.- u ,. n-
LII i
i l
CERTIFICATE OF NOTARY PUBLIC 2
3 I, Garrett J. Walsh, Jr., the officer before whom 4 the foregoing deposition was taken, pages 1 through 176, 5 do hereby certify that the witness whose testimony appears 6 i I in the foregoing deposition was duly sworn by me; that the 7
testimony of-said witness was taken by me and thereafter reduced to typewriting by me or under my direction; that 8
said deposition is a.true record of the testimony given by the witness; that I am neither counsel for, related to nor l
10 l l employed by any of the parties to the action in which this 11 l l deposition was taken; an d further, that I am not a relative 12 !
or employee of any attorney or" counsel emcloyed by the 13 i parties hereto, nor financially or otherwise interested in i
14 the outcome of the action.
15 16 ghyff, . ( ,
GARRE Y J. WALSH,JP[
l Notary Public in and for the 18 Commonwealth of Virginia at Large 19 My Commission expires: January 9, 1989 20 l
21 l 22 J ~
i I
A -?EDERAL 3EPORTERS,1NC.
- 3 347-1700 Nanoemde Cmanse 800 3h
SHOREHAM EXERC%SE IMPEDIMENT TO EVACUTION EDUTE MESSAGE t
Date: February 13, 1986 Suf folk County, New York Message: Impediment - Patchogue l
From:
C. Connolly, EOC Team Leader ZOC i Evacuation Ecs::e Coordinator at LERO To:
via Exarcise controllar l g
Initiating Event:
After EBS message to evacuate has been issued to '
l the public and FEMA fisid evaluator (C. Sarricks) l g
has notified EOC Team Leader that he/she is in position to evaluate field response.
) f Message:
A LOADED CRAVEL TRUCK WITH A 3ROKEN DRIVESHAFT, WHICE l IS UPRIGHT, BUT TURNED SIDEWAYS IN THE ROAD IS BLOCEING J l
THE NORTH AND SOUTH 30G(D*1. ANES AND BOTH SHOULD
~ YAPHANK - MIDDLE ISLAND ROAD APP 10ZIMATELY TIFTT "T" INTERSECTION Iv YARDS NORTH OF THE CAUTION LIGHT AT THE OF YAPHANE - MIPDLE. ISLAND ROAD, MAIN STREET AND MILL s
HIS IS A MULTIPLE ROAD (IN THE VICINITY OF TCP #124).
' VEHICLE ACCIDENT ALSO INVOLVING WREE PASSENGER C ATE BLOCKING BOTH THE NORTH AND SOUTH 30CND SHOU THERE ARE 0N_0, INJURIES TO ANY INDIVIDUALS.
TdE ROAD.
THE LERO RESPONDER TO THE SITE OF THIS IMPEDIMENT SHOULD LOCATE TdE TEMA EVALUATOR WHO WILL BE VEARI A COLORED ARM BAND.
Evaluator Cocunen t s Signoff Time
- 1. Message given to ,
l controller by team leader at LERO EOC
['8 N _
G am Leadel at LERO EOC)
Y
' I. Message dispatched to ens road crew / fuel truck responder from g
- the EOC (Evac.' Ops.
~ , Evaluator at LERO EOC)
Verification of Message g
3.
to road crew responder g 'CTI-received at ECC wucanun t c a c ions evaluator at LERO EOC) p
!. . Road crew unit evaluated at ene _ .
_ -j.,
field lo'c 569.a , ,,
W* )
2'
- - N~v '
~~
( F is h--~.a- .4.
p.m,k,.* g. _ .~'
~
. . .m ;. - * "*
- AY . ;;f 5 Y ,% ,
.. . . cc :. - .,
- - ' ' l ,j,
SHOREHAM EIERCISE I ZMPEDZEENT TO EUACUTTON ROUTE MESSACE f Date: February 13, 1986 l j l l
l Suf f olk County, New York J Message: Impediaanc - Parchogue -
) _
C. Cm aally, EDC Taas Leader Cf Froust EOC um r
To: Evacuation Route Coordinator at LERO p
via Exercise Controller After EBS message to evacuate has been issued ik) to "'
Initiating Event:
) has notified EOC Team Lasder that he/ she is 11.Zint position to evaluate field response. $
I Message: A IDADED CRAVEL TRUCK WITH A BROKFJiC D THE IAPHANK NORTH AND ISLAND
- MIDDLE SOUTHBOUND ROAD, APPROXIMATELY LANES AND BOTH SHO FIFTY (50) 7 "Y" INTERSECTION .'
' YARDS NORTH OF THE CAUTION LICHT AT THE
- OF YAPHANK - MIDDLE ISLAND ROAD, MAIN STREET AND MILLTH j.
- T ROAD (IN THE VICINITY OF TCP #124). ** j VEHICLE ACCIDENT ALSO INVOL/INC S OF THREE PASSEN ARE ELOCKING BOTH THE NORT8 AND SOUTBBOUND SH
, IRE ROAD. THERE AAE NO INJURIES TO ANY INDIVIDUALS. 1 l l TFE LERO RESPONDER TO THE SITE OF THIS LMPEDIME i SHOULD LOCATE THE FEMA EVALUATOR WHO WILL BE i 1
A COLORED ARM BAND. $
Evaluator Comment _s Signoff_ T_i ige,
- 1. Message given to __
controller by team _ _
~
leader at lea 0 EOC (Team Leader at LERO EOC) \
- 2. Message dispatched to the road crev/fvel truck responder from - _.
'~
g tne EOC (Evac, ops.
s> Evaluator at I LERO EOC)
- 3. Verification of Message to road crew responder -
l received at EOC (Cocmunicat ions evaluator at LERO
- i l
EOC)
.+
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Several TCPs wero evaluated. AH Trs?f!c Guides nr.d tne correct route :aps and
' equipment, as weH as dosimetry and simulated KI. AH traffic control personnel demonstrated that they were wen trained in their procedures, includng advice and guidance to motorists, and emergency worker radiological exposure control precedures.
Demonstration of the Port Jefferson Staging Area's rescurees for dealing with impediments to evacuation could not be evaluated. Prestaging of equipment and personnel accordng to :he LERO Procedures was demonstrated wnen several Road Crews and tanker trucks were requested by the Road Logistics Coordinator at the LERO EOC.
