ML20210B993
| ML20210B993 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/07/1987 |
| From: | Mccaffrey B LONG ISLAND LIGHTING CO. |
| To: | |
| References | |
| CON-#287-3353 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8705060063 | |
| Download: ML20210B993 (112) | |
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GEWEDyggg3 3353 TIR ~SCRIF1 DOCKETED c) C'F PRDCEEDL ~GS"" '87 APR 30 A10 50 gp UNITED STATES OF AMERICA 0 l\J1 NUCLEAR REGULATORY COMMISSION 0FFICE OF SELiiiARI 00CKEittlG & SEi"VICf-BR Aht'H BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the Matter of: :
- Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY : (EP Exercise)
(Shoreham Nuclear Power Station, : (ASLBP No. 86-533-01-OL)
Unit 1) :
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x DEPOSITION OF 11RIAN R. McCAFFREY l
l Hauppauge, New York l
Wednesday, January 7, 1987 ACE-FEDERAL REPORTERS, INC.
I stenot.1gv Reporters 444 North Capitol Street Washington, D.C. 20001 (202) 347-3700 Nationwide Coverage 800-336-6646 0705060063 870107 PDR ADOCK 050003gy l
PM i
1 1/7/87 1 UNITED STATES OF AMERICA sney353.0 NUCLEAR REGULATORY COMMISSION Rptd:JoeW 2
'iyped :SueW ATOMIC SAFETY AND LICENSING ~ BOARD GE9357,1 3 4 In the Matter of: :
5 LONG ISLAND LIGHTING COMPANY : Docket No. 50-322-OL-5
- '(EP Exercise) 6 (Shoreham Nuclear Power Station, :
Unit 1) : (ASLBP No. 86-533-01-OL) 8 DEPOSITION OF BRIAN R. McCAFFREY 9 County Attorney's Office Building 158, North County Complex 10 Hauppauge, New York 11 Wednesday, January 7, 1987 C4 12 Deposition of BRIAN R. McCAFFREY, called-for examina-13 tion pursuant to notice, at Hauppauge, New York, at 1:34 p.m.,
14 before Garrett J. Walsh, Jr., a Notary Public in and for 15 the Commonwealth of Virginia, when were present on behalf of
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16 the respective parties:
17 SUSAN M. CASEY, ESQ.
KARLA J. LETSCHE, ESQ.
18 Kirkpatrick &'Lockhart 1800 M Street, N.W.
19 Suite 900,. South Washington, D. C. 20036 20 On Behalf of the Intervenor, the' County of Suffolk 21 22
2 s
%mp 1 APPEARANCES: (Continuing) 2 3 RICHARD J. ZAHNLEUTER, ESQ.
Deputy Special Counsel to the Governor 4 Capitol, Room 229 Albany, New York 12224 5 On Behalf of the Intervenor, the State of New York 6
KATHY E. B. McCLESKEY, ESQ .~
7 SCOTT D. MATCHETT, ESO.
Hunton & Williams 8 707 East Main Street P. O. Box 1535 9 Richmond, Virginia 23212 On Behalf of the Applicant, the Long Island 10 Lighting Company 11
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2 EEEIEErs 2
3 Brian R. McCaffrey 4 Examination by Ms. Casey Page 4 5
6 7
8
_E _X _H _I _B _I .T _S 9 FOR' IDENTIFICATION 10 McCaffrey Deposition Exhibit Number 1 Page 5 11 McCaffrey Deposition Exhibit Number 2 Page 64
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4 1 P_ R,O C_ E E,D_ I'N_ G-S_
2 Whereupon, 3 BRIAN.R. McCAFFREY 4 'was called as.a witness and, having first been duly sworn, 5 was examined and-testified as follows:
6 DIRECT EXAMINATION 7 BY MS. CASEY:
8 Q Mr. McCaffrey, let me state for the record that 9 my name is Susan Casey. And I'm with the' law firm of 10 Kirkpatrick & T Lockhart which is representing Suffolk County 11 in.this. licensing proceeding.
12 Basically today I want to-ask you questions in-13 two areas. .One is what you've done~in connection with the 14 February 13th exercise; and, secondly, to. find out a little, 15 about wh'at you plan to testify about concerning the conten-16 tions on which you have been identified as a' witness.
17 So, would you' state your'name and address for 18 the record, please?
19 A Business address?
20 0 That's fine.
Brian McCaffrey, Post Office Box 618, Wading
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21 A 22 River, New York, Long Island Lighting Company.
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1 Q . And, what is.your present position with the 2 Long. Island' Lighting Company?.
3' A Manager of. Nuclear Operations, Support' Department 4 within the Office of Nuclear Operations.
5 Q Okay. And, I understand from your resume that
. 6 this department has five divisions.
7 A. That's correct.
8 0 And, are you in charge of all five of the 9 divisions?
10 A Yes.
. 13 Q Does each division'also have its own manager?
12 A . Each division.is hea'ded by a division manager.
13 MS. CASEY: I would like to identify as Exhibit 14 1 Mr. McCaffrey's. resume.
15 (The document referred to is 16 marked as McCaffrey Deposition 17 Exhibit Number 1 for identifi-indexxx 18 cation.)
19 BY MS..CASEY: (Continuing) l 20 0 Who is in charge of the Nuclear Emergency Pre-i- 21 Paredness -- I'm sorry. Who is in charge of the Emergency 22 Preparedness Division?
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1 AY Doug Crocker.
-2 _Q Now,-isiMr. Daverio also-in.that division?
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3 .A No , Ju3 is not.
4 Q And',- which division is he:in charge of?
A lNone.of the divisions.- He is the Assistant 5
6 Department Manager for the Department. He. reports directly-7 to me and the five divisions and the standard matrixs of
. 8' the org'anization chart report through him to me. So,.in 9 my absence he' serves as the Manager of the Department.
10 Q Now, I also see on the'second page of your.
11 resume, it states'that from December of 1984 to April of 12 - 1986 you were assistant to the Vice-President.of Nuclear 13 Operations.
4 14 .How does that position differ from what you are
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15 doing now?
16- A That position was'a staff position reporting to 17 .Mr. Leonard, supporting his personal activities and managing-18 . the Office of' Nuclear-Opera'tions. It had no line authority 19 to the departments. '
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20 The position I.now have is.a~1ine function. .
I 21 report directly to Mr. Leonard, and the divisions report I- 22 directly to me.
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1 Q Was it a promotion for you?
2 A Yes, it was.'
3 Q Was there any change'in the actual division?
4 What I'm trying to say is, was there originally this same 5 set-up with the five operational divisions prior to May 6 1986?
7 A No. Subsequent to my arrival, we made some 8 minor reorganization.
9 Q And, were these reorganizations at your instiga-10 tion?
11 A Mine and Mr. Leonard's jointly. There were no
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12 new functions created. We simply repackaged the existing 13 functions.
14 Q So you see no significance in changing this from 15 a staff support operation into an operational division; 16 is that correct?
17 A I don't think you are understanding what I told 18 you. There is no relationship between the position you asked 19 me on first and the second one. They are two different 20 positions in the company.
21 Q Well, perhaps I misunderstood you. I ~ thought 22 you said that this set-up with the five operating divisions
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2 A The Nuclear Oparations Support Department had-3 five divisions upon my arrival. We took the divisions and
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4 we reorganized them and retitled some of them and moved some 5 'PeoPl e'around. If you add up the sum of all the functions t
6 contained in the Department today, those 'are the same 7 functions that.were contained upon my arrival.
8 Q So, would it be fair to characterize thi~s as just 9 a paper' change?
10 A Not at all. As an example,'the Nuclear Security 11 Division is a higher level to give thel nuclear security 12 function the'importance that we thought itJdeserved.
13 Nuclear Security, prior to my arrival, was a
' Portions of the former division 14 section within the division.
it was in was broken up and security was elevated to a
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. division reporting directly to me.
i 17 Q And, did the Nuclear Emergency Preparedness-18 Division -- strike that, i
19 Is there'any difference between the place of the 20 Nuclear Emergency Preparedness Division and the present 21 hierarchy compared to its status; prior to the reorganization?
22 A Prior to May?
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~J 1 Q Right.
2 A No.
3 Q Mr. McCaffrey, could you tell me generally what 4 you did to prepare for this deposition?
5 A I read the contentions, I read certain elements of-6 the LERO and on-site procedures. I reviewed a number of 7 documents from the date of the exercise.
8 And I had meetings with my attorney.
9 Q Did you read all of the contentions?
10 A In preparation for my deposition today, I read l 11 Contentions 38 and 39 specifically for today. I have q
N-s' 12 Prcviously read the other contentions.
13 Q Do you know which version?
14 A No.
Q Okay. Which elements of the on-site plan did 15 16 you review?
17 A I specifically reviewed procedures related to 18 rumor control and media monitoring, as well as general 19 Emergency News Center activation.
Q And these were -- were these the new procedures 20 21 or the procedures which were in place at the time of the 22 exercise?
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1 A Both.
2 Q And which parts of the off-site plan did you 3 review?
4 A There'are OPIPs that are related to dissemination 5 of information. I reviewed that very lightly, because my 6 major function is with the on-site program.as an emergency 7 position. I s Q I assume you.mean dissemination of information 9 to the public and to the media rather than within the LERO 10 organization; is that correct?
11 A That's correct. I was only interested in review-(~h N/ 12 ing the interface function as it supported the' Emergency News 13 Center operation.
14 Q Okay. Which documents on the day of the exercise 15 did you review?
16 A Rumor control forms, ENC rumor control log, 17 notes of a number of personnel.
18 Q When you refer to the notes of personnel, are 19 you referring to logs or to their personal notes?
20 A These would be logs, controller logs, personal 21 notes, all of which I believe were turned over in discovery.
22 Q Did you review anything else?
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.}] 1 A In relation to what?
2 O Well,-you said that in preparing for--this -
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. 3 deposition'you reviewed a number of documents-from the' day.
4 of the exercise. g-5 A Those.would begthe only documents'.on.the;' day of' 6 the exercise.
- 7 Q So'you didn't, for example, look at any LERO 8 messages?-
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4 9 A. There were LERO messages from the day of the'.
L 10 . exercise, so I-would have~ looked at press releases,._both
.. 11 LERO and LILCO... As I looked at the' documents', fit would have 12 been the normal docunents used in manning the News Center I 13 that day and disseminating information.
14 So, the incoming information_was LERO press 7*
releases,- LILCO press-releases.' So, yes, I'v_e' looked at 15 16 those.
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! 17 Q EBS messages, did you.look at any of those?
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! ' 18 A I don't think so.
19 Q How about copies of transmissions to the district 20 offices and call boards, did you look at any of.those?
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21 A No . '
22 Q Have you yourself prepared any documents to be l-
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Li i used in this exercise litigation?
2 A I've worked with my attorneys on documents, yes.
3 Q Could you describe these documents?
4 MC. McCLESKEY: If what you want to know from Mr.
5 McCaffrey is if he personally has prepared any documents, 6 the answer is no.
7 If you want to identify what documents he has 8 worked on with his attorneys I have no problem with that.
9 I think going beyond that will be getting into attorney / client to claim; and, in addition, if what you really want to know is 11 what his responses to the' contentions are, I think you can
,c, 12 just ask him that because none of these documents -- well, 13 let's just leave it at that.
14 BY Mh. CASEY: (Continuing) 15 Q Well, could you just tell me quickly the types of' 16 documents and what areas they dealt with?
17 A Summary disposition motions on 38 and 39. They 18 dealt with responses to the contention as framed.
19 Q Have any documents been prepared for this litiga-20 tion under your direction or supervision?
21 A In the emergency planning litigation, that comes 22 under me. So, any document and all the documents that are
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I being prepared are_done in my organization.
2 O' So, is LILCO itself preparing documents?-
3 A- Our people are' working with Hunton &. Williams 4 .and preparing documents.-
5 Q And, again could you.give me a general idea of
- 6 what kind of documents are being prepared? Are.you working
7 on the timelines,'for example?
i 8 FG . McCLESKEY: Well, I will just respond by g saying, Ms. Casey, that obviously we are preparing testimony.-
I 10 We'are going to hearing in March'.
, gg And, beyond that I think if you want to know what
12 Mr. McCaffrey is going to be testifying about you can ask' 13 him that. The documents that he' is preparing with his' 14 attorneys come under the attorney / client privilege of' work 15 Product.
16 MS. CASEY: I'm not trying to inquire into any
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17 privileged areas. I just wanted to know what type of docu-4 18 ments the people working for him have been preparing.
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l 19 MS. McCLESKEY: Well, perhaps you could ask Mr.
I 20 McCaffrey other than those sorts of privilege documents 21 whether he has prepared any documents.
22 MS. CASEY: Okay, s
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21 BY MS. .CASEY: (Continuing) 2 Q Mr. McCaffrey,.with that. annotation, have you
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3' prepared any documents other than privileged documents which
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4 will be<used in the litigation?
5 A None myself.
-e Q But, I asked if any ha've been prepared under your 7 direction or supervision?
8 A Yes.
9 Q What are they?~
10 A We have prepared documents on timelines.-
11 Q Did people in your division-work on the~ ENC 12 timelines?
13 A Yes.
14 Q And the road impediments timeline?
15 A Road impediments were indicated on the'timelines.
16 Q You mentioned that you have begun to prepare 17 your testimony; is that correct?
18 A That's correct. Summary disposition motions.
19 Q When did you first.get involved in planning for 1
20 the February 13 exercise?
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21 A I was never involved in planning.
22 Q Do you consider training to be planning for the .
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I exercise?
2 A No.
3 0 When did you first get involved in training and 4 drilling of the emergency response plan?
5 MS. McCLESKEY: I'm going to object.to the 6 question as irrelevant, but you may answer it. ,
7 THE WITNESS: Years ago. We continuously 8 Prepare.
9 BY MS. CASEY: (Continuing) 10 0 It says on your resume that from November 1981 11 to December 1984 that you had overall management of the N/
12 Shoreham emergency preparedness program. Could you give me 13 a general description of your duties and responsibilities 14 in connection with this?
15 A Just give me a moment.
16 (The witness is looking at a document.)
I 17 During that period, I had reporting to me the 18 on-site emergency planning organization, 19 Q At this time, did you have any involvement with 20 off-site planning?
21 A I'm having the trouble with the dates of when 22 LERO began, but my recollection is yes, because during this (m.
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1 period I think we determined we were' going to produce the 2 LERO concept and my personnel were involved in the prepara-3 tion of that as well as the preparation for litigation.
4 Just for completeness, the inclusive dates on 5 here should not be meant to imply that during the total 6 range of those years I was managing emergency planning.
7 Functions were coming in and out during the period.
8 Q For example, you have written here that "Overall 9 Corporate training for emergency positions is included in 10 this function."
11 A That's correct, on-site emergency planning.
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' ! Q I don't see here that it says this is confined 12 13 exclusively to on-site.
14 A During that period, it would have been confined 15 to on-site, because on-site is a piece of a graded exercise.
16 0 If you can think back to the months immediately 17 preceding the February 13th exercise, can you tell me what i 18 sort of involvement you had in planning for the exercise 19 including drilling, the training program, on-site or off-site 20 functions?
