August 14,2000

TO: Dennis Sollenberger Office of State and Tribal Programs

FROM: Steve Hsu California Department of Health Services

SUBJECT: DEPOSITIONS OF JOHN VADEN (AUGUST 5,1998) AND RAYMOND F. FISH, JR. (OCTOBER 12,1999, NOVEMBER 8,1999) REGARDING PROVIDENCIA PROPERTY *1'

1 1 = SIPMES DISIRICr C= 2 SN X 2 CRTMAL DISTRICT CF GUZFCRNM 3 4 4 LSWA. MACM3War 5 Witns: Jolm Va.w 5 Plaiutiffs, 6 E8jmwomtr. by m. ?.tYpdth 6 1b. 97-5220 RAP (A2t4c VS. ED0Tr1X-tca' by Mr ates 10;~spf~s N. 8 Domusima by Mr hnd Pae142 9 Ebasumt~am by Mr Bow pag 193 9 NXMCMZATICK 10 RmttIr D1flrati by M. Mjeth Pag 197 10 IME-Fcac,M n2 R~the DomrtaLx bY Mr nmd Pag 224 322 22 P~rth= Domzin=xu by Mr ror Pae225

13 13 14 14 Depo~itim Of: 15 Ekiibits 15 critnf Attachmen B, 16 HE*~ c, Attachmft D, 16 Is,.: Wa~scy, Arý 5, 1998 Attadwerrt E and AttaadiluL F 17 wa vaud~for Idetaficatia 17 as Edi 1 page 22. is 18 Thim: 10:25 aam. An 18-pag domiret- aad 19 19 doaMet runbs 00300 20 tbki4* 00316 was ffrkd~ for 20 Plac: Idmi~ficaxria as Bdlibit 2 21 cri p~ 26. 23. 800 S. Casc Stee 22 22 23 23 Vubogrsphd by: 24 24 Repotedby: Nz 4089 INaxb 25 25

CERTIFIED COPY I 3

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1 2 iNDE2X 2 3 3 4 4 law Of fi~ of ICE & ICE 1800 1000 Wilshire Badewerd, ~ilts 5 Bftii.tS (OMTiTL3d). M~ee dommers Leitrimz 5 I.s Argeles, Cali~fomia 9W017-2475 d~= nzmass JL332h, 6 6 00030Aith wi I003SlAxdi'lx 7 wee IjK~to adiibit 2 7 mx ps 68. 8 8 Plaiit~iffs. 9 9 2009 Ck!ný -'x Eat Adte 3200 10 Los k'geles, CQ3ifiaxa 90067-3206 10 221 22 Rl±e ymm J. ~Nam, &q. x of as xx1 LU 122 122 for fo~IrByprdas Defaxbr IC2NRmn jaiO3s, Inc. 13 13 Law Of fie of EIBM, D'N49O, HUMLMS a mIGAR 14 14 221.Nth Fig.xa Stree, Rxite 2200 fmci foerif±ifairai as ins Akpeas, Califoemia 90012 15 ndiibit 6 npaxe 78. is 16 16 asc~an ax hol of Atte-ageaetr 17 17 18 2B ow,Offa is of vaammE, =l, B014 & ENp~E fokrItIirantjfa~ f as 355 S. (kard Ame Baite 4400 19 Exhibikt 7 page 780. 19 Los h~eles, CmIifAxa 90071 20 20 'stiby HWHM K. flMMI 899. mx kalf of a a casezisel 21 21 2/9/61g 2/9/6 ixton~n- 22 22 lefhbt 7 anx 80g~ t 23 23 24 24 this PA=.) 25 25

4 2 imI mffmr SERVwICE LMMA 1~MqM IWCFMM SERVICE I

1 1 2 2 INDESX INDEX 3 3 4 Four differet- rough draft 5 Exhibits (arzrý~) : A see-pa documet S Exhibits (a7tdrijed) - 6 6 r7.M4_1to L. - zg dOUe rubers X0166 7 7 8 Exdbi~it 21 n pag no0. 8 Exh~ibit 8 m page 85. 9 A gru of doavasts berinj 9 A tkre-as-e qp--tt dobiret rnirbes JI=9 10 thrug 3M250 was nwadd for 10 Idenificatiin as wasmce for Metificatia 11 11 as Exhibit 9 mi pag 88. 12 A two-pag letter to 12 Mr. A. AXMdai4 from 13 H. L. Price was mmaedcl 13 for Idetificatijr as A two-~ Tres t~pd 14 14 jarloxy 1, 161 to A.. Ija~ckefrom 15 1s H. L. Priceby R. L. Kir with attacumt wsm~ 16 16 for Idet~ificataio as 3. page 89. Exhibit 17 bbkeOesim n d AWuer Pae 98, Lines 17 throug 23 17 18 18 Aimes~ M.7 19 19 far' Metificatiui as 20 20 E~diibit 12 aripg 94. 21 !tearters Oartificate: Page 230 21 22 22 U.S. koadio EnerrN Wbmiiasia 23 23 for Irletifictiarx as Exhibit 13 on ag 99. 24 24 25 25

5 Lvemm wa SOVICE

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1 ME VM OAiHER: are reast, so let' go

INDEX 2 ahea ad get dthixs roliMi here. 3 Stand l, pleas

4 ake Pause 5 ME0VICE03UOM: 7his depoaitkic of John Vaden Exhibits W=Anued) : A tD-r letter Jaaa& 19 1961 to Cxrsm Stet JaTes l.-anroJ. D. Vacle 6 is being held ri August 5th, 1998 at 800OS. 7 Cu-sn City, kba3 Identifiaticri as Exh~ibit 14 anag 10M. 8 The caption of the is The Vesu Rearers : Pb 9 IM~ Pharracuicals and this dqmsit~rn is being ta1m no Edlbit 1wasPI~ P~Io 10 behalf of the Plaintiff. ofaiEhbt16 wasmade 11 'flu time on I~is 1017 a.m. Reote' aNote: No 22 Will all attorney Ieas pleasse idetify Eibt 17 eas ffadad5. 13 thammel'.s and state the pextie they relzeset2 14 W~.M:=: Good mrnuing. I'm MI i ý Ibt:Mith, BfrIuancFjI s fo 15 M-c-K-e-i-t-h, repreerrg Joseph and Virginia 1hrmari, f-r Idetification as Exhibit 18 an pag 101. 16 the Plaintiffs in the litigation. is Bra A cn-aq-e lFiIre Slip 17 MR. BFtM: Godunrm nfr. My name to L. .I~ from R. E. Brixiciu to %kidic is 18 Brwn It's B-r-y-a-n, B-r-o-ie-f. Aid I reprent 19 Rhr-Priler, Inc. Addrdstrative Prceze~s 20 MR~.PPXM1: Goo monming. W4rgre is as Exii 20 an pag 106. 21 Greg Patterso. I M .aeM1 Phnaretica).s, Inc. 22 W4.SHDV: Good mmming'. Pb rame is 23 Jchn Sctmn. Malt' s S-h-i-m-a-d-a. Aid I Le~zese 24 Pi.Xr. 25 VM1ý48 : If ther are any stipulaticas

8 6 LvE mm REPWM SWVICE J 1 penalty of pejury as if wee givin dhe testimonzy by either party, plesse ~stat dunm zxw. 2 tcisy in a court of 1w. w6. *JM: None. 3 Coyu. undrsand that? 3 MEVMMO~a m: 'Ba videogaphr's name is 4 A. Yes. 4 Bill H~ums of Bin a4Iveu Pra.= 5 Q. knd do you also urdrst~and that in the event yo 5 'fu ~Reprter's names is Del !4zmo from 6 irake dvrge it nay mean that eithe nyself or m~y of the 6 Lake Tah~e Fipcting Service who w3).1 now anistr the 7 other attores in the roocn w'axrthdat you lava 7 oath to the dexmt. B 8 MBE REOIR ol ýx naia )c= rigt hard, 9 A. Sh3AA I initial my ctgaves? 9 10 Q. Yes, yo hud 10 311 pid so, darxefore, it's aiportant dhat your try to 311 an in~erk widts -11 - by tde Plairriffs herein 12 giVe you bes test-cay this -ug 12 who, having I first duly swon by' -. was durapof 13 'Barafor, if youx don't understand a queastion, 13 exmursi ard interrtote as harufter se forth: 14 please ask us to clarify the q-stion. If ý-'re tired and 14 WBE FMFM 7hark you. 15 ýKu 'wa to take a break, let us know, we would hawy to 15 'ME VM AR: Please rI~1 16 take a break. -d iLf ym can't hear the qm~ticn or dxV t 16 EXMQMBY M. Ml't .~ 17 understand the quesetion, nukesure~ that the attounes 17 Q. Goo rrming, t&. Vaden 18 clarify and I 'n the gmsicn for you. 1s A. Good ttnmnx. 19 A. Very wel. 19 Q. it ýueaahad your depositia tal- p-iaal? 20 Q. Is thera any resonI why you can' t give bs 20 A. Nko. 21 testimrny tcdwy? 21 Q. Then I'Id like to go ove some of the grazd rules 22 AL No. 22 23 Q. All right. 23 24 flzrirg the couse of tie d~epoition I'm goirg to 24 A. Very weU. 25 b homM~i~ i'y sme Exhibits and you' Uge a coy to take 25 0.. Thank ýn.

9 31

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with tody whichi will. be ýý on copy. 7he Cou~t 1 Asyua see, tin Omt Rqzter -s tidxV d Rportrt will )mV a coy. )d dhen ry 0ze here will 2 my~ estaenents arr your responss. Ard in - r her to also lava a copy. 3 the bes possible rrI it's inporart, that yvu wait so I'm going to start with Ebdiini 1 to the 4 until I'm don and uti I these getlaium are don asking depositicri. and Exhibit 1 is a Lzuie of d~xnets starting 5 with 00289 through 00299. 6 ro )xn uriesard that?

7 Sof Attachren B, C, kttadmmn± D, 8 0. r. Attachment E and Attadm1n F was markedl for Idetifiation 9 Un -- it's alao tnpxrtat dhat when yx respod as Edlibit- 1.) 10 yui artio. you respone cut laid so tint ym unld say w6. L'tIerm: Q. lbwv if woi lak tcsazd the 11 ysor no, instead of rcddir your head or saying ut-huh or bottomn of tin pag ýoýr'U dathre's a referenc to jm 12 unh-unh (rntive r uesa), b.aoue she can aly ta~ke dox John Vadrt,~ z-adiokcgiCal health office and mutar of 13 IaTc Ctumttee. 14 Do you- uirstad that? is Do you se tint? fte au while the witness review douen) 16 Q. is there- M.. P't=0~f: I'm direcr~ting h wiLtias to dae 17 At the end of this depcatum te 0;t= Reporter place tint I'm referring to. 18 is gon to typ up a trascip~t and you will be sen a ME WMflM: Yes, I'm reaing~ this. 19 cop of the transc-4 and )xu will hive the oppotunity to M.S W.Il=: Q. Ckay.G. 20 MR)e , 9r to tda tra--4x to dar9 . testiany if A. I'm reairig it. 21 u May. ahief paus while tin witnes contmmn to 22 Do you urlarsd that? review domet) 23 A- I tn~nrrld. 'ME wn*Ml: I Should hive -i I more. 24 Q. Ckay. M.. MJMMl: 0. Owa. 25 Ad dhen you will1 be mgungi tin tar=4 tLzxk

10 12 LAMEMM H'BU'B'B SM I I.

1 A. 1b uek are that ti-e cprti wer in I ,h &e thirM that's izrp~tan is )Ku shilred 2' onpliaMn With the AM= BMW~ Qnm~m rezat1Cx. 2 tryrnot to respod rrnil there a actrmlly a gmsitn ti-nt's 3 7ht as th beed r8gamew:. 3 pening 4 0. D o± )a-c the cix~zitanrs iz which ycu 4 A. CksY. 5 wer hired to worit ho Nazr at the =~ fait11ty> 5 Q. So b ym see whr yo.v r zse is referece 6 A. Yes. 6 th~ere Mr. V~a, ai diouren rnmte 0=S9, the first pag 7 It was ny un~imfxrzb that the a pany hadi 7 A. OWy. 8 had ~se nr~mplianc hiscoy with t-e A== Energ 8 AnI to readthrztihall thi 9 chamuseaai. kid I wstoMd by AM inspetrm that they 9 Q ~ 10 wereudrso- - ' wh hai~ lioe shud ro 10 If yii would go bac to tha first pag whr your 3 beameddc tevdced ant that dWy iw i anibcy W*n 3.1 xv, is referencd. 12 woldb a fcrcful health phy-sics offi t we~rksure 12 A. Allrigh:. 13 that they -e cpexting ccxcly and efaly. 1.3 Q. 03aY. 14 Q. P~c prc to icmiiM at ISC whr did yo wrk? 14 Un -- beneath thea mm -- yu rume ti-re is a is Hye-- where did yai -r just prim to comizi to S 15 deciptimx of sure of ycx experience up utril tha time 16 A. Iher did I c) 16 ti-nt this dmmnt wsdrafted. 17 Q. . 17 A. Dc ywi have a gieticn? 18 A- In Btrk-* 18 Q. Yes, I do. 19 Q. And vks wa ti-e roe of the bus~ for which 19 te that aarately reflec %katyaw academi 20 20 training -o and eperiatn - 21 A. W~ze ta~l~drx abo Iart Speialties. right? 21 A. It Thto be acazrate- Thetrining 22 Q. Ma's righ2t -- right I F e y- got to 22 desribed fo e apeas to beaccuxat- of what I 9Jrditted 23 23 on -- for empborent 24 A. I wa wodcaV f= ti-e IA Chrity Heath Drvisa=i 24 Q. Or. 25 Q. *aIt did )OI do fc the LA aaII-y i~Th 25 W1s this -- uh -- infcontiri that was afrdmtted

13 15 IAKE T* WR USM LAKEVHM 'Wa= MMCE *

1 Divisiim? 1 for avnpyooeW - 2 A. I uw an inclsta1 hy-giena enie 2 A. Yes . 3 Q. Arid uknt type of z~respavalitim did yo h-am in 3 0. -- to Isctqes 4 thant jcb? 4 A. Thtnis crrec 5 A. 7b cutral ti-e cc at-il nexpcrse of nec1e 5 0. ffnrer, wen eed to let nrr finish. 6 w'addrn in icbstry. 6 -- the Isotqv Specialties C-ora~tin? 7 Q. Ard in ti-nt ith did ym go to f Ii I, J that 7 Mus was infcmrmticz1 yvio qr to ti-seQ 8 usdrnadicni- ninterialaP 8 A. It was-- I -- Ithink I as hired byR =. 9 A. Yes. 9 0- day. 10 We acnittrei and rogilated tha use of all sm 10 b this irlinia thot woa1A hav een 11 of radjatioa in all hospidtals, all V.A. medca 311 -rmde to Pamr? 12 uatitiuja.1m all detist offine, all irdscýa1 use of 12 A. Ys 13 X-ray xr±zn. Ard inl caxry-mnri with ti-e krrnc &-W~ 13 Q. Ard do you reallI approdmotetly &whei-au wer 14 (burnscimm we went artird with them an irpaetians of all 14 hired by Mmor 15 those pnto1e %h wer ueang niterial i-mad by tha Xarmc is A. Sometimea in 1%59, I believe. I'm not snt of ti-e 16 &i=Wg lbM-nrdia. 16 exac tine. 17 Q. Wmild ycu have ir apoct then 170 Pzmddi~a 17 Q. And wer yoau hired to wor at Iaottqpe 18 faciity I~ F Fu-~ I an eftPloym ti-? 18 specialtie *lbrw' at 170 Providenia in aBzkm*? 19 A. th -- rmD. rrv--did. 19 A. fnt isa Z 20 Q. am-y. 20 Q. day. 21 i-kci ti-e cb~zem i-thatiy re lodiam at ~rzb 21 PAd what was ycaz title when i-ou b-ega wcxkix 22 that ti-We' a an IsarPe 031tteL e axn...- VkM wa an 22 23 Leotqp OMUU=Mte 23 A. ibalth phmysics off ice. A. Pr. Isotcp 0bnmdse is ac 24 Q. And can i-au tall us whant som of your A &J wer 24 25 recormende by ktom &vergy lbnasimn to nave a grcp of 25 as the he'alth phmysics offimerl

14 16 LAKE M*RPOMM M7C /I'

But I dn' t reconize te specific iteus. 1 kroedagele pseple in all areas of use in radioaie WS. vtIm: Q. If you- 2 nrlei so they can advise an the safe qperatian and rule an X 7ey nay ham.e m frnm the licese plicatin. 3 ay projects in adianm to insure thnt tiey will be able to Q. Ckay.3 4 conply with all tin Xe~aznrmlts Of the regatiln. If you lock in the first IaragIi there's a date 5 Q. And is it yazunderstandixz that thn other here on the s liie. I believe that says 6/30/59. 6 individuals who are idified in tin docae that you A. Yes. 7 have in f rt of youwere also Iotopes O m nmui-i Q. kay. 8 during tin tine tint yui wn~md at tin ampamP I. Mat saC like a rejest_ in n appl.ication - 9 A. I lan't lookd at the wimle list, but I Q. Ckay. i0 reorgnize -- for instanc, the first nwe as tie A.L -- for possession limit. 11 dnimini -- uh -- of the Isotope Wmdttee, Q. 0-y. 12 nd, as I say, I hao ' t looked at the rest of Nowrthe types of radicacti'e vaterials tint are 13 the list. identified on this pae, clt 60, cesiun 137, - 14 Q. o yu at to tae aamm to take a lck at -ant is Sr 90, the third itan? 15 tint list, plesase? A. Mist did ym say? 16 A. I can do that. that stand- 17 Q. Mrk yu/. Q. M=tis Sr 90? What does A. Strztium 90. 18 (Brief intemrription) 19 2rief pame Qule the witnes revism dcbnmt) -- cobalt 60 - 20 flE wI.. : I reaxjniie John Lea. I recize Are these types of radicaiue nterials that 21 Art Seibel. I rxezgimimL Wettera-. Al eMdn4 were stored at ad i &J1l at the facility? 22 nrt reslly a nerx -- an official votixti-• e•r anyhow of A- Yes; that is true. 23 the comdttee; he was smply the vice-president of NU-rr. Q. md whan other types of radiotive nterials in 24 th -- these other are not ume ; theyre all addition to those that are iLdetified here wee store ard 25 use.

17 19 LAKEM*M E FC90M SON=IC m

1 ?6. im=KL I: 0. dIno yri nii by users? 1 used at tin facility? 2 A. Arything fran atanic number 3 to 83. We had a 2 A. people Vto emnk with the raiiosotopes, do the 3 broad bypkrfxt netrial license. We lad a source liae. 3 actuel riiicJ lalor and/or researchnirVViM 4 We had a .pecial rnulesr neterial license. -ki tihe 4 raioisotopes. 5 bypmrdt ferterial is -Jnt we calFe industrial brcad - 5 Q. Hae you• ad contact with any of the individals 6 6 wtn are identified an this dornetn in the last five •ears? 7 MlE WIRi: We l-ad a licese for byproduct 7 A. Mb. 8 naterial •n•ch ,es a I I industrial rear li s. 8 Q. kid do ym kno the ivesxinjs of 1W of the 9 WS.Mj=1": Q. Ckay. 9 individnls vft are idtified? 10 A. We had a special mrlear material liamce in 10 A. th -- m; n, I do nrt. I da't even know if 11 quaztiies less than a critical ines. Nd we had a sne 11 theyre alive. 12 netarial licanse. M ,st'afor thcriumi ad uranzn. 12 0. 2-n* y-.i 13 So there wem lots of licanses, and w lad sam 13 Now I'd like to draw y-r attmtim to dxazat 14 of all those fterialas grantd an all those at one tin or 14 ruib 00295. It's re of theidn mts t-here.- inm 15 arother were an tie p ises. 15 naters are in tie loe riath anr- . 16 Q. OWy. 16 A. I have that in fr ofire. 17 Was tritium ona of the types of noterials that 17 Q. Ckay. 18 was used? 18 Do y)ai recgize this doimt? 19 A. Yes, that'san tin bprcxuckt ffeterial licene. 19 Brief pmme while the wites revine dcunat) 20 Okay. 20 IM wrimS: I per se. Q. 21 A. See, that's ruitmr 3. 21 lie -- the third (sic) itae dcon an coalt 60 22 Q. akay. 22 appears -- or fourth iten -- a•pears Like it is an 23 Ad nnai~un-t1ruuzn -- was tint a t• of 23 arairet to the license, which I nay have sa as an 24 24 a•-dm t, b•. -- uh -- it IeIe" ain nant.year it was and 25 A. Ch, yes, tWl rebhcnthaere. 25 so forth and so forth.

18 20 I

W3t did that stand for again -- I'm sory -- the Q. 0-aY. 1 1 2 SR 9? 2 1111 poicaiium -- %as that X. 01 -- I'm no sure were that care fran uhi - A- Sure. 3 3 of 4 uh-- it's baically a -- uh -- arwstraz urrj type 4 Q. Ckay. 5 cdvice. 5 Pr an you tell us v'iat pglix1n is? 6 Q. I'm sorry. HNwdo yo say that word? 6 A. *jat poknium is? 7 BrarstralluC90 7 0. Rit. 8 A. Brms]trallu, b-r-e-m-s-t-r-a-1-1-u-n-g. 8 A. Polonium 210 is a raturally occurring zadioct-ive 9 Q. xnd vkat ds that men? 9 Isoe prinsrily and ai t exclusively an alpha emtter. 10 A. Breakin electn rdition. It's a Gemn term. 10 Ve is no gsmm radiati. Prd, theefore, you olAM rat 31 I dn't know as you Virt to get ito all thease U dect it with a Geiger axvrer. 12 tedhicalitie, bit tiat -- th-ese kind of source -- these 12 Q. Aid %hataxe the health irpacts of the pokraiza? 13 are the kind of souces one can put in a ge %hidixul.d 13 A It, s a very d rgreus element if it gets inside 14 be setting nrEt to a kbunh of beer axis comirn by, and if 14 the body. It's a bone seekr. 15 the be= i is rito fiIled all the way this radiatin that 15 Q. Ntw in the first pragraph tre's a refereice to 16 gos throg the top rntifies this dvice -- deetive 16 5,000 curies of cobalt 60. 17 device, ad that rrn-tqite-fillei can is thrsc cut, so you 17 A. Yes, ma' am. 1i cknt g a Is t beer xtx you buy a six-pack. 18 Q. Oay. 19 I.Ith thy it had a Gmnmi ngr ? 19 In Qir - 20 (aghter off the reord) 20 Was that -- is it you reollecrion that 21 M MU'fl: Well, I don't know -- I di't thin* 21 5,000 Curies WEs the avemre irr y of alt 60 that 22 it bad any zelatiazi 22 was at the facility? 23 But it's the kind that we pi in ga of 23 )L I thirk that was about the ,samn. I think it 24 various kinds, dnsity gu and all kinds of ligh 24 really ran around 3500, bese it was using it all the 25 gm . 25 timm and -ringing new in all tdo tire. It was a pretty

21 23 LAKE W mEr• RT SJI(C; I.

1 MS. tMMI: Q. You didn't use that to active stockpile. 2 •etemiane how much beer was in a ca, did ymi; you used Q. Ad whre ues the cckalt 60 stored at the 3 that to dtrmine how mudc prizoct vs in a so=r?

A- It mcas la.Ied -- it was stored in a ester-filled 4 A. Tha's rSGt. 5 Q. aoy. I undrstand. crete cell, vch was z d the swmri pc. 6 Mw how mch tritin would have been stored on a. Ckay. 7 the site on averag *%ile you were ther'? X-d the cesium 137 -- aprtmnately how ruch 8 A. Genrally we didn't store an awful i bccause - cesium 137 an avera was an invetory at the facility. 9 uh-- the tritim piesnized Ir runs n rmadioisotpe A- Ch. I would say ahot 1200 curies. 10 were never tm a few -- rit mae tham a hunred Q. Ard %herewas that stored? ll ,illion-res. A- su.ally in -- in hue casks. 12 And v~eld try to kee dmn the size an har u-- for instane, this sipwt franm Kalg, 13 base if ouhaId a larg qtity of tr=m pn we we as I recall u -- we hoak from them -- or the a 14 rerrrai by A~B to take urine sexples of ti-oae parpie %k i-ojft from than, •eca. tW nAe thise specially for 15 nay have I- eaqred and run an analysis for it, and that tieix ra ss, it- they had gmoe in firarial. problem - 16 was eiqznnve. and this was bourht, and it cae in a huge steel-exased 17 a. I'd like to go ck to tie ceium 137. lead-filled cask. 18 werea thse lead cargs stored at tha .rd dew un-e ra trays in there and yu FeId a 19 facility h.uge knlr.a liid xn ti- top to get down in ther• wi-th a 20 A. cli -- i-ack and near the i- lab armi, rwthe - handling dr-ice. You rver got your hand any of this 21 it was actaly rna the simmr pool. stuff. 22 a. Omay. Q. kad ti-e Sr 90 -- how much prod.•= s an saverag 23 And the -irium -- %berewa it stored tm intcry d4uir= the y were there? 24 did have it in stoxk? A. Witat as that gain? 25 A. In ti- cax:: 14 aotld laboratory. Q. The &r90 --

22 24

.1 1 0. dray. 1 A- Yes. 2 hAthe nagniumtoium -- i&tre eas -ho 2 dy.Ma 3 muhwsin stock? 3 Ariyo' recal that -- umn - d&amsi nrtbe 4 A. 'Ihe only nag~neu ue had on hard was in the fom 4 Mf32, the dommen jOI'Ie looing at x2gtz now, is one of 5 of nwrzsurý-thcrium wast, and that was storal in the - 5 the d~suets that I shwd jx 6 in a ibuiiryj the farthes to the Lea Of the faci~lity that 6 A. Yes, it does look like the saredoumet. 7 the Ime.e Would pexmdz. 7 Q. Ckrty. 8 Q. No I'd likea to tuma jouir attentin to 8 And I ase ým. sar qusui abou vk 9 d&x,.ITz nzu& 296. It's the rnet pag. 9 varcusl -- u -- activities took plac ar. the site.

10 A. 21- -- Wat? 10 A. rtiht. 23.1 Q. 296. 3 Q. dr0Y. 12 A. Ckay. 296. 12 Noyu i ,rsicne in you tesijn3' a few rayits 13 Q. If y~ can just look at this docurnt quickly. 13 ag a ewimnixS pool that was used for the storg of the 14 A. RLMM omplies) 14 oobat 60. 15 Q. I just want to confirm that this is a list of the is A. (wtns nosha affinnmt±vey) 16 type of itnxiants thatwuld1 hmm eenu at the facility. 16 Q. Can >Y± nmk on this vap with an "S" like am~ 17 A. This generally locks like the -- uh -- the tp 17 vkgnre the swdmtfdirg Poo was krcatMi apodnately.) 18 and the qunztities we genrally had an hand at all ti ew 1s A. Yes, I can mrmk on there %hr&~it's locrt-M - 19 A-d ascre woud be off repaired. Scme mild1 be coming back. 19 Q. dray. 20 ScTe wcW be being caflbated. kid some iwouA1be crr 20 I. - vkee it was located 21 bc. 21 Q. Can Yo d that. Pleasea 22 B we badI a very large quantity of all Of 22 A. C(ifless C2TT~ieS) 23 instnm±5nt. 23 I'm mrmking and -- px the l~ett "SP eizming 24 We acually manulfactured sme insitruet, and 24 P-1l 25 lMlrnr uss in the business of nuazfacvuir)9 -- wemd 25 Q. Mray.

25 27 LAKE MIX RECF MMIE

1 qmm~fi derie for deecing the things for beryllium 1 And just s ever~cue else in the roan knw vm that is 2 ores. it was a vey uniqueaw~Jimcna. 2 ýtx nexke. can you desi generally %imiee 3 Swe-- we had a lot of instn~rizton. we had 3 relative to some of the wr~iting an this d.zrent? tin - 4 one non that did nothuzj else but wcx nir~vna 4 A. Nazthve cirrar of the -- 4MIae-4t says M 5 all the time. 5 Shpand Off ic. 6 I. see. 6 Q. Ckay. 7 Now ýKu~ can g ahead axid set asi~ that vknole 7 Is it in the i~e rihthinid cmerof thet 8 dooset b.Jse I'm going to band youi another se of 8 as.are7 9 dxxaffs. 9 A. Yes; that is iz± 10 ah-ad psm vdile the witnes revews~ diciruts) 10 Q. dray. 11 M'. M1Uff: We're gougr to go ahead and nnk 311 And yi mentioned the -- uh - C-14 laboatory, 12 this as ddhiit 2, whdidi is J10332 and thei a serise of 12 the cmtcn-14 laboratory. Cini you nirk that with a 13 docmets, 00300 through 00315 (sic). 13 "0.14" - 14 fti 18-pag ckcuwet ur 14 A. Yew. dowret 'ltZ J10332aid~r 1s documet rurrters 00300 1s Q. -- onthenffeg tbxi 00316 w'as i I for 16 Iadffjicat:iai as Mdliibi 2.) 16 A. (Wtns canpLies) 17 M'. i'U(fl: Q. Mrh. Vaei? I'm going to hind 17 Q. An oukn t-icreatin-- uh -- the hotlash. Oni you 1s s morue newdocmets. 18 intei vkeze the hot lab *- 19 A. dray. 19 A. Rigt. 20 Q. dray? 20 Q. -- with an "Ml"? 21 Mrief prse utile the witnes reviae diasumf) 21 A. (Witnes crnplies) 22 M'. L't!Xf: Q. Now, Mr. Vade, yvou recll that 22 And up here (inclicating) was thme offi in the 23 wemt yesterrby etaningP 23 24 A. Wh~atdid ýati say? 24 Q. Are yu gonirg to mrak that wdid an "0"? 25 Q. Yaoi recl I thatw mnet yesterday euenimp? 25 A. In between was the shop arma (indiating).

26 28 LAKEV*M REP3= SMICE LAXEM-*M IWF= SEI I

1 1 Q. You also wereiaod that t~here were -- uh-- ste A. S:) it too special shielding. That'sa hky those 2 walfls are were tovir 2hare thicke. 2 nutexials -- I belieye it was the aggrmsiznthorziu 3 Q. Ca you rmrkd the wod "Fbbur i'& those rauiin 3 nTmatrials -that vee stred in a builduix toward tha 4 &uais were otP 4 of the prcpety. A. That's radiun, right them whr it says "I" - 5 Is that in doa wher the "R" is irrilcataii in or whatever it is -- rajiu. 6 7 Q. Now yx naricrodr that the wiaste was in svemal 7 A- That wa stre cuin this back baildirg -- is 8 diLfferu± kirids of padoagirg. Cmi yudsrb' fru h 8 part of the bak huilduzj hick in here (ixriz). 9 different kirx~ of packagirg that you ckserved? 9 Q. dkay. 10 A- Theure wee a lot of buerrs, a lot of smaflle 10 on ym garally dacrbe wheare WVire xmWOMr 311 cans, and a lot of canlisters.- oe wee W m boxes . 311 12 pld I thirk in a ffw case there wee evn sum fame bord 12 A.L I can say in aboi the right two-.thirds of the 13 13 14 Q. *aut )11 d z byuface - 14 Thelef1t part wsan expermnmi~l area ukre we 15 A. Nowi I &21 t knd what -- if there wexe secorkry 15 wexe radiatirg nras for the Air Fbrca expeximnu. 16 padoges insJ , beause I di~*it huue -- I di&'t open 16 Q. dnsy. 17 17 C~w call that the "Pat" armw, r-a-t armw? Is 18 %hen I got rid of those -'Iafler I 1s that corec? 19 siaply sat then in a barrel. I dij~i't Cpi than. That's 19 A- Yeah, ;wq. 20 c~griero~ts practijo -- to cpen thEan. 20 Q. dCkiy. 21 Q. Db yeu ra~wbe arpradnately how nuly oorrairars 21 Now in +btimir to storirg materials in the 22 of whateje sot were thee "in yxi first care to the 22 %ai~midiqpool, in the amci-14 lab, in d tikiýkir to the 23 facility-' 23 rea of the farizoity, can I-~ idetify for -n ary cdhr 24 A. No, I doW t. 24 axesa whee radicaciue materials wee stored at the site? 25 Q. Do j Ian# whether it was sore than a hxxtre or 25 A. Yes, th~ere w'ere cauidmzble waste -- radicaciv

31 29 LAKETAHM REFCR= SERVICE

i

less than a burxiraf? 2. waste stored in %keS is d~jxbr as the 'Lard" ai here. A. Ch, I waild assurne it wansmore then a hzrdrei. 2 0. Ckrey. 0. 00sy. 3 Cn)tdrwthe areawhekre tie waste was oate Wee the cortainers -- the smher cortairors 4 and call that 9ýe* ares'? tiateF deso bik -- are youi ta~lkdxg abor five-galron 5 A. It completely filled that yarid (irdcair). Q. Ocay. coriAirors or - lot of those. When you arrival at the faci~lity in apprcmzumtely A. Tore were a Q. X-d did they have cmmrs on theme 1959, can yo recl I the Iz' of barels or storag - A. Ye. 9 iii -- items with wase in tiEm in tie yaerd eras? 10 A. I roer -- I rvrasoaztedtif Aid- 11 There wee -- there were 0± only barrels, h& by the waiy, was all 122 tiere were every shae of cataixar inagirsbae nirbxlirg A. The n grsiurr-tixrixzn stored!, stxue1y w~'4, in %=e bns 13 some tiat I I Iruto ~apKe that they send cut dare Q. IS Mne~niUn-tboriMz IbiqC~j d or ldý 14 aid now I had to gtrid of then mysel~f, - Is it what? 1s Q. C~n ya.1 A. Q. TLqid oranld. 16 A. -- but- A. It is a so]1i namtal, so].iW alloy'. 17 Q. CGahad~. however, hamm -- uh-- sm oil - is A. I wareto sa atin thi ar 9 d- it It did, it, v&lidl is what. gmm it a ku-rr of greasy 3.9 looks like an "I" or sanatliirxj -- cri tie right of that yard otizpr oil mi look aid feel 20 darxe' asa rllaxera. 'fret newfiJ.2p ndth arrels that Q. wasit - 21 had raiunm in dhem ad were very high ai~vity. They hazard of that wsa fire haar. kid 22 haýx' t haan pardagi properly. flu son of radiun were A. The main fire people cawe cut ther ard skid: If that catdes 23 .no in tie cmver -- there's a u ajeraid bear wee comrg tie pit it cut. Ard I said: Well, 24 a= in all dire=±iona. an fi~re we cculd roer~ -- tiat catdhie ca fire you're rnt 25 Q. youam- tilief, -- I said if

30 32 Un M*M EWCR= SERVICE T

1 goi to be able to within dmiI of it, it hms so 1 .N- you mntkione taing~ this I- ,g9 this 2 site or - th falafl w dce damin Chicag, so. .. and h•_ii it off 2 ho, and wate . MfL is ore. 3 Q. Tll ne ahiac the w'-n boxe. were - 3 4 4 A. Tlh, were just industrial wo n boxes abou Ckay. 5 5 ao-ind thickwood. 7hat's wht it was. Do you recalI approxmntey w that cocurred 6 Q. Ckay. 6 after you owe to the facilit. 7 A. I ea:m that we didn't start pargir am/or 7 Do yiu recal what kind of wood it was? until I'd bee there a- a 8 A. Nhat? 8 -rryiz: amydriz off tIre 9 yer. I imag-. 9 0. ht kind of wood it was. Vs it plywood? Q. so •-ir• tha1 yaer it sat o.sid in the )wd 10 A. No, it w•at pIYW=xd R21ar -- just lodcd 10 U1 like pine wood tone. 11 arem? A. M 's rigt. 12 Mady. 12 1 Now, t~he druns andlt..•h:es and: th~e various Sime 13 Well, it -- it sat cu longer thma that. fly'd 14 canisters -- were they direct~ly on top of t-he pam~man? 14 rever -- thuyd neer used the disposl lies. is A. MWy were what? i5 Q. -ejy- is vkx? 16 .A fle •;e -- the pro licnsee - 16 Q. we they dirctly sitting on top of te parut 17 an the ground? 17 0. Ak who- 18 A. -- hadnvr iu•ed the d•ssal li•ense. Mlw hd 18 A. No, they -- thoee boc -- uh -- there was aspalt i. h± te- Ind 19 under- -- zxxk the maface - 19 nevr p - they'd take th e it. 20 Q. Ckay. 20 not paaed it or disposed of 21 Q. N do ou un tad te to be? Wht 21 A. -- undr thart yard. 22 would -- was the• - 22 of camose, the Wailding ha a anxxete 0l to 23 it. 23 x. fre crevic licerme. 24 0. Mkay. 24 A. m wa,. 25 knd •a ias thei r ee? 25 Were sane of the directly an top of the

33 35 LAKE m4£E iwa=IN SUZ41

A. I assme it was Isotps So.iati . 1 asphlt~? 1 2 2 A. Yes. Now = you know i-ei-e tie w•see that was sittinr 3 Q. dray. 3 4 Wes t•-ee any type of oix• over tie bxes - 4 in the yard - framQ 5 A. No. 5 A. Yes. We had a -- uh -- a Ie~e that showedl in a lot. 6 Q. 6 a 7 A. Nb. 7 of that_da - had takten in so mih wa•.e from 8 Q. Ckay. Let ne finish ny (,,stKin. 8 custrer, s:Ed-3s hrei -- or whoever. of it 9 -- that wre cut in th yrd? 9 ki : iemscmUy Ice, iere to ht 10 No. 10 rei fran booe I had i I those smmcm to call Iie and they su U1 A. Mate was mn -- athee w as m oerc this yard 11 this caqowW who, bad a aste dihspml 12 at all. 12 it cut to him cr be cmm ard gt• it -- or whatever. eh 13 Q. day. 13 Q. So )u caflled the carmer nd ask tem to 14 Were there any precatiio ta~in to preumt 14 another anixxal ance a•d take it my 15 rainwater fran scekix into the boe? 15 A. Yes. cb I etrid 16 A. No. 16 I--: ws aadked ba ee: 17 Q. May. 17 of this stff?- nd I said: Mme's a li wse 19 Syou ever he occan to see dsoalEti• a 18 d~i real I1i in tie are. 19 an the gard after aiy type of a rinstomrm 19 Q. Was .z r understading that the om~t== w~ho 20 A. No. 20 br-a#! w-r re± to izstcpe speciaities (bairp tba±t 21 Q. Was there arry dicoloain an the gx•xd while 21 that tiat wast was gon to be IIgIand disose of 22 y were woking at the faciliLy in the e of tie wase 22 oerly? 23 in the yard? 23 A .ba:trZely. 24 A. Nb= that I recal.. 24 Q. Oay. 25 Q. dray. 25 Did cL ever leve ocasi to rev-e an~y of the

34 36 LAKE M*E REKRrD2G SEWVI I

Itu bove, amd in cm~rswith tin anmtczres o~anr waste di&Sa1? 1 nmt 00301. wichd is thetbizd dxxve irdicated A. 1h. 2 th e r righthud xx of that dxur~zt is Q. ccay 3 A. I didm t erter a colmc with a~nyn. 4 A. Yes. Q. Okay. 5 Q. Is this the sw'mmzj pool that you referenc that Did yu ev'er reject any of tie waste that a3e to 6 c~rained tin faciliq 7 A. 'lint 15 oarretS. -- octat 60? A. Yes. 8 Q. that crutaiine tin 9 I. 'lint is DZ± I rejected -- dii -- let's se-- two tzu±Iad of U.S. Air Forc waste tint arrived at thn facility 10 0. cMay. -~I in pl-n while yowr eme tiny had a ourtract wit~h thn o~py tint said tin 1. VbS there any pral at tinre was uaf2l1 pad~age thiri waste properly far tratnit and deliver 12 at -- Lb -- a==i f=r detexminiý whethr or tin pml? it in tint ccrditiai. tWn diix' t -- tin!y had noi do 13 any cnad in this waste cin tin tnidts. 14 A. N:). Q. Was there any procerbm in place to chec tin 15 Q. OWa. %Us there arry prooei~re in place far detednix onraiir or -- uh -- woode b ~ cn a periodic ksis to 16 in tin piping? isetint tiny wer stilJ1J itac and riot 1e~idrg ary 17 whether or rit tiere was any leasIe 18 A. 1b. tin A. Vkuld youi repast tin q~esticn? 19 Q. Dmirgr tin tute tint you were at Ni4m was Q. Was there any p-crnkzr in place to prodcly 20 -e in tin pcol eve replaced? Ir there was cherk tin cavtairms and thn bam tint were cut in tin 21 A. 7he n tire w'ater wasn't replaced, --- to take care waste aras to seif tin were sti Il ixtra - 22 rr*a-up wate added to tin pcol farvW A. No~,th~ere was mi parocelre for tint. 23 of eiqnretkn. Q. So there was mID by 4&ii± LEE- 24 Q. N-6 do )cu have an estinste of ~apprimtely howv Isotopes Specialtia Cbffpxy detnn~dr if there was 25 mdic water wculd evapcrate in tin prol?

37 39 LAKEM*M REM= S3MCE

1 raicacive materials lekidrg fruim tlxe taiz 1 A. Nb, I do Mt. whehe or not 2 or... 2 Q. kd was tiers arry way to derir 3 A. I &n t. Iaxv what Isotops Specialties did. 3 tin -- uh -- re~ikctim in mate was cii to emvqrxatiin 4 Q. May. 4 %vraaslow leakge -- duh 5 Want did IMA= cb vkjen you wer fmpkiyad there' 5 A. No. 6 A. We did rx~ d~ tin ccrraizr far lemee. 6 0. 43M. 7 Q. Ckay. 7 Men ýKu left tin facility 8 SD)c cl aemwyo rwMoewyo 8 1b ýý reail aprxidnstely when you temimutei Nmm'? 9 tin other whenther tin mere, in fact, lasunr.? 9 )c eqpkcyerz with 10 A. bb. 10 A. I g. smwmm r in tinse in Jwaxny of '61 1 U. But 1et Ten just f~c tin rerard state thnt *air 11 left. 12 wre'las muzmi a inzarIb~anomterial cpm-atix ym1're 12 Q. kid were did you go? 13 diirg it in a restricted aera and ýtx aea tint you re 13 A. 1 we= to tin k~Cia MVMW~ Cgmndsioi. 14 goiU to mxiarmdnate that aera. 14 Q. in what state? 15 Q. ay. 1s A. Cli -- (Gmtci'a, mnyland. 16 16 Q. At tin tifme you left tin facility in 1961 w~astin 17 this doomnt. 17 u.t& sti IlI in tin swnýmir pxil? 18 18 A. M=n isret 19 uh -- crp:ia thnt I had mad I will take tienemm tint tin 1.9 Q. Did yaci have any irmlvenuz with tie 20 witr has maredan~c and aske orpia for everybodiy, so 20 csmniasicniui of thn -AimurM pcol7 21 maenwtake a break... 21 A. I was mt iuo1lve in arry decramnm~imei 22 aklef pan vhiile Mr. Browni, Mr~.Pttersmr and 22 Processes -- uh -- befare I left at all. 23 mr. aiinea rveZS2doarer) 23 Q. Clay. 24 bcS. Vci=l: Q. 0ay. 24 X-d stored in tin avmcxý p=1 maethe 25 I'd like to dtnvw ýom attatraoi to doomi~t 25 ccblt 60P

38 40 LAKMEM*MFEN3 SMUCE LvE imm mra= SWZCE A. where was it? 1 One of the biges rweas for o~zaizq Q. Was the cobalt 60 stored in the 9wAmvirU pool? 2 cadzeted mterial is that yaw workers t work in A. Mt is r. 3 ther they'U 11 ge z, so they •da•to cr dmn heir Q. And in what minter was it stored? 4 adwq ture, and this ges to be an econ2mi fHe. A. It wse stored ai the bcttn of the scimrin pool 5 Wahn it gets tco had. then yKu cle up. in biscuit par. 6 Q. Nd &zr-x t.he tie yo. were there, there was Q. *at do you men by *biscuit pans"? 7 re-e any claau.V A. Mm tin pre that ane pits dm&h in and nakes 8 A. No. hiSai in. 9 Q. Do you lax,, -heter. there bad been any clen.up Q. Literally" 10 pro to ý= ardngr to the facility in 1959? A. Absolutely. 31 A. lb I krnM if they clemrd up befre them? Q. And wt= des the cobalt 60 lack like to those of 12 Q. Yes. us in the rzom that have•e•er sam it? 13 A. Db, I have rno -- I don't rer anr rerd of A. It lccks like a sall cyline of gray, sort of 14 it. ffetallic, nrt krilliant brigt -- that's it. 15 Q. May. Q. Aid -- man how laxge woIld the cylibne be? 16 kd wte is the largest uitber of Cnie of A. It dep on vkii reactor it cam from 1? cobalt 60 that were in the pol at any givea time, if yu Un -- sce of it is about as big as that pen 18 recall? (ir{dicti). Sem of it is frter. 19 A. I wnuld sy in the ramue of 6,000 acres. And one takes bolt n-tars ad cus off a potion 20 0. Now biadW y= attentin to d&oxtem tnber and aesues how mey curies that is. A-d then yu pat 21 00X 302, the rmr dzcumes in line - that into a stainless steel ccrxainrm and that' s a seal 22 A. 302? 23 Q. Yes, sir. Q. wdWhen youwe descrieing the pen, the pen was 24 -- uh -- the C-14 labatory. akint a quarter inch in diameter? 25 akief pru•u wile the witness reviews dnzreo)

41 43

A. Sme are large~ than that. 1 MIE WqI'INm: Yes, it icks like the cold lab - Q. 2 we call it. A. sare maght be a half nxinc. 3 Ns.M:)E=IH: 0Q. y. Q. 4 Is this an=l= = vmri that i -*vm ym Pzx sme of the Fatam e -- hamfat wes that 5 yesterdey evening' in diameter? 6 A- M= wes the questkn? A. Not m3e than ahant a half ind,. I dn't think I 7 Q. vtot this armther docoa- that I s ýtm recall any bae than that. 8 yesterd~ay e-ungr' I s- this one. Q. OWa. 9 A. No, I cbnrt believe Wbi1L the cobalt- 60 on ocrasian have any rsn 10 Q. dray. to blee off the -- un- p gin or th - U1 Wat we ckre an the ben that are idmifiai A. Yes, it wuld -- uh-- it would -- uh - 12 here? It was kind of a brittle fretrial ad -- uh - 13 A ese are rxwilar laboratory -- like see in a the effects of water and so forth -- there was a Plati 14 high s l nnistry cda . It's just a raised portia ct. effect, '%idn .re that a very stall 1eRw would ge 15 and in the mddle te's a hood ard thn y do your on the walls of the swinmnan pool. 16 labmtcry work cut on the suface of the bn.tL It's up Q. knd ixnwgtie time ui we•e at NkL fran 1959 17 ahbz this far off t•e floor (nc:U}airg). It's higer to 1961 did arene ever dean the -- of the swimmng 18 kermme 1vj' re stardiig up, bt- 19 Q. What- A. IN. 20 I'm smry. PAd the reson wes tat the madiatin level did 21 neer get high h so that the non coUbIt cpee from 22 Do ýcu wnt to funish? the s9~aa of the pl - 23 No, that's it. A. Q. Safely. 24 I q ypeoi s. A. -- tidn is-- 25 *et type of wor wes dre .in the nab-14

42 44 LNVE M8E RFWTIN SaICE -- a lab-atry? wek bea emitte, so you 1l hold a cylinde of it -- tbe of it inywIIadyo ml o e A. 'ryW pmrobed tage -- 1h-- Cldcail3 %lith glass a ~ai14 atoml as a s.1otitute forntia enOrtel aws kid how mnVi vials would be sared And then they prcxied tritiate ai w uzd whre on pt Q. ~atudizately the tritium in and sksitutes it fBr the romal hydroge at any given time> -- uh- atoml. 1hee beame tri r to be use in edi A- I hav.e mDide abou how?nm vials, bit

tli -- thLy also did sate P 38 wxk inde, A. -- I'm sare there wa a omsideable ancunt of agin, usirij it as a tw 1i 14, being as it was les hazar.ie to keep Lug=r Q. AndP 38was the fllrloiixi? A. 1b, no, pkrhospu5. 9-titias. wouldhae visited Q. Mlay. Q. Is this a laboratory that you Nil when yx say -traer, was this the type of on a regular hsis A- Absoltely. tracer that was used, for eautple. in the oil =Izsxasy Q. -- as pat of yc respr-ibilities? for -- h-- detecting pipe locations? A. kAbsoltely. -- wedd not allow, any omking, any BIsrxzial radiograpy, I thirk youn're zefernm we alad not any chdu in. there or w~thuzj like this. Mwra to, is to check tie integrity of ssll eleasnts. and that eastir, woe glve. They woe labtzory Costs. 7h are include those mad in ftrxkY mm=3sx and OpielIs, bath of protetiofn. gas and so forth, to sade sr they,13 tan te ptessue. bootia 7hey woe all type Nowthi Indbanothfr to do vth this 2aottcry. 0.How fresent1y wwthis lab cleaned up -- th tV-1? M-atta a hot as=ce and it's in the hot oell vkxw they floor cleae u.p and the %all cleare wael those. A. I'm sory. I don't ber ),x. floos of this laborator~y Q. Owa. Q. Were the w]Js and the Wecan talk about that wheni v turn to the hot cleared on a periodic basis? cell laboatory. A. ]Absluely.

45 4.7

N

A. Allright. Q. kid bow wee they cleaned Q. in this koctario were there arry hazadoa A. Mfl-y were uaselly mopped, uet--stpe. ntxasthat were stored? QAnd where did do -- go that bad haen A. Yes, and there' a plenty of hazmxb dhandals as by the well as the raioisotopes. A. 'fle wtr wet ax no tie backar Q. Mray. sdiintsz pool. aid %wso]Jr 1-J- in a barre~l as a dicaive CmiK indicate an tie map Qdee tie tx waste. mraterials wee stored by writing an ISW? Q. Did it ehin into tint arm? A. A. in -- I think it's -- uh-- in this ctm rgh 0. to hrem %here it says "Safe C-141 arm. Did it -- bowt did it ge fran the ~I lalo Wrief intearn icn the area of the swimming pool? M.. MIMMl: "SfeW, s-a-f-e. A. Inbdraets. 0. "s~fe-, right? Q. Mray. A Yeah, I thirk that's - A. It wa in cotairmes Q. May. Q. -C-14". dura? A. -- nuinly Qiere they pat them -- right in tiere. And =iwa stared , 55-gallon Q. 'lie sale is difficult to tell. A. 'flat is right. C anI rýl-11 dnuwtelY vka the viJthmk Q. Mray, dray. and length of that arm? 'Iimnxg yo attemrc to cbizaxat 000303, the A. I'd say this -- it-- this vjnole laboratory rrb age~ eflal Labot~tory 61, vkat is a glome baG -r here (indinetir) ms t mrire than 30 feet. A. Tli -- a glav bo saa cotainerhthat ha tw 0. kid how were tie materials storeL? large holes abot =ahtijra height; that in tieoe holes A. In vials uejally. are hge nth gloý d=n - all the way u~p to the Q. knd bow - bile. Qne stri coe'sa throqh thes houles, and then A. Cm± 14 doest have aiythx bat a vey we*, zhey are in the 11ke glovs And now' you are working in

46 48 a glove bim contained area using yaw wh.ich axe 1 A. Utme -- the Lie that nra dixerty down throgh protcted, by the 11er gSles. 2 that whole stxnrem is the ede of the hl line. Q. Is this ore of the ho ares that j= -- ho lab 3 Q. May. azres that y wee referening earlier, 4 p yg e was the ho laratory A. This is one of the ho lab ares. 5 area? Q. How any hot labs were there at the facility?. 6 A. Un -- I think those -- those -- the rigthad A. Uh -- ther•e were aboiut -- uh -- half a Imm utt 7 siak is a hallUway, and I think thse cells were about ten we call cel s in theat lab where this wlk was perfo1m. a feet dee, 9 I'd say we're talking, maybe, total depth lN=mUy in a glove box ce doet snftI F w=ak 9 acrss I is akit 15 to 18 feet. with 9mna smres b the glovs offer rn protctioni 10 Q. kd its width, that's lerngth, it's from that, hz they cb offer sre -- gmite a bit from any I2 zeferring akirg of beta sames or -- uh -- in sce instances with 12 A. I don't know abua the length. additicral shedn, netitrn sairoes. 13 Q. Ms the 15 to 18 feet the widh or tha length. Q. does&cnt nzrber 303 only show us a portirn 14 A. Yeh. of a rran, or is this an en'tire rcon that we're lokin at 15 ell, a.ally - an this diaram' 16 Q. Yih or the lenth? Which one, with or length? A. Ch - if I can go bark to one of t-e original 17 A. U5.h. fsp, I think I can give omuan ill•stratin. 18 Q. Ckay. 0. Okay. 19 A. Memhkt Cn Is sopped araut smmftxe in this A. This - 20 axes (indicting), and in be was actually the shop Q. Wht a, bez is that? 21 area (ini irn). A. This is rntuer 301. 22 Q. When ym say, "In here wes actmlly the shop Mmses numbered mllIs, 1, 2, 3, 4, and so forth - 23 arem," w are you referring to? this is a typical pl of e of those 24 A. I'm referrir to the ares betwe the hot lab and Q. kaiy. 25 the cold lab.

49 51 LAK MMWINM-E SMVICE

4

Ad that 1, 2, 3, 4 is tp an the tcp part of the Q. Oay. pmag next to where it says - is it -- un -- the cold lab heing the C-14 lab? A- Nd tha Iwr of these vary. 7f-y pit ,rre in A. Yes. tier and thy, take than cm if t1y reed them. MWa cold Q. day. hWild then up, put then in and take then cut, so that So wes tie ma-sine shop appnuotely to the varied. rigt of %kxewe see, "Oilet" -- it lIra like -- "5,000 B3 this waild be aem of thoes and this am would be way down toaerd this end mroe -- probably rumber 1 - A. That's just a rnark an the vntilatin system. awy fran the botter ones. 0. Gry. Q. dkay. (Qfd you describe for us where tha mchin shp And you're referring back to dxumnat i 303 was with referenm to sum of the wording an this dzuwrr? wvu yni say *this ane"? A. iell, all of the - A. Mray. The way you rrake a hot lab is yma have to hai Q. Mray. negative tlatioan in the iht lab so that wven yu opn Now whe we lck• at dcrment nuvbr 301, does the door in the ho lab yua feel the air canirg in beind this do ermt shuw usethe etire hot lab? ycu. It weeps any conaination out tha exa systen so A. Yes, it does. it is not in y•rre•thin•r n e. flat's a safety festra. Q. Ckay. 0. dray. A. And this arms on the lftbad side is aually - A. jAd that -- what all this vetilation is -- is that's that resreac oufit divisian -- the t call. ended each one of these is J=I and ges up to a rof fi t rightthere - and so foHh. Q. Where - Q. Mfl's nmt alet is -- a bod?. A. -- along that mddle line. A. Moat's rghrt. Q. W it says "Q±Iat 2,000 CFM System", is tiet = ya~' re referringi to? Ard where was tha mrchinzm shp?

so IAKE M*M REFCRIU SEWICF 1 Aas h madune shop between• the hot lab Kd the 1 Q. Cka. cold lab. kmd what ws die in the cell? Q. Is it where - an4zdi, tely tesm e little A. O taes to rept) blac circles ae? See the black circles in etween the Q. )tn was de in the cell? cutlets? A. R-b7aaii of lag germ radiacion so s. A. I'm not -- I don't see vihant yu'e referring to. Q. Now on the rig side of this documet ther, s soffe writ~ing ta says, 11igon 0. Are you on dLunt 301? wase drum nt used*. A. I'la n 301. A. Wel, the place thre is fo -- uh -- s of Q. M~ay. radioictive gmtrial to be u-s in scurfs and of b ymc see were it says "Q±Jlet 3,000" ard then crpletl zamiactive msaia in source. to the left it says QCte 5,000"? Q. Did yu eer physicalUy oberve cne of A. ch. tht's another vntilarim system. Mat's tyrierg ld -- uh -- waste drun areas at the facility? for the cold lab. A. Un - we didn't ham any urd=gXCt d waste drums.

0. (kay. what we had -s a araete cyliier &]anin the g9o-d, and I'm still trying to get a sense of where the it ha a1- in it. It usa't sitting -- it wasn't a nachiie shp wa. drum. Itews a - *y dont you write down -- write %here the And then we bad a ariety of tx-s in there that nahine shop is aid hii se the &airff f= a ,anmt. could he naaid amzir so that we culd put sours in A. itss s toa inite) differfa pr a and mk whatthey wt add who ty wre Q. r-ite it dw,. plamse -- nbine shop. and so forth A. (Wites apias) Q. Wks this loted in the ho lab? Q. Thr Fnu. A. Yes, it was. Q. And appriately hw, was this -- .h - M6. M:EM1' - Q. Ah! Okay. stoage areEL So the s•ha. shp is higher u a the page A. Akr.- four fee, I think.

53 55 LVE MUE FWCRMG SET=

1 c -- r il izxlr where the lab ruit 1 is. 1 Q. Mkay. 2 2 And arunstely how, wide and lcn ass it? 3 'kay 3 A. It ws about -- uh -- two fe in diareter, 4 ±r to doumrut nter 306, %hidzis 4 5 described as Lgrat= No. 3 - 5 Q. (kay. 6 A. M= ,s the rudze of the sheet? 6 knd was it axc=ete-ined? 7 0. 306. 7 A. Yes. 8 A. 2? 8 . Ckay. 9 Q. 6. 9 *-s tiere ti• thian e of these tys of 10 A. 6. All right. 10 storage- Gb it. 11 A. Yes, I think there e two or three -11 that 12 0. May. 12 had tine kind of stor aotainers in them 13 Most are thes figumes that we're saeuiz an the 13 Q. were they afl. 3nt- in th he lak. 14 left sd t,dh= zurxed figue? 14 A. Yes, they were. i5 A. This (indicatzg)? 'lie mmxzd figme?> 15 Q. Ckay. 16 Q- (I tas) 16 Drg your artation to docurar 307 - 17 A. C!iiy. 17 A. 7, oiay. 18 Thnt's a hx cell. 18 0. -- the ne ? 19 0. hiw, large is the hot cell? 19 frief psum %hilethe wness rev d nt) 20 A. Ch, tiat ane is probably aieazt fo= fee long by 20 M. W 0=:Q. Ch -- do•u re nize wt 21 to~ fee wide. 21 this deits? 22 This is ane of thoee cfl s that ,u saw an th•t 22 A. Yes. 23 cther on - 23 M-is is arc- -- uh -- e-napaiatim ht call. 24 Q. Pnd %&n was dn-e in tie cell? 24 A-d it's apparently fcr the hier o soc s.

25 A. -- i, 2, 3or4. Miis isrof those. 25 I dm t ca ' Idm eenu sking the soaur that

S4 56 1 lazr whiile I was thee. 1 "Z question went to the st eraarea in t ko 2 Q. M- yc• say *that lazr , are-yo refeing 2 lab where yui wouzld have hm stoMrr source. 3 to - 3 A. Ch, I'm sure there• ere nmy, any sources still 4 X 2,000 an-ies is wt= it says down here at the 4 stored in the hot lab whn I left there. 5 botctm. 5 Q. Cky. 6 Q. dmy. 6 Is that becase you wcld have sen then or is 7 tin -- an the lefthand side there is a wriirng 7 that just y recollection? 8 that says, "Storge holes in st C sk"? 8 A. Un -- I -- I dcn't g• a rrn• and physically 9 A. Yes. 9 intory s 7h. 's too muhe sure. 10 Q. Is that wt yu were referzing to a nom-t agn? 10 Bt -- uh -- we always ket a lazre nxvber of 31 A. No, these are differen. 11 soceas an hand. And these are stll %sluable. knd I 12 Mvse are -- these are stee-encsed lesd-filld 12 would asume tat sar y sold them to some taer inlxary 13 casks. You hae to have a I I aiit= -- wtnxmý re 13 that oi!d use them if and wa they 1 qur the 14 up to this size scu a;ouneed, as swn hIere, eigt 14 facility. 15 inches of lead -- no concrete -- it will not stop it. is 0. dmay. 16 Q. Ut -- how ,sta of these casks wee there at tha 16 Mie ýK left the faiity in 1961 was it still 17 facility.? 17 operating andl rmufaft.ring sourtie 18 A. Wt kind of casks are you referm to? 18 A. Yes, it was still cI.ati. 19 Q. Mh type of sa e cask that yu just described 19 Q. Ckay. 20 with the lead. 20 tin -- tuzniM jtrx attention to domznt 308, the 21 arief in ion) 21 nnet kxzret in Lirm, there's a referenc to High Level 22 ME W"DESS: Ch 307?. 22 Laboratory No. 4. 23 MS. M•I•: Q. Yes, sir. 23 no y.u krxw wat is nw by high level? 24 A. I ham rno ia, hbutat 24 A. No, I'm not quite sure, and - 25 'flare ,as only one, I believe, in the -- 25 UE -- I &tn't know vial this was doe, bZ --

57 59 LVRE 7IMM I

Q. was -- Mus may have been %tatlat ue the storage -- in here. area for tie high level radiumn drus cut in back. Q. Was this cask aboe ground or below gzuxx Q. ckw. A. 7hswas above grourid But y don't know oe way or the-Vther? Q. daw. A. 1b. Brief intomtion Q. Ikry. M?. ?I.tCl=: 0. When )ou left tie facility in A. I'm nct familiar with this type of arsbeing in 1961 as this cak stiUI at the facility? use for a -- uh -- a laboratory. A I hamno idea. 0. cay.

0. Ckay. ziiMr >a attenti•n to dckuM 309, tie rg= Whn yu left the facility in 1961 was -- wer d~umnt -- um -- d you recie -- uh -- stat this the storag pits still being used -- the storge ares that &tmznt reflects of tie faciity. wax just decibed that were tie fa=-fcct de. storag A. No, I dn't from his -- uh- pits? It loos like some kind of a stozg facility. A. Well, we -- we had e all of the aste Prdmbly the last -- last cll back tdere. MW dad have stored cut in that hck are. I had taken it all cut and srme storage facility -- surces stored in that last cell. dumped it in the oi. Q. WhenYou say "last call*, would you be referring Asd I had zenve all the mn•sresiin-thiin cut to cell rumbEr 1, 2, - of this back buildixz anal taken it -- sa- that up to A. Niubvr 5. Idaho Rills. Aind I bad renmvd all the barrels of raidin Q. NmbW S. Ckay. anid set that up with tat nm-tinr. knd I'm going back to dxrnwt 301. Ckay? So all the waste on hand s basically - 'bexe's a reference hre to "10 storae holes,. possibly a few barrels as a result of activitieas in the hot Do ioukno what that refers to? lab. A. in stor. holes, a- say., Q. Ckay. Q. Yes.

58 60 LA3VE M PC3 SMVICE -- 1ý

-I

1 A. Yes, I see that. • Q. No, in tin middle of tin sg.ne smethirM says 2 Yes, they l htcaolkrles and thiy wre - "drain" and there's a word beneath it I can't read. 3 again, w thn stel pipe drnp down and - with the A. Mrain pac, p-a-c. 4 botttos in te and were trs tat one c•icd lift up with Q. Do jxu kncw what that refers to? 5 a pulley and thIn you cold pick a sourc hole. A. No, I don't. 6 Q. A*d this was siular to tin fan-ft de - Q. May. 7 A. Yes, r swall= in diamter. "Mlmingyour attenion to docmr 313, ••ich is

8 Q. ky. asoa mdmdxM pool diagra - 9 A. Mxh,. much smaller in dianeter. A. I'm looing at it. 10 0. Do you know pa~Dnstely what the diareter would Q. I take it that the trolley hoist was used to 31 be? iowr ad re sources frm the pool. .flnre's an "Sr - Trolley 12 A. I would sa tine/re - th*-- Icu're talking, Hoist". 13 ,yAbe, three ice or srmthing lie that -- three ude A. 4= is gti sicn? 14 in dinneter. Q. Was that used for lintxg ad takiMr sa es cut 15 M.kay. of tin pool? 16 Drawing iax attetion to cxxvma umber 311, A. It was used for lowering the cast (sic) -- the 17 vkhdi refers to a Laabgeorhato:ry #5 - cask to take - 18 A. Okay. I'm kediti at that. Cne de't pid&up the suce. Nhat )u do is 19 Q. I'm srry. loe a shielded caic that has a bole in the ottom so that 20 A. I'm bxcing at it. the water • gn tgo ur h it. PAd thn yu get don to tie 21 Q. doy. bottm. Tlhn you pick up ur soarce with a rmrote ontrol 22 'lrse lJittl circles at the ttom of the pige rcd, lift it up, put it insoi the shielded cask, pit the 23 there are twelve little circles aid then t bi circles - lid an, carefully hoist it up, and as you hnist it up the 24 uh- water ccres cut of the cask. 7hen yý inv it tp here 25 A. Mwny~ to bestz loations. where it 's shielded, and then ycu take it to the hot lab in

61 63 LANE WVE RElR= SMVIE

1 0. Of wh-ant u -- of t1he type th 3;u v-e just 1 that conrtra . 2 d 2 Q. COky. Ckay. 3 A. That is e . 3 Drawir yur attenti•n to doomeM rutber 314,

4 Q. The steel cylirm diriven own inmo the groxxV 4 also Sdmmrd M PooFciity -- u -- in tn4m r r ýra 5 A. (Witss s head affimtily) 5 c dmerthere's a referenc to "ackwash - to Wiilding 6 Q. When you left the facility do you -- did you ham 6 thrcnjn mr-i-siphon valve-. 7 any irmbmv•ent with rnovirg t.e metal cylinrs stog 7 Do youknow what tdat refers to? 8 holes? 8 A Ro, not particularly. 9 A. Did I t? 9 Q. Clay. 10 Q. md you hm e any irmimment with ermiq tihe 10 Man there's a refer•mnce to "1-1/2" -- it loks 11 metal cylinir sta holes? U to me like an atbreviatim -- "cbic pipirg - grauted in 12 A. No. 12 pool •alls to be given 2oG-perce.t (sic) "prsstire te 13 Q. Cky. 13 with no low in 24 hous". 14 Turig Yor attaitian to dcuzEt •a 312, 14 Do you know what that refe to? 15 then rrxpa , which is referenced as a SwmnirM Pool 15 A. I thirk that was a test result when they built 16 Facility - 16 the pooi that it was so~x~ed to be bWil to. 17 A. I see it, es. 17 Q. Ad &zuU tie time period ta t were 18 Q.C cky. 18 at Nx= from '59 to '61, did yo ver d any pressure 19 Lh -- what was thi pipe gmdrail referiMn to? 19 testrr? 20 A. 'fat was a railing axcxzd the edg of the pool to 20 A. No, I did mnt. 21 kee people fromn aoietally ftUuxj in. 21 Q. Ard do yot knowm ther man else did? 22 Q. COky. 22 A No, I di't. 23 nd tie "drain* -- is it p-a-t or p-a-c. 23 Q. Had samson else been testiM tie poi, would 24 A. Are you referrig to where it ws says six-inc 24 that hae been inonstian tint wulid hma cann - 25 cub? 25 A. I have no infoatit on thnt.

62 64 ING MOM• FUCRMU SWRVIrE 1 Nol. 1 abcuZ e24t fee ak~e gzrou. 2 Would it hwie been izzamtion that wold have 2 Q. I see. 3 Come to yc~ -t io if Sansoe else had hem testirg the 3 So~ it was an above-gxnxd umie - 4 pml? 4 A. 7ht is~ 5 A. Mt necssaily. Q. -- pit -- bcmas qpposeto apit. 6 Q. day. A. NaurlzlJy. 7 'flat wuAd rot have beeri discussed at the 7 Q. dray. 8 Isotoe Cammttee %t the =="~ta Tnat 8 kri did that sit ai tcp of asphalt? 9 A. Mot i-I1 it was a proc~erbe that harkit been. 9 k. Yes. 10 done. 10 Q. dray. 3.1 Q. at was 9*oee to he beixM done? Ul I'm don with this adiit 12 A. Yeah, -xýae to be done and wasnt done - 12 I'd like to go ha and take a ten-nmnrý break, 13 1 1I't been then it mild come up. 13 pick u~pthe cthr documents arxi make ccpie of the 14 Q. BRxt to yaw krowled1ge this was rrt a prosaire 14 15 that wa ae craa a reglar baIs? 15 Can I pias get a cop of arzy Of the documes

16 A. No, a air asIknowit wasriot. 16 ywi have there tha ytouz'e mad ~soe writizU m 17 0. drY. 17 A. Sire. 18 Mnief Pame) 18 Q. -- this n~rxp? 19 ME.):KElM: 0. dray. 19 20 Then~ zd xzse I'd like yc to lock at is 316. 20 21 I aolgi~ for the quality. lids is how wego 21 ME. lIH: Adi we ca g off tie zad 22 docmetUs ftrc the AM and tiny're vey difficult to rea 22 M~E VICS3VO: We are off the Ietxat125 23 at tmnas, and tb3iS is Cne Of them. 23 Wrie xeaesi) 24 rb yto kmwt this documet ref]act? 24 25 A. Do I k:c vfitm? 25

65 67 LAKE DR 3W =SVC LW~ MT REC EI

Q. Do Fn~ kno vht this reflects -- this &a~zzu? dorirmet nuztetsJ Qnyute11%at it is" 000301A anc 0003MA hc ccrain the vdtneseW nzakz~ A. it's another drmAvi of the faciity. wee s11 1 ; to Oftbit 2. 0. dray. Li -- I se it says "Strage Yard" arxi to the ME VICEGATM: Al rightee. rightised sid thee' a littl box that say "Pit". stand ky, p]sse A. Yes. Wrif PE Q. Do youev~ kno at that pit referred to? MfE VID03O: We are an the Ie~at 1LI4. A. Yes, it's the same one that wead ove here ai Please 1 t1.

thn first ftw rg zi -- tejer it is - M. RIO=: Q. Yr. vaen an yu tell ne if Q. Chb-kia yc axe femiaar with vtot types of I to Show~m

A. -- 32. the ABc issue cr i mar at the time of the 19509? Q. Ckray. A. I didn't view, those I. I didn't hase any knoag -ept hearsay -d thst they, edatd. A. It's just anotier picture of tha siam Q. day. crwriiretrn. Thlem tiat pit vkgre tie riuhu barels was, Did anyx tell you %bat tIrIr wee in and that'Is what this pit is. referenc to? Q. ;bw dee was this pitJ A. No, it w.as amrply -- it was amply stated that A. Mxhctse to rsepet) they wer te to rionoapliance rte. Q. How ee wa tie pit? Q. day. A. Tthink it 'as sabtg- ft~ stat- that to )KU? 'pll it didn't go uzdowguznd. dMay? A, 'The represetati~e of the Atazi Hnr -hs a a build-t.p doube-wooda stutr arm~mikn, rgislYGe Ba.;[Ia f J 1lIP wit.- sand ax all ai sabct twDc-foct thick per 0. Did Mr~.Blarr tell YOUubt type of nrn0CP1iarB shizeldizij anc it was hdIlr aboe ~xrxr.'fin ttp of it was be was referring to?