However, their performance in the fleid could not be evaluated. since delays' at :ne LERO EOC caused the Road Crew to miss its rendezvous with the Federal evaluator.
PATCHOGUE STAGING AREA The Patchogue Staging Area wu promptly opened and efficiently set up af ter :ne declaration of the Alert ECL. Au personnel were properly notifled and moeilized.
Individuals were cleared through security checks, briefed upon arrival. and issued dosimetry for fleid assignments. Staff!ng rosters indcated a twenty-four (24) hour
.esponse capabnity. The Patehogue Staging Area had adequate space, parking, equipment, and supplies. Operations were wou organized and clearly defined by functional areas. Communications were effective and messages were properly recorded, both to the LERO EOC and to emergency workers !n the fleid. However, security
, measures need to be strengthened at the Patehogue Staging Area and some of the l security measures demonstrated were not the same as those described in the LERO precedures. Messages were properly transmitted, status boards were won maintained, and's11 personnel were advised of developments by per:cde briefings. Direction of emerTency ;ersonnel in the fleid proceeded smoothly, but in9 dispatch of Bus Drivers out of the staging area was too slow.
Field activities originating from the Patchogue Staging Area included route alerting, raff!c control. reneral population evacuation ous routes, removal of an impediment to evacuation, bus transfer points, evacuation of the non-institutional:ed moeility-impaired, and evacuation of schools. The Route Alert Driver was deployed !n a
'imely manner and drove his route without any diff!culty. However. :he required :ime l for route alerting was excessive. Tourteen (.14) Traff!c Guides were evaluated at nine (9)
TCPs. These individuals were familiar wita their specific assignments with regard to guiding the raff!c and deployed the planned equipment, but they need training on how :s properly answer motorists' questions.
Four (4) general population evacuation ous routes were dispatened from :ne Patchogue Staging Area. The toilities of the drivers to drive ineir routes u planned varied greatly. The two (2) drivers reporting to the Brookhaven National Lacora:ory T ansfer Point understood how to use their dosimet.7. out one (1) of them omitted a smad part of his assigned evacuation route. Both of the two (2) drivers reporting to :ne Middle Island Shopping Center Transfer Point had difficulties in completing :neir assignments that resulted in a deficient demonstration. One (1) of :ne drivers :cox over two (0) hours to get to the Middle (sland Shopping Center Transfer Point tecause .e initiaHy went to the wrong aus garage af ter being dispa:ened'from :na staging area. The av
60 2.8 PATCHOGUE STAG 1NG ARZA ne Patchogue Staging Area is located in a LILCO building at the intersection of )
Main Street and Conklin Avecue in Patchogue, New York. ne second ficer of the building is used to dispatch LILCO repair crews. ne ground ficer and part of :te basement have been dedicated for staging area purposes.
The main noor of the faculty consists of three (3) rooms used for distinct purposes. The largest room, capable of accommodating four hundred (400) people, is used as a waiting, briefing, and dispatching area for emergency workers. An area exists at the south end of de room for dispensing food and beverages. A smauer room, located at the north end of the facility, !s used to brief emergency workers on desimetry and !ssue DRDs, TLCs, and KL This room seats about forty (40) Individuals. A third room, loca:ed adjacent to the largest room, !s dedicated to ecmmunications.
The Patchogue Staging Area building also has a basement for storsge of emergency supplies and a second floor not planned to be used in an emergency.
2.8.1 Staging Ares Operations The objective of demonstrating the abuity to receive emergency nott!! cations was met at ce Patchogue Staging Area (SA 1). All emergency notifications were received promptly. LZRO personnel were notified by a combination of pagers and talephone caH-outs at the Alert, Site Area Emergency, and General Emergency ECLs as specif!ed'In OPIPs 3.3.2 and 4.5.1. The staging area itself was notified of all changes in de ECL and protective actions as planned via dedicated telephone.
The objective of demonstrating the ability to mobilize staff and activate de Patchogue Staging Area was met (SA 2). The Patchegue Staging Area was promptly opened and eff!ciently set up after de Alert ICL. Responding individuals were cleared by security checks, briefed upon arrival at the Patchegue Staging Area. and issued dosimetry fer field assignments. Staff were promptly noti!!ad by individual pagers and a commercial telephone esilout process. Approximately three hundred (300) individuals reported to :he Patchegue Staging Area for the exercise.
Staffing resters demonstrated a cree (3) shift / twenty-four (24) hour espacility i at the Patchegue Staging Area, thus meeting the objective of demonstrating an acility to - !
maintain staff!r.g around the clock (SA 3). The staging area administrators - acked :ne actual staff!ng of each position until its full ;1anned complement was met or exceeded. l The rester of backup staff showed : tat three (3) shifts were availacle for au ;csitices I except Sus Drivers, Traff!c Guides, and Route Alert Driven; de latter posi !cns have between two and three (2-3) shif ts planned since :hese are relevant only :o evacua:icn.
It is assumed in the Plan that evacuation can be accomplisnad in :wo (2) or fewer snitts.
Se Patchegue Staging Area met de cojective of demonstrating adequate spcce.
- arking area. equipment, and supplies to su
- port emergenc7 cpera: dens (SA 4). A2 l operations were conducted on me first f!cor, whien was large enougn to comiceta:ty accommodate approximately four hundred (400) emergency worxers, except initial Aler:
61 ECL telephone calloutst these were done on the second floor (see discussion of SA 6 selow). Two (2) large parking lots are adjacent :o me staging area. An equipment was kept in a locked storage room in the basement. Se entire inventory as stated in OPIP 5.3.1 was verifled. However, only one (1) first aid kit was avaHable. It is recommended that consideration be given to acquiring more first aid kits, as wou as additional goggies, gloves, and t ts. Supplies for each function were prepared for ready use, with additional replau .nent materials on hand.
The objective of demonstrating that the Patchogue Staging Area can establish appropriate communleation links with the LERO EOC using both primary and backup systems was met (51. 5). Three (3) systems were used: dedicated telephone commercial telephone, and two-way radio. Both telephone systems wo'rked flawlessly. The two-way radio was successfuny t-Mad at 1114.