21 A As I said --
22 MS. McCLESKEY: Excuse me. I am going to object
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1 as'irrelevent to any pre-exercise' training-questions; and, 2 in addition to our general objection on relevancy; grounds,.
3 I'm< going to particularly object to; going'into,in any kind 4 of detail-the on-siteitrainingLprogram generally. I' don't 5 .have any problems having Mr. McCaffrey answer a few ques-
.6 tions about the on-site training as it' relates to.iumor' 7 control, although I do think that is irrelevant.'
8 But I'm certainly not, going ~to.have him go into 9 the on-site training; generally.
10 MS. CASEY: Okay. 'Well,.perhaps I should clarify.
11 I'm not specifically interested in training. What I'm trying to get'an idea of is what Mr. McCaffrey was doing in-
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12 13 the period immediately preceding the' exercise.
14 So, maybe I should just rephrase'the question.
15 MS. McCLESKEY: Tha't will be fine.
16 BY MS. CASEY: (Continuing) 17 0 okay. When did you first-learn that there would 18 be a FEMA-graded exercise?
19 A I'm not sure I recall the date. Some time, 20 1985.
21 Q And you can't narrow it down anymore'than 22 that?
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.1 A No.
2 Q From whom did you learn that'there~would be such 3 .an exercise?
4 A I dont' recall.
5 Q Once you did find out thatLthere was going to be 6 an exercise, what did you do to get ready for it?-
7 A At this point, I was Mr. Leonard's. assistant; 8 therefore, I had no line function in the preparation for it.
9 My preparation for it was restricted solely to 10 the' preparation for'the exercise in my role in the emergency it preparedness organization. Therefore, I was involved in
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12 drills and other training sessions, in' addition:to my 13 normal annual requalification for the' position.
14 Q So, are you saying that your. activities were
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15 confined to preparing to execute your role as a player-in-16 the exercise? -
17 A Correct.
18 Q Did you have any meetings with anybody about the 19 exercise?
20 A Undoubtedly.
21 Q could you tell me about any of these meetings?
22 A I couldn't recall the specific conversations if O
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=O that's what you are after. I certainly had to be involved 1
2 Lin discussions with Mr. Leonard in theicourse ~of his normal 3 staff meetings in assuring that the-organization was ready 4 to support the FEMA-graded exercise, that we were at a full 5 state of readiness through training.-
6 Q So, these were not discussions related to your 7 role as a player; is~that-correct?
8 A Some were, because my role changed. prior to the 9 exercise, a few months prior. I took the position that --
10 I took the position I have right now some timeJin the Fall 11 of '85 as the technical spokesperson.
f l 1; Prior to that, I had an engineering role.
- t O And, what did you-do to-assure Mr. Leonard that 14 the organization was ready to support the exercise?
A It wasn't my role to tell him that. It was the 15 16 role of the Department Manager of-the Nuclear Operations Support Department, plus the management of LERO, to tell I 17 18 him that.
19 Q Were you present when they told him this,'these 20 things?
21 A LERO, no. On-site, yes.
22 Q Did you watch any pre-exercise drills during this O
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1 2 A 1Where? Here or elsewhe're?. What's the question?
! 3 Q Pre-exercise drills,-for starters,Jof'the LILCO
- 4 _ plan?
5 A I participated in drills.
6 Q Did you. participate in all these drills in your 7 role'as on-site spokesperson?
4
- 8 A Early.in '85,-I was. participating as the' Engineer-t 9 ing Support Coordinator.at the EOF. Later on in 1985, I was 4
[ 'to Participating aslthe company techn~ical spokesperson.'
11 Q Did you.ever participate in these drills as an 12 observer?-
13 A. Prior to the' exercise, no.
14 Q Okay. In one.of your previous answers, you
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15 seemed to in'dicate that you had observed drills.at-other 16 nuclear power plants; is~that correct?
17 A Yes, it is, t- 18 Q And, do you recall what drills you observed and 19 when?
20 A It wasn't a drill. It was a FEMA-graded exercise.
21 I attended the Turkey Point FEMA-graded exercise in January.
22 of 1986.
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1 Q I'm sorry, I didn't catch the name of the 2 facility.
3 A Turkey Point.
4 Q Did you attend any others?
5 A I attended a drill at the Ginna Nuclear Power 6 Station.
7 Q And, when was this?
8 A Perhaps three years ago.
9 Q Did you attend any other FEMA exercises or 10 drills?
. 11 A No.
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N-a 12 Q Have you attended any since the February 13th 13 exercise?
14 A At other utilities, no.
15 Q wny did you attend the exercise at Turkey Point?
16 A I was new to the position of technical spokes-17 person, and I wanted to observe my counterpart at another 18 utility perform in a FEMA-graded exercise to determine how 19 they conducted their business and to observe the entire 20 EOF operations.
21 Q Did anyone else from LILCO go with you to this 22 exercise?
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1- .A Yes.
2 Q Who?
- 3. ,A There wa's Darrell Langford.
4, 4 O Anyone else?.
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5 A No. l l
6 Q Have you attended any drills or. exercises-~at 7 Indian Point?
< 8 A No.
9 -Q .How about.the' drill at Ginna, why did you
. 10 attend _that one?
l 'I t A Itiwas in a time when I was involved in managing-12 emergency planning during the' period that you previously As part'of my education,.I wanted.to observe
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14 another utility's operations so I got myself invited asian
- 15 observer.
! 16 Q By whom?
17 A I don't recall.
, 18 Q Arelyou familiar with the exercise objectives to that are listed in the FEMA post-exercise assessment report?
l- 20 A Only insofar as I read it after it was issued.
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- 21 Q So, you never saw these objectives prior to i
22 the February 13th exercise; is that correct?
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1 A Correct.
12 Q- --Did you attend any meetings;where. the'se cobjectives 3 werel discussed prior to-the February 13th, 1986 exercise?
4 A lha.
J 5 Q. Were the'objec'tives~ discus' sed:at any of the 6 training sessions y'ou-attended prior-to the exercise?
7 A No . .
Did you participate in the--Decemben 3rd'and 4th 8 Q l
9 drill, December ~3rd and 4th, 1985 drill?
10 .A I don't recall specificallyfunless youcan tell 11 me what teams were drilling.
O'- I'm' afraid I couldn't-tell you thaE.
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12 O Did-you 13 Part'icipate in the January 29th and 30th, 1986 drills.and j 14 training. sessions?
15 A I believe I-did.
!. 16 Q In-what capacity?
! 17 A Technical spokesperson.
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18 Q Can you tell me what facilities or drills then 1
! 19 that drilled?
I' li 20 A I can't recall whether all the' functions. drilled.-
I l 21 I drilled at the News Center, which was my post. I can't 22 recall whether all the other functions were drilling in their i
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.2 O So; the: ENC was' activated'.in-this' drill; is that 3,
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A Tita c's my recollection. ;
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5 Q Was rumor' control acti.vated?
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6 A If the ENC was activated, it was.
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' Were the district ' of f' iced and call ~ boards activat--
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9 A I don't know.
10 Q Do you know if any simulated rumor messages
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11 were introduced during this drill? s i (~)
(/ 12 A I don't recall specifically'. -
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$ 13 0 Were there any =cdia simulators at this' drill?
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':s i 14 A I can't, j recall.} When you"dyill as often as we 15 do, it's tough to recall who played olh what particular day.
j 16 Q Can yf ou give me 'a rough idea of how many drills -
,j .g7 there "have been J.n which the' ENC was activated?
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18 A For what period of time? ,
19 Q From November of 1985 to the present? , t t
20 A Perhaps 15 to 20.
21 Q -
Of these approximately 15 to 20 drills, can you 22 recall how many occurred prior to February 13th, 1986?
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1 A No.
2 O Would you say it was more than five?
3 A Undoubtedly.
4 Q Now, I'm talking about the time frame, November '85 5 to February 13th, 1986.
6 A And your question was prior to the exercise and I 7 couldn't recall exactly how many.
8 0 okay. But you said in the November '85 to 9 February 13th period you believe there were more than five; h 9 is that correct?
11 A Your question is November '85 to February '86?
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\' O Right.
12 13 A Probably it exceeded five.
14 Q You said that on the day of the exercise, your 15 position was on-site spokesperson. Do you still fulfill that 16 E01G?
17 A Yes, I do.
18 Q Could you just give me a general idea of your 19 duties and responsibilities in this role?
20 A As technical spokesperson.
21 0 Technical? I'm sorry, you said you were 22 technical spokesperson?
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O 1 A I'm the company's.. technical spokesperson in the 2 on-site organization.
3 Q- Okay.. What are your duties and responsibilities?
4 What do'you do?
5 A My job is to be at the News Center, directly-6 reporting to the Emergency Communications Director. My role' 7 is to maintain full and. timely cognizance.'of the developments 8 at.the plant, the actions of the Response Manager ~at the.
9 EOF, and prepare information for press conferences that I (
10 conduct jointly with LERO and the Emergency Communications' .
11 Director.
12 My functions also include' maintaining' cognizance 13 of. rumors coming into the' company for. purposes of. heading 14 those off at press conferences if we see a repeating pattern.
15 My function also includes observing the media monitoring" 16 area to see if there are any issues that warrant being ad-17 dressed in subsequent press conferences to correct informa-18 tion that a particular news program would have aired.
19 My job is also to brief the LERO organization on 20 technical developments at the plant, to exchange information 21 in a timely fashion with their operations so that when the 22 press conferences are conducted they are coordinated and the O
if ,
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1 1 information is-consistent..
2 -Q.
. Anything else? >
3 A I review-' press releases prior to issuanceffor
? -4 accuracy.
[ 5' Q' Do you review-both LERO and LILCO-press releases?
6 A: LILCO. .
Now, you say you-report to the Emergency Communica-
~
- endT1A' 7 -Q a tions Director?-
9 A That's a recent change. The day of the' exercise, j- to I reported directly to the News Manager..
11 O Why was the change made?.
12_ A We have taken some of the functions associated 13 with Public Information.tha~t were located at>the: Emergency 14 Operations facility and relocated those to the EmergencyLNews 15 Center to consolidate those areas. dealing with~public 16 information and to help expedite the issuance of LILCO press i 17 releases.
How does your reporting.to the Emergency Communica-18 Q
., 19 tions Director.rather than the Emergency News Manager effect.
20 this change?
21 A I'm not sure I follow the' question.
22 Q Well, you said that during the exercise you
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I reported to the' News' Manager but you now report.to an.
32 Emergency Communications Director;and that the reason for 3 this change was because certain fu~nctions have been~ taken out 4 of the' EOF --
5 A That'sEnot what I said.
s -Q~~ -- and relocated to the ENC in order'.to consolidate 7 the public --
8 A1 .Let meLexplain again.
9' O -- information functions.
-10 A I said we have consolidated public information 11 functions / from the Emergency Operations facility to the ENC.
n'"' .12 Associated with that, but not related to.what drove that, 13~ we' simply changed my reporting to the Emergency Communications f 14 Director. So, both the News Manager and I both report to I -15 the ECD.
16 Q Is this ECD an entirely new position?
17 A No.
L 18 0 So, in the previous-procedure.there was an f 19 Emergency Communications Director?
l' 20 A That's correct.
I 21 O I guess I'm just not clear on the change.
22 A Simply a geographical change.
O L
s
- i. ' > '
, 29
.~ ,
1- Q 'Where is-the: Emergency' News. Manager located?
2 A Ati the(ENC. m, -
T ,
3 Q Andwh'ere'isthdbCDloca'ted?
4 .A At the ENC today.
5 -Q :Okay. 'And in the past he~~was at the-EOF; is that.
6 what you are telling me?'
7 A Correct.
8 Q .Thank you. Is the ECD still considered'an on-site 9 position?
10 A Yes.
11 Q .Despite-the' fact that-he'is.now at the ENC? ,
12 A It doesn't change the' des'ignation. He is in the 13 on-site program.
14- Q You also said that it was part of'your duties 15 to keep. cognizant of what was going on.at'the plant. How 16 did you do this?
- 17. A Number one, the people that.were selected to be 1s the' technical spokespersons in the organization-were{ selected
~
19 based upon their past involvement directly in the design 20 and construction of the plant. Number two, I have on my 21 staff at the Emergency News Center plant engineers who work 22 at the nuclear power station who have intimate understanding O.
30
?8 --
(._,)
1 of the workings'of the plant. l.They are in phone communica-2 tion directly to the EOF and TSC to give me as current in-3 formation as is humanly possible'such that when'I do a 4 press conference it is very timely information.
5 So, I have all the technical support I need right 6 where I am.
7 0 Okay. I understand that you have the' technical 8 support. I guess what I'm trying to get at is how did you 9 actually get the information?
10 You said that you wer'e in phone ~ communication 11 with the EOF?
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\-
\
12 A Sitting at the Emergency News Center.we have 13 access to information from the Technical Support Center, 14 the Control Room and the Emergency Operations facility in 15 addition to whatever LERO can tell us in our communication 16 briefings.
17 I receive, and my technical people receive, at 18 the News Center telecopied information on plant status boards, 19 Rex forms and other technical information from the plant. We 20 supplement that with phone calls to assure that our assess-21 ments of what is going on, our perception of what is happening 22 at the plant is correct. And we get updated information, bm
31 f~N t )
v 1 So, we are cognizant all the time of what is the 2 latest development at the plant.
3 Q Okay. Now, this description you just gave -- j i
4 A -Let me just finish that. As well as what actions 5 the Response Manager is taking at the Emergency Operatior.s 6 facility when he is in command.
7 Q- Now, is -- can you tell me, is this the same a set-up as existed on the day of the exercise?
9 A Yes.
10 Q And there has been no change in the form of 11 communication between the plant and the EOF-and the ENC; r3 12 is that correct?
13 A That's correct.
14 0 Once the EOF and the ENC are in the sama building, 15 will there be any changes in the forms of communications 16 you just described?
17 A It might even be better. Instead of making a is phone call, I can now walk downstairs and see what's going 19 on.
20 Q You also stated that you would exchange informa-21 tion with LERO. Can you describe for me how you did that?
22 A When I had information, either early on when we O
O
32
~(v )
1 first activated,.I would go visit the LERO representative 2 or they would visit me and we would exchange information as 3 to what we were seeing from our respective organizations.
4 During the course of the day'as information was 5 updated, I.would routinely walk down the hall, visit the 6 LERO organization, talk to the technical spokesperson there 7 and exchange the latest information I had to assure i t was 8 consistent with what they were getting. If there were any 9 inconsistencies, we would both go back to our respective 10 organizations and determine where the differences were, such 11 that when press conferences were conducted or press releases 7
s' 12 issued they were consistent.
13 Q On the day of the exercise, for example, how many 14 LERO persons would you say you had contact with?
15 A My primary contact was with my counterpart who I 16 conducted the press conferences with who is the LERO spokes-17 Person. The spokesperson functions in a separate office at 18 the ENC and has a staff reporting to her. In that-case, it 19 was Plaine Robinson that day.
20 So, that day she had a fairly sizable staff per 21 the LERO procedures supporting her activities at the ENC, 22 much like I have a staff supporting mine at the ENC.
I x-
33
.g-1 LQ So, beyond Ms. Robinson,and whatLI assume would 2 be the public information staff, did you have any contact ~
' ~
~
3 with'other off-sit'e people?'