66 686 LAKE M*M REM= SMVICE A. I can, t rember that he did. 1 MSEVflECUR: May. Q. DxirLn the time period that 3ýoc wee arployed at 2 Stand by, please

Namr did -- ut -- the faaility receive arV ethe I of 3 M'. MUMl: Were gongq to 9D bak on the 4 rminrd. A. They did rat receive aiy sb catie Io once 5 71E VICEMME: Sandt by, p]sse

I -- IJen I was employed there 6 Mrief PENm) Q. is a show a~oe different than other types 7 MSE VIC03AFE: We are on. timer at 1158. of I Icn cocrnn xrznospbane? 8 A. I a.ze that ther~e wee an, more tan one 9 M'. P::1H: Lb -- just to clarify in the emen occsion a -- uh -- letter stat~irg that their ingpecicl 10 we er off the reod, Exbhits 3 and 4 are blank. Thet indicated there had been an item in xonczpiizra wdit the n next Exhiibit in line, Exhibit 5, is d.muet. rxube 287, an 12 Ppplication for Byrduct Mr al 13me Q. 1b you recal1, or axe cu speculating asa * it? 13 Q. W'. Vade, is it yc unclerstarrifrg dat you Min ou sayo sse that fran time to tine. 14 onipleted this aplicati~m? Did you cx!Iplete this doyo actually have m~y recollction. here today ab3a± is arn~aticn? notif~ications of nonampliane? 16 A. I aarzned I did. ye. A. I dVt recal a speific incdcl. 17 0. Ma~y. Q. May. 1s TM-- and on this aplio aic is a list of type

M'S. NJ=fl: Can we go off the I~a secn: 19 of hmard -- exame ae -- radcstive materials: MSEVIEOAPHE: 14l are off the Ierat 1356. 20 X~csicn off the rezcord 21 sulfur, sztntz=,, layptan 85, - M.. ?tJ=l: Mkay. 22 (Imnerts off tde record I'm going to go ahea and do tiat. 23 M'. ?':I=: Q. -- sodin. hydrogen and We will net be marking an Exhibi~t for adribit. 3. 24 polaiazn 210. Ird like to nnez* Bd~iit 4 -- 25 Do those reflc the types of matetrials that

69 71 LAM TMM REMRT SERVICE

1 NX I- I wolcgir -- we willot.bemnarking an were, in fac, stored and use at the Is 2 Exhibit 4. A. Yes; that is tru.. 3 'Sme ne= Exhibit is BdWint 5, wh&ich is a Q. -- at theim sotops facility.) 4 two-page &alrem 00C.87 -- actually it's just a ane--pg Ckay. Andtheare's a referenc here to a (AM Sie ouetetitled Christine Mi~ylor. 1b you recal M'iss Whlorl for DADdt A. Yes. for Idenification as 8 She was a -- uh -- nwiat-ion tech that I used for 9 M5S.Ml=S: Q. Do yo rerx9cnize what this help with surwms, and she arelyzd and rart seiplas - 10 d.zaret. is? We bad a cota ct with the blarqplitan. Water U X. Yes, it's an application for a hypodizcdt material Dit= o analyzing wat sarmples fo radiation. She 12 license. did that type of lab wor.

13 Q. Ruell emp1c~ed at Nx= would younlm'e comgleted Q. kit do you kcnew why she would lave been 14 adic types of q~1icaticoa? referene here as assisting yc 75 1 .Of the tonem? 15 A. Yes, I Submitted thee for pudirtpo~sesand A. Un -- I -- I presemn dmyre referring to the 16 for xrxal parpee on rirears occsions. fac that I did cosufltirz~i m e~alf of theimm y ~n-- 17 0. Ca yo tall whether or net yc wee the pesn uh -- as well as serving as a riati-in safety off i and 18 i&D genrared this praticular d~nrnt? health phyeics rffi 19 A. Gan I tell w'iac 0. So did yu do consulting an tie sidck o-sic of 20 Q. If )x wee tim perso i&D genated thm your -plcya-- for Laxqias? 21 doajmet. A. Yes. 22 MSEVZEGRFR I'msry. Are wesoff the I would be hired cut for $120 a day as a 23 I~here? consultant to different people that -- um -- wntmed 24 M'. MJ=fl: I'm sorry. No. assistance on wari~tingapplications for luxroes or do some 25 wel1. tart over. spd i work~n~at sare other plant.

70 72 LAKE7NE PFtCRDM SERICE tAKE M*M REFCMMS ERVICE 1 0. And, Mr. Vain, VhM YiC hirUi Out a 1 A. Well, my drjAve wms to rmoe all the 2 t did they pay Istcpe S ialy r Nur did 2 ctamnatio, r i coztanatia•n, frrn tie fcility 3 they 3 to tie satsfiacio and ra~uemna ts of tie kodoi Energy 4 A. 7hat's righ. 4 amms=cn ard the Ic kgge1es( ty Health ]partmem. 5 Q. •7he did? 5 Q. Do you recall %kter there ae gudei r 6 A. They did. 6 rse.iatic•s pb tt specified exatly imt occurs in 7 Q. day. 7 a deamrmiirdizP 8 a A. Yes. 9 It as stiII in the omase of y urr plcynmt for 9 Mee wre Iits set by Atomic EhergY Cb•tnisicn 10 10 with I~ to tie perrmmible azacrr of alpha and 11 A. That is corret; yes. ii beta-gmm contandnatkn levels that -flel be left in tie 12 Q. Now there's anohe refernce just above thit 12 bulding ard also r-adiation levels at 24 ince above tie 13 to "B9.prock=~ material nay also he stored at Isotopes 13 fU• rfae. 14 Specialties Orirey, 703 Wan Street, Bubrk-". 14 Q. C3 y telles in c tion with the 15 A. Yes. 15 703 1/sin Ste d sacni wha are the eeac step 16 Q. Do y - 16 that you tcok at the facility to ecotaminate it? 17 A. I see that. 17 A. Well, the first thiM you d in -- uh - 18 Q. W al o n did mtearials tha we wee using 18 eoaidnxati I rx i is to kInt the ho spot - 19 at 170 Providria be stcred at the 703 Main Street 19 those are rmdujl vry high- ye elbmxnate, remove, 20 facility? 2o and putin nhiet containers and taIw ay. 21 A. Lh -- it ws simply stord there. It %amý'tusae 21 Q. W-hen y. say 'el.nimai., iet are-you zaz.vizi 22 there. 22 Wa - 23 Q. 00y. 23 A- Yoi' nrerzermix part of the sstanroe that the 24 And wywould w a ben sari it there as 24 raiocive matearial has dcpitda an. 25 p I to m the 170 site? 25 0. Would that be s and --

73 75 LAKE 7N= RE3M SMMCE

1 A I -- y thirkin is -- as•I rell tey pro y 1 A. It ccud be a concete floor. It -ld be a 2 weren' t rearly to pit it 2rx= use fr prordticn vr at the 2 rafter. It could be a piece of wallboard. 3 Parovidenjia Wilding and being in a cask and so forth they 3 0. rdd you zeuve f12 s -- concret e at the 4 needed some . 'he is limited at the -- in the 4 703 facility? 5 are back there with the -- twee they could p& materials 5 A. Yes, I tock our the etire conrsente flo of t-e 6 in the Bm~wk -- in the Providmita facility. 6 buildtng anx all tie drainm. 7 Q. Are you fmuiar with the 703 Main Street 7 Q. kid mas tiet bhecme they wre camiated with 8 facility? 8 radi 9 A. Yes, indeed. 9 X. Tnel isa . 10 Q. Was it de similarly to the 170 Prvide=ai 10 P-d I tcrk out ofo the ckard to a depth of 31 facility? 1 tw3 feet. 12 A. It was ted in -- before. '-at facility tis used 12 0. Iob u m -- 13 before c~arently by Isotpe Siecaltii as their rein 13 A. Pnd I tock dovn all the Uareicr walls be=e 14 bmin use IaF tiey ever got u= tie P.oovz nca 14 1 buildin. 15 0. Do yu recalI how long --Ie 703 Main Steet

16 Q. Was it still cetiiM at the tine Wi 'micedat 16 17 170 Piwid.a? 17 A No, I hame moidea vwh -- 4m it opreated at 18 A. No, it warmt. 18 all. 19 Q. So it wse simply used for storage? 19 All I ws -- it took ewer m z r I ehseF I 20 A. It vas used far storae, bit I yes in d1 9 of 20 could clme it up to tie -isfa=- of the agenies 21 denaminatirsj that hlziding be:?az tiey wanted -- it was 21 irriolved 22 a l-es building; they •na•zd to give it ack to the 22 0. Do you recll having irnacted tie 23 cwnr. 23 703 Main Stree fac.ity Qmn you were at tihe Detnt 24 Q. Arid %nt t•jes of activities did yu enag in 24 of He•leth Services? 25 vhmn you dcrmranad the 703 Min Street buildin?. 25 A. No, I did rnt.

74 76 LAEM laMRMI SMVICE: I

1 Q. acay. 1 A- Prettygood. 2 Canyo recal ipprradztaly how ninny drums of 2 Q. Cicy. 3 matrials wee ramme from tin 703 site? 3 A. Prettygood 4 A- Cih. I would say les than a izxrded. 4 Q. And what doe this Ietar referexnc? 5 Q. And tin ixrb~a tin concxee thnt yx~ remover. 5 A. It's -- itss*s~ elngtl -jh- h 6 6 koninu Energy Cbndsiam tint NU~ has sold tin -- their .7 Q. 'fin ccete thnt You rammedi. 7 catmmy there cal M Isotope Spearaltis back to 8 A. Yes. 8 w. Goldsein. 9 Yobi se, I didn't have to ad corxxlte to thnt. 9 Q. Now this letter is -- uh -- mmo March 1, 1561. 10 It -e aleady heay errui to sirk. 10 Doc know whether you were sci I arployed at 3-1 Q. Cii -- draii ymm attention hick to 311 12 d~xnnt 287, tine V sofard .wtities of rainative 12 A. No, I was not. I mas in tin kranic amrgy 13 materials listedj here Urlde item A, B and C -- are those 13 Qmydssio iwrzdrg there starting abo± %tru~axy tin 6th, 14 represrtative of tin apprammite qmnresii tint would, 14 I believe. 15 hive bee in invetoiry at the Txc f-ility? 1s Q. Mkay. 16 IL ¶flrn are a Woed to be tin rrmcmire an hand, 16 17 cand if ý.tu'ze gonxg to excee tint you'll have to get a 17 Ib )Ku have any faimliarity with the 85 dkurin of 18 license aiaxrendn and get prausio to get zro. 1s xaicatxe waste tint was tra~nspoted to tin lNticanl 19 Q. Cksy. 19 RecorMs Site? 20 Doyi recal vkxetbe o not tin gaideIimns far 20 A. Yes, tint was a w'aste tint I treneorted while I 21 deconrasitnin from tin AM were dotiasts thnt w~er 21 wsthere. 22 p~tished in tin 8bieza Pceister? 22 Q. So tin waste reference in tins letter to javz 23 A. Yes, all their regultions are publIsha in tin 23 knowledg weaild hive benm transported prc to jou 24 24 dT-tinr 25 Q. All rigt. 25 A. Just tkr ure is all. I 1aobr ab3,r -- those

77 79 LAKE DHM REKR= SMIM LIME 7* EFR SM

1 M'S.I':Fl: tin -- I wotuld like to nark 1 85 chu of r~aiknitive waste. 2 Edlibit 6. It say J1436. 2 Q. Do x kano whvkatthose 85 dons corained? 3 (A are-page letter dted 3 A. MWincrotaired radixzn I'~rdu1, I1 6to James Mmm 4 fromNKmxeth Numen was 4 MS. I'JB1 And for tin 51 tint docurnt is nurkexi for Idmvificatiai as 5

6 M'. MM=1I: Q. 1b you wei to take a minut~e to Ard I'm going to mark SEuiiit 7. 7 lock at this doamvME sir? 7 (A ane-pa dcktrien errtit1 MasRaeSip to whnich is 8 Thij es to be a Dearo 2, 1960 (sic) 8 attace a cwD-pa 2/16/61 nemo to iarem BLv=andm 9 lette to Lsotým Specialties aoay (sic) ftcm 9 a sx-~ 6nnt

10 Jaims Keon (sic), Chair, and it looks to men- 10 far Igantif±ximas5 11 MES.Md=fl: Yan only hive on agetee 11 aqxes Noe: womt bwarig I~e JM3, whc 22 MR. EF4: th-inn. 12 2 af thsin 13 M'. M=fl: Chi I take a look at this a mninte? 13 left ot and reve give to this Rqxrre.) 14 14 1s M~. bt~M=: I apocoqJ . Can we strike tint 15 'IS. bti~l=: Q. Ekdinbit 7 is cainrised of 16 starting with my1 desci;Xion of what tint Ietwarvs? 16 d==m~ Jt04039 (sic) thlaigh JM447. 17 This is a M.mdi 1, 1%91 letter from, it looks 17 Un -- do ým zuxogrire this docrenut? 1s like, Kanreth lNewran, N-e-wma-n, Ulea1r Cororation of 18 A. ~Itzbr 4407 19 Arrrica, to U.S. kAndor D=W~ 0cbimission. 19 Q.beis439. 20 Q. Can ym rea this -- can you make cut this 20 Mr ntmtin 21 letter? Qn you pkrysimly read it? Is tin print readab3 21 'Ie wrumm: whiich ane wa- it. agin, please? 22 to yuipi 22 M'S.?.Jm: 0. Niozer 439. 23 A. Can I what? 23 A. 439. 24 0. Can yc read tin letter?. Me print is %er bad. 24 Q. Dt shfli be tin firster ntaa 25 25 A. Noi, I dont remgirej this dnx-=

78 80

78 I This isan inte l mseo at Mr. 1 Q. Ca ým tell me ht the crmateny of this Q. Mkay. 2 ]iqjA wide bcawheMs~? 7he Conrietenry - M-Axe is a referen to SMNwhidc I beliee is 3 A. It's vy viscous and vey oily. the Sa Frmsa Oomplace Divisian. 4 Q. So- Is that the AM?. 5 AX it &en' t run, in oter wods. Iv's ja -- it DD yx see this- 6 wJd.] run if it's up to tsi~erawtre to lathe, but o0.-si of A. Yes, that is -- they had thir regioal office - 7 t!= it's pretty sb.gish. Region 5 office was Innai in Sa Frarnis. 8 Q. Is it - un -- have higr visnity than the Actually it was in Berkley, I believe. 9 oils we pi in our autcmd..1as? 0. May. 10 A. Yes, it is. krd it discusses the fact that on 11 Q. kay. Jarxazy 14, 1961 there was a shiptert of approdmately 12 Is there some carln type of rtexal that )u 85 drum ad a lazr eUmbe of woode boes tainifr 13 could compare it to that weasuld reoo3gie? maneium-thor=un to MM - 14 A. Un-- it is a comon material usd in -- in -- to =at is NZS?. 15 reduce hos in lathirg proosses for ay metal. A- Natirl React= Test Site, Idaho Falls. 16 Q. Baz ftr those of us who go off to lme Depot on Q. May. 17 tbe wekcad, is there santhia you can think of in cur -- for diCEsOM. 18 daily limms - A. Mmts rigtZ. 19 A. No. Q. Ckay. 20 Q. -- that's similar - There's also a reid here that "SR cbserv 21 A. No. the disposal of 942 dus and six master-drun aztauirs at 22 Q. -- that's similar in tam• e ard viaity? sea on Jairuy 14th," - 23 A. What was that? A. Mat's riht, we took them cu anddumped them 24 Q. Somthing that's similar in viscoity in tems of off the hare. 25 how much it would run? Cna yKu thirk of smething --

81 83

Q. Does this reflect -- the 942 ad the 85 drums and A. Ch, I'd say ahxu SPE 50 -- 60 maybe. the large nuiber of wooden boes -- would all of these have Q. kid SAE 60 is Wht? cam from the 170 Prvicuimca site? Well, you only use 30 or 35 in )ur car. Oay?. A. 1hat is o . omy. May. Geta. A. Q. Ckay. l-re yu go. (Ca you explain to me why the therim fission Q. Thank . miterial woud get ito the coolats -- owth occurred? I'm sre the 94s u-star exacly what ya A. kbold your.et that, please? nean at•a they all duc their oil. Q. 3ould you explain to us km the -- uh -- thorium MMarter off the rerard) fission mraerials iýj2d get irto the colant? W6.Pý1X: All rigt. Let me just see here. A. Into what? ah-ief pa e) Q. 'ffe coolmt. Coolant, c-o-o,-l-a-n-t. M. 141=lr.: Q. All rit. A. Mi-t page are you on? If )01r un to page n J10447, that, a the Q. I'm kxcir at pae 444, JI0444. Mfle 's a last dm t. reference to 90 to 100 padc~e coutaining liq~dd, and A. Cday. further down it says that the bqlid Contains SMl amcus Q. Ax! can - of thoriium ad mixd fission pmrca s. A. All inigh. I'm lrkiin at 447. A. Ckay. Q. Ca ,Ku talc a lck ad. read tt, ple ? 'he solulbe oil is used as a coolant in lathing A. Mit resscoplies) procsses ere une is shaving mragnsiu-borium and the 0. day. lathe tool gets the metal extremaly hot so, therefore, You is the referae here to the 85 drums of need smethixM to reol down the tmiperature. that rasined at Is Specialties the 85 drum t•a kid that's vky they call it - ultmmately et to Idg-'? A. Yeah, that's the -- that's the 85 drums I sem up A. -- a-- to Ida F a"0s.

84

A. I

irny hive come off of the cobat 60 metal pi~ as they 1 o. A-4 the larg a-a=t of magneurr-thirln alloy were bears hxied.o 2 t.021 r aod chips pac,ýLt in wode =c -- aid those go PreI he hrnd beer warned on rim s~ occsions to 3 offt !o2n, tocr be aire to haid that materal cut at some distanoe from 4 A. Yeah, t:aiy uat- to Idakn. him, hx on -- apoarnt~ly an two three occsions he 5 0. 3W. beaxjt it in ro~ c2l and his film badge was on his belt 6 s~s. IH: :'m going~ to imnk ~D~ibit 8 whic~h d-n ere (irxincairn) acid he -- be got an eiqsive - *7 isJ X44E = X7454. a. xopommv to the film, badge, whichi didn' t neomrily 8 LA aseou-pa diaTInt c~r=SZn of a memo d~t& ref~ect gttirM an aoieaiqxpsi to his entire body. 9 Faiy 4, 1961 to L. R. Pgr frcm Drmlel E. waxne rid Q. Othe than this one incidet that w.as -- the tw.o 10 s , ofattachimens wass iujaffrIderri icatio as irrdt that wee repoted in this &ý, do you 11 recal any other incidens uber the Ux1asr Regultcry 12 03mnass1o sent a notification to Ux.x akn±*csveiqregore?. 13 aiýai p] wna take a loc art this &a~xsat? A. Wall, for the recod it was the kAtomc Eneirgy 14 AL 15 Q. Oa I ask, doe "im men 16 ;L Where are oL B&lb-- uh- 17 Q. :1m liokin at pag 10450. I don't know. 18 A. 4501? 'flase probably wer other examples of this and 19 Q. Yeah. thee opoazes w~e all1 -- 1*2 -- entirely thiraashe cut by 20 -aexels a nuabe: of referne to fte the the Isotope Cbimittee and all kinds of efforts node to try 21 abreoiacin2 "mr'. Are those mid.~dan7i to stcp reaxece of these things, h-s if Paeile wer 22 What I'm lookig at here, W. Vaden is -- hi - OvRA=xae too nmd2, they bad to be laid off awd caubdnt 23 in the thurd panwz~h, faxth line aio, 13100 mr of gama w&and it interfered with pro&=iatn, so there wass a -24 enoomre, I and I wo,1 l.ike to know wht the 9Imr'stands mne~y motive. 25 for.

85 87 IAM W*M RMRM M i

Q.All right. A. rt-lixrtgw- sE. m'. ?'tiE1- Im gon to go ahea and nm&r D~dibit 9, whkich is 3258 tkough 360. (A three- typsewrtten MS. mý=M Q. And was the millircetpsr limit = X~s319358Ehrox306 for eq=re to gama a~r.Uly 300 nrdfliznu9 in sa wass make for Identfia~tion as Odiibit 9.) the wites revieai &azas±) A. Yaesh, tkse's the weekly liofrt. Okanefpam vua M6. M=I=- 0. b you recgnize this dooinat? I do't. So %a~i1A it mbeentat tnda~yo rtiply the A. 1b, Q. Mray. weekly usina by 13 weeks to deemire if smntx* wass th-- drmdMx youzr attai~ra to r3259. the secn wastes maybe Ca o explain to us bowi they reached the pag, there' s a stateerut here 'that by daimal dissolut~im filrtmto, a~tin crawaiiin that this employee bad benOvrr psd procese chemical poyeiation and #Waicl A. )try be go the a~e25~mfle?. ion -cn, Q. Yes, Sir. whther any of these procsss waer x. I doWt recal Ibohegot it. I ko~whe did Do youi kno j~±iise at the I~soces faciuity7 iii-- vt9MewJT. D5idn't I giv~e an e~plamtion in heM2 I mis X. I didn't amanwy of those Ia used at Isue arde. MWa Usually Want one,4Z r ccrias the Omtw itin an this aaW. 0. lb you~ Yeahthtas the -- part of the prchlem. He was the onewh tookt the excang colum and A. RsXcgnd %hat.? fila a& of tde syata at the &,dmm pxal. Q. 37ai hwi~iting on this domest.

fle- thes rsviw are usdto cor~wusy A. No, Idoriot. filti tie to tike any raficacim untranl cut that I may my to You that in writing licenses it --

86 88 MOWHEE F~= EI

kf I

at the Isotqpe fac1I Jty. PAi I that thoe 1i cpi 1 the proszie of the* 1 a~p23 cw- s to write the 1 2 were the w~stes that had sme, of 2 licnse as bradt as ttatabla -r=Iz.. every prcs tha wastes ~nszTeux-týt~ 3 evLas thaxgr they hsad of or -ru -ae ffk uete 3 4 AK It had sma coolat Lr 4 as rflh lesa as theý.' am~, and the ar-y of the licensee waa whiat gave .z re isterry of the 5 renewer is to try tc stoý a:.: lhat. So it's -- it's a 5 Q. N~d that. 6 oil that yý das--e 6 kind of a contest. 7 A. Mhat's rigt. 7 So it's vat-y COMM~ to pxt =k rid We MaYd 8 0. Ik0y. a this; we nay do tU=; we naey ptcs W this; me nfay &, 9 Is the referenc here -- =agrap four to 9 this; we naey d all. these thzz 10 'flit gives yo2 - UW.t -y y it, then ycui hav 10 fta o tre 311 11 A- ~Ramraph Q. lb -- nirber foz. 3.2 Q. ¶Iha* you. 122 has also -n& asr- to atYlx-ize 13 mp. SHDa-v I III mo~ tc scike all of that, as 13 A. wfle lices of I qidd" waste 14 beingrsxrr-xespcsive sazxe tdte wac- a 4esticn. 14 the dispoal1 15 is that wht you're asto: 15 16 16 tin -- Exhibit Nxv!- 10 is gmrM to ha blark. wevee am~ ta~kirg almat Rdiibit MXd 21 isIS n~ rwtrf-I Jfle96 to 17 Is that the aswe mote 18 cr diffaeret li~zi I if yoz kxu 18 398. 19 X. I thinkit is, bitI ca't beme. 19 Q. Ckay. 20 X. R. 1uie~ck fran 20 H. L. Prim by R. L. Kirkt thojj, I do't bel~ieve it i.s. I 21 21 A. Ch secon f~or I6muifiation as don't haliaem it had anything to :J with -- uh- 22 22 23 And 'vfty d yo' think t.'t? V*t= is it that uke~s 23 Q. W.EVadn n if Ia Omut W.Mc=.Q.Jn- yo thirk that? 24 24 25 -- uh-- it Ief to the conmiastion 25 drwyam attentim~ to the fozth 1 1 an A- Bec~s

89 91

cdl type 1 doaunent 396. fiets is a A~ to tIe re~et that the 1 and it refers specifically to li-Ar versu the 2 2 license ha amaxled for tIe ch sosa of I Jq YJ containing 'kiat types of I q'i~ ase 3 not mone tha one times ten to the rmn~ famr ff~accrusa 3 Q. Now~,W. Vaien, the 4 per nofllliter of bypxtniiMt~a s. 4 thaem at the Ia7a fac:Lity tint wzi25 have re~dred lices? 5 Uh -- are tIe ligrid uatedaq F ereIheer 5 reis for aterb in the A.i Well, tItIs always sme 1irJ.vidI]aste being 6 different than tIE -- uh - sbmmy cf uenlniz 6 7 slash -- cooant that we've h' talking abmit? 7 geneated in the mold labortory. and there's aIoliwir~d wate often -- often generated in the hot lab, and there's 8 A. Witud yo ~that, ples? 8 clf-iz up) of these 9 0. Arethae- 9 also ligaid weste generaetd in 10 A. If yoW 11 lack at no t you~ape I ca ba 10 n yo btter. 11 M.Cay. appmazustely bow rvuay 122 12 Do )Ku have any ide of either in the 13 ;we tIe -- us -- I9dicri Fee4 to in this 13 -~ae of waste that wes dispose of, have been -- wozd have contained liqdd 14 1 fcox different tham the ua~eixvthcrein - 14 cr at Idaho vallel solid wastas?. 15 selas -- lain~t sb3y that w"e'vebe tal~aM about tha 15 wasts as c~eito 16 was In tUm wode bome, if ymkx 16 X. lo, I dont have any irles 17 A. Is yaow quetion 17 0. Ckay. = of I qiAA 18 K. SM*M~ cbjetkn. I think that is A. Of annm, we try to kmWthe am 19 19 motes at a maniu becia.m it's CWAqieui to M of 20 W6.lfI=: Q. Mb3V1 kn vkst I nean. by 20 ~iit asUj~ifi . 21 21 Q. kid vialt ty'pe of I J jJd moe ues gmimr-el in 22 A. I know ukit ==Me sbLMzY is, bit I see -- I 22 23 dmWt uxlrsarxi your quesirn.. 23 A. C~b 14, txitixn B-32 - *atriee they w~er 24 0. 0910Y. 36 s-n. We've ta~oad abot I b~eing liq'dA waste 25 Q. kd %hatma the consistawy o the 2.igrid wast

90 LABS MVKE TWCR SU I

1 to)ias - - and flag1as Auz--ft and Pxet Sno FUlta, - gm-tdin the ar--14 lab-at-y? 2 A. Yes. A. probably Like disteaz-r 3 Q. -- Richfield oil Anahim aaxi ThxmIi1. Q. And in t~hot I&b 4k 7yp of bli.L wat 4 i~anoatcnry. A. Simila-Z S During the t~im peari that ycu er an aep2Dý Q. Afti wcul it be a sintrZa o~icec 6 of N.or do You1xr1 receivire wastes ftn th~es dishaer'. 7 csomer~s at the 1D0 f&alti3iOy A. Yes. 8 A. ally frm obert S~naw. Q. And In %k= type of a o=Eai1e was *3cstrd 9 Q. And dc )o )oý. wtn kind of wanste Roet Shaw 14 A. It wer = a 55-ga23cr drunid itwa 10 transpoted to the facility? is aslid~fied. 1.1 A- I recll. that tU' repoted -- they sent ason 16 Q. Sime it WEaSsoa2idifi~ -- wy was it strz-.I cl~iA 12 gags arsear gmge, we valves, hit I ca' t rec1l1 wh&at 17 at tne time of it beiI di~ceecr, 213 the =3diiaive miaterial inmilve was. is A. It w~asn't. 14 Q. ibw v4w shipments onie to the fwlt di 19 15 LIctces specialties have trucks that Pickdtai the 20 A- It wasrt diqnsed as iizzid. We wee't aflloe 16 diiprmm c did tie cust aems thte dipiats? to duspos of it as hciel.i. 21 17 A- It mike bot w~ys. Q. day. ilinUfy they -- tUW -Ad1 pick up sial 23 utan I incorec tiat ttms d~xst 396 is is 19 shptats Vme they had pickop trck, but if their 14 rgetMan aseI I to the licme to pez )cu to 20 large *iipmets cam in saws, asonady else Ia than. die-poe of I1qi~id wastes? 21 Q. May. A- Yes, but diSPOE81 IV BoZifiia - 22 Mhs is alist of anlyfive -- excseRe -- ace, No, it satm without qo.ýfitne. im't it? 25 23 tw, three -- five csaatois. Q. Yes. 24 Wer die cthr cusatners diat youi're aware of A. I &fl't knowIwhWt that mean. 25 that wee alsoi -- uh-- uti2.iziM gIstcpes f- its waste -- Q. Ckay.

95 93 1AKE MIX RMMM SOME 1*

1 1 2 A. Nkt tzxk a praticular cm&at hit they cuild 2 3 receive an take waste back fron any of thirf custanras 3 I'm goixM to nudt E&U=~ 12, wichtt is d-iuT 4 tha tey' had sold naterial to. 4 MOO1"0 to 401. 5 0. Do y knoba, prciny ho naiy csayetrs 5 (A le-r2tra 13, 3961 to 6 6 f~ada A231aCh1sten we 7 A. No, that's a -- qglita a ocnatfecial. secrt. 7 Ed~iit 12.) 8 Q. W&U, it's m~ kgr~ a camm-cia1 secre becs a 9 they rm Waena 9 M6. MdMM: A dXImt CJ- Fe~bruay 10 A. It as toTie at tluttime - 10 --e January 23, '61 from Allen G3dti2n to the kotinc U1 0. AU right. 11 Energy Comssm 32 A. - and stiUI is beaue I dicx't know~. MW kept 12 Wrif P3 while the wIdl reve docmen) 13 it very ckm . 'Tis :is huisines ccrietinio. 13 M.. VM=m-n Q. W.k Vai in Jammy of 1961 14 WQ.r'e in a dma~itimf and yai rxwf to give us 14 was AMen Gldstein sti I' w3dnr at tie R= ftiuiity at is 15 yoraswer to the questi as bes you kra1 it, bome 16 this is a busines that no lager exists, so there's a~t 1s A-. fh-as fras I knw b aI't. 17 17 Q. Ckay. is X. I uriesand it. Aft I r.Ltie fact that yoa 28 At any tuna wbe mwer an aipk of N1x 19 thirk I .iht give ym a wrn anwr 29 wasm. Gldstein vxk Tg at the 170 Proideia pvqpety? Rb. I ckn't %a-&yi to give nm -- I went you to A. mb. he wasno. I rseve woke ith hmo o 2D 0. 21 give im you bes answe. 21 him I don't Ya a&y ide. 22 o. Ckay. 22 A. I don't know. 23 0.May. 23 In this oouresporino - uh -- ui item 24 Doyo krxw mbether it wa oethenk fifty 24 u6 2 Is a referenc to - uh -- wase CliO388 25 2s ccccs befr3 acqziixe asasset frcm fl4m Aixi=zft.

96 94 94E MO96M=SW 1 'FlE FEaM bsha affimativealy) 1 A. I dont have my idea. It - -d haeber 2 WE. MjCTfl: lay. 2 3 Q.Tt~M you attention to docimar nuater "13", 3 4 tvaadi is J10402 - 4 Q. Maiy. 5 A. -- tbese getasHa will taZ you it's a J3anuary 1., 1961 to the 6 U.S. Atarmc E1rmgy Ctrain1 orpetative, &og-eat-ogworld an the from J. D. Vden was m~ 7 for 1denifiat.cUin as 8 radoman-tical. 8 Q. krd it's - 9 O)rief pzme vkile the witnes ravas' docunn) 89 A. 'lat'Is vkry be bougt it back -- to ge that list 10 10 b~t~. 11 an this dowyet? 13. Q. Ma~y 12 A. I cbo recognize ny signatie on &dozmuZ402. 12 A. FRLTMWkit I I~d 13 Q. Ckay. 13 Q. Without tefll= me tienameis of tin oustcmis, 14 And the d.zast is dat-5 Janaray 13th, 1.961? 14 can you tell is how rasy casta- Isoc~es hxV 15 A. That is ~ 15 A. No w~ly. 16 Q. k-d this is a resignation from the Isa±pe - 16 0. Mry. 17 uh -- Coni.ttee7 17 ibNowyylou - is 19 A, I wasno -- I was not in t0±r bsixp-. lI hm 19 Q. kid does that reflect (sic) your recolecioni as 19 no knowledg of it. 20 to the last date that youi were eiplcye at the orI¶cT 20 Q. Ckay. 21 A. I bel~ieve it is, ye. 2.1 Is it tint you don' t hamj ~knowledg or youi 22 0. ay. 22 c&n' t wart to say a~nytra here this ==nag?. 23 23 A. If you say d= cn e tine, I'm 93ixg to waý 24 M'. ?'d'fl: I'm going to nurk Exh~ibit Nxrbe 14 -24 amt of here. 25 doaimets 403 thrO23h 407. 25 Q. Ckay.

99 97 Lvm MDRM YEPa;=M S3MCE

A. 'm tired faabeingzHJ-tj% 1 2 (A twa-~ letter M.day. A~t- (eid y~ 1961 to 3 James E=an J. 0. Vaden M~ij iz n, are drse csartor, H#- and with a tbre-pa Icq at~tadinnt was ffim1w for you'rxe 4 W~a] -- are thenam~es on this pag cusamm tint Idetaificatio as 5 aware of that Isotq~esas dodn hwiz wiWh 6 Mrepaue wile tin witnes reviews doaut-) A. W~11, I krW R#-e M=airfri. I weLct ard 7 W'. ?'dmla= Q. W~.vadi, is docinn wrote a license for tkbu. 8 mu~403 a list of the nuteriala in the corrainer thnt 9 wee dispoged of by' se an .Iammy 14, 1.961? kid kms abou WrO2e Airaof? 10 A. Yes. A. I knew tie pecpa cut dthe fro hime 3.1 ?ithe--M. uh - aarinitaxnc. hit I never ~i to kmw them at km levsel 12 Rx earapla. thn first item is cobat, 60, and cb waste or had anythirtj to cb with them on law ea3w~ t~e. 13 m"nextz to that? lnt dosa theInc"a stand 7flu- y0ou sea "9146 14 for? A. D~illiOMIR. And how abotn± Tssail Laboratoriea? 15 Q. So thn mifl~icuies cb rott X. rh -- I &on't-- I d~'t rec11 thnt. am at all. 17 Is there a way that weta correlate this list to 18 thn 948 container~s? ltd howu ahn± Richfield 021 Anbea 19 A. Ct~elate it with wint? A. II I Of them 20 Q. 'To the 948 =tarzies, so wnIxekrnw how r 'MWalad atoil tha t1W"d used in piatm wear tsswith irat 58 and tday were watixg to know bow dhey w± ntrri u-ass"'n got the log buck which ýjjUse -- gtrid of it. 22 A.&~ 23 actually - And that's all I krrw. ~apeifies 24 Exb catairr lad a rxubr at it, and the 1cg M6. bt.MC: Omn you wsk the Iaxfrcm tint 25 bock is entexed wbat' in tint cmitAlxat -- wtit tin las zwspm fr~tin vifl, V]w

100 LNE MWM REPCF=G SEMXE I

o. am, you tell rre 4&kat y;' re ref errnzg to here 1 isotqes are andho minh of ea&. one. 2 vt- you ffide that stataeset? Vh3at rra--agz1? 2 Q. This log lis- -- was tý-t sarething that the AMZ 3 A. I'm referring to paragrap four %heeit say, 3 keto is that saethirg that :stqe kept? 4 'fe necssty of followan 10-CET-20 rm.nusaE fo 4 A. It was left there wt--- left there, andi I dm't 5 )un whor's got it now. t1i -- 10-CF-20 does rio sey you ca't use grease 6 Bit I prshe - p!r~ orcalk narkings 7 In arry cloae of I J it beres part of the 8 pemm-rze record an behaf of AEC -- at lseast a cop off it. 9 Wat dosit say, if you recl I? 9 ah- -ase 10 A. It juet seys 101 sho~d pit the -- identify the 10 iscoe n pit the qiakLuty an there -- pesrxio. n2 IOO.sent rumbe "15' will hi blank. Q. lVwi you first bea working at the ompany was 12 DooxmM mutrh "171 %cL1 hi blank. 12 the q.imtty and type Of isotoe in the dnx ukrified an 13 14 14 mention of an~ Exhibit 1.6) 15 A. On the waste gimmated at the ca1any it was, hit 15 W'. YM M47: The next d~zire I'm gongr to muaa 16 all that stf sitt~ing out in bac it Le was~ns't. 16 is Exhibit NmUxEr 18. 17 Q. aOaY. 17 is A- MWgo that fm antaers.~ 18 T~~e BL-dic Files fro - ze Fibet Brmkmu wa 19 Q. Di yo ee hie occsion to hame a =estc 19 Exhibit 18.) 20 20 21 A. Well, I've talk~ed to him years~ I evr en 21 Wrifwie hie hewitness reviw ~et 22 witthe capa and I think I talked to him whenwI 22 W'. MctFM.- 0. Mm' s a re-fess in the 23 -a abat to leave. 23 first paragri to Aeojet Gý l crporaticn. 24 Q. Ckay. -24 Do~ ycu recal whethr lerojet was a client of 25 Nzi do yo reca I yor crremstio with him whe 25 Isotcp~es dxixe the tine you w!k' thue?

101 103 UiE mm~U Ra =SV

wee ahi±- to 1nae? 1 A. I dim' t kzimWwhat the FZPrpW is in Xef~eru 10.1 A- I askedhim if hewild be interested in te 2 to. I d='t recll aWVPrqxSal. z~anmtina the facffliy. kid be said -- iii -- -otet 3 Q. Mat I, maddrm01Syo s 0yu rem' 1Iwete w3AHd hi yaw type of fws?" I iztomed him vtat I tlxxrk 4 Aamoje General asa a custarer aE the ojmpap jwhe y0u wer wculd hi un' Jer , amd he el~ete not to take nv of fer. 5 apTlaye tksse? Q. Nw bad be been the indiividjal mtn had hued you 6 A. ND, I do o. 7 ~a.OW X. 0' Hadbe b the uirdivida1 wbtat7 8 tn -- diwire your ~ay"ic to the forth 0. Rio huedyo when yo were decadmicniaig the 9 pmzaqý that beins with -lhe la&e~ing of the wase 703 Main Stee facility. 10 storag A. !1b, I've never woke for W. QD~d~tein orha 3.1 A. Yes. aoV busies relations with himn w&tatsee. 1.2 Q. " -- anmers&y ari only of 9L Penci3S 13 rchl aknings - Vhat was the ruse of the o~~e at the 14 When you ariv at I were the corkixgs on 7M3 Min Stree fezilitj 15 the doirs thatyu observmed - uh-- still pencil arid chalk A. There were m~caqmy them, it was a prqxxty 16 or w tre different &mdirw? beiuz luss by Iqsotps Soeda22i Obpw. 17 A. 'That, mu~g others. Tbee wee anl ~ of Q. So T~ Smecialti ws the bhuixuin thit 3.8 markings on thin. there? 1.9 M~day. -p~ae A. Yes, .i Nx= %1hen I wa there. 20 O~e 21. A. Aridhe is wmcng in his stataemt tbat -- tim - Q. At 73M ainStret 221 uh-- they, had to be label - with anty cthe diffeznst Q. Rvxet*. 23 naterial thai tbnt. 24 W~.Brinkffi was in licesaing. He womno a I unzstad fo the 170 Pnmdenca prcperty 25 inspecor.

1IN IAMB 7*M Imuam M;5=

1 1 *1

1 4=e you tare a~e21y wmkin as a heath phei- - :.%hle I hile yotu' re lodan at that -- any mrre w.tr-er 2 A. They- 2 A. ( xdiurets to repear 3 3 Q. Do 4 4 A. Y -- no, I've go plenty to drink. 5 vilen I ca there they said: Qie of y.zr .AxJ 6 will be to help us ge this buii1dirg deommssioned so u EVfl=3FA9Pf: We have abat- two nrmntes to

7 cap-it bak to the -- get- it ba' to the 1aid~cd. t7 r dim~e 8 Q. C1aly. M:JýT: We probaby won't makce it. 9 So youi weren't paid a fee to do the 9 Q. Are you familiar with the Admnistratvee that - 10 d9imiSaW19ix at the 703 bxi1.dixn 10 Ptrocdures 13. A. kb, it vas part of ny A iee. 11 A. Yeah, that I wrote. 12 Q. I undertand. Mim*you far clarifingx that. 12 Q. Are thes proosiaes that youi wrote? 13 Doyo krx.w vk,&etky W'. Goldstein -- idxn he hired 13 A. No, these are nct. These were in existence kidle 14 to do the dCoysirn at 170 Provi~ia? 14 15 A. I dont kno if it was -- anything about- that or is Isote lbmtttee uus. 16 %ket2erit uwever deoc~asicrie or who did it or what. 16 0. So these are procedures that predated you?7 17 0. Chevy. 17 A. Msrt's true. 18 SO you wee already in Wadhizgton, D.C.? 1s Q. *=you ~eab. an arployee did yo revise these 19 A. I uas gon, yes. 19 zrosues? 20 Q. kxl so yuI don' t have any understanding of the 20 A. Yes, I did. 21 ~nde~msiadninp 21 Q. And whry did yo revise theI pr~le? I 22 M~. Mc*=fl: I'm sorry. M-at does that sasy. 22 A.L Well, I had different J~ an how things shoul1d 23 ZfE V=GAF: Five minutes until the tape 23 --2A era. 24 Q. Do you kno ubn you arrived SQnthr orno the 25 wE. MijI2: Ociy. I'm almost done, so... 25 teie that are in this doomet iSks hadenbing

105 107 IAKE -'M REPOKM SEW LAKE M-'- IURr SUMCEI

i

1 Q. Can youi tall us vkat Mr. Goldstin's reputationi 1 followed? 2 was in the iaotqes amunxity?) 2 A. No, I donot. 3 MR. FATIERS2: TUi-- objection; meleyay; - 3 Q. lb youi have airy rec11feticm of how Ik 4 W*S?'nl1: Q.You ca anse the question. 4 Im prceues? %tant? 5 M4. FATIERS: -- foundtiri. A. Do I have a recollectiai of 6 MfE I'flS: I--thi-- I'm rit astudet of the Q. How You 1'nz 1 tyrs pr-xnires 7 isot~ o!mnziity, and -- uh -- I wsa public servant. 7 A. No, I dormt. 8 And I didn't -- I didn't have myj relatica with him Well. one thing I did mmuri - I had eac 9 9 wzdaer read and admmrin3ae that he bad- and sign that he 10 M'. iMfl0: Q. So you don't know vihat his 10 bad read these procedures. 1.1 reP-atirz was ane vy orthe other good ar had? n 0. Vlas that a ractin that bad rio been in effect 12 A. No, I do mt. 12 at tie time - 13 M'. M:9=1: Umbr~ 19 is going to ha a blark 13 A. Mglt is tax, and I tk=iý it was a~brsolay 14 14 r~esay. 15 bftibit Nzdx 20 is J10147 duu*4 JIOISE. is Q. Mhmatin Isotope 4eaialties 03mdttte met did 16 Here you are. 16 tiny di ars %betheror not tie npaip2w vactually 17 (A cM M a,±au Slip 17 cayplynrm with these proosiaes? is R.. B &nidisn to v&hirh is 18 A. Pkarlutely. 'flat vas tin mmei them of tie 19 19 entire cavwAtatin. Adminitrative proedres 20 20 0. Prd how 1ar~did tin Isotope mmtngs typcll~y 21 as md~AinZ 20.) 21 22 Wrief Pe Quile thwitnes xaevieo dixzeM) 22 A. Ch., smoitimes an hawr -- smsetimes twoh 23 MS. MdK=- 0. Wv dia't you take a n ftto 23 dqn mon you ktino, howm utd h-nes we bad and t 24 look at this docxvert. 24

25 Do Yo w& n -- 1*2 -- do you vwat any iwper 25 0. M4 -m tin pzinmy discaai &duing

106 LAKE MO 'FWOMGSEMCE Lmm wm iwa= sEwim flE WMnfS: Mie ASC Byprxidr-t Material3 1 cry- to tua~-knnz nrestix the failire of Vatius Litomsz--g Branch. 2 irdividials to amiply with them prccceizres? W6. M=[=tI: Q. kid, Mr. Vaden, there's also a 3 A. Yes. Mr. K. . Price that's identified at =I'176 -- a Mr. Price. 4 And ve wnu13 cal in erqYpyes that wee"rvng 1 ou recogniZ~ze his urm? 5 any problem -- the womdxsts oo -- ard have tham _. K Yes, I do. 6 and give thair side of the story in intof the Ismcrpe 'flat's Harold Primr. He- was our~-- -- the 7 03mlittlae. dues a:tt=3 geeral for theAtari.c FRmWi Okm.missa - 8 Q. Did youi ever termnaxte anerlce b.ea they or lie ws in that of fice at the time it lat~ wet into 9 wee sioply mt± aplying with the proedes'l Nr- was formed. He vas the hea Lmfyer for the NC. 10 A. No, we neve did. to wadcxin at Lmce -- 1±1 -- an 21 Q. Did an eipqý- get a ict-Lp in his perrnel ~.Prior Pravidnca did Mr. Mason and you ever have a correrstion 12 file if ha %aso.~i in mrcurzpliance? 13 A. fley were given~ wein-Ag on a few o osi ,E I k I can't recall that wedid. 14 rec1l that. tin -- of c=se when I got there I qla;TJe for 15 2 EVICE03VOM: I'm 9Mn to have to C1"e Off 9idirected to Mr. M9 and I wet bak as 16 this tape. with him 17 M.. Mi~f= 00sY. Fine. to c As a matter~ of fact, I wanted to put tp a 18 MfE VIC0PAI: Cff tie recod at 1246. diaposl fa..lity cut in th-e deert. 'frey misse it in the 19 7his ends tape 1 of this derraitior by (sic) 1i~ app]i a&tJ o. 'That'Is how good they wese with arny of 20 Jdbn Vade an kAss 5th, 1998. Pleas go to tape 2. 21 did you eve talk to Mr. Primr before you 22 O)gcsaito off the r1 Q. 'bbw cme to wmk at Is:±cpas? 23 MHEVIC03PM. Stand by, pisee. )L No, I did mt. 24 W6. MJ1W'H: Are ve back tO 25 MHEVIrEAHHE: No. Stad by, plas. Q. Ocay.

109 111 IAKE MGM FWa= SEWICE

akief p-e) him. mmEVMEGARM-: On tie I~at 1.249. A- I rve'r evenwknew him or mat Please proceed. N=~ you Ms. Pmflt: I'm ganiz' to be muidng d~rrt So you -- vkaile ýi were employedat anute "21" utdi±i is .21.66 tiemug J.21.1 nvr met or spoke with him either? Mt=z diff .raxjm d aft A. ND, I rever not Yr. Price; no. let adrse to Q. in tevem.-Ig thase Iett cb 3Ku )tnok km erŽ the inftonztabo in these lettst is referring to those Rdbt21.) Ir to abow caue that )u were - akrief ipee vka tie wins remea duert) A- I do nt krw that, no. 'HE v=3WR. I nee to sy coe - thing. Q. Ocay. M6. Mj=l: Yes, air. 'flat' a all the qiesticri I hame an that letter. ,DE VZB0 R:M M-his bsgues tape 2 of the a~rief -s dqmsitoic by (si) Jckxi Vaden. 22 vkidh Is 7wank you. I'm going to be marking Edniiit X0250? M6. k'cIH: Q. Can you read mi 2~ dorm amibe J=~9 through d=Vnm± nn a~sr to be a series of draft Iletta -- di - raerselbly 'HE Winas: 2M*k Yo. by W. Maso. thio JrI20 w.asea for

A. Yaxkbet. Q. dray. Mrupamele the witnes review dbnaasi) kazmut VW ws We W6.M~l=: Q. I'm going to eFe to A. His nickme wa R~odM'arr. it's JmIL IHszi. nz~JM239 daed ucri th, 1959. kid he asthehedof theAM Ucensing rý--d Carie pme uhi the witns r~eve doaiu±t) 16. MIMTHI: Q. 7hle'saFinefl the firs

112 tLVE T*= RECRG SO= paragrWi-. to a reTplain of February 6th. 1.959 regrding 2 alleqtj of JI I ega a-4 unfair practice n dasposal of 2 A. Indusetrial bygiene engineer. 3 radioa~ve liquid waste by' Isotopes Ecezisat Ch~arry. 3 Q. Wmo did you start sa3czinr for the countyQ 4 Are ynou at a'- faym.iza with this amplaint7 4 A. 1952. 5 A. 1b, I'mmt~. 5 Q. were you alusys an industrial h~qatist (sic) 6 6 encer 7 afpay di-Imed of any w~asnes ky m 7 A. Yes. 8 A. Yes, I'm are they did. 8 Q. tUh-- you also mnwtioned that part of you 9 Q. Ns- whty do You say Ytu'- sure? 9 responsibilitieso wee to -- uh-- regulate radiictive uses 10 x Beause it was prjie for in the regalatiIore 10 by craqmiso that wee qperatizrg in IA County, is that :1 that =-tamn low qjatiýtn of dil-ted nxbca=ve maer~ial U1 . 12 could be disposed of in sx-tazy Sees-- mt~ ally bY 12 A. 31-at iscr~ 13 ISqotFe Specalties hr- by evey lianse license by the 13 Q. Gm you give rre an ide ahwt how nay facil-ities 14 14 were using radioacive maersials an IA Cbzity during the i5 Q. Miule you er an eypkay of Nac did youi 15 Lin that ycu wsani for LA Cbxzty? 16 obsrve any disposal of madiowive materials into the 16 A. !Whe I worked far the couty/? 17 seer sysem th-g di-ira 17 0. Yes. 18 A. No, I did not. is A. I'd say there were aprosdnetely 200 liceneso in 19 ;Rd the reao we -- we stcped the~ proc~edr 19 the county and apo~dmately 5, 000 X-ray mrachines. 20 be M ws cajsitre~rg the fac unmuchd as we had a 20 Q. I'm sory. 5,000 utiat? 21 daipposa license, that was riot a method w~e cad 11r3ue to get 21 A. X-ray machines. 22 rid of any carst wstea and they wanted to be ae that 22 0. X-ray rmadiines? 23 if we didn't throwanwa sota &aci the sink tkat way then 23 A. We also regulated X-ray machines. 24 there walled be no oonsima abar Vkre waste wse it that 24 M.Cay. 25 wait down the drain. 25 Lb-- did ycur inqpe~to also involve -- vbiiia

11 M1

1 M.. PM1M1: I hime r further que~tu at this yoLwre saodrki with the carrty also involve meaor 2 titre. tede camiuretaua of facilities? 3 So it's tine for lunch. A. No, it did mt. 4 M1E WIINES: Ckay. Q. *ast- ME5 VIE0AI85t: We are off ra ad t 1257. A- We didn't -- it didni't cn~e up. Mxxe wsa none Munch reces) bed±q &maidmted at the time. 7 ME1VIM03UM: Ckay. We're ready. Just Q. Clay. 8 stld by. So duzran t-he tune that you wa~m for the county 9 aklef pse) keadi ~hu there were no facilities yw were aware 10 7W1V11OGAPAR: Going an 3~at 1409. of 1Oft-i in LA Omzry - 311 Please I Ie A. 7hat's right. 12 EXiUNA= BY MLtNNTRM Q. -- that wee decmdaineda? 13 Q. xd aftexzaa, Mr. Vaden. MIyrai is A. That's right. 14 Greg Patrsn As I naraine to ym earlier, I i~e Q. tUe -- I'm going to now flip to t-he tine that youi is one of the Defendants in this aei-icn ICK natotils wen to work for t-he kAtoic nex Cbmmsioin. 1Ain, pisese if yiz d=Wt =1e~tan mey itat wsa your job title for the Atromi Bnerg 17 quesion that I aisi you or you cs't bee it, p3~ let tie

kno and I'Ul try to ;1 it A. fl -- helth #kryaka off i for a vkaije and then 19 A. 3Mak you. Q.-- or 1'31 say it lat Szia off icra 21 fli -- ymhad nenioned thlis norning that you -- sonething like that. 2Wa switchd it around 22 wadcai for t-haIeinsNx]e Ikary Health Dqxmt±a-, is b- y- got e wony -- ungo.e 23 thet corc? Whiat sa your responsibilitie;a a health A. 3uisM rigt. -b" off ice? .kid you are an ir~AyerW1 hgienlat fo the A. My -- thereason theyhired me ws eash of my

114 116 LAKEMM 1WCR= SEM= I

1 badr=id in eanlt!. :tvisions and b~eath d-=-Oat and 2 Q. I sma. 2 also with ny McTŽ :zxi sa riad -- op--. fray 3 3 needdsmcn wh - relate to wid help =Lin all the 4 Did that raminii aslo -NnIve tranxe on the 4 state apleq =n the k-teU' ate and those ~agens that 5 aversigtr of dtac.natikrý a prq-V? wee goirg to aa~epta- gefe to aagzle regulatory 6 A. Yes. xeqwibility, tie ZL eiM -id xe~guatacn, and inspetion 7 7he prnXIIPleS of dat.&,zaatic are fairly wslI 7 of use r~i leies that ce cut of OWaiIe v&an tto 8 knwn as over the )xs there's ba an awful uztbex of 8 statbecame ari agre-or state. M crayll it an ranýa 9 facilities that bad to to deczamirated so they colei be Q state. 10 retlainwiadariput back in use, so - 10 I. see. 311 It's starrIard rcutir pro~mazre ho c go about 311 Did nai i fz-a at ane point b~ar an agxeýa 12 this. 12 state? 13 kd all the states hive had sam emperieno in 23 A. Yes, they cd. 14 this bq.mee radium is a niotricois caamnator in 14 I -- I %assair to Cali~foxra becm of my 15 hospital . Whole hospitals in sare carrxies have been 15 3aioleig of the pecple here. kid I hoei thn and - 16 conpletely cmzsminiate and rover bwi able to use them 16 uh-- the 9"== ad so forth to ge the state agemn 1.7 agin. So tlaeve learned the hard uw Im to do this. 17 signad and ge -*ntaMtZ trw-fezref 18 kd it's -- uh-- rather rigorcu se%bmyo talk akrs± is 19 ndiLu gmMX into the old harý flos an hositals. 19 ib -- of state perszel? 20 Youi just had to go in and gult the %hole buiildlixe. 20 A- Yes. 21 Q. I se. 21 Q. kid did dthr tairinir also irI~x overseeing 22 22 deaamintiq facilmi tha at ha t fliii rd icaive 23 ycur job dtitl at the kAxmdc BRarg QOmmriaic? 23 materials? 24 A. What's that? 24 A. What ktind of facil~ities? 25 Q. You said that mb-- -- yo wr e first a -- and 25 Q. The f-1ilie5 like -- like Isctqas Specialties

3.17 3-19 LAE M*M FEPCF= SMI

i

that I*-iti -adradiative materials. 1 I -- a health phyics offIM 2 A- Yes . A. w a -- uh -- a stutue tzaizdrs pr-ag 3 0. AxItbkn yu werea sciera - dqme io the kadwrurd in the first plaxe. We had 4 A. RTYeala stierist TflatsS ikat it wass. ctain ragixme=t of the paermnel tdat tde state coucld 5 Q. 1bsical amaetist. ueas far as Itkeix aof bad~jraxI ard trainirg. And dhen we took tin fram dhre and P& tham dmzcg a k teý cos =n lenth #hsi and zadiamc pmoe~cti QWh8ile you wee at the kAt= Rormy Q.7midas 9 um )c ixr~ilved in caerseeirg the dwmrmdMticn of 10 facilities? WIE WIMMl: -- in radiaetim protectin in 11 A. No, I %a rnt. 12 m, jct -s p cially workirg with the at A-d thn as bad variou speciaflai-dome - 13 p1e to crust dhrn train tdan. and ge dhem irnolved in ame of time - the huggr health dqmxtnts split up the state proram. into a htommirg grcap and irgeitun group i~ ae 14 ~anem 15 Q. Youx'd also muticred dat -- that part of the aldnfistatioQL Zees bmumixed by NRm -s to -- it - So as had crieratio cour ard 1iceairg 16 their facility an Main Street is dat pr ad-sw pit cn at Behslan at the headnzter 17 dtanrairmte ssmeam times a yea fx stteapple. Aid den as had 18 A. irjqxctit pocceanes, of asmwput m cur -- uh - 19 Mflat is ~z~ aff it several times a yea. 20 Q. At that ture were ypi fala with - Ad den as bad satial ia ciz- in inzdstrial 21 or let me rephrase dhat. xadicgn# and rudser madiauie - y r aem it -- awe- 22 all the eiscilira ard all the differen use, so dhat 23 At the time that you we to they'd be able to reocguze and kwiotsit the lemiVbae 24 ~tdemaiate the mmn sbmt prpty, weeteed regalatios that hmd and Icrxý ijt tie lamang -a ai knowahow to regflate tie

118 120 LM 7AHM rdmx= SM IAE MNKaERE1Gr SEW

I I I

Are yc. with rye" I. bee pub2.isbe by the ktam-t r-= Oommassin related to A. 00Y 2 how to d~onbseito a por.e:!-Jý M.amy. 3 A. Dacdamsmitoung, ye, bi nt dByrstamratito. Vtzt -- whant wcml be the first step that a 4 Q. Ca you tall rmeuv~r the differem -s betwee cmpsny would do if they coeto d do c - A. Well, they would rxýif their cusomras if they 6 A. We~ll, weegigct of buxsins: DD ot am~idslan more wo~ ? Q. -and 3j morre sources -- this sot of thing. a A. decontamination is a corcto nf a And then OWe would have their healh #rysics 9 Situation. peso mraie srve~s and cetify that -- wil di~ia Of 10 Decamussicruiri co&1 be -- uh -- smply saying whatever wasteand~ -- un -- raioctive mazerials andi 3. the licene has expired now and -- uh -- rot asestied source and all that that thay bad an hwd. If they bal 12 therefare, this faciity is denis~e as far as use of as I say, if it Is usas hle y might sell it to somebody 13 radioacive mraterials on the ur~a.Sinply a cestion else or -- if it iasn't, theyd rbxa of it as wast. 14 of license actvitmis. 15 Q- Ckay. Q. Oray. In -

With respet to the survey -- uh-- what woud 17 let's sm. the sur-ey c2onss of? Vint would you do to survey the 18 Youi said that there are regulations regndi 19 de~tamnaton-- or deaom-t0ning- I'm S-Y. A. Well, you woulrd take- you radiation iratruzant. 20 A. No, there were no r-vguations on deotadrri tion. and se if them wee an*,iet radiation leuels 21 Q. Itrat about deC~nff~seaCi3? go around abokm baqjgronz. kd if there were, you go to do 22 A. RiY. saneting aboxt it. 23 I-b than, as far as the contatoation of 24 A. Jus p irocdrs. radicacive mraterial, youi take wipe tes with filter. 25 Q. AUl righ.

12M 123 LANE MICE M==l S0EM lAXE MqTE REMIM SUNICE i

and put them into a asme and to if it's 1 And wee thos procinLs s-ething tht Yc er mreasre see aboe PAd if there is, it's got to be cleaned 2 made awae of? bakground agin. up to see if it isn't. 3 A. Yes. off and cleaned M.. MMEMfl: I'm sory. aould you redbc his 4 You had to -- uh- resoses to that qusion? 5 Pta instane, if you -- )KxIn to mte into tie MlE RECIR ti-hum. 6 comrdsic as Youv~re asew 9e of these I ,ssand vxxcb. you can't have .7 say W' re no longe doing this amd we hav une a sre 7HE MMEDS: In other material in yc=~ possesion without a license. 8 of the prmie and we find m eminn -- ih - radiiacmle M4. PAM!4I: 0. 1 Uierstand. 9 radiatiton -- no source of raiito. Essenially it's at D~cod read) 10 badmrgrani Wokeit -a tie day we me in here - this sort U1 of thing. W4. 1ATIESC: 0. Ckay. :12 In othe ~rT yo had to assert te you're cut 13 of the busness; there's nothing remaining to tie propety things y would & then would be to 14 as far as radioisotoes, bae= ytou'e tin-n them into one of the insruenmt to go thrugh~ the faciliity to 15 someody tiat had a l~icene to receive tdm - vute tee son srt of pixdzM tp 16 anothe bxnizma with a srumla license -- yo sold it to tes to me whether thein rtcrumai was 17 tham or wbt~or Bit yeou do't have themnetara.am1 e. xdccie-- uh -- MOSM9 18 Yobr're cut of hafiz A. 'lint's true. of the ways that you t~este valld be to 3.9 Q.All rigt. 0. Md or& 20 Now let's go to the 1 4ne tint a facility take Wine ase? 21 woul~d go thmrog -- and I'm tafl~di shot the swrv tise A.. Mit istrue. 22 frae 1959, 1960, 1961 -- in that tine frn- tin Q. kid tewipesniples would betala of the malls or tin fl , - 23 Irr~le tint a ft1Lity esA3d go through in order - Wn?- A. Men wells, tin flor tin calling, ax~sie. 24 it - to stop its cpr-tin and reeie tinzdnwim of its tI 25 license and have the property relesed 0. Rvdid ym dete~ne %tie to take

IN4 1 serpes? lie's been deceased 20 years. 2 A- Well, if -- Lf ycu're fa r with the facility, Q. th -- wild LA Ccny Health had also -- wcid 3 you know 4ie radiation has been us- hr as -- in a )nj have surmitted any kind of ren*t to LA Gary Haalth 4 final urvey ane wii take then at -romn thra aim? 5 be=ae whn the AM a•cr air-y .•rpe came, tWi 11 do A. I don, t know whether they did cr rnt.

6 that; thy 11 take ran~im samples. --'I mary - - they mary Q. Lb -- were you familiar with where LA Co -y 7 pit a la p as hiy. as they c y ip tierm and wipe Health Department wud keep files an properties o 8 armid up there to see if they woad f=4i amethig. facilities that uti d radicactive materials? 9 Q. Lbi -- waild yu.a notify the AE2 -- and in the A- I'm srs arewhere in the ardcives they m=t have 10 instnce of the facdIli as in Lo k les,.- the Lo Agles a -- a -- somekind of a file an it, beceae they did keep 11 a-ty Health Dep - -- if y0. r to crd.z a files an all these s=r of thirg. They also kept names 12 survey fo purples of clcsig dn. a 5.lity? and infametioa about every license in the cat•-y. 13 A. th -- wall, notify themt -- in the case of Q. ki -- uh -- with respect to the Main Street

14 the -- whatever -- Nain Stret hii -- or watever it prcprty, did -- so I can clarify this -- did you 15 was -- noirtified than that we had etAdrataf it to sumit a ,e-;t to the Akoric Energy Ommissian abl wha-t 16 the limits IrFaI by AM and it was ready for their y bad dore at that facility to deonaminte it prior to d~ir f •~in 17 18 Q. Isee. A- No, I don't thinkz wet thrcugh the particular 19 Did you smibid, a I tc :he AEWwith Iee Ircaizresthat I used to dctanirmte it. It was rather 20 to the Main Stet prnaernty racime and -- uh -- there wre no req.ixent for it and 21 A. 1h -- Ibelieveve did. yes. I -- it didn't cocur to me to do it for ay rzescn. 22 Q. AU right. Q. I thougt that u had mhafrrZid that you thoig 23 A. kid AW had inecrss dow to mae their Ow th at u re F t had been prepared aid salitted to the 24 inspicns -- tw of them -- ard the cunty sat ane Amc &=W oml ssitn. A W-11, temnto -- at the temnto I thirk I 25 and they made an irn tion also aearee ly.

125 127

Q. Wes it the AMM. M of baliess for the AW set• then a lte aid said I've dtandrate to the to also cxirt an inspect.in of a fa=11ity that - levels matioed in yar letter of so-and-so and s-and-so and it's ready for inspection. A. Yes, it wes csatcary and art of their Q. AU right. procedure. After that to your knwle did the - Q. .•d that - A. Nb, tht was it. Would that also being• &iof the IA zxz-y Q. Mid the Atcm•c Rx-mW, 03mu carne cuat ad Hat D~eparmmt? ± •the prcpxety after y- suttaed that A. No, they hadn't otten tha far in the g3re, hu they -- t wantead to doit arto and so - A. Absltely. I said twm of then shoed p Ars mrh as I knew all those pnle I affar:ed Q. All rz"t. them the prtunity, aid they alm cut and did it. Did they oxdt their own, arv Q. Ckay. A. Abolutely. With zeat to the WMin szeet proty, did Q. knd ,culAd that be in the rnmmal co.se of events pmorsiel fran the Los Angeles Cbunty Helth Department tda the -- they waid ox~c their wn survey of the cole to the facility and do df owa irspxt±ion at Main Street? A. Asolutely. ney're s olsed to. It's called a A. Are ym seix rcutirely ,,,-tim es - dcose-at inspecion. 0. No, I'm talking about the tie tha yu were Q. All rit.

inv~olved in -- xii -- dqtznmtiratj the proerty. Do you recall the nams of the persons fron the A. 'fW came cut cnly the oe t=i to do threi Amrrmc a ammdssicn wo inspt the Main Steet inspectin them at the encl. facility? Q. 1b you recall wot perm -- what the rum of AX 0e I recall. 'flre were two of then I can't the perso %lo ý Cut? the seccnd aoe, hz one was Herb Bock -- H-e-r-b. A. fr - yss14 Bill Chri-1 tbon~et gellipy). EL-s been dwmased abshc 20 years.

126 128

-I- :. Iad the AM re:,.r that ynu dtaLnate a A. On tihe asis of whnt they told re. prr-ey=yapr to tnmnatrig a licenses held by that Q. All right. Akd "tney- being the Arnmc Energy ausmiai? A. Yes. A- blo in so nazy wc ecpt to say tha thetin es -- a=-rg what tame periocd say y)0 can't ham rdioative material >0urcsessson Q. Ad, this was diri A. Well, whn I was dealn wiath tne -n Franiso exle y>ou hei a licerse. So, camn~ly, if >o're 9ng offine and Gemn Blanc and }erb Bok and Dick Rmth and 126 to ces tin licnse or it e)Pixw -- or utlntever- -- You -- adr there were a camle more of tim -- and can' ham the raicati material thex -1-r Ray Fi. they ame aroud all the tine, and we g± ar unorr•rtian 9 Q. Al rit. first hand from thim. 12 So ona of the conditions to termirnatin a licne Q. wanzi .hav been to haw renovd my xaunI%•tI materials All right. So that the information tht yuv Just to tan Satisfaction - discussed was - 3 A. Tht's right, and if they find arthing - A. Te infcmmtin ormming whatever estians vi 14 -. nmes- had ao tihe relation or any other thirg, and wha it 15 A. Exc•se me. cames d,.n to -- uh -- d 'tamtioI asked tuem: %all, 16 Q. Tha's all rigt. I Cn get this don to Zo, bat it's goin to take 17 A. I - if tiny find arythirg an t-ii insecion forevr. Now tunt is tie practal level that I have to is theyre -- tecy will rt -- tiey will at terminate tie e drteaina to? Ad they told me. T2y wrote it at in 19 license. writing and -s eme a letter. 2025 Q. okay. 21 So the clamp of a prperty -- tie 0. OCay. tin t tinhe AMt wad aot 23 at ntia. of the pronrty mts be dane to the And >r urstn terminate a Lxm unless they w-e satisfii that tie 23 -tia ,io of the Aardc nRe 0zmissdon, is than proerty bad been clsane ip was ixtomotion provided you 24 right? A. if went to gtrid of the L- uxrm directly by Areainnl,t is tint right?

129 131 uAE mvm RwN SE=vIcs

i

A. Mfat isasa±. 1 Q. And rless tey're satisfie with thit clww Q. NMw -- uh -- to yoor knowlede was it prnmissible 2 the license cld at bein tznintd, is tint m t? -- or materials that 3 A. Rigt. to leawve crtain levels of radiirei with -,aitiw 4 MS. nqIrn: I'm going to object that it s had xadiwct -- had been cotamiratd -- to leaw trme an the yrqty at artain 5 fozsion. We d21't - materials levels? 6 Mns mnnss his testified that bi did at 7 doomm asr part of his respnsibilities for PM and A. mx& I right. Q. ro y0 rcall nt those levels we &ixg that a tint tin only d~.amdsioadg in was persnally wa 9 involved in usat tin Matin Street propety. kri, tine period? 10 tl fre, I do nt thin tian e cinitate on all A. i, I do nat. were infaaued at that ccasions tn tnhe AM eith r ad t la•w teinated a Q. lb >1 rcanl vrkmtI you 12 li e or tat- in all inste cortadnationa .Idlaw tinse- altbnxji you don't ransx tin levels raw, wner 13 been remo.ed Ier a li wosa entnted. Fu inore of ctain levels that the ir cIAd de•m to leav on tie pr=perty 14 I'ba to striks. pedmisible levels, I ixnst. it, mze established 15 K. EC l: Q. Mr. Vad, the answs thit A. These 16 >01 jiu ge ms regrding miat the AM waAd do or at do by AM. AVd I Can't rumese whnt tiny were, bit tiey wers bakground 17 in terauntig a license and in or aaxcniM or nt fairly low, I'd say, -- atno mh a 18 aiw g the d ntaeduntian of a property, nanyou tell and so fortli. 19 me an wint IW-- you provie me those ansr? vers d1d Q. lb >01 know whethr thi Atmic Enry amm' an 20 jai deain tt infametion or )lowledg2? caAd iss a zg , itself, an its suvey of a kmty 21 A. )m did I d tint? tint as bing~ dentsiatnt? 22 Q. How did you dtain the infstion and knrtled A. What prcpety?