The objective of demonstrating that the Patchogue Staging A*ea had adequate access control and that security eculd be maintained was partly met (SA 6). Access was suff!clently controlled at the Patenogue Staging Area, but not as described in OPIP 4.7.1. The planned complement of guards was posted at all three (3) entrances, and sign-
!n badging was implemented properly. When a reporter appeared at 1245 requesting access to the staging area. she was denied it by the Staging Area Coordinator and urged to go to the ENC. However, four (4) deviations from the Plan which require corrective actions were noted. First, the access point that was demonstrated was the north entrance rather than :Le Conklin Avenue main entrance as specifled in OPIP 4.7.1, Fr.ge
- 41. If the north entrante is the best access point, then it is recommended that OPIP 4.7.1 should be revised to reneet this practies. Second, LERO personnel used telephones on the second Coor to es:Ty out emergency notifleations. This contradicts security provisions in OPIP 4.7.1, Page 38, item #2, which explicitly sars all LERO personnel from the upper floor. It !s recortmended that either OPIP 4.7.1 should be revised to reflect this practice, or additional telegnones should be provided on the first noce to carry out the necessary emergency notifications. Third, the south door wu not kept locked as specif!ed in OPl? 4.7.1, Page 3, item it. It is recommended that the Staging Area Coordinator or a designes should be trained to verify that an doors required by the Plan to be locked are, in fact, toeked. Fourth, unauthori::ed entrance from the street to the staging area could be achieved through the open fire escape on the second Coor of :he east side of the bunding. It is recommended that a guard should be stationed at this location and tnat this !!re escape should be designated as a guard post in OPIP 4.7.1.
l The objective of demonstrating that messages were *:ransmitted in an aceunte and timely manner, messages were properly legged status coards were accurately maintained and updated, appropriate brief!ngs were neld, and incoming personnel wer*
briefed was met (SA 7). Messages were transmitted and logged properly; key items were scougnt by the Staging Area Coordinator to the recipients and the appropriate response was decided immediately. The status : cards located in the command room and :ne main staff room were updated and easy to read. Briefings of incoming staff and : hose continuaHy present were at regular and frequent intervals, as the situation dictated. The only area ecommended for improvement is that the person entrying out briefings snould me :etter versec in their underlying meaning. On occasion. :he Bus Dispatcher announced endiation readings, plant conditions, and wind directions (in degrees) :o me staff without
62 elaboration; when questioned by :he Federal evaluator acout de meaning of :he wind direction in degrees, he did not '<now its meaning. Also, questions from tne staff never were elicited. Given the nature of the activities at this location. thiz procaoly would not adversely affect the response to a eval emergency, out it is an area that could be improved by training the person carrying out briefings more thoroughly, and by requiring that staff questions be elicited.
The objective of demonstrating that the appropriate off!clal was in charge and in control of an overall response assigned to the Patchogue Staging Area was met by the Staging Area Coordinator (SA g). He used his emergency response checklist (from OPIP 4.3.1) and directed all operations through his principal subordinates. The Bus Dispatener and Lead Traffle Guide demonstrated thorough familiarity with :neir own eerponsibilities.
l The objective of demonstrating an ability to dispatch to and direct emergency l workers In the fleid was partly met (SA 9). Personnel were to be dispatched to the !!ald from ths staging ares for general population bus evacuation, school evacuation, evacuation of the mobility-impaired, route alerting, traff!c control, and removal of
- sific impediments. The Bus Dispatcher and Lead Traffic Guide closely oversaw the dispatch of Individuals under their control. These emergency workers were briefed on dosimetry, were issued dosimeters, and were issued instruction packets for their assignments prior to being dispatched to the fleid. However, the f!rst Bus Drivers were not dispatched until approximately 1045 - over two (2) hours after the 0832 declaration of the Site Area Emergency ECL. This is not according to the timetable for prestaging Sur Drivers stated in OP!P 3J.4. It Is recommended cat Sus Olspatchers should be sined in the tarportance of promptly dispatching Bus Drivers. Also, an additional area should be established for dosimetry distribution to reduce Bus Driver processing time.
and an additional trained Individual should be available to assist :he Bus Dispatener.
The oojective of demonstrating the aoility to communicate with all appropria:e
!!ald locations and personnel was met (SA 10). Communications with the fleid staff were maintained as planned with the Traffle Guides and Transfer Point Coordinators. Sta:us reports were obtained every thirty (30) minutes from each. When the radio of one (1)
Traffic Guide failed, the Traff!c Guide found a telephone and called the staging area. A replacement radio was promptly dispatched. ,
1 DEFICIENCY 1
Description Bus drivers were not dispatched until :wo (2) hours af ter l receipt of the Site Area Emergency ECL declaration (NURIG4654. II, J.9, J.10.g).
Recommendation,1:,-Ja, additional; ares should :e established for de distribution of dosimetry :o reduce Bus Driver processing time.
, Recommendation 2: Additional : sined staff should te provided to the l Sus Dispa:cner o assist nim in deploying over :nree nundred (300) l l
l l
53 drivers and Transfer Point Coordinators who are deployed from tne Patchogue Stagtng Area.
ARZAS REQUDLING CORAECTIVE ACTION l
- 1. Description OPIP 4.7.1 specifies that the only personnel entrance is to be the Main Entrance on the Conklin Avenue side of the building. The entrance actually used for this purpose was the one
- on the north side of the buildicg (Main Street) (no NUREG-0654 reference).
l l Recommendados: Since the system actually used seems to be superior to the Plan due to reduced congestion. OP!P 4.7.1 should i
be revised to indicate that personnel are to enter the Patchogue
! Staging Area through the Main Street entrance to the building.
L Descripdon: LERO personnel entered the upper floor repeatedly to use telephones for emerTency notification. This practice is explicitly prohibited by OPIP 4.7.1 (page 38, item #3) (no NUREG-0654 reference).
Recommendatica Elther OPIP 4.7.1 should be revised to reflect the actual practice of using telephones on the second floor of the Patebogue Staging Area budding, or more telephones should be l provided on the first Coor for LERO personnel to perform their i emerfency notif! cations.
1 -
- 3. Descrigdom The south door was not locked for security as specified in OPIP 4.7.1 (no NUREG-0654 reference).
l Recommendation All doors required to be locked by the P!an should be verifled as actually locked by the Staging Area l Coordinator or a designee.
1 i
- 4. Descriptions Unauthorized entrance to the staging area could be ;
l achieved through the open fire escape on the second floor of the 1 l east side of the building (no NUREG-0054 reference).
l Recommendation The fire escape on the second floor of the east side of the building should be designated as a guard post in the Plan and an individual should be assigned to staff this guard post.