~
4 A None. r 4
5 Q You also said that you observed the: radio 6 monitoring area. lCould you tell~ me'what'this involved?
7 A I termed it media monitoring.
8 0 I'm sorry, media monitoring..
9 A As part of the on-site' organization, we have an 10 area designated for training personnel to monitor -both 11 . radio and t.v. media, to observe the~ type of coverage that O 12 .is.being given-to-the information being released'to the 13 public. On the day of the exercise, I would routinely go 14 down there and inquire what activities were taking-place.
15 And, on occasion they would play it-back-for~me, That's 16 prior broadcasts, so I could. hear what was being said.
17 the purpose of correlating,to what we have said in press 18 conferences to see if the media were' airing the information 19 consistently and correctly.
All right. What kind of training did these 20 0 21 personnel receive?
R 22 A The media monitoring personnel are trained in
w
.34
, /N h_l I' don't-1 accordance withLthe LILCO plan. -The:specif ics, t
2 recall.- .
V 3 0 . Wodld this be in?accordance with'the~on-site 4 plan or the'. off-site plan?
. Yes, the lon4 site plan.: ' Media monitoring is-an
~
5 A 6 'on-site function.
7 MS. CASEY: I guess we have already asked for i .
8 sections'of the.on-site plan, but-that would be another
, 9 section that we would be interested in'seeing.
10 MS. .McCLESKEY: Yeah. I will look'into that.
11 My recollection -is that when Ms. Letsche 'and I had that i 12 correspondence.a year ago, we noted that the-Suffolk County-i 13 police, your client, routinely received a controlled copy 14 of the on-site plan and I believe that you-all get anything 15 you want from them.
16 But, I will double check that and make'sure that 17 that's the case. And you-all may want to call them yourself.
18 BY MS. CASEY: (Continuing) 19 Q You also mentioned that -- I believe you said 20 one of the purposes of your media monitoring is to correct 21 misinformation. And I believe you also said that you-22 would review on-site information in LILCO press releases so O
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35 g;
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I that you and LERO would be putting out consistent informa-2 tion.
3 Can you tell mefif during the exercise you had 4 any occasions where'you did'have to reconcile, for example, 5 a LERO press, any LILCO press release?
6 A I wouldn't have dealt with a LERO press release 7 anyway. It's an off-site function.
! 8 But I want to go back to the way you began the g question which infers the primary focus of the media monitor- (
10 ers is to support my inquiries; it is not. That was a 11 function we added to it to enhance our press conferences.
k- 12 The media monitoring people report directly to 13 the same' function, that is rumor control. And it's an 14 essential funnel to feed back information.
g3 Now, your question was whether I observed any 16 media releases that warranted correction. I --
g7 Q Well, maybe I'm misunderstanding what you said.
18 I thought the idea was that you would have contacts with 19 Ms. Robinson and the LERO organization in order to make sure 20 that both the on-site and the off-site organization were 21 giving consistent information.
22 A Correct.
(0
36 q
V 1 Q But now you say that you did not see any of the 2 LERO press releases; is-that correct?-
3 A I would review information with Ms. Robinson 4 during the day. I don't recall if I specifically looked at 5 any LERO press releases. I probably did.
6 They are posted in'the' LERO offices; they are 7 posted in the press rooms. It would probably have been 8 inconceivable if I didn't look at them from time to time.
9 What I'm trying to say is that it was not my role 10 in the on-site organization to bless off on those press 11 releases prior to release. My major function was to make p
~
12 sure that Ms. Robinson was fully aware of developments at 13 the plant, such that she knew real time what was happening, 14 such that when she was reviewing the LERO press releases 15 coming along she could flag whether there was an inconsistency ,
16 It's not my job to flag a LERO inconsistency in 17 their press release.
18 Q Okay. Well, that was basically my question.
19 Were there any instances where you noticed an inconsistency 20 between, for example, information being put forth by your l
- 21 organization and information being put forth by the off-22 site --
l (")1
A 37 e3-b A. I don't recall any.-
1
~
2 0 were there any instances where you realized that-3 you and Ms. Robinson'had, inconsistent linformation?
4 'A I don't recall the specifics that day. The reason 5
I say that'is between all the. drills.we)dealtin and the 6
FEMA exercise, there are many times when we would find --
7 not many, but sometimes' we would find inconsistencies and a we would talk about them.-
g I just'can't sit here and recall whether it was 10 a drill day or FEMA day and those type things.' If there-11 were inconsistencies, we talked about it.
12 0 Did you speak to Mr. Kowieski at all on the day 13 of the exercise?
14 A Excuse me. I didn't hear the question.
15 0 Did you speak to Mr. Roger Kowieski at all on e ay of de exercise?
16 17 A Never met him, never talked to him.
18 0 Did you remain at the ENC throughout the period 19 of the exercise?
20 A Y"8*
21 0 So, you never left the ENC?
22 A Correct.
O
38 rm
.v'
- l 1 Q I notice that at some of the press briefings, 2 I think at least on one occasion if my memory serves me 3 correctly, you 'said that you would like to leave the briefing 4 in order to get more updated information.
S Where were you going to get this information?
6 A Back to our office at the News Center. _
7 Q So, both LILCO and LERO had offices at the News 8 Center?
9 A That's correct.
10 Q And, anybody else?
11 A There was nobody else. We have offices set up
,s
- k/ 12 for other entities, but they weren't there that day.
13 Q Did you keep a log during the exercise?
14 A I did not.
15 Q Did you take~any notes?
16 A Yes, I did.
17 Q IIave those notes been turned over to counsel 18 for LILCO?
19 A I doubt it, because I can't -- I don't know where 20 my notes are.
21 MS. CASEY: If !!r. ficCaffrey's notes are located 22 and they have not been turned over to us, we would request a O .
39 k) copy of them.
I 2 MS. McCLESKEY: I will state for the record-that 3 Mr. McCaffrey's notes have been diligently searched for and 4 that Hunton & Williams does not ha~ve~'them and has no record 5 of ever having received them.
6 In addition, Mr. McCaffrey cannot find them. And, 7 I suggest that you ask him to describe them for you.
8 BY MS. CASEY: (Continuing) 9 Q Could you describe them for me, Mr. McCaffrey?
10 A Sure. On the day of the exercise, the way I get 11 ready for briefings for LERO as well as the press conference
\ 1 12 which is to talk to the EOF, talk to my staff at the ENC, 13 compile a timeline of developments at the plant and the status 14 of significant equipment, put together the' picture of what 15 I see at the plant, review any press releases issued prior 16 to that time or prior to activation of the News Center, and 17 then structure the points that I want to emphasize in the 18 press conference that we would then subsequently go do.
19 That's what would be on the notes. Throughout the 20 day, you would simply see more of the same, block after block 21 after block like that.
22 O Could you describe the rumor control operation for
(~)
v
40
/ m.
\~j 1 me?
2 A Rumor control is an organization of personnel at 3 the Emergency News Center who are~in contact with both the 4 News Center Manager and the . district offices and the call 5 boards. Their role is to receive inquiries from people call-e ing into district offices or call boards, assure those in-7 quiries are logged, responses are obtained, reviews of those a responses are obtained and that correct information is then 9 forwarded back to the point at which the inquiry-came into 10 the company.
11 Q Now, is the News Center Manager the same as the I
k>-
12 Emergency News Director?
13 A No. You are confusing some terms.' The Emergency 14 News Manager, the ENM, reports to the ECD, who is the 15 Emergency Communications Director. Rumor control function 16 reports to the Emergency News Manager.
17 Q So, all rumor control personnel are on-site; 18 is that correct?
19 A That's correct.
20 Q How many rumor control people were there.at the 21 ENC on the day of the exercise?
22 A Including the management structure, somewhere b) u
41 0
t around six to ten people, more like ten maybe.
2 O What is the management structure? Ms. Robinson 3
started to tell us about that this morning but said she 4 didn't know the chain of command. ,
5 A What you have are people who sit in a location 6 and they have people they report to. They receive phone 7 calls from district offices or call boards. One of.the personn al a there is responsible for keeping the log. This person, upon g receiving an inquiry, would request an ID number. Those are 10 the ID numbers you see on the rumor control sheets that you gg have.
)
(~/
k-12 The rumor, or more correctly the question that is 13 being raised since few of them are really rumors, would then 34 be written down. The management of that organization would 15 bring that to the Emergency News fianager for a determination 16 of whether the information can be responded to by either 17 LERO or LILCO, and then that piece of paper will go off on 18 its way to get an answer, would come back with an answer, 19 that answer would be reviewed by the Emergency News Manager l
20 for his concurrence or changes, and it would go back to the I
! 21 rumor control personnel.
22 The log would be updated to show the time of the 4
(._
I
42
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_)
I return of the answer and the response would go back out to 2 the particular district office or the~ call board that the 3 inquiry came in from.
4 Q Okay. Now, after the rumor control person --
5 strike that. .
6 When a rumor control person receives-a call from 7 one of the' local offices, district offices or call boards, a does that person himself log it in or does he take it to 9 another place to be logged?
10 A That person fills out the rumor control form.
11 You will note when you look through the~ control form, an n
N' 12 ID number is in the upper left-hand corner. A separate per-13 son is maintaining a log of that. That person logs the :ID 14 number, tells the person filling out the form the ID number 15 to put on it and writes down then the gist of the information 16 from the form, such that the log then indicates the general 17 information that was being requested.
18 O Okay. And then does the person who originally 19 filled out the rumor question take the form over to the 20 Emergency News Manager?
21 A No. Their structure, their management structure, 22 does that.
O
43 s
k_ ,
1 Q What I'm trying to do is follow the rumor or the 2 rumor message form.
3 A One of their management people would.take the 4 piece of paper and send it on its way, while that person
~
5 continues to sit there receiving additional calls.
6 Q Okay. So, after the recepient of the. call gets 7 the now identified or logged in message-back, he or she 8 would give it to a rumor control supervisor?
9 A No. It comes back through'that supervisor.
10 The person that brings it out for the answer brings it back 11 with the answer.
("
12 Q You are' ahead of me.
13 A It's logged out.
14 Q You are ahead of me. The rumor control person 15 who is taking the calls, receives the phone call of a rumor.
- 1s IIe or she writes down the rumor, takes it somewhere'to be l
17 logged in and given an ID number.
18 A The logging is as close as we are sitting here.
19 So, I simply sit here and I say to you: Give me a number.
20 Would you give me a number? And you give me a number.
And that's the extent of the logging in? For 21 0 22 example, I would not have to give you the question for you Q
'u)
44 m
/
1 to look at and make notations in your log; is that correct?
2 A Let me go through it slowly. I write down the 3 inquiry. I've asked you for a number. You give me a number.
4 That way you don't have multiple numbers being handed out.
5 As soon as I finish filling it out, I give you the 6 sheet. You then. lift from it the essence'of the question 7 so that when you look at the log you_can tell the general 8 idea of what was being questioned. That's how you know what 9 goes on in your ENC log.
10 Then, supervision takes it to get an answer.
11 Q Okay. Now, then supervision takes it to the n
(\ ') 12 Emergency News Manager who makes a decision as to whether 13 this should be answered by the off-site organization or by 14 the on-site organization; is that correct?
15 A That's' correct, on the' day of the exercise.
16 Q Okay. I will get back to that.
17 A We have changed it subsequently.
18 0 okay. Now, Ms. Robinson gave us a pretty good 19 idea of what happens to the rumor, if it is an off-site 20 rumor, up to the point where it comes back to the Emergency 21 News Manager.
22 Could you tell us what would happen to the rumor b,
s_
45 Ns-1 sheet after that?
2 A -After it comes back with a LERO answer on it?
3 0 Right.
4 A It comes back to the Emergency News Manager who 5 would then concur with it and pass it on to the rumor control 6 organization.for logging in the return of-the answer.
7 Q To whom would the1 Emergency News Manager hand it?
8 A Well, it would be supervision-in rumor control.
9 0 okay.
10 A Again, the people'that are filling out the 11 sheets are not getting up moving pieces of paper. They are (s\-) 12 sitting there filling out subsequent sheets.
13 Q So, the supervisor would see that it got logged 14 in; is that correct?
15 A That's correct.
16 Q And then return it to the original person who 17 took the call?
18 A It wouldn't necessarily have to be that person.
19 It could be anybody. And then forward it back to the call 20 board and log out the time that took place.
21 0 So then one of the rumor control personnel would 22 call up the originating office?
O
46
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_/
1 A That's correct.
2 0 Suppose the Emergency News Manager had made the 3 initial determination that the rumor'should be~ answered by 4 on-site personnel? Again, I'm talking about the day of the 5 exercise. What would happen to the rumor message once the 6 Emergency News Marager.had determined it was an on-site rumor?
7 A The people in the' room would give him the answer.
8 It could be one of the technical people.
9 0 Was there any formalized system for that, or would 10 he just say: Hey, I've got a question.- Can anybody answer 11 it?
(
k3/ 12 A The management people in rumor control, having i3 drilled so often, . generally know who to talk to in a given 14 type of a question. So, it's no magic to them deciding who 15 they should talk to.
16 They know what the resources are in the room. They 17 know where they can get it. If it isn't readily available 18 there, because we are tied into the EOF, they could go 19 elsewhere to get additional information. If we need to get 20 information frca the plant, we can contact the Technical 21 Support Center. We can get it there.
22 Q And, who would write down the response?
O (J
47 s
v i A I don't recall who is actually putting pen to 2 paper and writing that response out.
3 MS. CASEY: Off the record.
endTlB 4 (Off-the-record.)
5 MS. CASEY: Let's take a break.
6 (Whereupon, a recess was taken at 2:40 p.m.,
7 to reconvene at 2:52 p.m., this same day.)
8 BY MS. CASEY: (Continuing) 9 0 On the day of the exercise, what did the media 10 monitoring people actually monitor?
11 A Radio and television.
I'~)
l N/ 12 Q And, what sort of -- do you recall what sort q[
13 coverage they wrote about or told you about?
14 A They basically covered all the major channels, 15 t.v. channels, 2, 4, 5, 7, 11, cablevision, 55 and covered 16 the major radio stations, and they would actually watch them i7 live and tape them so even if a broadcast had occurred a 18 half hour or an hour earlier, I would inquire whether there 19 was any significant ones and they would show it to me.
20 0 So, you did see tapes or hear recordings on what 21 they had monitored; is that correct?
22 A Yes.
O
48 N ,.e' 1 Q On the basis of your viewing of these tapes or on 2 the basis of other information you got from the media monitor-3 ing. people, was there any media misinformation i at you 4 corrected on the day of the exercise?
5 A I don't recall any. I thought the coverage was 6 pretty good, given that they were generally delayed broad-7 casts.
8 Q And, did you discover any rumors that you felt 9 had to be addressed in press briefings?
10 A I don't think so, t_ t Q Can you recall the content of any of the tapes A
\-) 12 or videotapes which you reviewed?
13 A YOS*
14 Q Could you tell me about some of that?
15 A I watched myself on t.v.
16 Q That was it?
i7 A They played it out on t.v. They had radio 18 broadcasts I was able to listen to.
19 So, basically we saw replays of press conferences 20 we conducted in addition to stand-up broadcasts that the 21 media people conducted either in the hallways or outside.