23 tat tin - altti ten tstn•r- tint you jinr [zu'did me Q. A I.x4t~y tint was being dstandrntt, like 24 r 11ixthe nVr pmoanixus - xit -- fo daontamnixai a tin Matin Stree propety. xild tiny laws insst a repot7 Ctjertim. le did aot te fy that 25 1-upty acd teunbntirg the liceses? WS. MIW :

132 130 LVE NMEE = SWIM I

1 A. -- h-M not Coef--!t.-.ly 1 the A~r- oa~r ar- .ama 9=vey of the prpety. 2 I~f youi'r usimcx a =rIp,.fli of ceium 1.37 chloride 2 W.F.PAZFS24: I beLieve he did. 3 it will go -4z into cocrc floos -- right c. in. You 3 MDEWM'DM: Are we at: the trial? 4 go to dig the cocrt ca. 4 W~.Mi=R I hae. to irrj=)e chjectains WHL 5 Q. fli -- speaking off cocee did ytczr deo- - he makes sa:ýans mt I believe miseprset. wkiat ycaj'v -of stated. 6 WLbld the a.=%PLof Strike that. 7 MRt.PAIE.TS: Q. Mr. Vaden, the attcaxey a-- 7 8 Did the sr~vey of the M=2 Stree p ýt pemted n ake d-ectiacn 9 involve takixv any kind of -- uh-- soil saples cr 9 A. Pmethey?. ~ 10 sauples of the concrete 10 Q. -- to g~s~n that 11 A. Vh4x was this? 3.1 X. aay. 12 At the a 'in Stree facility. 12 Q. -- I have so that it's on the recod of the- Q. 13 A. we surveyed around and we found extensive 13 iih -- of the trans p, so that they prseve tat - cnamindation. in thea soil paticuilarly in back. And vn 14 A- All igkZ. 1.4 went in anddugcut all the soil two, feet BTin e ack 15 Q.-- cbjerziem for later. 15 yard. 16 ar it w as ~nynastandi th~at ýax sid that 16 17 Q. All right. 17 pers3T1 from the Accmic Elrgmg Clondisim came cut to the 18 An o did you - is MainStetppety and surveyed that p~ety themselves, Wata tess did you I~ axc tia soil to L9 is that rigt? 19 20 den~n thaut it was cotaminated? 20 A- flaer survevd the property at Main Stet 21 A. Wgra got it contadminted axe you1 sxyixP 21 Q. itat tests did you Ifn Fam thea sal to 22 Q. OW~a. 22 23 deemnez whether ax rit it was contminated with 23 M yb know '.*atb the Jan'yiAa -- whte tie 24 radicaciv materials? -~24 Mnad &= ~iqM -- the personl from the 25 A. Mmsuze- -- neasremats by' inatnuit mainly. 25 kAtmi Earjer O=Tasic.j icm~ a report regading tat

133 135 LAMEM% rMUUM SEVI tAKE 7NKE REM=D UMC

t

Q. Cksy. 1 d~omrissica? What- was -- hatt instrumet was this? What kind 2A. I do not I= that, hit thea property was was it? 3 rele.asd. of inistrument 4 ahlef pan M=Ia the type of 5 W.R MMSM~: Q. Vhst do o mean vkmi~ you say' Q. 1b, wh&atkind of instrmet? 6 ti-at *the proprty wa reeased"? instrument? 7 A- It was gim back ax takenack by' ti-a larzaod. 0. lbwi did youz detemx - uh-- whethe c not y 8 Q. Did the Axi &mw~ Cbnmysim prao4d arry kind 9 of notificaion tat they h-ad released ti- acpt and strike th-at. 10 that :it axcild bea use fax ote purpse safely? CtŽe thax removal of a naeia1 dth=Is U1 A. T-bx-- I boe mi~8deaAý-that. - -- --I method are you awae of 32 Q. Wa ti-a Ph= SUe pety the only proerty =iztatdrated uh what from radioacive 13 where you wee persoa1y involvedi in de aidratirý a to clean -- xux -- a contaminarted ckjec 14 prcpmrtY? ffateial? dus sittirg an fixture 15 A- '&autisrgit. A.. if you hmmj raiccive with 16 Q. W. Vaden uhta a-- xix -- portion. of a faaility and/ax walls,.n ca n use a amnple diergat sobutiax dirt. 17 conaxtamnaxted with some sort of radioactie cloths or brLuahs and wipe it off Just like any

IS materials -- let's s' a portiax of a walU a dusk ax 19 axratbixr doe tht aiation affix itsef to ti-a -- to A. Yes, th-at vw done 20 whoteve physical cibjec it's bee. xposed to? Q. -- an theMain Stee fadlity? 21 A. It I I I thea chemial cuizd that it'sa A. -- particularly cn. the zfters. 22 mixed with. Oatain chmna1 coapon will cofinir with 7he prevLDxa att s by ~papp to deoaanrite 23 different materials- Somtimes it's amnply sitting ka thea 24 Pyically, tl- -i faciLity wer sort of -- ~a. 7bey use a pramnoic 25 Q. All right- drill, 4udii in umx blv patices of the contauist

134 336 LAIM 7RMl=MSW

______A. 1 ______7

sinply 9ging to -- he bat it back to get the castaer 1 ceret they were aryir to get all the way up ai all the list. kd hesaidshe9wssiug to gt- cu; hewas going - 2 rafters. kid I had to go around and clam the m-nle darn uh -- cloee the btJmxi tcin. 3 U-,dm 1p. So I •aid: What a"= dtctamntici? It -- I 4 wI use eletric dills that dn' t make my dust. said: I'll he around just a little bit lcrasr; I can gt 5 Q. lb yoL knowlede vmud tie Atc Energ it started -- cr Vdataver. 6 Ommisssm hame allowed the release of a prqarty for nd he said: 1b, we'ze goig to have sae 7 further uses -- uh -- aserdni this prty had licenhse -- wa ter -- he didn't 9o along. and it used iotive ateriais? people 0. Clay. 9 A. it, they wauldn' t -- they w'ildn' t and - Was it yur impression that -- thit he was going 10 th -- tiey were -- tire was asm prere by the to be reqmnsible f- making sure tie prtet - .1 ladlod vkc stated tint 4=t lie ventad to pit in their A. Right, Iassmed he wld be. 12 next was either a cm*%kitden ar a risexy. Q. Pleas let me 13 MS. Mtim: And, again, I'm jus 9gon to A. Ebsen e. 14 interject an objection to Mr. Patterson'saam question as Q. -- finish. It makes it vey bard for her if you 15 ladare fou~ndatio. don't mait until I finish. 16 ycu cans ahead, thouh. I sean, you already Uh -- was it yor iipressin thit W. Goldstein 17 we.= ahead, so... ves tking an the resxnsibility of d5 atnti o 18 uE' Wn : Which we asame nue they wmeted -- a lot. of mney. aathm ia e otin enr a Sreet prperty? 19 to sell us the building very A. It wes my inpressmn thit he wild dobthat. 20 MR. PAT'ERSN: Q. ts the AM Rsdenawere of the 0. day. 21 potetil cs of theinMain Stretpripaty? Akd how did yu. om ky that inpressiorn? 22 A. Yes, they were. We discssed it. A. Bsm it's %uot's re.uized. 23 MS. WMMI: Can we just clarify far tie Q. was it your inpressin that he bd pzridased the 24 renord: W. Varen, was the property tin yo• ere Just property also? 25 talýd about with reqat to the inkey tie Min Street

137 139 ¶fIlMM Fdt'D SMR7fCE t

A He said he was. 1 jrqerty? (rief pane) 2 'lE llINESS: Yes; tiat's right. W4. PATIEMA: Q. Ckay. 3 MS. Mti'=: 'flk you. I'm going to abm arn Edribit mnmaid as 4 MR. NC']ESM: Q. I'm prettY re yM re Exhibit 23. And, W. Vaden, I'd ask far y• to take a lcck 5 ier atn this, but just to make sure: You have no at this dmoast. 6 pejrsnal kl eae of tie -- of ay of te eavers regrdig A. Witess• umplies) 7 the • •bntamdnatiiar the d ssianirg of the Q. Hme you had a chiroe to look at tie ocuaaet, 8 providenia Street perty, is tint ri4t? Mr. Vaden? 9 A. I missed the first -- I hamn kneeni of A. I have looked at the leter. 10 what? 0. Do yu rergmize this leter? U1 Q. Ynu don't inre my knowledge of -- of tin how ar A. No, bit I reoxgmie the limits tInt axe in here. 12 thi sm in mirium the P id a Street propety was Q. When y Fer to "the limits', d• yiumen thn 13 deotardrat~ed, is tint right? Irsted as 1, 2, 3, 4? 14 A. 1b, I ws at there at all. item 15 0. kay. A. Mist tiny're talking abot, -- ut -- tin- radiation or they would not let anrbd 16 Ho did yi4 cme to knw that - levls that mist be W±Iie 17 you -- I thdir that you testified thit y1u ead elme in tin baildlrg. 18 asked Vt. Golsein -- ui -- or offered your sevices to -- the item I"sted as 1, 2, 3 ad 19 damtaudnte tin Provideria - lb' these 20 A. nhat's true. 4 -- tin reunirements izqxnd upon you &iq your of the Min Street - 21 Q. -- sret a-certyto w. Goldstein. mt'atu . Mat is c . 22 sty dad you do tint? 23 A. Br- Q. - 24 I asaed him uiy in koalt ti• bzild bs., and A. fltisrrz ± fried -) 25 In said In msnm't going to cpaat* tiere milpnme; in was

140 138 insE MGM ~rumI Siv LM• WMMR•R"R•VO I.

h-d I an gon to aplgz ahea of time. I Im I %R. r7p92: Q. I'm alm,= finisi~, going to be ju~p2Xg aroud a little bit hi.ae I'm just 2 Wt. van-_ txywxj to ask you qust=1a that have occrred to mebse 3 upo y0= aIMCS to - 4 nay I= th at Ddiib. A. 'fat's dkay. 5 o. -- the other attorneys' questions. So in the W'. A. A.-Mich~d from if I caitus 10. aknt vh&at I'm F. L. Pric a uz~ couzrse of dong~ that, as frietficatitn asing~ you,. if youa o..11 please tall me that you don, t 8 Ewhibt 23.) undestand or yc're not - 9 W'. FFý Q. tki -- I'm just going to ask A. I sure will. you12ifya -- ifyo k0.13crkne rlacaneiePsl thiat eaylame Q. -- cleas. been= Z Sm-et this -- to. Chiy. Qeat. 12 Did )Ku know a Richard tonelson? F~xt, Qxxr do youz residel> 2.3 A- Yes. A. iMiat is %b&at? 14 Q. itw d= yi )mw hum) Q. itaire &b ym. -- iire do yx live? 15 A- ai, jtat- taD3-: to him at meetings and things A. Right here in towni. 16 &r~w tka ti Q. 17 Q. %3s this -~inth tm ircd that you wer Ita ' s the adrs athee? 18 A. 19 A. I thixrt I ney ave seien u t the O~rson Ciny? 20 FePs thJo i faci:--y &vdenue visited dthee with the Q. Yeah. 21 Xh -- 22 Q. Have 10.1 had any' discus~icri with Vc. Doe2sm in Aidif - 23 the lar five year? Is there a rkrre azitbe wecn reach 10ou at if -24 there -- it berras -- 25

143 141 1A85 M*M8IWGN3 MMVC IAXE Mq-1E RWCR= SMIM i

1 m'. I'jD: It's in the sAvpem. 1 A. - r= in the las -- not in the ast 30 yam. 2 WR.SHD9ZMj Q. Is athem- 2 3 A 885-9534. 3 x.R. E~7ESC: Q. Wre 10' -- uh 4 0 'flat's great. 4 Did you krxw a peso by the riam of a 5 A. Area cod (702). S 6 Do you1 have any present plans to nove frcm that 6 A. Say agin? 0 7 7 Q. Saxdl SiqUfI -- something like that. Doe 8 A. lb vkglt? 8 tha mm -- strik a bell? 9 Q. lb 10.1 hae any Iras plans to nOme? 9 A. I &sY't think so. 10 A.L I'm thinking abou1t it. -Sire my wtife died, I'm 10 (03UOs Off the 11 311 geting too Ing a hcus arx I'm thirkirg abou gairg irt~o a ll 12 12 %mbliss1llyshot. lbara you for ?czr timea. I'm 13 Q. Are 1y- thi~Tkin - 13 firdshad lb 10.1 have any artr -3 plawn to Tmna or is this 14 II wego off the Iarfor a minut~e? 14 15 - 15 MEl~ just ec"Othin 16 A. Not right no, but - 16 B I live in a 5th Avrmu tarhus axlf it al&=. 17 M 17 Of tie recod at 1447. M33XFM: Aid I happe to be in a private cd'flx- in that . I'm a 18 tn 18 the h-r so it kind of bwehove we that n.jte 19 rie 19 narbe of into try amctfit -- they've got 20 M 20 if I nove cut crg ndrij aut of daeir ears.. 21 Please P~xwd~ 21 oxdiudnimua caiwteabou~t, this lawsuit? 22 22 Q. W=~ wer 0' f~irst A. ltasn I was cotacte ahcui vkst? 23 m. . vami as I indicated to 10. przcr to the 23 24 Mh. were yw~ first contacted about this law3A 24 satof th awcetim m ram is Jichn -Siarl and I'm have be =rutedabt a I m dt. 25 25 x. I rever

142 144 IHE EM= 1 i 've be' cxacted abca a dq-t-m. 1 fchit he won't tall arybxly z-ruingir the shriff ut~ 2 Q, vb ere~ yoa first conacted -Amv a dqxsiticn? 2 that is. I. .. 3 ). I think abn.± sixintarl ag. 3 MmI.e~er off the recý 4 Q. Do ym recl Iv contacted1 ymP 4 P.R. SHDWA: Q. Nbtr was you re, disonsicn with a~nye aiait the ckprniturm 5 A. tin -- ilieye it w~assamod~xy fran her off i 5 6 6 A. Chi, I think just akror a mrruh ago -- di - 7 7 sa1ecre callo and said: SOm m. &an to I.A and -- uh- 8 A. Lb -- the-- un-- the-- uh-- coaplaiaznt c 8 we, U pay your way and e eytlur f= a depitrim. And I 9 4xve tint'sa lisud on tin stiboena. I don' t remuTr 9 said: 1-b, I don' t wat to ge back to LA fcr any purpse 10 vkn it was. 2.0 whatsoeer. So they said: W-1.1,w~e'll hay it up cu 11. Ch, Ice & Ine. 'flnyre cmang in thro.gh 1.1 W~y. 12 tne & Ine. 12 13 Q. cimy. 13 aubpoe. hit it said vtme it umgoing to be in Remn. 14 D:) you recal Who fran that 2aý fnn contacted 14 kthetnh-. the loct~ion ves rn,,e to here in 15 is 16 16 17 it? 17 Q. S-- pricrto 18 I don't knowi. Sv -- I think she thinks she wa 18 Strike that. 19 tin cne thnt firs cotntacte Tie. 19 So whe wa -- whn-a tie firs neeing 20 Q. was this a telphne aLl 30.1 received? 20 fac-to--fac tint ya had with &Tjon ab..Z tin dqxnitiai? 21 A- Yeah. 21 A. L-Ast night. 22 Q. Was it a nen that contace jt1? 22 Q. krl w'kn was that with? 23 A. No, I belimev it was a lady. ge said that she'd 23 A. Ibis lady right here (mxorinti PM. Wtreith) . 24 bee referre to tre by Bnlanc, I thinkt it wa. So I 24 Q. Uh -- pro to that tine had~ you net with ar3bxdy 25 ~ml a him up and gmm him tin Q=n far. 25 abtý-d-i-

145 147

1*

I (Xaj~rer off thn recod) 1 X. Absolitely Mt. 2 M.. HIM~AM:Q. Did -- did - 2 Q. Rave you eje given any witten statamrts in 3 A. It t'omn cut it's allI his failt,. I'm going to 3 aMzn=IM¶ With this dqposit=Vn 4 nell himnup agin, nw tiat I krxw what tin sitmation is. 4 A. wiktten staterents in tin anthbtim stut? 5 0. Wl~this irdividal] tell youi ivt thny were 5 Q. In ccneciin with this dqnsitia, hme y ou - 6 cafl'irr 30z? 6 A. 1b. 7 A. Yea. 7 0. -- prmviied sany wri~ttenstt~ 8 M saind that - -- hoicaly tbnt -- u 8 A. 1b, I havle mt. 9 smeix* krigbt tie old Providma pr~arty and tien 9 Q. Did yoi ., --

10 leaned Iate tint it -- s a ~In I -- had ins a 10 D nngy-eting lot nigkt wht were you U1 1z 1 site by thn EP a a w'aste site cr aziething and 3. 12 that they wanted to know what I Mewa~ it when I wa 12 A. She aske if I had ge cetain d~rnmus 13 them ad 9D fczth. 13 befoer -- 14 7ht was akoaZ it. 14 Q. k-d wee sme is 0. All xigZ. 35 A. -- msrt of wh&ich are in this pile right hier 16 Did you &dwin this telepbzne covran tion tell 16 17 %bt 301 m~ild recall aba tin prtperty? 17 Q. DD yau recal I ay &-zes that wee aonlasIt is A. ND, I -- we cd't ge ixt-o tint. rada Aail. is night tint 30i were't shoon taugbt (sic)? 19 0. EV tin way, is W. Ala still alive? 19 A. Mo I ccuiiiirt -- oAgnli't upke tint distiznicta. 20 A. Wk. Blanc? 20 lbnne's too dmn mmy tczay. 21 Ye,iheis. 21 M6. MJMM: I can I~ f= tin I~that 22 0. It=er does he live? 22 every d~zrat tint I sibma W~.Ibion is a duent tha 23 A. Szairem w in hIifrniia. Ido' t knowexactly 23 asa pzrciza1 takry at tin dqmiticst 24 Qxe. 24 M6. SIE9L1 0. So you1 reaull any abtjec tha 25 e' go a old cdn up mn asna t~rof 101 rhmmoad last W43t tiat lwse mt the s.*ijes of

146 146148 yor to make :qaws~le tcarY I Q. Vbs it also part of responsbility 9r -- d - - the physical ccx at the facility 2 A. i can't recal wr.%thj- sp=ý 2 that sich as there wee' ariy -- ub - Q. oowti zspalsbilities of the 3 wee -- uh proper, easkuir =raizias of aryy kind of fsat-eial and that kirti of 4 Isxqtce 03mtitee was tz -- ui -- maes issue of 4

enapl1ye CipA2Mm, Wit!' --'PiWY Pr~ W Coret waste yes, I E A- Yes, capn cau...axm wiath -m reglaticri of 6 A. When it had to do with ~acriumm, for selectixg the quality~ of barrels that tihe AM. 7 was responible a satisfactory cortaizier acidirg to E Q. Were them arry " matter = Jem tia the a wouild be ~ra of thing. 9 Ia~tipE Olnittee Cialt- %Ch~apat f3= thoe iM s? 9 re.iqtia and all this sort vii2 be uriI e to ccrAin A.K ot, it was ct~yanfned to tie safety of tie 10 Q. Mtw those barrels - us of the radiiaLxleid.- on tie prcer-_ andi so fcrth. .1 mast geineated &n-irg -- -- the ~aceaticns at tha 212 Un -- tie cm= ce was vNmy a~ive in the wase 12 faciity? ,3 hindiljxg. Mtsmwewul np trxlcc of maste fron 13 A. lhti those over a highway 14 Bidrkk all the way d:);r. =c Lang Bsc, a sasbe of the 14 kid when you2 transport nee the 25, Isotop Consittee woild a~ieys cratzy 'c.± a gru of 15 y~ou'r5s b±130 to = regulations, so it mist 16 trucks just to sake sure emAythiz got tI safely. fla-y 16 gaalifikat~aal. tiat tine we pit the WlI-a~rove shipire 17 woujl've had safety radii~ai deecionu egzipwaz in their 17 kid at amzui the place 18 cre. 7hay would be in din9 in cas ac:hirx got -- anlht 1S8 a- an3mkm. Before that time, msrttzi the gamrtity on the 1-r ae'a got los off the trs- Aid they would run izatfac 19 one ox3d amnply write the isotopeand 2o with the poilice, tie whole bit -- um - 20 side. that the requirements 7- 7hat was their -j± and they =i poetty din good 21 Q Is it your recolletion with the oonpW.ry 22 onit. 22 4wag - uh -- whi~sle youwee eqp17yed to 1~9an tiay do chaz~ 23 Q. I muz to fcus lcur atterrim right now on 23 X. 7hy axe subjec 24 regularly. Sme of them dazm qlite often. 24 uh -- irstamew in which the Isotope 0--tn" -- di we get a clarification? 2s addressed isseso situtoswe aqic&a2spoes may not have 25 M~. MMiM CtuO

149 151 MElaM* WFMGSF LAKE UH REOMMC

I. He asked whether youi raw U during the time 1 bee azplyirM with axejpocdrs topic 2 How did those instnce to the asmmittee's 2 you were ter whether tie regulationse I g ~Ion the 3 attentim? 3 of - ary spec2ifi 4 A. How did they Q=7' 4 MEl NITESS I dorn't mrwber D. 5 Howibdid the cnrfmm~ find cat dhat tiose tuirgs 5 dege that I r~ ersticn, hr- I'm sre them emae -qHWX: Q. Youarecfl there beirg 1±Dz9 6 Ind -ý -- tiat apkses bad not foloe proceire? 6 M'. 7 A. kMnly tiat mas my jab to kee tiem I~nfred. 7 but at this time you sait -- bexk %tatthey Were? stuck irt~o 8 Uh -- if it y!=jut a tzz oveeqamze, I 8 A. 1W~ put cut sq4p~namts which we just 9 wouild gay to the cnmzittse -- but in tie eye=t it was a 9 our xegulaturam and started following. flut's tie way that repxtabae ~expoue to the Pwoar BierW Ommisan, thay 10 wokd 3.1 Q. Ile *they" hirg wh? 12 got a copy1 of tie lattar. 0. Now was oe of yaw Zespmnihi2ties at -- uh - 12 A. AW and r and any zutbe of regaatr~y 14 tie Pzuixlil I~rmtY to MM3 the ezpkýý anmL sae 13 agaries. 22 sure that tdey mae- ox prrp Safety proosus 14 0. What other r respvibilities did yvmuhave at the A. 'flat's right, ard to m~ak ae they got their 15 P~idxa facility?. 16 physial exmsn mid team in~ag e and as forth aA they 16 A. I thir* I've -- uh -- I've decie pretty well 17 wore dwix wruitarirg egmnnZ and everything that ins to 17 in derai I tiose that I had. tie is cb aithi pertainliM to =fyifin Safty. is Q. I'd like to fox. yaw atteryicn rxw on 19 0. A-d that's somattdM ycxu did on a regular basis? 19 receipt of waste material frcm -- uh -- Is±le atozels. 20 A. Absoluely. 1hat's what I mas paid for. 20 A. Witnes rrzls head affinvaively) *alit were some of your othe respaible as 21 Q. Youi uirtbted that for snall .axzrs the czmpw' 21 uh 22 had the ability to Just pick than up in pickup trucks, 23 A- I ran tie filmbs ig seinvce, for oe thing, arid 23 corc? 24 as I my, I would consult, an haelf of tie caq~V %hen - 24 A. 7heti re 25 thni omEEy. 25 0. And for the large %taluma of uatexial those vae

150 MM~ MU M ER LAZE 7AEFCM M 1 deie-t by' th in a rers tbrsehves, ? 1 0. Do yu recalU the n~ars of any' of the 2 A- or a =mLatto1 shipper. o.ista0Trs -- uh' -- chat youi -- whs place of b.2sines you 3 C. Sa-bocty k-ned by tin -- wenst to in the pdn4,p truck? 4 7, That's riqm= A. tn -- no, I ca't.

5 Q. -- csae Q. Eb youi recal the aviru e of the waste nnteriaJls 6 A- 'hat' s rigt. that ý- were piddrg W. 7 Q. onethig:-nee~dtokid rmid you A- Well, aie tine I recal ve pidcni tp a cmplie of 8 abou: atI's flportar that ýK ai'ac.Ljtfl I finish. 9 That w.' we'rze rio talking u. er ea ±loce and uska it lighs. These wer beas ligts eunsed in heavy plastic 10 1 1~ or. the Onxt Repoter. toe as ifadarkes for different things includinq thenend of a

jet -- uh-- arning down to a fighter plan so we c~i see 1.2 A. Mkay. 13 Q. One of ti-n reqaribilitles of ti-n na of tin standards hrt sa they had blown it and they had to get 14 Isotopes a==t~tee was to acirpy astoer isipm=r of rid of the whonleshi~pnant, so they saed if I cai1d come b~y 15 waste to the Provd=:i~a fa.lity'. ft'2=s one of tie and pick it up. Scb I went cut and picked up a aipla of 16 things tin-y did? barrels of it and bro4E it down to the fumility. 17 X 'Tb tin lag Bgai whrf We 2n3F it Mi Q. Mvta kind of barrels wee these*> 18 1 9as. A. 55-gallon dhUI. 19 Q.All right. 0. with tops an them? 20 So when ym wee -- previoaJly talkedi abot -- Ax of case. 21 di -- ,i of tie Isotope 03nrd-tse participating in a Q. kid where wer those barrels placed->

22 =rjoy - uh -- you wee referrin = si- -- the X Theywer placed in the facility irrtil I fard 23 ;~1Z of waste from P viiara =o the Iig Beac anothe amtor that rede - 24 Adin.l~y these had krypton. 85 in than. IL- a 25 A. That is ~ kzicirg fcr saw kryptn 85, so I chadoe to see if they

153 155 1AIE M*M FWFM WC

4

1 Q. Wlt I'd liketo fan youmis the recitof 1 i'eznet cotuitadred on tin a-si , and I told theineral

2 wast r tin tm 11 of wa from -- iii -- Ioce 2 neagr~: As fa as I'm cocrned x can sell thane to himn 3 azzare to tie Pxif~ faciity. 3 if ha's got a licene. 4 (ay? 4 So theydid. S A. Rig. S So )c.1d'adcyou those sped fi barels for 6 Q. Now wee tir-sh dipments acc-paiied by aqý-x 6 cnamitniticn o the a~i infare releasing them to tin 7 frm tin Isotops Qaxmnftsee '7 cantour? 8 A. In the camof thenpidep tn..k I was nit. 8 A.Bea tiny wnt cut of cur facility. 9 Bit in tie cae of a cmemial trick comng in., 9 0. When wast wse received firm, custam= at tin

10 it caen izxle D rules and it do't reArLle -- it any 10 irvjffa facility, wse it cre of ycow job or

ll hae fMflaw? io& -- you Mo - youi cant Bond YOir n respaisbilities to chack tin cutside of those waste 12 IaC~nmuktee unn beck ther to -e all the way - 12 13 HzIM of tons of this aimeor tin highy every day 1.3 A. Thtisairt 14 I wregiatianz.O 14 Q. -- for cotamdration? 15 0. Bat whateer -- at least dzing tie tie yo wr 215 A. Yes.

16 emloe with the caqw uhw tie co 'r w~ald send 16 0. So as wast wuald come into tin facility floe tie 17 out the pidq~ tnck to pick up wast )m%isae io the 17 oamqxsys cutmr, Yx wuiid see if they wee leaking? is is . 'That's tone 19 19 kid any oterkan dd of contaizne. cQntoaxs tint 20 Q. lb ym zecl m anc ' tWd yo did tint? 20 wated raliatim wzrm- for tinir raig-pycr=w~ 21 A.. I dn't )OrDI tin nz~ 21 send an empty shipin cask. Well, we w3z1d neka tin 22 It wse only a Ilcoa hail, so it wsn' t soawu 22 Ban-c, pit it 211tin cnit and retium it. And tian they'd 23 23 say: D& it's cortndnatedineiu. 24 I dm't k3. ftbaby avag - every two 24 Nell. we forzd cut it was tarWmtad insin

25 amtaa aehn -- ls~nike this. whan it wa aaaxg in eaipy, suppoKy, go floe tint day

154 156

______.1 i wewid irside, a si , and everyidra ese. 1 supposed to be untZ X . 2 2 Q. But it was the caqtmy' standard pa-.r=M to Q. H frewetly did they -- how freqntmly did 3 -neck for contamntin on the cutsit of wage cataiiers 3 they• are a &a-d ispect? 4 received at the facilitty? 4 A. Wel1, I would say ahý±t four times a year.

5 A. M-at is true. 5 Q. Vas it alIys the same iptor or a 6 WS.Mc!H: I'd like to cb3ect. Vague as to 6 differet - 7 7 A. 1b, they would have different inppos. 8 MW.SW : Q. Witle y•u wee aTplod theme. 8 Q. ID you recall tihe nes of any of t1re 9 Let ae do it agn, do.y 9 inspecors? 10 Waile you. were a at the facility was it 10 A. Yes, I think I indicated that GCe Alar, 11 1.1 -he arpqay s practe to check waste containrs received Herb Bck - - Dick Smith, Ray Fis, - 12 at the ftacility f=n its customers for nttaoxan" an tihe 12 And theme ws one other. I cnmvt reuTber his 13 a -- i., of those arrairnes? 13 name thoh. 14 A. Yes. 14 0. Asi• frcn M. Blan:,Ido knvowere any of 15 Q. Did you use a Gei r cunter? 15 thoe otdr individuals are presetly. 16 A. Did I tat? 16 Xt No, I don't. 17 Q. How did youcdeck for • .taminai? 17 Q. Him these irspectrs from the AM would anoe cu 18 L. b took wpe tests. Wse'd take -- w also tock 18 id=Wold they inspec?

19 aurs meaements. Smatu•nes we'd take wpa sts 19 A- 7hY would irmet -- uh -- all of ffy rx~ 20 and we'd still get an irsumen trasarent. 20 'fl prodre was to go to the general mnamger 21 7he stuff was zadicacdave. Ry? Beca it 21 and say: I am here to inspect your operatio ard their 22 ad ben neutron activatad and it I mIt have crty 22 licnse ruibers, a so-and-so-and-so. APd ten they 23 a mrtin an it at all. 23 etar not forge that; otherwse, dhey get anbg troble 24 Q. I yo hame an =JerstareaM as to w the - 24 with the office. 25 pnw to yozur aqplcV=t with the omq=V vthex it wa 25 As a attier of fact, one of tUm didn't d:) it,

157 159 LAKE7HE R •F G SEWI LAKE 7124E lEFUU=MS CE

tem oaqW s Practi to dai taste anta r rceived 1 and te rm a• e aroxd and said: Who's takir• al from its cusomer for leaka? 2 ycr time up, Jdyr? Ad I said: This is the AE A. I don' t really have ary utnz sardig that they 3 inspetr. He said: Wel., you didn't tell e you were adsuc a poliOy. 4 here for an insetiar and you're in here inerferirM with Q. Yu dm't knr aae way or the ctorgn? 5 cprat••Ins. A. N2. 6 He gam him a bad tine. Q. Witle y0u Were with the cuant did you an 7 So the' e s~wmeef to go to tq nur~at- firs coas go Cut into the yard that youi p-viusly 8 and say: We're haze to mie this insanciua. iattifief as axsainJM te contain= to dek to se 9 Ad tden they aome aound ad they sit don and if you cvmiav ary I from those cotainers? 10 they say: Well, I want to see all the rI hatt Yi A- Did I go out and do wtat? 11 have recoded sin the last visit, all the exposure Q. Check for leeks. 12 ro fr- every -,ivnidua., all the air saple r s, A. Fl. 13 all the film bmdge Ireon tihe primeter of tie Wrief pae) 14 prqpezty, all the wipe tests o~m tie whole buiding and Mt. SR1) - 0. Doy kn wIri th anynelam else 15 the hot Iah and so, FoI -- 4Vi all of thes things -- and at the may ire those waste contairmx in the 16 tie Ilatest results of physical mert r amany biolcgical rd an CraM•n for leemlt -- smeone other tkE 17 sarples taml, and so forth and so forth. Yourself? Eb Yma knw' d-I-,tatkqpmvx 18 So they spnd a cap]~ of cedazstee gon A. 1 to uy krrmlag. 19 thugh in dtil, Ish ard verse, reading the mtuxn Q. You metio thnt an occasion -- AM--i 20 of eachi zafiiosjp anMdttae meeting. 7hoe ndnsea axe would±carMane kty the P±mddmx~a facility. 21 m•ye in the file - and so forth. . hgt is tr. 22 So tihy -- thiy did a pretty caqmoeinsi job. 0. Ibtet i - 23 Q. You mentione tha thetinscors would emnine rD they come by on a reguarly scaiduld basis? 24 the results of wipe te•_s? A. 11, UHir -- the ir• tiu-e WermalkmS 25 Satis tis .

L58 160

158 160 1 Q. A-at wipe tess are yc.i refettng to? Ctcusiani of the record 2 A. Wipe tests that we made in the =xse of okxd read) 3 bjsitvss all thý ith cold lab, all tl-u4 the hcx M. S[MAM; Q. Did the Inrpecors inqp the

4 lab, all outside, al: an,.nf u- -- pruss to mdak sure that weiwee uzýI the xrnxaumos in a irestrict A. Yes. Crily vislelly, h~airv. They woud lock at carea and that we wee ckeying the reguirnxuwits ftow the tie rartaa mxntor. 7 rm-restricted area, whc are diffatair. Q. N-d did the inspectors also inspect the w'aste 8 Q. Wilie yii wee with the a w did the ccp: starg area at the fatility? 9 hav'e a reguar practia of coxrdc-g wipe --vys 10 12 A. I &rl't krrsr if the cmpmV did or no, br. I Q. it'-- why cb yo say that? 12 was in ny progam and it w- asd zereglarly. A. Well, there's -- tiere's 9xh a thing as 23 Q. Arid where speifically within the facility uroesry radiati~m eqsje Aid whkydeiberately gc) 14 you' have these wipe tess ccxut: u=t an area yo salradykr the level of aitamniat= 15 A. Well, as I mnaticned, I woud do them an the t and the hegtof mlimitn ecxposue is pretty high -- wh 16 sraces and m the fl~r and the laoa~tocy and the ho 9D in th-r aid ge exqrasd? What's the pciit? 17 ceIlI and in the faciity mndura stp, offit - I'd i- Q. Mbwis that raidatim that -

is di tŽHn m the sereay's dai- -- every -- wall, they Wich~dareas are ycu rferring to as - 19 wat reassuanc. And -- youi see, tleyre not being A. I'm referrin to any restricted arm ai the 20 radiatii workrs, their lseves of expm are sonc i--y-- resticted armas vkeie cnly radiatic umi'mrs 2.1 kiwex that yo have to take special preamaicne; to prtts= caoand their eqspane ard ture of expojre Is strictly 22 tiat aeas. limited. 23 Q. Wouild ý-. t~ai ary wipe s-ples a *sii the And it's aginst the po.c~y of radiaticn to let -24 facilitp. arrybxdy else go in there and stay in there fcr- any 1axjth 25 A. Yes, wetcrk of t~iareairecssly.

LAKEMI= A~rE SRV61 163 IAKE MVUE REM= SERVICE

1 Tb esablish %batbadqxrour leves wee wewc 0. 7fose reticted armas would intin, tie -- uh-

2 dksn to the post offi alnZ- crr a ncrih and wiped tin arm here y-i previculy decie -- h-- barrels as 3 f2ccr of the ps off,. Mant was ow baicgzrxid being stoaed? 4 starr~rd. A. I'm talkidj alat, tie restricted areas whc are

5 Q. Ad the caq~iw kept I of all thos kr~im to evm~tdy vin works in the plant, 6 wipe-d-a saiples? 7 A. Absoltly. Eburd notebics, not I~ -- ad tIt in wkime tie waste is stored, the ke= 8 notebooks -- boxid I I. cell and tie a3d labortoy. 9 0. lb you knowi wbethr r riot the cmw bad 7he czn1y rcn-restr d armas an the prqperty axe 10 follcwed such proooize peior to ycu eftplcfent with th tie &Nic and the mautde shop. Q. Wyanex 9estirn is gaing to be kinsi purely an 12 A- No, I dDiot. tie fac tit I don- t kmw much abo i any'thing about 13 Q. DD you -11 aaeing any wipe sep~irx r

14 that prdae you e~3qa sat with tie omparry? is it pmibls 15 A. No, I did nx. Wall, was it the am at tie Prade~nctia facility 16 Q. Apart fran inqXIr the I~ tiat Ycu'w tiat asm of tie wste aantaorms were emitting Yidhatian 17 previ~aly descibedk - uh-- did the AMJurpectrs earnl tbmajh Physically tiey weeWI't leicirg any of tie is *.aec the #S 1 failitaie? 19 A. Yes, tey di~d. 7liny we= ape the vfta pl.ace A. Well, I'li hmm to ask you to give en that agin 20 with tdair ~amisrmoao a 11-1i bit. 21 M6. Yc.tiH- I'm Borry. Can y repet the

22 9-UQZL Please? tia -- is it yaw rein13ctim thnt tiere w~er 23 MEWCMU is tie 9qesiam Vatbe antaalars at the Pxrwidxa facility tiat wser 24 M.M:KM Ye. emitting ielntaan that could be detectd by. my of 25 Mwod zea ins-t -~ dxrga tin #Wsical omtainers, dwsielum,

162 164

&

I t I

were irnact and with:=i leaks? A. Did I say at? 0. W these airtigh drums -- that cobalt A. If I tnrsvez-d the c ~re -- uh -- the material? questin co rrcly, amy conainer can be emitt-ing rdiation A. Un -- yes. eve if it's airtir• zrd doesn't leek arr-thi Q. hid vz.e were those drums sted prior to beirn we're talkig radiatim in :he form of pum;lar put in these old bxys? energo r waste vesus zdliti in the form of pat-icre A. I thirk sum of were in tbat pit with the or Iqaidqj djriý = -- phy9sically out of som container, radium because that's whe the really high leel stuff so all radiation conzaines with a se- source in it - was, and then some of thm were cu there in the yard, and it doesV t leak physically -- still h•s radiation amdr then some of them came ct of the ho lab and were odmgged cut the si deperixn on how nuh aieldir t-heme is at that tine and ten -- thern put iro the big auo be e aroumd it. n-le more shielding, the l . You can't st. we krw t1y had big dros. it all. It's the law of dimin -emtxs, really. Q. Did you personally inspect each of the If you put eno lead around smehing to keep ontainer uh -- prior to tem btn --- -- shipped nr radiation cut, you orild neve lifft it. You -0fd rnevr for disposal at am? use the radiatinn. It's inpoible. X Uh -- I always insp e the ne barrels - Deo tiat aeam y=uz eetio or - eithe me or som of nv crew ixgp=t the new barrels to Q. Yes, it does. make sure ther were m holes in them. A. 00y. Q. Wt I'm eferring to is at the tive the Q. No pr-Icusly in your cqtri-n you -- yu barrels -- the cntaireas were colIezced and put onto the desribed te dispsal of same nin rirad plus cotainer at sea in 1961. trucs for shpment.. A. MW had to all be wipe-tested and measrd for A. (ins nds bead • ly)_affinT zadiatioi. Q. Do you reall that iridnt? A. Yes. Q. flst wsa part of the proreizre prior to duppirg? A- Tat is riht. Q. w ts cntainrs wre, as I undzstand it -

167 165

And, funthevxcre, on the label it says what the and c ± me if I'm wro -- Containers thit were in the level is, too. You got to ge tht on theie for waste store area in the Prdancia faoility. radiation A. Not all at the swe time, bIt they were - rOT purposes. Q. S: if there was, for instan, a karrel they were tien -- sMe of them ý Ioahf tiere, snom f containui colt eterial in the stoa yad that was them we already tiere, ad some of thm camn in alreay Ioaded there, so.. . going to be trma rtead for sipment for die a at sea Q. tie- d~mig this =iien± in L%6., tiat bmos1 w=Wl haveeenim

Bu the wasteaontalres tiat wer in -- kept in A. very barrel tiat lseft there w wipe-terted and the wast yard were amon tin axtainers that were dispose of at sea? l~amdp prcpely. was ac of the I p of tht wipe-testing A. Yes. Q. Ped to dtere w r there wre any leaks from tin barrls? Q. Now the ontainers thit we dispse at sea, A. Miat was tie ida tky ti wee inecta, yes. were anmyocf J, containrms relq tge prior to disposal? Q. And do you recalI deecrin any leas fran any of A. Yes. thy were. of any of the materials t were shipped for Q. Do you recal uidi ose? tin barrels A. The ones tiat lhd tzxsmm ly high sourcs of jr~ and Ai Spsel at Se? coblt in then -- uh -- we dgirally in s5-gallon dram A. Again? Q. o yu remll"dring the corse o the or smallet dza, hit the acivity wa o poweful we 9g ie-testizx tint as dxz whether any of the cotainers same old usteed V13rx~ hbVs, Mt the tWS 0± of tdM, fi lId them with t onof =c=ae, put this dom tie tiat wer transpoted fjor di qxgl at ean - whether any of containers sowed any leaae? mdidle, amd thin acrated thit ito tint. A. Were tiey what? It weighed a-n4t 2, 000 1 Jn eac. Q. Each of t heCrinew thnt w trnpted for Q. Now were these sealed drums of that umetial thit yu we talking abiu -- thn cosit m-tial -- were these disposa at seausewip-tested prior to shipingz. A. Min isotr±. airtight dons?

LAKE ME •REPORT=S•WIO1 IAKE Mi EOTI E=I T

Q. How, often - kn---eppec that udp-testin was to A. We lode a pema1 bo~ar full of that 2 mriesuy~n-thoriinm and all tiý raidns barrels and sent it upto Idaho. Q. were thrme 85 barrels? A- Yeah. 0. 7h -adi of the waste ta~xxa s for trrsot 0.Al right. L-r ebsposa, ar sea wa aIsc sA avised bY ABClpers-l1, kiy other in~ts in which the caary transpoted waste for edi ssa1 du-rr tie Lure ýtu wer A- No. ic 0. We-a =mol%%rent &_d AM haw with those -- with A- k1ell, tin Only ace tine I was nmat1e in1 waste 12 -3t ah-nw disposl was as a onsaltant to Cbst Rise (ltxrntac 13 A. OrwCr two ooa~s they 1aan inser= to spelixj) ?Mrizn. I tcki *affL three barge I. fr-on 14 no ait with =e argez. thir~i weruehai cut to the coe an diarp it. is Q. kid - was- a ueing or neeting pro to the Q. B= tint was directly from tin c~toistnrl 16 acna shipize to go ovr p neae with tin SE- (sic) - A- Yeah, we er -- I was doiiM consulting. 17 wit tin A~r- oxxe? Doyo ram' I1tint? Q. Do ym~ raufl..1 apat fran tin shiprent of tin 18 A-. ehp tin firs tm. I cant recall. zniiizn barrels to Idaho and the ahiprnt of barrels for 19 Q. Ar. any tine white )cz were enplaeai at tin dlispos at am, wee tinre any orlier incidurs -- a 20 -ov-im :5tft, did_ yo eerse -&- tint ' instance tint you cn recal in1 vkt waste containrss 21 zbaxjht indicae that any of tie wast containers stme wee transported fo disposa atie place? 22 in tin soage ýerd bad I eae ors 1a tinir cotents? A- ii,, I don't recll any other insatance. 23 AX 02- you wen down-the lastat. 0. Ftevria-ly ý testified tint yo -- ý 24 Q. Ckay realdtoba tches of waste that you reorvarux be 25 At am' tun while you2were eaplayed at the dibrspos of , and thent I was unc-1ear as to what you

169 171 IJW MWM== SVICE

4

1 testinrxnyeas. A. I cc that part. 2 T11--

Q. -- fatulity. did yo ver see arry irrdict~ic tint 3 A. I thir* y0.u usy be referrang to tin Air Pintse any of tin woe otaziiners tha wer artAixne in tin 4 shipients, is tiat it? )exd bad'leke oraul thin~ cotats? Q. It w'as jiý= prim to that testimrny. X. Ch, yeah, I'm air 1 sawvde~nc of tint. Un -- y s eeaskedi if you w~d recaU tin Q. Ir)o3you ecal any a~xh incidets? 7 narsa of any of -- uh-- Isoqt Speialties ostainew. A. Nc, mat in particular, hit it wa - A. Ch, yes. 'fWn ba hu m-atix there a long ture andI they 9 Q. Ard dndMr tint testimorny you indicated tiat sate sa of tins st in very bad shp. 10 there were twbatchesd of wsate that ymi nod a DoCr a~-11 any leaks thoug, orsills' 11 resffarcat-ion to a ant~cmer - A. I d~ct recal a spific in z, h~t I recall 22 A. 'at is true;yes. dsa2tan on 3ossm2duq at bares ard it looked to 13 0. -- to do sanrthing. me Like ,i'd bee otit of tins. 14 A. 7hat istrue. Q. If yami them, did yo.u db awthinr. is Q. Now cdi you reatlI tin rawe of that custaine? A. Ff~2' 16 A. Yea, oneof themwas -- uh-- OlTech -- I 0. Did you dD ac~thirzP. 17 beiiaye it wsa. A. 1b. 1hnt Is to di? 18 Q. And vkr wsa tien auzs of tin za,2mwratic - MWa were in a re~ a - and the whole 1.9 A. They bad --. u -- dxim ants exprbat" with mots plc- a goin to kme to ge clae p ev5eintliy. 20 with cato 14 and they bad put themt -- owlad them u=t Q. (lt tiw the shanen of cotainer fai 21 five-ga11- cars. NA they didn't p.9 enough famuIdvjd eli~psa1 at S. were Ia any otertia whil~e yo were 22 on and tin min dia~de started Wilding. And thes eupo~ at the Providn* LM~ity that wase =am 23 thing wrsat m to blcw tp weetzm zptmi for diMg . am Place? 24 Soth V sysa: What can I do? Ard I A. OEr 25 said: 7hee's a 1ast dispo1a carparvin tamt.

170 172 LMME DWR SBI= LVE VRE MMM smace So he -- he sent themt ar there. Stand by, please.

1he ctkzŽ am was -- ur-- vkkiat like to cal (Brif Pam) the Srt~a rýn Bay fiasco We had some expets cmie up ME~ VIECGAPFR On the Xeý at 1553. there iwn use za2ative rx to try to find cut if a Please proceed. fnme-ym2e extensur of the High P=-,ne (# xi qxUing) W~. SH4 :11d Like to hm Thdxiit Nj~zir 7 place in Flu of Mr. Vaen

M12EWIfl': -- of thm arnfallI o the W~. SHB4Vk: Q. W. Vadm, if yaou mfld t to the ag thy-t has tha mbm~ 31044 on it -- on that Ai he the effhb.ft emrirh so it waildi' t am back an the dD~eat. Yomi'1 finrd the pag aimbs on the hotan beach with high E. coli rwaiirs. righthand coner. Ad to do this theyput a lot of raiinsot*pe - (Brief p3e uh-le the witnem reviews &xomuts) taell, they himat in a M.D. and I don't know if he'd W'. SHD%.P- Q. If you o3,1 look at the bttani everbee araxd this sof before, but he I rightband c~e of the dxuzrmt.

ccrztamirgmtix a wide area. So all that juzk wa The very, very hottan. contanuated. it had to be removai. X. Ch. kid I -- I reammude it go c0± to this cwmpey, 0. And if youi arnfd fm= to pae444. and that's wk~ it went cut -- to Isotope Specialties. A. OW~s. W4. SfliMl: Q. Nd it went to Isotopes Q. 7hreea41s. A. Got it. A. It iwat to Isotqes -Vialties. Q. Amd db you see the first full patragah bagirrxM Q. Mie -- you asythe-- the- with the wod on "Jaimxy 10, 1961"? A. 'fat was before I got there. A. I sam that I I Q. We~ll, the wamse that you were rF * 9 to, uh-iat Q. And there's a refeemre in that pragraph to - ws-- were those ocem sediments or -- uh-- -ak~eccmtining liqlid.

173 175 JOIMU5R8KEMO SERVICE

1 A. kb; m~. th -- n~oidimz 85. Ito you eamthat> 2 flay wanted to use cesimz 137. And it cme A. Yes. 3 beifore a group of city/axrmty perPle in=UxbMz ffe. Ad11 Q. Aid that's tie lic.ide that yxi previciisly

4 said: Are you Cut of yawr rrdXd Mils et3~ lasts decibed as beiril coo~ant liqmd? 5 30 years. We don't want it around 30 - A. Yes. 6 Q. So they tockit--theyasexit t Iotop~es Q. tMtr kind of cnainera were tiose -- was that 7 Speialties? liciid contairmie in? 8 A. MW sent it 0±i there, the whole - the 4ole A. Paper-- or-- or wooden 9 cotaeixated -- they had barels AMlJ - Q. It was a I i clif d it it was in vora oxs A. Yeah, it was in wock boxes. 3.1 A. -- ofa~taidratied Q. were thos boxes IJ no in airy fadliaic? A. No2. 13 A. Pzoudm~a. Q. Wes it ume Sozild tlse lic4Ii? 14 0. Let's take a break A. Yea.

is A. Aid the othe mewet at u±tmaI aes with the Q. So vtm~it says liquidl waste, it wasnt -- it was 16 county, too. I was't with than then, bit I Primrarily solid; thee waswt a aoatire of l~iwi an it, is 17 lbey wee an AM hdipeeal lienem and they that coret 18 umeata to know bow to get rid of tie stuff. I told than A. Yes.

19 abat- them M 11=. I - uh 20 Q. let'stakea break. 7MENWfl: Aid the reason was that -

21 A. 7he I had to take care of it nmealf lat whsen M.YCK -- objection; asked and ansered.

22 I. 7HE PUTNES: -- tie varzmn-tbcraim eas groazd 23 MnE VnM3AM : We are off themcord at 1528. ip very finely, so it was )dnd of a ln.h type Sb f. 24 Okdrecss M~. WM Q. rid this -- did the contents of 25 ~ ~ r dWcLMRMRay. (Bmerj rady? the boxes leak cut?

174 3.76

1. A lbly whe they .r--edone up -t Phillips Ii M3EWMEMl: - - I do rec11 that. 2 u.nloaing the MW xkn a -- a fhak-bift Q. And whaet do you recal tine tŽha 4the side of WR. SKM'M: fran Roet &aw Fulton-) 4 Ocher than tb=. =.e ccrr~ -- ocher then that reoivari A. lb- -- they wee valves that led scra of 5 the 031teMS Of boxes remedird insi~ the %hat the sor of 6 radiation an then, bit I do not recll A- Mvxe was nthtl'z. ieW-x9 Cut of thaN. radation wee. 0. DD youxrec.U &Iy that -- those maer~ials wer facility? 9 Mtz.Sfll.A: :I fD&ibit 12 caild be placedi ~tto the Praiderria -- had bB~e Fra of W~t.Va:d-i, pleae. A. It was my inpressim that they wee MlEREPCRIR: Mr. MOM, I'll take "7" back andt defec~ive or ojper-used or wee mDlarjr cpenave. sem to the faclity for disposl? 12 I11.1 give you~ "12". Q. So they wee 13 71E WMEnS: ap A, 'flat iscorrect. Q. Do yaI reJ.l the volume of such valve that vexe 14 ME REPORFhR: :1an yu 15 Mrief p a L.m tha witnes review documet) 16 Wt. SHDVM: Q. Now, W~.Vade this documet A. Nb, I don't. Q. Do youI rea~ll the nunbe of container? 17 referne a ch posl co~z with Hi44s Aircraft. came in 55-galloni drur.. is 1b ycu se that? A. I believe they werercie? 19 A. I seetint. Q. Do you~ recall how~ mny drms 20 0. Do youi recal thea Pzouidenca L31ity recaiving A. Nb, I don't. ther w- only cne 22 Q. is it you r~1eooleci any type of waste frcn -re Aicrftdzr the tine that 22 yomcep~loyd at ti-a 532itY.1 shipnMt or -~ than one? A. I only recl I the one. 23 A. M, I o t those drums wee p]aef 24 Q.- Same questim for Dog]1a Aircrft. Do you Q. Do youi recal waem pla-i-- 25 recall-- A. tin-- theywereprcbaly

177 179 LAMETAH IWD= SMIC

%.;od 1 X. No. 1 No, I don't recall. it specifical.y, hit I out with thea cher dnrm an ti-a 2 Q. WUl, let Rie firýfl - 2 anss= they wer placed 3 A. Nb, I do Mt. 3 waste ýwd. XS-flr ti-e 4 Q. Ckay. 4 Now ptuiraikly y-1 descibe 5 let tie ask the question, jutt so the recod's 5 rex4± -- receipt of waste fron Ridifield Oal khraim 6 r!1 . 6 lb you recl I that tesinoony? 7 lbo you recal thea Pzoimmenia fac~ity -~VirU 7 A. I clsria vkatl (sic) that 8 mny usse hra Dzlbx s Aift during ti-e tune YM er 8 Q. eivirg waste fran Richfield Anahim 9 there? 9 had 10 A. lb, I dono. 10 X. lb. 31 Q). Woufld Fu~ hav.e bee made ooze of the sore of 11 Q. -- UiX B- 32 all wsse received at tha Pzmaenia L-lity durir tha 12 A. kl, I didn't sy that. 13 ture you1 wer sypbayd, th-1. 13 1 said that I heard that they bad a prchaw with like to figure cut som 14 A. 'flu w- a notecc recoding -- it -- that had 14 omtaiuxatef oil that they wculd 15 xeoxir~ in it abor wast ti-at h-ad been received ove 15 way to dice of. So I ametef cetain cheadca" fo 16 previous tinre Q=' I wa~ there. 16 adirb±ficatim. B& thea -thy felt men a ItteI bit 17 Q. Dxr thea tine you wee there, v,.eld 17 hlig. 18 Personally am eimy ship== ti-at -iivei at thea facility? is And that's ti-e last I head of that sifltku.tc 19 A. Mt is - I. 19 Q. lb u recal arry irstarx in whic mt~e 20 Q. kA- yw~ iwiozm peesoca3y inspect each sh#iput? 20 material. f=rau difield Oil. khnaixm wa reaie at ti-e 21 A. flat is ~ 21 Pzamideca facility? 22 Q. kit do you recall d~rug ti-e ti- y-~ were theree 22 A. lb, I dono. 23 receiving mny waste at ti-a PrmtAmiir hb3ity fram the 23 Q. lb yu recall any insances in wichi ~ fran 24 Thmsdil lab twy umn received at thea Providerica 25 A. Yes, -- 25 faclity?

178 178lAO I

A. I don, t eje recll ss~l hea~ring of Uist 1 A. Yes; that is tnle. rm bfore toda. 2 Q. Mtat types of waste waild -- wal e involved in I_ Do ya rcl I the rares cy- any of the other 3 those instance? conxnus fro wkrz waste was xece-ved at the PruJ2fr-a 4 A. Basically it w.as -- uh -- w'aste like the spen 5 stnsrrman in fromi radiio~*rs. We- m~yod those 6 fromi thesh~ields and put them in cL= cin ctau-es uri1

Time wee -- as a clear, a lot of them waer 7 wegot sifficient waste in there to masks a barrel loa. radoraphrs serduxhig bak prr. sanx~e that we had sold 8 X~tEsr ncanoe, the dupnmt from the to them. 9 Air Fore~ -- they were not peddagsi at all -- wr Specialty ampzVy Q. And they wee ssdi_ t~rrm spar sa~es back to 10 eve-nlly ped-ajsi by Isotoes 311 Q- flvre were, in fact, shipmnts received from the A. For d~iSol, yie. 12 Air Force at the Prnjiri facility)? 13 A. Fromthe Air Ftre,ye.

W4.S@ý: If Ddnihi 18 coul be p2wý 14 0. lb you recll %hattype of material that, was? 15 A. It was basically miaterial that had bee' USed in 16 the flying recos downiin the Tens arm and ..~ of it aief pame whl the witrg renaew &xinat) 17 consisted of rasixo activated waste. M. &M*M: Q. Wk.Vae, if you mi~3d look at 1s 0. And in what type of crztaine wee those received the third paragrap on the firm page of that dlruuZ. 19 f3= the Air Fohe7n Do y~use tat 20 A. flsy were rnt in acrrainxa. Miat was the A. Yes. 21 problem to padog it Q. it begins, -Ie waste ~ ae" 22 Tli-i cota ct sard they had Do you se that paxragrph 23 acoxdir to shipenm1 of radioactive waste an D I sethat. 24 reqLat~icns, and they came tp with their own trxuis, If you could read that 1 9 ;1 to yuraelf. 25 Air Force tx k, and it wasna't padcagedi at all.

181 183

1 A. I'm dingthat rxw. 1 Q. V1=~ did this mraterial lock like? 2 Rures nnplies) 2 A.~ Inis what? 3 MlE WrflM: I've rea the third I g Iit 3 * a~t did tke miaterial look like? 4 ML. SMThM 0. Is tiat an aca5 descriptio 4 A. it wasaavariety of sbff like hig -- uh- of how acas to the waste storg areaws c=1xolai?7 Ita that you naild pu~t JP-4 jet fueil thra,# and boal A. Mistis tni. meatal boxe. This is the to4oiet metal you ca thixkt of. 7 Q. 'lt' all I have with that &xurrat. And I don't )x what they' had onairun, but If yo -fled look at Efth~ 21, p]ese 8 they iz 13) chkesd , very heaW. We had to use diamoid 9 akpoterI Idinvmw to witnes) 9 -m to cut tns ad=x up. kid they were weesnzg cut 10 Wie pae whil the wimms reies ocwt 10 hi~ like you noj1d't believe. Talk ahi nctrinsy U1 MLRSM4D9 Q. Now thes are those draft 311 Q. Ail what did yýi do with all of that material 12 lett that you were previnaly naskeSam glsions 12 onc - 13 ~abo. 13 A. Put them in barrels and lap them in tin cown. 14 no you kno whether I eSoodualti ever 14 Q. kni were those among the karreis that wee stoe is receivaf firai versions of flare letters? is in the w.estt area? 16 A. I dirmt. 16 A. M33's zigbt. 'fl~re the ones that wnet down to 17 Q. so Youi have~ P-3jno u )-edg as to nintbe 17 the barge and riýt on cut. 12 they wee eve sent, is that tone 18 Q. *at is raitrn acivaed~ material made of? 19 A. Nb, I do mt. I do no =. 19 A. Matisuwhat? 20 0. 'rt' all. I have for thos. 20 Q. *at is netitnn activatedl maternal made of? 21 21 A. Tli -- well, the asic principles of i 22 KZ- 9{lWIL- Q. Men waste was received at the 22 23 Pr~aneia faclty in= amtam, were there ever any 23 Oki ixtealptitn) 24 omm in hic heOn e was treated in tsashrn 4' 24 1WWDS:'fihn uic prinnple of r 25 25 qperadmr is to hire u~nqh -- tin -- e-wichar nmnit

tinin 184 IMYdTVXE W 182 1 =gte that the fl=D of rn.tr=x start a caen recin A. It uxart inno the barrels in the back, myfrete 2 Amting rear that chain reaczic, 9.1±1 as a -raco or in, and cbkn the cx..

3 =h.-u bc~~ they wer flying all ovrthe plac -- if ='s Q. k-d ta was mart of the oca dipoa - 4 -1 pmotr-y, then mzx= will' armt.avat it. Myyvr: A. Yes, --r. 5 mak tie oastiaxg atars actave in tie material. 6 kid tint's ho you make iociascutcps. YcL take A. Yes, sir. 7 a piece oif ocr ordinary coblt mretal 59 an ai ,-dw 8 the rea . Itt )dds It ip to rd1t 60. It cns ~r 9 raioacive -- the half life of 5.3 ye~s And the hanif used the prasen speri-I unem r aterial. 10 life is tbL length of time it takes for half of the ~kat doe tha= MWL 3.1 acivity to take aay. A. Spei~a" iiiti~ar maerrial is unainun 235, 12 W4. 9040k: Q. blowwh&ile ýii were with ccxrry p),xm~iun. any isotope of plmraiimn uzainmn 233 o ry 13 health you recl a instane in utui± w.aste fro an othe sibsani enrichd in wiy of the ab,.ie. 14 e~q~eimnts at High P~mirne (pi~rtic splling) n TfalJ I %as Q. Mms are all flicremrb] material?

15 ta~es to the Pzr~dmxa~a faclity? A. Ya.2 -m to kno ad±Py rw, material? 16 A. 7hat is ~ Q. 2b. 17 Q. Dyo know whehe it was acuilly received at Are thos fissioanble materials? A. Yes, they are. 1.9 A. Yes, it was. Matntypeof - 20 Q. Aidwas that frantth City or the Qxrityof Are you faduiar with the type of activities that 21 Ins Axr1l? wee con1zte by Resarc Cntmcel &zir tie time - 22 A. itmks the city. A. Yes, sir, I am. 23 Q. Ard cb yo recal in what type of ca~rar mmtha Q. -- dmnLrU the time yo were at Prar,4mra? 24 msterjal wesreceived? A. Yes, sir, I am 25 A. in55 a dau~s. Q. Vtut type of acivities wee rcrdrtaii by

187 -MWr IWMMSRVICE

1 Q. Aid it=n was thenatutre of tie radioacive 1 Pimarc Chmicl? 2 material that c~rrmx=.ed tint material? 2 A. 'flu 3 A. Sm-A mainly. 3 W'. EFO: ~Eame me. 4 Q. Mat was tin raiatv material in it? 4 Ca I objec to his gaestion for fcxzdtimr - 5 A. P-dim85 was sifl M n it -- the tý tin p-riu qntion?

6 carief intamrzWticn) ME MIEflS: I - 7 ME WMES: FA~iT M-1.S{ThWY. Q. Go an. 8 It was sipmIPA o it by tin peso wmha the 8 A. 'fin cptkim at -- at tint division was to 9 lcng-hlodled tun~ and wsa~poeefy pod them in the 9 reio.e va1wleh a ~eairths fran ore that are nciunlly 10 tmatk. hit he un geting it all o.w tin place. 10 I eas in t-a gmlit-i , and ti1 things are like includ~ tiensand and tiese earrels whc was arard tie 21 bfiumn and izidiiu and all tiese things tint cot spcala 3.2 thingr for shielding pe to keep - and evn so the 12 electuon t3e inim . 13 ac in thn vicinity - their dommntar went off sqml 13 kid in doing so tiny cae acos and bne to 14 7hat's udiy I call tin whle thingr a fi. 14 take cae of to carbim thoizn whiich is radicacre, is 15 tiornn 232 and reja lumznx whichi s zaimctcive, 238. 16 were recemwd at tin Pxrmawa. facility tiat cor~aires 16 So it was low level sanxnu nuterial. 17 A. Igzdnmewoy five, I believe. 17 so ore wer 1m 1 by is I keno it was tiere hý I dlispse of it 19 after I gtnthee. 19 A. Yes, air, on a pilot plan imia. 20 Q. Whei do ym menyoidipcen of it? 20 Q kAid did yui v smawm rsol involvemen with 21 A. I -- it was o site iwheI amixed at P~videnca 21 so= of th activities at Aemc Omnrdl? 22 onera.and I was reAjxied to ge rid of it mysvelf. I'm 22 A. He agplim them withi zbatiax from 23 the one th it go tbare, and then I bad to ge 23 1mas Servicee - Seviow bnae= timse things axe 24 rid of t 24 madlocai-ve -- daal and tin ca b in-voted arit as oh, A.U did it go? 25 imid ben a haezv mptl type tzzdc, tltyze also toxic

I= WDEIWOMMERVIC 188 LAKMKIE RMR EVICE I

3. in their c~ right, plus t.h f-c that t0"Ier Prontv tO 2 ou wall2 or thw!- side of the plant pocrrially expose A. That is care, Q. Do you hame an esinaet as to whaat pruffag of 3 tkhin to cpeat~i.or w. cur side, so we nr'.iztcre tht aree, daspoeai in 4 too. the wastes that wee disposed of a-- se ee 5 Q. lb yo pecsraly rmiutore the Researc Cici thir origial craitAeaz, 6 side? A. In tka original ar-Lners, did you s~y? 7 A. That is cw=e. Q. Yes. only waste that we 8 Q. 'lb your xnowlet did the Research Chemica A. I waald guaes pmrabab1y the 9 cpeatatJ2s geerte ay w.aste naterda17 packaged in 55-g2alln drms uiii-le 1 w'as there %s Ai~xe to am - 10 A. Yes. in those oarainers. A lo of the material cut wor in ti-ar 11 ke got r-,: of the thŽorain aid the uawiun th= now I, m talking -- the aim in the pit up to Idaho PFtls and the orns in the 12 waes a -- to then a tate pFcb fran their rare earth original conatainers back Wiiduir we tipie in the kracs in thirn cr~alau

14 Q. Ard vf ws o with that usist matenal? is A. Sha wstea TDt oL of it, ýmiay An I c2l to you an that? back tie last 16 Q. Mtat wa &xae with it? MR SlHISM: If youi auldArad 17 A. It was "sati 3lik arry othe0 r diomive e 18 that we had on the propety. It wet with th arrzels ard Macld read) ahsasion Off ti-a reaxrd

20 Wrief pa MiE WTUIMS: So 1 9. Wkst I'm trying to sy 21 W.. GW M Q. art fran the dfsaairbly of is thaut -- uh-- we ad to repackag all the old aistarex 22 use soarce that tne ccqazy wald recive fran its waste 0±r there, and that was 90 1an of the w.aste ai 23 aistomers, wee t any other ways in which the caqny~ hand ~wtI arrived. Q. Prd it was repackage into 24 trated porI waste reoeived fran its aistoazs7a MR. SlHDVI: 25 A- No, we rm- re~xe any wast that ws -

189 191 IM 7*M REM= SM71CE

c :min the ccianr it was axuidezd to be too 1 A. Yes. cdmzeaztu a practice, and the e==nc xe=3u wee not 2 Q. Do 3.0. irJ.l who waild hi-me beenmos 3 1aEWu1aei-fla1 at Istma Sp~alt-iu v'&iiUs yo. vaMe theree Q. Cbs aziixg theu ortsarnm thamt wee disposed at 4 with oistarer cotracs? ses. in 3-961, Wae Motof thos container -- :1 of thos 5 wastes dimse of _ the angina ooainrms that tbWm 6 Q. Vb therae 9malm at the-axn3mW thatws owe in whan theyunn received at -- uh -- the Frodnria reqxxmible for sasles facility? A. I -- I ellt thatt they bad maxein -1 X. Yes, allcf those, asfar asI Unow. 9 f=-- uh -- ta~ge radi)axlide likem for medical use, Q. D:> yaa zecl a intnerW n whiida -- uh -- any 10 hit ti-my Ieato be sasluman type and were alesys hxjing of ti-ose oztairam frc oastar bad to be repckgdi nM to all~ tiem to carry a vial with smei ~acl rosteria prior to disposing "- in the oomv 12 in at, whichdI would rio let themano. in -- I said: Just AX We did reakg a lot of tie waste that was - 13 tell thi-n it looks like this. Mw ayn~'t tell aijthing the old w~aste that wasci hand duk I arrive. Same of 14 dtffeat whether it's radioacive not. ti-u wee in very po orrainars, so we pit ti-em in the 15 larzeI . 16 M.R.SRD49P. I don' t think I hame arry otheru Q. Do )cu~f duktber that was waste received 1'? gistn for you,1 air. Mirk you from austa1er? 19 A- Yes. TEE VIC0RM: We are off the I~at 1621. Q. Do youx rearll - 20 hijef reces) Of thewat that tas chb e of at se in 1961, MlE VIDSMO: I'm going to go ahea and howsmaia of ti-ut was, if you can xeal 3, vas Ir~ at 22 9m tmape rxw. We're zeal d3 to the end of this

the fa.lity at th *i you rived in 35%9? 23 tape, unleass you. think yaw questic=3 win. be Ixx see A. I waaldetiae 90 1 of it. miits- eitbi winate, sir. Q. Nd the balarne a reoeveor u ta~~dil 25 ML ERC: It umy be.

190 192 IAKE 7AHM REFCF=PG SEWIM

A. 1 'EVMM=APfl: It Rey be. faclty is Isotopes Speialties?

2 Let's TSgo to thea-, t~d, SIXI I'!-' let youl A. Yes, I uxkstcod it was Itss aSpeialties. 3 )ac a a1uple of Ttfl-xa before its over. Q. And iot Research chemcals? 4 A. M-at'sr right. 5 Q. Cky. 6 You~ earlier testified that saye of the wastes 7 MlE V=AM1M: We are on the recod at 1622. fran Researchi Chmcas was disposed of at sea by yo.a. 8 Pleas procee. A- Yes. 9 EXIONMCN BY' W. ERCg: Q. Un -- what kind of waste was this? 10 w. Mr. vad=. as I told yoca earli-,, ny rnwe is A. So naterisi. 3.1 arym Bron, ard --represe cro of the taferrbns. 322 Iamc-F21aem. I'a xgoi to kee this really brief. ;L Ikadixrn and tkhiixn. 13 Ddyu-- wve c ee aip2yed hy Resasrch Q. kid that's it? 14 A. 1hat's it. 15 Q. Nhat pecoage of waste disposed atam naie 16 0. ~eardai 37MTWc15. 17 X. ND, sir. A. I waild 9. al-, a barrel. evey sixtnrrtl. 1s Di~d Fdi Chemicals qsate se~azately fann Q. So thmereas - 19 T~ Spcallti A. Let me exlain. 20 )L Yes, sir. 7hy hadhir own IsJin fr= AEC. OOd he 21 Q. rb youI 1aje mx' perscn kmwle~ of the w'aste wee a licersse al.so. 22 hwf= piroc es; used by Research Chacas? 23 A. Yes, I was familiar with thaei pperation. Soa harrel six -- six mxrhs- 24 Q. How wee ýai famliar? Wirtwas the hem of I neai, of the nine hunr&,e and s3e m ~eJl that 25 Yo- fanlia-t- wer dispsed of at ams, abou approdnutely utat

193 195 LNM M*IM REFCFMM SERVICE

i

A. it was a rae eath e~ract prcs, a I . ge of tle waste in those bewrels owe from Reeac chmialwt prodie It was very ommma. Be=V a cheica engineer I bad no proble urdertarxir~g that. A. I ckn't know what they pit at in the pile in the Q. Ckiry. pastct there, b& w-dle I was there they only made a Thra#± this depsitim ID=)el has referred bare] alD*- every few norths. It was no big operation. to tin Pxatyoi~a facility. Q. kid aut of a aixc-arrth period you sid a barrel Is it you urimsazrjh tat this Ptrvdeii~a every six srI ? facility rFa to Spec~ialties? A. somebirg blal that.