ARZAS RECOMMENDED FOR IMPROVEME.Yf a Description The Sus Dispatcher was not well enougn versed in the meaning of the information he communicated to the staff during briefings. Questions from tne staff were never elicited.
+- = = . . . .,
Recommendation Persons carrying out briefings should be trained suff!ciently acout the meaning of terms associated wita plant conditions and wind direction so that they can explain these :hings in understandable terms to the staff. Also, it should be '::ade a routine part of the brief!ng process to ask if any of the staff have questions.
Description Only one (1) first cid kit was avaHable at the Patchogue Staging Area. No boots, gloves, or goggles were avanable for aiding in emergency work.
Recommendation Consideration should be given to acquiring additional fint aid kits, boots, gloves, and goggles at the Patchogue Staging Area.
2.8.2 Implementation of Field Activities The objective of demonstesting the abHity to p'rovide backup public alerting, if necessary, in the event of partial siren system fanure was partly met (Fleid 5). Mounting and operation of the mobile pualic address units assigned to the Route Alert Drivers was demonstrated at the staging area. The driver who was evaluated had good knowledge of the route plan in the affected area and drove at an appropriate speed. He 'ctew how to giv_e vertal Instructions if anyone should approach the vehicle with questions regarding the prescripted message. Total time from dispatch to the beginning of the route was nineteen (19) minutes, with another f!fty-one (51) minutes needed to complete the route itself because of the length of the route. It Is recommended that the plans for tackup route alerting should be reviewed and revised as necessary :o reduce the time needed f:e pucHe alerting.
~~he cojective of demonstrating :nat access control points can be established and staffed by Tesific Guides in a timely nanner was partly met (?!ald 5). AH nine (9) TC?s evaluated were fully staffed in a timely manner. AH personnel understood the concept of Operations at :neir respective locations, including timely radic communication and check-in. as well as proper placement, as appropriate. of :arricades and cones. However.
only one (1) Traffic Guide out of the fourteen (14) who were interviewed at nine (9) TC?s
'c:ew the location of the Reception Center, and one (1) Wsff!c Guide :hougnt : hat :ne general puolic was to be directed to the IWDF. It is recommended nat au Traff!c Guides te trained :o advise motorists with questions to :une to :he E3S station (W ALK-FM) for the latest information on all matters related to the emergency, including :he ccation of the Reception Center. ~ ' -
The cojective of demonstrating a sample of resources necessary to implement an orderly evacuation of an or ; art :t :he 13-mue IPZ was not met (?!ald 9). T:ur (4) Bus Crivers dispa:ened from the ?stenogue Staging, Area were evalua:ed. Two (2) Of :ne s
drivers were sole to pick 29 :uses at designated yards. ;rected :o assigned ::ansfer
- oints. and drive their assigned routes, althougn one (1) of them missed part of his assigned evacuation route. More confusion was evident on the part of the
- :her trivers.
65
' One (1) driver proceeded to the wrong ::ansfer point, and completed his route only after being prompted by the Federal evaluator. The other driver :ock over two (2) hours :o get to his transfer point from the staging area because he initially went to the wrong eus garage. It is recommended that training be provided to Bus Drivers to assure that : hey will be sole to follow directices given to them and to drive their routes from the staging area to the bus garries to transfer points, and to complete their entire assigned pickup routes. In addition, it is recommended that OPIP 3.8.4. Attachment 2 (Pages 13-14) and Attachment 1 (Pages 10-12) be revised to require, respectively, the Bus Driver to present, and the Transfer Point Coordinator to verify, each Bus Driver's copy of the Bus / Van Dispatching Form (OPIP 3.8.4, Attachment 7. Psge 82) to assure : hat the Bus Driver has arrived at the proper transfer point.
The colective of demonstrating a sample of resources necessary to deal with impediments to evacuation, such as inclement weather or traffic obstructions, was partly met (Fleid 10). This demonstration was impaired by two (2) factors. First, the LERO EOC failed to transmit the entire free play message with the result that Road Crews could not locate and racognize the Federal evaluator at the Impediment (see ciscussion of objectives EOC 7 and ECC 17 in Section 2.1.1 above). This delayed evaluation of :he response by over an hour. Second, the Road Crew was not informed that the Impediment was a multiple vehicle accident, and only one (1) tow truck was dispatched. This would have been inadequate for removal of the impediment, which the Tow Truck Driver estimated would have required thirty (30) minutes to clear with the proper equipment.
Rerouting of traffle was not observed. It !s recommended that the appropriate personnel at the Patehogue Staging Area be trained to request more information regarding impediments from the LERO EOC when impediments to evacuation are indicated. .
The objective of demonstrating a sample of resources necessary to control access to ah evacuated area (Traffic Guides) was met (Fleid 11). Equipment and resources evaluated by the Federal evaluator were adequate to control access to the areas evacuated. For example. entire complements of barricades, cones, and personnel identifled in the Plan were demonstrated at TCPs $31 and $32. Though Traffic Guides could not position their vehicles in roadways adjacent to :he actual spot unere they would guide trs!!!c, interviews by the Federal evaluator indicated that they had ample knowledge of correct positioning.
~he ooiective of demonstrating the adequacy of evacuation ous transfer points.
Including access and parking / transfer areas, was partly met (Fleid 12). Transfer points were evaluated at Brookhaven National Laboratory and Middle Island Shopping Center.
These locations were easily recognized with free access and ample ;arxing. Trr.sfer Point Coordinators were cinarly in control at both locations. *Iowever, one (1) prootem was ::oted. The driver of the bus for the non-institutional! zed moeility-impaired (see discussion of ?! eld 14 below) pecceeded to the Brookhaven NationL Laboratory Transfer Point upon completing his route (as planned), where he was directed to the EWDF despite the fact that a :nessage from the Bus Dispatcher at 1145 to :e transmitted :o all Transfer Point Coordinators had requested all drivers arriving tefore 1600 at a transfer )
- oint to. be directed to the Reception Center. It is recommended that Transfer Point i Coordinators es trained to follow instructions from
- te Staging Area regarding directions
- nat are :o :e given :o special popula:!on evacuation route Bus Drivers, since :ne Sus 1
I l
56
\
Orivers are trained to return :o the transfer points for instructions as speci!!ed in :ne Precedures.