22 O So, was -- were the media monitors monitoring just
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(_)i
s 49 l'
- O .I stories dealing with the actual events of the' exercise?
2 'A That was their focus. But if there was no broad-r 3 cast on, whatever was on t.v._at that time was playing.
4 10 We know that you were-the.~on-site:spokesperson and 5 Ms. Robinson was the LERO spo'kesperson'. 'Did anyone other 6 than the two o f you speak at the press briefings held during 7 the exercise? - -
8 A Ye s '. '
l 9 -Q Who?
- 10 A Darryl Langford, the Emergency, News Manager,
- -and l
l 11-two scientists from.Brookhaven National Laboratory..
12 .O And what' organization is Mr. Langford affiliated 13 . with?-
~ ~
i- 14 A He was affialiated with LILCO when he was the
'15 Emergency News Manager.
16 Q Is that no longer true?
i 17 A Correct.
18 0 Ih) you know who he'is affiliated with now?
19 A I think it's Intercom Systems Company, Atlanta.
1 20 0 So, I take it he is no longer participating in --
21 A That's correct.
22 0 -- any exercises or drills? And, how about
<O
50
,s U the two scientists you mentioned from Brookhaven Laboratory?
1 2 Did they participate in any drills or exercises prior to 3 the February 13th exercise?
4 A Yes, they did.
5 Q Did any other Brookhaven scientist fulfill this 6 role in any other drills?
7 A Not that I'm aware.
8 0 And have these two scientists participated in 9 drills following the February 13 exercise?
to A I don't.know, because I haven't been in all the 11 drills. We have multiple teams that drill. I function on
('s
~
12 one particular team, so I can't attest'to who was at the 13 other drills.
14 Q Were they at any of your drills or any of the 15 drills you attended?
16 A Since February? No.
17 Q Did anyone take their places?
18 A No. Typically what you do if they are not there 19 is, you would simulate their participation.
20 Q Which LERO shift are you on? I'm sorry. Which 21 LILCO on-site shift are you?
22 A I'm Team One.
O V
r 51 p
-Q 1 0 Who is'in overall command:of.the1 ENC?
'2 A Today or the' day of the exercise?
3 Q Well, let's start with the day of the' exercise.
4 A The Emergency News Manager,_although even'on the 5 day of the exercise'the Emergency News Manager reports to 6
the ECD, but he sits at'the EOF.
-7 So, the reporting change did not change. The 8 person-that was in: command at thesNews; Center was the News
(
g Manager at-the' day of the exercise.
10 Q- And,;I'm'~sorry if you have already:gone=over this 11 with me, but now is the Emergency News Manager, is tha't an' 12 off-site' position?
13 A - On-site.
34 Q On-site? And the ECD is zul on-site. position; 15 is that correct?
16 A Correct.
17 0 'So that in actuality, LILCO rather than LERO has-18 overall command of the ENC; is that correct?
19 A That's correct.
20 Q Now, is that still true?
21 A Yes.
22 Q Ms. Robinson mentioned this morning that the O
52
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(_)
1 emergency operations facility is being moved. Can you tell 2 me why it's being moved?
3 A Our lease is up.
4 0 Did you attempt to renew your lease?
5 A No. The company decided it would be a prudent 6 move to move the EOF basically a 100 yards away-across the 7 street to a new training facility that was constructed and a which would house the simulator, thereby enhancing the EOF g operation for having it in the same facility as the simulator.
10 0 What simulator? Or, what is the simulator?
11 A The simulator is a large computer-based operation fJ
\- 12 where you duplicate in every respect the controls and the 13 panels of the contr'ol room at the nuclear plant and have 34 the computer-driver scenarios that would activate various 15 gauges, lights, alarms as if the operators were in the 16 control room in a real emergency and program in various 17 activities and test the operators on that operation.
18 Prior to that we were renting time at the Limerick 19 simulator. However, we made a corporate commitment to spend 20 a large amount of money and to build our own specific simula-21 tor.
22 O Why did the company deternine that this would be
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53 n
.]
1 a prudent move?
2 MS. McCLESKEY: I am going to object to this 3 question. -It's irrelevant. You can answer it, but I am 4 going to instruct the witness not to answer any further 5 questions about this area.
6 It seems totally unrelated to any of.the contention s 7 you have filed.
8 MS. CASEY: Well, this appears to be one of the 9 changes that has been made in the ENC, on-site and off-site 10 Operations, since the exercise. And I feel it's relevant 11 to Contentions 38 and 39.
,R
\- 12 MS. McCLESKEY: Well, I may have misunderstood, 13 but I thought your question was why does the company think 14 moving the EOF to the training building is a prudent move; 15 and I think that's totally irrelevant to your contentions, 16 because the EOF is not the ENC.
17 MS. CASEY: But it will be now housed in the same 18 building as the ENC; is that correct?
19 TIIE WITNESS: That's correct.
20 BY MS. CASEY: (Continuing) 21 Q And didn't you tell me earlier that you thought 22 that that might improve your ability to get information (a
f 54 O
V 1 'l quickly from the Emergencyf0perations Facility; isn't that 2 right?-
~
3 MS. McCLESKEY: I think you are mischaracterizing 4 what Mr. McCaffrey said. What he~said was that in the. future i
5 he will walk down the stairs rather than making'a phone call,
! e and that's all he said.
7 BY MS. CASEY: (Continuing) 8 0 So, why did the company believe it was aLprudent.
4 2
9 move to move the EOF into the same. building as the ENC?
j- 10 A The' decision to move the EOF 'was nade 'at a time i 11 when the ENC had no plans to move tofthat building. It was 12 a totally nutually exclusive decision.
i.
i 13 O Do you know why it was decided to move the ENC 14 into the same building as the EOF?
A Our lease was up at another facility and we had l 15 4
18 space available in the training facility, and it was in the
! 17 right geographical location for having a news center.
i 18 0 Ilave any ENC drills taken place in this new l 19 facility?
20 A The facility is not ready to accommodate-the EOF.-- ,
t 21 the ENC yet, 22 Q So, I take it the EOF is already there; is that f
4 6
4 3
t
_ - . . _ , . _ . . _ _ _ _ . . . _ _ . . _ _ . _ . _ . _ _ _ . _ , . _ . . , _ . , . . _ , _ . . _ _ ~ _ _ . _ _ _ . __ _ .._. _ _ _ _ _ _ _ _.._ _ _ _ _ ,~.
55 n
s I correct?
2 A The EOF is currently transitioning from its 3 current location to the~new training facility. It's essential ly 4 almost there.
5 Q And when is it predicted that the ENC will be 6 there?
7 A April 1.
8 Q Would you, in fact, go downstairs to the EOF and 9 ask them for information during a drill, do you believe?
10 A During a drill or even a real emergency, I 11 would not be inclined to go down there routinely because I would not want to interfere with their activities. Ilowever ,
12 13 on a given point there is nothing to preclude my walking 14 down there and talking to the same people I would do on the 15 phone if their schedule permitted.
16 0 Will there be a new plan revision, whether on-site 17 or off-site, to reflect the move of the ENC and/or the EOF 7 18 A It would'have to be a revision for the on-site plan 19 to show all the physical change of the ENC from one part of 20 Long Island to another part of Long Island, yes.
21 Q Would there be a revision to the on-site plan?
22 MS. McCLESKEY: Asked and answered.
56
?~ .
1 BY MS. CASEY: (Continuing) 2 0 You may answer.
3 A That's what I just answered.-
4 0 I'm sorry. I thought I said the off-site plan.
5 Will there be a revision to the off-site plan'to reflect this a change?
7 A It would have to be at some point. It would be a a very minor change because the function doesn't change. All 9 that changes is where it sits.
10 0 Have you seen any plan changes labeled or 11 characterized as Rev 9?
12 Fts. McCLESKEY: Objection. Irrelevant.
13 BY MS. CASEY: (Continuing) 14 0 You may answer.
15 A No.
16 0 Have you heard about any such changes or proposed l 17 changes?
18 MS. McCLESKEY: Objection. Irrelevant. In 19 addition, in order to answer the question I think you ought 20 to make it more specific and tie it somehow to this witness' 21 role in this litigation.
1 22 BY MS. CASEY: (Continuing) i U)
57 "h
(G 1 Q Will Rev 9 contain, or does Rev 9 contain, 2 revisions which were' adopted to reflect the move of the 3 ENC?
4 MS. McCLESKEY: Objection. The question assumes 5 the existence of Revision 9 which the witness has already 6 said he has never seen anything of.
7 BY MS. CASEY: (Continuing) 8 Q Itave you heard anything about a Rev 9?
g MS. McCLESKEY: Objection. The question is vague 10 for the reasons I stated two objections ago.
11 BY MS. CASEY: (Continuing) 12 O Ilave you heard of anything called Rev 97 13 MS. McCLESKEY: Objection. Same objection.
14 MS. CASEY: You may have a continuing objection.
15 MS. McCLESKEY: I'm going to instruct my witness 16 not to answer a vague question like have you heard anything g7 about Rev 9. IIe is being produced to respond to specific 18 contentions about the exercise.
19 BY MS. CASEY: (Continuing) 20 0 D y u understand the question, Mr. McCaffrey?
21 A I find it vague.
22 0 llave you ever heard the term "Rev 9" used?
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58
,q Y]
1 MS. McCLESKEY: Objection. Irrelevant. You 2 can answer if you want to. .
3 MS. CASEY: I'm simply trying to clarify the 4 question for the witness.
5 TIIE WITNESS: Only that it would follow Rev 6, 7 6 and 8.
7 BY MS. CASHY: (Continuing) s 0 llave you ever heard that term vocalized before o today?
10 A No.
11 0 Could you describe for me any changes made in 12 the rumor control on-site procedure since the publication of 13 the FEMA pre-exercise -- post-exercise assessment report?
14 A We revised the rumor control procedure, which is 15 one of the four series procedures --
16 0 I'm sorry, one of the?
Four series,-F4rl,,4,d,),f lj,j tf 37 A 4 3r3, whatever. They are al L 18 four series for public information. We revised the 19 procedure to reflect the option to go around the Emergency 20 News Manager to obtain an answer to a rumor inquiry, thereby 21 expediting getting that answer. That was a change.
22 He have revised the procedure to reflect the new O
59 1 program by which a LERO summary sheet would be sent directly 2 to the front-line emergency call boards and district offices a from the EOC, such that they have timely summary information 4 available to respond 'to inquiries. That would be reflected 5 in the on-site procedures as taking place.
e Q Any other changes?
7 A on your question of rumor control, no.
8 Q Okay. What is going around the Emergency News 9 Manager? Does this mean that nobody makes any decision as to to whether off-site or on-site should answer? Or, does it 11 mean that all rumors go immediately to on-site?
12 Can you explain that to me?
13 A It means that the management of the rumor control 14 organization having drilled and been trained on exactly 15 where to go for the answer, and they simply go get it.
16 0 So, your answer implies that there has also boon 17 a change to the training program for the rumor control 18 peoplet is that correct?
19 A Any time we have a change to any on-site or off-20 site procedure, we train ,everybody associated with those 21 procedures.
22 0 What kind of training do you use to get people to O
l 60 O i make that sort of substantive distinction?
2 A I don't know personally. The personnel in my 3 organization do the training and they take care of making 4 sure that happens and based upon test results they confirm 5 whether the training is adequate to instruct them.
6 0 Do you know what these tests are like?
7 A only insofar as the tests I have taken for my a position.
o 0 Well, for the rumor control personnel, for 10 example, would there be tests giving simulated rumors and 11 asking then to distinguish whether the on-site or the off-12 site organization should respond?
13 A I don't know.
14 0 Uho in your divisions might have that kind of 15 knowledge?
16 A Doug Crocker, who I identified before as the 17 Division Manager for Emergency Preparedness, is responsible 18 for implementation of all training programs.
19 0 Anybody else?
20 A The personnel under him.
21 0 Would any LILCO consultants be involved in these 22 training changes?
O
61 O
V A Yes.
1 2 O Why did you make these changes in the rumor 3
control procedure?
4 A They were done to reflect lessons learned from 3
previous drills and the FEMA-graded exercise and to improve 6
the responsiveness of the organization. That's the purpose 7 of all the drills.
8 And, when we find that the way that we are conduct-g ing business can be improved we routinely and regularly make 39 changes.
O Itave there been any drills since these new pro-11 cedures were in place?
12 13
^ YO8' 14 0 were you satisfied with the results of those drills?
15 16
^ UU*
17 0 Was there any measurable improvement?
18 A I don't personally know the measure of improve-to ment. The personnel that report to me in emergency prepared -
20 n as have advised me they seem to be working fine.
21 0 Did he give you any further description than 22 that?
O
62 4 m
U t A No.
2 Q What changes have you made in the ENC procedures 3 since the drill?
4 A The four series procedures, one of which is 5 rumor control, is in the ENC procedure.
6 Q Okay. I think we have pretty well covered 7 that. Did you make changes in any other ENC procedures?
8 A The changes associated with the relocation of o the Emergency Communications Director to the News Center to proper had to be embodied in the procedure change, also in 11 the four series.
12 0 Now, what was the substance of the change?
13 A Organization chart showing who reports to who, 14 physically where they are located, and the text that.goes 15 with it to show the flow of information at the News Center to and the function of the ECD with relation to all the people 17 who now report to him at the News Center.
18 0 okay.
19 A One of the changes I described before was I now 20 report to the ECD, not the ENM.
21 0 Did you have any involvement in changing the '
22 off-site ENC procedures since the exercise? l
(
4
63 1 A Since the LERIO organization reports to me, 2 yes, in that regard it was delegated.
3 0 And what changes have been nade in those ENC 4 procedures?
1 5 A I have not reviewed the procedure, the OPIPs, 6 in detail. But the essence of the changes provide the i
7 pipeline directly from the EOC directly to the customor a call boards and district offices with the sunmary shoot, 9 in addition to direct telecopy of the LERO press releases.
10 And it may not be teletyped, I'm not sure whether lg it's a !!arris -system or telecopied. Probably a liarris system 12 directly; that is, it's a main framo system direct computer 13 terminal to computer terminal. I think it's what I've just 14 described thero.
g3 COURT REPORTER: That system was what, pleaso?
16 Tile WIT!!ESS: A Ilarris computer terminal system, g7 a computer based system to provido the information.
ga BY F1S . CASEY: (Continuing) i 10 0 Now, other than those changes you havo just 20 liuted, are you aware of any other changes to either on-sito 21 or off-site Etic procedures?
22 A No.
64
~ OA/ m Okay.
1 MS. CASEY: I would like to have marked 2 as McCaffrey Exhibit 2 a copy of a.nemo,' dated August 19th, 3 1986 from John D. Leonard, Jr. t o Douglas M. Crocker.
4 (The document referred to is
$ marked as McCaffrey Deposition 6 Exhibit Nunber 2 for identifi-indexx 7 cation.)
8 DY MS. CASEY: (Continuing) 9 0 Okay. I just wanted to ask you a couple of to questions about this, Mr. McCaffrey.
) 11 Havo you soon this memo beforo?
I 12 A May I have a moment?
13 0 Suro.
14 (The witness is looking at the document.)