A. .eer to Is±ot !atis Q. How narny etari every six Irxtha from 7hlat's %ta= it wa ca.1sf whe I wa tbere. IceS emis3Zie -- Or frCn OMtCM! of If~t~ Pn. riot to Resarc Chemicals? A. Not V*it? A. Ch, I 9gess ten or twelve naw4be. Q. Not to Resad, aHE.cJ.s? A. I'd roe beard of that azzpny Iaoe Nd wias an of tie wasta from Reserch Chemcal 0. YouI had tesifiFA earlier that Resarch Ondcals dispse of in any othe ny?

ws- Ut-a Fesarc -- yui have rove boad of A. 0-sticn agin? Reeac Cheicas Q. 7fle wase from Reserch Chemical -- wa it Sti that. dispose of in an obeIway?~ X. I'm awy. I didnt uiersand you. I tkrs4±t A. NotthatI knowof, ro. yo gve, a differert rnme. Q. 0csy. Q. No. M. H: Ard that's all I hrve. let ire repet the q~etin. 'Tflmvibo this dexasizi the rest of the M. M:'fI=: I'm g~irs to bave aba 40 urv*a± attomy here have zFerI to the Prmddw=a faciity. of 9qesaor. No it your unzmsariM that the Pzmddwk~ia MEWME: Youi dm't get to go mazd agin,

194 196 LMM MVM JWCRrMG SERVICE I= MU R!= SERICE I

1 do ya? 1 thre diffa t d~,i- points or, ea. scale . Ands mw are rniltip.as off 2 w'. mj=ZIH Yes, ue d 2 of them hae thre to fcu satala, vk-ndh 3 3 eac other. So it vaMrn21 ft= scnewhee L~ike w~r i to possibly as nm. as 4 P'S. Mij=3: We get =o = arct-5 = we'r 4 .002 milrioUxj~ai all the th type of 5 re, *,rdfcentietly, but I III tor to be as fast as I car 5 2,00DOO nlixcepwn pe hou depedent q.x. 6 'MEiV=MkuM~A: S.'***d ie gc ff=- 6 Geiger carztat mwxacan~ai. 7 7 Q. Do youi recl th type of Gege c~e dth- was a W. WE=I: yes, P) jusat ic a S1!ta 8 use at the Prujide.a pr~pty?' 9 9 A. No, I do mt. We had at l.east 25 different 10 MEV GAPE:W are off d at 1C26. 10 sty3.as of Geige a,.zts. 12 wrie recess) 1:1 Q. Di -- I shei yco a. Didibit earliat- toay that 12 12 listdth type of eipe~nM . 13 13 A. Yes. 14 14 Q. Do youi recal vkmdtk that Exhibit Jiarifi-i 15 16 MfE V1COAR: Onthd eam at 1E2. 16 A. No, I cDaildn! t recl atkrter dhat twasth r*w 17 1his begins t~ap 3 of the ftosti- k~r (sic) 17 use ove there. 18 19 M'. PtI0fl: W131, let ne p.LU dafdibiti.h 19 Please 1 ar, I 20 9IEDM E4MN.2 BY 16. RSEIM: 20 7hit willbe faast . 21 21 Can yo -- 1±1 -- return to the witns Wrhi 1,

22 dwmi~sicnii3 of the proety. 22 spetifioally pae296? 23 Ma dcr~mdmammu o==ra at Min Rweet, bdd 23 ahwxrter anplies) Ch, I I him theinle1 24 you take any actia sil or swpes tha got rn 24 MEl' M. IE: 25 the laboatory -- that wee tested ina 1~b==rry 25 Exhiibit.

197 199 INE MfE ]UMMU MRVItE

A. No. 1 Q. Was the =T~p.ix of the ==!te and the soil. at 2 Q. Mrk. Vae, a you look at doauent 296.) that failityr limite to the Geige axX13at? 3 A. I'm lookij at doozrsrt 296. A. Yes, it Mo. 4 Q. krd are aqrof the ita spacfiFAz on this pg Q. when yo take a wipe eample, do you dset 5 aMztas? r~ ap-- uh-- aii- cwater~ to te mi~awh rn 6 Yes, dae firs item is, CH survey ueat , asyo see that wipe saple .exed a certain I2T -rno .7 A- Yes, bat in soil -- in a wipete .oyadput it 8 I din't knowr why they on~ly got ne ayailabl. into ku-4 of a a,.ter rdat can cr%= hv+ bta-gMe ard 9 'flat's -- they just put &i~awthe minimLmn here. alpha sq-ately. 10 0. Uxk Ssi~ti~vity I~Rw, b4ate it has 0.2 to 2 - Q. You iribzyets tha 4i~iil at Spe~jqtiaA A. 20 -- dhat's 20. 32 there uss a IM that I I the reaj].ts cif wipe eample 0. 021Y. Did I uncarsan Yo occrec1r7 13 Arid dt'~s - A. Thlat isa± 14 What dosthe or stand f= agin2 I'm s~ry. Q. ksil who was in 1argeof p tti± pxtant is A- It'a .2 millirorietra to 20 willixoutjaw per dhat 1c9? 16 bmw -- is %atit sw hee. A. It %asqfVr espnib~ility. 17 Q. O00Y. M.day. is So it azmikit d~ea arv)ýhizide .2 o 1b you kc who the health pbyaao e off was 19 apythirg abmm 20 mill~izoermtpe, is dtmtoret aftra )m' dqmted the facdity in 19Q2. 20 A. 7ba's ~. A. 1b, I ont 21 Q. Nware dane y other Geii o.axrm *b are Q. Do you kiro at tht 1emel the camte is 22 idetified on this d=MMt?

ml 3beted -- wasmlihwfi at the time ym '*kv at the 23 A. Th -- rio patio~1srly Gei~ ocoes hr-ar facility? axe ion, uintelw sur' m!axs. Mxm are ditfaxetstk A. 'The r-ii -- *ý are alvams -01you at waters daot id lsamease gaxi an eta

LVEMONWE 19R 200

______1. I

1 A. Mirm-e Pe IL I Q. or. vou. tell u~s which ones tlrase aLr 2 Q. O-Y. 2 A. We]. y-7' start wath the second am. im. -- naibt 3 Is that urellet than a firocurie 3 s..mve ra . Yto a it says it dmecs curr 4 A. It is a cortrati2m; no a pysical affDXL 4 0. Ow. 5 Q. am~ you rexlain for us n2m-pyi s what that 6 mnse? 6 A. -6 = ay -- the am nod by' MCZ-- 40 detec 7 A. So mx radioactive particles per ~volume of air. 7 the alpha-beta anam &--j beta-gnam. 8 It's like sasyix there are twety dus part~icles 6 avear. iow -- -e have alphan trte It says 9 in this cup full. of air distuxse in there versus asYM13 9 alpha, bea-gna smisitime also. 10 there'sa five -- uh -- five ounm or five grame or 10 h. wehave arms natois. are not Geiger 11 Ccrzezs. 12 Q. Would thisreflectthie mwof -- u--od 12 Let's se. 13 radioactive iraterial? 13 'lT='s -- tint's ahir the size of the 14 A. W-11, this is an old starird used, I think, by' 14 detecitfl-dvaeretd type which inczuck Gage amteiz s. 15 EPA for -- uh-- ndnimmn detabt-e titiiu in air o 15 Q. itat did era nuInitor do? 16 smedatiig like that. 16 A. 'fin arm nonitor are those in tin facility tint 17 Q E tie eqidpi~e:t thnt's ideti~faie on these two 17 are nrnxtf or. tin wanls andi at varic.n locemns to 1s which paem of wgiiprnu did ýKu use to tes the 18 nonitor thn .athet raiation in tiat aras. 19 integrity of thecntai~aners that were received at tin 19 Q. kid dosineter~s? 20 facility by acutsaers? 20 A. ms axe tin thirge tint - l ittle dibr~ tiat 21 A. 'flve types of fer~LEL~y held ioni dvmer~s are noc 21 tie -d wh*il~e tin' e WM3013. Arid tiey EIC lck~ 22 used to tes axtairnrs for #*,si.j. 1eaks] of raxai~ve 22 through themn &-e se a smle in tiere tiat tellI tiem the 23 nateriai or anyothr nuterial orliquid. flhj are ineato 23 anount of radititon tiat they're gzirz, at mpar nrticular 24 test-- q=e -- leakage--unquote--of waves of 24 poirt in tine -- how nuch thyve receved thtdy. 25 radiastion cmag throug the side. 25 kd they're 9Xponed to do tint, too, bam if

203 1ABE TWE FZ= SOMCE +

1 Q. I uimstand that. tiey cgert =ti radiation tiny're apsedt to tall thiri 2 x. lCay. aupervts: 1w're gtiirx mpseraa Inte. kid the 3 Wen, tiat a9nrviatr 2ccim into it to Me wht t-x prcblsm s 4 Q. Dlbyou use them Vtx of O*Apnar1 to figr OX Q. ck~ainyou u to thenexat pagead tell in etr 5 vkgtbnor n0t any of tin mintaiersr vare emitting wave of army of tin ir specified an tiat paeare Gmier 6 radiaticm) 7 A. frnt is ~ A. lb. tbny'e -- them~' Is - iii - 8 Q. 00eY. W1,~ll no, there's no Gei~ onr~er there. but 9 And whkich of these piaa of egiipnant did you thein Ia In such as tin Iaemm - uh- and tin 10 use to check thn containers when tiny arrived fran Virorn rachici de are dnr gI u ha a ni be p3acm at a~r' Irnatofmanard tiey tdill dee -- iii 32 A. AVy ca--- arny instaient tint wdfl read zore 9=m mmadiait and so fith as it o~t at tint site. 13 teno 200 aifliromans~ pe ha beas tiat is thn 0. And tin -- Vh-- deignation ahe thn woo 14 81rf lindt b,' DOT. If it's higher than tint, you cant -tritirzu in tin thurd atxmi amr, can yo te3lli whant 35 shpit. that abbomdatian stands for? Slb we re talking im 4 1n basicafy v A. You're on what pag? 16 17 tian Geiger coi ter. Q. 'nur saepg, right abov thn word -t=Wix, 18 Q. And teion I~ 'H~aic.u2 hme banti far einple. ubere it say, like, 10-5- - 1-9 tin LwIee A. 5k-U thetne of thn ;ag, PIw. 20 Q. Mml rm pag. It is 297. 0. day. Ok pm -&mdl tewin nes rreae dcxmM) 21 Mliich ws it? M'. k1jfl: Q. At tin tcp. 22 23 A. It wculA be- uh- A. Chi. dwa. Ckray. Let's am. QGreat. 24 to revim document) Marstin "=ft11" stn for? Oklef pm wijile tin

______A. I

1 MfE WrnS: For irstawc, that Jc.3ar, A-5St. 1 Q. were their d-jrs :f that type of waste in - 2 whih is, I 9s, about the third oam&7.. 2 A. Mi-re we sam b= it had s z. a short half 3 WS. W'tXE=: Q. Is that iat y recl I us;-_ 3 lifee that the engy was gone bafore we evr di of 4 to test the cm-xws for - 4 it. 5 A. ND, I don' t recal ich one I d used. 5 7hat' as arnhr ce of those replao1able sourcs. 6 Q. F=, the waste ctainers that were cn the 6 Q. If there had h . energy emttixn fro those .7 .7 pnoperty whe you first arived at Provicia, didyo barrels, would it have - 8 8 prargx1ly eer take ane of these Geiger axzntrs and You say it g o --itl it st . MM it stops 9 asTple to sae u,•her there were waves amr_ frm the 9 does it disappesi A. Basically. 10 c~rainer?. 10 31 A. Ni, I did not. 11 7,retKically -- it really rver stops 12 0. Ckay. 12 thoetically, bit a ly there's a practical limit to 13 Mw d you have a inrsein dMs 13 14 A. ChQadl engineerig. 14 Q. Ho does rne)mw whn it has stoppea 15 Q. 0sy. 15 16 A. I also have an A.B. degree ad vajcr in both 16 A- Well, thre' s a little bhlom that appears an the 17 d stry ad biog bore that. 17 ausi• of the shield if i4 doei' t get -- get any furthe 18 Q. Okay. 18 cut. It's called a bo It ii--- side-ay 19 if a wive of radiati is erritted fr•n a 19 disspatas into the struue of the ,terial. 20 ccnta.n,• and that crztainer is sitting an .e, does 20 Q. Well, when yo sd a wode rcz cn top of 21 the emmt adiation. ham the p iai to bni to the 21 aspalt, would you have lm any shield near that? 22 caxxete? 22 A. NMt -- rot really. 23 23 It's a vey ligh ield, hi anything will "24 Q. ckW. 24 shiIld radiatian. It's jT's - 25 Mit hapen to that arittad xadiatimn? 25 Again, it J I ' an the energy, as I say. You

205 207 IAX M:HMEIWRTN SERVICE NMIAM••E IWCRrINM SERICE

1 k. It evatially hits maxzj atcm and the t is 1 ca put this out in fui of an alpha sa and you're 2 trý- 3to paw thramh, tha it stop mnxiM almo. 2 safe fr- being hit by a alha particle. becuse it's a 3 Q. Oay. 3 big, heavy, saki-_ng p-,t . Bit a gmm ray with a 4 Are does it go uben you have conrete or 4 lit of energy behind it can go thrugh a mile of that 5 asphaln that's porcus? 5 6 A- It gos as long as it still has energy, and 4mn 6 S. would you - 7 that's disipated it stops. 7 MR.SWMb hle r Isdhould indicate tha the 8 0. Cay. 8 wite is hbolizu Wpa s e o f . 9 How l dos it take that enrgy to stop? 9 MS.MJE=•: M33k yOU. 10 A. Iqlma j o-nathe size of energ to start with. 10 Q. yoiui had 9- rays srittin fran barrels, 31 Q. Ckay. 11 for ameple, is it irnrvale they wouild have penerated 22 A. Very hard energ will go thrt uh nary i2nds of 12 the co te or aspalt? 13 lead aore it stos. Ligt aegy will stop within ane 13 A. It I• how thick that asphaltrorte 14 mil.iimater of the lead. 14 is. 15 Q. Cay. 15 Q. I rzmd. 16 Fbr th tyes of alpha rays tha wre a 16 rief intemprzx) 17 frus polmixi for amnple, - 17 MS. NUOMR: 0. fb you have any )Iol e about 18 A. Alpha rays are not r'&ut we call penetating 18 how cm- -- bow thick the conee or asla3Zt ms in the 19 radiatiuL 'fry will not even. go through the laye of yaw~ 19 waste stcru, a - 20 sidn. 20 A. No,- 21 Q. Flr the type of 9mee rays that re eitted from 21 Q. -- at Pzmt=hia? 22 the typs of radiation in containrs - 22 A- No, I don't. 23 A. Sme of thn were -- like antinry 127 is so 23 Q. Now is it a0= that the caly decamiordrrj 24 pmorful -- it's the one that can hit really -- mxre 1od 24 tha You eve s rvisd eroally aat th Wain Stmeat 25 a neu.rm cut. jus -- alnba like a re r. 25 fadflty

206 208 LMADE REP C:rl' SERVICE

-I

I / r

I A. 140. 2 Q. So &ranr tne ta=e y>u wnxcd for the AM, Q. -- an behalf of - A. it. 3 yva did not persnrm!ay sp•r•-g any aditiasal 0. OWy. 4 was the wste tiat was gmnrated at Isotop 5 A. Nb, I didn. the waste 6 0. Ckay. wtile you were there handled differatly than 7 If the AMC M to pzcply trminate a that was received from custanrs in tern of its packaging and strzage 8 licnse, you wazdi',t ave amy iea aneay -r the otr if A- Not 41ile I was them. 9 that, in fac, happed, wtuld yi? 0. OMay. 10 A. No, I waiad mc. no you haenV knowlede as to wether pi= to 31 Q. 0ky. in the 32 Ud if the Ar failed to aczaUly cornduc a the tie yo cane there the waste thit was gerattd differaetly than the waste that tas 13 survey before a lIcen tiws t adret& you would not have cperatiam was handled 14 ane -- my idea ane um.- r the cthl .f that hapapnd? receivd ftam ostalas? 15 A. Nt, rot unies -- not unless I tes involved A. No. 16 Q. You knve m knowlee? I have m knowled. 17 o. aigz. A. txmt ts-e 18 But you e aoly imalved in ane? H.ow, ummy t-s did you persnally 19 A. Yes, tim Inte Soialti .. ky ,es of a picukp tndc fan autrmers? tink it wtssaybe 20 Q. W•en you ad W. Gldtendisnmso 1our . Ch, it wasn't too oftU. I g cut and 21 deaU7mssiani the praty, did Im aproant y or did e aryn ar three marhs I'd he -alld upon, to 22 you anoc hi-1 g a ccxp1 of barrels r sant•hig. at tin facility did tn fbacility 23 A. It am-e up - tine generl weamt-ian between Q. tile you -e n t any wod be s froam astars? 24 theitw. I-- itasta -- asfr asIknow, a 25 plami -- other tha s to say -- di -- I will ke A. I can't recall mny.

209 211 LAKE MWE PEFa= S9MCE IAKE 7l ]WORMI3 &ICE

available fit a li"tl 1axer in the ent that you're Q. Lo you konw whe r the AB Sun it was plmxdm an n amanr and y- need som elip -- just ocAntixxi its inspections, its pmrodic qarterly u decib, take Gaigewr artA asples scnethin like tint. i spectins that 0. Gkay. of t restricted waste statr ares? Did it surpms ym ta Mr. Goldein returned A. No, I don't believe they evr - hi I to the facilit whenm bad •ot b thre for perdiod Well, thny dint' t evw take amy saNpls, of time? don't believe tin evaer tok amy radiati rading either. 0. Is- A.L Uh - taell, I di&Vt e; it, bit I didn't vrasus tadia.im ntt being Involv in t•i ht en of anything I -- I So wthn you say amples wasn't -- yia know -- I didn't think to mnh of it. redig, are you-- it -- diotintuxpbetena wipie Q. Andt was y•_ nzundtairadn as to why saml aan Wtigr omir- - mW. Gldstein ws involved in the anudsiadzn of the A. Yes; that is tone. Q- Is it acriaate to say drat the PWs primay

A. I didn't uxk~mtd oirar tt hi was fmns was an the safety of nglajew and the levels of involved in the - in the dw--m-ii nirg. I was izrx eapurt for tIree esple as qoroed to whethercr- riot the in•ssim he wan baznd it back f m type of any diatiun lbad contaiute the concete or soil bwnkth aumriual p and - uh the Concree? And en -w talUked i said thit -- I said: Oh, A. I tbirk that's generally a trie st.ate'. youmre goig to it -- or sanlhiz like thit. He Of canme, tiny were also prinarily intersted said: I just S it back to g the olmmers -- ar tht Nmtarl at the facility in the restricted area did facility nd get into the WhtMr -- SM003il like this. Sget away from the Q. Did he - uznestritted area, fr istanc, in tie -- in thi hoaue A. And tb•'s wen thi de,-,-ai- nirg cnvm up. nr ti site, too. 7hty wre proteti tin geinl Q. Did n e•e r to ou> a bei as repanikale ftr taing care of the dmUtds~iadzg Q. But an lag as tin mate stayed in tin reW=5te

210 212 IAVE M•rE FWCF= SWIMC IM A WillHM rIN -DcM= 1 a , the AEB did not focus or nose areas? that ya did no take wipe splaes in tin ack bhilduxg 2 A. N:. wheme the waste storae amd the pit was locate 3 Aid that -- that's te principle of taimne A. Miat's righ, I did not. 'lint was anothe 4 Ya. pu it in a plae that you kno you're gwng to have to restrcted arma. cn:e it esaaially (sic) se time, ard thats it. Q. Ncw turning to tie swimtzn pool,x you mution 6 Q. Now you mentioned as .nzt of the hes1h safety - that thenAM inctos woul, in fact, inwct tie pool. 7 1.j -- ffio' s resporshibaty you. woild take pe saples Men you were sayin that, were ýý referncirg Si ctounter readinrs of the arxe around th pol to see 9 if it was emitting hi•A levels of radation? ID Q. kid were there cca n whenhyou took wipe A. fly iwould mainly ome inck, I believe, to see a1s wre, in fact, tihe levls of iari. exeed if -- uh -- ary water was beinr splIadn arozud because you

12 th reco nie - were taking contairns oru, and also they )cried at the :3 rare arma ntcr. i4 Q. Cay. MlE VICAPAM: I'm seeingyour hand a lt. Qn a mxrkaly basi ca you ell Ibo fregintly MS. IMEfl : I'm sorry. 16 tint ocu~ and %hexe? Q. Dfxirp tie time yu were at•thet Isctpes facility 17 A. Prbisbly onc a nnrh in tie hot lab. did you evr witness any wetr splaahig cu of the pool? is •.0. Ckay. A. Ch, si , it I;; I qguite often. 19 And did it o r in ay theIr areasr. 0. "Oite oft•n* meanin seral tines a week? 20 A. Uh -- sometimes in the coId I& but very raely. A. Yeah, - 21 Q. Wt= you toak a wipe sawple and you frmi Well, every time you took one of thise big 22 eevato levals of nadatioJ, Vf= sten did yo take to duiel& ou it usually hk ened. 23 Q. ýbt - 24 A. I required thnt the arm be cleaned. A. Ekt you ;1ln3 that ip, of caxnse. 25 Q. rd when the area was cleaned, what did that Q. •,s you referred to tihe ABC conxtig ain

213 215 LW• MWX ER==/ SEWIM• LVE 7ARE FEEMM SEWICE

I Implve? izeiaa of the pool, tiny did -- tin irnspcors did not 2 A. It inolved taking ip the off tie -- like physicaUy o into the pol and heck for craks? 3 t flr of theiht lab, ad then wasiz tin whole thing A. Ch,. back, no. 4 mwith ups -- derent. Q. In fact, %tileyou wre there an dec ad for 5 Q. kid whe there was any eess wat that was cracks in tin pool. 6 garenauri tni4x m where d- water 9:Q A. No. 7 A. er was m e ss ar. It s dcon in Q. Yu stated thnt the A-r did not inspect in 8 ai~ls -- all cra~inedz - sq~L~ cut in pails and wie zetricted areas. Did that nee they did no inspect in -9 up and aq-ictag the hot cell area" 2D 0. d where did the wter in the pails g to? A No, tiey didn't 9o in there. 22 A. It want into inre3s and uns -olidiefie Q. okay. 22 0. Wlh you talked a takt gdr•p a that wt But tiny did go near tie swimmuV pool. 23 on the grasud, ca )ui describe what kind of that Isn't the swinming pool in tin hr cell area? 3-4 use? A. It is in the hotcaell ara, hru it is not in the 35 A. Mh, it was is Astrial -- uh- iAsial type - hot cell. 26 uh - e that yu couAd walk m wimat -- uh - Q. Ieee. 17 3•a•r• x• m ,in it and so f Ith. It's a partly plasic S tiey•ould have comated no radiatio IS in the mie and thin to•a 1 an tie ozne like readigs o wipe smples of the hot cell ares? 39 iqn craft ard so forth A. 7hlt's rigkt. 20 Q. %a this tstit % m especially for But I weat to eqp1ain to yu there's wndme all 21 ia esd use, or was it used geerlly - alon that buiding wheire an cn lock in and m what's

22 A. I don't believ thy claie it vs for tha, going an -- hpntirm in tie hro cll, so t•iy could 23 hr - uh - it wa n practi to u that kid of der operatin witho gaing in. 36 in br• us.za-- samid tie s ,'::y. 0. But dbsevirw cpareti does nt give you 25 Q. And just sota I am aocuzzm is it da1iti leeals, orrect?

214 216 MASEMOM IWCF1G R IAV U*MlE IFW SWIM

J. ne of the barrels fell off the dam truck and 1 A. No. 1 fcrtuaC Was rig-- 2 Q. iWen you ultimrately began repa3 g the w e 2 Ouly1urM of the Isope tCxittee 3 drums and cntainers and wCooen" for disposa at the 3 behind and he saw it- and topped the farmn' s truck whn rolled it 4 ocean, before yi reakd did y' take Gaiger 4 was running the fle . ly took a big plat and 5 redin of the pad ? 5 up in his truck. By then th pol i had om. Scetd was acting 6 A. th. 6 7 0. 00ay. 7 91sx cicusly Mier the Vi . B ru 183)9; M 8 You metrioned that 90 p of the wea Bt it Ws- rMrrd; Mn kss; 9 9 material in the zesrxicted ares wre, in fact -- was, it. Q. W•.Shimac askesd saw qusin ahou• you kmd 10 fac, repackaged befcme it wae to the coa . 10 leaks wile you were at the facility. 11 A. 'fat is correct. 311 dsrved o you cxair the emission of radiatian at 12 Q. Vbs that - 12 ý 13 Ckay. 13 levels that are unacetable to be a leak, or do& 14 AVr 'as it repcagd~e? 14 ccnsider a leak a physical release of the pmoJuct? 15 A. Bease the condition of the other pacgs were 15 A. We always calsidr leakage to be Fkbsi1l 16 rio njt-imtb for traxnsptation. 16 release and usually of a iJ iAd. before you came to Isooe 17 Q. AWd hw did you determine that they were not 17 Q. You mantiod tha 18 suitable for tranpotatian? 18 w.ste received by ccupnies -- cstaim was r d in a 19 A- May did't mam the specifications of DOr for 19 20 ,aterials of cnstuction and so forth. 20 DO you recalI tha? 21 Q. You mntio earli)r abou the 200 mocro- - 21 A. Yes. Q. And wiile you were at Isot op s there a 22 A. -- miJlxzo a h otur - 22 23 0.--ri.lircetgea limits for DOT transotation 23 similar log that o used when wste was received frm 24 Do yu know whether or no aheleels of the 24 custA.rrs? A. Mlat is t:rue. 25 millirc atgens in cmonecian with the ctains tat wre 25

2 219 ILVE M*ME •KW!M S3MICE IAKE MWKE SERICE

1 repacagd exee dae 200 ndillirosngen7 1 Q. Wkbud UaA hav been neaof your custmers? 2 A. No the are that I rekai:ad. 2 A. 'fly -Ad have been, bit I'm rno -- I'm rio 3 But ym Tay recal the radium es in the pit 3 awae that daey werv. 4 re redig a lt ove that, ad so thed •R r, itself, 4 Q. NM at"' LU.C.) 5 5 exc ded r r laticn. So I wnt to the BArm aof 6 6 Explskives and got an entin for tint ship,,rt. Q. You' re aware? 7 0. Were the drius and wo packags that wdt e 7 A. I'm not abre. 8 •hbiped to Idaho d-uipe to Imo be tday wee to 8 Q. Okay. 9 radioive to &ITp in the cxm? 9 'fme -s a d&mvrm tha wde Iro*W at -- uh - 10 A. No, thy -- we we -- we wen't cxmpir tdat at 10 while W. S a wes asking you quetions dat d i n that time, bit I didn't w•t to I I gall hse en n1 the restncted area in whidc waste as -- uh -- hand - 22 bxs full of m siin-thoriu cuttings. 12 h -- stared. And it discsrdhe fact t thered w a 13 Q. Had yurackaged them c=A dey hav qn into 13 lockdn the gate - 14 the oceai_ 14 MS. MJ=CiH: Well, thy don't we sh the witness i5 A. Yes. 25 EMdtbit 18. It's JI134. 16 Q. So thy we snt to Idaho bm e you did rn 16 17 wnt to have to go th=gxh the repaog cozrcisel 17 MrIef Pale while the wites znoe d~sat) 19 A. 7fat's righ. 'flre we 75 ton sf tof 18 M. M =: Q. Calli0 )nam atttm to that 19 tbigs. 19 - three, 20 Q. DuriM the ti•e period tint ta rezpadogi of 20 A. Yes, Isee it. 21 the nine hdred and some odd drus occurre did-- w-e 21 Q. -- it s asth "*the gate is interlo*ed to 22 tere any ac ent tha ocurredP 22 at± boh a lo1 arlihl signal, whidch c b shut off 23 A. I don' t recall any physical mdaents . 23 if d .ixe. 24 .0h, d ae sane incidt. an a shpmt of 24 Do yu recall r the -ail taiqa %= in 25 bnrreIs g=3x doaa ta freemy, Har Freay, fo a 25 eff during t t m wae at ta fxility?

218 220 IMMKM*= RCMM SEV= I

1 A. Yes, it was in effec. 1 Research Chanial? 2 Q. Ck~ay 2 A. Yes. 3 Wa~sthee any smmlar zresarctin that prvne 3 4 peop]a from going irto the back ba-di r~ roar the pit 4 infcrmt~im do y~ base that undrmstadir? 5 arain the bed& bulldý 5 A On information from Al Mic-Ai. 6 A. Tha doo in the b:ack building was kept iockeda. 6 Q kid who was Al Midveil? 7 Q. C)kay. 7 A He was vc-presdei in char~ of tha facility. 8 Did it hawe a surdlar -r]7ie alarm if that joc a Q *sei you eumat.1y begn workiMx fo the 9 9 PICZ -- 10 A. No, it did mt. 10 Well, strik that. 11 Bit it had a roof an it wn nobody col ge in 11 During the toe period that you. worked for either 12 tha way, see. 12 tha (seith departrui or tha AEX, did yo ozruc 13 Q. Cksy. 13 inspecicns of facilities that were swmdlar to the I±sopes 14 A. flint's %hky we had the adible -- uh-- ad s 14 facility-, 15 15 A. No. 16 if the osi~ gate -- we're Afraid fl92ti 16 M.. M1Jfli: I have m~furthe quenstions at this 17 sareboj woul~d get ove o~ fence -- sonrs kid va~ld ge± 17 time. 18 araind there or smetbin and ge in there and this ffffyb 18 flE VI=A1E: This ccrrb.de the desitiai? 1.9 would give us a dinm to catchd tbefore tha got into 19 WR. PFfflXtC: I have mr futher~ questions. 20 20 21 Q. Whorhad accss to tha key to the ac buldinr? 21 M.R.SHIMP: Hopefully brief. 22 A. I think Idid. 22 23 Q. Did &a' of tha other eiplawe have aces to it? 23 MlE VM32GRPI: Should we go off the ~ 24 A. Well, my assistant. I tbix* ha had a key. 24 fj=anm Ite? 25 Q. A-A ~4= atys his rame? 25 W.. Mzfl{: I dont know that we med to.

22 223 IAKE M*rE RETCRIW SERVICE

1 A. 1 ME VIE3~PAPRM: ICkay. 2 2 ahif ixlzeranticn) 3 MhEWI'fl: Wetterau, W-e-t-t-e-r-e-a-u (sic), 3 4 I believe. 4 Mr . Vaen, &wheyouI testified that aprsonartely 5 M.. WR~IS~l: flint's Leonad; not Larry. 5 ninety-sare-odd perrm of the -- uh -- waste caraizers 6 6 bad to be repackaged prior to dispsl at see bain they 7 M.. IMIH: .You mntzione that yo' 7 did m~t ea r ~speaicaticris for trnpot that doen't 8 codce survey's at Reeac Oinniral? 8 mr4sn doe it, that 90 pezrcen of tha coutaizners wer 9 A. Yes. 9 physically leaking o were asrnrm rx tiqkt, does it? 10 Q. Howi fr-enstly did ycu a-dim asuveys? 10 A. It nears that they were rio in theapprcel 21 A. Pzdnably onc a wnath. 3.1 pakae that Wr zegixee for t uiqtation by~ truck. 122 Q. kdx vwhe 3y.I say "onduc sn1my*. wee those 22 Q. Baiem L~r pecdfia certain types of harrel of 13 Geiger m.xtar and wipe sanples? 13 a cetainl strarth7 14 A. Wipe sanples anl Geiger cunter. 14 A. 'flit is r± fw is Q. rd. was it that the amant of T-b-ion mi the 15 All heaiels have a sei~firation arurb that - 16 wipe smqple ever in excs of the zingiixe liffits? 16 ouzlook it up and yo tell the weigt of the steel and 17 17 the - tinruee of ribsan t.de si&e and tdihma

18 0.You mr-icrad tint to youzr ixr~lartanchir 18 pressre ard -mid cthe types of ,materadl. 3.9 Research Owidral generated about one harre of wase every 19 Q. So a b arrel -1~d b hajnsimclly tigt - 20 six irui, is that corect? 20 tint is, m~phyical sepg or leakag of naterial -- y 21 A. 7hlnt is .rzw± 21 sti I , have to be repckge be= the bmn1 wasni't 22 0. And was that harrel stored in thent--gi~ 22 stzaU encugh 23 restricted wase amor iiini tin back b~Idir#? 23 A. Yes. 24 A. M whatscutsi . 24 25 Q. No it ymm undsmarding that mor~ also amned 25 MR. EWW: I have one nce gmsiaL,

222 IA WE4 REP09M SERVICE IMZ WO~E REPlIIP SEVC 1 M.. ?.tj=0fl Sure. MIO o1ff the180r 2 'ME V10033WA.: We are toa~rsurt.= the 3 'IFE VICEO~k=: YCU CEV .Et StaV ~ deo4--,is that a=-? 4 are, youaikeJ~. 5 SUERE)1ZtýLaBv W. EtM: TEIEVIEEMMA , C-- the I~rat 1707. 6 M.r. Vade- Mihis eid tape 33 of -.n dqxitih by (sic) MP. EFM: Can I hWve himt &-a E~ibit: ad .ichn Vac an Aigist 5=. !996 and erns tins depitiai. it's documet ruibe 00301? Got to doi n., ==j. 9 10 Wt. 3C :Q. I'm kodcir az 301. I tita' it's 11 a co.pl of pae on tie -- tin pa~e hwi sti41clate that tin 12 ab pus vkule tie wies xermz domzes) ax=t Roter will ser the aig~ial ta=4 du&nzr ly 13 IMR.EFU: Q. Yes, that's it. to Mrt. '.~i with a m mecp ---at is self-addrsse to 14 On you mark an that mep exa~y where 15 W. Vak wil- -e 33 dhys to revie tin 16 MSE Tý Cff the reax. m~ 1a~ 9 , if noesay and sig the 17 MSE VICSOPAEE: Gaiz'S cf tin I~at- !705. und p3mvl of pe=Try. In tin evem that 18 Maaý off the reorC W.Ab- does zM siW. t-ii depsit-ionu tsnnwvi xkm 19 MSEVICE3WIM Ouy. S&i by'. rnen3.ty of perjurny f= any re~s -- uh-- it's stipulatM 20 tin~sthe arue tint- a o~~ of tin depsatun nay he

22 MSEVICEWOE: Cri tin 3~ar 1706. use ir carxnctin with * ro-b19 ir 22 Please IrtrL QuIM that Mr. Maie nake to tin dqprsitic2 23 Mt. BF1C: Mr . Vaon fo tin roccr c~ w2iM in axmmxniate to oernel E= tin oknt parties upm 24 youm*~ m~damnsnrL n 00301A whee Faeec is~ receipt by, Iceb & Loe, aof tin =giLrsl will. be made 25 was lce' awnlable to counsel q= zonml rs i

z tAXE 'VM EMU=N SOMICE

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.4 1 2 3 1,* the within witnes, cet~ify that the within 4 deoit-in has previlcsly bee sibiitte to nae fcr 5 exww==i; that I have exanedx the sw and the samr 6 has bee rea by m~; and I have naie am dtorsp in form 7 cr &sanoe therem as I deire. 8 Date of signirrj: 7hyof__da 1______9 1998. 10 2.1 12

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1 SIM CP C@1ZC ) 2 COIM OF EL 3P ) 3 1, EM 1UIW, Owtified a&rthan Repmte of the 4 -at of CQ1ifcsna, hereby certi~fy that the witnes in the 5 foregoing depoitu was by ire ciily swo to testify tha 6 trith, the i4xD1e Mith mid m~nMhiiit tha Moit ii tde 7 within entitl.ed cam; that said deoition, vas tak at 8 the Ut.v and place temen stated; that the test~inrm of 9 tke said vittes % reptei by ire and was thereafter 10 treucrbe±k txzd y dixect into typewritir; that tha 11 faregorij is a ftil, crmplete and tine I~of sid 12 testincry; and thst the Witnes was given an cpprtunity to 13 read and sa~id dqmsiticn and to slicibe tkat~e 14 &idthe siqwbire of the witnes not be affixed to the 15 depitim the witrzw seIm not have aveflai kdnt.1I of 16 the qpxbztiziiy to sign ct the signs~re has benamived. 17 1 firtkg iertify that I am rio of o,.zuej cr

18 attwjey fat efr1ý at any of tke parties in the fategodz 19 dqaitici and cqidi rae. or in any Wy interste in 20 the cutcre of the cam Iaein soid apiui. 21 IN WTDW REFS, I have heamto setr knyid 22 th~is..d yo Ia1LA 1998. 23

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230

1. October 12, 1999 Raymond F. Fish, Jr. Volume I

I I EXHIBITS MARKED FOR IDENTIFICATION CONTINUED 2 No. Description Page 2 IN THE UNITED STATES DISTRICT COURT 3 8 Document entitled "Figure 3-1 Results . 118 3 CENTRAL DISTRICT OF CALIFORNIA of und and floor surface gamma 4 radiation surveys." 4 --oOo- 5 9 Document entitled "Figure 3-8 ...... 122 5 Locations and results of in-situ 6 gamma ray spectrometry." 6 JOSEPH A. THOMSON and VIRGINIA THOMSON, as individuals, 7 10 Document entitled "Table 3-3 ...... 123 7 Measurements of surface Plaintiffs, 8 contamimntioo, beta and alpha." 8 No. CV-97-5220 RAP vs. 9 11 Document entitled "Table 3-1 Locations 126 9 with localized elevated areas of ICN PHARMACEUTICALS, INC., a 10 contamination." 10 Delaware corporation; NUCOR CORPORATION, a Delaware 11 12 Four-page document numbered 4-6 to ....127 11 corporation; RHONE-POULENC, INC., 4-9. a New York Corporation, 12 12 13 Letter to Edgar Bailey from Ross A. 134 Defendant. 13 Scarano dated April 8th, 1996. 13 Bates-stamped ICN 001937 to 001960. 14 14 14 Letter to Raymond Fish from Martha 135 15 Sharp dated December 17, 1997 re: 15 Interview staemet. 16 16 15 Document entitled "Guidelines for ..... 146 17 Decontamination of Facilities and 17 DEPOSITION OF Equipment Prior to Release for Unrestricted Use or Termination of F. FISH, JR. 18 18 RAYMOND Licenses for Byproduct, Source, or 19 Special Nuclear Naterial" dated 19 April 22, 1970. 20 20 October 12, 1999 16 Subpoena for Raymond Fish...... 146 1 - 181) 21 21 Volume I (Pages Plaintiff's Exhibits marked: 22 22 17 Document entitled "California 167 23 Radiation Con=rol Regulations" 23 REPORTED BY: JULIE ANNE ZEIGLER, CSR 9570 JOB 84467 1966. 24 24 25 25 Page 1 Page 3 4 I INDEX 2 IN THE UNITED STATES DISTRICT COURT 2 3 CENTRAL DISTRICT OF CALIFORNIA 3 INDEX OF EXAMINATION 4 -- 000-- 4 Page 5 5 EXAMINATION BY MR. PATTERSON ...... 7 6 JOSEPH A. THOMSON and VIRGINIA. 6 EXAMINATION BY MS. McKEITH ...... 148 THOMSON, as individuals, ) K 7 ) 7 EXHIB••S MARRED FOR IDENTIFICATION Plaintiffs, 8 ) No. Description Page RAP 8 vs. )No. CV-97-5220 Exhibits: 9 9 Defendant ICN Pharmaceutical's ICN PHARMACEUTICALS, INC., a 10 Delaware corporation; NUCOR 10 1 Letter to AA. Michaud from H.L. Price .53 CORPORATION, a Delaware on the letterhead of the United II corporation; RHONE-POULENC, INC.. 11 States Atomic Energy Commission. a New York corporation, 12 12 2 Letter to Nuclear Corporation of ...... 58 Defendant. America, Inc. Isotopes Specialties 13 13 Company Division from James R. Mason with a docket stamp date of 14 February 1, 1961. 14 --oOo- 15 BE IT REMEMBERED that, pursuant to Notice, 15 3 Document entitled "Contamination . 64 Guides." 12, 1999, commencing at 10:08 16 16 and on Tuesday, October .66 4 Document which contains some pictures & Bisgaard 17 of various survey instruments. 17 a~m thereof, at Lewis, D'Amato, Brisbois 18 LLP One Sansome Street, 14th Floor, San Francisco, 18 5 Document entitled "Atomic Energy. 75 Commission, Title 10 - Atomic 19 California, before me, JULIE ANNE ZEIGLER, a Certified 19 Energy (ARC Reprint Containing 30, Amendments Issued Through July Reporter, personally appeared 20 1958)." 20 Shorthand 21 RAYMOND F. FISH, JR. 21 6 A diagram entitled "Figure 1-2 . 91 Thompson Property Facility Map." 22 22 Document entitled "Former Isotopes .... 113 7 23 called as a witness by the Defendant ICN 23 Specialties Company Site: 170 West Burbank, Providencia Street 24 Pharmaceuticals, Inc., who, having been first duly 24 California." sworn, was examined and testified as follows: 25 25 Page 2 Page 4 ______.1. I Page 1 - Page 4 Combs & Greenlev. Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I

1 --o0o- I the witness. (Witness sworn.) 2 LOEB & LOEB LLP, 1000 Wilshire Boulevard, 2 3 Suite 1800, Los Angeles, California 90017-2475, 3 VIDEO OPERATOR: Go ahead. EXAMINATION BY MR. PATTERSON 4 represented by MAUSSA HATHAWAY McKErIH, Attorney at 4 5 Law, appeared as counsel on behalf of the Plaintiffs. 5 MR. PATFERSON: Q. Good morning, 6 PROSKAUER ROSE LLP, 2049 Century Park East, 6 Mr. Fish. 7 Suite 3200, Los Angeles, California 90067-3206 7 A. Good morning. the substance of the 8 represented by GREGORY J. PATTERSON, Attorney at Law, 8 Q. Before we get into 9 appeared as counsel on behalf of Defendant ICN 9 deposition, we would all -- counsel here would all 10 Pharmaceuticals, Inc.. 10 like to make it clear that we're simply here to try to that 11 LEWIS, D'AMATO, BRISBOIS & BISGAARD LLP, 11 get your best testimony today regarding events 12 221 North Figueroa Street, Suite 1200, Los Angeles, 12 occurred a long time ago, and that there is no 13 California 90012 represented by JOHN H. SHIMADA, 13 interest on the part of any of our clients -- I 14 Attorney at Law, appeared as counsel on behalf of 14 represent that there's no interest on the part of ICN 15 Defendant Nucor Corporation. 15 Pharmaceuticals, Inc. to sue you in this matter 16 MCCUTCHEN, DOYLE, BROWN & ENERSEN, LLP, 355 16 because of facts arising out of this matter in any attached to your testimony 17 S. Grand Avenue, Suite 4400, Los Angeles, California 17 way. There's no liability about 18 90071 represented by BRYAN K. BROWN, Attorney at Law, 18 today. We tell you that so you feel comfortable 19 appeared as counsel of behalf of Defendant 19 giving your best testimony today. 20 Rhone-Poulenc, Inc. 20 A. Thank you. 21 --o0o-- 21 MS. McKEITH: And I represent the 22 VIDEO OPERATOR: Here begins Videotape No. 22 plaintiffs in this lawsuit, and we do not have any 23 1 in the deposition of Raymond Fish in the matter of 23 interest in filing litigation against you. We simply 24 Thomson versus ICN Pharmaceuticals in the United 24 want your best recollection of what occurred in the 25 States District Court, Central District of California. 25 early 1960s. Page 5 Page 7

Case number is CV 97-5220 RAP. Today's date is MR. SHIMADA: I'll join in those statements October 12th, 1999. The time on the video monitor is on behalf of my client. 10:08 a.m. The video operator today is Rhonda MR. BROWN: I will also join in those Collins, a notary public, contracted by Video statements on behalf of my client. Solutions, a LegaLink company in San Francisco, MR. PATTERSON: Q. Mr. Fish, have you California. ever had your deposition taken before? This video deposition is taking place at A. No. One Sansome Street in San Francisco and was noticed by Q. Have you ever testified at a trial? Proskauer Rose for Defendant ICN Pharmaceuticals. A. I have testified at administrative Counsel, would you please voice identify proceedings conducted by the Atomic Energy Commission yourselves and state whom you represent. and the Nuclear Regulatory Commission. MR. PATTERSON: Greg Patterson from Q. How many times have you testified in those Proskauer Rose on behalf of icN Pharmaceuticals. proceedings? MS. McKEITH: Good morning. I'm Malissa A. At least twice. McKeith from Loeb & Loeb. I represent Virginia and Q. What was the substance involved in those Joseph Thomson, the current property owners. first? MR. SHIMADA: Good morning. My name is k In the first one, it was the action on the John Shimada of Lewis, D'Amato, Brisbois & Bisgaard part of the commission to terminate licensed activity. for Nucor Corporation, a defendant. And in the second one, it was concerning activities MR. BROWN: Good morning. My name is Bryan related to a nuclear power plant. Brown. I'm from McCutchen, Doyle, Brown & Enersen. I Q. How long ago was this? represent Rhone-Poulenc. A. The first one I testified was in 1960, and VIDEO OPERATOR: The court reporter today the second one would have been in the mid-'70s - '75 is Julie Zeigler of LegaLink of Northern California. to '77. Somewhere around there. Would the court reporter please swear in Q. Was this testimony given under oath? Page 6 Page 8 Page 5 - Page 8 Combs & Greenlev, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I

A. Yes, it was. 1 something, it's a perfectly fime answer to say "I Q. Mr. Fish, you've also been given the oath 2 don't remember." in these proceedings today. And that oath has the 3 Are you aware of any reason why you can't same solemnity of the oath that you gave during your 4 give your best testimony today? administrative hearings. Do you understand that? 5 A. None. A. Yes, I do. 6 Q. Are you on any kind of medication which Q. I'm going to go over a few ground rules 7 might impair your memory or your ability to testify? regarding the deposition today so that we have an 8 A. No. understanding of how this should work. The court 9 Q. What I would like to do now, Mr. Fish, is reporter will be taking your testimony down and 10 get an understanding of your background. I would transcribing it into a booklet form. You will have I 1 first like to have you describe your education since the opportunity to review that testimony and make any 12 high school. changes that you feel are necessary. However, I would 13 A. I have a bachelor of arts degree with a caution you that if you make substantive changes to 14 major in chemistry and a minor in physics from San your testimony, that that -- those changes might be 15 Jose State, and I have a master's of business used in any trial to impeach you or to attempt to 16 administration from John F. Kennedy University. discredit you. So it's really important today that 17 Q. When did you receive your bachelor's you try to give us your very best testimony. 18 degree? A. I will do that. 19 A. Bachelor's degree I received in June of Q. It's also important that you wait until I 20 1951. And master's, I received in June of 1971. finish my question, and then you can provide your 21 Q. Okay. You kind of cut me short there. answer, and I will try very hard to wait until you 22 Again, it's easy for us to start talking over each finish your answer before I ask my next question. 23 other. So please try not - That allows the court reporter to take accurate 24 A. Sorry. testimony. It's very difficult if she has to try to 25 Q. Could you just describe briefly the sort of Page 9 take our testimony when we're talking over each other. I range of courses that you had at San Jose State? Okay? 2 A. They had a number of courses that were A. I understand that. 3 established for the degree which covered general Q. Responses like "uh-huh" or *huh-uh,* I 4 chemistry, organic chemistry, and analytical would try to avoid because in booklet form you can't 5 chemistry, and physical chemistry. Those were the tell whether it's a no or a yes. So in those 6 primary courses in chemistry. instances, it would be important to provide us with a 7 I took some courses in physics which no or a yes. Okay? 8 started with general physics and a couple of other If you don't understand the question that 9 courses, and I don't remember those offhand right now. we ask today, then it's perfectly fine to let us know 10 And then there were other required courses to get a that and we'll try to rephrase it in a way that you do 11 bachelor's degree, which included foreign language and understand. Okay? 12 some other courses like political science courses and A. Yes. 13 these types of courses and, of course, English. Q. Again, we're entitled to your best 14 Q. Did you take any courses involving recollection of what occurred. If you have a memory, 15 radioactive materials at San Jose State? however faint it might be, we would like to hear about 16 A. No, I did not. that, but we would also caution you not to guess. Do 17 Q. Did you go to work after graduating from you understand the difference between having a sort of 18 San Jose State in 1951? vague memory and guessing? 19 A. Yes, I did. A. Yes. 20 Q. Where were you first employed? Q. We'll all try not to assume or guess today 21 A. I was employed in late fall of 1951 by because we are talking about events that occurred 22 California Research and Development Company, which was nearly 40 years ago, and we all understand that it may 23 a subsidiary of Standard Oil of California. be difficult to remember everything. So when -- as we 24 Q. What was your position at California go through today, if you simply don't remember 25 Research and Development Company? Page 10 Page 12 I Page 9 - Page 12 Combs & Greenley, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I

A. I was an analytical chemist. 1 A. They would be what we call "scalers" with Q. And what were your responsibilities as an 2 various types of detectors depending upon the type of analytical chemist? 3 activity being evaluated. kind of Geiger A. To perform all of the activities assigned 4 Q. Did you ever use any to the laboratory, which was primarily the collection 5 counters during this time period? of samples and the analysis of those samples. 6 A. Not during this time period, no. Q. What would these samples be analyzed for? 7 Q. How long did you work at California A. For the most part, the samples were 8 Research and Development Company? analyzed for nonradioactive materials, calcium and 9 A. I worked until mid-September of 1953. water, total solids in water. These kinds of things 10 Q_ Did your position change during that time with respect to -- however some of the work involved II period from? the analysis of urine samples for radioactive 12 A. No, it did not. materials, including uranium and plutonium. 13 Q. So you were an analytical chemist from 1951 Q. What was the purpose of conducting the 14 to 1953 at California Research and Development? urine sample? 15 A. Yes. A. To make an assessment of internal 16 Q. What job did you have next? disposition. 17 A. From there I went to work for the Nuclear Q. Where were these samples coming from? What 18 Division of North American Aviation, and I don't facility? 19 remember the job title, but my work assignment was to A. From the employees at the site employed by 20 evaluate the effects of radiation on organic CR and D. 21 materials. Q. Was -- when you say "CR and D," that's 22 Q. And I'm sorry, when did you start working California Research - 23 there? Do you have a sense of - A. California Research and Development. 24 A. In the late fall of 1953. November, give Q. And did California Research and Development 25 or take a month. Page 13 Page 15 Company conduct radioactive materials research? Q. Where was the Nuclear Division of - A. Yes. A. They were located in Downey, California. Q. Do you have an understanding of what that Q. And where was California Research and research involved? Development Company located? A. It was a wide-ranging research. One of the A. They were located in Livermore. assignments was to deal with the potential machine Q. You testified that you evaluated the production of enriched uranium, which was a major effects of radiation on organic materials. Could you effort there. And then there was also other types of explain what that involved? research work going on involving radioactive A. Yes. That was taking various materials materials, and there was nonradioactive work going on, that the organization considered potential coolants in including diffusion pumps and these kind of things, a reactor, in an organic reactor, and in order to which would be related to the major project. determine the potential problems from these materials Q. Did you, yourself-- were you involved in being subjected to radiation, we did laboratory any of this research? studies of these organic materials by subjecting them A. No. in a laboratory atmosphere to radiation, and then Q. Did you receive any training regarding evaluating the material. testing or sampling for radioactive materials? Q. What kind of organic materials were subject A. I received guidance by supervision and to the radiation? other experienced chemists in the areas that I was A. These were primary biphenol and tertiary working in, but in terms of a formal course, I did not phenol materials. have a formal course. Q. Was this work done under a license issued Q. Did this work involve the use of any by the Atomic Energy Commission? instruments to detect radioactive materials? A. I think it was, but I'm not sure. I know A. Yes, they did. they also had activities going -- being performed Q. What materials were those? under contracts with the Atomic Energy Commission. Page 14 Page 16 Page 13 - Page 16 Combs & Greenley, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I I1 1 Q. Were you involved in any of that work? I THE WITNESS: No. That's a type of 2 A. No. No. 2 instru ament. 3 Q. While employed at Nuclear Division of North 3 MS. McKErrH: Do you know how to spell 4 American Aviation, did you receive any training on the 4 that? 5 radiation safety or precautions, etc.? 5 THE WITNESS: G-e-i-g-e-r. part. 6 A. Everybody got training on radiation safety. 6 MS. McKErrH: Got that 7 That was -- everybody was subjected to that in order 7 THE WITNESS: And Muller, M-u-e-l-l-e-r, I 8 to be able to work safely in that kind of an 8 think. That's a guess. 9 environment. 9 MS. McKErrH: Thank you. 10 Q. Could you describe to me what kind of 10 MR. PATTERSON: Q. How long were you 11 training you received while at Nuclear Division of 11 employed at Nuclear Division of North America? 12 North America? 12 A. I left them in the middle part of 1956. 13 A. We would have received training on the 13 Q. So you were there for almost three years? 14 types of radiation, the effects of radiation, the 14 A. Yes. 15 instruments used to measure the radiation, and 15 Q. Did you have the same position during those 16 appropriate safety practices. 16 three years? 17 Q. Can you identify the instruments that you 17 A. Yes. 18 were trained to use while at Nuclear Division of North 18 Q. Was the work that you did at Nuclear 19 America? 19 Division of North America, was that in a laboratory? 20 A. I can't identify them. I can tell you that 20 A. Yes. 21 they would have been the typical Geiger-Muller type 21 Q. And during that time period, did you handle 22 instruments and ionization-type instruments, and those 22 or use radioactive materials? 23 would have been the primary instruments in use at the 23 A. No. 24 time. 24 Q. Did you maintain certain radioactive 25 Q. And what did the Geiger-Muller -- what was 25 materials in the laboratory? Page 17 Page 19 + 1 it used for? A. I did not, no. 2 A. Measuring beta gamma radiation. Q. Were there radioactive materials maintained 3 Q. Do you recall what kind of measurements in the laboratory? 4 were used at that time to measure the beta gamma ray A. Yeah, there were radioactive materials 5 radiation? In other words, what - everywhere. 6 A. Typically, the units were in milligram Q. It was someone else's responsibility to 7 or -- actually, milliroentgen or fractions of a handle those? 8 milliroentgen using the metric system. It would be in A. Yes. 9 tenths or hundredths. Q. Could you describe to me in a little bit 10 Q. And what were the ionization instrument - more detail exactly what your responsibility was in 11 A. Would be the same type of measurements. that laboratory? 12 Q. It would also test for beta and gamma A. Yeah. I had a piece of equipment in which 13 radiation? I put my samples and it had the capability of 14 A. Yes. Some of those instruments had the elevating the temperature on the sample, and then I 15 capability of measuring alpha, but, primarily, the would subject it to radiation from a machine -- from 16 problem was the beta gamma problem. A minimum amount an accelerator. And then when the -- and we would 17 of alpha around or alpha contamination or radiation. establish how much radiation was to be imposed upon 18 Q. Were the Geiger-Muller instruments capable the sample, and then we would take the sample out and 19 of detecting alpha radiation? analyze it and see what changes had occurred. 20 A. No. Q. When you left Nuclear Division of North 21 MS. McKEITH: Could you spell Muller for America Aviation, where did you go to work? 22 us? A. I went to Aerojet General Nucleonics 23 THE WITNESS: Pardon? Company. They were located in San Ramon, California. 24 MS. McKErrH: Geiger-Muller, the Muller. Q. What was your position at Aerojet General? 25 Is that the brand name? A. I don't remember the position. My Page 18 Page 20 Page 17 - Page 20 Combs & Greenlev. Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I

1 responsibility was to oversee the fabrication of the any instruments to measure radioactive materials or 2 cores for the research reactors, which the company was contamination while at Aerojet General? 3 building for universities. It was a combination of A. Yes, I did. 4 research and training. Q. And what instruments were those? 5 Q. When you say "oversee" -- could you read A. They would have been the Geiger-Muller and 6 back his answer for me, please? ionization-type instruments. I don't remember whether 7 (Record read.) there was any specifically for alpha, but it would be 8 MR. PATTERSON: Q. Did you have a staff just the typical instruments that you would use for 9 that you oversaw? the type of materials being used, which was primarily 10 A. I had two technicians working for me. enriched uranium. 11 Q. And you were involved in fabricating Q. Were you ever involved while at Aerojet 12 research reactors? General with cleaning up any radioactive 13 A. No. The core. contamination? 14 Q. The core. A. Only to the extent that we had to keep the 15 A. The core. lab clean and prevent contamination within the lab 16 Q. What is the core? from moving outside the lab. 17 A. The core is the material that contains the Q. Was there a continual monitoring within the 18 enriched uranium, which is the center piece of a lab of radioactivity? 19 reactor. The core is where the fission takes place. A. Yes. 20 Q. Did you receive any training while at Q. Were you involved in doing that monitoring? 21 Aerojet General? A. Yes. 22 A. Yes, I did. Q. And where were you employed after working 23 Q. Could you please describe that training? at Aerojet General? 24 A. One of the courses I took was a nuclear A. In September of 1959, I was employed by the 25 engineering course put on by the staff, and that's the Atomic Energy Commission, specifically the San Page 21 Page 23

only formal course that I remember. I Francisco operations office. Q. Was there any kind of informal training? 2 Q. Where was that office located? Do you recall? 3 A. When I joined them, they were located in A. There certainly was training in radiation 4 Oakland, California. safety. Every plant or facility that uses radioactive 5 Q. What was your position when you started? material has a radiation safety training program. All 6 A. It was a radiation safety specialist. employees are required to attend and take it. 7 Q. What were your job duties as a radiation Q. How long did you work at Aerojet General? 8 safety specialist? A. I worked there until the middle of 1959. 9 A. My duties were to inspect licensed Q. Did your position change while you were at 10 activities -- those activities licensed by the Aerojet General? 11 Commission within the area of jurisdiction, which was A. Yes, it did. During the last nine months, 12 California, Arizona, Hawaii, and the Pacific Islands. I was assigned to a group of people that were working 13 The inspections included inspections for compliance under a contract with the University of California 14 with the regulations as well as for safe practices, laboratory in Livermore. 15 and all of the other things that went with it, Q. And what were your responsibilities at that 16 including the handling of radioactive wastes. time? 17 Q. Was there a -- were you in a particular A. My responsibilities at that time were 18 department or division of the Atomic Energy liaison with people at the lab in the area of high 19 Commission? explosives. 20 A. This was a group that was called the Q. Would these be explosives using radioactive 21 inspection group, and it was just one part of the materials? 22 operations office, but it administratively reported to A. No. No, these are real high explosives 23 people in Bethesda, Maryland. that are used in connection with nuclear devices. 24 Q. Can you describe to me what other groups or Q. Did you utilize any survey instruments or 25 divisions were in your San Francisco office at that Page 22 Page 24 Page 21 - Page 24 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I

I time? I limitations of the instrumentation. It would have 2 A. There was a radiation safety group. There 2 involved evaluating geometries with respect to the 3 was a contract administration group. There was an 3 measurements. I think that's the best I can do for 4 engineering group. I'm sure there were two or three 4 you. 5 other groups, but I don't remember those. Those 5 Q. Also, just to -- if you ever feel like you 6 people were primarily dealing with the contract 6 need to take a break, just let us know and we'll go 7 activities such as the Lawrence Livermore Lab, the 7 off the record. 8 Berkeley Livermore Lab -- or the Lawrence Berkeley 8 A. All right. 9 Lab, and other contract activities as opposed to 9 Q. Don't feel like you have to keep going if 10 licensed activity. 10 you need to stop. Okay? 11 Q. Was there any group located in San 11 A. All right. Thank you. 12 Francisco that was involved in issuing licenses or 12 Q. What kind of instruments were involved in 13 amendments to licenses? 13 this training while you were at Argonne Lab? 14 A. No. 14 A. I don't remember, except that it would 15 Q_ Did all of that come out of Maryland? 15 cover all of the types of instruments in use at the 16 A. Yes. 16 time. 17 Q. Did you receive training when you were 17 Q. These were instruments to measure 18 employed by the Atomic Energy Commission? 18 radioactive activity? 19 A. Yes, I did. 19 A. These were instruments that were typically 20 Q. Can you describe that training for me? 20 used by the radiation safety people to measure various 21 A. There were two or three courses at Argonne 21 types of radiation, direct levels of radiation, as 22 National Laboratory put on specifically for the 22 well as contamination levels of activity and removable 23 inspection groups. One concerned various 23 activity. 24 instrumentations and measuring all types of radiation. 24 Q. Could you describe to me the types of 25 Another one dealt with, specifically, with 25 instruments that were available although I understand Page 25 Page 27

I reactor-related activities. I have taken -- there was I you don't remember exactly what you were trained on. 2 a two-week course put on for environmental activities 2 A. They would have involved the Geiger-Muller 3 related to licensed activities. There was one or two 3 types, which, of course, included the pancake type of 4 course involved in what I would describe as nuclear 4 Geiger-Muller instrument. It would have included 5 engineering, understanding reactors and the 5 ionization types, which -- both the Cutie Pie and the 6 components. I'm sure there were some other education, 6 Juno were examples. It would have included 7 but that sort of summarizes it. 7 instruments for measuring alpha contamination with a 8 Q. The two or three courses that you took 8 large or a rectangular screen, thin Mylar window. 9 at -- was it Argonne Laboratories? 9 Those are the primary types of instruments it would 0 A. Yes. 10 have involved. 1 Q. Was that done at the time that you became 11 Q. What is a pancake type Geiger-Muller? What 2 employed by the Atomic Energy Commission? 12 is that? 3 A. It was done over a period of time. 13 A. A pancake-type Geiger-Muller is a circular Q. Let me ask you: Did you receive any 14 detector, normally with a shielded top and a thin film training prior to actually being in the field, so to 15 that is used to collect the radiation from 180 degrees speak? 16 so that it's basically shielded from from the top, but A. No. These were courses that were given 17 measures only that that comes from -- through the after I had actually done inspections. 18 bottom, through the thin film, and it's a -- it works Q. You described at least one of the courses 19 the same way that a Geiger-Muller did. as a course on instrumentation? 20 Q. Did it measure the radioactivity in A. Yes. 21 milliroentgen or millirems? Q. Could you tell me what that course 22 A. It typically was in milliroentgens. involved? 23 Q. Can you tell me what the difference is A. It would involve the use of 24 between a mllliroentgen and a millirem? instrunentations. It would have involved the 25 A. Yeah. The difference between a Page 26 Page 28 Page 25 - Page 28 Combs & Greenley. Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I 1 milliroentgen and a millirem is related to the I it depends upon how much activity is there. 2 different effects that different radiations have on 2 Q. Did you have any training in 3 individuals. Beta and gamma radiation have a 3 decontamination procedures while at the Atomic Energy 4 conversion factor of one, which means it reads 4 Commission? 5 directly. Neutrons have a factor of 10, which means 5 A. No formal training. 6 that 1 milliroentgen, which is not the terminology 6 Q. Did you have some kind of on-the-job 7 used for neutron, but 1 would be 10 in terms of 7 training, so to speak? 8 millirem. In the case of alpha, I think it was a 8 A. Yeah. The issue of decontamination was 9 factor of 20. But the difference between 9 discussed and exchanges among inspectors and 10 milliroentgen and millirem is to account for the 10 supervision and things, and those from headquarters 11 different effects the radiation have. 11 would take place. And, of course, there was always 12 Q. You testified that you had some training in 12 documents to read where this had been written up. 13 evaluating geometry measurements or geometric 13 Q. In 1961, what were the procedures used at 14 measurements? 14 that time, generally, to decontaminate a facility that 15 A. They would discuss the issue of geometry. 15 was contaminated with radioactive materials? 16 If you have a situation where part of the source is 16 MR. SHIMADA: Objection; the question is 17 shielded, you need to recognize that, because the 17 overbroad and vague. 18 radiation goes in all directions. So that if you have 18 MS. McKErri: Also it's vague as to whether 19 something in the way, it would shield it. So you 19 you're talking about decontaminating an area that will 20 would not get total measurement of the radiation 20 be used again for radioactive source work versus an 21 because some of it would be shielded out, and you need 21 area that would be decommissioned. I think if you 22 to be aware of those effects. 22 clarified it, it would help everybody. 23 Q. So the placement of your measuring 23 MR. PAT'rERSON: Q. The attorneys are 24 instrument might affect what reading you got? 24 going to be putting objections on the record so that 25 A. It can have an effect, yes. 25 they can preserve them if we use this testimony in Page 29 Page 31 1 Q. And was the -- so you were getting training I later proceedings. 2 in evaluating the placement of the measuring 2 Did you understand the question or do I 3 instruments as compared to the source; is that what 3 need to clarify it? 4 this course involved? 4 MS. McKErrH: Sometimes the attorneys 5 A. In essence, that's right. What it was - 5 object because the question is actually vague and we 6 the attempt was to make you understand what happens if 6 want to make sure the record is very clear. 7 certain situations occur, and you need to be aware of 7 THE wrrNEss: Would you restate it, please? 8 them so that when you make your valuation, you 8 MR. PATrERSON: Q. All right With 9 understand what outside effects have occurred that 9 respect to a facility, that -- let's say, a licensed 10 could make a difference on the end-reading that you 10 facility licensed by the Atomic Energy Commission - 11 get. 11 what I'm asking is just a general case question of 12 Q. I see. With respect to the alpha, beta, 12 what kinds of methods were used at that time to clean 13 gamma rays, are any of those waves more easily 13 radioactive materials contaminated in the facility. 14 blocked, for lack of a better word, than the others? 14 A. One technique would have been the use of 15 A. Yeah. Alpha is the easiest to block, and 15 chemicals or soaps or detergents or things like this 16 typically you can block it with one or two sheets of 16 in a liquid medium and then using some kind of a rag 17 paper. Betas are more energetic, but are also 17 or some other thing to wash it and take it up, which 18 easily -- you can easily shield them. And gammas are 18 would be used typically for surface type of things. 19 the most difficult to shield. 19 In the case of where it has gotten down in between 20 Q. What would you use to shield a gamma 20 parts of linoleum or other similar materials, it would 21 radiation, generally? What types of materials? 21 involve taking those materials up. If it got into a 22 A. The best one, of course, would be lead, but 22 concrete crack -- surface crack or something like 23 concrete was used to shield for gammas. I'm sure 23 that, it would then have to be chipped out. Those 24 heavy metals, steel plates and things like that would 24 are, basically, the techniques and, of course, you 25 also be used in concert with something else. A lot of 25 know, the various ways of using -- you could use Page 30 Page 32 .1. Page 29 - Page 32 Combs & Greenlev, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I I 1 mechanical equipment like they use to clean floors, Q. Did you receive any training on how to 2 you know; that would be the same as using a rag or survey a facility for radioactive contamination? 3 something, except it would just be using a mechanical A. Well, I guess you would say I received it 4 mechanism to do the physical removal. every time I received training on radiation safety, 5 Q. Was the Atomic Energy Commission involved because that's basically telling you how to -- or 6 in developing procedure for cleaning up radioactive showing you how to make radiation measurements, and 7 contamination to be used by licensees? you make the measurements in order to find the 8 A. Not our group. contamination. 9 Q. Was there another group that you're aware Q. Aside from the survey instruments that you 10 of that did that? described, the Geiger-Muller and the ionization-type I I A. If that did occur, it would have occurred instruments, were there other mechanisms used to test 12 under the developmental part of the Atomic Energy for radioactive materials? 13 Commission, which is the other nonregulatory group, A. Later on, sodium iodide crystal and - 14 and I don't know whether they were doing that or not. detectors were developed and used, and I'm not just 15 Q. You had mentioned that you took a course in sure what others because we used -- at some point in 16 environmental activities and licensed activities? time we had a sodium iodide detector. 17 A. Yes. Q. Did you have any training on how to take a 18 Q. What did that course involve? wipe sample to test for radioactive material? 19 A. At that point in time, the licensing A. No formal training, no. 20 process was getting involved or had become involved in Q. Did you have some on-the-job experience on 21 the environmental aspects of building primarily how to take wipe samples? 22 nuclear power plants, but also some of the larger A. Yeah, there was on-the-job experience. 23 licensed activities had an environmental component. There were discussions of how do you take a sample to 24 It involved the gamut of doing the preliminary make a representative, and then you get into 25 environmental assessments prior to the reactor discussions of how big an area are you talking about, Page 33 Page 35 4 I becoming operational. It included, for instance, and how do you -- what techniques to use to randomly 2 where activities occurred out in the ocean, it would sample that area and what would be the best way to do 3 involve making sure that no oil was dropped out there it. It was talk among all of us. 4 or, if any oil was, they had a program to collect it Q. When you say discussions, would you have 5 and grease control and all of these types of things. meetings where these issues were discussed? 6 And it also involved the environmental samples A. No formal meetings, no. 7 associated with evaluating the total environment Q. While in the office, you discussed how to 8 situation prior to the facility becoming operational. take representative wipe samples, for instance? 9 Q. When you say "environmental situation," do A. Yes. 10 you mean the effect of a nuclear power plant operating Q. How long did you work at the Atomic Energy 11 around the surrounding environment? Commission? 12 A. No. It was, for instance, at Rancho Seco A. I worked until the Atomic Energy Commission 13 it involved looking at the animals that were there and was eliminated and divided into the two groups, which 14 they discovered a three-legged toad. It involved was in 1975. And at the time of dissolution, I went 15 making assessments of radioactive material that may be with the group that became the Nuclear Regulatory 16 there before any was brought on the site, so that you Commission. 17 know the background levels. And there were some Q. You testified when you first went to work 18 problems at Rancho in this area. at the Atomic Energy Commission, you were a radiation 19 It involved an evaluation of the fish specialist. Did your position change at any time 20 population out in the ocean areas where the cooling while with the Atomic Energy Commission? 21 waters would be discharged and collected so that, at A. Yes. Around 1980, I got involved in 22 some point down the line, you could make a comparison emergency preparedness at nuclear power plants, and 23 to see whether the activities of the facility had an then I eventually made section chief in charge of 24 effect on it. It was basically what we call emergency preparedness. 25 background -- establishing background information. Q. I'm sorry, in charge of - Page 34 Page 36 Page 33 - Page 36 Combs & Greenley. Inc. (415) 512-1234 Fish, Jr. October 12, 1999 Raymond F. Volume I