The objective of demonstrating a sample of resources necessary to effect an orderly evacuation of the non-institutional! zed mobulty-impaired individuals within : e 10-mue EPZ was partly met (Fleid 14). Evacuation of non-institutional 12ed mobility-Impaired individuals was demonstrated by a driver who was knowledgeable acout procedures for obtaining an evacuation vehicle, driving a route for euro-side pickup, and returning to the Brookhaven National Laboratory Transfer Point. Seventeen (17) mobulty-impaired ladividuals were located from the route map, the route was completed in less than two (2) hours and the bus returned to the transfer point at 1459. The estimated time for driving the entire route, stopping at the transfer ;oint. and proceeding to the Reception Center (this latter segment was not observed) was over three (3) hours. However, the residences of some mobulty-impaired persons were diff! cult to f!nd using the map provided. It is recommended that drivers designated to I
pick up non-institutional! zed mobility-impaired persons at their residences, should be I provided with more detailed maps and clearce descriptions of pickup points.
The objective of demonstrating a sample of resources necessary to effect an orderly evacuation of schools within the 10-mue EPZ was partly met at :he Patchogue Staging Area (Fleid 16). The sus Dispatcher at the staging area arranged for one (1) cus to simulate the evacuation of forty (40) children to the Reception Center, based on a LIRO EOC .equest. The driver was famular with his function and fouowed his directions very well. However, the stsging area :cok forty (40) minutes to dispatch the driver af tre
- hor request was received. It is recommended that the Bus Dispatcher.be provided w.:n trained staff support so that Sus Drivers can be dispatched in a more timely manner.
DEFICIENCY Description A Bus Driver took two (2) hours and ten (10) minutes to proceed from the staging area to the : snsfer point. Another driver went :o the wrong transfer point and his mistake was not reccgnized by the Transfer Point Coordinator. Yet another driver missed a segment of an assigned evacuation route (NURIO-0654. II, J.9. J.*,0.g).
RecommendaJon la Sus Drivers for general population evacuation routes should receive ::sining to assure their acility to fonow directions given to : hem so :ney can (a) fonow routes from :he staging area to bus garsges and then to trsnsfer points, and (b) fonow an assigned bus route. }
Recommendation 2: O ?!P 3.3.4, , Attachment 2 (Pages 13-14) and Attachment 1 (Pages 10-12) should be revised to require, respectively,
- ne Bus Driver :o ; resent, and the T:snsfer Point Coordinator to verify, ;
esca Sus Driver's ccpy of the Bus / Van Dispatching Icem (O?!P 3.5.4. l A::achmen: 7[ ? age 62) to assure :nat :he Bus Driver has arrived 1: :ne preger Transfer Point. ,
AREAS REQUIRING CORREC'ETVE ACTION
- 1. Descrigdom Traff!c Guides do not have complete or correct information on the appropriate destination for evacuees (NUREG-0654,1 J.9, J.10.g).
Recommendation All Traffic Guides should be trained to advise cotorists with questions to tune to the ESS station (WALK-FM) for the latest information on all matters related to the emergency, I
including the location of the Reception Center.
- 2. Description Appropriate personnel and equipmsat were not dispatened to clear the multiple venicle accident simulated as an Impediment to evacuation (NUREG-0654, II, J.10.k).
Rooommendadom The appropriate personnel at the Patehogue Staging Area should be trained to request more information from the LERO EOC when impediments to evacuation are indicated.
- 3. Description Instructions for the driver of the non-Institutional 2ed mobility-impaired bus to proceed to the Reception Center were not properly transmitted to the Bus Driver l at the Brookhaven National Laboratory Transfer Point (NUREG-0 6 54, II, J.10.d).
Recommendation Transfer Point Coordinators should be trainesi to follow instructions forthcoming from the staging area regarding directions that are to be given to special population evacuation route Bus Drivers, since they are trained to return to the T snsfer Point for instreetions as specified in the LERO Plan.
- 4. Description Residences of some non-institutionalized mobility-impaired persons were diff! cult to find (NUREG-0654. II, J.10.d).
Recommendation Drivers designated to pick up non-institutionalized mobility-impaired evacuees at their residences should be provided with more detailed n:aps and clearer descriptions of picimp points. ;
l l l S. Description It took forty (40) minutes from receipt of a LERO request to dispatch a Bus Driver to simulate the evacuation of forty (40) senool children (NUREG-0654, J.S. J.10.g). I
- :n .:. o .w, -
~
Reconimendatiom The Bus Dispatcher at the Patchogue Staging Area should be provided with trained staff support so that Sus
] , Drivers can be dispatched in a more timely manner.
N
~
sa AREA RECOMMENDED FOR IMPROVEMENT
Description:
Seventy (70) minutes elapsed f.cm the time :he I.ZRO EOC informed the Staging Area of the given rimulated siren fa!Iure 4
until pucile alerting was completed.
Recommendation: Plans for backup 4 routs slerting should be reviewed and revised as necessary to reduce the time needed for reate alerting.
2.8.3 Emergency Worker Radiological Fm Control
'I"no objective of demonstrating the ability to continuously monitor and control-emergency worker exposure, including proper use of personnel dos! metry, was partly met at the Patchogue Staging Area (Fleid 1). Most of the emergency workers evaluated ,'
Including six (6) Bus Drivers, a Route Alert Driver, a Road Crew, and haff!c Guides at' 1 three (3) locations - demonstrated knowledge of use of dosimetry and actions required in response to certain readings as called for in OPIP 3.9.1. However. :hore were exceptions. Distributive of dosimetry to the general population evacuation route Sus Drivers at the Patchogue Staging Area was accompanied by the careful reading of instructions- by the Dosimetry Record Keepers covering au features of OPl? 3.9.1, including the use and meaning of rudings on the 0-200 mrem and 0-5 Ram DRCs.
However, the Bus Dispatcher later made repeated statements with a buuhorn wnich em'phasiz'ed only that general- population evacuation route Bus Drivers were to can in when a reading of 3.5 was reached on the DRD he did not give the units associa:ed with
- ne 3.5 number, nor did he mention the use of the 0-200 mrem DRD which !s supposed to trigga the f!rst can-in at a reading at or above 200 maam. These builhorn announcements may have led to confusion, because one (1) general populatica evacuation route Bus Criver :hought the 0-200 mrem DRD was for use if the 0-5 ' Ram DRD reacned 5 and did not ' cow which DRD would give him :he 3.5 Ram can-in reacing. In addi:fon, this general population evacuation route Sus Driver read his DRDs only wnen it was convenient to do so, when the bus stopped (cr other reasons, about every : hie:y (30) minutes.