15 A Yo8-t l
16 0 okay. Ilave you soon it with those handwritten 17 annotations beforo?
l 18 A on which part of the document?
j to 0 Woll, if you look through on the firnt page in 20 the lower right-hand cornor, then on Pago 3, Pago 4, Page 5,
) at Pago 6, Pago 7, Pago 8, Page 9 and so on, it apponra that 22 somebody made a handwritten updato to the memo.
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i_____--_______-__-_________-_-_-___-
65 1 A I recall the mark-ups in'here. I'm not sure I 2 remember the mark-ups on the cover page.
3 0 All right'. Now, if you will look on Page 4 of 4 this exhibit, this seems to indicate that the changos involv-5 ing the simultaneous transmission of information to the call e boards was going to be practiced in drills.
7 Does this refresh your recollection as to whether a or not any drills have boon held using the now procedure?
9 A Are you on ECD, ENC-17 i
10 0 Yes.
11 A ftay I have just a moment?
12 0 Yes.
13 (The witness is looking at the document.)
14 A Okay. What's the question?
i3 0 lias the now procedure involving a simultaneous 16 transmission via computer to the 1:NC and all rumor control 17 locations boon practiced in drills?
18 A I don't know.
to 0 Now, Ms. Robinson indicated that thoro havo boon 20 drills involving computer transmission to ENC, and I just 2 wondered if you know whether they have tried this proceduro?
22 A I don't know.
O
66
[vb i 0 Do you'know who summarized this -- the information?
2 A What information?
~
3 0 Well, according to the proceduro, essential 4 omorgency information will be put in a summary form. I just wondered if you know which position was responsible for
~
3 o summarizing the information?
7 A No.
a O If you would look at Page 8 of the same exhibit, o next to the LILCO response to the EOC-8, there is a hand-go written notation which stated, "Ponding FEttA review of SNPS 11
'FCitA 43' report on siren syntom. Schedule uncertain."
12 Sinco August 1986 is what in stated in that 13 notation still true?
n (The witness is looking at the document.)
g3 A The typod words are correct. I'm not sure I know to what a rnftA 43 in.
17 Q IIan LILCO nubmitted any reports to FEttA for 33 review, any reports on the niron nystem for roview?
i to itS. ficCLESKEY: I object to the quantion as totally 20 irrolovant to the exorcino litigation.
21 You can annwor if you know, fir. ficCaffroy.
22 Tilt WITNESS: Could I hear the quantion again?
l i
67 O
V i t BY !!S. CASEY: .(Continuing) 2 Q IIas LILCO submitted any reports on its siren i
3 system to FEMA for review? l 1
j 4 MS. ficCLESKEY: I will object to that question l 5 as vague. When? In the'lifatime'of the' plant?
6 !!S. CASEY: Since the February 13th exerciso.
7 Ti!E WITNESS: I don't know.
8 BY tis. CASEY: (Continuing) i o O If you will look at Pago 9, around the middio of to the pago, the typed LILCO responso'is, " Schools will bo l
} 11 requestod to participato in future exorcisoc."
12 Itavo schools boon requestod to participate in 13 futuro exercinen? l i 14 !!S. ficCLUSKEY: Objection. Irrolovant. You may l 13 answer if you wish, i
to Tile WITNESS: I don't know.
l 17 BY !!S. CASEY: (Continuing) 4 la O tir. McCaffroy, you indicated that you have already I
to begun drafting tontimony on contentional in that correct?
20 A Yos.
2 Q Do you have a copy of the contentionn with you?
22 A I don't.
C:)
l
68 1
V) r
, t !!S. !!cCLESKEY: I have a copy which I will be 2 glad to sharo with fir. McCaffrey.
3 ftS. CASEY: Thank you.
4 MS. !!cCLESKEY: You are welcome.
5 DY MS. CASEY: (Continuing) 6 Q Can you give me a gonoral idea of what you are 7 planning to say in connection with Contention 387 a (Tho witness is looking at the document.)
i
> 9 A !!y testimony will respond to the on-sito portions
(
10 of the various subparts, most of which as I recall aro LERO.
I 11 Q Woll, could you identify for me which p.1rts you O
\' would bo intending' to tastify on with that distinction in 12 13 mind?
14 A Yos. 30.A, 38.D.
is 0 38.D?
! to A correct. 30.0, 38.P, 38.Q.
17 0 And what in the gist of your testimony going to I is bo in connection with 30.A? l 10 !!S. CASEY: Off the record.
I 20 (Of f-tho-record . )
- 21 HY MS. CAUUY: (Continuing) 22 O okay.
(
4
69 1 A Could I hear the question again?
2 0 What is the gist of your testimony going to be 3 on Contention EX-38.A?
4 A It's obvious I haven't finalized my position on 3 any of those but I will give you my impressions at this l e point.
7 The first fact being that the fact that the first a press briefing was not hold until 8:40 does not suggest a that thoro was no contact or supplying of portinent informa-to tion to the nodia prior to that time.
- That the activation timo for the News Contor was 12 perfectly appropriato. That's the gist of it.
is Q Will your testimony specifically be addressing 14 the issue rained in the last sentonce of 38.A?
i is A Yes.
16 0 How?
I i7 A ny providing a clone picturo of how nitornativo to and primary information was already being provided prior to
- to the activation; and in the nchomo of thingn, the information 20 nupplied at the Nown Contor nnd the nown conforoncon was 21 not the primary noann of providing information for the I
22 public.
() __
[
70 t'
\"] 3 0 Okay. So, would it be fair to characterize 2
your pr posed testimony at this point then as saying that ossentially there was no delay in ge'. ting:.information to the 3
4 public?
3 A tty position would be that the timing on providing the information was suitable, given the regulations and the procedures in place.
7
, O What information was provided to the media prior to the opening of the ENC?
A The media woro provided with LILCO press releases.
10 0 Yon.
9 A They woro provided with Ens nossages.
12 0 Whoro did they act them?
g g A It's ny understanding that the Ens nossages woro innued by the Director of Local Responso and that goes U Y " "" U"' 0' "Y 0 " " O ""
la g7 for oither activation of the EOC or the ENC to dinseminato g,
that information, that the prior two docunonts I indicated woro rolonned prior to the facilition being activated and to then ronuning an additional loval of disnomination of informa-20 tion to tho media.
21 22 0 How, woro hard copion of LILCO nrons rolcanon O
i
71
(~>
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I disseminated to the press from any place besides the ENC; or 2 when you referred to LILCO press releases, do you essentially f
3 the hard copy of the first two EDS messages?
4 A When I said information was provided, means it 5 was given to the news nodia by the public information organiza- -
6 tion prior to the activation of the ENC, and they consisted 7 of LILCO press releases and the EBS message.
8 Q So, actual LILCO press releases were handed to o members of the media before the ENC was opened; is that what to you mean?
11 A Prior to the ENC being opened, there are no 12 press at the ENC. The public information organization la providos that information to the press through their channels.
14 Q So, how did the Public Information Offico got is those releases to the press, given that thoro was no place to for the press to moot the PIO people?
17 A The Energoney Communication liaison is working is with the Emergency Communication Director by phono immediately to an unusual ovents and alerts are dociared. Press roloanos 20 are prepared jointly with them, and they are released to the 21 media.
22 Uxactly the mechanics of how that ploco of paper O
I
72
,O
'J t gets to the media, I would have to refresh my memory with 2 the EPIPs.
3 Q So, are you saying that on the day of the exercise 4 some member of the media had a LILCO hard copy press release 5 in his hand prior to activation of the' ENC?
6 A I don't khow exactly how that front-end worked 7 prior to my arriving at the ENC. My assumption is that at a that point the handing of the document would have been 9 simulated.
10 0 Dy whom to whom?
11 A Dy the Emergency Communication liaison and the O
\l 12 ECD, using the four series procedures which spell out how 13 they would do that.
14 Q I assune those four series procedures you are 33 referring to, those are the on-site procedures which --
is A These are the emergency planning implementing it procedures that I call EPIPs, E-P-I-P-s.
is 0 Are those on-site procedures?
19 A They are.
20 0 So, you have no personal knowledge of any member 21 of either LILCO or LEno having contact with a member of the 22 media prior to the ENC activation?
O
73
,A ._
(_)
. A That's correct.
2 Q okay. And what was going to be the gist of your 3 testimony in connection with 38.D?
4 A The gist of this one is that in the new ENC 5 location, you will'not only have a number of dedicated machines 6 we are bringing from the existing ENC but now having moved 7 into a 115,000 square foot building'that houses a large a number of personnel, there is a huge copying capacity in the 9 building which we would have total access and priority for.
10 0 Were you aware that during the exercise LERO 11 workers were told to ingest potassium iodide at approximately C) b 12 9:45?
13 A I don't recall.
14 0 And, what would your testimony in connection 15 with Contention EX-38.0 be?
16 A I'm sorry, 38.0 you are on?
17 0 Yes. I believe that's one that you identified.
is (The witness is looking at the document.)
to A Okay. I haven't formulated a position on that.
20 0 In your opinion, is it important for the media 21 monitoring peopic to be abreast of current information 22 coming out of the plant?
O
74 1 .A In the hierarchy of things,..I don't. regard it as 2 - very important at all. .Tha~t is, the media monitoring 3 -personnel are simply monitoring the media, radio and t.v.'s; l
4 and, therefore, 'whether :there is}a shorti delay- between the 5 information should not make'a large difference.
6 Q Maybe I'm misunderstanding'the! function of these 7 media monitors. Do they just sit and, literally monitor a what is before them and then just Nait for somebody to come.-
o ask them about it, or would they be expected to view what to is front of them for inconsistencies.with the'information 11 they have?
12 A You've got a lot of parts to.that question. Who 13 are you suggesting comes to inquire from them something?
14 Q Well, apparently during the exercise you did; 15 is that correct?
16 A That's correct, but as far as whether they have 17 press releases is immaterial to what I need from them. So, la that's a non-point.
19 Q That wasn't my point. I'm trying to figure out, 20 do they just sit there and monitor or are they expected to 21 take some action?
22 A My recollection of their procedures are that they O
i I 75 Y
1 -are supposed to. observe inconsistencies 1and inaccuracies ,.
2 between what we are.giving out and what'the press is saying.
3 0 So, is it fair to say that in-order to determine 4 whether the pres ~s isimischa'racterizing the/information you 5 are.-giving out, they need to know what information you~are.
^
a giving out?
7 A Well, if you look at the' timing on here, if you 8 look at the timing between ;8:45; and 9:05 lto .9:31, these
-9 people are looking at delayed broadcasts from media monitor-to ing personnel. You could probably delay-it by an hour and it they would still be ahead of what the press is'saying, O
12 because what they are seeing is something that was reported g3 on events that took place a half an hour, two hours, an 14 hour ago.
15 0 So, you are saying that the media monitoring 16 personnel should have this information at some point, but g7 the particular times referenced here would give you no cause 18 for concern; is that a fair characterization?
! 19 A The times here'give me no concern. And, yes, i
20 they should have the information. My recollection from the drill though was that -- and this is subject to verification, 21 i
22 but I believe they also had a monitor of our press conferences
}
i l
}
i
76
(^T LJ 1 that they could watch at the same time.
2 Q And, could you tell me what your testimony will 3 be'in connection with 38.P?
4 (The witness is looking at the document.)
5 A The first point will be obvious., I will correct 6 the contention. The public information people'from LERO 7 do not control rumor control, so I basically will describe a the operation we have'already been through here as to how g rumor control functions manns it.
go And I will describe how it is effective.
11 0 Will you' describe --
12 A And, I will describe improvements we have made to 13 make it more effective, g4 O So, I would infer from what you've just said g3 that it's your position that the rumor control operation 16 was effective on the day of the exercise; is that a fair g7 statement?
18 A Yes, it is.
19 0 And, what is your proposed testimony on 38.O?
20 (The witness is looking at the document. )
21 A My position would be that the dissemination of 22 information was good to start with. And, as I've said before, O
77
( 1 on any drills we've done we always look to learn, and I will 2 describe the improvenents we made and how that will shorten 3 the time frame for providing current information to where 4 people need it.
5 Q Do you have any data or proof to support the 6 assertion that the improvements described will shorten the 7 time frame?
8 A The first proof is going to be simply that we 9 understand how the paper flows through the process and, 10 therefore, these fixes were' designed to improve that process 11 so inherently they have to make it better. All that matters
\
12 is the demonstration, and that is subsequent drills will have 13 shown that.
14 And I would expect by the' time I submit testimony 15 I will have that information.
16 Q So, there have been subsequent drills tes' ting 17 these new procedures?
18 A I believe I've said before I don't recall.
19 Q But you expect to have this data?
20 A Yes.
21 Q Is an extra LERO spokesperson going to.be added 22 at the ENC?
subsumed contentions 8 Q l 9
- 9. into 39? If.you'look on Page',58, I.think'that's wher~efthey 10 start.
~
I 11.
(The witness is looking at the document.)
f
!' Q A/ A 44.. This is the'one' dealing-with evacuation.
12 13 shadow?^
f
} 34 Q Right.
4 15 A -No.
16 Q Would you be' offering testimony on the:-- what is 17 sort of the' predicate of the. evacuation shadow issueiinathat 18 contention? The'first sentence is.the exercise revealed a n
- 19 fundamental flaw in the'LILCO plan in that as a' result of 20 LILCO's' inability to provide accurate, clear, consistent and non-conflicting information to the public. Then, it goes 21 22 on to say as a result of this there would be a voluntary r.
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. - . - - . . - , . . - _ , . . . - - , - , . . . . . , . . , - - - , , , . = - . _ . - . . , . _ - . - - , . . . - ,
-79
/ ~.
%,y 1 evacuation.
2 A I'm confused by the cuestion. What we just dealt 3 with will address the front-end of this.
4 Q Okay. And, how about 22.F?
5 (The witness is looking at the document.)
6 A No.
7 Q And, I'm sorry, there is still more.
8 A What page?
9 Q Page 61. Contention 42 has also been subsumed.
10 (The witness is looking at the document.)
11 A No.
12 -Q Now, if you would go back to Page~52, do you 13 think you could summarize for me what your testimony will 14 be on that contention?
15 (The witness is looking at the document.)
16 A Start with 39.A?
17 0 That's right. That's the first oneyou said you 18 will be testifying about.
19 A Again, my position is as it's evolving but I will 20 tell you generally where we are~now.
21 (The witness is looking at the document.)
22 I don't recall all the admissions, so I am going
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.1 to assume the' time framescare correct. -l 2 ,Q I will represent'to you that most of the' time ~
3 frames have been admitted.
4 A On 39. A (i) , the position would be to refer.to 5 the changes in the system to provide. summary information
~
6 directly to the l call -boards and district offices as well as-
, the LERO press releases' via the computer system which should
~
7 8 improve the time' frame.
9 But, notwithstanding that the EBS system is the to primary means of dissemin'ating information to the' population, I
- 11 that the press conferences are the second most important f N- l'2 means of. providing timely- information, and tha't responses to 13 individual inquiriesL-- and this one is not a rumor, it's 14 simply a question -- is ranked -in that position,: and that 4
15 the time frame'is not necessarily unacceptable,.but nonethe'-
16 less we are going to improve'it, and it chould be dramatically 17 improved.