A. Emergency preparedness. preparedness requirements in place at that time? Q. Now, you say in 1980, at that point you A. There was an extensive modification to the were with the Nuclear Regulatory Commission? requirements in the regulations as the result of the A. Yes. Three Mile Island accident, and there was an extensive Q. So was it -- from 1959 to 1975, were you a evaluation of the reactor sites to see how they were radiation safety specialist? coming along with respect to implementing those new A. I was a radiation specialist. requirements. And then having gone through that Q. Did your duties or responsibilities change initial evaluation at all sites, then, from thereon, during that time period from '59 to '75? it was routine inspections of those activities. A. Yes, it did. In around 1968 or 1969, my Q. Do you remember in 1960, '61, the responsibilities changed to the extent that my personnel -- the names of the personnel in your assignments were with large licensed facilities like inspection group? Vallecitos and for nuclear power plants, and the A. Yes. general types of licenses I was not inspecting Q. Could you give me those names? anymore. A. The director was Richard W. Smith. The Q. And did you continue with those assistant director was Gene Blanc, B-l-a-n-c. The responsibilities from approximately '68, '69 through inspectors included Sam Cassalina, William Cooley, 1975? Herb Young. There was a reactor inspector, Robert A. Yes. Engleken. There were two secretaries, Ida Q. Now in 1975 when AEC broke up into two Alexander - parts, you went with the Nuclear Regulatory Q. That's very good. Commission? A. -- and Barbara Govia. And there was an A. That's correct. investigator and I don't remember his name. Q. What was your position at that time? Q. Do you keep in contact with any of these A. It was the same. people? Page 37 Page 39 4- I Q. Radiation safety specialist? A. Bill Cooley has passed away. I see Gene 2 A. Yes. Blanc periodically. Gene lives in Moraga. 3 Q. And then in 1980, you moved to emergency Q. Here in Moraga, California? 4 preparedness of nuclear reactor incidents, I suppose; A. Moraga, California. And I do not have any 5 is that correct? contact with Dick Smith. I see Ida Alexander 6 A. Basically, emergency preparedness was the periodically. 7 inspection and review of emergency plans at nuclear Q. Do you know where she lives? 8 power plants, but it also included the response of the A. She lives in Orinda, California. 9 agency to a nuclear accident, and the program that the Q. What about Sam Cassalina? 10 agency had for those areas. It also involved A. Sam Cassalina was -- left the office in the 11 interfaces with the states on emergency preparedness. early '60s, and I heard of some of his activities for 12 Q. Did you assist in developing emergency a few years and have not had any further contact. 13 preparedness plans? Q. And what about Herb Young? 14 A. For the agency, yes. A. Herb Young, in the early '60s, moved back 15 Q. And did you evaluate emergency preparedness to the office established in Atlanta, Georgia, and I 16 plans of various facilities? have not heard anything since. 17 A. Yes, those within the region. Q. You may have mentioned this already, but 18 Q. Would you provide comments to the facility, Bill Cooley? 19 perhaps, on how to improve their emergency A. Bill Cooley is passed away. 20 preparedness or deficiencies, that kind of thing? Q. What about Richard Smith? 21 A. The agency's inspectors were not allowed to A. Dick lives in I think it's Woodbe Island in 22 do that. We were told to make an evaluation and Puget Sound up near Seattle, Washington. 23 either say yes, it met the requirements, or no, it Q. Could you describe, in general, what the 24 didn't meet the requirements. responsibilities were of the inspection group? 25 Q. So there were specific emergency A. The inspection group's responsibilities rage a Page 40 Page 37 - Page 40 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I I 1 were to evaluate the licensed activities with 1 terminated. 2 compliance of the radiation safety and other 2 Q. When you say "request from the licensing 3 requirements in the regulation. It was to evaluate 3 group" 4 the safety practices. It was to evaluate the handling 4 A. Yes. 5 of radioactive wastes. In the case of nuclear 5 Q. - was this the licensing group that was 6 reactors, the radiation specialist's function would 6 located in Bethesda? 7 also include the environmental programs. I think 7 A. Yes. Organizationally, the inspection 8 those were the primary areas of responsibility. 8 function and the licensing function were separate. 9 MR. PATTERSON: Can we go off the record 9 Q. As an inspector, how would you be informed 10 for a couple minutes. 10 of the AEC requirements, new regulations or guidance? 11 VIDEO OPERATOR: Going off the record at 11 A. We each had copies of the regulations, and 12 11:04. 12 as amendments were issued, we would get those 13 (Break in proceedings.) 13 amendments to put in our document, in our book. They 14 VII )EO OPERATOR: We're back on the record 14 were working documents. 15 at 11:12. 15 Q. Did you periodically receive any kind of 16 MR. PATITERSON: Q. Mr. Fish, how long did 16 guidance documents from the Atomic Energy Commission 17 you work at the NRC? 17 that weren't in the form of regulations that - 18 A. Until I retired in December of 1989. 18 A. The office received copies of the guidance 19 Q. Did you have the same position from 1980 19 documents, and typically those would be circulated to 20 through December of 1989 while at the NRC? 20 the inspectors, and then ultimately wind up in a 21 A. Yes. 21 central location, which one might call a library. 22 Q. We were talking, before we went off the 22 Q. What kind of guidance documents did you 23 record, about the general responsibilities of your 23 receive? 24 group, and we talked about evaluating licensing 24 A. They covered all kinds of guidance 25 activity, evaluating safety practice, handling of 25 documents that would be - they were primarily Page 41 Page 43 radioactive wastes. Would you be involved in actually I intended to provide guidance to the licensees as going to a licensed facility and reviewing their 2 oppose to internally. At some point in time, they procedures? 3 started issuing regulatory guides, and, of course, in A. Yes. 4 addition to those, there were the group guides, for Q. Would your group also be responsible for 5 instance, the NCRP, the National Council on Radiation overseeing the decommissioning of a facility? 6 Protection and measurement had documents. We would A. We would be involved in -- to the extent 7 have access to those, too, as well as the internal that the commission was involved, yes, we were part of 8 documents that were available to licensees. that process. 9 Q. You stated that your group would receive a Q. And what would be your responsibilities as 10 request from the licensing group -- let's back up a part of that process? 11 little bit. Was it your understanding that if a A. The process involved, from our perspective, 12 licensee wished to terminate the license and receiving a request from the licensing group that the 13 decommission the property and have it released for licensee had requested the authority to abandon the 14 unrestricted use, that that request would be made to facility, and would have been required to provide a 15 the licensing group in Bethesda, Maryland by the survey of the facility, which would have been provided 16 licensee? to us, and licensing would request that we make a 17 A. That's correct. confirmatory survey. We would likely make the 18 Q. And then the licensed group, would they confirmatory survey. And once we had confirmed that 19 contact your office? the release requirements established by the licensing 20 A. They would either send a memo requesting a group had been met, we would have submitted a written 21 confirmatory survey to our headquarters people, which report to our headquarters confirming that the release 22 would then be transmitted to the field, or in some criteria had been met. That report would have been 23 cases, they might send the request directly to the then transmitted to the licensing people with a 24 field. statement saying that we recommend that the license be 25 Q. Would the request generally be in writing? Page 42 Page 44 Page 41 - Page 44 Combs & Greenley. Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I 1 A. Always in writing. I did. Ours was a random survey. 2 Q. And would you be provided with whatever 2 Q. So you conducted direct radiation 3 survey the licensees had conducted on the property at 3 measurements. Do you recall what instruments you were 4 that time? 4 using in 1961? 5 A. Yes, we would. 5 A. Yeah. We were using a Geiger-Muller survey 6 Q. Would you review those surveys prior to 6 instrument. 7 conducting your own survey? 7 Q. Any other instrument? 8 A. We would. 8 A. Not that I can remember. 9 Q. How would you be informed of the 9 Q. And you also recall conducting or taking 10 requirements related to the level of radiological 10 wipe samples? 11 contamination which would be allowed on the property 11 A. Yes. 12 in the event it was going to be released for 12 Q. Would these wipe samples be taken randomly 13 unrestricted use? 13 through the facility? 14 A. A copy of the letter of the licensee would 14 A. Yes. 15 also be sent to our office. 15 Q. Would you take wipe samples of both 16 Q. And would the letter to the licensee 16 restricted and unrestricted areas? 17 contain the requirements the licensee was to meet in 17 A. Yes. 18 order to obtain its termination of its license and 18 Q. And would you take direct radiation 19 release of the property? 19 measurements of both restricted and unrestricted 20 A. It would. 20 areas? 21 Q. During the 1961 time period, were there any 21 A. Yes. 22 regulations which provided the levels of radiological 22 Q. Once you had conducted your survey, what 23 contamination allowed on a property intended to be 23 would you do next? 24 released for unrestricted use? 24 A. If there were levels of radiation or 25 A. No. 25 removable contamination in excess of the limits stated Page 45 Page 47 4. 1 Q. Were the requirements imposed on a licensee 1 to the licensee, we would identify those areas and the 2 seeking to terminate the license essentially on a 2 licensee would have to do additional decontamination, 3 case-by-case basis? 3 and then we would come back and make additional 4 A. They were. 4 surveys. 5 MS. McKErrH: Could you reread that last 5 Once all of the results of our confirmatory 6 question? 6 survey show that the release criteria had been met, we 7 (Record read.) 7 would then summarize or document the results of our 8 MR. PATTERSON: Q.When I'm referring to 8 survey in a report and send it to our headquarters 9 "requirements," I mean the clean-up criteria for that 9 with a transmittal memo stating the fact that the 10 facility to meet in order to terminate their license 10 release criteria had been met, and then our inspection 11 and release the property and have the property 11 headquarters would then transmit it to the licensing 12 released for unrestricted use. Those criteria were on 12 people with the same request. 13 a case-by-case basis? 13 Q. Would the transmittal memo contain a 14 A. They were. 14 recommendation that the license be terminated? 15 Q. Now you indicated that your group would 15 A. It's likely that the one going from our 16 conduct a confirmation survey? 16 headquarters to the licensing people would say that 17 A. Confirmatory survey. 17 the release criteria had been met and that we 18 Q. What did that involve? 18 recommend that the license be terminated, but since I 19 A. Well, it involved making a survey similar 19 didn't generate those memos, I couldn't state any more 20 to what the licensee had performed, but just to 20 than I have. 21 confirm his results, and we would make the same types 21 Q. Who would generate those memos within your 22 of surveys. We would make direct radiation 22 group? 23 measurements. We would also take wipes to assess the 23 A. Within our group, the report would have 24 removable contamination. It wouldn't necessarily be 24 been prepared by myself or the inspector performing 25 in the same areas, but it could be, that the licensee 25 the confirmatory survey. That same person would have Page 46 Page 48 Page 45 - Page 48 Combs & Greenlev. Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I

drafted a transmittal memo for signature of the would address the change and why the change and supervisor or director for transmittal to our programs that would be related to it. headquarters. The supervisor would then make Q. Would you interview any representative of appropriate changes that he wanted, essentially, in the licensee prior to conducting -- prior or during the transmittal memo, but if he had questions about the time you were conducting your survey7 the inspection or the confirmatory survey report, that A. Confirmatory survey? would be resolved before it was put in final form, Q. Confirmatory survey. then the package would be sent to headquarters. A. There was contact made with the licensee to Q. Were the confirmatory surveys always establish a visit to make the confirmatory survey, and documented, in your experience? there was always initially a licensee present. For A. Always. the most part, there was always a licensee Q. And would there -- in your experience, representative present, but it's conceivable on large would there also have been some sort of transmittal releases that we would be on our own, but in this from your group to licensing in Maryland? case, that would not be so. There would have been a A. The transmittal from our group in the field licensee person there at all times. would be to the inspection function and headquarters, Q. What part of the Atomic Energy and then the inspection function and headquarters Commission, what division, would actually terminate would then transmit it over. the license? Q. You mean the inspection function and A. The licensing people. headquarters in Bethesda, Maryland? Q. And that would be the licensing group out A. Right. of Bethesda, Maryland? Q. And they would transmit it to the licensing A. In Bethesda, Maryland. portion of the AEC? Q. And would you generally -- would your A. Right. office receive copies of any notice to the licensee Q. Prior to conducting a confirmatory survey, that the license had been terminated at that facility Page 49 Page 51 would you generally attempt to find out information if you had conducted a confirmatory survey? about the property first? A. Yes, we would have gotten a copy of the A. The inspection file would be completely termination letter. reviewed before it went and that would include the Q. And what division would authorize -- would license, the backup documentation to the license, and that same division authorize the release of the then the inspection reports, previous inspection property for unrestricted use? reports. A. The letter typically stated that the Q. So you would review the actual license licenses were terminated and the property could be issued to that licensee prior to conducting your used for unrestricted use. confirmatory survey? Q. Mr. Fish, as you know, this case involves a A. Yes. property located at 170 West Providencia Street in Q. And you talked - Burbank, California. Are you familiar with that A. That includes any amendments that had been property? issued to it. A. Iam. Q. What backup docs would these files Q. And were you involved in conducting the typically contain? confirmatory survey of that property? A. The backup documentation is documentation A. I made the confirmatory survey. submitted by the licensee to the licensing people, Q. Do you recall what regulations or initially, for the initial issuance of the license. guidelines were in place at that time with respect to It would contain the complete program of what they the cleanup criteria for the Providencia property? were going to do and the radiation safety program and A. No, I do not. all of the other things that the licensing people Q. You don't remember? required to be submitted before they would issue a A. I don't remember. license. It also included any documents that the MR. PATTERSON: I'm going to show Mr. Fish licensee submitted to have amendments issued, which a document that we'll mark as Exhibit 1 to Mr. Fish's Page 50 Page 52 I Page 49 - Page 52 Combs & Greenlev, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I I 1 deposition. Have this marked, please. were in 1961? 2 (Whereupon, Defendant's A. No, I don't. I don't remember what they 3 Exhibit 1 was marked were. 4 for identification.) Q. Does reading the four requirements on this 5 MR. PATTERSON: Q. Mr. Fish, I'll ask letter refresh your recollection as to what might have 6 that you review this document for a moment. been the requirement at Providencia Street? 7 A. Yes. A. The second requirement of 2 millirer in any 8 Q. Mr. Fish, this documents appears to be a one hour at a distance of 3 inches is something that 9 letter from the Atomic Energy Commission to Isotopes seems reasonable to me at this point in time, that 10 Specialties Company regarding the criteria that was to that's the number that would have been used because 11 be used at a property located at 703 Main Street typically 2 millirem was an accepted number for a 12 Burbank for purposes of terminating the license. Is maximum radiation level. 13 that a fair summary of the document? MR. SHIMADA: Move to strike as 14 A. Yes, it is. nonresponsive as to what his recollection was. 15 Q. And would this typically be the kind of THE wItNEss: The third one does not. I 16 letter that the licensee would receive during this don't recognize that number. There was a second 17 time period regarding the criteria for that number at a higher distance, but that number is -- I 18 property -- the cleanup criteria for that property? don't recall. 19 A. Yes. MR. PATTERSON: Q. Okay. And would - 20 Q. Now, there's a listing of four criteria on A. The fourth one is what we typically used. 21 the first page. Do you see that? Q. The fourth one, it says: "No radiation 22 A. Yeah, I do. attributable to byproduct material contained in drain 23 Q. The first criteria is that: "The lines or pipes located within the boundaries of the 24 radioactive contamination must not be readily property shall be detectable by surface measurements 25 removable from the property." Can you explain to me, made with a scintillation-type survey meter." So you Page 53 Page 55 if you know, what might be meant by what is "readily would typically at that time conduct surveys of the removable"? drain lines and pipes? A. The purpose of the wipes was to detect or A. We would have. to assess the compliance with this requirement. We Q. This indicates that the radiation level at had some numbers that we used to define "readily 3 inches from the surface was -- what's the removable" because it doesn't say, so we had to define implication of the distance 3 inches? Why do you it. And that would have been acceptable -- the think that would have been used? numbers we were using would have been acceptable to MR. SHIMADA: As phrased, the question the licensing people, but I don't remember what the calls for speculation. numbers are. MR. PATrERSON: Q. Do you understand the Q. What were the -- when you say "numbers," do question or would you like me to try again? you mean levels of detectable contamination? A. I think I understand the question. It's an A. Yeah. When you take a wipe, you put it in attempt to or it is establishing a maximum amount of a scaler and measure it, and you get -- the end result radiation that is allowable at the facility to meet is counts per minute from that wipe. The wipe would the de minimus requirements. It's related to have been taken over an approximate area so that we potential exposure to individuals occupying that space can now get the results in counts per minute per area, in an unrestricted use. Sets the upper limit. typically a hundred square centimeters. We then Q. Let me ask it a different way. Is the - convert it to dpm, which is an efficiency conversion would the distance between the measuring instrument on the instrument. And then that number, the end and the radioactive source have an effect on what you result, which would be in disintegrations per minute were reading on your instrument? per hundred square centimeters, would then be used to A. Yes. There is the -- you set it at an assess the amount of removable activity for that area established distance because if you didn't set an sample. established distance your -- you wouldn't be able to Q. You don't recall today what those numbers relate one reading -- a reading in one location to a Page 54 Page 56 Page 53 - Page 56 Combs & Greenley. Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I I reading in another location. So it had to be an I (Whereupon, Defendant's established distance. And the distance that you 2 Exhibit 2 was marked measured -- you make the measurements in has an effect 3 for identification.) on the reading. The farther away you are, the less 4 MR. FAITERSON: Q.Take a moment to just reading you get. 5 take a look at that document. There's a docket number Q. Do you remember what the detection limits 6 on the top right-hand corner. Do you see that? It of the instrument that you would use in 1961 to 7 says 27-7? conduct a confirmatory survey, what those detection 8 A. Yes. limits were of the instrument? 9 Q. Do you know what that refers to? A. The minimum detectable would have been a 10 A. Yeah. Each licensee for each license was tenth of an mr per hour. There were some instruments I I given -- there was a docket number assigned to it. So that went down to a hundredths of an mr per hour, but, 12 it relates to a licensee and a license of that at this point in time, I can't differentiate between 13 licensee. those two with respect to the instrument I used. 14 Q. Would that docket number be assigned by the Q. When you say "mr per hour," what does "mr" 15 Atomic -- by the AEC? stand for? 16 A. In this case, it would have been assigned A. That means milliroentgens per hour. 17 by the AEC, yes. Q. Would the instrument have a meter on it 18 Q. And there's a sort of a stamp. You see which would show you in some fashion what you were 19 that, where it says "Docketed February 1st, 1961"? detecting? 20 A. Yes. A. Yes. 21 Q. "Division of," I think, it says "Licensing Q. And would the meter be in divisions of 22 and Regulation"? what? Milliroentgens - 23 A. Urn-hum. A. Milliroentgen per hour. And it had several 24 Q. What was that purpose of that stamp, if you scales on it. I mean, one was -- times one, 1 time 25 know? Page 57 Page 59 10, 1 times 100. A. Just to acknowledge receipt of it and its Q. What were the scales used for? docketing. A. To allow the instrument to record higher Q. What is meant by "docketing"? levels of activity. It would change the scale from A. It's an assignment. That's their way of saying -- from one-tenth of milliroentgen per hour to assigning all items related to a specific licensee and one milliroentgen per hour. You could then switch it, specific license. Docketing means that it has been and then it would go from 1 to 10, and times a hundred received and acknowledged and from there it tends to would go from 10 to 100 just to allow you to get become a -- it might be published in the federal higher readings and record on the meter. register to indicate it had been received. Q. And what would -- what would cause you to Q. When you say "received and acknowledged," switch from different scales? Would that be dependent received and acknowledged by whom? upon the amount of radioactivity that's occurring in A. In this case, it was received by the the area you're testing? Division of Licensing and Regulation. A. If the meter shows that I'm off scale high, Q. In the upper left-hand corner. I then have to switch it to a higher level to get it A. Yes. back to on scale so that I could make a determination Q. There's a some reference to -- there's some of what it was. numbers there, it says, "(4-580-6, 7, 8, and C-53 Q. And is this scale sort of a like a -- I'm perhaps 52)," do you see that? trying to imagine -- like an arrow -- like with a A. Yes. speedometer would have where you see an arrow move Q. Do you know what that refers to? across the scale? Is that what these counters have? A. Yes. A. Yes. Q. What does that refer to? Q. Mr. Fish, I'm going to show you a second A. The first one refers to license No. 4-, document which I would like the court reporter to mark looks like, 580-6. That's a license. The 7 refers to as Exhibit 2. license No. 4-580-7. The third one is 4-580-8. So Page 58 Page 60 Page 57 - Page 60 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I

those are three byproduct material licenses. The has a legal licensee listed in license numbers other number, the C-5352 refers to a source material 4-580-6,, 4-580-7,, 4-580-8 and C-5352, and is license. responsible for any license material in the form of Q. This letter is a little bit difficult to radioactive contaminants fixed to real property at the read, so I'm going to read a portion of it. It states 170 West Providencia facilities. References made to that this is a letter to Nuclear Corporation of our letter of December 23rd, 1959, regarding the America, Inc., Isotopes Specialties Company Division, levels of contamination which would be considered de 170 West Providencia, Burbank, California. minimus at your previous 703 Main Street, Burbank, "Gentlemen, we were advised by telegram dated January California facility (copy enclosed). These de minimis 3rd, 1961 from Mr. John Vaden, that Isotopes criteria will also apply to the current situation. Specialties Company, Division of Nuclear Corporation Upon completion of any necessary decontamination of America, Inc., had been sold to U.S. Nuclear procedures you're requested to notify this office of Corporation. Further, by letter dated January 4th, the contamination levels which remain in the 1961, U.S. Nuclear Corporation requested an amendment buildings." of its license No. 4-5241-1 to authorize the Is it your understanding, Mr. Fish, that decontamination of the Nuclear Corporation of America, this letter appears to be stating that the four Inc., Isotopes Specialties Company Division criteria that I showed you in the Exhibit 1 letter Laboratory premises located at 170 West Providencia, were the criteria that were to be used at Providencia Burbank, California." Street? Mr. Fish, did you know Mr. John Vaden? MR. SHIMADA: Objection; calls for A. Yes. speculation, lacks foundation as phrased. Q. How do you know him? THE WITNESS: Yes. A. Through my responsibilities as an MS. MCKEITH: Join in the objection. inspector. A. This letter does require those same Q. Do you know who he worked for at that time? requirements for the decontamination of the 170 West Page 61 Page 63 4- A. At that time, I don't remember who he Providencia. worked for. MR. PATrERSON: Q. So if you were Q. Do you know who he worked for at any time conducting the confirmatory survey at this property, that you recall? would these have been the criteria that you would have A. Well, at some point in time, I know he used even though you don't remember today? worked for the licensing people in the NRC. A. Yes, they would. Q. Let me ask it a different way. Do you have MR. SHIMADA: Same objections. a recollection that Mr. Vaden worked for Isotopes MS. McKErrH: Same objections. Specialties Company at one point? MR. PATTERSON: i'm going to show you A. At this point in time, I do not remember another document that we'll mark as Exhibit 3 to that fact. Mr. Fish's deposition. Q. The letter indicates that U.S. Nuclear (Whereupon, Defendant's Corporation was requesting an amendment of its license Exhibit 3 was marked to authorize the decontamination of the 170 West for identification.) Providencia property. Would an amendment to its MR. PAfITERSON: Q.Have you had a chance license be necessary for it to conduct -- for U.S. to look at this document, Mr. Fish? Nuclear Corporation to conduct this work if it wasn't A. Yes. part of their original license? Q. At the top of the document its heading - A. Yes, it would. although it's difficult to read, I believe it reads Q. I'm going to continue reading for a second "Contamination Guides" at the top. And then there's a here. "From informal communications we understand heading called "Vacating Facilities." Do you see that another division of your corporation will that? continue to occupy these facilities for purposes not A. Yes. covered by ABC licensing. The Nuclear Corporation of Q. And then underneath that are four -- appear America, Inc., Isotopes Specialties Company Division, to be four criteria, clean-up criteria. Those Page 62 Page 64 Page 61 - Page 64 Combs & Greenley, Inc. (415) 512-1234 F. Fish, Jr. October 12, 1999 Raymond Volume I I clean-up criteria appear to be the same criteria that I MR. PATrERSON: Q. Any of the other are listed in the Exhibit 1 letter; is that right? 2 pictures - A. Yes. 3 A. None of the others were used at that Q. If this document were -- did you maintain a 4 facility. I recognize the meters, but none of them file that you used in making sure that you understood 5 were used in that confirmatory survey. what -- did you maintain any kind of personal file of 6 Q. Could you look at the page that has 527 at documents? 7 the top? You see there's two pictures there in the A. No. 8 bottom picture. Do either of those two instruments Q. During this time period? 9 that are on that table look like one you might have A. No. 10 used? Q. Did you keep any kind of folder where you 11 A. The one instrument that is in the center maintained regulations or guidance documents at that 12 top is also similar to the one I used. time? 13 MS. McKEITH: Could we just clarify. It is A. I did not. 14 not the one you used, however? Q. Was one maintained at the office, to your 15 THE wrITEss: It does not look like the one knowledge, for general use? 16 1 used, but it's very similar. A. There were folders for each license which 17 MR. PATTERSON: Q.And the same goes for contained all of the materials that were germane to 18 figure 8A -- it looks like the one you used, but it that license. A copy of the license, the applications 19 may not have been the exact piece of equipment? associated with it and inspection results, and other 20 A. I know this one is not. correspondence. 21 Q. How do you know that? Q. Mr. Fish, do you recall the kind of 22 A. It doesn't look like the instrument I used. instrument you used in conducting the confirmatory 23 Q. Now, these instruments have what I'll survey at 170 Providencia? 24 describe as a box and then what appears to be some A. Yeah. I used a Geiger-Muller tube survey 25 sort of tube connected to the box. What portion of Page 65 Page 67 I 1 instrument. the instrument did you use to actually measure the 2 Q. Do you remember what the detection limit of radioactivity? 3 that Geiger-Muller tube was? A: The detector is the tube. 4 A. No, I do not remember specifically. Q. What type of detector was used in the 5 MR. PAT•ERSON: Can we go off the record instrument that you used at Providencia Street? 6 for a minute? A. It was a Geiger-Muller tube. 7 VIDEO OPERATOR: Going off the record at Q. A Geiger-Muller tube? 8 11:56. A. Yes. 9 (Discussion off the record.) Q. Can you explain to me how that detector 10 VIDEO OPERATOR: We're back on the record works? 11 at 12:04. A. It's a tube that has a center wire to it, 12 MR. PATTERSON: Q.Mr. Fish, I'm going to and it -- as the radiation goes in, it records 13 show you a document which contains some pictures of electrically the event, and then transmits it down the 14 various survey instruments, and I would like you to electrical wire to the box which has the meter. 15 look through them and see if you recognize any Q. Do you remember the -- was there an opening 16 instruments that you may have used at the Providencia or a window in the tube that would allow the materials 17 facility. to come in to the tube? 18 And I'll have the reporter mark this as the A. The tube is shielded, and it has both -- it 19 next number, please. has a window in it that can be used both open and 20 (Whereupon, Defendant's closed. 21 Exhibit 4 was marked Q. Do you remember the window thickness of the 22 for identification. instrument that you used at Providencia? 23 THE wrrNESS: Figure 8a is similar, but not A. I do not. 24 exactly like the one I used. It has the same type of Q. Do you remember the detector size for the 25 a detector with the same connection to the meter box. tube? Page 66 Page 68 Page 65 - Page 68 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I I A. I do not. When you say the window size, A. Periodically, the instruments were are you talking about the detector or are you talking calibrated. about the shield around it on the previous question? Q. Who did the calibration? Q. In the window thickness? A. I don't remember. A. Yes. Q. Would you do the calibration? Q, I'm talking about the detector portion. A. No, I would not do the calibration. A. The detector portion, yeah. I do not Q. Did you wear any kind of headset when you remember the - conducted your survey at Providencia? Q. Do you recall the thickness of the shield A. No, I did not. around the tube? Q. Referencing the criteria that are listed in A. Not specifically except that it was a metal Exhibits 1, 2, and 3. shield that you used to open and close. A. Yes. Q. Where was the window located on the tube of Q. Assuming those are the criteria that you the instrument that you used at Providencia? would have used in conducting your confirmatory A. Well, it would be similar to the picture survey, can you tell me first how you conducted your shown. It would be a tube like this with a shielding direct readings at the Providencia property? around it, and the shielding would have a movable MR. SHIMADA: Objection; question calls for piece that became the window, and you could move it speculation, lacks foundation. aside so that you had direct exposure of the THE WITNESS: When I made the surveys, I Geiger-Muller tube to the radiation, or you could would make the measurements -- assuming these are the close it in which case you put the additional density criteria, I would make the measurement at three inches of the window to shield out the lower energy and use the criteria shown in No. 3, which is a value radiation. at 18 inches. And the reason for doing that is if Q. Was the tube that you used I'm going to it -- it would allow me to differentiate between refer to this as a side or end window? possible problems, so that if I found numbers above Page 69 Page 71 I A. It would be a side window. the 0.25 millirem, then I would make an additional Q. Side window. So the window wasn't at the evaluation to see that it met the 2 millirem at 3 bottom portion of the tube? inches criteria. But if it met the 0.25 millirem A. No. criteria at 3 inches, it automatically met it at 18 Q. It was on the side of the tube? inches. So it was just a simpler way of restricting A. Yes. the additional work I had to do with respect to Q. Would you use the tube differently, in evaluating radiation levels that are above the 0.25. terms of how you held it, to take a measurement Q. Just so I understand: So you would have depending on whether it was an end window or a side measured and looked for .25 millirems at any one hour window? at 3 inches? A. Yeah. Those instruments would be used A. I would. differently because what you do would be to -- in the Q. Do you also recall taking wipe samples case of an end window, you would expose the end of the during your confirmatory survey at Providencia? tube in order to get the measurement. In the side A. Ido. window, you expose the side of the tube. Q. And how were those wipe samples analyzed? Q. So you would hold the tube horizontally to A. They were taken back to the office and the area that you were testing? counted in a scaler. A. In the case of side -- the whole length of Q. At the office? the side of the tube, yes. A. At the office. Q. Did the Atomic Energy Commission own the Q. How large were the wipes that you used when instrument that you used to conduct your confirmatory you took a sample? survey at Providencia Street? A. The filter papers were approximately A. Yes. one-and-a-half to two inches in diameter. And they Q. Were these instruments -- was this would be filter papers typically used in a chemistry instrument calibrated? lab, and I would just use finger pressure to wipe the Page 70 Page 72 Page 69 - Page 72 Combs & Greenley. Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I 1 filter paper on the surface. I We're going offthe record at 12:17. 2 Q. How large of a surface area would you wipe 2 (Luncheon recess taken at 12:17.) 3 with the one particular wipe sample? 3 --oOo- 4 A. One wipe would typically be used over a 4 AFTERNOON SESSION 1:12 p.m. 5 one-square meter, and we would make about 10 short 5 VIDEO OPERATOR: Here begins Videotape No. 6 swipes over that one square meter area. 6 2 in the deposition of Raymond Fish. We're back on 7 Q. Using the same wipe? 7 the record at 12 minutes past 1:00. 8 A. Using the same wipe. 8 MR. PATFERSON: Q. Good afternoon, 9 Q. And then what would you do with the wipe 9 Mr. Fish. I'm going to show you a document we'll have 10 after you had done that? 10 marked next in order. 11 A. Put it in a container -- in a holder, 11 (Whereupon, Defendant's 12 either a -- well, for the most part, it was put in a 12 Exhibit 5 was marked 13 small manila envelope so it wouldn't get contaminated 13 for identification.) 14 or would be preserved. 14 MR. PATrERSON: Q.For the record, this 15 Q. And then - 15 is *Part 20, Title 10 - Atomic Energy Commission 16 A. And then taken back to the office for 16 Regulations.* At the top it says: *AEC reprint 17 counting. 17 containing amendments issued through July 30, 1958.u 18 Q. Would you take them back yourself- 18 Mr. Fish, would these regulations have been 19 A. Yes. 19 regulations that you would have reviewed as part of 20 Q. -- if you were doing the wipe samples? 20 your responsibilities at AEC in 1959, 1960? 21 A. Yes. 21 A. Yes. 22 Q. Would you do the analysis of the wipe 22 Q. And do these regulations look familiar to 23 samples yourself? 23 you today? 24 A. Yes. 24 A. They do. 25 Q. Do you remember doing that for Providencia 25 Q. I'd like to refer you to Section 20.102, Page 73 Page 75 I Street? I which is on page 3, essentially, of the document. It 2 A. Yes. 2 refers to permissible levels of radiation in 3 Q. Do you remember talking to anybody employed 3 unrestricted areas. Do you see that? 4 by Isotopes Specialties Corporation prior to 4 A. Yes. 5 conducting your survey where the topic was the survey, 5 Q. And Subsection B provides that: "Except as 6 the decontamination procedures? 6 authorized by the Commission pursuant to paragraph 7 A. No, I don't remember that. 7 (small a) of this section. No licensee shall possess, 8 Q. Do you have a specific memory of reviewing 8 use, or transfer licensed material in such a manner as 9 the Isotopes Specialties file before conducting the 9 to create in any unrestricted area from radioactive 10 confirmatory survey? 10 material and other sources of radiation in his 11 A. I do not have a specific memory of going 11 possession: (1) Radiation levels which, if an 12 through the file. 12 individual were continually present in the area, could 13 Q. But that would have been your practice at 13 result in his receiving a dose in excess of 2 14 the time? 14 millirems in any one hour.* You see that? 15 A. I would have had to do that in order to be 15 A. Yes. 16 prepared for the confirmatory survey. 16 Q. Does that refresh your recollection on what 17 Q. Do you remember in reviewing that -- do you 17 level was considered safe at that time? 18 have any recollection of any reports of any releases 18 A. It -- the maximum of 2 millirems in any one 19 or spills onto the property? 19 hour is the maximum radiation level that was deemed 20 A. I have no recollection of that. 20 acceptable to -- in unrestricted areas, which means 21 Q. It's a tough one. 21 areas that were accessible by nonradiation workers, 22 She's out of tape. I suggest we maybe 22 including the general public. 23 break for a quick lunch since I'm very hungry. 23 Q. So that level was considered safe or 24 VIDEO OPERATOR: This marks the end of 24 considered the level that would be considered -- would 25 Videotape No. 1 in the deposition of Raymond Fish. 25 not be harmful to any person coming in contact with Page 74 Page 76 Page 73 - Page 76 Combs & Greenlev, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I I - I Q. What do you mean by "very large group"? 1 that level for that period of time? 2 A. Millions. It's, you know -- it's a bigger 2 MR. SHIMADA: Objection; mischaracterizes 3 look at the picture of effects of radiation on people, 3 the testimony. 4 and so the group would be very large. And it's done 4 THE WITNESS: That's the maximum level. 5 by the National Council on Radiation Protection in 5 There's a second requirement in there that goes along 6 measurements who put all the basis for these kinds of 6 with it which alters the potential exposure somewhat. 7 things together. And so they do studies and out of 7 MR. PATTERSON: Q.And what's that? 8 this comes their recommended number. It's a group of 8 A. Well, in (2) it says that "radiation levels 9 professionals, the top people in the United States 9 which, if any individual were continuously present in 10 form this group, and they do the studies and make the 10 the area could result in his receiving a dose in 11 recommendations. 11 excess of 100 millirems in any seven consecutive Q. And would the Atomic Energy Commission 12 days," and that's less. 12 13 utilize those recommendations - 13 Q. And the 2 millirems per hour corresponds, I 14 A. They would. 14 guess, to the reference in the clean-up criteria in 15 Q. -- in its application to various licensees? 15 Exhibit 1 where it notes that the radiation level at 3 16 A. Yes, they would use those bases for 16 inches from the surface of the floor and wall shall 17 creating the regulation. 17 not exceed 2 millirems in any one hour; is that right? Just so I understand. So the average 18 A. The numbers are the same. 18 Q. -- and, I'm sorry was a hundred and - 19 Q. The numbers are the same. Was there a 19 number 20 A. 70. 20 number -- a level that was used for a period of a 21 Q. -- 70. If you were trying to determine 21 year? In other words, you couldn't be exposed to a like the 170 West Providencia 22 certain amount over a period of a year at this time 22 whether a facility that, what number would 23 period? 23 facility was complying with then? I mean, you don't expect a million 24 A. The number was not in the regulations per 24 you use, to go through West Providencia? 25 se, but there was a number that was used in 25 people Page 77 Page 79

I establishing numbers in the regulations, and the 1 A. No, but the numbers -- the intent to 2 the exposure to people -- nonradiation workers 2 number was a maximum of exposure to any individual in control say, the Providencia location would be 20.102. 3 the general public of 500 millirem per year, maximum, 3 at, 4 that you would use, and these 4 to any one individual, but the average of individuals These are the numbers that apply to the licensed activities to 5 was to be down to 170 millirem per year. 5 are numbers 6 that the quote, general public, or office 6 Q. Could you explain what you mean by the assure excessive exposure. And so 7 average of any - 7 workers would not receive upon an operating licensed 8 A. Any single individual, the maximum would be 8 this requirement is imposed 9 as opposed to a facility where you're 9 500 millirem, but if you take a group of people, the activity of releasing it. 10 average exposure to that group -- and, in this case, 10 decontaminating it for the purpose 11 Q. I understand. Previously, you testified 11 of course, the group would be a large number -- the 12 between roentgens and rem, and 12 average would have to be 170 millirem not 500. So about the relationship gamma or beta radiation 13 everybody couldn't get 500 millirem. 13 I think you indicated that for 14 essentially an equivalency of 1? 14 Q. Isee? there was A. Yes. 15 A. The average of everybody would have to be 15 of 16 down to 170 millirem. 16 Q. If you look at Section 20.4, *Units 17 -- it's on the back page of the first 17 Q. Okay. So if you had an unrestricted area Radiation Dose" 18 middle column about halfway there - 18 where you had a lot of people going through, you would page. In the 19 MS. McKErIH: Could you refer to the page 19 have to make sure that you were not exposing them to 20 the average number; is that what that means? 20 number? 21 A. Well- 21 MR. PATTERSON: It's the second - stamp? 22 Q. No, it doesn't. 22 MS. McKEITH: What's the Bates -- page. I don't have a 23 A- It really doesn't because the group that 23 MR. PATTERSON: copy. 24 you're dealing with in establishing 170 millirem is a 24 Bates-stamped What was the 25 very large group. 25 MR. SHIMADA: No Bates. Page 78 ______I Page 77 - Page 80 Combs & Greenlev. Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I I the Providencia 1 number? 1 conducted the confirmatory survey of 2 THE WITNESS: It's paragraph 20.4. 2 property, was California an agreement state at that 3 MR. PATTERSON: It's paragraph 20.4. It's 3 time? 4 on the back of the first page of the document, and the 4 A. Since I don't remember when I made the 5 middle column about halfway there. 5 confirmatory survey, I don't know. I know that 6 Q. It discusses what looks like what we're 6 California became an agreement state in September of 7 talking about. It says: "For the purpose of the 7 1962. 8 regulations in this part, any of the following is 8 Q. Would you have conducted a confirmatory 9 considered to be equivalent to a dose of one rem." Is 9 survey after California became an agreement state? 10 that what you were referring to in terms of one dose 10 A. Not by myself. If California had been an 11 of-- it says *one dose of I r.* Is that w1 ru a 11 agreement state, California might have asked us to 12 roentgen? 12 provide a joint confirmatory survey, but I don't 13 A. Yes. 13 remember that such a request was made. 14 Q. "Due to X or gamma radiation, and then it 14 Q. Do you recall if, at the 170 Providencia 15 says, "dose of one" -- what's a rad? 15 property, did you conduct that by yourself or were 16 A. That's an energy term. In 20.4 b, it talks 16 there people from the State also involved in 17 about rads, and it says that 1 rad is the dose 17 conducting that survey? 18 corresponding to the absorption of 100 ergs per gram 18 A. No, I conducted the survey myself. There 19 of tissue. So it's 100 ergs of energy received in a 19 were no state people. 20 gram of tissue. 20 Q. Can you explain to me what counts per 21 Q. Can you explain to me the difference 21 minute measures? 22 between a roentgen and a rad? 22 A. Counts per minute is the values that the 23 A. They are basically different measurements. 23 detector sees. Each gamma ray that comes from the 24 One is talking about energy deposited in tissue. 24 contaminated particle or the radioactive particle 25 Q. Which one is that? 25 gives off a gamma ray. The gamma ray goes into the Page 81 Page 83

I A. That's the rad. And the roentgen or rem is detector. That event is counted in the detector. 2 a measurement in air. So it's really counting events Creates a certain amount of energy, electrical energy, 3 or the amount of radiation in air as opposed to in which is then picked up by the central wire, in the 4 tissue. case of a GM tube, in an ionization chamber, and then 5 Medical people, when they treat people for, it's sent to the meter for counting. And those are - say, cancer with radiation, they do it in terms of those events are in counts per minute, typically. And rads because it's the energy deposited in the tissue. then there's an efficiency conversion which transfers Q. When you conducted a -- strike that. it from counts per minute into milliroentgen. Was there a requirement in 1961 that the Q. I'm sorry an efficiency - licensee who is conducting a survey for purposes of A. There's a correction factor that you use. terminating a license also drill soil borings to Q. When you had the Geiger-Muller instrument obtain subsurface radioactive material readings? in 1961, would the instrument tell you how many counts A. There was no regulation requirement for per minute it was picking up? that. If such a requirement were to be made, it would A. No. It recorded directly in milliroentgens have been in the letter from the licensing people to or roentgens per hour. the licensee instructing him to do those kind of Q. How would you -- was there a way to measure tests. counts per minute at that time? Q. Absent a determination that there had been, A. No, I don't recall that there was a way of let's say, a release into the subsurface area of the measuring counts per minute. If you put a headset on, facility, would that have generally been a requirement you would be hearing the counts per minute, but the of the licensee to conduct subsurface soil sampling? dial would not read in counts per minute, but you MR. SHIMADA: Objection; calls for would hear the individual events as it was recording. speculation, lacks foundation. Q. I see. So there's nothing on the dial THE WITNESS: Not normally. itself which would tell you how many counts per minute MR. PAWTERSON: Q.At the time that you it might be reading? Page 82 Page 84 Page 81 - Page 84 Combs & Greenlev. Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I

A. No. I Providencia? Q. Now, can you then explain to me what 2 A. Since I don't remember when I made that disintegrations per minute means? 3 survey, the answer has to be no, I don't. A. Disintegrations per minute is counts per 4 Q. If you had conducted the survey, would you minute times the efficiency factor of the instrument 5 have been the one to notify the state of California or that's counting it. So you have a source that you 6 would someone else in your offite have that know the disintegrations per minute and you put it in 7 responsibility? the instrument, and so it records so many counts, and 8 A. It would not have been me. you know that it has so many disintegrations and you 9 Q. Do you know who it would have been? compare those two numbers. You get a correction 10 A. In some cases, the notification would have factor to transfer it from counts per minute into 11 come from Bethesda, Maryland. And in some cases, it disintegrations per minute. The counts per minute is 12 would have come from our office -- somebody in our less than the disintegrations per minute. 13 office. Q. And for purposes of your conf'rmatory 14 Q. After a license expired or was terminated, survey in 1961, you would be measuring the 15 and the property released for unrestricted use, would milliroentgens? 16 your group have any further involvement with that A. Yes. 17 property assuming there was no licensing activity Q. But you would not be measuring counts per 18 occurring on the property? minute or disintegrations per minute; is that right? 19 MR. SHIMADA: At what point in time are we A. No, except in the case of the wipe sample. 20 talking about? Q. The wipe samples would be analyzed in terms 21 MR. PAWTERSON: '61. of which -- counts per minute or disintegrations - 22 THE WITNESS: Once the license is A. The analysis would come out in counts per 23 terminated, we no longer have any -- would have had minute and then you would convert it into 24 any responsibility for it. We would have no interest, disintegrations per minute. 25 unless somebody from the general public asked us for Page 85 Page 87

I Q. Would you convert that -- or is there a way information and we would try to respond to public 2 to convert that into milliroentgens, into the requests. 3 equivalent milliroentgen factor? MR. PATTERSON: Q.With respect to 4 A. Not really. Providencia, do you have any memory of being informed 5 Q. Not really. Prior to California becoming of the fact that there was going to be a 6 an agreement state, would the Atomic Energy Commission decommissioning at the 170 Providencia property? Do 7 still notify California of its intent to terminate a you remember how you were informed of that? 8 license and release a facility? Do you know? A. The process in notifying us would have been 9 A. At some point in time, they did those kind the licensing people would provide us with a copy of 10 of things to keep California informed, but I don't the letter to the licensee providing the release 11 remember when that occurred. criteria, and then the licensing people would, by 12 Q. You don't remember whether it was before or memo, request that we make a confirmatory survey after 13 after California became an agreement state? they had received the survey report from the licensee. 14 A. It would have been before, but, you know, MR. SHIMADA: I move to strike - 15 there was a period of time when California started the MS. McKEITH: Move to strike as 16 process of - an interest in becoming an agreement nonresponsive. 17 state, and then it took some time before they actually MR. SHIMADA: Join. 18 became an agreement state and, of course, during that MR. PATTERSON: Q.Would the survey 19 period of time there was a greater effort to keep them report that you received from the licensee have a plot 20 more informed of everything that was going on within plan or a map of the facility? 21 California, even though it was still under the A. Yes, it would. 22 jurisdiction of the AEC. Q. And would that survey - 23 Q. Do you know whether California was in the MS. McKErrH: I would like to object to the 24 process of becoming an agreement state at the time extent that he asked you whether you remembered as it 25 that you conducted the confirmatory survey at related to this property, not generally. Can we just PaE3e 86 Page 88 Page 85 - Page 88 Combs & Greenlev, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I i make it - I another document which we'll mark next in number. 2 MR. PATrERSON: That last question was 2 (Whereupon, Defendant's 3 generally. 3 Exhibit 6 was marked 4 MS. MCKEITH: I'm not trying to trick 4 for identification.) 5 anybody. I just want to know what the witness 5 MR. PATTERSON: Q.rIll ask you to take a 6 remembers as it relates to this property, if that's 6 look at that document. Do you recognize this as the 7 what you're asking, as opposed to what he testified to 7 map of the Providencia Street property at that time? 8 earlier this morning at length, which was his general 8 A. For the most part, yes. 9 recollection about he had done at that time. You 9 Q. Are there parts that don't look familiar to 10 understand the difference we're - 10 you? 11 THE WITNESS: Yeah. What you're concerned 11 A. The upper left-hand comer where it says, I 12 about is do I remember seeing the specific memo 12 guess, that's "Bay" and "Class" something or other, 13 requesting, and the answer to that is no. 13 which is in front of Bay-A, that I don't have any 14 MR. PATTERSON: Q. Generally, would the 14 recollection of that. The rest of it is just pretty 15 survey received from the licensee also provide you 15 much as I remember it. 16 with the description of the manner in which they 16 Q. Just so I understand, underneath Bay-A 17 conducted the survey? 17 there's a rectangle, and inside of that is the word 18 A. I guess the answer to that is generally no. 18 "Bay." You don't recognize that as part of the 19 They would describe the instrumentation that was used 19 facility at that time? 20 and they would show the results. 20 A. No. U1 Q. Would there be anything in the survey you 21 Q. And that's also true of the rectangle that !2 received from the licensee that would show you where 22 has "Class" written in it? !3 they took wipe samples? In other words, would they 23 A. Yeah. !4 plot out on a map where the samples were taken? 24 Q. Do you see where there's a couple of !5 A. There would be either a -- there would 25 other -- there's a notation here that says "fences Page 89 Page 91 4 I either be an identification on the plot plan or there installed 4/99 for control of site." Do you see that? 2 would be a verbal description of the location. A. Yes. 3 Q. So you would have some understanding of how Q. I'm assuming those fences were not in place 4 they took the survey and where they took samples from or there weren't any fences there at the time you 5 before you went out to do your survey? conducted your survey? 6 A. Yes. A. There were no fences there. 7 Q. In reviewing the survey from a licensee who Q. What I would like to do, Mr. Fish, is kind 8 was providing the survey for purposes of terminating of go through this plot plan and have you describe to 9 the licensing -- license and releasing the property, me what you did when you conducted your confirmatory 10 what would be your -- how would you basically evaluate survey. And let's start first with the area that's S11that survey? What would you be looking for? marked the "office area." Do you see that? 12 A. There would be two things we would be A. Yes. 13 looking for. We would be looking for the numbers, the Q. Did you conduct any direct measurements in 14 actual numbers, to see how they relate to the release the office area at the time you conducted your 15 criteria, and we would be looking at locations to see confirmatory survey? 16 the thoroughness of the survey. A. Yes, I did. 17 Q. In 1961, would the measurements that were Q. And can you just generally describe how you 18 provided to you by the licensee be in the form of the would have conducted your direct readings? 19 milliroentgens? A. Yeah. I would have used the -- held the 20 A. That's the form it would be in, yeah. detector in my hand with an open window and at 21 Q. And then if they -- did they also inform approximately 3 inches or whatever distance was the 22 you of the results of wipe samples in this survey higher number distance, and then, just being bent over 23 report by the licensee? would have slowly gone over areas of the floor and 24 A. I don't remember. dividing the floor in sort of square areas or 25 Q. Mr. Fish, I'm going to provide you with rectangular areas of a given dimension like, maybe, Page 90 Page 92 Page 89 - Page 92 Combs & Greenlev, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I I whether that lab was there i every three or four feet square, I would go randomly 1 Q. Do you remember 2 at the time you conducted your survey? 2 over that, and then gradually work down through the A. I do not remember that. 3 whole room. 3 4 Q. And then just to right of that, there's a 4 Q. Would you also -- then you would be marked "lab," do you see that? 5 watching the meter as you did that? 5 section 6 A. Yes. 6 A. Yes. 7 Q. Do you recall that being there at the time 7 Q. To determine whether it would pick up any conducted your survey? 8 radioactive material readings? 8 you A. I don't remember that. 9 A. Yes. 9 that it says "cooler.' Do you 10 Q. Do you remember whether, when you conducted 10 Q. Above II remember seeing that - 11 your direct survey of the office area, whether you 12 A. I don't remember that. 12 picked up radioactive material readings? about the lockers and 13 A. No, I don't remember. 13 Q. -- facility? What 14 the rest rooms, were they there? 14 Q. Would you also conduct direct reading I don't have any recollection of that. 15 measurements of the walls in the office area? 15 A. 16 Q. Do you see where it says *Sump with Cs 16 A. I wouldn't have checked in the office area 17 walls, no. 17 137"? 18 A. Yes. 18 Q. Did you take any wipe samples in the office remember a sump being in that 19 area? 19 Q. Do you the building? 20 A. I don't remember. 20 approximate location in I do not remember that -- a sump in that 21 Q. Would it have been your general practice to 21 A. 22 location. 22 take wipe samples in this type of area? with respect to the building 23 A. It would have been -- my normal activity 23 Q. Once again, of a concrete floor open 24 would have included a few wipe samples there. 24 area you've described as sort area, can you describe to me what you did in 25 Q. Moving up to the area marked "Tritium and 25 Page 95 Page 93 + C-14 labs." Do you see that? 1 conducting your direct reading survey of that portion A. Yes. 2 of the property? Q. Did you conduct a direct reading survey of 3 A. Well, I would have started in one location front or that area? 4 and then worked my way either from back to A. I don't remember that area. 5 from one side to the other and taken a specific area the meter Q. What do you recall the interior building 6 and just randomly, in a slow fashion, moved looked like at that time? 7 over to see if I detected any radiation that exceeded A. What I remember is that the -- there was a 8 the lower number at the shorter or distance. Move to strike as front office area, and then there was a large open 9 MR. SHIMADA: space in the back part of the building. And 10 nonresponsive. way across previously, walls or, in this case, where it says "hot 11 THE wrINESS: And then work my and then moved over for another cells" and things like that, had all been removed. So 12 or down the building the the main part of this -- back part of the building was 13 section, and did that until I covered, basically, all open and there was nothing else in there except 14 whole area. for the pool. 15 MR. PATTERSON: Q.Do you have a specific Q. So where it says "former hot cells" - 16 memory of doing that at this facility? A. Yes. 17 A. Yes. to me is based Q. -- all of the walls in that area had 18 Q. So what you're describing already been removed when you did your survey? 19 upon your memory? A. All that was there was the flat concrete 20 A. Yes. floor. 21 Q. Do you remember -- leaving the pool aside Q. Do you remember whether there were -- next 22 for a moment. Do you remember any areas within that to the tritium and C-14 lab, there's a notation called 23 portion of the building that exceeded the criteria? "QA lab," do you see that? 24 A. I don't remember any. A. Yes. 25 MS. McKEmTH: Is it that you don't remember Paae 94 I -- Page 96 Page 93 - Page 96 Combs & Greenlev. Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I

r - . - - I any areas or you don't remember one way or the other? I Q. Do you remember how big the pool was 2 THE WITNESS: I don't remember the numbers. 2 approximately? 3 A. Specifically, I do not. I can make an 3 So what I do remember is that the first survey that I 4 estimate of what the pool -- what I sort of remember 4 made, there were areas that did not meet the criteria 5 the pool size, but I - 5 and the licensee had to do additional decontamination 6 Q. What's your best estimate? 6 to meet the criteria. So I had to come back either a 7 A- My best estimate, it was about, maybe, four 7 second or a third time. I don't know how many times, feet by, maybe, seven to ten feet long. It 8 but it was at least a second time in order to make 8 or five 9 wasn't a large pool. 9 additional measurements to confurm that the 10 Q. Did you see any indication of cracks or 10 decontamination that had been done now satisfied the 11 repairs in the pool walls? 11 release criteria. 12 A. I did not see any repairs. All concrete 12 MR. PATrERSON: Q. Do you remember what 13 has cracks to some extent. There's at least surface 13 areas within the building had levels that exceeded the it. I can't say that I saw and was aware of 14 criteria at that time? 14 cracks on just has surface cracks, so. 15 A. The only one that I remember - 15 the cracks, but concrete Q. Do you remember, as you sit here today, 16 specifically that I remember, that did not meet the 16 cracks in the pool? 17 release criteria at the time I made my first survey 17 seeing 18 was the cobalt pool. 18 A. No. Did you ask the licensee if they had ever 19 Q. How did you survey -- first of all, was the 19 Q. any leakage from the pool? 20 pool filled with water at the time that you conducted 20 experienced I asked them that or 21 your survey? 21 A. I don't know whether 22 A. No, the pool was empty. 22 not. if the pool had any pipes 23 Q. Do you remember what the walls of the pool 23 Q. Do you remember 24 were constructed of? 24 or drains coming into the pool? point in time, I 25 A. No, I don't remember specifically what they 25 A. I don't know. At this Page 97 Page 99 - + I were. I remember that there was a concrete pool, but don't remember whether -- my recollection is that it pool, which means that it 2 whether they had some additional coating on that was -- it was a stationery have pipes that would circulate the water. 3 concrete, I don't remember specifically. would not pit that had water in it for 4 Q. Do you remember the pool being dry? It was just a concrete were stored in there. 5 A. Yes, because that's the only way I could shielding and the sources were -- at that 6 make my survey measurements. Q. Do you know what sources that were 7 Q. Why is that? Would the water - time, were you familiar with the sources 8 A. The water would interfere. stored in that pool? is cobalt 9 Q. -- interfere with the measurements? Did A. The ones that I can remember there 10 you go down into the pool to do your survey? sources. I can't honestly say that I remember c-e-s-i-u-m, sources, but I know 11 A. No. I lowered the detector into the was cesium in there, And so 12 edge -- around the edge of the pool. that they were working with cesium sources. stored in the 13 Q. When you say "lowered the detector," is the larger sources would have had to be 14 that the tube portion of - pool. in the 15 A. That's the tube because it has the lead on Q. Why would they have had to be stored 16 it that would allow me to lower it. pool? only way to 17 Q. And how did you lower it down? Did you A. Too much radiation. It's the exposure to the 18 just lower it down slowly and watch the counter? keep the radiation down and prevent 19 A. Yes. radiation workers. 20 Q. The gauge? Q. The instrument, which I think you described instrument 21 A. Down and then across to get the whole as a Geiger-Muller instrument, would that 22 surface. be able to differentiate between different isotopes? 23 Q. Did you attempt to survey the whole bottom A. No. 24 portion of the pool? Q. What would the -- so the instrument would 25 A. I don't remember that. be measuring, essentially, gamma and beta Page 98 I Page 100 Page 97 - Page 100 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I I radioactivity? A. Yes. 2 A. Yes. Q. Do you remember coming back more than once 3 Q. Could it detect alpha activity? or at least once? 4 A. No. A. I remember making at least a second visit, 5 Q. Now, you said that you recall or you and there may have been a third visit, but I remember 6 remember in the cobalt pool you determined that there the second visit. I don't remember -- but there could 7 was additional cleanup required in the pool; is that have been a third visit before we got all of the 8 right? elevated areas eliminated. 9 A. That's correct. Q. Do you remember a company called Research 10 Q. Was that in the interior of the pool? Chemicals operating at this facility? 11 A. Inside surfaces. A. I don't specifically remember. 12 Q. Was it at the bottom of the pool, do you Q. Were they operating at that facility when 13 remember? you conducted your survey? 14 A. I know it was on the sides. With respect MR. BROWN: Asked and answered. Objection. 15 to the bottom, I don't know. MS. McKErTH: Objection. 16 Q. Do you remember the levels that you were THE wrrNESS: All activities at that 17 reading? location had ceased at least with respect to the main 18 A. No, just that they exceeded the limits. part of building. I don't remember about the 19 Q. Do you have a memory of how much they activities in the bays at the back of the building, 20 exceeded the limits in terms of a lot or a little? but all activities in the front building had ceased. 21 A. No. MR. PATrERsON: Q. Do you remember seeing 22 Q. What did you do when you determined that any drums stored on any portion of the facility? 23 there were elevated levels above the clean-up criteria A. No, I do not remember that. 24 in the pool? Q. You don't remember whether they were there 25 A. I told the licensee that the levels or not, or are you sure -- were they there? Page 101 Page 103 exceeded the limits and that they needed to do A. They could have been, I just don't -- if additional decontamination work because we couldn't they were there, I don't remember them being there. release it in its present situation. Q. Did you also take wipe samples of the Q. Do you remember who you talked to? interior portion of the building in that large open A. No. area that you described? Q. Do you remember talking to a Richard A. Yes. Donaldson? Q. And could you tell me how you took those A. I have talked to Richard Donaldson, but I wipe samples? don't know whether it was he at that time. A. Yeah. I would take the small filter paper Q. You just don't have a memory today of who and with a certain amount of finger pressure would you talked to at that time? estimate an area of approximately one square meter, A. No. There was somebody there and I don't and over that one square meter randomly take 10 wipes know who, or at least I can't remember who it was at with the filter paper, and that would constitute that this point in time. sample. And then I would do that on another area of Q. At some point did you -- were you informed approximately the same size with the same number of that additional clean-up activities had been conducted wipes, and then randomly do the whole surface. in the pool? Q. Would you do any kind of grid of that A. Yes. interior portion and then kind of randomly decide Q. Do you know what those activities consisted where to take samples? of7 A. I didn't set up a grid. Ijust-there A. I know that they chipped out parts of the was a -- it wasn't totally random when I did it. It concrete that had the high levels of activity and then would be kind of like, I would do a -- take out a one they would have disposed of them. meter square area and then move in a regular fashion Q. And did you come back and do an additional down, and then go over a ways and work my way back up, survey of that area -- of the pool area? similar to the way the survey -- the direct radiation Page 102 Page 104 Page 101 - Page 104 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I I levels were made and cover it that way so that it A. All of the drain lines and pipes that were 2 wasn't totally random and it wasn't regimented by there and accessible were tested or measured. 3 having it set off by squares and specific squares. Q. Were these measured with direct readings 4 Q. Would you take a wipe sample and then use from the Geiger-Mullcr? 5 it to take a portion of the, you say, square meters A. Yes. 6 you're describing? Q. And how would you test the drains? 7 A. Yeah, one wipe would be used for an area of A. You would lower the instrument, the 8 about one square meter. detector, into the drain. 9 Q. Just so I understand, would you move up to Q. Would you attempt to lower it as far as it 10 the adjacent square meter and then take another wipe could go or was there a set measurement that you went 11 sample or would you just move down a little bit? into the drain? 12 A. It might be the next square meter and it A. I don't remember whether it was as long as 13 might be the next meter and a half. It wasn't the cord would allow me to go, but I remember all of 14 regimented to every square meter, but it was routine the drains were checked. 15 to the extent that it would allow me to say that I had Q. And did you find any levels of 16 more than just totally randomly surveyed the surfaces. radioactivity above the clean-up criteria in those 17 Q. Were those wipe samples, then, taken back drains? 18 to your office and tested? A. I don't remember specifically that any of 19 A. I took them back to the office and I them exceeded the limits which would have required 20 counted them. some additional activity. I don't remember. All I 21 Q. Did any of the wipe samples that you took know is - 22 in this large portion of the building exceed the Q. You're certain you tested them? 23 clean-up criteria? A. I tested every one of them. 24 A. From the first set of samples, I do not Q. And if one of the drains had shown elevated 25 remember whether any of them exceeded what we would radioactivity, it would have been your practice to Page 105 Page 107 1 determine to be acceptable. I inform the licensee and make them do some additional 2 Q. Now, you say the first set of samples, was 2 clean-up; is that correct? 3 there a subsequent set of samples? 3 A. If it exceeded the limits, it would not 4 A. There may have been. If there were any 4 have been allowed, and they would have had to do 5 samples that exceeded what we would find to be 5 additional work to clean it up. 6 acceptable levels, we would have notified the licensee 6 Q. Did you -- referencing this Exhibit 6 7 of the area that it came from and we would have made 7 again, looking to the south of the building, there is 8 another set after he had done additional work. 8 what looks like a driveway or a -- do you see that? 9 MS. McKErrH: I'm going to object. He's 9 A. Yes. 10 asking you about the specific facility. You're 10 Q. Did you conduct a survey, direct readings 11 speaking generally. We want your recollection - 11 from the Geiger-Muller of that area? 12 THE WITNESS: I'm talking about that 12 A. There were surveys made in that area, yes. 13 facility. 13 Q. And were those surveys done with the 14 MS. McKEITH: Okay. Then I'm unclear as to 14 Geiger-Muller? 15 whether or not he found elevated levels the first time 15 A. Yes. 16 out or not. 16 Q. Would you have conducted those surveys in a 17 THE WITNESS: And I said I didn't know. 17 similar fashion to that that you described with 18 MS. McKEITH: So you don't recall? 18 respect to the interior of the building? 19 THE wrINESS: I don't recall. 19 A. No, not as thorough. 20 MR. PATTERSON: Q. Do you remember coming 20 Q. Not as thorough. Why is that? 21 out a second time to take additional wipe samples in 21 A. Because it was in an unrestricted area and 22 this portion of the building? 22 you wouldn't expect to find anything there, but you 23 A. No, I do not. 23 would make surveys to check and confirm that that was 24 Q. Did you also test any drain lines or pipes 24 true. There's a side entrance there, and so you would 25 in the facility? 25 be more thorough in your survey in that area because Page 106 Page 108 Page 105 - Page 108 Combs & Greenlev. Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I I. I A. NO. 1 that would be the potential source of activity coming 2 Q. You remember it was elevated above the 2 out from the restricted area. So you would be more 3 asphalt portion? 3 thorough there than you would be in other areas of 4 A. Yes. 4 the- 5 Q. Was there a roof covering? 5 Q. Do you remember whether this area that 6 A. No. 6 we're referring to was paved in any way? 7 Q. Did you conduct a survey of this area with 7 A. There was asphalt on it. 8 the Geiger-Muller instrument? 8 Q. Do you remember any cracks in the asphalt 9 A. Yes, that area was surveyed. 9 that caused you to review them more carefully? Q. Can you describe to me how you conducted 10 A. No, I don't remember that. I don't 10 11 that survey in that portion of the property? 11 remember that. Only that the same mechanism would be used 12 Q. Do you remember the asphalt being in good 12 A. 13 there as the rest of it. The survey performed was 13 shape or poor shape? Do you have any recollection? throughout. You didn't change the way you 14 A. No. 14 consistent 15 made the surveys. 15 Q. Did you take wipe samples of that area? portion of the facility, you 16 A. There were some wipe samples taken in that 16 Q. So in this above the 17 area. 17 would have held the tube at the same level that you did inside the building? 18 Q. Did you remember how many? 18 ground 19 A. Nope, I do not. 19 A. Yes. And would you have walked sort of back and 20 Q. How did you determine how many wipe samples 20 Q. -- similar way that 21 to take in that area? 21 forth across this area in a way what you did inside the building? 22 A. I don't know how I did determined it. I 22 you described A. Similar, yes, I would have. 23 mean, I took some to make an assessment of the 23 take any wipe samples of this area? 24 potential removable contamination in that area, and I 24 Q. Did you 25 can't even tell you how many I took. 25 A. Yes, wipe samples were taken in that area. Page 109 Page 111 1-i I Q. Moving to what I'm going to call the back 1 Q. Do you remember any locations where you 2 area, the east of the building. 2 took wipe samples? 3 A. Yes. 3 A. No. 4 that are marked "storage 4 Q. This map is a little bit different in that Q. There's some areas 5 the north is to the left instead to the top of the 5 bays" at the top of the paper. 6 A. Yep. 6 paper, but the east of the building. Do you remember B," and "Bay C." 7 what was in the back of the building there? 7 Q. And it says "Bay E," "Bay a survey of those areas? 8 A. What I remember in the back there was a 8 Do you remember conducting survey of those 9 concrete pad in sort of the area around where the 9 A. I do not remember making a 10 cobalt pool is. 10 areas. when you were at 11 Q. Is this an elevated pad? 11 Q. Were these bays in place 12 A. It was an elevated pad. That is elevated 12 the facility? that 13 above the asphalt, and that's the only thing that I 13 A. I remember that those bays and 14 remember back there other than the asphalt that was 14 building was back there. 15 laid. 15 Q. Do you recall any reason why you wouldn't 16 Q. And was this just -- the rest of it was 16 or didn't conduct a survey in those areas? 17 flat asphalt of this portion in the area? 17 A. I don't recall. that says, 18 A. As near as I can recall. The only thing I 18 Q. In Bay B, there's a small square out." 19 specifically remember is that concrete pad being back 19 "floor sump with thorium material was cleaned 20 there in that corner. 20 Do you see that? 21 Q. What I would like you to do is, if you 21 A. Yes. 22 could, draw where you believe -- you remember seeing 22 Q. Do you remember seeing a sump in Bay B? 23 the pad on that document. And, if you could, put the 23 A. No. going inside these bays, 24 word "pad" in there. How high was the pad? Do you 24 Q. Do you remember 25 remember? 25 leaving aside whether you surveyed them or not, going Page 110 Page 112 Page 109 - Page 112 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I I 1 inside these bays to look around? A. Um-hum. 2 A. I do not remember going into these bays Q. It shows a "15-foot by 24-foot double wall 3 during my confirmatory survey. concrete-lined pit-waste storage." Do you see that? 4 Q. When you conducted the survey, we talked A. Yes. 5 about the window on the tube. Q. Do you remember seeing that in the paved 6 A. Yes. area at the time you conducted your survey? 7 Q. Was that survey done with the window open? A. I do not remember. I don't have any memory 8 A. All surveys were done with the window open. of that. 9 Q. Going back to the pool, do you have a Q. At some point, Mr. Fish, were you satisfied 10 memory -- at some point did you determine that the that the clean-up criteria at the Providencia facility II clean-up criteria in place at that time had been met had been met by the licensee? 12 inside the pool? A. Yes. 13 A. Yes. Q. What did you do at that point? 14 Q. Mr. Fish, I'm going to show you another A. At that point, I would have returned to the 15 document which we'll mark as Exhibit 7. office and written a report of the visit or visits, in 16 (Whereupon, Defendant's this case it was at least a visit because I know there 17 Exhibit 7 was marked was a second one. And it would have reflected all of 18 for identification.) the work that we did there and results of our 19 MR. PATrERSON: Q. Mr. Fish, if you look confirmatory survey and would have been transmitted by 20 at Item No. -- there's a No. 5 in the area called memo or memorandum to our headquarters, inspection 21 "Work Area." Do you see that? function headquarters. And then inspection function 22 A. Um-hum. headquarters would transmit it to the licensing people 23 Q. And then under 5, it says: "Cesium-137 informing them of the results of our survey. 24 facility. Storage: Ten 2-inch holes to 6 feet bgs," MR. SHIMADA: Move to strike as 25 which I assume is below grade surface, "manufacturing nonresponsive. Page 113 Page 115

of up to 1,000"curies of source material." Do you see I MR. PATrERSON: Q.You used a lot of "I that? 2 would haves" and "I would have done this." Do you A. Yes. 3 have a specific memory of writing the report for Q. Do you remember any holes in that portion 4 Providencia property? of the property? 5 A. Yes, I do. A. I do not remember any holes. 6 Q. And do you have a specific memory of Q. Do you remember seeing any coverings that 7 writing the - would suggest to you that these holes may have been 8 A. I have a specific memory of generating a capped? Do you remember anything, seeing like fresh 9 draft of the memo transmitting that report. concrete or anything? 10 Q. And who would that report have gone to? A. I do not remember anything. 11 Did you give that report to someone to review? Q. So you have no memory today of those holes? 12 A. Yeah. My supervisor reviewed the report A. No, I do not. 13 and reviewed the draft of the transmittal memo and Q. If you look at -- there's also a No. 6. It 14 made changes in the memo that he felt appropriate. says: "Storage laboratory. 15 storage holes four 15 Q. Who was your supervisor at that time? feet, bgs," which again I assume is below grade 16 A. At that time, I believe it was Herb Brook. surface, "for hard gamma emitters and soft gamma 17 Q. Would Mr. Brook have been responsible for emitters." Do you remember seeing any holes in that 18 then transmitting the final document to the licensing area? 19 division in Bethesda, Maryland? A. No, I do not. 20 A. No. Q. Seven refers to the cobalt pool. You do 21 Q. Who would have that responsibility? recall that? 22 A. The inspection people in Bethesda, Maryland A. Yes. 23 would have the responsibility. Q. You see where it says No. 9 in the paved 24 Q. Okay so the -- I'm sorry. Would Herb area? 25 Brook -- would your office have transmitted the frmal Page 114 Page 116 Page 113 -Page 116 Combs & Greenlev, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I