Another? bus driver read his DRCs only t vice, wnen etminded :o do so Oy :ne Transfer Point Coordinator. For example, he did not ' cow that 3.5 Ram was his call-in reading. It is recommended that the vercal instructions given to genersi population evacuation route Bus Drivers by :ha Sus Dispatcher over the bulfhorn be more ;recise :o emphasize the proper use of both DRDs and the careful reacing of expesure concol inscuctions for emergency workers. General ;cpulation evacuation route Bus Drivers snould also be =sined to read their DRDs t; proximately every f!ftoen (15) minu:es wnen they are inside the 10-mile EPZ, stopping the bus :o do to if necessary. Traff!c Guides a:
two (2) TC?s did not know dose authorization !!: nits. It !s recommended :ha: an Traff!c Guides snould be trained so that they know dose authorization limits.
~he cafective of demonstrating the ability to supply and administer KI. once :ne decision is made :o do so, was partly met at the Patenegue Staging Area (?!ed ~'.
Emergency worxers were authorized :o take simulated K! at acout 0953, wnile 5: 12 Ir. :ne staging area. A2 at :he emergency workers, with the exception at a Rou:e A.ert Oriver.
\ . ..
69 understood the proper procedure f;r authorization and use of KI; a numcer et these asserted that they were not alle:Ti e to it. The Route Alert Driver understood the purpose of KI, but was unaware of the automatic ingestion instruction in OPIP 3.3.4.
Attachment 1, item #9, and believed that he would receive KI authorization in an ESS message. Route Alert Drivers should be trained so that they know that KI authorization is to be issued to them by their supervisor as specified in the LERO Plan.
The objective of demonstrating that emergency workers understand who can authorizs exposure in excess of the general public PAGs was partly met at the Patchogue Staging Area (Fleid 8). Most of the emergency workers evaluated were aware of tne ensin of command for authorization of exposure in excess of the general public PACS, as well as the fact that this would be an additional voluntary act. However, Traff!c Guides at two (2) TCPs dd not fully understand that the chain of command for excess exposure authorization gives the Lead Traffic Guide authority to authorize excess exposure by radio, and some Traff!c Guides indicated that they might question the authority of the Lead Traffic Guide to issue the authorization for excess exposure, 't !4 recommended that all Traffle Guides should be trained to know that the Lead Traffic Guide can authorize aren in excess of the general population PAGs by radio.
DEFICIENCIES No 1 deficiencies were observed in the implementation of emergency worker radiological exposure control for fleM activities deployed from the Patchogue Staging Area.
AREAS REQUIRING CORRECTIVE ACTION
- 1.
Description:
The Patchogue Staging Area Sus Dispatcher :nade repeated statements with a bullhorn which emphasized only that general populaticn evacuation route Bus Drivers were to callin if a reading of 3.5 was reached on their DRD; he did not give the units i associated with the 3.5 number nor mention tne use of the 0-200 mrem DRD wnich Is supposed to trigger the f!rst esil-in at a reading at or above 200 mrem (NUREG-0654, II, K.3, E.4).
Raeommendation: ne vercal ins
- ructions given to the genersi population evacuation cute Bus Drives y the Patchogue Sus ;
Dispatcher over the bullhorn should be more prec!:,4 to emphasize the proper use of both dosimeters and the careful reading of exposure control instructions for emartency workers.
- 2.
Description:
One general population evacuation route Bus Driver read}.DRD,s' enly twice.'it. the instructions of the Transfer Point Coordinator and another read his DRDs on.ly wnen it was c?nvenient (NUREG-0654. II. E.3.a. K.3.b).
i
70 s
l i
Recommendation General ;cpulation evacuation toute Bus Drivers should be trained :o read :teir desimeters approximately every f!fteen (15) minutes when they are inside the 10-mile EPZ, stopping the bus to do so if necessary.
- 3. Description Traff!c Cuides at two (2) TCPs did not ' cow dose authorization limits (NUREG-0654, II, K.3.a. K.3.h).
R4rcommendattom Trs!n the Traff!c Guides so that they know the dose authert:ation limits.
- 4. Description The Routs Alerting Driver observed believed he would receive KI authorization In an EBS message. This is inconsist$nt .
with OP!P 3.3.4, Attachment 1, item 69 (NUREG-0654, II, J.10.e.
J.10 0.
l Recommendation Route Alert Driver 3 should be trained to know that KI authori:stion is to be issued to them by their supervisor as specif!ed in the LERO Plan. :
i
- 5. Description Traff!c Guides at two (2) TCPs cid not fully .. , 41 I understand that the chain of command for excess exposure ;'
authorization gives :he Lead T sff!c Guide authority to authorize
. _ excess exposurs by radio, and some T:stf!c Guides indicated that they nignt question the authority of the Lead Tittf!c Guide to issue :he authorization for excess exposure (NUREG-0634, II, K.4).
Recommendattom All Traff!c Guides should be 'rsined :0 know that the Lead Trstf!c Guide esa authorize exposure In excess of
- he genersi population FACs by radio.
.ZAS RECOMMENDED FOR IMPROVEMENT No arets recommended for improvement were observed in :he !mplemen:2:fon of ergency worker radiation exposure control for f!sid activities deployed from :te
- negur. Staging Area.
RT/?3 HEAD STAGLNG ARZA
'~ho a!vernead Staging Ares is Ices":d in the :asement of a L*LCO facill:7 in rernesd. New York. A large worxspacs is divided into an off!ce for :te Stag ng Area ordinator, and sections for :te administra:ive support staff, and : communications if. 2.ere are seversi ether .coms specif!ed f:e fleid ;:ersonnel and rela:ed staff.
.~
~ -
TAB 12 4.6 SdCRERAM NU"E FCWgt STA!!OS - $39%AT Of DCTICIENCIES AND AREAg Rgqu!1DG cot 21CTIVE ACT!CN February 13. 1984 FATQt0GUE STAGDG AAEA Fage 1 of .