18 -Q Would you say anything else, or is that pretty 19 much all --
20 A That's it, on 38. 9. A (1) .
21 Q I'm sorry, 39.A including all the small Romans.
22 A I was just focusing on (i) at that point. But, do
-- g n,, , -,- --wm . ~-,-,-,,,.,w.,-, .e... -e.,,e, e n m .. - ~ - . . . - ,- , a w ,,---,-,,,-s--,--- --,,- a- -r. .
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81 D 1 you want me to say something on A, the block, the text here?
2' O On Contention 39.A, as well as small Romans -(i) 3 through .(v) which essentially are.given as examples?
4 A Okay.
5 (The witness . is looking at the document.~)
6 Q Okay. ;
7 MS. McCLESKEY:. I'm sorry, I' don't understand. Do a you want him.to tell,you in specifics:- ,specifically in 9 response to (i) through '(iv)' wha ~t he is going to say. to 10 ea'ch of those little' subparts?'
11 MS. CASEY: No. In fact, if what he' would say to 12 the other subparts is what he ha~s already said, then that's 13 fine.
14 MS.-McCLESKEY: I think he gave you that_ general --
15 I thought the question was generally how you are responding 16 to 39.A, and he did.
17 BE . CASEY: But then he' told me'tha't that response 18 was confined to (i).
19 THE WITNESS: I was respohding to (i).
20 MS. McCLESKEY: Okay.
21 BY !$ . CASEY: (Continuing) 22 O If your response'to the others would be the same, O
( ..
82
()
I then you don't need to tell me anything more.
2 MS. McCLESKEY: Off the record.
3 (Off-the-record.) j
~
4 THE WITNESS: It's the general -- it's the same 5 general theme as on (i), and that is that the general process 6 of providing a response is to the front lines, was timely but it's going to be improved, and that one must recognize that
~
7 8 it is impossible to provide instantaneous information to 9 anybody and get it right and keep it consistent.
10 And, therefore, by definition in any system there ,
11 is going to be a time delay. What we are doing is trying to
[]
x- 12 reduce that to the smallest practical time frame.
13 BY MS. CASEY: (Continuing) 14 Q And, would it be fair to say that that is the 15 general tenor of your testimony at this point --
16 A Yes.
17 0 -- as far as all of the subparts to 39.A?
18 A Yes.
19 0 Okay. If you would look at the next one that 20 you identified which I.believe is 39.B, at this point do 21 you believe you will have testimony on that content:Lon which 22 would be materially different from what you have said would ,
l'
(
83 ,
-1 be-your testimony on Contention 39.A?
-2 (The~. witness is looking at the ' document'. )- L 3 A Essentially the 'same with' the difference being
~
4 that each of these examples, I generally find the time frames-5 perfectly. appropriate..
6 0 So, in your opinion, none of 'the examples listed :
in 39.B gives an example'ofia'ilag time-thatJwould cause
~
7 a concern to you? I's that'a fair characterization?
9 A Yes.
10 0 And at this point, what is vour proposed testimony 11 in, connection with 39.C? ' : t
.k' 12 (The witness is looking at the document. ) '
13 A I'm sorry, I lost the~ train of-the question.
14 0' Could you tell me what,' at this. point, you are
- ?
15 proposiftg to testify to in - connection with .Contentioni 39.C',-
16 including its subparts?
17 A I'm generally going to conclude that the responses t
I 18 were-provided in a reasonable time frame and it would seem 19 that the overall evacuation of the' masses would have had no 20 effect on any of that.
- .f- ,
21 0 So, would it be fair to say that you.have no j
u l
.! 22 problem with the substance of any of these responses?
L O~
u
84
/ \
L) 1 A If you would just give me a moment?.
2 O Yes.
3 (The witness is looking at the document'.')
4 A Given who the caller was, where they were, and 5 the information they were desiring and the overall effect 6 upon the evacuation or other protective actions, I found
~
7 all of the answers-appropriate and the time. frames acceptable, s Q What difference'~does it make who the' caller is?
9 A Your question was, did I consider them appropriate.
10 You have to look at each of the 35 rumor control messages, 11 look at where they were-living. If your concern is timing,
(~n
-) 12 you have to look at where they are. If they are 50 miles 13 from the emergency planning zone, it's of no consequence.
14 So, if you prioritize the importance of various 15 responses I would rank that one lower than another one.
16 So, you need to look at each one, the timing, the individuals, 17 is it a rumor, is it a single inquiry, would it effect 18 their own personal safety, would it effect others personal 19 safety, would it effect evacuations, would it effect shadow 20 phenomenon? All of those need to be weighed when you make 21 a judgment.
22 O Have you analyzed each of the rumor control message s es
85
%.)
1 _used during the exercise for these factors?
2 A Yes.
3 MS. CASEY: Off the~ record.
4 (Off-the-record.)
5 MS. CASEY: It should only be a few more 6 questions.
7 BY MS. CASEY: (Continuing) 8 0 Going back to what you said your testimony might 9 be in connection with Contention 38.A, you mentioned that to information was provided to the media prior to the'first 11 press briefing, and you mentioned EBS messages and press
(' And I'think we ha've pretty much covered the' press 12 releases.
13 releases.
34 But, how were the EBS messages given' to the 15 press?
16 A I don't know.
17 Q Do you mean that they would have been heard on 18 the air?
19 A Normally, an EBS message would have been aired, 20 it would have been issued by the LERO organization and the 21 EBS station would have broadcast that message.
i l
22 0 So, that'show the press or the media would have C
I l
_=
7--
86 N_]
I had access?
2 A In addition to press releases issued by both LERO 3 and LILCO.
4 Q Do you know when it was decided to move the ENC 5
into the Hauppauge building?
6 A Yes.
7 Q When was that?
8 A About thirty days ago.
9 Q Do you know, is there any intention at the present to time to change the location of any other LERO facilities 11 other than the EOC from where they were at the time of the
,~
's> 12 exercise?
13 A LERO facilities?
14 Q Right.
A Yes. A replacement for Nassau Coliseum.
15 Q Any others?
16 17 A No.
18 Q Are any of the LILCO facilities that .were involved 19 in the exercise going to be moved other than the EOF 20 that you have already mentioned?
A And the ENC, no.
21 22 0 so, you would characterize the ENC as a LILCO lao s
87 O 1- facility?
2 A It's an on-site facility.
3 MS. CASEY: I have no further questions.; Thank 4 you.
5 MR. - ZAllNLEUTER: No questions.
6 MS. McCLESKEY: I don't ha've any questions.
7 (Whereupon, the taking of the deposition was 8 concluded at-4:22 p.m., Wednesday, January 7, 1987.)
10
^ N* ~! DA' Y; kkA4 L____
BRIAN.R. McCAFFREY- / #7 11
~
12 13 14 Substdbed end swom 9 to before me mis --. day of ,
15 16 My Commission Egres #
37 18 19 20 21 22 O
88
-Di) '
1 CERTIFICATE OF NOTARY PUBLIC 2
3 I, GARRETT J. WALSH, JR., the'~ officer before whom 4 the foregoing deposition was taken, pages 1 through 87, do 5 .hereby certify that the witness whose testimony appears t
'in the foregoing deposition was duly sworn by me;-that the 7 testimony of said witness was taken by me and thereafter 8 reduced to typewriting by me or under my direction; that 9 saiddeposition{isatrue' record'of;the$estimony,given'by 10 the witness; that I am neither counsel for, related to nor 11 employed _by any of the parties to theJa'ction in which this
- 12 deposition was taken; and further, that I.am not a relative 13 or employee of any attorney or counsel employed by the 14 parties hereto, nor financially or otherwise interested in 15 the outcone of the action.
16 17 GARRETT . . WALSH,JR.[
18 19 Notary Public in and for the 20 Commonwealth of Virginia at Large 21 22 My Commission Expires: January 9, 1989 O
.( f/2C4Ffrey Ex #/
June, 1986 Brian R. McCaffrey Educationt l
B. S. Aerospace Wdng l University of Not::e Dame - 1967 '
M. S. Aerospace Engineering '
. Pennsylvania State thiiversity - 1972 Thesist. A Stasty of the Effect of a l Glove Vane on the Aerodynamic Fagdes of a Supersonic Aircraft Configuration M. S. Nuclear Engineering Polytechnic Institute of New York - 1978 Registered Professional Engineer - New York State May 1986 to Present Iong Island Lighting Ccapany Shorehan Nuclear Power Station
- Manager of the Nuclear Operations Support Department This department reports directly to the vice President,141 clear Operations and covers five Divisions; Nuclear Limnsing and Regulatory Affairs, Nuclear O Financial Services, Nuclear Security, Nuclear Scia. p cf Preparedness and Nuclear Contracts and Material Control.
Functions include primary contact with the Nuclear Regulatory remniesion,
- assessing evolving regulations, managing all nuclear litigation, and evaluating
! regulatory doctanants for impact on plant design or operation. Other l responsibilities cover cost control, estimating, budget and cost administration for the Office of Nuclear Operations, nuclear records management and administration of site clerical and adninistrative personnel. The h p cy l Preparedness area covers all corporate onsite and offsite nuclear energency planning, training, conduct of drills, staffing and preparations for the annual j FDR graded exercises. The Department also is responsible for all facets of
- nuclear plant security including all hardware, ocmputer systems, ccepliance with j federal requirunents and managenent of a 200 man contract guard force. Finally, I the Department is responsible for nuclear contract developnant and l administration, administration of site warehouses, spare parts and inventory control.
I l
\
j { 764769
n ,wnhar 1984 to April, 1986 Iong Icland Lighting Ng Shoreham Maclear Power Station Assistant to Vice President - Maclear Operations Provided direct support and assistance to the Vice President for a 700 man organization covering quality assurance, enghing, operations and all support i for the Shoreham Maclear Power Station. This position includes a working knowledge of all facets of the nuclear program. Prepares special reports and studies as directed and advises the Vice President cm matters requiring his personal attention. Maintains office continuity in the absence of the vice -
President and represents the Vice President in both industry and in-ccupany
,' meetings. Manages many special projects for the Vice President and interacts directly with senior corporate man =r==nt. Provides policy clarification and advice to the personnel within Office of Nuclear Operations.
Novannhar 1981 to narwnhor 1984 Iong Island Lighting Ocupany Shorehan Nuclear Power Station Manager, Nuclear 0:npliance and Safety Division of the Nuclear Operations Support Department.
- Primary responsibility for conduct of the Atmic Safety and Licensing (ASIB) w_-
- ='ings, <:orporate point contact for all interface with the Nuclear Regulatory hiasion, evaluation of NRC issuances and receipt and maintenance i
of the Operating License and all state, federal and lent permits for the
- Shoreham Station. 'Ihis position is responsible for development and l inplementation of the corporate regulatory strategy and policy.
l Also served as Olairman of the Independent Safety Engineering Group (ISEG) which i
has corporate responsibility for evaluation of all operational problens at other operating nuclear stations and assessment of their safety or reliability
! significance to Shoreham. The ISEG also performs surveillance and monitoring of Shoreham's operations and reconmends means to improve safety and reliability.
Responsible as Board Engineer for overall conduct of the corporate Nuclear Review Board. This position develops and inglenents the Review and Audit program as required by Technical Specifications. Responsible for administrative and technical support of the NRB.
Other respcmsibilities included overall managenent of the Shoreham Dnergency Preparedness Programs. This function includes preparation for and conduct of l drills and graded egercises. Over#1 corporate training for emergency positions is included in this function. Other miscellaneous responsibilities include overall coordination and management of information requests frcm the Institute of Nuclear Power Operations, corporate nuclear policies and all programs defining organizational relationships among departments within the Office of Nuclear. ,
O (764770 N,--.,----- - - - - , _ . _ , - - - - , _ _ . , . _ , - ,.,we.a, -.-n- A -- --n- - - - - - - --
j -
April 1980 - October 1981 Iong Icland Lighting Ompany Shorehan Nuclear Power Station Assistant Project Manager for Engineering and Licensing for Shorehen Nuclear O Power Station. Responsible for the overall engineering, project adninistration, procurunent requirements and 14-=ing of the Shoreham Station. In this capacity, directed and approved all engineering efforts of the Architect ;
mgineer and Naclear Steam m14=*. This organization was also responsible for i directing the activities 1*ing to an Operating License fra the Nuclear j
- Begulatory h 4== ion. Primary corporate responsibility for interfacing with '
3 the Nuclear Regulatory newenimairm and overall management of the ASIB pWings as well as the Advisory Comnittee m Reactor Safeguards. Licensing included all coordination, preparation, legal interfaces and condact of the ASIA licensing
- g_-Mi ag= .
January 1979 - April 1980 Iong Island Lighting Way Shoreham Nuclear Power Station Held the positim of Project Engineer for the Shoreham Itaclear Project. In this
! capacity I managed the Project Engineering Organization and was responsible for the overall LIICO Engineering management of the Shorehan 14aclear Power Station, including the Architect Engineer and Nuclear Steen Supplier. These activities 1 cover all mechanical, electrical and civil design, procurement and engineering scharbling to support the con.hsction effort.
October 1977 - Dece ber 1978 Iong Island Lighting Capany Shoreham Nuclear Power Station Held the position of Senior Licensing Engineering for the Shoreham Nuclear
- Project. Responsible for the licensing activities leading to an Operating
! License. This position was responsible for the day to day contact with the NIC and developnent of corporate positions on new and evolving regulations and coordination of the corporate effort for conduct of the public hearing before j the Atmic Safety and Licensing Board. All current and emerging regulations were assessed and recamandations made for ccupliance.
j June 1975 - September 1977 Img Island Lighting Company i
l Senior Engineer (and Imad Mechanical hgineer) in the Power Engineering l Department responsible for halance of plant engineering for both fossil and j nuclear power projects. (Nuclear projects covered are 820 W BWR and two 1150 l W IHR's.) Position included responsibilities as Project Coordinator for gas
! turbine installations. Coordinated ccupletion of one 250 W gas turbine power station and ccuplete design, bid solicitation, contract award, engineering, budget, schedule and procur m ent for a second 250 W installation. Performed various evaluations of alternative energy sources. Also, Program Manager for wind turbine projects. Submitted successful pr==al to Department of Energy for a candidata site at Montauk, N.Y.
1 i O j [764771 l
t
e January 1973 - May 1975 Iong Icland Lighting CEpany Held the positions of Amarv-iate Engineer and Engineer in the Power Engineering Department involved with balance of plant engineering cm both fossil power O stations, gas turbines and nuclear power stations.'
June 1968 - nm,- e=r 1972 Grunann Aerospace Corporatim Aerodynamics and Iceds Engineer for the design of the F-14A fighter aircraft.
Experienced with wind tunnel model testing and ocaputer modelling of aerodynmaics for the purpose of predicting maw 4== Inadings cm various aircraft '
w.-i.ts. Ibliowing ocupletion of design work transferred to the flight test
! center at Calverton, N.Y. Responsible as a Stability and Control Engineer for l predicting flight test behavior and planning and conducting flights for the purpose of ocnfirming predictions. Experienced cm hydraulic similatim and instrunentation of a supersenic fighter aircraft. Developed various cm-line ocmputer programs to perform real time calculations during actual flights.
- September 1967 - June 1968 Pennsylvania State University Research/ Teaching Assistant in the Aerospace Engineering Department. Taught
, three senesters of basic aerodynanics and aircraft design to urd y. duate students.