And previously our office had provided i document to the inspection portion in Bethesda, 1 Associates. you with a copy of that report; is that right? 2 Maryland division? 2 3 A. That's true. 3 A. Yes. 4 Q. Have you had an opportunity to review the 4 Q. And would they have independently reviewed Rogers & Associates report -- read it? 5 the report or was that part of the process? 5 6 A. Yes, I have. 6 A. I'm sure that before they transmitted it to 7 Q. Now, this particular figure appears to show 7 licensing, they would have reviewed it, but I don't gamma radiation measured 3/30/99 8 have any knowledge that that's what they did. 8 average surface in, I guess, one-meter-by-one-meter 9 Q. Did anybody from the inspection division in 9 through 4/17/99 Is that your understanding? 10 Bethesda call you regarding your report of the 10 grids. 11 A. Yes. 11 Providencia confirmatory survey? are in -- it appears 12 A. I don't remember hearing any or having any 12 Q. And these measurements 13 to be micro rs per hour? 13 conversations with the people in Bethesda, the 14 A. Microroentgens per hour. 14 inspection function in Bethesda, on that report. 15 Q. Microroentgens per hour. 15 Q. Would you receive notification that the 16 A. Yes. 16 report had been accepted and the license terminated? 17 Q. Now, the highest level that I could find is 17 A. We would have received a copy of the letter in the yellow portion of this 18 that the licensing people sent to the licensee saying 18 a measurement taken shows 106 microroentgens per hour. It 19 that the license had been terminated. 19 document that 80 east and looks like and - 20 Q. Do you remember seeing that letter? 20 is at the coordinates sorry, 80 north and 22 -- I'm sorry, I'm not doing 21 A. Right now, I can't say that I remember 21 I'm about 22 north. Are you 22 seeing that letter in person. 22 this right. It's 80 east and per hour to a 23 Q. Do you remember having an understanding 23 able to convert that microroentgen hour? 24 that the Providencia property license had been 24 milliroentgen per 25 terminated? 25 A. Yes. Page 117 Page 119 1- I A. Yes. Q. What would be the milliroentgen per hour 2 Q. How do you have that memory? measurement be? A. 0.1 -- a tenth of amilliroentgen. 3 A. Because we no longer conducted any we were to, you know -- assuming a 4 inspections there, and so that just terminated our Q. And if to double that 5 responsibility in that area. half life of 30 years, if we were it would be .2 milliroentgens 6 Q. Did you use any other instruments other measurement, 7 than the Geiger-Muller to conduct your survey at the approximately? 8 Providencia property? A. Yes. And that would be -- that number would be 9 A. No, I didn't, not that I remember. I don't Q. 10 remember using any other. below the .25 millirems per hour that this document criteria, at least for 703 Main 11 Q. Do you know whether the -- the person shows was the clean-up right? 12 conducting the survey on behalf of the licensee used Street; is that correct. 13 other instruments in his -- in the licensee's survey? A. That's have detected that 14 A. No, I don't remember what instruments he Q. Would your instrument 15 used. level? have detected that level if I had 16 MR. PATTERSON: I would like this document A. It would 17 marked as Exhibit 8. been close enough to it, assuming, of course, that 18 (Whereupon, Defendant's it's twice this value. - 19 Exhibit 8 was marked Q. I understand. If it was this value 20 for identification.) strike that. be measured on the ground 21 MR. PATTERSON: Q. Mr. Fish, this This appears to 22 document, Figure 3.1, was taken from the site or floor surface. Do you see that? 23 characterization of residual activity from former A. Yes. I guess, you had indicated that 24 radioactive materials, license operations, Thomson Q. And again, the reading 25 Property, Burbank, California, prepared by Rogers & the distance from the source would affect Page 118 Page 120 I Page 117 - Page 120 Combs & Greenley, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I 1*I 1 that you would obtain? 1 you conducted the confirmatory survey? 2 A. No, I don't believe so. 2 A. That's correct. Marking next in number, 10. 3 Q. And the farther away that you were from 3 MR. PATTERSON: 4 (Whereupon, Defendant's 4 that source, the lower the reading would be? 5 Exhibit 10 was marked 5 A. That's correct. for identification.) 6 Q. Is there any measurement that you see on 6 Q. Have you had a chance 7 this Figure 3.1 which was -- which is above the .25, 7 MR. PATTERSON: 8 to look at this table? 8 which is above .25 -- I'm sorry, .25 millirems? 9 A. Yes, I read this table when I read the 9 A. As I review this thing, the 106 was the 10 report. 10 highest number there. 11 Q. This is Table -- for the record -- 3.3 of 11 Q. So the answer is no? 12 page 3-24 of the Rogers' report, and it shows various 12 A. They are all less. measurements of what appears to be beta and alpha 13 Q. Even if you would have detected twice the 13 at the Providencia property. 14 level shown in this document, that would have been 14 surface contamination toward the bottom, Mr. Fish, there's a 15 acceptable criteria assuming that the .25 millirems 15 You'll see "Area Outside on Asphalt*? 16 was the level you were using as clean-up criteria? 16 heading called Yes. 17 A. Yes. 17 A. beta concentration there done 18 MR. SHIMADA: Objection; calls for 18 Q. And there's a per minute, and it shows a 1,331,200 counts 19 speculation. 19 in counts 20 per minute. Do you see that? 20 MR. PATTERSON: 1 need to take a bathroom 21 A. Yes. 21 break. Can we go off the record for a minute. that you were using 22 VIDEO OPERATOR: Going off the record at 22 Q. Would your instrument have been able to detect that kind of 23 2:24. 23 at the time 24 (Break in proceedings.) 24 activity? A. I don't know. 25 VIDEO OPERATOR: We're back on the record 25 Page 121 Page 123 Q. Why don't you know? I at 2:39. know how -- I don't know 2 MR. PATTERSON: I'm going to mark as next A- Because I don't convert that number into miUirem or 3 exhibit, No. 9, this document. how they would per minute 4 (Whereupon, Defendant's micro -- milliroentgens or microroentgens 5 Exhibit 9 was marked at the time. the surveys for 6 for identification.) Q. The report indicated that were performed 7 MR. PATTERSON: Q. Mr. Fish, have you had beta and alpha surface contamination and that most of the 8 a chance previous to today to review this particular with beta and alpha detectors, by placing the detector on the 9 figure, Figure 3.8, which I'll represent is from the surveys were performed Would 10 Rogers report? surface and making one-minute measurements. by placing the detector II A. Yes, I have. conducting the survey that way measurement greatly 12 Q. What is your understanding of what this on the surface and making a minute were measuring when 13 document is depicting? increase the counts that they in which you conducted your 14 A. This document depicts measurements made to compared to the manner 15 identify the source of the radiation in these areas. survey? instrument on 16 Q. You say identify the source. Do you mean A. Well, if they are laying the those counts 17 identify the type of isotope? the surface, directly on the surface, at three 18 A. Yes. would not be the same as my measuremwnts 19 Q. If you look at this, they are showing a inches. be lower - 20 series of different circles, and the circles indicate, Q. Would your measurements 21 apparently, measurements taken in multiples of the A. Yes. they were reading on the 22 background measurement. Do you see that? Q. -- than what 23 A. Yes. surface? would have been lower. 24 Q. Do you have any way of looking at that and A. My readings placing the 25 correlating it to the measurements that you took when Q. And it says that it was Page 122 Page 124 Page 121 - Page 124 Combs & Greenlev, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I I I detector on the surface and making one-minute 1 2:48. Okay. I would like the 2 measurements. Do you know what they mean by making 2 MR. PATrERSON: as next in number as 3 one-minute measurements? 3 reporter to mark this document - 4 A. Yeah. They put the meter there and left it 4 exhibit (Whereupon, Defendant's 5 there and accumulated the counts over a one-minute 5 was marked 6 period of time, and then they would stop the 6 Exhibit 12 identification.) 7 collection of the counts. 7 for Fish, if you could 8 Q. So these numbers indicate an 8 MR. PATTERSON: Q. Mr. 9 turn to page 4.7. 9 accumulation -- your understanding is these numbers 10 A. Yes. 10 indicate an accumulation of counts over a period of second full 11 one minute? 11 Q. Under paragraph 3, the is a gamma logging hole 12 A. From what you read, that's what happened. 12 paragraph, it notes that there high localized radioactivity at 25 13 Q. And that's not the manner in which you 13 14, which indicated surface of the concrete 14 conducted your survey; is that correct? You didn't 14 centimeters beneath the and remaining very 15 leave your instrument over a particular area for a 15 extending to about 30 centimeters 16 minute? 16 elevated to a depth of about 50 centimeters. The based on field 17 A. No. I did not collect data that way. 17 radioactivity is primarily cesium-137 18 Q. And it wasn't at that time in 1961 -- it 18 gamma spectra - are you reading 19 wasn't common practice to collect data in that way; is 19 MS. McKErrH: What page 20 that correct? 20 from? 4-7. 21 A. Our confirmatory surveys did not make the 21 MR. PATTERSON: 22 surveys in that manner. 22 Q. And the maximum levels appear to be very a Ludlum 2221 with a 23 MR. SHIMADA: Move to strike as 23 localized. The maximum saturated 24 nonresponsive. 24 one-inch diameter -- is that sodium ion? 25 MR. PATTERSON: I would like to mark next 25 A. Sodium iodide. Page 125 Page 127 t I in number, 11. 1 Q. -- iodide Ludlumi probe at 1 million counts 2 (Whereupon, Defendant's 2 per minute. And it says the HPs Cypher with a 3 Exhibit 11 was marked 3 one-inch sodium iodide probe also saturated at 19 4 for identification.) 4 million counts per minute. where gamma 5 MR. PATTERSON: Q. Have you previous to 5 Do you have an understanding of 6 the deposition had a chance to review this table, 6 logging hole 14 was located on the property? in 7 Mr. Fish? 7 A. I can't tie down the -- in that diagram 8 A. Yes, I have. 8 that report. There it is. Yeah, I see where hole 14 9 Q. This is Table 3.1, *Locations with 9 is located on the diagram in the report. 10 localized elevated areas of contamination," pages 34 10 Q. Mr. Fish, you're looking at the Rogers 11 and 35 of the Rogers report. This appears to show 11 report? 12 various areas of concentrations of contamination in 12 A. Yes, I am. It's Figure 4.1. It says, 13 counts per minute. Is that your understanding of what 13 "locations of bore holes and sample collection 14 this document shows? 14 points." 15 A. Yes. 15 Q. Where does it show gamma logging hole 14 to 16 Q. Do you have any ability to convert these 16 be located? 17 readings into the measurements that you utilized, the 17 A. Gamma 14 is back in the southeast corner. 18 milliroentgens per hour? 18 Q. Is that near where the - 19 A. No. 19 A. It would be near the cobalt pool, but I 20 MR. PAT'ERSON: And we'll mark -- go off 20 can't tell from its location whether that's a point 21 the record for a moment, please. 21 that's inside or outside of the walls of the pool. 22 VIDEO OPERATOR: Going off the record at 22 Q. Did this level of activity at this location 23 2:47. 23 surprise you, given the work that you had done at that 24 (Discussion off the record.) 24 site? 25 VIDEO OPERATOR: Back on the record at 25 A. If that activity is from inside the walls Page 126 Page 128 Page 125 - Page 128 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. Octobcr 12, 1999 Volume I I of the pool, it would have occurred after my survey. I A. I'm not familiar with that instrument per 2 And so, I guess, it might or might not have surprised 2 se. I'm familiar with instruments that use a sodium 3 me. It would not have -- if it's inside the pool 3 iodide detector. 4 walls, I would have discarded it because it was 4 Q. Is a sodium iodide detector more sensitive 5 something that would have occurred after my survey. 5 to radioactive contamination than the detector -- the 6 When I left the survey, the pool was empty. 6 Geiger-Muller tube that you used? Would it pick up 7 So after the survey and those things, then 7 more counts per minute? 8 they obviously filled the pool in -- the pool area in. 8 A. Yeah, it would be more sensitive. It would 9 And I have no knowledge or control whatsoever of what 9 pick up lower counts, lower amounts of activity. 10 it was filled with. So to that extent, I 10 MS. McKErrH: Object. Move to strike. You 11 wouldn't, you know -- it's conceivable they put 11 asked him whether it would pick up more counts. 12 contaminated dirt or something else back in there. So 12 MR. PATTERSON: Q.I asked whether the 13 to that extent, it wouldn't surprise me. I would just 13 Ludlum instrument would -- over the same period of 14 kind of discard it. If it was outside of the pool, 14 time -- pick up more counts per minute than the 15 outside of the pool walls, I guess I would have been 15 instrument that you used? 16 surprised that there were those kind of levels. 16 MR. SHIMADA: Objection; lacks foundation. 17 Q. If it was outside the pool walls but 17 MR. PATTERSON: Q. If you know. If you 18 underneath the concrete, would that have potentially 18 don't know, you don't know. Or maybe I'm not phrasing 19 masked the levels that you would be able to read with 19 the question very well. 20 the instrument you used at the time? 20 A. I think that's true. The Ludlum sodium 21 A. The pool walls would have - 21 iodide instrument is more sensitive, which means it 22 MR. SHIMADA: Objection; lacks foundation. 22 can pick up smaller amounts of activity than a 23 THE WITNESS: The pool walls would have 23 Geiger-Muller tube. So that if you're using the two 24 shielded that source so that measurements inside the 24 instruments, the sodium iodide detector will pick up 25 pool would have not likely seen that kind of a source. 25 smaller amounts and record the presence of radiation Page 129 Page 131 I MR. PATTERSON: Q. So the concrete would I before the Geiger-Muller will. 2 have acted as a shield? 2 Q. Mr. Fish, as you sit here today, did you 3 A. It would. 3 believe that you had sufficient data at the time you 4 Q. And do you remember -- does this refresh 4 conducted your final confirmatory survey based on your 5 your recollection at all of what kind of readings you 5 surveys and the licensee's surveys to support the 6 were getting in the pool area? 6 decision to allow the property to be released for 7 MS. McKEITH: rm going to object. Asked 7 unrestricted use based on the criteria in place in 8 and answered. He indicated the readings he got in the 8 1961? 9 pool area when he signed off was below the 2 millirem 9 A. I believed that the surveys -- the 10 per hour. Is that correct, sir? 10 confirmatory surveys we made confirmed the results of 11 THE WITNESS: That's right. It met the 11 the licensee's surveys, and that the facility, when we 12 release criteria. 12 finished our confirmatory survey, had met the release 13 MS. McKErrIi: And these are higher than 2 13 criteria in the letter from the licensing people for 14 millirem per hour? 14 releasing the facility to unrestricted use. 15 THE WITNESS: I would guess so, but I don't 15 Q. And your survey was -- of the Providencia 16 know. Because, you see, they are talking in terms of 16 property was as -- strike that. 17 counts per minute, and I have -- there's nothing in 17 Did your survey meet the standards for 18 the report that allows me -- provides me with 18 conducting these types of surveys that were in place 19 information to convert that into the numbers that - 19 in 1961, in your opinion? 20 the readings I was that making. 20 A. There were no standards per se. 21 MR. PATTERSON: Q.Are you familiar with 21 Q. I understand that, but did they meet the 22 this instrument called the Ludlum 221 with a one-inch 22 industry practice at the time? 23 diameter sodium iodide, is it? 23 MR. SHIMADA: Objection; lacks foundation. 24 A. Sodium iodide. 24 THE wrrNESS: The survey was performed in 25 Q. Ludlum probe. 25 accordance with the acceptable methods used by the Page 130 Page 132 Page 129 - Page 132 Combs & Greenlev, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I I I 1 inspection function for performing those surveys. I the primary building and 10 to 22 microroentgens per 2 hour inside of the primary building." Can you convert 2 MR. PATrERSON: Q.Do you remember if you 3 those levels to milliroentgens? What would 11 be? 3 had conducted any surveys prior to the Providencia 4 A. Well, 11 would be .011. The 80wouldbe 4 survey for purposes of terminating the license and 5 .08 milliroentgen. The 10 would be .01, and the 22 5 releasing the property for unrestricted use? 6 would be .022 milliroentgens per hour. 6 A. I do not remember whether I had made such 7 Q. All of those levels were below the .25 7 surveys prior to this survey. 8 millirems per hour referenced in Exhibit 1; is that 8 Q. I believe you testified that you went to 9 right? 9 work in 19 -- middle of 1959? 10 A. That's correct. 10 A. September of 1959. ii Q. So there were -- strike that. 11 Q. September of 1959. Was this one of the - PATrERSON: Off the record for just a 12 if you know, was this one of the first confirmatory 12 MR. 13 moment, please. 13 surveys conducted by your off ice for purposes of VIDEO OPERATOR: Going off the record at 14 terminating a license and releasing the facility? 14 15 3:07. 15 Would it have been one of the first? 16 (Discussion off the record.) 16 A. It would have been one of the first. I 17 VIDEO OPERATOR: We're back on the record 17 don't know that it was the first, but it would have 18 at 3:09. 18 been one of the early ones that we did. MR. PATTERSON: Q.Mr. Fish, I would like 19 Q. Were you familiar with the facility at 703 19 to look through the documents that you brought 20 Main Street in Burbank? 20 you 21 today and locate a December 17th, 1997 letter and 21 A. No, I was not. 22 attached statement from Loeb & Loeb. 22 Q. Did you have any involvement in the What I would like to do is have the 23 confirmatory survey conducted, if any was conducted, 23 that as the next exhibit in number, both 24 at 703 Main Street? 24 reporter mark 25 the letter and the statement together. 25 A. No, I was not involved in any way. Page 133 Page 135 - I 1 Q. Did you conduct any kind of radioactive I (Whereupon, Defendant's Exhibit 14 was marked 2 contamination survey at 703 Main Street at any time? 2 for identification.) 3 A. No, I did not. 3 Q.]Mr. Fish, did you have 4 MR. PATTERSON: I'm going to have marked 4 MR. PATFERSON: to meet with a Martha Sharp at some point 5 next in order an April 8th, 1996 letter from the 5 occasion to this statement being provided to you? 6 Nuclear Regulatory Commission to the State Department 6 prior 7 A. Yes, I believe I did. 7 of Health Services. you discuss? 8 (Whereupon, Defendant's 8 Q. What did the statement that is 9 Exhibit 13 was marked 9 A. We were discussing letter. They came to my house -- two 10 for identification.) 10 attached to the came to my house. There had been previous 11 MR. PATTERSON: Q. Mr. Fish, have you had 11 people came to my house 12 a chance to read this document prior to your 12 discussions by telephone, and they that's here, and I 13 deposition today? 13 and we looked over the statement 14 A. First time I saw it. 14 made corrections as indicated, which were initialed, I signed it. 15 Q. What I would like you to do is turn to page 15 and then do you remember who the - 16 7 of the document, Bates-stamped ICN 001947. You see 16 Q. If you could, one of the persons that met with you? 17 at the top there, it notes the heading: "170 West 17 was Martha Sharp was one. 18 Providencia Street*? 18 A. Martha other person was? 19 A. Yes. 19 Q. Do you remember who the a Larry R. Druxel. 20 Q. In the second paragraph it says, "General 20 A. The other person was to your statement, 21 area exposure rate surveys of areas within and outside 21 Q. If you could refer states that "IsC" 22 of the two site buildings range from 11 to 80" -- is 22 Mr. Fish. The last paragraph this is 23 that microroentgens? 23 that refers to Isotopes Specialties Company; at the 24 A. Yes. 24 the first page of your statement, sir, a plaster 25 Q. -- "per hour on the outside (east side) of 25 bottom -- maintained an -- "isc maintained Page 134 Page 136 Page 133 -Page 136 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I

lined isotope storage pool which was used to store that same page, "Upon inspection for site release at cobalt, possibly cesium, and other radioactive the 170 West Providencia Street property, I detected materials." Is this referring to the cobalt pool that levels of cobalt-60 in excess of the AEC release you referenced previously? limits in 'SC isotopes storage pool, and levels of A. Yes, it is. radiation exceeding regulatory standards was detected Q. And it says here that it was a on the concrete pad outside the building marked as plaster-lined pool. Does that refresh your Exhibit 2 on the attached site map.* recollection that this pool was lined somehow? Does that refresh your recollection that A. The source of the statement is -- that I you detected radiation exceeding regulatory standards specifically remember -- is that when I was working at on the concrete pad? Do you remember that, as we sit the U.S. Nuclear Facility over there, the here today? discussion -- we had a discussion about the pool at A. I guess the answer to that is yes. Isotopes Specialties, and the people at U.S. Nuclear Q. You do recall -- I think your previous said that one thing that they were not going to do testimony was you didn't remember other areas. This with their pool was to line it with plaster as it had refreshes your recollection that there was another been done over at Isotopes Specialties because that area and that was the concrete pad? created great problems from a contamination standpoint A. That was an area that needed additional and the decontamination of that contaminated plaster. work, yeah. That's the source of that statement, were those Q. Do you know what additional work was discussions, which - conducted on the concrete pad? Q. So you had a discussion with someone at A. No, I don't. U.S. Nuclear that whatever they were using to line - Q. Did you come back and conduct another that was used to line the pool at isc wasn't what they survey of the concrete pad to determine whether they wanted to use the next time? had cleaned it to the standards? A. It created problems from a decontamination A. I don't specifically remember surveying Page 137 Page 139 standpoint. that pad, except that I do remember that on the Q. And that's what -- how you came to this follow-up survey trip that all areas that were higher understanding that it was lined? were resurveyed to make sure they met the release A. That's specifically -- I can remember - criteria. So if that -- if -- and it's not if, the discussions at U.S. Nuclear concerning the really. I remember there were elevated levels there, Isotopes's pool, and that's the source of that and I did survey on the next trip to make sure that statement. I can't say that I remember the plaster on the decontamination work had been adequate to meet the the pool at Isotopes Specialties, but I can remember requirements. this discussion, and that's the source of the Q. On the next page it says that: "Steel statement. beams to store equipment on, and process source Q. In the next paragraph on the next page, the material were located on the concrete pad." That's on last sentence indicates that: "Two types of sources page 3 of your statement. stored in the pool were Cobalt-60 in the form of metal A. Um-hum. pellets and cesium-137 in the form of a chloride Q. Do you remember seeing steel beams on the power"? concrete pad at the time you conducted any of the A. That's wrong. It's powder. confirmatory surveys that you did at Providencia? Q. Powder? A. I remember seeing steel beams. I don't A. It's powder, not power. remember that they were there at the time of the Q. Do you have a specific recollection - confirmatory survey. again, I'm just trying to make sure I understand your Q. Did you conduct inspections of the testimony before and this statement, that cesium-137 Providencia property as an inspector prior to was actually stored in the pool? conducting the confirmatory survey? A. I can't say right now that I remember A. I don't remember that I did. specifically that cesium was stored in the pool. Q. It also says that *process source material Q. And then, again, in the last paragraph on were located on the concrete pad" on your statement. Page 138 Page 140 Page 137 - Page 140 Combs & Greenlcv, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I

I Do you see that? Page 3 at the top. 1 A. Yeah, I understand the question. 2 A. Yeah. 2 MS. McKEITH: Are you marking the document? 3 Q. Do you remember -- what is process source 3 THE WITNESS: I just - 4 material? 4 MR. PATIERSON: Q. You seem to have some 5 A. The activities that were going on there 5 difficulty. 6 were activities with respect to rare earth, and source 6 A. The numbers are a little different. For 7 material was the feed material that was used because 7 instance, in Table 2, they are talking about a maximum 8 it contained the rare earth and the rare earth 8 reading of 1 millirad and 0.2 millirads per hour at 9 material would be eluted out of the feed material. 9 one centimeter. Those numbers are more restrictive 10 Q. And it's your memory that those materials 10 than the 2 milliroentgen and the 0.25. 11 were located on the pad? 11 Q. The tables you're referring to are -- they 12 A. The statement here relates to what the 12 are -- let's see, there's a Bates-stamp number on the 13 steel beams were used for, not that there was material 13 side iT 1771? 14 there. 14 A. Yes. 15 Q. Okay. You lost me. What did you mean by 15 Q. And it says "surface contamination levels"? 16 that statement? 16 A. Well- 17 A. What I said was that the steel beams which 17 Q. At the top. 18 were used to store equipment on and process source 18 A. -- there's, basically, a Table 1 and a 19 material -- so the steel beams were located on the 19 Table 2. And Table 1, the total would be relating to 20 concrete pad. 20 a radiation level-type measurement. The removable 21 Q. And on the steel beams were equipment and 21 would be just that. Removable levels of contamination 22 source material? 22 that you would detect by wiping. Table 2 is basically 23 A. No. On the beams -- the steel beams were 23 set up the same way, that is, the total would be the 24 used as a framework for holding equipment that was 24 instrument reading and the removable would be what 25 used in the processing of the source material. 25 would be on the wipe. Page 141 Page 143

Q. Okay. Now, I get it. Do you have an idea I Q. If a radioactive source were, let's say, of how many confirmatory surveys you conducted while 2 left in the ground, does it have the potential to employed with the Atomic Energy Commission both before 3 migrate and contaminate further and further out as and after the Providencia property? 4 time goes by? A. I can only make an estimate of what that 5 MR. SHIMADA: Objection. The question might be, and it was eight or ten confirmatory surveys 6 is- that I made over the period of time. 7 MR. PATTERSON: Q.If you know. Q. Mr. Fish, do you have a document that's 8 MR. SHIMADA: -- vague, lacks foundation, entitled "Guidelines for Decontamination of Facilities 9 calls for speculation. and Equipment"; it's dated April 22nd, 1970? 10 THE WITNESS: If the source is a sealed A. Yes. 11 source, the activity will not move unless the sealing Q. Did you have an opportunity to review this 12 material is violated. If it's an unsealed source and document prior to the deposition? 13 there's some kind of a driving medium such as rain A. Yes, I have. 14 water or some other water movement, the answer is it Q. Was this a guideline that you used around 15 would tend to move, or some of it would tend to move. 1970 in decontamination efforts? 16 MR. PATTERSON: Q. If there was an A. Yes, it was a document that we used. 17 unsealed source, say, in subsurface soils and those Q. Were the standards or criteria used in 1970 18 subsurface soils were impacted with solvents, do you to obtain a release for unrestricted use or 19 have an understanding of whether that would have a termination of a license more strict in 1970 than they 20 bearing on the ability of that radioactive material to were in 1961? 21 migrate? MR. SHIMADA: Objection; the question is 22 MR. SHIMADA: Same objections. vague, lacks foundation. 23 THE WITNESS: There are mechanisms where MR. PATFERSON: Q. Do you understand the 24 the solvent could move it. question? 25 MR. PATTERSON: Q. What is your Page 142 Page 144 Page 141 - Page 144 Combs & Greenley, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I I I deposition. And you -- did you attempt to determine I understanding of what those mechanisms would be? 2 whether you had documents responsive to the exhibit 2 MR. SHIMADA: Same objections. 3 prior to coming to the deposition? 3 THE WITNESS: Well, if the solvent -- if 4 A. The only documents that I ever had since I 4 there's a -- if there's a physical opening so that the 5 retired are the documents that have been provided by 5 solid could move it by just physically moving it, it 6 the lawyers in connection with this experience. 6 would do it. The only other mechanism would be if it 7 Q. And you produced all those documents today?. 7 was soluble to any extent in the solvent, it would 8 A. They've all been brought here today. 8 then move. 9 Q. I have a couple quick questions going back 9 MR. PAT`TERSON: Q. In your experience, is 10 to your confirmatory survey at Providencia. Would you 10 it true that it's essentially impossible in every I1 have surveyed any vents that were in the facility? 11 situation to measure residual radioactivity at every 12 A. Any vents that were there at the time that 12 point and space and time at a facility? 13 I made my confirmatory survey were surveyed. 13 MS. McKEITH: Objection. 14 Q. And how did you survey those? 14 MR. PATTERSON: It's a statement right out 15 A. With the same mechanism that I used in the 15 of Marson. 16 others; I surveyed them with a Geiger-Muller survey 16 MR. SHIMADA: I object also. Vague and 17 instrument and would have -- and made wipes in the 17 ambiguous, overbroad, calls for speculation, lacks 18 accessible areas to see if there was removable 18 foundation. 19 contamination. 19 THE WITNESS: There's no way you can 20 Q. Do you remember whether there were any 20 measure all radioactivity. It's just an 21 tiles in any portions of the building, floor tiles? 21 impossibility. 22 A. I do not remember that. 22 MR. PATTERSON: We're running out of tape. 23 Q. Do you remember requiring that any floor 23 Why don't we take a short break, and I think I'm 24 tiling be removed because of concerns that radioactive 24 almost finished. 25 materials seeped into the cracks? 25 VIDEO OPERATOR: This marks the end of 145 Page 147 Page i i Videotape No. 2 in the deposition of Raymond Fish. 1 A. I do not have any recollection of that. 2 Q. When you analyzed the wipe samples that you 2 We're going off the record at 3:27. 3 took from Providencia, would you have kept some sort 3 (Break in proceedings.) 4 of record of what the analysis showed, written record? 4 VIDEO OPERATOR: We're back on the record. 5 A. The counting of the wipes would have been 5 This marks the beginning of Videotape No. 3 in the 6 written, and then those numbers would have been 6 deposition of Raymond Fish. The time on the video 7 transferred to the report and that's the extent of the 7 monitor is 3:32. 8 record. 8 MR. PATTERSON: Q. Mr. Fish, what I would 9 MR. PATTERSON: I don't have any further 9 like to do is take that last document that we were 10 questi ons at the time. 10 looking at, the decontamination standards, and hi tve 11 VIDEO OPERATOR: Going off the record at 11 the reporter mark that as the next exhibit in numi )er. 12 3:36. 12 (Whereupon, Defendant's 13 (Break in proceedings.) 13 Exhibit 15 was marked 14 VIDEO OPERATOR: Back on the record at 14 for identification.) 15 3:41. 15 MR. PATITERSON: And then I would like to 16 EXAMINATION BY MS. McKErrH 16 have the subpoena attached to the exhibit marked as 17 MS. McKEITH: Q.Good afternoon, 17 the next exhibit. 18 Mr. Fish. I'm Malissa McKeith, and I represent Joseph 18 (Whereupon, Defendant's 19 and Virginia Thomson, who are the current owners of 19 Exhibit 16 was marked 20 the Providencia property. Do you recall whether you 20 for identification. ) 21 ever had occasion to speak with Mr. Thomson in 21 MR. PATTERSON: Q. Mr. Fish, if you could 22 approximately 1961 or '62 when you were conducting the 22 look at Exhibit 15 that was sent to you, and 23 decommissioning of the property? 23 specifically Exhibit A. If you could look at Exhibit 24 A. No, I did not have any discussion with him. 24 A to the subpoena, that exhibit requested that you 25 Q. Do you recall whether you spoke to anyone 25 identify and produce documents here today at your Page 146 Page 148 Iae1~-rg ' Page 14.5 - rage t148 Combs & Greenley. Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I who owned the property at the time that you I not the licensee had met the release criteria for decommissioned the property? 2 unrestricted use, that took approximately a day and a A. No, I didn't. 3 half? Q. When you conducted the surveys that you 4 A. It might have been done in a day. It might have been discussing earlier today, can you tell me 5 have been done in a day and a half. I just don't approximately how long it took you to conduct each of 6 remember the length of time specifically -- how long the surveys that you've been describing? When I'm 7 it took me to do it. saying that, was it a day or two days? Five days? 8 Q. So the work that you described today where A. The individual visits were either a day or 9 you -- based upon what you're saying, my understanding a day-and-a-half type time frame, but I don't remember 10 is that you surveyed, virtually, all of the interior specifically. It would not have been like five days 11 of the building at 170 Providencia; is that correct? because the facility was not big enough to warrant 12 MR. SHIMADA: Objection; mischaracterizes that much of an effort. 13 his testimony. Q. Now, my understanding is that after 14 THE WIWTESS: I did survey -- the survey Isotopes Specialties Company -- or excuse me, after 15 covered the entire building, the front building. U.S. Nuclear conducted their survey of the property, 16 MS. McKEITH: Q. The entire interior of they provided written documentation to you and 17 the front building? requested that you come to verify their survey 18 A. Yeah. results; is that correct? 19 Q. And then it included areas of the driveway; A. They provided a copy of the survey, and the 20 is that correct? request was made to the licensing people in Bethesda, 21 A. That's correct. Maryland, not to our office in the Bay Area. 22 Q. And it included the area of the concrete Q. Now, as you sit here today, do you recall 23 pad that you've described in the open backyard area? the actual survey documents that were forwarded from 24 A. It did. U.S. Nuclear to Bethesda and then, apparently, 25 Q. And did it include any of the back bays Page 149 Page 151 forwarded to you? 1 that were depicted on the exhibit that Mr. Patterson A. No, I do not. 2 showed you earlier today? Q. You mentioned that you would go to the 3 A. I do not remember whether the survey facility and you conducted both wipe samples and 4 included those areas or not. direct readings with the Geiger-Muller; is that 5 Q. Well, Isotopes Specialties Company was an correct? 6 operating business. Did you ever have occasion to A. That's correct. 7 visit the facility while it was still functioning? Q. And you described a situation where you 8 A. I do not remember whether I made would conduct this work and then you would report back 9 inspections at Isotopes Specialties at that location to U.S. Nuclear as to whether any additional 10 or not. remediation was required; is that correct? 11 Q. You testified earlier that when you came to A. I had the discussion with the licensing 12 the property to conduct your first initial survey representative that was there. 13 that, with the exception of the pool that remained Q. Do you know whether that licensing 14 open, there were no other open subsurface structures representative was Mr. Donaldson from U.S. Nuclear? 15 such as holes or sumps that you recall; is that A. I do not remember who the person was 16 accurate? specifically. 17 A. No. What I said was that there were drains Q. Do you recall whether there was more than 18 in the floors and that those were surveyed. one individual at the property when you were 19 Q. Other than the drains, were there any other conducting your surveys? 20 below grade openings that existed at the facility when A. No, I do not. 21 you conducted your initial survey? Q. So you don't recall one way or the other? 22 A. I don't remember whether there was or not. A. I know there was at least one person. 23 Q. When you testified earlier today, you Q. Would it be accurate to say that, when you 24 indicated that you did not recall, for example, conducted your initial survey to determine whether or 25 subgrade holes in the hot lab area? Page 150 Page 152 Page 149- Page 152 Combs & Greenlev. Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I

I A. That's true. I fact that thorium was one of the source materials used 2 Q. Was that because they weren't there or you 2 at the 170 U.S. Providencia site? 3 just don't remember one way or the other? 3 A. Yes. 4 A. I don't remember one way or the other. 4 Q. And are you aware of the fact that Isotopes 5 Q. For a licensing facility that was seeking 5 Specialties Company was permitted to accept waste from 6 release for unrestricted use, was there a regulation 6 its customers, some of which included thorium? 7 in place at the time that would have prohibited their 7 A. Right now I do not recollect that. 8 closing such below grade storage facilities prior to 8 Q. You indicated previously that you would 9 your conducting an inspection? 9 have reviewed the file concerning the 170 Providencia 10 A. There was no regulation in place that would 10 property prior to conducting your survey; is that 11 have done that. II correct? 12 Q. So a licensee such as Isotopes Specialties 12 A. That's correct. 13 Company could have filled in any of their below grade 13 Q. And if Isotopes Specialties Corporation's 14 storage areas and paved over them prior to your 14 license permitted it to receive thorium from its 15 conducting your final survey and that would have been 15 customers, would that have been reflected in its rile? 16 consistent with the regulations? 16 A. Yes, it would have been listed on the 17 MR. SHIMADA: Objection; calls for 17 license. It would have been reflected in the file. 18 speculation, assumes facts. 18 Q. Would you have fashioned your survey to 19 THE wITNEss: The answer to that is that if 19 detect the kind of contaminants or the type of 20 there were storage locations below ground, they would 20 radioactive materials that Isotopes Specialties 21 have had to survey them, decontaaminate them if 21 Company had used on the property? 22 possible, but could not hide them or cover them up 22 A. Yes, we would have. I would have. 23 before we made our confirmatory survey; but that was 23 Q. What type of radioactive materials does 24 not by regulation. 24 thorium emit -- or radioactive rays? 25 MS. McKEIrH: Q.You have a very clear 25 A. It's a beta gamma, but there are some Page 153 Page 155 recollection of surveying the vents; is that correct? I thorium isotopes that emit alpha. A. I have a recollection of surveying the 2 Q Can you recall specifically whether thorium vents, some vents that were there. 3 230 emits alpha, beta or gamma? Q. And you have a recollection of surveying 4 A. No, I don't remember. the drains, as you sit here today? 5 Q. My understanding, based on your testimony, A. Some drains that were there I have a 6 is that the Geiger-Muller that you utilized did not recollection of surveying. 7 detect alpha rays; is that correct? Q. And you have a recollection of surveying 8 A. That's correct. the interior of the pool -- the cobalt pool; is that 9 Q. And my understanding is that you didn't correct? 10 utilize any other instrument for direct readings other A. Ido. 11 than the Geiger-Muller in the field; is that correct? Q. But you have no recollection of surveying 12 A. That's any other below grade storage areas at the site as you 13 MR. PATrERSON: Misstates his testimony. sit here today? 14 MS. McKErrH: Well, he can clarify it now A. I do not have any recollection of making 15 if it does. those surveys. 16 THE wrINESs: That's my -- that's my Q. So is it possible that you did not conduct 17 recollection, that that was the instrument that I used any surveys in those additional below grade storage 18 to make the direct radiation measurement. areas? 19 MS. McKErH: Q. So if there was alpha 20 MR. SHIMADA: Objection; calls for 20 contamination on the property, it would not have been 21 specul ation. 21 detected with your Geiger-Muller? 22 MR. PATTERSON: Join. 22 A. That's true. 23 THE WITNESS: I don't know. I just don't 23 Q. And with respect to the wipe samples that 24 recolIe ect. 24 you've described having taken, if there was thorium 25 MS. McKEIrH: Q. Are you aware of the 25 contamination on the property that was emitting alpha Page 154 Page 156 Page 153 - Page 156 Combs & Greenley. Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I 1 radiation, would that have been detected on the wipe 1 Q. Are you aware of the fact that Isotopes 2 samples? 2 Specialties Company's license permitted it to have 3 A. Yes, it would have. 3 polonium-210 on the property? 4 Q. And can you tell me how one, based upon the 4 A. Yes, I was. I am. 5 wipe samples, differentiates between alpha 5 Q. Excuse me? 6 contamination, and beta or gamma contamination? 6 A. Yes, I was and I am aware that that license 7 A. In the case of the wipe samples, the 7 allowed it. 8 instrument was such that, by changing the dials, you 8 Q. Do you recall what clean-up criteria you 9 would be able to measure either alpha or beta gamma. 9 utilized with respect to alpha contamination? 10 Q. Do you have any recollection, as you sit 10 A. There was no criteria for alpha in the 11 here today, whether or not, in fact, you changed the 11 release criteria that we were using. 12 instrument in order to check for alpha rays at the 170 12 Q. How did one make a determination at what 13 Providencia property? 13 point a property should be released that had utilized 14 A. The wipes were counted for both alpha and 14 polonium-210, as an example? 15 beta gamma. 15 A. The licensing people made that 16 Q. And you have a distinct recollection of 16 determination. They decided what the release criteria 17 that? 17 were, and we were only using the numbers established 18 A. Yes. 18 by them. 19 Q. And the 2 millirems per hour that we've 19 Q_ Have you seen any of the documents that 20 been discussing as what you believe the clean-up 20 you've seen here today, sir, that indicated what the 21 criteria was for the time, did that number apply to 21 clean-up criteria was for alpha rays that would have 22 alpha readings as well as beta or gamma readings? Was 22 been emitted from polonium-210 at the facility? 23 that a collective number, so to speak? 23 A. No. 24 A. No, that number would not relate to alpha 24 Q. Do you have any recollection of what 25 contamination. 25 criteria -- you've indicated that the clean-up Page 157 Page 159 I Q. Are there any documents that we've seen 1 criteria for an alpha emitter that would have been 2 here today, sir, that would indicate to you what the 2 generated from the polonium-210 would be have been 3 clean-up criteria was for alpha contamination in 3 less than the 2 millirem per hour; that's correct, is 4 approximately 1961 when you decommissioned the 4 it not? 5 property? 5 A. Alpha -- the limits established for alpha 6 A. No. 6 contamination are lower than those for beta gamma. 7 Q. Do you have any recollection of what the 7 Q. Do you know whether it's, at that time 8 clean-up criteria would have been for alpha 8 period, was 100 percent lower or 50 percent lower? 9 contamination? 9 A. I don't know. You know, there was a 10 A. Depends upon the type of alpha 10 definite lower number. 11 contamination you're dealing with. If you're dealing 11 Q. Could you explain to us why that is. What 12 with alpha contamination that comes from a natural 12 is are more problematic about alpha contamination than 13 thorium, one of the components being an alpha emitter, 13 beta contamination that would have justified a lower 14 you would be looking at numbers that were comparable 14 clean-up criteria based upon your experience over the 15 to the release values that were given in the letter. 15 last, approximately, 30 years with radioactive 16 And that's different, for instance, than if you were 16 materials? 17 dealing with, say, polonium-210. Because natural 17 A. The difference is that the real problem 18 thorium -- the release criteria for radiation levels 18 with alpha contamination is an internal disposition 19 for natural thorium would coincide. If you were 19 problem. It gets inside. 20 dealing with other isotopes that had alpha emitters, 20 Q. Gets inside what? 21 then the criteria would had to have been different. 21 A. Gets inside the body. And the other 22 Q. Would the criteria have been more stringent 22 problem is that the damage caused by alpha radiation 23 or less stringent for radioactive material such as 23 is more severe than beta gamma, and that's why you 24 polonium-210? 24 have the conversion fact -- a larger conversion factor 25 A. Would have been more restrictive. 25 when you change from milliroentgens to rem. The Page 158 Page 160 Page 157 - Page 160 Combs & Greenlev, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I

I factor associated with alpha, if I remember right, is conduct those readings in the field? A. That's true. 2 a factor of 20. So it would be, basically, 20 times thorium-230 is a 3 more damaging -- an exposure from alpha would be Q. Do you know, sir, whether thorium? 4 approximately 20 times more damaging than exposure to naturally-occurring A. When you talk about thorium, natural 5 beta gamma. But also you have to recognize that the of isotopes in there, and I 6 range of the alpha particle is very short, and that's thorium, it has a number 7 why it becomes a problem when it's an internal don't remember which isotopes and what percentage. the case for thorium-232? 8 disposition as opposed to an external exposure. Q. Is that also it has 9 Q. Were there field instruments available at A. When you talk about natural thorium, I don't recall which 10 the time that would have detected alpha radiation from a variety of isotopes, and the 11 a direct reading instrument? isotopes are there, but I am sure that if you see 12 A. Yes. composition of natural thorium, you will find some 13 Q. Can you tell me what those were? part of it is also thorium-230. 14 A. Well, the Juno had a capability of Q. I guess what I'm confused about is based 15 detecting alpha because it had a thin window and you upon your testimony a few moments ago, my impression, thorium 16 could open it up and expose it. I don't specifically and correct me if I'm wrong, was that natural 17 now remember other instruments, but I know there were would not emit alpha rays. Did I misunderstand 18 instruments capable of measuring alpha contamination. something? 19 Q. Is there a reason that you did not utilize A. If thorium-230 is an alpha emitter and 20 those instruments in the field at a site where thorium-230 is one of the components of natural 21 alpha-emitting radioactive materials had been thorium, then natural thorium would have an alpha 22 utilized? component. 23 A. Yes, because the release criteria didn't Q. If we find any contamination on the 24 involve that. Providencia property that is in excess to -- of the 2 25 Q. But you've indicated that there was some millirems per hour that you believe was the release Page 161 Page 163 I.i I release criteria for alpha emitters, did you not, that criteria - 2 was set by the Atomic Energy Commission? A. Yes. 3 A. The licensing people, if they knew or had Q. -- would that indicate to you that there 4 reason to suspect that there w"s a problem with alpha was a portion of the property that had not met the 5 contamination, would have included alpha requirements release criteria? 6 in the letter that they sent for the release criteria. A. Not necessarily. I mean it could have 7 The letter that was sent in this case did not contain occurred after my survey. 8 any such requirements. And our, you know -- we were Q. You have indicated that after your survey 9 there to make a confirmatory survey that the facility the cobalt pool remained open? 10 met the release criteria in the letter. A. It was open when I made my final survey, 11 Q. So, essentially, what you're saying is the yes. 12 silence in the letter of any release criteria for Q. And therefore you have no readings that 13 alpha contamination meant that you did not apply any would indicate that once the cobalt pool was closed, 14 release criteria for alpha contamination; is that however it was closed, it continued to meet the 15 correct? release criteria? 16 A. In our survey, that's true. A. I have no knowledge about the status of 17 Q. So regardless of what level of alpha that pool if it was filled. Whatever they put in 18 contamination you would have detected, there was no there, they put in there, but I have no knowledge of 19 release criteria to compare it to based upon the that. 20 absence of that criteria in the letter? Q. So it was not the ABC's practice at the 21 A. That is true. time to ensure that previously open areas that had 22 Q. And because the letter that you used as been used for storage were actually physically closed 23 your instructions for how to conduct the survey did or covered up prior to releasing a site? 24 not require any alpha readings, you did not utilize A. No. 25 the equipment that was available at the time to Q. So at that point in time -- at the point in Page 162 Page 164 Page 161 - Page 164 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I

i time where you released the site -- no, strike that. 1 aware of, yes. 2 Can you describe for me what some of the 2 MS. MCKEITH: Can we go off the record for 3 limitations are, if any, with regard to the 3 a moment? 4 Geiger-Muller insofar as it samples beta and gamma 4 VIDEO OPERATOR: Going off the record at 5 rays in the field? 5 4:10. 6 A. It has a limitation with respect to the 6 (Discussion off the record.) 7 minimum amount of activity it can detect because of 7 VIDEO OPERATOR: Back on the record at 8 the thickness of the walls of the tube. 8 4:12. 9 Q. Does it have any limitations in terms of 9 MS. McKEITH: Q.I'm going to mark as 10 the upper limits that it detects? 10 Exhibit, I believe, 17 a document. The first page 11 A. Yeah, it does. If you put it in a 11 which is entitled "California Radiation Control 12 radiation field that is extremely high, it will -- the 12 Regulations" dated 1966, attached to which is a 13 tube will saturate and when it saturates, the reading 13 document described as "Control and Removal of 14 then goes to zero. Normally, it goes to zero. 14 Radioactive Contamination in Libraries from the 15 Instead of off scale, it goes to zero. That's a 15 National Bureau of Standards Handbook 48" dated 1951, 16 saturated tube. 16 which is a multipage document. Also attached to that 17 Q. When there's no radiation being detected, 17 is a "Safe Handling of Radioactive Isotopes, National 18 does the instrument sit at zero? 18 Bureau of Standards Handbook 42" issued September 19 A. Yeah, except that there's an occasional 19 1949, and also attached is a chart previously attached 20 blip which represents background radiation that will 20 to this deposition entitled "Comparison of Various 21 reflect on the instrument, but it's kind of an 21 Release Criteria." 22 occasional thing that you would be aware that it was 22 (Whereupon, Plaintiff's 23 at least receiving background radiation independent of 23 Exhibit 17 was marked 24 what's there. 24 for identification.) 25 Q. Now you indicated that you were not the 25 MS. McKEITH: Q. Sir, you're familiar Page 165 Page 167 individual who calibrated the Geiger-Muller? 1 with the National Bureau of Standards? A. That's true. 2 A. Iam. Q. If the Geiger-Muller had not been 3 Q. And is it correct that employees of the accurately calibrated, how would you have known in the 4 Atomic Energy Commission refer to the National Bureau field? 5 of Standards handbook in connection with their work at A. The only way we would know that is if the 6 the Atomic Energy Commission? instrument didn't function properly in a way we would 7 A. Some people did, yes. have expected it. But the instruments are calibrated, 8 Q. Did you? and the calibration records were kept in the office. 9 A. We did not directly use these documents, Q. But you don't have those calibration 10 except to be aware of the information that's there. records; is that correct? 11 Q. What is the National Bureau of Standards, A. No, I do not. 12 if you know? Q. I am reading from a document entitled "Safe 13 A. National Bureau of Standards is an Handling of Radioactive Materials" that was published 14 organization that sets up certain standards. It's not by the U.S. Department of Commerce, National Bureau of 15 only radioactive material. Actually, most of its work Standards Recommendation of the National Committee on 16 is in other areas -- nonradioactive material areas. Radiation Protection, Report No. 30, National Bureau 17 Q. I'm going to read from one of the documents of Standards Handbook issued March 1964 and, beneath 18 that I've provided to you that is contained in the that, it states *supersedes Handbook 42." 19 National Bureau of Standards, and it's a reference to Are you familiar with the name I just read? 20 typical radiation survey meters. I'm showing the A. Yes. 21 witness the page that I'm referring to. It might be Q. Are these standards that employees of the 22 simpler if you thumb through that quickly, and it's Nuclear -- Atomic Energy Commission would have 23 the only chart of its sort. utilized in the early 1960s? 24 MR. SHIMADA: Which document did it come A. They are documents that we would have been 25 from? Page 166 Page 168 Page 165 - Page 168 Combs & Greenlev. Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I I MR. BROWN: Page 16 and 17. 1 1961 allow you to do quantitative analysis? 2 MS. MCKEITH: It's page 16 and 17 of the 2 A. it allowed us to do quantitative analysis 3 National Bureau of Standards Handbook issued September 3 to the extent it was required by the release criteria. 4 1949. 4 Q. What steps did you take, if any, to 5 MR. SHIMADA: Thank you. 5 determine whether or not there had been any releases 6 MS. McKEITH: Q.Did you find that 6 of radioactive materials at the Isotopes Specialties 7 document, sir? 7 Company during its operations that would have resulted 8 A. Yes. 8 in contamination beneath the concrete of the facility? 9 Q. And you see there's a reference to portable 9 A. The only thing that I did was review what 10 Geiger-Muller counters? 10 was in the -- in our license file in our office. 11 A. Yes. 11 Q. So you took no independent steps to confirm 12 Q. Drawing your attention to the fourth column 12 whether a licensee had, for example, buried any 13 over under "Ranges"? 13 radioactive materials on the property? 14 A. Yes. 14 A. Not in connection with the confirmatory 15 Q. It says "multiple range," nominal, maximum, 15 survey. 16 80,000 c/m"? 16 Q. In connection with day-to-day operations at 17 A. Yes. 17 a company such as Isotopes Specialties -- strike that. 18 Q. What does "c/m" stand for? 18 The fact that there was some 19 A. Counts per minute. 19 decontamination that was required at the facility, did 20 Q. The Geiger-Muller that you utilized, did it 20 that lead you to conclude that there had been some 21 have counts per minute on it? 21 releases of radioactive materials during the 22 A. No, it was in milliroentgens per hour. 22 operations? 23 Q. Does that lead you to believe that the 23 A. To the extent that it had been released 24 instrument that's being described in the document is 24 from the area for which it was being used, the answer 25 different than the Geiger-Muller that you utilized? 25 is yes. Page 169 Page 171 I A. Not different per se, but it reflects -- or 1 Q. So in the areas that were restricted areas, 2 it doesn't reflect the advances made in the 2 there were actually releases of contamination in those 3 instrumentation between the date of this document and 3 areas? 4 the time that I'm involved with it. 4 A. Yes. 5 Q. What this document says is "per rapid 5 Q. That you indicated were subsequently 6 radiation detection. Normally improper for 6 cleaned up through the use of -- you mentioned some 7 quantitative work." Was that no longer true in 1961 7 chemical agents? 8 that it was not proper for quantitative work? 8 A. I was not there when they did the 9 A. Depends upon what you mean when you say 9 decontamination, so I don't know the techniques, 10 quantitative work. You know, this report, which uses 10 except that I saw chips out of the pool. So I know 11 a sodium iodide detector - 11 that was the technique that was used for that. 12 Q. When you say "this report" - 12 Q. When there were releases in restricted 13 A. The report of the site characterization 13 areas back in 1961, is it possible that those releases 14 done by Rogers & Associates engineering unit. That is 14 would have penetrated the concrete and gone into the 15 what I would consider quantitative work, qualitative 15 soil below the concrete, based on your experience at 16 work. 16 the Atomic Energy Commission? 17 Q. I'm sorry, you just said quantitative and 17 MR. SHIMADA: Objection; lacks foundation, 18 qualitative? 18 calls for speculation. 19 A. It's quantitative here. I'm trying to 19 THE wrrNESS: To some extent, it would have 20 relate -- the instruments that were used here for 20 probably gotten into the concrete because concrete 21 making some of the assessments, which certainly - 21 always has minor cracks. Cracks that go all the way 22 Q. Sir, I would rather focus on the document 22 through would be different than surface cracks. 23 that you're looking at relative to what you used in 23 MS. McKEITH: Q.When you were conducting 24 1961 as opposed what the consultants used in 1999. 24 your release survey, was the purpose of the release 25 Did the Geiger-Muller that you utilized in 25 survey to determine whether or not there were safe Page 170 Page 172 Page 169 - Page 172 Combs & Greenley, Inc. (415) 512-1234 October 12, 1999 Raymond F. Fish, Jr. Volume I

I levels at a certain distance from a radioactive source I Q. In fact, would it have been unusual for beneath concrete at 2 as opposed to determining whether or not, in fact, you 2 someone in 1961 to conduct samples a decommissioning, based on your 3 had contamination remaining in the concrete or in the 3 a facility as part of 4 soil? 4 experience at that time? 5 A. The purpose of the confirmatory survey was 5 MR. SHIMADA: Objection; lacks foundation. 6 to provide information that said that we could rely on 6 THE WrINESS: Depends upon the activities 7 the results of the licensee survey. 7 and what occurred at the facility, whether it would 8 Q. In this instance, the licensee did not - 8 have -- in most cases, the activities were -- and the 9 well, strike that. 9 types of releases that did occur in facilities like 10 In 1961, was it possible to actually sample 10 that -- were such that it would not be normal to take 11 concrete for radioactive materials? 11 those kind of samples. 12 A. Sure, it was possible. 12 MS. McKEITH: Q.How would you know one 13 Q. Do you know whether Isotopes Specialties 13 way or the other what types of releases occurred at 14 Company ever sampled any of the concrete at its 14 that facility other than what your licensee reported 15 facility to determine whether there was radioactive 15 to you? 16 material in that concrete? 16 A. Inspection results would identify -- if 17 A. No, I do not know. 17 they had occurred, there's a reasonable expectation 18 Q. Now, you testified earlier that the 18 that it would have been detected and written up in the 19 concrete, in fact, serves as a shield to radioactive 19 inspection report. 20 materials. 20 Q. How frequently -- you were the head of an 21 A. Concrete can be used as a shield. 21 inspection unit during that time period? 22 Q. So if there was contamination beneath 22 A. No, I was not. I was just a radiation 23 concrete in an area where you surveyed, would that 23 specialist. Just one of the inspectors. 24 concrete have served as a shield for your detecting 24 Q. But you were familiar with the day-to-day 25 those radioactive materials? 25 procedures of an inspector during that time period? Page 173 Page 175 i A. Yes, it would have. I A. Yes, I was. Q. So if there was radioactive under the 2 Q. And during the approximately 1957 to '61 concrete at any location on the Providencia property, 3 time period, can you tell me approximately how many you would not necessarily have detected that with your 4 times a year you were required to investigate a survey; is that correct? 5 site -- or inspect a site? A. I would not necessarily have detected it. 6 A. I can't tell you exactly. I can tell you Q. And you took no independent steps to 7 that the system that was used, we -- the frequency of determine one way or the other whether there was 8 the inspections was related to the type of activities contamination beneath the concrete at any area of that 9 that were involved, and those that had a greater facility? 10 potential for problems were inspected more frequently A. No, I did not. 11 than others, and the inspection frequency ranged Q. Do you know -- did you review anything in 12 anywhere from twice a year to once every five years. the survey conducted by Isotopes Specialties Company 13 Q. So twice a year would have been the maximum from which you could conclude that they took 14 number of inspections that would have occurred at a independent steps to determine whether or not there 15 facility like this? was any contamination beneath the concrete? 16 A. Yeah. At this kind of a facility, it would MR. SHIMADA: Counsel, were you meaning to 17 be more apt to be once a year. say Isotopes Specialties Company? 18 Q. So other than the inspections that would MS. MCKErrH: Yes. 19 have occurred once a year, you -- you meaning the THE WITNESS: I do not remember any of the 20 Atomic Energy Commission -- relied upon what the details of their survey. 21 licensee told you with respect to whether there were, MR. SHIMADA: Object that it assumes facts. 22 in fact, releases at the facility? MS. McETrrH: Q.So you don't know one 23 A. Yes, but there was -- there were reporting way or the other whether they took any samples? 24 requirements in the regulations with respect to A. At this point in time I do not. 25 accidents and occurrences. Page 174 Page 176 I Page 173 - Page 176 Combs & Greenlev. Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I I I Q. Certainly. And assuming that somebody Providencia because of the contamination caused by the 2 actually followed those regulations, you may or may plaster; is that correct? 3 not have gotten information; is that correct? A. The problem was that the plaster tended to 4 A. That's true. absorb the contamination. The water would get into 5 Q. You described a slab in the backyard area. the plaster. It was more pervious to the water, and 6 Was this a concrete slab that was to grade? hence the contamination would get into the plaster, 7 A. To grade? and that created a decontamination problem. 8 Q. In other words, Mr. Patterson asked you Q. How do you mean "a decontamination 9 whether the slab was elevated above grade. problem"? What was the problem? 10 A. Yes, it was elevated above grade. A. There would be more activity there because 11 Q. Was there any pit in the middle of that it would tend to collect in there, and the more 12 slab -- a pit meaning a subsurface structure outside activity, the greater the problem of -- it's a matter 13 as part of that slab area? of physically going in and removing the plaster. And 14 A. I don't remember whether there was any kind that's just more work and more potential exposure to 15 of a pit in there at all per se. the people that are doing the work, than if you just 16 Q. So your recollection is there was no pit; had a bare concrete surface. 17 is that correct? Q. Was all of the plaster removed in 18 A. There was no pit if you describe a pit as connection with the decommissioning at 170 19 similar to that cobalt pool. Providencia? 20 Q. What about a structure that would be three A. Yes, it was. 21 to five feet deep, deep meaning below grade? Q. And then beyond that, you recollect that 22 A. At this point in time, I don't remember there was concrete that was chipped? 23 anything like that being in the slab. A. There was concrete -- the surface of the 24 Q. But based upon what you were saying concrete showed elevated radiation levels, and when I 25 earlier, if the license reflected that such a pit came back after it had been further decontaminated, it Page 177 Page 179 I existed, then the licensee should not have closed that was clear that some of that contamination had been 2 pit, meaning covered it up, before you conducted your removed by chipping. 3 survey; is that your understanding of what the Q. Did you physically ever go into the pool 4 regulations would have required at the time? and inspect it for cracks? 5 A. That's true. A. No, I did not. 6 Q. Are there any limitations to taking wipe MS. McKErrH: It's approximately 4:30 now, 7 samples on asphalt as opposed to concrete? and I would like to conclude the deposition for today. 8 A. It's more difficult to take a sample off of Mr. Fish has agreed to advise us whether 9 asphalt than it is on concrete because the surface is November the 8th, Monday, November the 8th, is a 10 not as smooth. convenient time for him to reconvene the deposition. 11 Q. So did you account for that in connection Thank you for your time today. 12 with the wipe samples that you described having taken VIDEO OPERATOR: This marks the end of 13 on asphalt? Videotape No. 3 in the deposition of Raymond Fish. 14 A. I took a sample of the asphalt in a method Going off the record at 4:32. 15 so that I would be able to detect whether there was 16 any removable contamination on that asphalt. (Whereupon, the deposition was 17 Q. But you took no steps to determine whether adjourned at 4:32 p.m.) 18 or not there was any contamination beneath the asphalt --oOo- 19 area itself? I declare under penalty of perjury that 20 A. That's true. the foregoing is true and correct. Subscribed at 21 Q. Now, you mentioned a conversation you had 21 , California, this day 22 at U.S. Nuclear concerning the plaster and the pool, 22 of 1999. 23 and you indicated that U.S. Nuclear stated words to 23 24 the effect that they did not intend to operate their 24 25 pool in the similar way that they had done at 170 25 Signature of the witness Page 178 Page 180 Page 177 - Page 180 Combs & Greenlev. Inc. (415) 512-1234 Raymond F. Fish, Jr. October 12, 1999 Volume I

I CERTIFICATE OF REPORTER I SIGNATURE AND ERRATA SHEET 2 2 (To be signed by deponent) 3 I, RAYMOND F. FISHKJR, do hereby declare under I, JULIE ANNE ZEIGLER, a Certified 4 the penalties of perjury that the foregoing aetimony Reporter, hereby certify that the witness in 5 Shorthand is true and correct (with the exception of the the foregoing deposition was by me duly sworn to tell 6 following changes listed below): truth, the whole truth and nothing but the truth 7 the Page Line Changerorrection Reason in the within-entitled cause; 8 That said deposition was taken down in 9 shorthand by me, a disinterested person, at the time t0 and place therein stated, and that the testimony of 11 the said witness was thereafter reduced to 12 typewriting, by computer, under my direction and 13 supervision; 14 I further certify that I am not of 15 counsel or attorney for either or any of the parties 16 to the said deposition, nor in any way interested in 17 the event of this cause, and that I am not related to 18 any of the parties thereto. 19 20 DATED: ,1999. 21 Executed this __ day of _ 1999, 22 at 23 24