Recommended NUREG-0654 Cserective retten FIMA-REP-1
- 29. 1 Exercise ' resent
%. Raceemoeded Corrective Action Refersece 2/13/84 Stetus lERICIIKIIS 1
Sus drivers were set dispatched antil two (2) hours J.9, receipt of the dita Area Eserressy EC:. J.10.g after declartti n.
t (1) An additional area should be established for the distributes of dosimetry to reduce Bee Driver processing time.
(2) Additional trained staff should be provided to the 1 1 Sus Dispatsher to assist his is deslaying over enroe hundred (300) drivers and Trasefer Feist Coordinators wne are deployed free the Fatahogne f 5taging Ates.
J.9,
- A sus driver took two (2) hears and tes (10) eientee to proceed from the staging area to the ';ransfer poist..
J.10.g AaAner driver west to the vrees traeefer point, and his sistake ups not recogsised 57 the Transfer Feint Coordinatst.. Yet another driver sissed a segnant of as assige.e4 evacuation reste (NCIEG-0454. II, J.S. J.10.g).
(1) Sus Drivers for general population eveaustion 1 ;
toutes should receive training to aoeurs their ability to fellow dirsatione gives to them se they cza (s) f allev routes free the staging area to bus garages and then to transfer points, and (b) follow as assigned bus route.
Attachment 2 (Pages 13-14) and I
() 0FIF 1.~6. A .
Attact M 1 (7 ages 10-12) should be revised to require, respectively, the Sus Driver to present, ar.d the Transf er Point Coordinator a verify, each lus Driver's copy of the Bus / Tan Dissatchias Fers (3FIF 3.6.a. Attaanomat 7 Page 62) to assure that the tus Driver has arrived at the proper Transf er
?oint.
AREA 8 REQUI1 LEG CDSSECTITE ACTI35 1 0FIF Is.F.1 specifies that the only personnel settanus is N/t 1 :
to be the Main f.atrence on the ' Cone.Lia~ Avenue side of the building. The estrene.e actually used for this purpose was the one on the north side of ~ trie building (Mais Street). 3ince' tne syetes actually used seems to be su>erior to tne Plan outs *o ret.uced congestion. 0F17
- .7.1 snould be revised to indicata that personnel are to enter the ?stenogue $tagtag Aree enrougn the Main Street enttance to the cuilding.
4 L - - - - .
130 TABLE 4.4 SR0REEM NUC' ZAE Fown STATION - SUNt%LT OF OEyt0:1NC 5 AND AAEA.1 t! OUI 1!3G 00EAECTIVE ACT MN February 13. 1986
?ATO:10 CUE STAG NG AZZA (Cont'd)
Page : sf .
Recommended N ]654 "arreettve ae: a ,
TF.MA-R17- L Rev. 1 Ezercise Present Me. teceasseeded corrective Action taference 1/13/86 Status
,1Z20 perseasel encared the upper floor repeatedly es ue ' N/t I :
telepaones for emersesey notification. This practice is explicitly prohibited by 0717 6.7.1 (page 38, itee
- 3). 11ther GFD 6.7.1 should be revised to refleet the actual practice of using telephones os the secoed flocr of the Patchogue staging Aras building, or sere telephones should be provided on the first 21ser for
'E30 personnel to perform their emergsacy notifications.
3 The south teer was not locked for security se specified N/R 1 ;
in CF D 4.7.1. t.11 deers rewired to be locaed by the Flaa should be verified as actua1Ly locked by the Staging Area Coordinator or a designee.
4 "nautherised entrance.to the stagist asse could be M/t I L achieved througa the opes fire esaspe on the second
!1oor of the east side of the tu11 ding. The fire essape
- on the second !!aor of the east side of the buildiac should be desissated as a guard poet la the Flan and an individual should be assignes ta staff this guard poet.
$ Trai!1c Guides do set have coeslete or correst inforzea J.f. % .
tion on the apstopriate destination for evacuees. All J.13 3 traffic Ouides smould be traised to advise seto ris ts with questions to tune to the E35 station (VALI) for the latest infortasian on all setters related :s tne j energency. inclading the locatise of the luception Center.
3 Appropriate personnel and equipenet were not disps::hed J.10.'s I ;
- s clear the sul:1914 venicas accident staulates as an isoodiasat :s evacuation. The appropriate personesi et ta Patchogue Staming Area should be trained to request note inf ornecias f ree the 1.11t0 50C when i.apediennts to evacuatioe ;te indicated.
7 instr' actions !st the driver of the ion-institutionalized J.10.4 i non111ty-Las41 red Due s arscoed :s :Me teception Center wee not properly transmitted to the 3us 3 river at the troodaves National *.anoratory Transfer Foint. *ransfer
?sist Coordinators should >s trained : follow instruca tions fortsetsing from the stagir.g area regarting tirections : r at are to be given ca special populatica evacuation trace %s Orivers, since they are trained :s return :o :r.e transfer poinc !se instrue:1one as l specefied in :ne LI13 Flan, l
- ABLE 4.4
$ROLERAN NUCI.1A1 PCWEL STATION = $120tAAT OF OETIC:E.NC:13 AgD AAEA3 1 EQUI 11M CORAECTIVE ACT!:N Februar* L3. 1984 PATCROCUE STAGING AAZA (Cass'd)
?sse 3 of .
Recommended NUltzG-0434 carveettve ae: tan TEMA-REF-L law. 1, Exercise Present tacoasseded Corrective Action tsforence 2/I3/84 $tatus ito.
some see-institutionalized moeility= J.10.4 1 ;
8 Residences of ispaired perseas were difficult to find. Drivers designated to pick up nea=isstitutionalised estility=
inestred evacuees et caett residences should be provided witM acre detailed aspe and cisarer descriptions of picaup points.
It took forty (10) sinates free receipt of a 1.I20 J.9, I ;
9 request to disoeten a tus Driver to staslate the J.10.g evet ation of forty (40) scheel dildres. The les
- Dispatcher at the Fatshogne Staging At aa should be provided with trained staf f support se that 3ee Drivers can be dispatched La a more timely asener.
na Fatchstue Stagtag Area tus Dispetener ande repeated t. 3 , I I
$0 scataments with a bullhort. whica emphasised saly that t. 4 genersJ population evacuation route Sua Drivers were to cal} ta if a reading of 3.3 was reached on eftear 3RD: he did not give the units associated with the 3.3 ausher nor wation :na use of the O=100 stan 3kD vesica is supposed to tridger the first call-ta at a reading at or aoove 300 3 Ass. De vernal insert.stione given to the general population evacuation rauts tus Drivers by the Patchogue sus 31spectner over the bullhorn saoult, be more precise to owen size the proper use of born desteeters and the careful reading of espaure control instructions f=r emergency workers.