1 Med3er:
l j p V
American Society of Mechanical hgineers i
American Nuclear Society - Iong Island Section Electric Utilities Operation and Application Ccmmittee of ASME Gas Turbine Divisim -
1974 - 1976
~
Westinghouse PWR Orientation Course - 1979
~
ASME Section XI Inservice, Inspection -
~
Miscellaneous courses:
Engineering Econcmics Nuclear Power Welding NDE Examinations Quality Assurance O
[764772
.y. - . ,.m-_ , _ ---- . . _ . _ - - , . . , _ _ , _ . - . _ , , --._._ ._,-__e _,__ _ . . . . _ _
e Publications i i
~
A hst Fauva-a to Pztwide an Ecormic Evaluation of Techniques to control Hot Section Corrosion in Gas O Turbines C. L. Knauf, B. R. McCaffrey, J. M. Vitelli - ASME Gas Turbine Conference, March, 1976. W limbed in Gas Turbine International, May 1976 ,
~
Response of a Light Aircraft to a Thermal Exhaust Pitana F. W. Lipfert, B. R. McCaffrey, E. A. Sanlarenzo, Paulo Barenti and B. W. Mrw=4rIr Sixth (bnference on Aerospace and Aaranattical Meteorology - November 1974
'O J
!O 4
b764773 1 -
- a b [ b m
,' l b llllll hN Ib
/ Y 7
August 19, 1986 EPD: 86-0338 To J. D. Leonard, Jr.
From: Douglas M. Crocker
Subject:
LILCO's Response to NRC and FD!A Coc:=ents on E=ergency Exercise Held on February 13, 1986.
Attached are two copies of LILCO's response to the FD!A Graded Exercise held on February 13, 1986. The responses are separated into three (3) parts. They are:
Part I -
Open Items identified by the NRC Part II -
Deficiencies identified by FEMA
) Part III - Area (s) Requiring Corrective Action identified by FDIA The Item (ls used in our report correspond to Tables 3.1 - 3.10 in the FDtA Post Exercise Assessment Report. Should you have any questions on thispeport please call c:e at 420-6225.
Douglas M.
S./ ~
rocker, Manager 01 Nuclear Energency Preparedness DMC:CLK:cf M C. Mp5C. d cc: B. M. McCaffrey C. A. Daverio a y d g, Q gg ngkak.%
C. L. Krieger Files # 12.5, 22.0 desu. b h b kus M Oh kh M '
D yok h m- V esM e 5 pie c.s.c. c.a me c.t ed 2V n % sJ
~
L 810000
l
(
C) c "'5" "5" ' ""c ^" "^ ca"'"'S ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 During the Shoreham exercise the onsite energency respectively.
response organizations were eva(luated by the NRC and F identified ' Deficiencies' and ' Area (s) Pequiring Corrective Ac <
The following tables identify these items and detail LILCO's response. The item numbers report. used in Part II and III correspond to Tables 3.1-3.10 in the FEMA In general, where additional training is the identified action, the training material course content has been revised and will be the next round of training to be held during the fall of 1986. presented during pART I
'OPEN ITEMS' IDENTIFIED BY THE NRC ,
I O
1 l
1 i .
i lO 310001 Page 1 of 17 I
l e . .
l LILCO's RESPONSE TO NRC AND FMA COMENTS ON MERGENCY EXERCISE HELD OR FEBRUARY 13,1986 PAPT I '0 PEN ITEMS' IDENTIFIED BY THE NRC (continued) r b
I O
i
.1 1
l 4
1
- O 810002 Page 2 of 17 :
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i
)
O 'co' = ars'o"$r 'o "ac ^"a aa caar"'s ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 PART II - DEFICIENCIES InDITIFIED BY FEMA These items must be corrected feediately by LERO.
ITEM f RAC RECOMMENDATION LILCO RESPONSE E0C-1
' Delays in responding to the two (2) evacuation impediment free-play Procedures have been kt b i
messages inserted at the LER0 E0C were reviewed and revised h 6/80/8' caused by the failure to infom the ensure infomation on impediments is promptly Evacuation Coordinator in a timely passed to all relevant manner. In addition there was a lack personnel and a coordinated of Internal comunication in response response implemented. In to these impediment problems. addition, a Traffic
- Pertinent infomation was not included Engineer has been added to i on the 1045 and 1106 LERO Message the LER0 E0C staff to Foms from the Evacuation Route assist in evaluating road Coordinator to the Evacuation Support impediments and developing l Communicator for Ro.te Spotters / Road
- A Crews regarding the simulated alternate routing. .
i 'U impediment involving the gravel truck ' g~te, and fuel truck problems. As a result The Traffic Guidance Table wp ,
i Top TT-6 has been modified '
' of this lack of information, the i
impediment problems were not analyzed to the to incorporate procedures. the changes A LnN.
in a timely fashion and incomplete .
equipment was dispatched to handle the gravel truck impediment in the field. Internal comunications .
kS Jpc_ , _ j g5 a procedures should be reviewed and i
revised as necessary to ensure that goc.kibi6- . T Ount-infomation on impediments is promptly l
passed both up the chain of command to the Evacuation Coordinator and downward y* P CD and laterally to all lead coordinators under the Evacuation Coordinator and nemm( * '
their staffs. Additional training is i
needed to ensure that the procedures, .'
whether new or current, are properly implemented. All coordinators at the EOC, and those who initiate messages,
' must be trained to include all pertinent i
" infomation on the LERO nessage foms and to analyze the equipnent requirements to clear impediments, ,
i' O t i
. 810003 Page 3 of 17
LILCO's RESPONSE TO NRC AND FEMA C094ENTS ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 PART II - OEFICIENCIES IDENTIFIED BY FD4A (continued) 1701 # RAC RECOMMENDATION LILC0 RESPONSE EHC-1 Insufficient copying capabilities at Copying machines in the ENC the ENC resulted in delays in the are being evaluated for distribution of information. These upgrade and replacement as delays affected the following two (2) pecessary. J areas:
o Hard copies of EBS messages Nea fLn y+ der or machohis{da to, ksu en hen
- ptevJenkm xpedite M were not provided to the media dissemination of in a timely manner, information, procedures \
o Rumor control personnel were not have been revised.(6/JO/88)
Essential emergency able to answer questions received information will be put in q from the public because they were summary fom and
-Q not given accurate up-to-date simultaneously transmitted status reports. via computer to the ENC and all rumor control locations.
LERO should make provisions for g gegQ i reliable and rapid equipment to V reproduce, in hard copy, all ded,lC appropriate messages for distribution to the ENC staff.
PATCH-1 Bus drivers were not dispatched until There is no requirement to two (2) hours after receipt of the dispatch bus drivers within Site Area Emergency ECL declaration, two hours of a Site Area Emergency. The dispatch of (1) An additional area should be bus drivers was within the established for the distribution times detailed in the LERO of dosimetry to reduce Bus Driver pl an, processing time. L )
T (2) Additional trained staff should be provided to the Bus Dispatcher to W % Ff.MA
\
j assist him in deploying over three no (tu-ch'A b g
- hundred (300) drivers and Transfer Point Coordinators who are deployed from the Patchogue Staging Area.
l Q .
L 810004
! Page 4 of 17
_ . . - =-
O LILC0's RESPONSE TO NRC AND FRA CGNENTS ON MERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 PADT II - DEFICIENCIES IDENTIFIED BY FNA (continued)
ITN e RAC REC 094ENDAT!0N LILCO PESPONSE t
PATCH-6 A Bus Driver took two (2) hours and . LER0's investigation of the ten (1) minutes to proceed from the problem revealed that staging area to the transfer point, during past det11s bus Another driver went to the wrong drivers have repeatedly transfer point, and his mistake was volunteered to go to the not recognized by the Transfer Point same transfer points and Coordinator. Yet another driver bus yards. Thus, they had missed a segment of an assigned not become familiar with evacuation route, the other possible M ocations. LILCO will run (1) Bus Drivers for general population " road rallies" to have the evacuation routes should receive bus drivers familiarize n
U training to assure their ability ta'" themselves with other bus follow directions given to them so yards and transfer points.
they can (a) follow routes from the ; T the future, emergency staging area to bus garages and preparedness training will then to transfer points and (b) force the use of different follow an assigned bus route. '
transfer points and bus yards. The Transfer Point (2) OPIP 3.6.4, Attachment 2 CoordinatorProcedurewill[(
(Pages 13-14) and Attachment 1 indicate that bus dispatch (Pages 10-12) should be revised to j forms are to be. checked require, respectively, the Bus Driver to present, and the Transfe [' Rev. 7.upon driver's arrival, in Point Coordinator to verify, 4 g Q ges GMel ,
each Rus Driver's copy of the Bus / Van Dispatching Form
\^ .y"l (5/2dedi EM t (OPIP 3.6.4, Attachment 7, o r %*/. - s,+ +$ h Page 62) to assure that the Bus tweke y d e U4 .
Driver has arrived at the proper transfer point.
RIVER-2 The time between deployment of Traffic Traffic Guides will be Guides from the staging area and their pre-equipped for immediate arrival at TCPs was excessive, takin dispatch for the 2 mile between fifty (50) and seventy (70) g EPZ. An additional person minutes; approximately thirty minutes will be assigned to assist O was spent in line at the staging area I receiving field kits and procedures.
with equipment distribution.
A more expeditious means of dispatchingL 4 o g 4 4 M (6/NJd the Traffic Guides from the staging area I reu_+rce d cN . "g ;'
to the field should be developed, f i' 810005 Page 5 of 17
O' LILC0's RESPONSE TO NRC AND FEMA COMENTS ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 PART !!! ' AREAf s) RE0UIRING CORRECTIVE ACTION' IDENTIFIED BY FEMA --
i 1
These items need to be corrected by LERO and demonstrated during the next emergency response exercise.
ITEM 8 RAC RECOPNENDATION LILCO RESPONSE
! E0C-2 There was some confusion regarding The FAA will be contacted as the method for notifying the Federal part of FD4A's FRERP g Aviation Administration (FAA). response. Plan and (1) The LERO procedures should be proceduresrevisedin[6[Jo/$,
Revision 7. Training reviewed and revised as necessary material has been revised to ensure that a point of contact accordingly.
] with the FAA has been designated.
(2) The LERO EOC staff should be trained in the appropriate O procedures so that the FAA can be notified in a timely manner.
l E0C-3 Since there are no procedures for The Long Island Railroad is
, notification of the Long Island now called and informed of Railroad (LIRR) in the Plan, the the emergency. Plan and LIRR was not notified during the procedures revised in exercise. , Revision 8. "I*ssd Wk (1) The LER0 procedures should ** #
D I be revised to establish a point QO' i of contact and'a means for notifying the LIRR.
I (2) The LERO EOC staff should be Training material has O
! trained in the revised procedures been revised accordingly so that the LIRR can be notified -
in a timely manner. " ' ^h k*
pr .d.4 m f9t /od.In ,
f lO I
Page 6 of 17
O- LILCO's RESPONSE TO NRC AND FDiA COMENTS ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 PART I!! ' AREAf s) REOUIRING CORRECTIVE ACTION' IDENTIFIED BY FEMA (continued)
ITE'4 # RAC RECQittENDATION LILCO RESPONSE i
EOC-4 The dose assessment status board in The dose assessnent status the accident assessment area had to board has been revised accommodate both DOE RAP and LILCO to separate data from the field monitoring data.
There were DOE RAP and LILCO field not enough columns on the board to monitoring teams.
keep the two (2) sources of data
_ separated. LERO should enlarge QOM fg y g7 (g i the dose assessment status board to i accocunodate a clear separation between the data reports from the DOE RAP and LILCO. field monitoring teams.
E0C-5 The downwind distance of the sample The field teams will i~
was incorrectly reported to 7,000 transmit data in miles
' meters instead of 700 meters for one to minimize confusion.
of the thyroid doses reported by a A precaution has been 00E-RAP field monitoring team. placed in Revision 8.
This error was caused by a decimal point misplaced during the conversion ggwag of the distance units and meant M w6 A g
that the initial calculation of thyroid dose based on this measurement was 9 000 mrem /hr. at 4.3 miles
! downwind instead of 9,000 mrem /hr.
at about 0.5 miles downwind.
About five (5) minutes elapsed before this error was found and corrected.
, All downwind distance from the field should be reported consistently in either miles or meters.
i i
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- 310007 i
i Page 7 of 17
O trLCO's REs*0usE TO *RC A=0 rixA Co.iENTs ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 i
PART III
' AREAf s) REOUIRING CORRECTIVE ACTION' IDENTIFIED BY FEMA (continu ITEM # RAC RECO94ENDATION LILC0 RESPONSE EOC-6 During the reporting of the initial Dose projections based upon DOE RAP thyroid doses, only one field extrapolated field data will measurement, the 1400 mrem /hr be reported as ' projected' measurement made at about 1204 at and posted in the projected two (2) miles from the plant, was data column. A precaution available. This value was used at has been placed in 1
the LERO EOC to extrapolate doses at Revision 8.
other distances. These extrapolated "Tb b e iss - 4 D data were reported as actual m A ,, u d measurements at other distances rather than as projected data on the dose assessment status board. It took two and one half (2.5) hours to identify O and correct this error. LERO reporting procedures should be reviewed to ensure .
proper coordination and proper reporting.
EOC-7 Although he later quoted the PAG The Health Services correctly when asked to do so by a Coordinator has been
, Federal evaluator, during a briefing provided with review i
held at the LERO EOC at about 1110, material on the use the Health Services Coordinator and meaning of the misstated the EPA PAG as being EPA PAG's.
, nandatory evacuation when the projected thyroid dose was boSd ~
five (5) Rem. The Health Services he,19%
' Coordinator should review the EPA PAG guidance in order to avoid any possible l
l confusion that could result due to misinfomation given during briefings.
E0C-8 Prior to the exercise, LILCO management The siren system will made the decision that the siren be activated as part system would not be activated as part of a prompt notification
, of the February 13, 1986 exercise, test, prior to commercial
) -
Activation of the siren system should operation, be actually tested in the future.
pg*3 FmA O reure- f s'oe'
" FEM 43 " "f&
m, s a reL SW
- 6-Page 8 of 17 sa,js u.a~810008
O Litco'= arsaoast to aac **o rota ca'<tvis ON D1ERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 PART I!!
' AREAf s) REOUIRING CORRECTIVE ACTION' IDENTIFIED BY FEMA (continu ITD4 # RAC RECONENDATION LILC0 RESPONSE E0C-9 There was a rielay of about forty-five Traffic Control procedure (45) minutes between the LERO EOC's has been revised to direct first attempt to have Route Spotter expedited dispatch of t
- 1005 verify the fuel truck impediment personnel responding to and the dispatch of that spotter from incidents identified by the Port Jefferson Staging Area, the EOC. Procedures This delayed timely verification of revised in Rev 7 and 8.
the impediment. Personnel need to be trained in the development of gj3 eggs , @
alternative approaches when delays are reasonably anticipated in the g g kg,,f a field verification of impediments to gy,gM-evacuation. Development of alternatives 1 should include consultation between, at a minimum, the Evacuation Coordinator and the Evacuation Route
. Coordinator.