JULIE ANNE ZEIGLER, CSR 9570 25 RAYMOND F. FISH, JR- Page 183 Page 181

1 October 25, 1999 2 SIGNATURE AND ERRATA SHEET 2 Raymond Fish 3 (To be signed by deponent) 3 12 Doral Drive Moraga, CA 94556 4 I, RAYMOND F. FISH, JR., do hereby declare under 4 Re: Joseph A. Thomson, et al. vs. ICN 5 the penalties of perjury that the foregoing testimony 5 Pharmaceuticals, et al. 6 is true and correct (with the exception of the 6 Dear Mr. Fish: 7 following changes listed below): 7 Please be advised that the original transcript of your deposition taken October 12, 1999 in the 8 Page Line Change/Correction Reason 8 above-entitled matter is available for reading and signing. The original will be held at the offices of: 9 9 Combe & Greenley 10 10 49 Stevenson Street Suite 400 11 11 San Francisco, CA 94105 12 12 for thirty (30) days in accordance with Federal Rules of Civil Procedure Section 30(e). If you do not sign 13 13 your deposition within 30 days, it may be uaeds fully as though signed. 14 14 If you are represented by counsel in this matter, you 15 15 may wish to ask your attrney how to proceed. If you are not represented by counsel and wish to review your 16 16 transcript, please contact our office for a mutually convenient appointment to review your deposition. 17 17 Thank you for your cooperation in this matter. 18 18 19 19 Sincerely your, 20 20 21 Executed this __ day of ,1999, 21 Julie Anne Zeigler, CSR 9570 22 at 22 23 23 ce: Original transcript GREGORY 1. PATrERSON. Attorney at Law 24 24 MALISSA HATHAWAY McKEITr, Attorney at Law JOHN HKSHIMADA, Attorney at Law 25 RAYMOND F. FISH, JR. 25 BRYAN K- BROWN. Attorney at Law Page 182 Page 184 Page 181 - Page 184 Combs & Greenley. Inc. (415) 512-1234 Fish, Jr. & - accumulation Raymond F. October 12, 1999 I I 127:6 184:3,7 1970[s] 3:19 142:10,16 3200 [11 5:7 133:19,24 134:2 120011] 5:12 142:18,20 341i1 126:10 75 1] 2:18 1971 [1 11:20 35 11] 126:11 & 1121 4:17 5:2,11,16 6:15 122 pi 3:5 123 111 3:7 1975 [4]36:14 37:5,18 355 pi1 5:16 -8 6:18,21 118:25 119:5 37:20 135:22 170:14 184:9 126 [11 3:9 3:07 [1 135:15 814] 3:3 60:17 118:17,19 36:21 37:2 38:3 1980[41 !3:09Il11 135:18 80 [5] 119:20,21,22 134:22 127 [11 3:11 41:19 3:27 [11 146:2 135:4 12:0411] 66:11 1989[21 41:18,20 3:32 111 146:7 80,000 11 169:16 '5911] 37:9 12:17[21 75:1,2 199612] 3:13 134:5 3:36 I11 148:12 84467111 1:23 '60s [21 40:11,14 12th 1l1 6:2 1997121 3:15 135:21 3:41 111 148:15 8a [21 66:23 67:18 '61 [3] 39:10 87:21 176:2 13 [2] 3:12 134:9 199911o] 1:20 4:16 6:2 8th[4 3:13 134:5 180:9,9 '62 [11 148:22 134111 3:12 170:24 180:22 181:21 3rd11] 61:10 1 '68 11] 37:17 135 [113:14 182:21 183:21 184:1,7 '6911] 37:17 137 [11 95:17 1:0011] 75:7 -4- 1 -9- '70s [11 8:23 14 [1 3:14 127:13 128:6 1:12111 75:4 4[3] 2:16 60:23 66:21 9 14 3:5 114:24 122:3,5 136:2 '75 [2] 8:23 37:9 128:8,15,17 lst[1] 59:19 4-5241-1 [1] 61:15 90012 [135:13 '77 [11]8:24 14612] 3:16,20 4-580-6 [21 60:17 63:2 90017-2475 [1] 5:3 14811] 2:6 -2 4-580-7 121 60:25 63:2 90067-3206 [11 5:7 14th [l] 4:18 2 [24] 2:12 55:7,11 58:25 4-580-8 [21 60:25 63:2 90071 [1] 5:18 15 [41 3:16 114:15 146:13 59:2 71:11 72:2 75:6 4-6[11 3:11 91 11] 2:21 .01 11]135:5 146:22 76:13,18 77:8,13,17 130:9 4-7 pi 127:21 94105 [1] 184:11 .011 [11 135:4 15-foot [1i 115:2 130:13 139:7 143:7,10,19 4-9111 3:11 94556[11 184:3 .022 [1] 135:6 16141 3:20 146:19 169:1 143:22 146:1 157:19 128:12 9570 131 1:23 181:25 .08 t11 135:5 169:2 160:3 163:24 4.1 1] 2-inch [1i 113:24 4.711 127:9 184:21 .2 [11 120:6 167 [113:22 97-5220 [11 6:1 4/17/99[l] 119:9 .25 [71 72:9 120:10 121:7 1"7 161 3:15,22 167:10,23 20 [5] 29:9 75:15 161:2,2 121:8,8,15 135:7 161:4 4/99 [11 92:1 169:1,2 -A 170123] 2:23 52:11 61:8 20.102 [21 75:25 80:3 40 pi 10:23 -0 61:18 62:14 63:5,25 65:24 20.4 141 80:16 81:2,3,16 40011] 184:10 A.A[ix 2:10 78:5,12,16,24 79:22 83:14 5:6 6:3 0.1 [11 120:3 2049 [11 42[21 166:19 167:18 a.m[2] 4:17 88:6 134:17 139:2 151:11 22 [5s 3:19 119:21,22 0.2 [1i 143:8 4400 [ji5:17 abandon 111 42:14 155:2,9 157:12 178:25 135:1,5 0.25 14] 72:1,3,7 143:10 179:18 48 [11 167:15 ability131 11:7 126:16 221 121 5:12 130:22 144:20 001937 [11 3:13 1771 [1] 143:13 49[11 184:10 2221 11] 127:23 able [al 17:8 56:24 100:22 17th [p 135:21 4:10[1i 167:5 001947[1] 134:16 22nd[11 142:10 119:23 123:23 129:19 18 121 71:23 72:4 4:12 1ii167:8 00196011] 3:13 230[ij 156:3 157:9 178:15 180[11 28:15 4:3011] 180:6 23rd 111 63:6 above 112] 71:25 72:7 -1 1800 I11 5:3 4:32121 180:14,17 95:10 101:23 107:16 24-foot [1] 115:2 181 11]1:21 4th i]61:13 110:13 111:2,17 121:7,8 1 [261 1:21 2:10,14 5:23 25 [21 127:13 184:1 177:9,10 29:6,7 52:25 53:3 57:25 19121 128:3 133:9 27-7 [11 59:7 above-entitled pi] 58:1,7 63:17 65:2 71:11 1949 [2] 167:19 169:4 -5 74:25 76:11 77:15 80:14 2:24 11 121:23 184:8 1951151 11:20 12:18,21 5 141 2:18 75:12 113:20,23 81:11,11,17 128:1 135:8 2:39[11 122:1 absence [p] 162:20 15:13 167:15 50121 127:16 160:8 143:8,18,19 2:47 [1] 126:23 Absent 11] 82:18 1,0001[11 114:1 1953131 15:9,14,24 500 [41 78:3,9,12,13 1956 pi 19:12 2:4811] 127:1 absorb pi] 179:4 1,331,200 111 123:19 52[1] 60:18 1957 [11176:2 absorption [11 81:18 1-211] 2:21 527 [11 67:6 accelerator [11 20:16 1958 [21 2:20 75:17 -3 10 114 2:18 3:7 29:5,7 53 pi 2:10 accept 11] 155:5 1959131 22:9 23:24 37:5 3 [19 2:15 55:8 56:5,6 58:1,7,8 73:5 75:15 58 111 2:12 acceptable pj 54:7,8 123:3,5 135:1,5 63:6 75:20 133:9,10,11 64:10,13 71:11,22 72:2,4 104:12 580-6 [i1 60:24 76:20 106:1,6 121:15 1960 [31 8:22 39:10 75:20 72:10 76:1 77:15 92:21 100 6] 58:1,8 77:11 81:18 127:11 140:12 141:1 132:25 81:19 160:8 1960s 121 7:25 166:24 146:5 180:13 -6 accepted [21 55:11 1000 [1] 5:2 1961 [251 2:14 31:13 117:16 3-1 [2) 3:3,9 6[s] 2:21 91:3 108:6 106121 119:19 121:9 45:21 47:4 55:1 57:7 access [11 44:7 59:19 61:10,14 82:9 84:12 3-24 [1] 123:12 113:24 114:14 10:08 [21 4:16 6:3 85:15 90:17 125:18 132:8 3-3 111 3:7 64111 2:15 accessible [31 76:21 126:1,3 134:22 107:2 147:18 11 6] 3:9 132:19 142:21 148:22 3-8 [11 3:5 2:16 135:3,4 66 [1] 158:4 170:7,24 171:1 3.1 131 118:22 121:7 126:9 accident [2] 38:9 39:4 113 111 2:22 172:13 173:10 175:2 [11 176:25 3.3 pi 123:11 -7 accidents 118 ji 3:3 1962 [11 83:7 accordance 121 132:25 3.8 [1] 122:9 7 [7 2:5,22 60:17,24 11:04111 41:12 1964[1] 166:18 184:12 3/30/99 [1] 119:8 113:15,17 134:16 11:12[11 41:15 1966 [21 3:23 167:12 account 12] 29:10 178:11 30 [9] 2:19 75:17 120:5 70 121 79:20,21 11:56[11 66:8 196811] 37:10 166:17 accumulated l[ 125:5 127:15 160:15 703161 53:11 63:8 120:11 12p[1 1:20 3:11 4:16 75:7 1969ij 37:10 184:12,12,13 accumulation j21 125:9 A A ______Index Page 1 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. accurate - Bethesda October 12, 1999 125:10 agreement [9183:2,6,9 appear [3] 64:24 65:1 assignment [2] 15:19 B-I-a-n-c [11 39:16 127:22 60:4 bachelor[1] 11:13 accurate [3] 9:24 150:24 83:11 86:6,13,16,18,24 152:16 ahead [1] 7:3 appeared [s1 4:20 5:5,9 assignments [21 14:6 bachelor's [31 11:17,19 5:14,19 37:12 12:11 accurately [il 166:4 air [21 82:2,3 assist 11] 38:12 acknowledge il] 60:1 al[21 184:4,5 application [p] 79:15 background[7 11:10 applications [pl 65:19 assistant[1] 39:16 34:17,25,25 122:22 acknowledged [3] 60:7 Alexander [21 39:20 165:20,23 60:10,11 40:5 apply [41 63:10 80:5 associated [3] 34:7 65:20 161:1 backup [31 50:5,15,17 acted pi 130:2 allow [9] 58:3,8 68:16 157:21 162:13 71:24 98:16 105:15 appointment [1] 184:16 Associates [3] 119:1,5 backyard [2] 151:23 action [I1 8:17 177:5 107:13 132:6 171:1 appropriate [3] 17:16 170:14 activities [291 8:19 13:4 allowable pi 56:14 49:4 116:14 assume[3] 10:21 113:25 Bailey [1] 3:12 16:24 24:10,10 25:7,9 114:16 26:1,2,3 33:16,16,23 34:2 allowed [6] 38:21 45:11 approximate [2] 54:16 Barbara [1] 39:22 34:23 39:9 40:11 41:1 45:23 108:4 159:7 171:2 95:20 assumes [2] 153:18 bare ilj 179:16 174:22 80:5 102:16,19 103:16,19 allows 121 9:24 130:18 April [41 3:13,19 134:5 based [13] 96:18 127:17 103:20 141:5,6 175:6,8 almost [2) 19:13 145:24 142:10 assuming [gu 71:13,20 132:4,7 151:9 156:5 157:4 176:8 apt[I1 176:17 87:17 92:3 120:4,17 160:14 162:19 163:14 along [2] 39:6 77:5 121:15 177:1 activity [271 8:18 15:3 area is61 22:19 24:11 172:15 175:3 177:24 25:10 27:18,22,23 31:1 alpha S61 3:8 18:15,17 assure [] 80:6 18:17,19 23:7 28:7 29:8 31:19,21 34:18 35:25 36:2 bases [p1 79:16 41:25 54:23 58:4 80:9 54:16,17,23 58:13 70:17 Atlanta [1] 40:15 basis [31 46:3,13 79:6 87:17 93:23 101:3 102:22 30:12,15 101:3 123:13 124:7,8 156:1,3,7,19,25 73:2,6 76:9,12 77:10 atmosphere [1] 16:15 Bates [21 80:22,25 107:20 109:1 118:23 78:17 82:19 92:10,11,14 123:24 128:22,25 131:9 157:5,9,12,14,22,24 158:3 Atomic [331 2:11,18,18 Bates-stamp [1] 143:12 158:8,10,12,13,20 159:9 93:11,15,16,19,22,25 94:4 24:18 131:22 144:11 165:7 8:10 16:22,25 23:25 Bates-stamped [3] 3:13 159:10,21 160:1,5,5,12 94:5,9,18 95:24,25 96:5 31:3 32:10 179:10,12 25:18 26:12 80:24 134:16 160:18,22 161:1,3,6,10 96:14 102:25,25 104:5,11 33:5,12 36:10,12,18,20 actual [3] 50:8 90:14 161:15,18 162:1,4,5,13 104:14,23 105:7 106:7 bathroom piz 121:20 149:24 43:16 51:16 53:9 59:15 162:14,17,24 163:17,19 108:11,12,21,25 109:2,5 70:20 75:15 79:12 86:6 Bay [si 91:12,18 112:7,7 addition [11 44:4 163:21 109:15,17,21,24 110:2,9 142:3 162:2 166:23 168:4 112:7,18,22 149:22 110:17 111:7,9,21,24,25 additional [211 48:2,3 alpha-emitting [p] 168:6 172:16 176:20 Bay-A [21 91:13,16 97:5,9 98:2 113:20,21 114:19,25 69:21 72:1,6 161:21 attached [91 7:17 135:22 bays[s] 103:19 112:5,11 101:7 102:2,16,24 106:8 115:6 118:5 123:16 alters [1] 77:6 125:15 129:8 130:6,9 136:10 139:7 146:16 112:13,24 113:1,2 151:25 106:21 107:20 108:1,5 167:12,16,19,19 139:17,19 150:10 154:18 always [71 31:11 45:1 134:21 139:16,17 149:22 beams [91 140:10,14,17 49:9,11 51:10,11 172:21 151:22,23 152:25 171:24 attempt [71 9:16 30:6 141:13,17,19,21,23,23 address [] 51:1 107:9 ambiguous [,1 145:17 173:23 174:9 177:5,13 50-1 56:13 98:23 bearing [11 144:20 adequate [il 140:7 178:19 147:1 amendment [3] 61:14 became [p 26:11 36:15 adjacent[1] 105:10 62:13,15 areas [441 3:9 14:19 34:20 attend [1] 22:7 69:18 83:6,9 86:13,18 adjourned [Il 180:17 38:10 41:8 46:25 47:16 attention [1] 169:12 amendments [71 2:19 47:20 48:1 76:3,20,21 become [21 33:20 60:8 administration [2] attorney [101 5:4,8,14,18 25:13 43:12,13 50:13,25 92:23,24,25 96:22 97:1,4 becomes [11] 161:7 11:16 25:3 75:17 181:16 184:15,23,24,24 97:13 103:8 109:3 112:4 becoming [s] 34:1,8 86:5 [2] 8:9 184:25 administrative America[to] 2:12 17:12 112:8,10,16 122:15 86:16,24 9:5 17:19 19:11,19 20:21 61:7 attorneys[2] 31:23 32:4 126:10,12 134:21 139:14 beginning [11 146:5 administratively [1] 61:12,16 62:25 140:2 147:18 151:19 attributable [i 55:22 begins [2] 5:22 75:5 24:22 American[21 15:18 17:4 152:4 153:14 154:13,19 authority [11 42:14 [s1 5:5,9,14,19 advances pi 170:2 among [21 31:9 36:3 164:21 168:16,16 172:1,1 [4152:4,5 behalf authorize 6:13 8:2,4 118:12 advise [1] 180:8 amount[9] 18:16 54:23 172:3,13 61:15 62:14 below [zif 113:25 114:16 advised [2] 61:9 184:7 56:13 58:12 77:22 82:3 Argonne 13] 25:21 26:9 authorized [1] 76:6 27:13 120:10 130:9 135:7 AEC 1il 2:19 37:20 84:2 104:10 165:7 automatically [11 72:4 arising [1] 7:16 152:20 153:8,13,20 43:10 49:23 59:15,17 amounts [3] 131:9,22,25 available [5] 27:25 44:8 154:13,18 172:15 177:21 62:24 75:16,20 86:22 analysis [7j 13:6,12 Arizona [1] 24:12 161:9 162:25 184:8 182:7 183:6 139:3 arrow [21 58:19,20 73:22 85:23 148:4 171:1 Avenue [1] 5:17 beneath [s] 127:14 AEC's [11 164:20 171:2 arts[11 11:13 average [s] 78:4,7,10,12 166:18 171:8 173:22 Aerojet [s] 20:22,24 analytical [4] 12:4 13:1 aside [4] 35:9 69:19 96:21 78:15,20 79:18 119:8 174:9,16 175:2 178:18 21:21 22:8,11 23:2,11,23 13:3 15:13 112:25 Aviation 13) 15:18 17:4 bent [1] 92:22 affect [21 29:24 120:25 analyze [1i 20:19 aspects p1] 33:21 20:21 Berkeley [21 25:8,8 afternoon [31 75:4,8 analyzed 13:7,9 asphalt [14] 109:7,8,12 avoid [11 10:5 best [I] 7:11,19,24 9:18 148:17 72:15 85:21 148:2 110:13,14,17 111:3 aware [121 11:3 29:22 10:14 11:4 27:3 30:22 again [10] 10:14 11:22 Angeles [41 5:3,7,12,17 123:16 178:7,9,13,14,16 30:7 33:9 99:14 154:25 36:2 99:6,7 178:18 31:20 56:11 95:23 108:7 animals it] 34:13 155:4 159:1,6 165:22 beta [241 3:8 18:2,4,12,16 114:16 120:24 138:20,25 Anne [s] 1:23 4:19 181:4 assess [3] 46:23 54:4,23 167:1 168:10 29:3 30:12 80:13 100:25 against [11 7:23 181:25 184:21 assessment [21 13:16 away [4] 40:1,19 57:4 123:13,18 124:7,8 155:25 160:6 agency [31 38:9,10,14 answer[121 9:22,23 11:1 109:23 121:3 156:3 157:6,9,15,22 161:5 165:4 agency's [p] 38:21 21:6 87:3 89:13,18 121:11 assessments [31 33:25 160:13,23 Betas I1] 30:17 agents [] 172:7 139:12 144:14 153:19 34:15 170:21 -B 171:24 assigned [5] 13:4 22:13 Bethesda [1s] 24:23 43:6 ago[41 7:12 8:21 10:23 b [5] 76:5 81:16 112:7,18 163:15 answered [2] 103:14 59:11,14,16 44:15 49:20 51:21,22 130:8 112:22 87:11 116:19,22 117:1,10 agreed 1v 180:8 assigning [1] 60:5 Index Page 2 Combs & Greenlev, Inc. (415) 512-1234 Raymond F. Fish, Jr. better - conducting October 12, 1999 117:13,14 149:21,25 buried[1] 171:12 77:22 84:2 104:10 107:22 cleaning [2] 23:12 33:6 comparison [21 34:22 167:20 better 1] 30:14 business [21 11:15 152:6 168:14 173:1 cleanup [31 52:20 53:18 [31 22:4 170:21 101:7 complete [1] 50:20 [131 10:18 28:24 byproduct [3] 3:18 certainly between 177:1 28:25 29:9 32:19 56:19 55:22 61:1 clear[4] 7:10 32:6 153:25 completely [1] 50:3 57:13 71:24 80:12 81:22 CERTIFICATE [] 180:1 completion [1] 63:11 181:1 100:22 157:5 170:3 -C client [2] 8:2,4 compliance [3] 24:13 beyond [11 179:21 Certified [21 4:19 181:4 clients [1] 7:13 41:2 54:4 C [] 112:7 bgs [2] 113:24 114:16 certify [21 181:5,15 close [31 69:12,21 120:17 complying [1] 79:23 C-14 [21 94:1,23 big[31 35:25 99:1 149:12 Cesium [41 100:11,12 closed [s] 68:20 164:13 component [21 33:23 C-53 [11 60:17 bigger[p] 79:2 137:2 138:24 164:14,22 178:1 163:22 C-5352 [2] 61:2 63:2 cesium-137 [4] 113:23 Bill [3] 40:1,18,19 closing [I1 153:8 components [3] 26:6 c-e-s-i-u-m [11 100:11 127:17 138:14,21 158:13 163:20 biphenol [1 16:19 coating [1] 98:2 c/m 121 169:16,18 chamber [m 84:4 composition [1] 163:12 Bisgaard [31 4:17 5:11 cobalt [121 97:18 100:9 6:18 CA[2) 184:3,11 chance [51 64:15 122:8 101:6 110:10 114:21 computer[[1 181:13 123:7 126:6 134:12 128:19 137:2,3 154:9 bit [s5 20:9 44:11 61:4 calcium [11 13:9 conceivable [21 51:12 105:11 110:4 calibrated [5] 70:25 71:2 change [9] 15:10 22:10 164:9,13 177:19 129:11 36:19 37:8 51:1,1 58:4 [21 138:13 Blanc [2] 39:16 40:2 166:1,4,8 cobalt-60 concentration [M] 111:14 160:25 139:3 123:18 blip [p 165:20 calibration [5] 71:3,5,6 166:9,10 Change/Correction [21 coincide pi 158:19 concentrations M] block [2] 30:15,16 182:8 183:7 California [491 1:3 2:24 collect [SJ 28:15 34:4 126:12 blocked [11 30:14 37:11 157:11 3:22 4:3,19 5:3,7,13,17 changed 121 125:17,19 179:11 concerned [21 25:23 body 1] 160:21 5:25 6:6,24 12:22,23,24 changes [8] 9:13,14,15 collected [1] 34:21 89:11 13:23,24,25 15:7,14 16:2 20:19 49:4 116:14 182:7 book [1p 43:13 collection [3] 13:5 125:7 concerning [41 8:19 183:6 booklet [21 9:11 10:5 16:3 20:23 22:14 24:4,12 128:13 138:5 155:9 178:22 40:3,4,8 52:12 61:8,19 changing [] 157:8 bore [11 128:13 63:9 83:2,6,9,10,11 86:5 collective [1] 157:23 concerns [1] 147:24 borings [1] 82:11 characterization [21 Collins [1) 6:4 concert [1] 30:25 86:7,10,13,15,21,23 87:5 118:23 170:13 bottom [s] 28:18 67:8 118:25 167:11 180:21 column [31 80:18 81:5 conclude [31 171:20 charge [2] 36:23,25 70:3 98:23 101:12,15 calls [1o0 56:9 63:20 169:12 174:14 180:7 chart [21 167:19 168:23 123:15 136:25 71:17 82:22 121:18 144:9 combination [1] 21:3 concrete [50] 30:23 32:22 Boulevard [1) 5:2 145:17 153:17 154:20 check [2] 108:23 157:12 Combs [1 184:9 94:20 95:24 98:1,3 99:12 boundaries p1 55:23 172:18 checkedf2] 93:16 107:14 99:15 100:4 102:22 110:9 comfortable (1] 7:18 110:19 114:10 127:14 box [4] 66:25 67:24,25 cancer[1] 82:6 chemical [11 172:7 coming [a1 13:18 39:6 129:18 130:1 139:6,10,16 68:14 capability [3] 18:15 chemicals [21 32:15 76:25 99:24 103:2 106:20 20:13 161:14 139:20,23 140:11,15,25 brand [1p 18:25 103:10 109:1 147:3 141:20 151:22 171:8 capable[21 18:18 161:18 break [8] 27:6 41:13 chemist[3] 13:1,3 15:13 commencing [1] 4:16 172:14,15,20,20 173:3,11 74:23 121:21,24 145:23 capped [11 114:9 chemistry [7 11:14 12:4 comments [] 38:18 173:14,16,19,21,23,24 146:3 148:13 177:6 carefully [1] 109:9 12:4,5,5,6 72:24 Commerce [ij 166:15 174:3,9,16 175:2 briefly [t] 11:25 178:7,9 179:16,22,23,24 case[2o] 6:1 29:8 32:11 chemists [11 14:19 commission [40] 2:11 Brisbois [31 4:17 5:11 32:19 41:5 51:14 52:10 chief [1] 36:23 concrete-lined [1] 2:18 8:10,11,18 16:22,25 115:3 6:18 59:16 60:12 69:21 70:13 chipped [3] 32:23 102:21 23:25 24:11,19 25:18 broke [11 37:20 70:18 78:10 84:4 85:20 179:22 26:12 31:4 32:10 33:5,13 conduct [261 14:1 46:16 94:11 115:16 157:7 162:7 56:1 57:8 62:16,17 70:21 Brook [3] 116:16,17,25 chipping [ij 180:2 36:11,12,16,18,20 37:3 163:8 37:22 42:8 43:16 51:17 82:21 83:15 92:13 93:14 brought [3j 34:16 135:20 chips [11 172:10 case-by-case [21 46:3 53:9 70:20 75:15 76:6 94:3 108:10 111:7 112:16 147:8 46:13 chloride [i1 138:14 118:7 134:1 139:22 5:16,18 6:20 79:12 86:6 134:6 142:3 Brown [91 cases [41 44:23 87:10,11 circles [21 122:20,20 162:2 166:23 168:4,6 140:20 149:6 150:9 6:21,21 8:3 103:14 169:1 175:8 172:16 176:20 152:12 154:17 162:23 184:25 circular[11 28:13 163:1 175:2 Cassalina [3] 39:17 40:9 Committee [t] 166:16 Bryan [3] 5:18 6:20 circulate [] 100:3 conducted [471 8:10 45:3 40:10 common [1] 125:19 184:25 circulated [p] 43:19 47:2,22 52:1 71:8,15 82:8 [31 109:9 160:22 building [321 21:3 33:21 caused Civil ij 184:12 communications [M1 83:1,8,18 86:25 87:4 179:1 62:21 94:6,10,13 95:20,23 96:12 clarified [i1 31:22 89:17 92:5,9,14,18 93:10 caution [21 9:14 10:17 [23] 2:13,23 95:2,8 97:20 102:16 96:23 97:13 103:18,19,20 clarify [31 32:3 67:13 company 106:22 6:5 12:22,25 14:1 15:8 103:13 108:16 111:10 104:4 105:22 cc[t] 184:23 156:14 108:7,18 110:2,6,7 111:18 ceased [21 103:17,20 16:4 20:23 21:2 53:10 113:4 115:6 118:3 123:1 111:22 112:14 135:1,2 Class [2] 91:12,22 61:7,11,17 62:9,25 103:9 124:14 125:14 132:4 cells [21 94:12,16 139:6 147:21 151:11,15 clean [4] 23:15 32:12 136:23 149:15 152:5 133:3,13,23,23 139:20 151:15,17 center [3] 21:18 67:11 33:1 108:5 153:13 155:5,21 171:7,17 140:15 142:2 149:4,16 68:11 buildings [2] 63:14 clean-up [20] 46:9 64:25 173:14 174:13,18 150:4,25 152:21 174:13 134:22 centimeterp[] 143:9 65:1 77:14 101:23 102:16 Company's [1] 159:2 178:2 Burbank [81 2:23 52:12 centimeters [5] 54:18 105:23 107:16 108:2 comparable [1] 158:14 conducting [27] 13:14 53:12 61:8,19 63:8 118:25 54:22 127:14,15,16 113:11 115:10 120:11 45:7 47:9 49:25 50:9 51:4 158:3,8 compare [21 85:10 51:5 52:15 64:3 65:23 133:20 central [5] 1:3 4:3 5:25 121:16 157:20 162:19 43:21 84:3 159:8,21,25 160:14 71:14 74:5,9 82:10 83:17 Bureau [10] 166:15,17 [21 30:3 [3] 112:19 compared 96:1 112:8 118:12 124:11 167:15,18 168:1,4,11,13 Century [i 5:6 cleaned 124:14 139:24 172:6 132:18 140:22 148:22 168:19 169:3 certain [i1 19:24 30:7 Index Page 3 Combs & Greenlev, Inc. (415) 512-1234 confirm - detecting Raymond F. Fish, Jr. October 12, 1999 167:21 171:3 171:19 172:9 179:7,8 150:20 153:9,15 155:10 162:5,13,14,18 163:23 65:21 172:23 167:14 171:8 172:2 173:3 corresponding [1i crystal [fi 35:13 deemed [i1 76:19 173:22 174:9,16 178:16 [21 177:21,21 [4] 46:21 97:9 81:18 CS[11 95:16 deep confirm 180:1 108:23 171:11 178:18 179:1,4,6 corresponds [1i 77:13 CSRI[3 1:23 181:25 defendant[9] 1:12 2:9 confirmation 1i1 46:16 continual [1] 23:17 Council [2] 44:5 79:5 184:21 4:12,23 5:9,15,19 6:9,19 confirmatory p5s] 42:18 continually [1] 76:12 counsel 11o1 5:5,9,14,19 curies [11 114:1 Defendant's [16] 53:2 42:19 44:21 46:17 48:5 continue [3] 37:16 62:20 6:10 7:9 174:17 181:16 current [3 6:16 63:10 59:1 64:12 66:20 75:11 122:4 48:25 49:6,9,25 50:10 62:23 184:14,15 148:19 91:2 113:16 118:18 123:4 126:2 127:5 134:8 51:6,7,9 52:1,16,17 57:8 continued [21 3:1 164:14 counted [4] 72:17 84:1 customers [21 155:6,15 65:23 67:5 70:21 136:1 146:12,18 64:3 continuously [11 77:9 105:20 157:14 cutruj 11:21 71:14 72:13 74:10,16 83:1 deficiencies [11 38:20 contract [4] 22:14 25:3,6 counter[1] 98:18 [1] 83:5,8,12 85:14 86:25 Cutie 28:5 define [21 54:5,6 88:12 92:9,15 113:3 25:9 counters [3] 15:5 58:21 CV [] 6:1 [i 6:4 169:10 definite[i] 160:10 115:19 117:11 123:1 contracted CV-97-5220 [21 1:8 4:8 125:21 132:4,10,12 contracts [] 16:25 counting [s] 73:17 82:2 degree[s] 11:13,18,19 Cypher[1] 128:2 12:3,11 133:12,23 140:16,19,22 control [7] 3:23 34:5 80:2 84:5 85:6 148:5 142:2,6 147:10,13 153:23 92:1 129:9 167:11,13 counts [36] 54:15,17 degrees [1] 28:15 162:9 171:14 173:5 -D [4] 1:10,10 convenient [2] 180:10 83:20,22 84:6,8,12,17,19 Delaware confirmed [21 42:19 184:16 84:20,21,24 85:4,8,11,12 D[3] 2:1 13:21,22 4:10,10 132:10 85:18,22,23 123:19,19 density [11 69:21 conversation [i 178:21 125:5,7,10 D'Amato [3] 4:17 5:11 confirming [1] 42:22 124:13,17 [3] 24:18 conversations [1] 126:13 128:1,4 130:17 6:18 department 134:6 166:15 confused [11 163:14 117:13 131:7,9,11,14 169:19,21 damage [11 160:22 dependent [ij 58:11 connected [1] 67:25 conversion [51 29:4 couple [4] 12:8 41:10 damaging [2] 161:3,4 connection [s] 22:24 54:19 84:7 160:24,24 91:24 147:9 data[31 125:17,19 132:3 depending [21 15:2 70:9 66:25 147:6 168:5 171:14 convert [9] 54:19 85:24 course[201 12:13 14:20 date[3] 2:13 6:1 170:3 depicted [11 152:1 171:16 178:11 179:18 119:23 124:3 86:1,2 14:21 21:25 22:1 26:2,4 3:13,15,19 61:9 depicting [1l 122:13 consecutive [11 77:11 130:19 135:2 dated[91 126:16 26:20,22 28:3 30:4,22 61:13 142:10 167:12,15 depicts [t] 122:14 consider [i 170:15 31:11 32:24 33:15,18 44:3 coolants[1] 16:10 181:21 deponent [21 182:3 183:2 considered [7] 16:10 78:11 86:18 120:17 cooler[1] 95:10 day-and-a-half 11i deposited[21 81:24 82:7 63:7 76:17,23,24,24 81:9 40:1,18 courses [is] 12:1,2,6,7,9 149:10 Cooley [4] 39:17 deposition [28] 1:17 consisted [11 102:19 40:19 12:10,12,12,13,14 21:24 25:21 26:8,17,19 day-to-day [21 171:16 5:23 6:7 7:9 8:6 9:8 53:1 consistent [21 111:14 cooling [1] 34:20 175:24 64:11 74:25 75:6 126:6 153:16 court [s] 1:2 4:2 5:25 134:13 142:13 146:1,6 cooperation [11 184:17 6:23,25 9:9,24 58:24 days [6] 77:12 149:8,8,11 constitute [1] 104:13 184:12,13 147:1,3 167:20 180:7,10 coordinates [1i 119:20 cover[3] 27:15 105:1 constructed 11] 97:24 de[31 56:15 63:7,9 180:13,16 181:6,9,17 copies [31 43:11,18 51:24 153:22 184:7,13,16 consultants [11 170:24 deal [1] 14:6 copy [91 45:14 52:2 63:9 covered [71 12:3 43:24 depth [1] 127:16 contact [71 39:24 40:5 65:19 80:24 88:9 117:17 151:15 dealing [6] 25:6 78:24 62:24 96:13 11:11,25 40:12 44:19 51:8 76:25 119:2 149:20 164:23 178:2 158:11,11,17,20 describe[1a1 184:16 17:10 20:9 21:23 24:24 cord [1 107:13 covering il 111:5 dealt [1] 25:25 25:20 26:4 27:24 40:23 contain [5] 45:17 48:13 core [61 21:13,14,15,16 coverings [11114:7 Dear[i] 184:6 67:24 89:19 92:8,17 95:25 50:16,20 162:7 21:17,19 CR [21 13:21,22 December[sj 3:15 41:18 111:10 165:2 177:18 contained [4] 55:22 cores [11 21:2 41:20 63:6 135:21 [1s1 26:19 65:18 141:8 168:18 crack [21 32:22,22 described 60:14 35:10 95:24 100:20 104:5 corner[5] 59:6 [121 99:10,13,14 decide [1] 104:18 container [1] 73:11 cracks 111:22 150:8 91:11 110:20 128:17 99:15,15,17 109:8 147:25 decided [11 159:16 108:17 containing [21 2:19 151:8,23 156:24 167:13 corporation [21] 1:10 172:21,21,22 180:4 decision [1] 132:6 75:17 1:10,11,11 2:12 4:10,10 169:24 177:5 178:12 create [1] 76:9 182:4 contains [3] 2:16 21:17 5:15 6:19 61:6,11 declare [3] 180:19 describing [3] 96:18 4:11,11 183:3 66:13 61:13,14,16 62:13,17,22 created [31 137:17,25 105:6 149:7 179:7 [i contaminants [2] 63:4 62:24 74:4 decommission description [41 2:8 3:2 44:13 155:19 Corporation's [1] Creates [1] 84:2 89:16 90:2 contaminate 11] 144:3 155:13 creating [11 79:17 decommissioned [3] detail [1] 20:10 31:21 149:2 158:4 contaminated [6] 31:15 correct [381 37:23 38:5 criteria [176] 42:23 46:9 details [11 174:21 46:12 48:6,10,17 52:20 decommissioning [sj 32:13 73:13 83:24 129:12 44:17 101:9 108:2 120:13 [91 14:23 54:3 53:10,17,18,20.23 63:10 42:6 88:6 148:23 175:3 detect 137:18 121:2,5 125:14,20 130:10 101:3 123:23 143:22 135:10 149:19 150:6,7,11 63:17,18 64:4,25,25 65:1 179:18 contamination [65] 155:19 156:7 165:7 71:10,13,21,22 72:3 2:15 3:8,10 18:17 23:2,13 151:11,20,21 154:1,10 65:1 decontaminate [2] 178:15 23:15 27:22 28:7 33:7 155:11,12 156:7,8,11 72:4 77:14 88:11 90:15 31:14 153:21 97:4,6,11,14,17 detectable [31 54:12 35:2,8 45:11,23 46:24 160:3 162:15 163:16 96:23 decontaminated [1 101:23 105:23 107:16 55:24 57:10 47:25 53:24 54:12 63:7 166:11 168:3 174:5 177:3 179:25 177:17 179:2 180:20 113:11 115:10 120:11 detected [s] 96:7 120:14 63:13 64:20 109:24 decontaminating [2) 123:14 124:7 126:10,12 182:6 183:5 121:15,16 130:12 132:7 120:16 121:13 139:2,5,9 132:13 140:4 142:18 31:19 80:10 156:21 157:1 161:10 131:5 134:2 137:17 correction [21 84:10 decontamination [221 143:15,21 147:19 156:20 85:10 151:1 157:21 158:3,8,18 162:18 165:17 174:4,6 158:21,22 159:8,10,11,16 3:17 31:3,8 48:2 61:16 156:25 157:6,6,25 158:3 175:18 corrections [I1 136:14 160:1,14 62:14 63:11,25 74:6 97:5 158:9,11,12 159:9 160:6 159:21,25 detecting [4] 18:19 57:20 correlating [11 122:25 97:10 102:2 137:18,25 160:12,13,18 161:18 161:23 162:1,6,10,12,14 161:15 173:24 correspondence [I] 162:19,20 164:1,5,15 140:7 142:9,16 146:10 Index Page 4 Combs & Greenlev, Inc. (415) 512-1234 Jr. detection - example Raymond F. Fish, October 12, 1999 I I 43:14,16,19,22,25 44:6,8 easy [i1 11:22 engineering [4] 21:25 detection [4] 57:6,8 66:2 discard [ij 129:14 25:4 26:5 170:14 170:6 discarded [1] 129:4 50:24 53:8 65:7,12 135:20 Edgar[1i 3:12 146:25 147:2,4,5,7 149:24 Engleken [pJ 39:19 detector[2s) 28:14 35:16 [11 34:21 edge [21 98:12,12 discharged 158:1 159:19 166:25 English [1 12:13 66:25 68:3,4,9,24 69:2,6 discovered [1I 34:14 168:9,17 education [21 11:11 26:6 69:7 83:23 84:1,1 92:20 enrichedl[3 14:7 21:18 9:17 effect [6] 29:25 34:10,24 98:11,13 107:8 124:9,11 discredit [1] doesn't [51 54:6 67:22 23:10 170:2 56:20 57:3 178:24 125:1 131:3,4,5,24 170:11 discuss 121 29:15 136:8 78:22,23 ensure [1] 164:21 Donaldson [3] 102:7,8 effects [s] 15:20 16:7 detectors [3] 15:2 35:14 discussed [31 31:9 36:5 17:14 29:2,11,22 30:9 entire [2) 151:15,16 36:7 150:15 124:8 79:3 entitled [si 2:15,18,21 detects [11 165:10 discusses [1181:6 done [211 16:21 26:11,13 2:22 3:3,5,7,9,16,22 10:14 26:18 73:10 79:4 89:9 efficiency [41 54:19 detergents 1ij 32:15 discussing [3] 136:9 84:7,9 85:5 142:9 166:13 167:11,20 149:5 157:20 97:10 106:8 108:13 113:7 determination [4] 58:16 113:8 116:2 123:18 effort[3) 14:8 86:19 entrance [1] 108:24 82:18 159:12,16 discussion [o] 66:9 128:23 137:16 151:4,5 149:13 envelope [1] 73:13 determine [15] 16:12 126:24 135:16 137:12,12 153:11 170:14 178:25 137:21 138:9 148:24 efforts [11 142:16 environment [31 17:9 79:21 93:7 106:1 109:20 Doral [1] 184:3 eight [pj142:6 34:7,11 139:23 147:1 150:12 167:6 113:10 dose [s] 76:13 77:10 environmental [SJ 26:2 150:25 171:5 172:25 discussions [6j 35:23 either [p1] 38:23 44:20 80:17 81:9,10,11,15,17 33:16,21,23,25 34:6,9 173:15 174:8,15 178:17 35:25 36:4 136:12 137:20 67:8 73:12 89:25 90:1 double [2115:2 120:5 96:4 97:6 149:9 157:9 41:7 [31101:6 138:5 determined 181:16 equipment [101 3:17 101:22 109:22 disintegrations [10] down [flh 9:10 32:19 57:12 68:13 78:5 electrical [21 68:14 84:2 20:12 33:1 67:19 140:10 determining [1] 173:2 54:21 85:3,4,7,9,12,13,19 34:22 85:22,25 78:16 93:2 96:12 98:10 electrically [11 68:13 141:18,21,24 142:10 developed [11 35:14 162:25 disinterested ['1 181:10 98:17,18,21 100:18 elevated [is] 3:9 101:23 developing [2] 33:6 104:24 105:11 128:7 equivalency [p] 80:14 disposed pi] 102:23 103:8 106:15 107:24 38:12 181:9 110:11,12,12 111:2 equivalent [21 81:9 86:3 disposition [3] 13:17 Development [7] 12:22 Downey[1] 16:2 126:10 127:16 140:5 ergs [2j 81:18,19 12:25 13:24,25 15:8,14 160:18 161:8 Doyle I21 5:16 6:21 177:9,10 179:24 [2] 182:2 16:4 dissolution [I1 36:14 ERRATA dpm 1] 54:19 elevating [1] 20:14 183:1 [ii distance [131 55:8,17 developmental draft 121 116:9,13 eliminated [21 36:13 essence [1] 30:5 33:12 56:6,19,23,24 57:2,2 [11 49:1 103:8 [71 46:2 49:4 devices [t] 22:24 92:21,22 96:8 120:25 drafted essentially 173:1 drain [61 55:22 56:2 eluted [11 141:9 76:1 80:14 100:25 145:10 diagram [3] 2:21 128:7,9 distinct jij 157:16 106:24 107:1,8,11 emergency [(] 36:22 162:11 dial [21 84:21,23 District [611:2,3 4:2,3 drains [91 99:24 107:6,14 36:24 37:1 38:3,6,7,11,12 establish [21 20:17 51:9 dials [1 157:8 5:25,25 107:17,24 152:17,19 38:15,19,25 established [i] 12:3 diameter [31 72:23 divided [1136:13 154:5,6 emit [3] 155:24 156:1 40:15 42:20 56:23,24 57:2 127:24 130:23 163:17 159:17 160:5 dividing 1ij 92:24 draw 1i1 110:22 Dick [21 40:5,21 emits [1] 156:3 establishing [4] 34:25 2:13 15:18 Drawing 1j] 169:12 division [231 56:13 78:1,24 difference[S] 10:18 16:1 17:3,11,18 19:11,19 drill [11 82:11 emitted [11 159:22 28:23,25 29:9 30:10 81:21 20:20 24:18 51:17 52:4,5 Drive p1] 184:3 emitter[31 158:13 160:1 estimate [js 99:4,6,7 89:10 160:17 104:11 142:5 59:21 60:13 61:7,11,17 12] 108:8 163:19 [16) 29:2,2,11 driveway different 62:22,25 116:19 117:2,9 151:19 emitters [4] 114:17,18 et[2] 184:4,5 56:18 58:11 62:7 81:23 158:20 162:1 divisions [21 24:25 driving[p 144:13 etc. [1] 17:5 100:22 110:4 122:20 57:22 emitting [11 156:25 143:6 158:16,21 169:25 dropped p] 34:3 evaluate[61 15:20 38:15 docket [4] 2:13 59:5,11 employed [111 12:20,21 41:1,3,4 90:10 170:1 172:22 drums [1 103:22 59:14 13:20 17:3 19:11 23:22 evaluated [2] 15:3 16:6 differentiate [31 57:13 Druxel [] 136:20 23:24 25:18 26:12 74:3 71:24 100:22 Docketed [t] 59:19 evaluating [SI 16:16 dry 1ii 98:4 142:3 differentiates [I1 157:5 docketing [3] 60:2,3,6 27:2 29:13 30:2 34:7 Due[t] 81:14 employees [41 13:20 41:24,25 72:7 differently [2] 70:7,12 does [1] 50:15 duly [2] 4:24 181:6 22:7 166:22 168:3 evaluation [5] 34:19 difficult [6] 9:25 10:24 document [591 2:15,16 [201 15:5,6,10 empty [21 97:22 129:6 38:22 39:5,8 72:2 30:19 61:4 64:19 178:8 2:18,22 3:3,5,7,9,11,16 during 9:4 19:15,21 22:12 37:9 45:21 enclosed [1] 63:9 [11143:5 3:22 43:13 48:7 52:25 event[41 45:12 68:13 difficulty 53:6,13 58:24 59:5 64:10 51:4 53:16 65:9 72:13 end 191 54:14,20 69:25 84:1 181:18 diffusion [1] 14:11 64:16,18 65:4 66:13 75:9 86:18 113:3 171:7,21 70:9,13,13 74:24 145:25 events [s] 7:11 10:22 dimension [1] 92:25 76:1 81:4 91:1,6 110:23 175:21,25 176:2 180:12 82:2 84:6,22 116:18 117:1 direct [19] 27:21 46:22 113:15 duties [3] 24:7,9 37:8 end-reading [11 30:10 eventually [1] 36:23 47:2,18 69:19 71:16 92:13 118:16,22 119:19 120:10 121:14 122:3,13,14 energetic [11 30:17 everybody [5] 17:6,7 92:18 93:11,14 94:3 96:1 -E 31:22 78:13,15 104:25 107:3 108:10 126:14 127:3 134:12,16 energy [39 2:11,18,19 23:25 24:18 150:5 156:10,18 161:11 142:8,13,17 143:2 146:9 e[3] 2:1 112:7 184:12 8:10 16:22,25 everywhere [13 20:5 26:12 31:3 32:10 166:13 167:10,13,16 early [517:25 40:11,14 25:18 exact [1] 67:19 direction [1] 181:13 168:24 169:7,24 170:3,5 33:5,12 36:10,12,18,20 133:18 166:24 [4] 20:10 28:1 directions [1] 29:18 170:22 43:16 51:16 53:9 69:22 exactly [3] 66:24 176:6 directly [5] 29:5 44:23 earth 141:6,8,8 70:20 75:15 79:12 81:16 documentation [4] 50:5 EXAMINATION [s 84:14 124:17 168:9 50:17,17 149:17 easiest [1]30:15 81:19,24 82:7 84:2,2 86:6 166:23 168:4 2:3,5,6 7:4 148:16 39:15,16 easily 13] 30:13,18,18 142:3 162:2 director[3] documented [i] 49:10 168:6 172:16 176:20 49:2 east[6] 5:6 110:2,6 examined [1] 4:25 documents [24] 31:12 [2] 5:16 6:21 dirt [11 129:12 119:20,22 134:25 Enersen example [3j 152:24 Index Page 5 Combs & Greenlev, Inc. (415) 512-1234 Raymond F. Fish, Jr. examples - guidelines October 12, 1999 159:14 171:12 files [1] 50:15 found [21 71:25 106:15 generate [2] 48:19,21 160:2 examples [1] 28:6 -F filing [1] 7:23 foundation [pq 63:21 generated 1ij 71:18 82:23 129:22 generating[1] 116:8 exceed [2) 77:17 105:22 Fp[ 1:18 4:21 11:16 • filled [5i 97:20 129:8,10 153:13 164:17 131:16 132:23 142:23 Gentlemen [1) 61:9 exceeded lioi 96:7,23 182:4,25 183:3,25 144:8 145:18 172:17 97:13 101:18,20 102:1 fabricatingpii 21:11 film [2] 28:14,18 175:5 geometric [p 29:13 105:25 106:5 107:19 fabrication [1] 21:1 filter Is] 72:22,24 73:1 four[s] 53:20 55:4 63:16 geometries cij 27:2 108:3 104:9,13 facilities [91 3:17 37:12 64:24,25 93:1 99:7 114:15 geometry [21 29:13,15 exceeding [2] 139:5,9 38:16 62:23 63:5 64:21 final [61 49:7 116:18,25 Four-page [1] 3:11 Georgia il 40:15 132:4 153:15 164:10 except 1io0 27:14 33:3 142:9 153:8 175:9 fourth [31 55:20,21 germane [1i 65:18 69:11 76:5 85:20 94:14 fine[21 10:10 11:1 facility 16si 2:21 13:19 169:12 given p] 8:25 9:2 26:17 140:1 165:19 168:10 22:5 31:14 32:9,10,13 fingerc21 72:25 104:10 172:10 fractions [1 18:7 59:11 92:25 128:23 34:8,23 35:2 38:18 42:2,6 finish [2] 9:21,23 158:15 exception [3] 152:13 42:15,16 46:10 47:13 frame[i] 149:10 182:6 183:5 finished [2] 132:12 framework [I1 141:24 giving [1] 7:19 51:25 56:14 63:9 66:17 145:24 excess [sj 47:25 76:13 67:4 79:22,23 80:9 82:20 Francisco p7 4:18 6:5,8 GM[1] 84:4 first [29] 4:24 8:16,17,22 77:11 139:3 163:24 86:8 88:20 91:19 95:13 24:1,25 25:12 184:11 goes [91 29:18 67:17 11:11 12:20 36:17 50:2 144:4 excessive vi 80:7 96:16 103:10,12,22 frequency [21 176:7,11 68:12 77:5 83:25 106:10,13,25 111:16 53:21,23 60:23 71:15 165:14,14,15 exchanges [I1 31:9 80:17 81:4 92:10 97:3,17 frequently [2] 175:20 112:12 113:24 115:10 [4] 92:23 97:19 105:24 106:2,15 176:10 gone 39:7 excuse [2] 149:15 159:5 132:11,14 133:14,19 116:10 172:14 147:11 133:12,15,16,17 134:14 freshp[i 114:9 Executed [2] 182:21 137:11 145:12 6:14,17,20 7:5,7 149:12 150:4 152:7,20 136:24 152:12 167:10 good [91 183:21 front [6] 91:13 94:9 96:4 39:21 75:8 109:12 148:17 153:5 159:22 162:9 171:8 fish [5ss 1:18 3:14,20 4:21 103:20 151:15,17 exhibit 141] 52:25 53:3 Govia [1] 39:22 58:25 59:2 63:17 64:10 171:19 173:15 174:10 5:23 7:6 8:5 9:2 11:9 full [1j 127:11 34:19 41:16 52:10,24 53:5 64:13 65:2 66:21 75:12 175:3,7,14 176:15,16,22 fully pi 184:13 grade [12] 113:25 114:16 77:15 91:3 108:6 113:15 fact [13] 48:9 62:11 88:5 53:8 58:23 61:20 63:15 152:20 153:8,13 154:13 [1] 41:6 43:8 113:17 118:17,19 122:3,5 155:1,4 157:11 159:1 64:16 65:22 66:12 74:25 function 154:18 177:6,7,9,10,21 123:5 126:3 127:4,6 134:9 160:24 171:18 173:2,19 75:6,9,18 90:25 92:7 43:8 49:16,17,19 115:21 gradually [1] 93:2 117:14 133:1 135:8,24 136:2 139:7 175:1 176:22 113:14,19 115:9 118:21 115:21 122:7 123:15 126:7 127:8 166:7 graduating 11] 12:17 146:11,13,16,17,19,22,23 factor [101 29:4,5,9 84:10 graM [2] 81:18,20 146:23,24 147:2 152:1 128:10 132:2 134:11 functioning [1] 152:7 85:5,11 86:3 160:24 161:1 135:19 136:4,22 142:8 167:10,23 161:2 Grand [1 5:17 146:1,6,8,21 148:18 180:8 -G grease ci] 34:5 Exhibits is] 2:7,9 3:1,21 facts [3] 7:16 153:18 180:13 182:4,25 183:3,25 71:11 great[i] 137:17 174:22 184:2,6 G-e-i-g-e-rc1i 19:5 existed12] 152:20 178:1 faint il 10:16 Fish's [2] 52:25 64:11 greater[3] 86:19 176:9 gamma [33] 3:3,6 18:2,4 179:12 expect [21 79:24 108:22 fairtij 53:13 fission [11 21:19 18:12,16 29:3 30:13,20 greatly [1] 124:12 expectation [1] 175:17 fall[2] 12:21 15:24 five[sl 99:8 149:8,11 80:13 81:14 83:23,25,25 expected [ij 166:8 familiar[1ii 52:12 75:22 176:12 177:21 100:25 114:17,17 119:8 Greenley [1] 184:9 127:12,18 128:5,15,17 [91 35:20,22 91:9 100:7 130:21 131:1 Greg [1] 6:12 experience fixed [1] 63:4 155:25 156:3 157:6,9,15 49:10,12 145:9 147:6 131:2 133:19 166:20 GREGORY [21 5:8 flat [2] 94:20 110:17 160:6,23 161:5 160:14 172:15 175:4 167:25 175:24 157:22 184:23 floor i1] 3:3 4:18 77:16 165:4 [21 14:19 farpi 107:9 grid [2] 104:17,20 experienced 92:23,24 94:21 95:24 gammas [2] 30:18,23 99:20 farther[21 57:4 121:3 112:19 120:22 147:21,23 grids[i] 119:10 gamut [1] 33:24 expired [11 87:14 fashion [41 57:19 96:6 floors [2] 33:1 152:18 groundr[6 3:3 9:7 111:18 104:23 108:17 gauge Iq 98:20 explain Is] 16:8 53:25 focus [1] 170:22 120:21 144:2 153:20 68:9 78:6 81:21 83:20 fashioned [p 155:18 Geiger[1 15:4 group [4o] 22:13 24:20 85:2 160:11 folderpi] 65:11 February [2] 2:14 59:19 Geiger-Muller [391 24:21 25:2,3,4,11 33:8,9 [3] 22:20,21 folders [11 65:17 17:21,25 18:18,24 23:5 33:13 36:15 39:12 40:24 explosives federal [21 60:8 184:12 22:23 follow-up [1] 140:2 28:2,4,11,13,19 35:10 41:24 42:5,13,21 43:3,5 feed [2] 141:7,9 47:5 65:25 66:3 68:6,7 expose [3j 70:13,15 followed [1] 177:2 44:4,9,10,15,18 46:15 feet [6] 93:1 99:8,8 113:24 69:20 84:11 100:21 107:4 48:22,23 49:14,15 51:20 161:16 following [3] 81:8 182:7 114:16 177:21 108:11,14 111:8 118:7 79:1,4,8 exposed [11 77:21 183:6 78:9,10,11,23,25 felt [i 116:14 131:6,23 132:1 147:16 79:10 87:16 exposing [1] 78:19 follows [1] 4:25 150:5 156:6,11,21 165:4 fences [4] 91:25 92:3,4,6 group's t1i 40:25 exposure [13] 56:16 foregoing [41 180:20 166:1,3 169:10,20,25 groups [4] 24:24 25:5,23 69:19 77:6 78:2,10 80:2,7 few [41 9:7 40:12 93:24 181:6 182:5 183:4 170:25 163:15 36:13 100:18 134:21 161:3,4,8 foreign [i 12:11 Gene [3] 39:16 40:1,2 guess [14 10:17,21 19:8 179:14 field [121 26:15 44:22,24 20:22 form0io] 9:11 10:5 43:17 general [221 12:3,8 35:3 77:14 89:18 91:12 extending [11 127:15 49:15 127:17 156:11 22:8,11 23:2 49:7 63:3 79:10 90:18,20 20:24 21:21 119:9 120:24 129:2,15 161:9,20 163:1 165:5,12 32:11 37:14 extensive [2] 39:2,4 138:13,14 23:12,23 130:15 139:12 163:14 166:5 40:23 41:23 65:16 76:22 extent [13] 23:14 37:11 Figueroa 1j 5:12 formal [6] 14:20,21 22:1 guessing ti] 10:19 42:7 88:24 99:13 105:15 31:5 35:19 36:6 78:3 80:6 87:25 89:8 129:10,13 145:7 148:7 figurepii] 2:21 3:3,5 93:21 134:20 guidance ci'14:18 43:10 for mer[3] 2:22 94:16 43:16,18,22,24 44:1 65:12 171:3,23 172:19 66:23 67:18 118:22 119:7 118:23 generally [121 30:21 121:7 122:9,9 128:12 31:14 44:25 50:1 51:23 guideline u1] 142:15 external [1] 161:8 forthc[l 111:21 file [9] 50:3 65:5,6 74:9 82:20 88:25 89:3,14,18 p3] 3:16 extremely [1] 165:12 guidelines 74:12 155:9,15,17 171:10 forwarded [21 149:24 92:17 106:11 52:19 142:9 150:1

I I £ I Index Page 6 Combs & Greenley, Inc. (415) 512-1234 guides - kind Raymond F. Fish, Jr. October 12, 1999