Gee general population evacuation route Sua Oriver read c.3.a. 1 :
11 020e only twice at the instructions sf :ne *ransfer t.3.5 Point Coordinator sad another read nis :Us only vues is vos convenient. Oeteral populatiou evacuation routs Sus Orivers should be trained to esad chair dosiseters approxi stely every fiftees (15) simtas vnen they are inside t'te !D-sile EF1 stopping tt.e bus to do so if secaseart.
1: Traffic Guides at two (2) 00Fs die not know does (.3.a.
- t. 3. 3 I
autnorisation limits. Orsin the Traffic Guides so snat Fay kaov the dose authorization 11 sics.
13 *he toute Alerting Driver observed believed ' he would J.10.e, t :
receive C ausnorizacima in as C15 wasage. Bis La 1.10.!
inconsistent with opt? 3.3.4 Attaeneent 1, tres 79.
Route Alert Drivers enould be trained to how %t C authorization is :s de issued to thee by their superviser as specified is :ne '.IM Flan.
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132
- ASLE 4,6 JECREMM 1 COMAS Powtt $7A*:03 - SCMMAAT OF OtFICIDCIIS AND A1223 t!QUIRL4G CCRAZCTIVE ACT :N Tebruary 13, 1786 PATSLOG;E $TAGING AAEA (Cont'f)
?sgo a of .
latomended M m]634 Osergettve Ae: ton FD8.A- AAF-1 tev. 1 Czercise ??. vent Recomenaded Corrective Action Reference I/13/56 Status to.
Traffic kideo at two (2) TO?e did rwt ! ally understand t. 4 t :
l 16 I that the enais of coassad for esasse esseeure authorization givse the 14ad Traffis kids authority to sothertse escoes espesute by radie, and sees Traffis kides 1 set =ated that they sight question the authority of the h ad Traffic kide es issue the autnerisation for escoes esposure. ul Traffic kides should be trained to knew enas the Med Traffic kide saa ausmerise espesure is excess of the general popul4 ties FAGe by .
radio.
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T3AF Feorvary 13, 1986
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Date:
, ew York M'ibgu %
se - Patchogut
.elea g - : G % %_ %,
% Q S_OmNQ EOC Team Leader ECC via ~ ~
- oenolly, LERO ide at ) ~
d Traffic Control Gu n
tor (C. Sarricks -
--cise Co troller m FEMA l 'ield evaluareporting through TCPs n esaluated.
nt: Notification froTeam haea beeLeader that all 'M'%a, , ~
PATCHOGUE E to EOC w Patchogue Staging AreaTRAFFIC CUIDES FROMAS$1CNMEMIS - 6t OF FURIRER FEMA EVALUATI0d CF ALL
E ITACING AREA MAS BEEN COMPLETED.C DISCRETION OF LER ,
FERSONNEL ARE AT TF that traffic is ,
should provide'timeswed TCP chat at each D. d{
I - '
Evaluatorwere guides intervie -
'-alu a tion wed evaluated. Time Intervir 2
Post i
(2:51 r .g ~ l Traffic Centrol l' S Q 94 { 1 "l c3 n 1n Doh n'7 '(flA Y_ ,,
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Field Evaluator .
Team Leader ..
slied t ECC (after P n
- valuation it last of TC sintersectio(Team Leader ,,
a u igned) at LERO EOC) give n to Message r by T e am controlle LEKO EOC i!eam Leader at LERO ECC)
Leader at s EXERCISE r.
.y j THIS IS AN . . .
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SHORIHRf EEERCISE j ..
- *FFIC CONTROL FCINT K2SSACE Date: February 13, 1986 Suffolk County, New York .,
TCP Release - Petebogue ,%*a' Message:
01'2$ !!
C. Connolly, EOC Team Leader From: 4 t f* > '
To: Lead Traffic Control Guide at LE10 EOC via Esercise Controller i ) -~
l through Ini tiating Event- Notifiestlos from FEMA field evaluator to EOC Team Leader that all TCPs report ng i (c. $str cks -j-l
.m..
Patchogue Staging Area have been evaluated. EA CHOCUE
'N ,I Message: THE FEMt ETALUAT!ON OF ALL TRAFFIC CUIDES w'F STACING ARIA dAS BEEN COMPLETED. -
PERSONNEL ARE AT TEE D15C1ET103 0F LE10.
traffic N
Evaluar.- should provide times ttist is Ml
- 1. Field Evaluation guides w=:s interviewed at each TCP that gl
- 1 evolusted. I
- Time Interviewed
(:c l l Traffic Control Post # - , .
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SHORERAM EXZRCISE yy /(.q ;-- *n , .
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a0CT: ALz1T ac nsssAct (Sissisted Sires Tailure)
Date: Feoruary 13, 1986 ..,
Suffolk County, New York 'a ra~a Message: Route Alert C. Connolly, ECC Tesa Leader Tree:
To: Coordinator of Fablic Information at LE10 ECC via Exercise Controller Approximately 20 minutes af ter sires activation. N'C Isiciating Event: g~ s.
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- 6, 45 AND 8-) HATE FAI1ZD TO ACTIVATE. r D
Evalustor T Commene s_
l $iguoff* _ime
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controller by Tess _
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Leader at IIRO EOC (Team Leader at LERO COC) -- ..
- 2 Message dispatched from $
Special Facilities Evacuacion Coordinator __
to Lead Traffic Guide _
g at Staging Areas ^ (Evac. Ops. g 3
Evaluater at l,i LERO EOC) 3 Time Comments 2 Evatustar's None Siren i E
- 3. Route Alert Driver (s) _
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XX YX l
Jeployed from Staging _ _
t 6
Area 4
f OMo XX
- a. Route Alert Driver (s) ..
completed Route.
(Enter time ~ ~ -
toute was completed.) .
THIS IS AN EXERCISE GOOGC003 e .
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