EOC-10 Only the Shorehan-Wading River School Schools will be District participated in the requested to participate i February 13, 1986 exercise. Prior to in future exercises, the exercise, LILCO management made M e g S Q([ ggcA-the decision that other school districts
' were not to be included in the exercise. In the future all Cogeckg.
schools must be included in all i
Federally evaluated exercises and drills.
EOC-11 Dosimetry and training have not LILCO is ready to abide been provided to the Bus Drivers by its commitment to provide used for school evacuation, training in basic principles of radiation j (1) Bus Drivers used for school and dosimetry use and to evacuation should be trained provide personal dosimeters
, in the use of dosimeters, and KI tablets to all school bus drivers upon (2) Adequate supplies of dosimetry request.
O should be provided for Bus Drivers used for school evacuation.
g 4
} 810009 i Page 9 of 17
f O 't'co' = arsao"55 to "ac ^"o 'E"^ cot"'s ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 PART III
' AREAf s) REOUIRING CORPECTIVE ACTION' IDENTIFIED BY FEMA (continued ITEM # RAC RECCNMENDATION LILCO RESPONSE EOC-12 Some of the Ambulette Drivers were not Training of ambulance /
aware of when to take their KI. ambulette drivers is Training on KI procedures should be being scheduled and has given to the Ambulette Drivers, been revised to provide increased emphasis on dosimetry and radiological protective actions for emergenTramas,cy workers.
EOC-13 Bus Drivers used for school evacuation have not been trained in XI policy and See EOC Item 11. A Oroc.eSSe4A 9 h Th the use of KI. Sufficient supplies of KI are not available for School Evacuation Bus Drivers.
(1) Bus Drivers used for school 4
evacuation should be trained in KI policy and the use of KI. Q0 CSS PCC (2) Adequate supplies of KI should be provided for Bus Drivers used for school evacuation.
EOC-14 Ambulette Drivers were not all trained
- See EOC Item 12.
regarding who can authorize doses in excess of and what to do in the event Tp m , n D cedude d of exposure above the general public l PAGs. Ambulette Drivers should be in 3d
- l trained on excessive exposure authorization and applicable procedures.
J EOC-15 Bus Drivers used for school evacuation See EOC Item 11.
have not been trained regarding who can authorize exposure in excess of the general public PAGs. Bus Drivers (\o p ro M C S.S used for school evacuation should i V
.- receive training regarding who can authorize exposure in excess of the general public PAGs.
u 810010 Page 10 of 17
Q' LILCO's RESPONSE TO NRC AND FEMA CGNENTS ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 PART III . ' AREAf s) REOUIRING CORRECTIVE ACTION' IDENTIFIED B ITEM # RAC RECOiMENDATION LILC0 RESPONSE ENC-2 Maps and displays in the media briefing The suggested additional room were insufficient. The following displays and status displays should be posted in an area boards have been provided easily visible to reporters: to the ENC.
o An EPZ map which tracks protective actions and plume pathway, dOSC k o A status board which provides O ECLs and their times of declaration ENC-3 Some hard copies of EBS messages that
- The emergency press were provided to the press contained releases, which do not extraneous information (clearly O marked for deletion) that should contain deleted material, will be posted in the ENC.
have been omitted to avoid possible Procedures revised in confusion. Hard copies of EBS Revision 7.
messages posted in the ENC for use (./so/J6-Clo5ed by the press should contain only that infomation which was broadcast to the public.
PORT. One (1) Bus Driver neglected to Training materials have JEFF-1 read his DRD at anytime during the been revised to. provide seventy-five (75) minutes he was additional emphasis on working in the EPZ. All Bus Drivers radiation a d dosimetry.
should be trained to read their DRDs u h b e. russ ed, every fifteen (15) minutes as described gg in LERO Procedures. g4 h,n,Q g4 PATCH-2 OPIP 4.7.1 specifies that the only Procedure 4.7.1 has been i
personnel entrance is to be the Main revised in Revision 8 to Entrance on the Conklin Avenue side of' indicate actual flow of the building. The entrance actually personnel, used for this purpose was the one on
- the north side of the building To be TSSwed N -
(Main Street). Since the system W
- b ## ***y actually used seems to be superior to the Plan due to reduced congestion, t OPIP 4.7.1 should be revised to indicate that personnel are to enter the Patchogue Staging Area through the Main Street entrance to the building. L 310011 Page 11 of 17 -
l 1
LILC0's RESPONSE TO NRC AND FEMA CMENTS ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 l PART III ' AREA (s) RE0UIRING CORRECTIVE ACTION' IDENTIFIED BY FEMA (continued)
ITEM # RAC REC N ENDATION LILCO RESPONSE PATCH-3 LERO personnel entered the upper Procedure 4.7.1 has been floor repeatedly to use telephones revised in Revision 8 to for emergency notification. indicate access to upstairs This practice is explicitly prohibited areas.
by 0 PIP 4.7.1 (page 38, item #3). To w isswe.4 hrs ueek Either OPIP 4.7.1 should be revised y to reflect the actual practice of using telephones on the second floor *4
- of the Patchogue Staging Area building, or more telephones should be provided on the first floor for LERO personnel to perfom their emergency notifications.
O
- PATCH-4 The south door was not locked for Procedure 4.7.1 has been security as specified in OPIP 4.7.1. revised in Revision 8 to All doors required to be locked by ensure south door is closed the Plan should be verified as actually and guarded.
locked by the Staging Area ge,a%c Coordinator or a designee.
PATCH-5 Unauthorized entrance to the staging Procedure 4.7.1 has been area could be achieved through the revised in Revision 8 to, open fire escape on the second floor ensure the entrance on the of the east side of the building, northeast corner of the The fire escape on the second ficor second floor is locked.
of the east side of the building I
should be designated as a guard post see. On in the Plan and individual should be assigned to Staff this guard post.
PATCH-7 Traffic Guides do not have complete The Traffic Guide Procedure or correct information on the has been modified in Rev. 8 appropriate destination for evacuees. to have evacuees listen to All Traffic Guides should be trained WALK for emergency to advise motorists with questions to infomation.
tune to the EBS station (WALK-FM) for 3e,g, ,,g ,qg the latest information on all matters O related to the energency, including the location of the Reception Center.
t 810012
_ _ _ _ _ _ _ Pag (12 of 17 _
l O utCO'. RESPONSE TO =RC Ano nxA ComnTs i
- ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 j
i PART !!!
' AREAf s) REOUIRING CORRECTIVE ACTION' IDENTIFIED BY FEMA (continued '
ITEM # RAC RECONENDATION LILCO RESPONSE 7 bdsh, % FW4A) M res re PATCH-8 Appropriate personnel and equipment f'After road crews are were not dispatched to clear the dispatched to their
- multiple vehicle accident simulated field positions they as an impediment to evacuation. connunicate via radio The appropriate personnel at the l with the E0C. The Lead Patchogue Staging Area should be trained to request more information Q Traffic Guides at the IStaging Area do not decide from the LERO EOC when impediments which trucks are to be to evacuation are indicated. dispatched to a particular impediment.
a PATCH-9 Instructions for the driver of the The Transfer Point non-institutionalized mobility-impaired Coordinators' training Q
- bus to proceed to the Reception Center were not properly transmitted to the material has been modified to ensure the relay Bus Driver at the Brookhaven National instructions from the l Laboratory transfer Point. Transfer SAC's to the bus drivers.
Point Coordinators should be trained g to follow instructions forthcoming from the staging aret regarding directions that are ta be iven to go,;b bW ,.cge 4t l special population evacuat on route Bus mE 4 / oc,4, Drivers, since they are trained to return to the transfer paint for instructions as speciffeo.in the LERO Plan.
PATCH-10 Residences of some non-institution- The maps used to find homes alized mobility-impaired persons in the EPZ are being were difficult to find. Drivers reviewed for clarity. Where i
designated to pick up non-institution- applicable, the number of
! alized mobility-impaired evacuees at the utility pole that their residences should be provided services the residence or with more detailed maps and clearer other landmarks will be descriptions of pickup points. 'ncluded, lin EVdu M .)
,,%Ie.44os4 PATCH-11 It took forty (40) minutes from Rev. 8 has been revised to receipt of a LERO request to dispatch indicate an additional LERO a Bus Driver to simulate the evacuation Staff person will assist the of forty (40) school children. The Special Populations Bus Bus Dispatcher at the Patchogue Staging Dispatcher.
Area should be provided with trained To be.T5.swd staff support so that Bus Drivers can 43 g y nea be dispatched in a more timely manner.
l Page 13 of 17
O LILCO's RESPONSE TO NRC AND FDIA CGMENTS ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 PART I.!! ' AREAf s) REOUIRING CORRECTIVE ACTION' IDENTIFIED BY FEMA (continued)
ITD4 # RAC REC 04MENDATION LILCO RESPONSE PATCH-12 The Patchogue Staging Area Bus All personnel going into the Dispatcher made repeated statements field receive a dosimetry with a bullhorn which emphasized only briefing when they are that general population evacuation issued their dosimetry.
Route Bus Drivers were to call in if a reading of 3.5 was reached on The Lead Traffic Guides their DRD; he did not give the units and Bus Dispatchers associated with the 3.5 number nor training has been mention the use of the 0-200 mrem DRD modified to emphasize which is supposed to trigger the the need to be more first call-in at a reading precise with their at or above 200 mrem. The verbal infonnation. '
instructions given to the general "O population evacuation route Bus Drivers by the Patchogue Bus dispatcher over the Trathk 4e W pecSede bu11 horn should be more precise to 3 f 0ck -
emphasize the proper use of both
- dosimeters and the car ~eful reading of exposure control instructions for emergency workers.
, PATCH-13 One general population evacuation Training material will be
convenient. General population evacuation route Bus Drivers should g '9pacegg,), h n,/
be trained to read their dosimeters approximately every fifteen (15) minutes when they are inside the 10-mile EPZ, MQ Pggd .
stopping the bus to do so if necessary.
PATCH-14 Traffic Guides at two (2) TCPs did not See Patchogue S.A. Item'13.
know dose authorization Ifmits. Train the Traffic Guides so that they know qs c.hde .
the dose authorization limits.
O I
i " 810014 i
Pace 14 of 17
O LILCO's RESPONSE TO NRC AND FEMA COMENTS ON EMERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 PART III
' AREAf s) REDUIRING CORRECTIVE ACTION' IDENTIFIED BY FEMA (continued)
ITEM # RAC RECOM ENDATION LILCO RESPONSE c
I PATCH-15 The Route Alerting Driver observed See Patchogue S. A. Item 13.
believed he would receive KI Route Alert Drivers consume authorization in an EBS message. their KI tablet when they This is inconsistent with OPIP 3.3.4, hear a General Emergency Attachment 1, Item #9. Route Alert declared on the radio.
Drivers should be trained to know that -
K! authorization is to be issued Training material has to them by their supervisor as beert modified ccordingly.
specified in the LERO Plan.
Tram % th /Occ PATCH-16 Traffic. Guides at two (2) TCPs did See Patchogue S.A. Item 13.
not fully understand that the chain O ar co-aad rar 'xc > xa==ar-authorization gives the Lead Traffic N64 w w Guide authority to authorize excess exposure by radio, and some Traffic Q ;(te,di 4e %
)
Guides indicated that.they might question the authority of the Lead Eres. d b f 0d.-
Traffic Guide to issue the authorization for excess exposure. All Traffic Guides .
should be trained to know that the Lead Traffic Guide can authorize exposure in excess of the general population PAGs by radio. .
RIVER-1 While the status board was updated Training material has been periodically, the time was not always modified to ensure S. A.
included when new infomation was personnel record the time posted. Personnel should be trained that updated infomation to record the time that updated is posted on the status .
nfo ation is posted on the status board. y/Och% mig RIVER-3 The access road at the Brookhaven Brookhaven Substation T.P.
Substation Transfer Point was narrow is LILCO property and is and curving and could be impassable in cleared regularly by LILC0 inclement weather. Consideration plows. This facility, O shau'd 6 s'v a to r iacatias ***
Brookhaven Substation Transfer Point hich<=atacatrai ad convenient location, was to a different location, not a problem when used during the drill on 1/30/86 L 810015 immediately following a
, snow storm._ )
Paee 15 of 17_ ____ __N O NP 12- b
LILC0's RESPONSE TO NRC AND FEMA CtN4ENTS ON EMERGENCY EXERCISE HELD ON FEBRUARY 13,1986 PART 111
' AREAf s) REQUIRING CORRECTIVE ACTION' IDENTIFIED B ITEM # RAC RECOPe1ENDATION LILCO RESPONSE RIVER-4 One (1) of the drivers for the general population evacuation bus routes Training material has been modified to emphasize the dispatched from the Riverhead Staging importance of reading the Area did not read his DRDs every DRD and other aspects of fifteen (15) minutes as stated in KI and dosimetry.
OPIP 3.9.1. Bus Drivers for the general population bus routes should be given additional training to read f g g'yh their low and mid-range DRDs every fifteen (15) minutes.
RIVER-5 Two (2) of the eight (8) Traffic Guides See Riverhead S.A. Item 4 did not fully understand the difference '
between low and mid-range DRDs. Traffic Guides should be given additional /0c3r- bruEas training in the use of low and mid-range ORDs.
RIVER-6 One (1) Bus Driver simulated the ingestion of his K! tablet prematurely. See Riverhead S.A. Item 4 prior to being assigned an evacuation .
route. Bus Drivers should be given additional training in procedures for l0d kaaok ingesting XI.
REC. On several occasions, personnel CTR.-1 Training has been modified radiological monitoring took approximately four (4) to five (5) to emphasize that monitoring minutes per individual, which is must be completed within the time specified in the considerably longer than the ninety procedure. -io be. TESat d.
(90) seconds specified in the LERO O kJ d Procedures. All monitoring personnel
- Y g assigned to the Reception Center should be trained to monitor individuals within of g j
- Traenen,d ninety (90) seconds as prescribed in OcW[ci/M M-the LERO Procedures. fA O -
O' LILC0's RESPONSE TO NRC AND FD1A CO# TENTS l DN DtERGENCY EXERCISE HELD ON FEBRUARY 13, 1986 PAPT III
' AREA (s) RE0fdRING CORRECTIVE ACTION' IDENTIFIED ITEM # RAC RECGif1ENDATION LILC0 RESPONSE CONG. Neither of the two (2) congregate The Red Cross has the CARE-1 care facilities activated for the February 13, 1986 exercise are responsibility for maintaining a list of identified in the latest submission congregate care centers.
of the LERO Plan. The Plan should be Since the list is revised revised to include all facilities periodically (as particular intended for use as shelter facilities centers become unavailable during a radiological emergency at SNPS. or as new ones are added),
These facilities should be included in it would be inappropriate the If st attached to LERO's letter of to include the list in the agreement with the American Red Cross. LERO Plan. Instead Appendix 8tothepianwill
~s be revised to contain a new letter of agreement with
) the Red Cross which will state that the Red Cross will maintain an up-to-date list of congregate care t centers and that the If st will be made available to the appropriate federal agencies on request.
C C e idt. $ \ t. C~ N
% av.k yS< \e.%
dces n4 c,.ho,l.,, % ae 3xed.
muG b* W"' # lid"5 uA % ARC hoo 4e k M e-. % n O- -
1 b 810017 i
I- -- -- . __ _
_._.______ _ Page 17 of 17