T I 17:22 23:6 35:10 guides [4] 2:15 44:3,4 57:15,17,24 58:5,6 72:9 increase [1] 124:13 instructions p1 162:23 64:20 76:14,19 77:13,17 84:15 independent [4] 165:23 instrument [ss] 18:10 ISC [41 136:22,25 137:23 119:13,14,15,19,23,24 171:11 174:7,15 19:2 28:4 29:24 47:6,7 139:4 -H 120:1,10 126:18 130:10 independently [ii 54:20 56:19,21 57:7,9,14 Island [21 39:4 40:21 130:14 134:25 135:2,6,8 117:4 57:18 58:3 65:23 66:1 Islands [1] 24:12 Hl[2] 5:13 184:24 143:8 157:19 160:3 67:11,22 68:1,5,22 69:14 INDEX [1] 2:3 84:11,12 85:5,8 isotope [21 122:17 137:1 H.L[11 2:10 163:25 169:22 70:21,25 house [3] 136:10,11,12 indicate [7] 60:9 122:20 100:20,21,21,24 107:7 isotopes [36] 2:12,22 half [41 105:13 120:5 125:8,10 158:2 164:3,13 111:8 120:14 123:22 53:9 61:7,10,17 62:8,25 151:3,5 HPS [11 128:2 indicated [16] 46:15 124:16 125:15 129:20 74:4,9 100:22 136:23 halfway [2] 80:18 81:5 huh-uh [p] 10:4 80:13 120:24 124:6 130:22 131:1,13,15,21 137:13,16 138:8 139:4 hand [11 92:20 hundred [41 54:18,22 127:13 130:8 136:14 143:24 147:17 156:10,17 149:15 152:5,9 153:12 155:4,13,20 156:1 158:20 handbook [6] 166:18,19 58:7 79:19 152:24 155:8 159:20,25 157:8,12 161:11 165:18 169:24 159:1 163:6,7,10,11 167:15,18 168:5 169:3 hundredths [2] 18:9 161:25 164:8 165:25 165:21 166:7 57:12 172:5 178:23 instrumentation [41 167:17 171:6,17 173:13 handle [21 19:21 20:7 174:13,18 74:23 indicates [31 56:4 62:12 26:20 27:1 89:19 170:3 handling [s] 24:16 41:4 hungry [1] 138:12 [2] Isotopes's [11 138:6 41:25 166:14 167:17 instrumentations indication [1] 99:10 25:24 26:25 issuance [1] 50:19 hard [2] 9:22 114:17 -I [9] 76:12 instruments [441 2:17 ISSUe [31 29:15 31:8 50:23 harmful [11 76:25 individual ICN[121 1:9 2:9 3:13 4:9 77:9 78:2,4,8 84:22 149:9 14:23 17:15,17,22,22,23 issued 101 2:19 16:21 HATHAWAY [21 5:4 4:23 5:9,24 6:9,13 7:14 150:19 166:1 18:14,18 22:25 23:1,4,6,8 43:12 50:9,14,25 75:17 134:16 184:4 184:24 individuals [s] 1:6 4:6 27:12,15,17,19,25 28:7,9 166:18 167:18 169:3 haves [11 116:2 Ida [2] 39:19 40:5 29:3 56:16 78:4 30:3 35:9,11 47:3 57:11 issues [1] 36:5 Hawaii [11 24:12 idea p] 142:1 66:14,16 67:8,23 70:11 industry [1] 132:22 70:24 71:1 118:6,13,14 issuing [21 25:12 44:3 head [p 175:20 identification [2o0 2:7 inform[2] 90:21 108:1 Itemn] 113:20 3:1 53:4 59:3 64:14 66:22 131:2,24 161:9,17,18,20 heading [41 64:18,21 informal [2] 22:2 62:21 166:8 170:20 items [1] 60:5 123:16 134:17 75:13 90:1 91:4 113:18 118:20 122:6 123:6 126:4 information [71 34:25 intend [11 178:24 itself[21 84:24 178:19 [141 31:10 headquarters 127:7 134:10 136:3 50:1 88:1 130:19 168:10 intended [2] 44:1 45:23 42:22 44:21 48:8,11,16 146:14,20 167:24 173:6 177:3 49:3,8,16,17,20 115:20 intent [21 80:1 86:7 -J identify [91 6:10 17:17 informed [7] 43:9 45:9 115:21,22 interest [(s 7:13,14,23 J[ ] 5:8 184:23 17:20 48:1 122:15,16,17 86:10,20 88:4,7 102:15 86:16 87:24 2 headset [2] 71:7 84:19 146:25 175:16 James [1] 2:13 informing[1] 115:23 interested [11 181:17 Health [] 134:7 imagine [1] 58:19 January [21 61:9,13 initial [s5 39:8 50:19 interfaces [1] 38:11 hear [2] 10:16 84:22 impacted 11 144:18 150:25 152:12,21 job [41 1:23 15:16,19 24:7 interfere [21 98:8,9 heard [21 40:11,16 impair[i] 11:7 initialed [1] 136:14 John [6] 5:13 6:18 11:16 hearing [21 84:20 117:12 interior[sJ 94:6 101:10 61:10,20 184:24 impeach [t] 9:16 inside [15] 91:17 101:11 104:4,18 108:18 151:10 hearings [p 9:5 implementing [il 39:6 111:18,22 112:24 113:1 151:16 154:9 join [s5 8:1,3 63:23 88:17 113:12 128:21,25 129:3 154:22 heavy [1] 30:24 implication [1] 56:6 internal [4] 13:16 44:7 129:24 135:2 160:19,20 joined [1] 24:3 held[41 70:8 92:19 111:17 important [31 9:17,20 160:18 161:7 184:8 160:21 joint [1] 83:12 10:7 insofar[1] 165:4 internally [] 44:2 help [1] 31:22 Jose [4 11:15 12:1,15,18 imposed [3] 20:17 46:1 [3] 24:9 176:5 interview [2] 3:15 51:3 hence (1] 179:6 inspect 80:8 180:4 investigate [1] 176:4 Joseph [si 1:6 4:6 6:16 [5] 39:18 40:13,14 148:18 184:4 Herb impossibility [I1 inspected ['1 176:10 investigator i] 39:23 116:16,24 145:21 JR[6] 1:18 4:21 182:4,25 inspecting [1] 37:14 involve [7114:22 26:24 183:3,25 hereby [11 181:5 182:4 impossible [] 145:10 32:21 33:18 34:3 46:18 183:3 impression [1] 163:15 inspection [29] 24:21 JT[1] 143:13 40:24 161:24 hide [11 153:22 25:23 38:7 39:12 improper[i1 170:6 48:10 49:6,16 involved [3s] 8:15 13:11 Julie [61 1:23 4:19 6:24 40:25 43:7 181:4,25 184:21 high [al 11:12 22:19,23 improve [1) 38:19 49:17,19 50:3,6,6 65:20 14:4,13 16:8 17:1 21:11 58:14 102:22 110:24 115:20,21 116:22 117:1,9 23:11,20 25:12 26:4,23 July [21 2:19 75:17 127:13 165:12 in-situ [11 3:5 117:14 133:1 139:1 153:9 26:25 27:2,12 28:2,10 June [2] 11:19,20 higher [7] 55:17 58:3,9 Inc131 1:9,11 2:12 4:9 175:16,19,21 176:11 30:4 33:5,20,20,24 34:6 4:11,24 5:10,20 7:15 61:7 Juno [21 28:6 161:14 58:15 92:22 130:13 140:2 [10] 34:13,14,19 36:21 38:10 61:12,17 62:25 inspections 24:13 jurisdiction [2] 24:11 highest [21 119:17 121:10 24:13 26:18 39:9 118:4 42:1,7,8,12 46:19 52:15 inches [13] 55:8 56:5,6 83:16 133:25 170:4 176:9 86:22 hold [1] 70:16 140:20 152:9 176:8,14,18 justified [11 160:13 71:21,23 72:3,4,5,10,23 involvement [2] 87:16 73:11 inspector[61 39:18 43:9 holdert] 77:16 92:21 124:19 133:22 holding [] 141:24 48:24 61:24 140:21 incidents [l1 38:4 175:25 involves [1] 52:10 -K hole [41 127:12 128:6,8 include [3] 41:7 50:4 inspectors [51 31:9 involving [2] 12:14 14:9 K[21 5:18 184:25 128:15 151:25 38:21 39:17 43:20 175:23 [12] 35:13,16 holes poj 113:24 114:4,6 iodide keep rn 23:14 27:9 39:24 included [1sl 12:11 127:25 128:1,3 130:23,24 128:13 installed [1 92:1 65:11 86:10,19 100:18 114:8,12,15,18 24:13 28:3,4,6 34:1 38:8 131:3,4,21,24 170:11 152:15,25 39:17 50:24 93:24 151:19 instance [7] 34:1,12 36:8 Kennedy[11 11:16 ion [i] 127:24 honestly il 100:10 151:22 152:4 155:6 162:5 44:5 143:7 158:16 173:8 kept[21 148:3 166:9 ionization [3] 18:10 horizontally [1] 70:16 includes [1] 50:13 instances [1] 10:7 kind s3i 11:6,21 14:11 165:15 28:5 84:4 hot [3 94:11,16 152:25 including [4] 13:13 instead [21 110:5 15:4 16:17 17:8,10 18:3 ionization-type [31 22:2 27:12 31:6 32:16 hour[p41 55:8 57:11,12 14:11 24:16 76:22 instructing [1] 82:16 Index Page 7 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. kinds - measurements October 12, 1999 38:20 43:15,22 53:15 65:6 less [6] 57:4 77:12 85:13 51:20 54:9 59:21 60:13 81:6 108:8 119:20 144:20 158:23 168:15,16 65:11,22 71:7 82:16 86:9 121:12 158:23 160:3 62:6,24 82:15 87:17 88:9 Los [41 5:3,7,12,17 173:16 92:7 104:17,18,22 123:23 letter[37] 2:10,12 3:12 88:11 90:9 115:22 116:18 lost [11 141:15 materials [4] 12:15 13:9 129:14,16,25 130:5 134:1 3:14 45:14,16 52:3,7 53:9 117:7,18 132:13 149:21 13:13 14:1,10,17,23,25 144:13 155:19 165:21 150:12,14 153:5 159:15 lower p171 69:22 96:8 15:21 16:7,9,12,14,17,20 53:16 55:5 61:4,6,13 98:16,17,18 107:7,9 121:4 175:11 176:16 177:14 62:12 63:6,16,17,24 65:2 162:3 19:22,25 20:2,4 22:22 124:20,24 131:9,9 160:6 23:1,9 30:21 31:15 32:13 kinds t41 13:10 32:12 82:15 88:10 117:17,20,22 life f11 120:5 160:8,8,10,13 43:24 79:6 132:13 134:5 135:21,25 likely [31 42:18 48:15 32:20,21 35:12 65:18 lowered121 98:11,13 68:16 118:24 137:3 knew [1]162:3 136:10 158:15 162:6,7,10 129:25 162:12,20,22 Ludluml[l 127:23 128:1 141:10 147:25 155:1,20 knowledge [5i 65:16 limit f2]56:17 66:2 letterhead [1 2:10 130:22,25 131:13,20 155:23 160:16 161:21 117:8 129:9 164:16,18 limitation [1] 165:6 166:14 171:6,13,21 level 12o045:10 55:12 lunch [1] 74:23 known [v 166:4 limitations [41 27:1 173:11,20,25 Luncheon [1] 75:2 56:4 58:15 76:17,19,23 165:3,9 178:6 76:24 77:1,4,15,20 111:17 matter[7] 5:23 7:15,16 119:17 120:15,16 121:14 limits [In) 47:25 57:6,9 -M 179:12 184:8,14,17 121:16 128:22 162:17 101:18,20 102:1 107:19 maximum [13] 55:12 lab [15] 22:19 23:15,15,16 108:3 139:4 160:5 165:10 23:18 25:7,8,9 27:13 level-type [1] 143:20 M-u-e-l-l-e-r [11 19:7 56:13 76:18,19 77:4 78:2 line [6] 34:22 137:15,22 78:3,8 127:22,23 143:7 72:25 94:23,24 95:1,5 levels [35] 27:21,22 34:17 machine[2] 14:6 20:15 137:23 182:8 183:7 169:15 176:13 152:25 45:22 47:24 54:12 58:4 main [Sl 53:11 63:8 94:13 Laboratories [1] 26:9 63:7,13 72:7 76:2,11 77:8 lined[3] 137:1,8 138:3 103:17 120:11 133:20,24 may [12] 10:23 34:15 40:17 66:16 67:19 103:5 laboratory [11] 13:5 97:13 101:16,23,25 lines [4] 55:23 56:2 134:2 102:22 105:1 106:6,15 106:24 107:1 106:4 114:8 177:2,2 16:13,15 19:19,25 20:3 maintain [3] 19:24 65:4 184:13,15 20:11 22:15 25:22 61:18 107:15 127:22 129:16,19 linoleum [1132:20 65:6 McCutchen [21 5:16 114:15 135:3,7 139:3,4 140:5 j11 32:16 maintained [51 20:2 143:15,21 158:18 173:1 liquid 6:21 labs [11 94:1 65:12,15 136:25,25 179:24 listed [6 63:1 65:2 71:10 McKeith [s1l 2:6 5:4 155:16 182:7 183:6 major[31 11:14 14:7,12 lack [1) 30:14 Lewis (I 4:17 5:11 6:18 6:14,15 7:21 18:21,24 listing [1] 53:20 Malissa[41 5:4 6:14 lacks [11] 63:21 71:18 liability [1i 7:17 19:3,6,9 31:18 32:4 46:5 82:23 129:22 131:16 litigation [I] 7:23 148:18 184:24 63:23 64:8 67:13 80:19 132:23 142:23 144:8 liaison [1l 22:19 [41 16:5 manila [ij73:13 80:22 88:15,23 89:4 96:25 1l1167:14 Livermore 145:17 172:17 175:5 Libraries 22:15 25:7,8 manner [s] 76:8 89:16 103:15 106:9,14,18 laid 1ij 110:15 library [1i 43:21 124:14 125:13,22 127:19 130:7,13 131:10 lives [4] 40:2,7,8,21 143:2 145:13 148:16,17 language [1] 12:11 license [so] 16:21 42:25 manufacturing [11 LLP [5] 4:18 5:2,6,11,16 148:18 151:16 153:25 44:12 45:18 46:2,10 48:14 113:25 large [131 28:8 37:12 localized [41 3:9 126:10 154:25 156:14,19 167:2,9 51:12 72:20 73:2 78:11 48:18 50:5,5,8,19,24 map [61 2:21 88:20 89:24 51:18,25 53:12 59:10,12 127:13,23 167:25 169:2,6 172:23 78:25 79:1,4 94:9 99:9 91:7 110:4 139:7 174:19,23 175:12 180:6 104:4 105:22 60:6,23,24,25 61:3,15 locate [I] 135:21 62:13,16,18 63:1,3 65:17 located [201 16:2,4,5 March [11 166:18 184:24 largerp] 33:22 100:13 65:19,19 82:11 86:8 87:14 mark [131 52:25 58:24 mean [151 34:10 46:9 160:24 20:23 24:2,3 25:11 43:6 87:22 90:9 117:16,19,24 52:11 53:11 55:23 61:18 64:10 66:18 91:1 113:15 49:19 54:12 57:25 78:6 Larry [11 136:20 118:24 133:4,14 142:20 69:13 128:6,9,16 140:11 122:2 125:25 126:20 79:1,24 109:23 122:16 last [s1 22:12 46:5 89:2 155:14,17 159:2,6 171:10 140:25 141:11,19 127:3 135:24 146:11 125:2 141:15 164:6 170:9 136:22 138:12,25 146:9 177:25 167:9 179:8 location [13] 43:21 56:25 160:15 licensed [161 8:18 24:9 57:1 80:3 90:2 95:20,22 marked [3o] 2:7 3:1,21 meaning [s] 174:17 late[21 12:21 15:24 24:10 25:10 26:3 32:9,10 96:3 103:17 128:20,22 53:1,3 59:2 64:13 66:21 176:19 177:12,21 178:2 Law [s] 5:5,8,14,18 33:16,23 37:12 41:1 42:2 152:9 174:3 75:10,12 91:3 92:11 93:25 means [9129:4,5 57:17 95:5 112:4 113:17 118:17 184:23,24,24,25 44:18 76:8 80:5,8 locations [7] 3:5,9 90:15 60:6 76:20 78:20 85:3 licensee [s4] 42:14 44:12 118:19 122:5 123:5 126:3 100:2 131:21 Lawrence [2] 25:7,8 112:1 126:9 128:13 127:6 134:4,9 136:2 139:6 44:16 45:14,16,17 46:1 meant [3154:1 60:3 lawsuit [117:22 153:20 146:13,16,19 167:23 46:20,25 48:1,2 50:9,18 lockers [11 95:13 162:13 lawyers [1] 147:6 50:25 51:4,8,10,11,15,24 marking [21 123:3 143:2 Loeb [6] 5:2,2 6:15,15 measure[121 17:15 18:4 laying [1] 124:16 53:16 59:10,12,13 60:5 marks [4j 74:24 145:25 23:1 27:17,20 28:20 54:14 63:1 76:7 82:10,16,21 135:22,22 lead [4] 30:22 98:15 146:5 180:12 68:1 84:16 145:11,20 89:15,22 90:7 logging [3] 127:12 128:6 169:23 171:20 88:10,13,19 Marson [1] 145:15 157:9 90:18,23 97:5 99:19 128:15 leakage [1] 99:20 Martha [41 3:14 136:5,17 [61 57:3 72:9 101:25 106:6 108:1 longer[3] 87:23 118:3 measured 1121 8:14 26:19 97:8 136:18 107:2,3 119:8 120:21 least 115:11 117:18 118:12 170:7 99:13 102:13 103:3,4,17 151:1 153:12 171:12 Maryland [121 24:23 measurement [is] 29:20 [2o] 59:5 64:16 66:15 115:16 120:11 150:23 173:7,8 175:14 176:21 look 25:15 44:15 49:14,20 44:6 70:8,14 71:21 82:2 67:6,9,15,22 75:22 79:3 165:23 178:1 51:21,22 87:11 116:19,22 107:10 119:18 120:2,6 80:16 91:6,9 113:1,19 117:2 149:22 121:6 122:22 124:12 leave [1] 125:15 licensee's [31 118:13 114:14 122:19 123:8 143:20 156:18 leaving [2] 96:21 112:25 132:5,11 135:20 146:22,23 masked [i1 129:19 measurements 341 3:7 left [7] 19:12 20:20 40:10 licensees is] 33:7 44:1,8 [31 72:9 94:7 Mason [1] 2:13 looked 18:3,11 27:3 29:13,14 110:5 125:4 129:6 144:2 45:3 79:15 136:13 master's[21 11:15,20 35:6,7 46:23 47:3,19 left-hand [21 60:14 91:11 [61 3:18 25:12 licenses looking [11] 34:13 90:11 material [331 16:16 21:17 55:24 57:3 71:20 79:6 25:13 37:14 52:8 61:1 legal [1] 63:1 90:13,13,15 108:7 122:24 22:6 34:15 35:18 55:22 81:23 90:17 92:13 93:15 LegaLink [21 6:5,24 licensing[4o1 33;19 128:10 146:10 158:14 61:1,2 63:3 76:8,10 82:12 97:9 98:6,9 119:12 122:14 length [31 70:18 89:8 41:24 42:13,17,20,24 43:2 170:23 93:8,12 112:19 114:1 122:21,25 123:13 124:10 141:4,7,7,9,9 151:6 43:5,8 44:10,15 48:11,16 looks [5] 60:24 67:18 140:11,24 124:18,20 125:2,3 126:17 49:14,22 50:18,22 51:19 141:13,19,22,25 144:12 L .1. & Index Page 8 Combs & Greenlev. Inc. (415) 512-1234 Raymond F. Fish, Jr. measures - office October 12, 1999 129:24 54:1 55:5 60:8 67:9 83:11 175:8 135:24 137:24 138:11,11 120:9 121:10 123:3 124:3 129:2,2 140:6,9 146:11,17 126:1 127:3 135:24 measures [2] 28:17 84:25 105:12,13 movable [11 69:17 142:6 151:4,4 168:21 nine [1 22:12 143:12 146:11 157:21,23 83:21 move [is] 55:13 58:20 157:24 160:10 163:6 measuring [131 18:2,15 ingrate [2] 144:3,21 69:18 88:14,15 96:9 nominal [1] 169:15 176:14 25:24 28:7 29:23 30:2 Mile [1] 39:4 104:23 105:9,11 115:24 none [3] 11:5 67:3,4 125:23 131:10 144:11,15 numbered [1 3:11 56:19 84:19 85:15,18 milligram [1] 18:6 nonradiation [2] 76:21 100:25 124:13 161:18 144:15,24 145:5,8 numbers [26] 54:5,8,10 million [3] 79:24 128:1 80:2 54:11,25 60:17 63:1 71:25 mechanical [21 33:1,3 128:4 moved [4] 38:3 40:14 nonradioactive [31 13:9 96:6,12 77:18,19 78:1 80:1,4,5 mechanism [41 33:4 Millions [1 79:2 14:10 168:16 85:10 90:13,14 97:2 125:8 movement [1] 144:14 111:12 145:6 147:15 millirad [1] 143:8 nonregulatory [1 33:13 125:9 130:19 143:6,9 moving [4] 23:16 93:25 mechanisms [31 35:11 millirads [1) 143:8 nonresponsive [Is 148:6 158:14 159:17 144:23 145:1 110:1 145:5 55:14 88:16 96:10 115:25 millirem [2o] 28:24 29:1 MS [47] 2:6 6:14 7:21 Medical [1] 82:5 29:8,10 55:7,11 72:1,2,3 125:24 -0 ['1 11:6 18:21,24 19:3,6,9 31:18 Nope [1] 109:19 medication 78:3,5,9,12,13,16,24 32:4 46:5 63:23 64:8 Oakland [1) 24:4 medium [21 32:16 144:13 124:3 130:9,14 160:3 67:13 80:19,22 88:15,23 norp[] 181:17 oath [4] 8:25 9:2,3,4 [131 28:21 meet [12] 38:24 45:17 millirems 89:4 96:25 103:15 106:9 normal [21 93:23 175:10 object [7j 32:5 88:23 46:10 56:14 97:4,6,16 72:9 76:14,18 77:11,13 106:14,18 127:19 130:7 normally [41 28:14 82:24 106:9 130:7 131:10 77:17 120:10 121:8,15 132:17,21 136:5 140:7 130:13 131:10 143:2 165:14 170:6 145:16 174:22 164:14 135:8 157:19 163:25 145:13 148:16,17 151:16 north [il] 5:12 15:18 17:3 objection [20] 31:16 meetings [21 36:5,6 milliroentgen [17] 18:7 153:25 154:25 156:14,19 17:12,18 19:11,19 20:20 18:8 28:21,24 29:1,6,10 167:2,9,25 169:2,6 172:23 63:20,23 71:17 77:2 82:22 memo [11q 44:20 48:9,13 110:5 119:21,22 103:14,15 121:18 129:22 57:24 58:5,6 84:8 86:3 174:19,23 175:12 180:6 49:1,5 88:12 89:12 115:20 [I] 6:24 131:16 132:23 142:22 119:24 120:1,3 135:5 Muller[3] 18:21,24 19:7 Northern 116:9,13,14 notary [1] 6:4 144:5 145:13 151:12 143:10 multipage [1] 167:16 memorandum [11 notation [21 91:25 94:23 153:17 154:20 172:17 115:20 milliroentgens [14] multiple [1] 169:15 175:5 28:22 57:17,23 84:14 notes [31 77:15 127:12 1s1 31:24 memory [i1] 10:15,19 85:16 86:2 90:19 120:6 multiples [1l 122:21 objections 134:17 64:7,8 144:22 145:2 11:7 74:8,11 88:4 96:16 124:4 126:18 135:3,6 must[i] 53:24 101:19 102:10 nothing [4] 84:23 94:14 96:19 160:25 169:22 mutually [11 184:16 obtain [4] 45:18 82:12 113:10 114:12 115:7 130:17 181:7 121:1 142:19 minimis [1] 63:9 Mylar [1i 28:8 notice [2] 4:15 116:3,6,8 118:2 141:10 51:24 obviously [1] 129:8 memos [2] 48:19,21 minimum [31 18:16 noticed [1] 6:8 57:10 165:7 occasion [3] 136:5 mentioned [51 33:15 notification [2] 87:10 148:21 152:6 minimus [21 56:15 63:8 40:17 150:3 172:6 178:21 N [ 2:1 117:15 minor[2] 11:14 172:21 occasional [2] 165:19 met [13] 38:23 42:21,23 name [5] 6:17,20 18:25 notified [1] 106:6 165:22 48:6,10,17 72:2,3,4 minute [42] 54:15,17,21 166:20 notify[3] 63:12 86:7 87:5 113:11 115:11 130:11 66:6 83:21,22 84:6,8,13 39:23 occupy [1] 62:23 notifying [1p 88:8 132:12 136:17 140:3 84:17,19,20,21,24 85:3,4 names [2] 39:11,14 occupying [11 56:16 151:1 162:10 164:4 85:5,7,11,12912,13,19,19 Natcrial [tl 3:19 November [31 15:24 occur[3] 30:7 33:11 180:9,9 metal[21 69:11 138:13 85:22,24,25 121:21 National [4] 25:22 44:5 175:9 123:19,20 124:4,12 now[26] 11:9 12:9 37:2 metals [1] 30:24 79:5 166:15,16,17 167:15 occurred [17] 7:12,24 125:11,16 126:13 128:2,4 167:17 168:1,4,11,13,19 37:20 46:15 53:20 54:17 10:15,22 20:19 30:9 33:11 meter[21] 55:25 57:18 130:17 131:7,14 169:19 169:3 67:23 85:2 97:10 101:5 34:2 86:11 129:1,5 164:7 57:22 58:9,14 66:25 68:14 169:21 106:2 117:21 119:7,17 73:5,6 84:5 93:5 96:6 natural [9] 158:12,17,19 175:7,13,17 176:14,19 minutes [2] 41:10 75:7 163:5,9,12,16,20,21 138:23 142:1 149:14,23 occurrences [1] 176:25 104:11,12,23 105:8,10,12 155:7 156:14 161:17 105:13,14 125:4 mischaracterizes 12] naturally-occurring Occurring [2] 58:12 77:2 151:12 165:25 173:18 178:21 meters [31 67:4 105:5 [1] 163:4 180:6 87:18 Misstates [1] 156:13 168:20 NCRP [1] 44:5 NRC [31 41:17,20 62:6 ocean [2] 34:2,20 method [i] 178:14 misunderstand V) near[4] 40:22 110:18 October[s] 1:20 4:16 6:2 163:17 nuclear[6] 2:12 3:19 methods [21 32:12 128:18,19 8:11,20 15:17 16:1 17:3 184:1,7 132:25 modification [1] 39:2 nearly [1] 10:23 17:11,18 19:11,18 20:20 off [23] 27:7 41:9,11,22 metric [1] 18:8 moment [6) 53:6 59:4 necessarily [4] 46:24 21:24 22:24 26:4 33:22 58:14 66:5,7,9 75:1 83:25 96:22 126:21 135:13 105:3 121:21,22 126:20 Michaud [1] 2:10 164:6 174:4,6 34:10 36:15,22 37:3,13 167:3 37:21 38:4,7,9 41:5 61:6 126:22,24 130:9 135:12 micro[2] 119:13 124:4 necessary [3] 9:13 62:16 moments [1] 163:15 63:11 61:11,12,14,16 62:12,17 135:14,16 146:2 148:11 microroentgen [pi Monday [1] 180:9 62:24 134:6 137:11,13,22 165:15 167:2,4,6 178:8 119:23 need [7] 27:6,10 29:17,21 138:5 149:16,25 150:10 180:14 monitor [2] 6:2 146:7 30:7 32:3 121:20 microroentgens [61 150:15 166:23 178:22,23 offhand p1 12:9 monitoring [21 23:17,20 needed 12] 102:1 139:17 119:14,15,19 124:4 Nucleonics [11 20:22 office [3s1 24:1,2,22,25 134:23 135:1 month [1] 15:25 neutron [1] 29:7 Nucor[4j 1:10 4:10 5:15 36:7 40:10,15 43:18 44:19 mid [1] 8:23 months [1] 22:12 Neutrons [p] 29:5 6:19 45:15 51:24 63:12 65:15 mid-September [i] Moraga [4] 40:2,3,4 new[4] 1:11 4:11 39:6 number[43] 6:1 12:2 72:16,18,19 73:16 80:6 15:9 184:3 43:10 54:20 55:10,11,16,17,17 87:6,12,13 92:11,14 93:11 22:9 morning [61 6:14,17,20 next [22] 9:23 15:16 47:23 59:5,11,14 61:2 66:19 93:15,16,18 94:9 105:18 middle [61 19:12 105:19 115:15 116:25 80:18 81:5 133:9 177:11 7:5,7 89:8 66:19 75:10 91:1 94:22 77:20,24,25 78:2,11,20 105:12,13 122:2 123:3 79:8,19,23 80:20 81:1 119:1 133:13 149:22 might[2o0 9:15 10:16 mostt[8 13:8 30:19 51:11 166:9 171:10 184:16 11:7 29:24 43:21 44:23 73:12 91:8 124:8 168:15 125:25 127:3 134:5 91:1 92:22 96:8 104:15 Index Page 9 Combs & Greenlev, Inc. (415) 512-1234 Raymond F. Fish, Jr. offices - practice October 12, 1999 L I offices [1] 184:8 order[111 16:11 17:7 35:7 parts [4] 32:20 37:21 91:9 142:7 160:8 175:21,25 37:13 38:8 102:21 176:3 oil [3] 12:23 34:3,4 45:18 46:10 70:14 74:15 plaster [in 136:25 75:10 97:8 134:5 157:12 passed [2] 40:1,19 periodically [41 40:2,6 137:15,18 138:7 178:22 on-the-job [3] 31:6 43:15 71:1 179:2,3,5,6,13,17 35:20,22 organic [61 12:4 15:20 past [1] 75:7 16:7,11,14,17 Patterson [1s1 2:5 5:8 ijury[3] 180:19 182:5 plaster-lined [11 137:7 once [11] 42:19 47:22 183:4 48:5 87:22 95:23 103:2,3 organization [21 16:10 6:12,12 7:4,5 8:5 19:10 plates [p1 30:24 164:13 176:12,17,19 168:14 21:8 31:23 32:8 41:9,16 permissible [1] 76:2 plot [41 88:19 89:24 90:1 52:24 53:5 55:19 one [931 4:18 6:8 8:17,19 Organizationally [1i 46:8 permitted [31 155:5,14 92:8 8:22,23 14:5 21:24 24:21 43:7 56:10 59:4 64:2,9,15 66:5 159:2 plutonium [il 13:13 66:12 67:1,17 75:8,14 25:23,25 26:3,19 29:4 original [41 62:18 184:7 person [l0 48:25 51:15 point [27] 33:19 34:22 30:16,22 32:14 43:21 184:8,23 77:7 80:21,23 81:3 82:25 76:25 117:22 118:11 87:21 88:3,18 89:2,14 35:15 37:2 44:2 55:9 48:15 55:8,15,20,21 56:25 Orinda [1] 40:8 136:19,20 150:16,23 57:13 62:5,9,10 86:9 56:25 57:25,25 58:6 60:23 91:5 96:15 97:12 103:21 181:10 Ours [Hi 47:1 106:20 113:19 116:1 87:19 99:25 102:14,15 60:25 62:9 65:15 66:24 personal [11 65:6 113:10 115:9,13,14 67:9,11,12,14,15,18,20 outside [111 23:16 30:9 118:16,21 121:20 122:2,7 123:16 128:21 129:14,15 123:3,7 125:25 126:5,20 personally [1] 4:20 128:20 136:5 145:12 72:9 73:3,4,6 74:21 76:14 159:13 164:25,25 174:25 76:18 77:17 78:4 81:9,10 129:17 134:21,25 139:6 127:2,8,21 130:1,21 personnel [2] 39:11,11 131:12,17 133:2 134:4,11 177:22 81:11,15,24,25 87:5 96:3 177:12 persons [pi 136:17 135:12,19 136:4 142:24 points [1] 128:14 96:5 97:1,15 104:11,12 overbroad [2] 31:17 perspective [1] 42:12 104:22 105:7,8 107:23,24 145:17 143:4 144:7,16,25 145:9 political [11 12:12 145:14,22 146:8,15,21 pervious [1] 179:5 115:17 125:11 133:11,12 oversaw [] 21:9 polonium-210 [61 133:15,16,18 136:17,18 148:9 152:1 154:22 Pharmaceutical's [11 158:17,24 159:3,14,22 oversee [21 21:1,5 137:14 143:9 150:19,22 156:13 177:8 184:23 2:9 160:2 overseeing [1] 42:6 paved[41 109:6 114:24 150:23 153:3,4 155:1 Pharmaceuticals [1] pool [74] 94:15 96:21 157:4 158:13 159:12 own [3] 45:7 51:13 70:20 115:5 153:14 1:9 4:9,24 5:10,24 6:9,13 97:18,20,22,23 98:1,4,10 163:20 168:17 174:8,23 owned [1] 149:1 pellets [1] 138:14 7:15 184:5 98:12,24 99:1,4,5,9,11,17 175:12,23 owners [2] 6:16 148:19 penalties 121 182:5 183:4 phenol[11 16:20 99:20,23,24 100:2,8,14 one-and-a-half [1] penalty [11 180:19 phrased [21 56:8 63:21 100:16 101:6,7,10,12,24 72:23 102:17,25 110:10 113:9 -p penetrated [11 172:14 phrasing [1 131:18 one-inch [3] 127:24 113:12 114:21 128:19,21 128:3 130:22 p.m[21 75:4 180:17 people[4o] 22:13,19 physical (31 12:5 33:4 129:1,3,6,8,8,14,15,17,21 24:23 25:6 27:20 39:25 145:4 129:23,25 130:6,9 137:1 one-meter-by-one-meter Pacific [1] 24:12 42:24 44:21 48:12,16 [1] 119:9 physically [41 145:5 137:3,7,8,12,15,23 138:6 package [1] 49:8 50:18,22 51:19 54:9 62:6 164:22 179:13 180:3 138:8,13,22,24 139:4 one-minute [4] 124:10 80:2 pad [191 110:9,11,12,19 78:9,18 79:3,9,25 physics [31 11:14 12:7,8 152:13 154:9,9 164:9,13 125:1,3,5 110:23,24,24 139:6,10,16 82:5,5,15 83:16,19 88:9 164:17 172:10 177:19 one-square [11 73:5 139:20,23 140:1,11,15,25 88:11 115:22 116:22 pick [7] 93:7 131:6,9,11 178:22,25 180:3 131:14,22,24 one-tenth [1 58:5 141:11,20 151:23 117:13,18 132:13 136:11 poor 111 109:13 137:13 149:21 159:15 picked [21 84:3 93:12 ones[2] 100:9 133:18 page [271 2:4,8 3:2 53:21 population 1i1 34:20 67:6 76:1 80:17,18,19,23 162:3 168:7 179:15 picking [11 84:13 onto [1] 74:19 169:9 81:4 123:12 127:9,19 per 1pi 54:15,17,17,21,22 picture[31 67:8 69:15 portable[1 000[71 1:4 4:4,14 5:1,21 134:15 136:24 138:11 57:11,12,15,17,24 58:5,6 79:3 portion [241 49:23 61:5 75:3 180:18 139:1 140:9,12 141:1 77:13,24 78:3,5 81:18 pictures [4] 2:16 66:13 67:25 69:6,7 70:3 96:1,23 98:14,24 103:22 104:4,18 open [16] 68:19 69:12 167:10 168:21 169:1,2 83:20,22 84:6,8,13,15,17 67:2,7 92:20 94:9,14 95:24 104:4 182:8 183:7 84:19,20,21,24 85:3,4,4,7 105:5,22 106:22 110:17 113:7,8 151:23 152:14,14 pagcs[2] 1:21 126:10 85:11,12,12,13,18,19,22 Pie [1] 28:5 111:3,11,16 114:4 117:1 161:16 164:9,10,21 85:23,25 119:13,14,15,19 piece [41 20:12 21:18 119:18 164:4 pancake [2j 28:3,11 opening [2] 68:15 145:4 119:23,24 120:1,10 67:19 69:18 portions [1] 147:21 pancake-type [1] 28:13 123:19,20 124:4 126:13 openings [1] 152:20 pipes [61 55:23 56:2 position [l10 12:24 15:10 paper[61 30:17 73:1 126:18 128:2,4 130:10,14 99:23 100:3 106:24 107:1 19:15 20:24,25 22:10 24:5 operate [1] 178:24 104:9,13 110:6 112:5 130:17 131:1,7,14 132:20 pit[9] 100:4 177:11,12,15 36:19 37:24 41:19 135:1,6,8 143:8 operating [5] 34:10 80:8 papers [2] 72:22,24 134:25 177:16,18,18,25 178:2 157:19 160:3 163:25 possess [1] 76:7 103:10,12 152:6 [91 76:6 81:2 paragraph 169:19,21,22 170:1,5 pit-waste [1] 115:3 possession [1] 76:11 operational [2] 34:1,8 81:3 127:11,12 134:20 177:15 place[131 6:7 21:19 31:11 operations [6j 24:1,22 136:22 138:11,25 possible t61 71:25 percent [2] 160:8,8 39:1 52:19 92:3 112:11 153:22 154:17 172:13 118:24 171:7,16,22 Pardon [1) 18:23 percentage [11 163:7 113:11 132:7,18 153:7,10 173:10,12 operator [23] 5:22 6:3,23 Park f1 5:6 181:11 66:7,10 perfectly [21 10:10 11:1 possibly [11137:2 7:3 41:11,14 part [2s] 7:13,14 8:18 13:8 placement [2] 29:23 74:24 75:5 121h22,25 perform [1] 13:4 potential [101 14:6 16:10 19:6,12 24:21 29:16 33:12 30:2 16:12 56:16 77:6 109:1 126:22,25 135:14,17 62:18 performed [61 16:24 145:25 146:4 148:11,14 42:8,11 51:11,16 placing [3] 124:9,11,25 109:24 144:2 176:10 73:12 75:15,19 81:8 91:8 46:20 111:13 124:7,9 [21 179:14 167:4,7 180:12 132:24 Plaintiff's 3:21 91:18 94:10,13,13 103:18 167:22 opinion [1] 132:19 117:5 163:13 175:3 potentially [1] 129:18 performing [21 48:24 plaintiffs [41 1:7 4:7 5:5 opportunity [3] 9:12 177:13 133:1 powder [3] 138:16,17,18 119:4 142:12 7:22 particle [3] 83:24,24 perhaps [21 38:19 60:18 power [s] 8:20 33:22 [] 44:2 161:6 plan [31 88:20 90:1 92:8 34:10 36:22 37:13 38:8 oppose period [231 15:5,6,11 plans [3] 38:7,13,16 138:15,18 opposed [s3 25:9 80:9 particular[S1 24:17 73:3 19:21 26:13 37:9 45:21 82:3 89:7 161:8 170:24 119:7 122:8 125:15 53:17 65:9 77:1,20,22,23 plant [3] 8:20 22:5 34:10 practicer[] 41:25 74:13 173:2 178:7 parties [2] 181:16,19 86:15,19 125:6,10 131:13 plants [4] 33:22 36:22 93:21 107:25 125:19 132:22 164:20 Index Page 10 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. practices - regulations October 12, 1999 I practices [31 17:16 24:14 44:13 45:3,11,19,23 46:11 148:10 rate l[] 134:21 109:13 130:5 137:8 138:19 139:8,15 148:1 41:4 46:11 50:2 52:6,8,11,13 quick [2] 74:23 147:9 ratherm[1 170:22 52:16,20 53:11,18,18,25 154:1,2,4,7,8,12,15 precautions [1] 17:5 quickly [11 168:22 ray [5] 3:6 18:4 83:23,25 156:17 157:10,16 158:7 55:24 62:15 63:4 64:3 83:25 preliminary [1] 33:24 71:16 74:19 83:2,15 87:15 quote [1] 80:6 159:24 177:16 Raymondiis1 1:18 3:14 premises [11 61:18 87:17,18 88:6,25 89:6 recommend [21 42:25 90:9 91:7 96:2 111:11 3:20 4:21 5:23 74:25 75:6 48:18 prepared [31 48:24 74:16 146:1,6 180:13 182:4,25 118:25 114:5 116:4 117:24 118:8 recommendation [2] 128:6 r[4] 2:13 81:11,11 136:20 183:3,25 184:2 preparedness [ol 36:22 118:25 123:14 48:14 166:16 132:6,16 133:5 139:2 rad[41 81:15,17,22 82:1 rays(71 30:13 155:24 36:24 37:1 38:4,6,11,13 recommendations [2] 38:15,20 39:1 140:21 142:4 148:20,23 radiation [9s] 3:4,23 156:7 157:12 159:21 149:1,2,16 150:19 152:12 163:17 165:5 79:11,13 presence [1] 131:25 15:20 16:7,13,15,18 17:5 155:10,21 156:20,25 17:6,14,14,15 18:2,5,13 re [2] 3:15 184:4 recommended [11 79:8 present Is] 51:10,12 157:13 158:5 159:3,13 18:17,19 20:15,17 22:4,6 reactor 7] 16:11,11 reconvene [1] 180:10 76:12 77:9 102:3 163:24 164:4 171:13 24:6,7 25:2,24 27:20,21 21:19 33:25 38:4 39:5,18 record [431 21:7 27:7 31:25 174:3 preserve [1] 27:21 28:15 29:3,11,18 reactor-related [1] 26:1 31:24 32:6 41:9,11,14,23 preserved [11 73:14 Proskauer [3] 5:6 6:9,13 29:20 30:21 35:4,6 36:18 46:7 58:3,9 66:5,7,9,10 37:6,7 38:1 41:2,6 44:5 reactors [4] 21:2,12 26:5 pressure [2] 72:25 Protection [3] 44:6 79:5 41:6 75:1,7,14 121:21,22,25 104:10 166:17 46:22 47:2,18,24 50:21 123:11 126:21,22,24,25 55:12,21 56:4,14 68:12 read [16] 21:5,7 31:12 provide [i0] 9:21 10:7 131:25 135:12,14,16,17 pretty [p 91:14 69:20,23 72:7 76:2,10,11 46:7 61:5,5 64:19 84:21 146:2,4 148:4,4,8,11,14 prevent[2] 23:15 100:18 38:18 42:15 44:1 83:12 76:19 77:8,15 79:3,5 119:5 123:9,9 125:12 88:9 89:15 90:25 173:6 167:2,4,6,7 180:14 previous [7] 50:6 63:8 80:13,17 81:14 82:3,6 129:19 134:12 166:20 recorded [1] 84:14 provided [10] 42:16 45:2 96:7 100:17,18,19 104:25 168:17 69:3 122:8 126:5 136:11 recording [1] 84:22 139:13 45:22 90:18 119:1 136:6 119:8 122:15 131:25 readily [31 53:24 54:1,5 147:5 149:17,20 168:18 [41 68:12 85:8 previously [71 80:11 139:5,9 143:20 156:18 [241 29:24 55:4 records 158:18 160:22 reading 166:9,11 94:11 119:1 137:4 155:8 Providencia [531 2:23 157:1 56:21,25,25 57:1,4,5 164:21 167:19 52:11,20 55:6 61:8,18 161:10 165:12,17,20,23 62:20 84:25 93:14 94:3 rectangle [2] 91:17,21 62:15 63:5,18 64:1 65:24 166:17 167:11 168:20 96:1 101:17 120:25 121:4 rectangular[21 28:8 Price [1] 2:10 66:16 68:5,22 69:14 70:22 170:6 175:22 179:24 primarily[71 13:5 18:15 124:22 127:19 143:8,24 92:25 71:8,16 72:13 73:25 79:22 radiations j1129:2 161:11 165:13 166:13 23:9 25:6 33:21 43:25 79:25 80:3 83:1,14 87:1 reduced [1 181:12 127:17 radioactive [6O0 12:15 184:8 refer [61 60:22 69:25 88:4,6 91:7 115:10 116:4 13:12 14:1,9,17,23 19:22 117:11,24 118:8 123:14 readings [20] 58:9 71:16 75:25 80:19 136:21 168:4 primary[7] 12:6 16:19 19:24 20:2,4 22:5,21 23:1 132:15 133:3 134:18 82:12 92:18 93:8,12 107:3 17:23 28:9 41:8 135:1,2 23:12 24:16 27:18 31:15 reference [41 60:16 139:2 140:16,21 142:4 108:10 124:24 126:17 probe[3] 128:1,3 130:25 31:20 32:13 33:6 34:15 77:14 168:19 169:9 147:10 148:3,20 151:11 130:5,8,20 150:5 156:10 problem[12 18:16,16 35:2,12,18 41:5 42:1 157:22,22 162:24 163:1 referenced [21 135:8 155:2,9 157:13 163:24 53:24 56:20 63:4 76:9 137:4 160:17,19,22 161:7 162:4 174:3 179:1,19 164:12 179:3,7,9,9,12 82:12 83:24 93:8,12 reads 121 29:4 64:19 References [1] 63:5 provides [2] 76:5 130:18 118:24 131:5 134:1 137:2 problematic [1] 160:12 real [3122:23 63:4 160:17 referencing [2] 71:10 providing [2] 88:10 90:8 144:1,20 147:24 155:20 108:6 problems [6] 16:12 155:23,24 158:23 160:15 really [61 9:17 78:23 82:2 34:18 71:25 137:17,25 public [6] 6:4 76:22 78:3 referring [6] 46:8 81:10 80:6 87:25 88:1 161:21 166:14 167:14,17 86:4,5 140:5 176:10 168:15 171:6,13,21 173:1 109:6 137:3 143:11 published [2] 60:8 reason [7111:3 71:23 168:21 procedure [2] 33:6 173:11,15,19,25 174:2 112:15 161:19 162:4 184:12 166:14 refers [a] 59:9 60:20,23 Puget [] 40:22 radioactivity [n] 23:18 182:8 183:7 procedures [6] 31:3,13 28:20 58:12 68:2 101:1 60:24 61:2 76:2 114:21 pumps 11) 14:11 reasonable [21 55:9 136:23 42:3 63:12 74:6 175:25 107:16,25 127:13,17 175:17 145:11,20 reflect[2] 165:21 170:2 proceed [1 184:15 purpose [71 13:14 54:3 receipt [] 60:1 proceedings [8] 8:10,13 59:24 80:10 81:7 172:24 radiological [21 45:10 reflected [4] 115:17 173:5 receive[is] 11:17 14:16 9:3 32:1 41:13 121:24 45:22 17:4 21:20 25:17 26:14 155:15,17 177:25 146:3 148:13 purposes [7] 53:12 62:23 rads [2181:17 82:7 35:1 43:15,23 44:9 51:24 reflects [p] 170:1 process [12] 33:20 42:9 82:10 85:14 90:8 133:4 rag[2] 32:16 33:2 53:16 80:7 117:15 155:14 refresh[s] 55:5 76:16 42:11,12 86:16,24 88:8 133:13 rain [] 144:13 received [19]11:19,20 130:4 137:7 139:8 117:5 140:10,24 141:3,18 pursuant [2] 4:15 76:6 Ramon [1] 20:23 14:18 17:11,13 35:3,4 refreshes [i1 139:15 processing [il141:25 put [19] 20:13 21:25 25:22 43:18 60:7,9,10,11,12 regard [11 165:3 produce[i 146:25 26:2 43:13 49:7 54:13 Rancho [2] 34:12,18 81:19 88:13,19 89:15,22 [31 47:1 104:21 regarding [7j 7:11 9:8 [1l 69:21 73:11,12 79:6 84:19 random 117:17 produced 147:7 85:7 110:23 125:4 129:11 105:2 14:16 53:10,17 63:6 production [1] 14:7 receiving [4] 42:13 117:10 164:17,18 165:11 randomly IS]36:1 47:12 76:13 77:10 165:23 professionals [1] 79:9 regardless [1] 162:17 putting [1] 31:24 93:1 96:6 104:12,16,18 75:2 program [5l 22:6 34:4 105:16 recess [11 regimented [2] 105:2,14 recognize [7] 29:17 38:9 50:20,21 - range [4] 12:1 134:22 [1] 38:17 -Q 55:16 66:15 67:4 91:6,18 region programs [2] 41:7 51:2 161:6 169:15 register p1] 60:9 QA [11 94:24 161:5 prohibited [1] 153:7 ranged[11 176:11 [21 170:15 recollect [3] 154:24 regular [1] 104:23 [11 qualitative [1] project 14:12 170:18 Ranges 169:13 155:7 179:21 regulation [31 41:3 [ij 6:1 82:13 proper 170:8 quantitative [s] 170:7,8 RAP[3] 1:8 4:8 recollection [33] 7:24 59:22 60:13 79:17 properly [11 166:7 170:10,15,17,19 171:1,2 rapid [l 170:5 10:15 55:5,14 62:8 74:18 153:6,10,24 91:14 property [70] 2:21 6:16 rare [31 141:6,8,8 74:20 76:16 89:9 regulations [21] 3:23 questions [3] 49:5 147:9 95:15 100:1 106:11 24:14 39:3 43:10,11,17 Index Page 11 Combs & Greenlev, Inc. (415) 512-1234 Raymond F. Fish, Jr. regulatory - September October 12, 1999 45:22 52:18 65:12 75:16 112:9,13,22,24 113:2 requirements [191 38:23 right [221 12:9 27:8,11 saw [31 99:14 134:14 75:18,19,22 77:24 78:1 114:4,6,7,9,11,18 115:5,7 38:24 39:1,3,7 41:3 42:20 30:5 32:8 49:21,24 65:2 172:10 81:8 153:16 167:12 117:12,20,21,23 118:9,10 43:10 45:10,17 46:1,9 77:17 85:19 95:4 101:8 says [321 55:21 59:7,19 176:24 177:2 178:4 118:14 130:4 133:2,6 55:4 56:15 63:25 140:8 117:21 119:2,22 120:12 59:21 60:17 75:16 77:8 130:11 135:9 138:23 regulatory [s] 8:11 136:16,19 137:10 138:4,7 162:5,8 176:24 81:7,11,15,17 91:11,25 145:14 155:7 161:1 36:15 37:3,21 44:3 134:6 138:8,23 139:10,14,25 requiring [1] 147:23 94:11,16 95:10,16 112:7 139:5,9 140:1,5,14,17,18,23 141:3 reread [1] 46:5 right-hand [1] 59:6 112:18 113:23 114:15,24 147:20,22,23 149:10 124:25 128:2,12 134:20 relate [41 56:25 90:14 [171 Robert[ij 39:18 150:16 151:6 152:3,8,22 research 12:22,25 137:6 140:9,24 143:15 157:24 170:20 153:3,4 156:4 161:1,17 13:23,24,25 14:1,4,5,9,14 roentgen [3] 81:12,22 169:15 170:5 related[11] 8:20 14:12 15:8,14 16:3 21:2,4,12 82:1 163:7 174:20 177:14,22 scale [6) 58:4,14,16,18 26:3 29:1 45:10 51:2 103:9 [21 80:12 remembered [21 4:15 roentgens 58:21 165:15 56:15 60:5 88:25 176:8 88:24 residual [2] 118:23 84:15 181:18 145:11 scaler[2] 54:14 72:17 remembers [1] 89:6 Rogers [6] 118:25 119:5 relates [31 59:12 89:6 resolved [1] 49:7 122:10 126:11 128:10 scalers [1] 15:1 141:12 removable [13] 27:22 170:14 scales [3] 57:25 58:2,11 46:24 47:25 53:25 54:2,6 respect[1g9 13:11 27:2 relating [1 143:19 54:23 109:24 143:20,21 30:12 32:9 39:6 52:19 Rogers' [I] 123:12 Scarano [i13:13 relationship [11 80:12 143:24 147:18 178:16 57:14 72:6 88:3 95:23 roof [11 111:5 school[] 11:12 101:14 103:17 108:18 relative [11 170:23 [21 33:4 167:13 room [1i 93:3 science [1] 12:12 removal 141:6 156:23 159:9 165:6 release [42] 3:17 42:20 removed [5i 94:12,19 176:21,24 rooms [11 95:14 scintillation-type [1] 42:22 45:19 46:11 48:6 147:24 179:17 180:2 respond [1] 88:1 Rose [3] 5:6 6:9,13 55:25 48:10,17 52:5 82:19 86:8 removing [1]179:13 screen [1] 28:8 88:10 90:14 97:11,17 response [1] 38:8 Ross [1] 3:12 102:3 130:12 132:12 repairs []1 99:11,12 routine [2] 39:9 105:14 se[s] 77:25 131:2 132:20 Responses [1] 10:4 170:1 177:15 139:1,3 140:3 142:19 rephrase [1 10:11 rs]j 119:13 responsibilities [121 sealed[1] 144:10 151:1 153:6 158:15,18 report [36] 42:22,23 48:8 13:2 22:16,18 37:8,11,17 rules [21 9:7 184:12 159:11,16 161:23 162:1,6 48:23 49:6 88:13,19 90:23 40:24,25 41:23 42:10 running [1] 145:22 sealing [1] 144:11 162:10,12,14,19 163:25 115:15 116:3,9,10,11,12 61:23 75:20 Seattle [1] 40:22 164:5,15 167:21 171:3 117:5,10,14,16 119:2,5 [9120:6 Seco [1] 34:12 172:24,24 122:10 123:10,12 124:6 responsibility -_ 20:10 21:1 41:8 87:7,24 second [16] 8:19,23 55:7 released [91 44:13 45:12 126:11 128:8,9,11 130:18 116:21,23 118:5 S ['j 5:17 45:24 46:12 87:15 132:6 148:7 150:9 166:17 55:16 58:23 62:20 77:5 159:13 165:1 171:23 170:10,12,13 175:19 responsible [31 42:5 safe [61 24:14 76:17,23 80:21 97:7,8 103:4,6 63:3 116:17 166:13 167:17 172:25 106:21 115:17 127:11 releases [1o[ 51:13 74:18 reported [3] 1:23 24:22 134:20 171:5,21 172:2,12,13 175:14 responsive [1] 147:2 safely [i 17:8 secretaries [1]39:19 175:9,13 176:22 reporter[12] 4:20 6:23 rest [4] 91:14 95:14 safety[•6 17:5,6,16 22:5 r[7 releasing [6j 80:10 90:9 6:25 9:10,24 58:24 66:18 110:16 111:13 22:6 24:6,8 25:2 27:20 section 36:23 75:25 132:14 133:5,14 164:23 127:3 135:24 146:11 restate [1] 32:7 35:4 37:6 38:1 41:2,4,25 76:7 80:16 95:5 96:13 50:21 184:12 relied i 176:20 181:1,5 restricted [s] 47:16,19 reporting 1p 176:23 109:2 172:1,12 Sam [3] 39:17 40:9,10 see [so120:19 30:12 34:23 rely [1] 173:6 39:5 40:1,5 53:21 58:20 reports [3] 50:6,7 74:18 restricting [1] 72:5 sample p]a 13:15 20:14 rem [41 80:12 81:9 82:1 20:18,18 35:18,23 36:2 59:6,18 60:18 64:21 66:15 160:25 represent [7] 6:11,15,22 restrictive [2] 143:9 54:24 72:21 73:3 85:20 67:7 72:2 76:3,14 78:14 remain [1i 63:13 7:14,21 122:9 148:18 158:25 104:14 105:4,11 128:13 84:23 90:14,15 91:24 92:1 remained[21 152:13 representative [6] result [5] 39:3 54:14,21 173:10 178:8,14 92:11 94:1,24 95:5,16 96:7 99:10,12 108:8 164:9 35:24 36:8 51:3,12 150:13 76:13 77:10 sampled 1i] 173:14 150:15 resulted [11 171:7 112:20 113:21 114:1,24 remaining [21 127:15 samples (53] 13:6,6,7,8 115:3 120:22 121:6 173:3 represented [61 5:4,8,13 results [is1 3:3,5 46:21 13:12,18 20:13 34:6 35:21 5:18 184:14,15 122:22 123:15,20 128:8 remediation [i 150:11 48:5,7 54:17 65:20 89:20 36:8 47:10,12,15 72:12 130:16 134:16 141:1 represents [1] 165:20 90:22 115:18,23 132:10 [1741 10:24 72:15 73:20,23 85:21 143:12 147:18 163:11 remember 149:19 173:7 175:16 10:25 11:2 12:9 15:19 reprint [2] 2:19 75:16 89:23,24 90:4,22 93:18 169:9 20:25 22:1 23:6 25:5 request[i] 42:13,17 resurveyed [1i 140:3 93:22,24 104:3,8,19 105:17,21,24 106:2,3,5 seeing [141 89:12 95:11 27:14 28:1 39:10,23 47:8 43:2 44:10,14,23,25 48:12 retired 121 41:18 147:5 99:17 103:21 110:22 106:21 109:15,16,20 52:22,23 54:9 55:2 57:6 83:13 88:12 149:21 returned[1] 115:14 112:22 114:7,9,18 115:5 62:1,10 64:5 66:2,4 68:15 111:24,25 112:2 148:2 requested [51 42:14 [16] 38:7 117:20,22 140:14,17 68:21,24 69:8 71:4 73:25 review 9:12 150:4 156:23 157:2,5,7 61:14 63:12 146:24 45:6 50:8 53:6 109:9 165:4 174:24 175:2,11 seeking [2] 46:2 153:5 74:3,7,17 83:4,13 86:11 149:18 116:11 119:4 121:9 122:8 86:12 87:2 88:7 89:12 178:7,12 seem [1] 143:4 requesting [3] 44:20 126:6 142:12 171:9 90:24 91:15 93:10,13,20 sampling [21 14:17 82:21 seeped [1] 147:25 62:13 89:13 174:12 184:15,16 94:5,8,22 95:1,3,9,11,12 San 112] 4:18 6:5,8 11:14 sees [1] 83:23 95:19,21 96:21,22,24,25 requests [1l 88:2 reviewed [7] 50:4 75:19 12:1,15,18 20:23 23:25 116:12,13 117:4,7 155:9 send [3] 44:20,23 48:8 97:1,2,3,12,15,16,23,25 require [21 63:24 162:24 24:25 25:11 184:11 sense 11] 15:23 98:1,3,4,25 99:1,4,16,23 required [11] 12:10 22:7 reviewing [4] 42:2 74:8 Sansome [2] 4:18 6:8 100:1,9,10 101:6,13,16 74:17 90:7 sensitive [3] 131:4,8,21 42:15 50:23 101:7 107:19 satisfied [2] 97:10 115:9 102:4,6,13 103:2,4,5,6,9 150:11 171:3,19 176:4 Rhonda [1] 6:3 sent M 45:15 49:8 84:5 103:11,18,21,23,24 104:2 178:4 saturate [i 165:13 117:18 146:22 162:6,7 105:25 106:20 107:12,13 Rhone-Poulenc [4] requirement [9] 54:4 1:11 4:11 5:20 6:22 saturated [3] 127:23 sentence [1] 138:12 107:18,20 109:5,8,10,11 128:3 165:16 55:6,7 77:5 80:8 82:9,13 Richard [41 39:15 40:20 separate [1] 43:8 109:12,18 110:6,8,14,19 saturates [1] 165:13 110:22,25 111:2 112:1,8 82:14,20 102:6,8 September[6] 23:24 Index Page 12 Combs & Greenlev, Inc. (415) 512-1234 Raymond F. Fish, Jr. series - survey October 12, 1999 I 83:6 133:10,11 167:18 signing [1] 184:8 111:20 148:3 168:23 standpoint [2] 137:17 subsequently [t] 172:5 138:1 169:3 silence[il 162:12 Sound [1] 40:22 subsidiary [11 12:23 11:22 15:22 series [1] 122:20 46:19 source [33] 3:18 29:16 start[31 substance 121 7:8 8:15 similar[121 32:20 92:10 served [11 173:24 66:23 67:12,16 69:15 30:3 31:20 56:20 61:2 substantive [11 9:14 85:6 109:1 114:1 120:25 started[sl 12:8 24:5 44:3 serves [1l 173:19 104:25 108:17 111:21,23 subsurface [71 82:12,19 177:19 178:25 121:4 122:15,16 129:24 86:15 96:3 Services [11 134:7 82:21 144:17,18 152:14 simpler[2] 72:5 168:22 129:25 137:9,19 138:6,9 state [19] 6:11 11:15 12:1 177:12 SESSION [1] 75:4 140:10,24 141:3,6,18,22 12:15,18 48:19 83:2,6,9 simply [3] 7:10,23 10:25 such [15] 25:7 76:8 82:14 set[11] 56:22,23 104:20 141:25 144:1,10,11,12,17 83:11,16,19 86:6,13,17 Sincerely [il 184:19 155:1 173:1 83:13 133:6 144:13 105:3,24 106:2,3,8 107:10 86:18,24 87:5 134:6 152:15 153:8,12 157:8 143:23 162:2 single [1] 78:8 sources [9] 76:10 100:5 statement [191 3:15 158:23 162:8 171:17 sets [2] 56:17 168:14 sit18] 99:16 132:2 139:10 100:6,7,10,11,12,13 42:25 135:22,25 136:6,9 175:10 177:25 149:23 154:5,14 157:10 138:12 seven [3] 77:11 99:8 136:13,21,24 137:9,19 sUe [1] 7:15 165:18 south 1i1 108:7 138:7,10,21 140:12,25 114:21 sufficient [1l 132:3 site [17] 2:23 13:20 34:16 southeast 11] 128:17 141:12,16 145:14 several [1] 57:24 suggest [2] 74:22 114:8 92:1 118:22 128:24 space [3] 56:16 94:10 statements [218:1,4 severe [1] 160:23 154:13 134:22 139:1,7 145:12 states[91 1:2 2:11 4:2 Suite [5] 5:3,7,12,17 shall 13] 55:24 76:7 77:16 155:2 161:20 164:23 184:10 speak [41 26:16 31:7 5:25 38:11 61:5 79:9 shape [2] 109:13,13 165:1 170:13 176:5,5 148:21 157:23 136:22 166:19 summarize [11 48:7 Sharp [3] 3:15 136:5,17 sites [21 39:5,8 speaking [1] 106:11 stating [2] 48:9 63:16 summarizes [1] 26:7 SHEET[21 182:2 183:1 situation [7] 29:16 34:8 stationery [1] 100:2 summary [1] 53:13 34:9 63:10 102:3 145:11 Special [1] 3:19 sheets [1] 30:16 SUMp [5] 95:16,19,21 150:8 specialist [7] 24:6,8 status [11 164:16 shield [131 29:19 30:18 36:19 37:6,7 38:1 175:23 steel [91 30:24 140:9,14 112:19,22 30:19,20,23 69:3,9,12,22 situations [1] 30:7 specialist's [11 41:6 140:17 141:13,17,19,21 sumps [11 152:15 130:2 173:19,21,24 size [41 68:24 69:1 99:5 141:23 [27] 2:12,23 supersedes [1] 166:19 shielded [6] 28:14,16 104:15 Specialties 53:10 61:7,11,17 62:9,25 steps[S] 171:4,11 174:7 supervision p3] 14:18 29:17,21 68:18 129:24 slab [6] 177:5,6,9,12,13 174:15 178:17 177:23 74:4,9 136:23 137:13,16 31:10 181:14 shielding [31 69:16,17 138:8 149:15 152:5,9 Stevenson 11] 184:10 Supervisor [41 49:2,3 100:5 slow [1] 96:6 153:12 155:5,13,20 159:2 still [3] 86:7,21 152:7 116:12,15 Shimada[391 5:13 6:17 slowly [21 92:23 98:18 171:6,17 173:13 174:13 stop [2] 27:10 125:6 support [1 132:5 6:18 8:1 31:16 55:13 56:8 small [4] 73:13 76:7 174:18 63:20 64:7 71:17 77:2 104:9 112:18 storage[131 112:4 113:24 suppose p1] 38:4 specific [14] 38:25 60:5 114:15,15 115:3 137:1 80:25 82:22 87:19 88:14 smaller [2] 131:22,25 60:6 74:8,11 89:12 96:5 surface [311 3:3,7 32:18 88:17 96:9 115:24 121:18 139:4 153:8,14,20 154:13 32:22 55:24 56:5 73:1,2 Smith [3] 39:15 40:5,20 96:15 105:3 106:10 116:3 154:18 164:22 125:23 129:22 131:16 116:6,8 138:19 77:16 98:22 99:13,15 132:23 142:22 144:5,8,22 smooth [1] 178:10 store [31 137:1 140:10 104:16 113:25 114:17 specifically [23] 23:7 145:2,16 151:12 153:17 soaps [1] 32:15 141:18 119:8 120:22 123:14 154:20 168:24 169:5 23:25 25:22,25 66:4 69:11 124:7,10,12,17,17,23 sodium [121 35:13,16 97:16,25 98:3 99:3 103:11 stored [S1 100:5,8,13,15 172:17 174:17,22 175:5 127:24,25 128:3 130:23 103:22 138:13,22,24 125:1 127:14 143:15 184:24 107:18 110:19 137:10 172:22 178:9 179:16,23 130:24 131:2,4,20,24 138:4,24 139:25 146:23 Street [2o] 2:23 4:18 5:12 short[4] 11:21 73:5 170:11 149:11 150:17 151:6 6:8 52:11 53:11 55:6 63:8 surfaces[21 101:11 145:23 161:6 soft[i] 114:17 156:2 161:16 63:19 68:5 70:22 74:1 105:16 shorterp[] 96:8 soil[4] 82:11,21 172:15 spectra 1[1 127:18 91:7 120:12 133:20,24 surprise [21 128:23 134:2,18 139:2 184:10 129:13 shorthand [3] 4:20 181:5 173:4 spectrometry [1] 3:6 181:10 strict [1] 142:20 surprised [2] 129:2,16 soils [2] 144:17,18 speculation [10o 56:9 show [131 48:6 52:24 sold 1J1 61:12 63:21 71:18 82:23 121:19 strike [141 55:13 82:8 surrounding 11) 34:11 57:19 58:23 64:9 66:13 88:14,15 96:9 115:24 solemnity t[1 9:4 144:9 145:17 153:18 survey [163] 2:17 22:25 75:9 89:20,22 113:14 154:21 172:18 120:20 125:23 131:10 35:2,9 42:16,18,19 44:21 119:7 126:11 128:15 solid [1] 145:5 135:11 165:1 speedometer [1] 58:20 132:16 45:3,7 46:16,17,19 47:1,5 showed[4] 63:17 148:4 solids [11 13:10 171:17 173:9 47:22 48:6,8,25 49:6,25 spell[2] 18:21 19:3 152:2 179:24 soluble [11 145:7 stringent [2] 158:22,23 50:10 51:5,6,7,9 52:1,16 spills [p] 74:19 showing [31 35:6 122:19 Solutions [1] 6:5 structure [2] 177:12,20 52:17 55:25 57:8 64:3 168:20 spoke [i1 148:25 65:24,25 66:14 67:5 70:22 solvent [3] 144:24 145:3 structures [1] 152:14 71:8,15 72:13 74:5,5,10 shown [4] 69:16 71:22 145:7 square [14] 54:18,22 73:6 studies [3] 16:14 79:7,10 107:24 121:14 92:24 93:1 104:11,12,23 74:16 82:10 83:1,5,9,12 solvents [1] 144:18 subgrade [1] 152:25 83:17,18 85:15 86:25 87:3 shows [7] 58:14 115:2 105:5,8,10,12,14 112:18 someone [51 20:6 87:6 87:4 88:12,13,18,22 89:15 119:19 120:11 123:12,19 squares [2] 105:3,3 subject [21 16:17 20:15 116:11 137:21 175:2 89:17,21 90:4,5,7,8,11,16 126:14 staff [2] 21:8,25 subjected [21 16:13 17:7 Sometimes [ij 32:4 90:22 92:5,10,15 93:11 side [131 69:25 70:1,2,5,9 stamp [412:13 59:18,24 subjecting [11]16:14 94:3,19 95:2,8 96:1 97:3 somewhat [1] 77:6 70:14,15,18,19 96:5 80:22 submitted [41 42:21 97:17,19,21 98:6,10,23 108:24 134:25 143:13 Somewhere [1] 8:24 stand [2157:16 169:18 50:18,23,25 102:25 103:13 104:25 108:10,25 111:7,11,13 sides [1] 101:14 sorry [lo] 11:24 15:22 Standard [1] 12:23 subpoena [3] 3:20 sign [1i 184:12 36:25 79:19 84:9 116:24 146:16,24 112:8,9,16 113:3,4,7 119:21,21 121:8 170:17 standards [191 132:17 115:6,19,23 117:11 118:7 signature [4] 49:1 132:20 139:5,9,24 142:18 Subscribed [lu 180:20 11:25 26:7 118:12,13 123:1 124:11 180:25 182:2 183:1 sort[14] 10:18 146:10 166:16,18,22 Subsection [1] 76:5 49:13 58:18 59:18 67:25 124:15 125:14 129:1,5,6 signed [51 130:9 136:15 167:15,18 168:1,5,11,13 92:24 95:24 99:4 110:9 subsequent [1] 106:3 129:7 132:4,12,15,17,24 182:3 183:2 184:13 168:14,19 169:3 133:4,7,23 134:2 139:23 Index Page 13 Combs & Greenley, Inc. (415) 512-1234 Raymond F. Fish, Jr. surveyed - utilized October 12, 1999 140:2,6,19,22 147:10,13 terminology p]1 29:6 tie [11 128:7 trip [21 140:2,6 understand [24] 9:5 10:3 147:14,16 149:16,18,20 terms [9] 14:20 29:7 70:8 tiles [21 147:21,21 tritium [2] 93:25 94:23 10:9,12,18,23 27:25 30:6 149:24 150:25 151:14,14 81:10 82:6 85:21 101:20 30:9 32:2 56:10,12 62:21 tiling [1] 147:24 true [1s1 91:21 108:24 72:8 79:18 80:11 89:10 152:3,12,21 153:15,21,23 130:16 165:9 119:3 131:20 145:10 155:10,18 162:9,16,23 times [o1 8:12 51:15 91:16 105:9 120:19 tertiary [11 16:19 57:25 58:1,7 85:5 97:7 153:1 156:22 162:16,21 132:21 138:20 142:24 164:7,8,10 168:20 171:15 163:2 166:2 170:7 177:4 172:24,25 173:5,7 174:5 test [s] 18:12 35:11,18 161:2,4 176:4 143:1 106:24 107:6 178:5,20 180:20 182:6 174:13,21 178:3 tissue [S5 81:19,20,24 183:5 understood [1] 65:5 tested [41 105:18 107:2 82:4,7 surveyed [91 105:16 truth[3 181:7,7,7 unit[2] 170:14 175:21 111:9 112:25 147:11,13 107:22,23 title [31 2:18 15:19 75:15 try [10] 7:10 9:18,22,25 United [51 1:2 2:10 4:2 147:16 151:10 152:18 testified [141 4:25 8:8,9 toad [11 34:14 5:24 79:9 8:12,22 16:6 29:12 36:17 10:5,11,21 11:23 56:11 173:23 today [3sl 6:3,23 7:11,18 80:11 89:7 133:8 152:11 88:1 units [2] 18:6 80:16 surveying [7] 139:25 7:19 9:3,8,17 10:10,21,25 154:1,2,4,7,8,12 152:23 173:18 trying [s5 58:19 79:21 universities [1] 21:3 11:4 54:25 64:5 75:23 89:4 138:20 170:19 surveys [36] 3:4 45:6 testify [1] 11:7 99:16 102:10 114:12 University 121 11:16 46:22 48:4 49:9 56:1 testimony [221 7:11,17 122:8 132:2 134:13 tube [33] 65:25 66:3 67:25 22:14 71:19 108:12,13,16,23 7:19 8:25 9:10,12,15,18 135:21 139:11 146:25 68:3,6,7,11,16,17,18,25 unless [2] 87:25 144:11 111:15 113:8 124:6,9 9:25 10:1 11:4 31:25 77:3 147:7,8 149:5,23 151:8 69:10,13,16,20,24 70:3,5 unrestricted [221 3:18 125:21,22 132:5,5,9,10 138:21 139:14 151:13 152:2,23 154:5,14 157:11 70:7,14,15,16,19 84:4 44:14 45:13,24 46:12 132:11,18 133:1,3,7,13 156:5,13 163:15 181:11 158:2 159:20 180:7,11 98:14,15 111:17 113:5 47:16,19 52:6,9 56:17 131:6,23 165:8,13,16 134:21 140:16 142:2,6 182:5 183:4 Today's [1] 6:1 76:3,9,20 78:17 87:15 [11 4:16 149:4,7 150:20 154:16,18 testing[31 14:17 58:13 together[21 79:7 135:25 Tuesday 108:21 132:7,14 133:5 turn[2J 127:9 134:15 142:19 151:2 153:6 suspect p] 162:4 70:17 too [2] 44:7 100:17 swear [1) 6:25 tests [11 82:17 twice [51 8:14 120:18 unsealed [2] 144:12,17 took [261 12:7 21:24 26:8 121:13 176:12,13 swipes [11 73:6 Thank [6] 7:20 19:9 33:15 72:21 86:17 89:23 unusual [1] 175:1 switch [31 58:6,11,15 27:11 169:5 180:11 90:4,4 104:7 105:19,21 two [201 21:10 25:4,21 Up[33] 23:12 31:12 32:17 184:17 26:3,8 30:16 36:13 37:20 Sworn [3I 4:25 7:2 181:6 109:23,25 112:2 122:25 32:21 33:6 37:20 40:22 thereafterpi[ 181:12 148:3 149:6 151:2,7 39:19 57:14 67:7,8 72:23 43:20 44:10 84:3,13 93:7 system[2] 18:8 176:7 85:10 90:12 131:23 therefore [ij 164:12 171:11 174:7,14,24 93:12,25 104:20,24 105:9 178:14,17 134:22 136:10 138:12 108:5 114:1 131:6,9,11 therein[1] 181:11 149:8 top [141 28:14,16 59:6 131:14,22,24 143:23 thereof [1 4:17 two-week [1] 26:2 153:22 161:16 164:23 table [131 3:7,9 67:9 123:8 64:18,20 67:7,12 75:16 thereon [1] 39:8 79:9 110:5 112:5 134:17 type[171 15:2 17:21 18:11 168:14 172:6 175:18 123:9,11 126:6,9 143:7 178:2 143:18,19,19,22 thereto [1] 181:19 141:1 143:17 19:1 23:9 28:3,11 32:18 66:24 68:4 93:22 122:17 upper[41 56:17 60:14 tables [11 143:11 They've [i] 147:8 topic [1] 74:5 34:7 149:10 155:19,23 158:10 91:11 165:10 takes [1] 21:19 thickness [4] 68:21 69:4 total [51 13:10 29:20 176:8 69:9 165:8 143:19,23 uranium[41 13:13 14:7 taking [7] 6:7 9:10 16:9 types [ig] 12:13 14:8 15:2 21:18 23:10 32:21 47:9 72:12 178:6 thin[4] 28:8,14,18 161:15 totally [3] 104:21 105:2 105:16 17:14 25:24 27:15,21,24 urine [2] 13:12,15 talks [1] 81:16 third [5]55:15 60:25 97:7 28:3,5,9 30:21 34:5 37:14 103:5,7 tough f1] 74:21 used [931 9:16 17:15 18:1 tape [2] 74:22 145:22 46:21 132:18 138:12 18:4 22:24 23:9 27:20 thirty [11 184:12 toward [11 123:15 175:9,13 technicians [1] 21:10 28:15 29:7 30:23,25 31:13 Thompson [1] 2:21 trained [2]17:18 28:1 typewriting [1 181:13 technique [2] 32:14 31:20 32:12,18 33:7 35:11 172:11 Thomson [10o 1:6,6 4:6 training [241 14:16 17:4 typical [31 17:21 23:8 35:14,15 52:9 53:11 54:5 4:6 5:24 6:16 118:24 17:6,11,13 21:4,20,23 168:20 54:22 55:10,20 56:7 57:14 techniques [3132:24 148:19,21 184:4 22:2,4,6 25:17,20 26:15 typically [161 18:6 27:19 58:2 63:18 64:5 65:5,23 36:1 172:9 27:13 29:12 30:1 31:2,5,7 65:25 66:16,24 67:3,5,10 61:9 thorium[19] 112:19 28:22 30:16 32:18 43:19 telegram[1] 155:1,6,14,24 156:1,2,24 35:1,4,17,19 50:16 52:7 53:15 54:18 67:12,14,16,18,22 68:4,5 telephone [11 136:12 158:13,18,19 163:4,5,6,9 transcribing [11 9:11 55:11,20 56:1 72:24 73:4 68:19,22 69:12,14,24 telling [1] 35:5 163:12,16,21,21 84:6 70:11,21 71:14 72:20,24 transcript [3] 184:7,16 73:4 77:20,25 89:19 92:19 temperature [1] 20:14 thorium-230 141 163:3 184:23 163:13,19,20 105:7 111:12 116:1 ten [31 99:8 113:24 142:6 transfer [21 76:8 85:11 -U 118:12,15 129:20 131:6 thorium-232 ij! 163:8 tend [31 144:15,15 179:11 transferred[11 148:7 U.S [1i6 61:12,14 62:12 131:15 132:25 137:1,23 tended [11 179:3 thorough [4] 108:19,20 transfers [i 84:7 62:16 137:11,13,22 138:5 141:7,13,18,24,25 142:15 108:25 109:3 149:16,25 150:10,15 142:17,18 147:15 155:1 tends [1] 60:7 transmit[41 48:11 49:18 155:21 156:17 162:22 thoroughness [I1 90:16 49:22 115:22 155:2 166:15 178:22,23 tenth[2j 57:11 120:3 164:22 170:20,23,24 three ['1] 19:13,16 25:4 tenths [1]18:9 transmits [i1 68:13 ultimately [11 43:20 171:24 172:11 173:21 25:21 26:8 39:4 61:1 term [1] 81:16 transmittal [a1 48:9,13 Um-hum [41 59:23 176:7 184:13 71:21 93:1 124:18 177:20 113:22 115:1 140:13 terminate [61 8:18 44:12 49:1,2,5,13,15 116:13 uses [2] 22:5 170:10 three-legged [1] 34:14 transmitted [sl 42:24 unclear[1j 106:14 46:2,10 51:17 86:7 through [21] 2:19 10:25 using[1B 18:8 22:21 terminated [il1 43:1 44:22 115:19 116:25 under[141 8:25 16:21,25 32:16,25 33:2,3 47:4,5 28:17,18 37:17 39:7 41:20 117:6 22:14 33:12 86:21 113:23 48:14,18 51:25 52:8 87:14 54:8 73:7,8 118:10 121:16 47:13 61:23 66:15 74:12 transmitting [21 116:9 127:11 169:13 174:2 123:22 131:23 137:22 87:23 117:16,19,25 118:4 75:17 78:18 79:25 92:8 116:18 180:19 181:13 182:4 159:11,17 terminating [s1 53:12 93:2 119:9 135:20 168:22 183:3 82:11 90:8 133:4,14 172:6,22 treatp[1 82:5 utilize [51 22:25 79:13 trial [21 8:8 9:16 underneath [f3 64:24 156:10 161:19 162:24 termination [41 3:18 throughoutpii 111:14 91:16 129:18 45:18 52:3 142:20 thumb [1] 168:22 trick [11 89:4 utilized[,1 126:17 156:6 Index Page 14 Combs & Greenley, Inc. (415) 512-1234 Ruymond F. Fish, Jr. Vacating - zero October 12, 1999 '1 159:9,13 161:22 166:24 waters[1] 34:21 116:3,7 Y 169:20,25 170:25 waves [1] 30:13 written [3] 31:12 42:21 ways [2] 32:25 104:24 91:22 115:15 148:4,6 -V 149:17 175:18 wear[1] 71:7 wrong [2] 138:16 163:16 Vacating [1] 64:21 West [ii] 2:23 52:11 61:8 61:18 62:14 63:5,25 79:22 Vaden [31 61:10,20 62:8 -X 79:25 vague[7] 10:19 31:17,18 134:17 139:2 32:5 142:23 144:8 145:16 whatsoever [11 129:9 X[21 2:1 81:14 Vallecitos [1 37:13 whole p7j 70:18 93:3 valuation ['] 30:8 96:14 98:21,23 104:16 -y 181:7 value [31 71:22 120:18 wide-ranging [1] 14:5 year [91 77:21,22 78:3,5 120:19 176:4,12,13,17,19 William values [21 83:22 158:15 [1l 39:17 Wilshire [ii5:2 years [7] 10:23 19:13,16 variety[i] 163:10 40:12 120:5 160:15 wind [1] 43:20 various [121 2:17 15:2 176:12 16:9 25:23 27:20 32:25 window [221 28:8 68:16 yellow[11 119:18 38:16 66:14 79:15 123:12 68:19,21 69:1,4,13,18,22 Yep[1] 112:6 126:12 167:20 69:25 70:1,2,2,9,10,13,15 York[2l 1:11 4:11 vents [51 147:11,12 154:1 92:20 113:5,7,8 161:15 154:3,3 wipe [5o] 35:18,21 36:8 Young [31 39:18 40:13 47:10,12,15 54:13,15,15 40:14 verbal [Il 90:2 72:12,15,25 73:2,3,4,7,8 yourself [41 14:13 73:18 verify [1] 149:18 73:9,20,22 85:20,21 89:23 73:23 83:15 versus [2] 5:24 31:20 90:22 93:18,22,24 104:3 yourselves p] 6:11 video [271 5:22 6:2,3,4,7 104:8 105:4,7,10,17,21 6:23 7:3 41:11,14 66:7,10 106:21 109:15,16,20 -z 74:24 75:5 121:22,25 111:24,25 112:2 143:25 126:22,25 135:14,17 148:2 150:4 156:23 157:1 Zeigler[6] 1:23 4:19 6:24 145:25 146:4,6 148:11,14 157:5,7 178:6,12 181:4,25 184:21 167:4,7 180:12 wipes [a] 46:23 54:3 zero [4] 165:14,14,15,18 Videotape [61 5:22 72:20 104:12,16 147:17 74:25 75:5 146:1,5 180:13 148:5 157:14 violated [i1 144:12 wiping [11 143:22 Virginia [41 1:6 4:6 6:15 wire [3] 68:11,14 84:3 148:19 wish 121 184:15,15 virtuallyr[i 151:10 wished [1] 44:12 visit [11 51:9 103:4,5,6,7 within [121 23:15,17 115:15,16 152:7 24:11 38:17 48:21,23 visits [2] 115:15 149:9 55:23 86:20 96:22 97:13 voice[1] 6:10 134:21 184:13 Volume [11 1:21 within-entitled [1) 181:8 VS[31 1:8 4:8 184:4 witness [45] 4:23 7:1,2 18:23 19:1,5,7 32:7 55:15 -w-W 63:22 66:23 67:15 71:19 W[1] 39:15 77:4 81:2 82:24 87:22 89:5,11 96:11 97:2 103:16 wait [2] 9:20,22 106:12,17,19 129:23 walked[i] 111:20 130:11,15 132:24 143:3 wall [2] 77:16 115:2 144:10,23 145:3,19 walls [141 93:15,17 94:11 151:14 153:19 154:23 94:18 97:23 99:11 128:21 156:16 168:21 172:19 128:25 129:4,15,17,21,23 174:20 175:6 180:25 165:8 181:5,12 warrant [1] 149:12 Woodbe [11 40:21 wash [1] 32:17 word][3 30:14 91:17 110:24 Washington [11 40:22 words [sj 18:5 77:21 waste [1] 155:5 89:23 177:8 178:23 wastes [3] 24:16 41:5 worked [91 15:9 22:9 42:1 36:12 61:25 62:2,3,6,8 watch [11 98:18 96:4 watching [1 93:5 workers [41 76:21 80:2,7 water[ll 13:10,10 97:20 100:19 98:7,8 100:3,4 144:14,14 works [2] 28:18 68:10 179:4,5 writing [4144:25 45:1 .1. I 1.j Index Page 15 Combs & Greenlev, Inc. (415) 512-1234 Raymond F. Fish, Jr. 10-12-99

EXHIBITS MARKED FOR IDENTIFICATION CONTINUED No. Description Page THE UNITED STATES DISTRICT COURT IN marked by Rhone-Poulenc: CENTlRAL DISTRICT OF CALIFORNIA Exhibits 23 Letter to Eugene V. Kleber at Research 257 Chemicals. Inc. from Kber Price JOSEPH A. THOMSON and VIRGINIA dated May 18, 1961. Bates-stamped THOMSON, as individuals, RP00015 to 00016.

Plaintiffs, 24 Letter to Fred E. Nathanson from Kber .259 dated August 29, 1961. vs. )No. CV-97-5220 RAP Price Bates-stamped RP 00018. ICN PHARMACEUTICALS, INC., a Delaware corporation; NUCOR CORPORATION, a Delaware corporation; RHONE-POULENC, INC.,) a New York corporation,

DefendanL )

DEPOSITIONOF RAYMOND F. FISH, JR.

November 8,1999 Volume H (Pages 182 - 290)

REPORTED BY: JULIE ANNE ZEIGLER, CSR 9570 JOB 85447

182 184 i 1 I INDEX 2 2 IN THE UNITED STATES DISTRICT COURT 3 CENTRAL DISTRICT OF CALIFORNIA 3 INDEX OF EXAMINATION 4 -a0o 4 Page 5 .-.. 187 5 FURTHER EXAMINATION BY MS. McKErIH 6 JOSEPH A. THOMSON and VIRGINIA ...... 226 6 EXAMINATION BY MR. SHIMADA THOMSON, as individuals, 7 EXAMINATIONBY MR. BROWN ...... 249, 283 7 8 FURTHER EXAMINATION BY MR. PATIERSON .. 262, 283 Plaintiffs, 9 FURTHER EXAMINATION BY MS. McKEITH .285 8 10 vs. )No. CV-97-5220 RAP 11 EXHIBITS MARKED FOR IDENTIFICATION 9 12 No. Description Page ICN PHARMACEUTICALS. INC, a 13 Plaintiffs Exhibits marked: 10 Delaware corporation, NUCOR 14 18 Document entitled"AtachmentG . 202 CORPORATION, a Delaware continued Facilities and Equipment 11 corporauon RHONE-PRULENC, INC.,) 15 continued." Bates-stamped 000305 a New York corporation, and 309 to 316. 12 16 Defendants. 19 Document entitled "Compliance Report" .210 13 17 stanped "Copy." 18 20 Letter to Mr. ames Mason from J.D. .- 215 14 -aOO Vaden dated Januaty 19, 1961 on the 15 BE IT REMEMBERED that, pursuant to Notice, 19 letterhead of Nuclear Corporation 16 and on Monday, November 8,1999, commencing at 12:53 of America. 17 p.m. thereof, at Lewis, D'Amato, Brisbois & Bisgaard 20 18 LLTP, One Sansome Street, 14th Floor, San Francisco, 21 A draft dtcumnent to Mr. Goldstein from 219 19 California, before me,JULIE ANNE ZEIGLER, a Certified 21 Mason dated 9W2something/58. 20 Shorthand Reporter, personally appeared 22 Exhibits marked by Nucor Corporaton: 21 RAYMOND F. FISH, JR. 23 22 Letter to Raymond FLsh, Jr. from . 245 22 Daniel Fresquez dated September 27, 23 called as a witness by the Defendant ICN 24 1999. 24 Paarnmaceuticals, Inc, who, having been first duly 25 N/III 25 swon, was examined and testified as follows:

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1 -oOo 1 release criteria were. 2 LOEB & LOEB LLP. 1000 Wilshire Boulevard. 2 Q. Do you know whether Isotopes Specialties 3 Suite 1800, Los Angeles. California 90017-2475. 3 Corporation was permitted to bury any radioactive 4 represented by MALISSA HATHAWAY McKEH'H. Attorney at 4 materials on the property? 5 Law, appeared as counsel on behalf of the Plaintiffs. 5 A. There were in the regulations requirements 6 PROSKAUER ROSE LLP. 2049 Century Park East. 6 allowing under certain circumstances provisions for 7 Suite 3200. Los Angeles. California 90067-3206 7 burying radioactive wastes. 8 represented by GREGORY J. PATTERSON. Attorney at Law, 8 Q. My question was: Do you know whether 9 appeared as counsel on behalf of Defendant ICN 9 Isotopes Specialties Company was permitted to bury any 10 Pharmaceuticals, Inc. 10 radioactive wastes or materials on the property? 11 LEWIS. D'AMATO. BRISBOIS & BISGAARD LLP. 11 A. The answer is no. 12 221 North Figueroa Street, Suite 1200, Los Angeles, 12 Q. Is that no, you don't recall, or no, they 13 California 90012 represented by JOHN H. SHIMADA. 13 weren't permitted? 14 Attorney at Law, appeared as counsel on behalf of 14 A. Will you repeat that? 15 Defendant Nucor Corporation. 15 Q. Do you recall one way or the other whether 16 McCUTCHEN, DOYLE, BROWN & ENERSEN, LLP, 355 16 they were permitted to bury any radioactive materials 17 S. Grand Avenue, Suite 4400. Los Angeles. California 17 on the property as part of this release and/or 18 90071 represented by BRYAN K. BROWN. Attorney at Law, 18 decommissioning? 19 appeased as counsel of behalf of Defendant 19 A. No, I donit remember. 20 Rhone-Poulenc. Inc. 20 Q. Did you take any steps as part of your 21 21 survey in connection with the decommissioning to 22 VIDEO OPERATOR: Here begins Videotape No. 22 determine if they had, in fact, buried any radioactive 23 4 in the deposition of Raymond Fish. Today's date is 23 materials on the property? 24 November 8th. 1999. The time on the video monitor is 24 A. To the extent that I reviewed what was in 25 12:53. The video operator today is Stephen Statler 25 our file, which would have included any reports that

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1 employed by Video Solutions, a Legalink company, of 1 they made of releases or similar actions that were in 2 San Francisco, California. 2 violation of the regulations or that were identified 3 All those who were present at the October 3 in previous inspection reports, to that extent, the 4 12th session are present today. Please begin 4 answer is yes, but no other extent. That is, the 5 FURTHER EXAMINATION BY MS. McKErrH 5 survey itself did not 6 MS. McKErrH: Q. Good moming, Mr. Fish. 6 Q. So if as part of the decommissioning of the 7 You may recall that I represent Joseph and Virginia 7 its site or the closedown of its site, Isotopes 8 Thomson. the individuals who purchased the Providencia 8 Specialties Company had buried radioactive materials 9 property in the mid- 1960s after it was decommissioned. 9 and had not told the Atomic Energy Commission, you did 10 rm going to continue the questioning from our last 10 not take any independent action to determine - one 11 sessions. 11 way or the other to determine if there was any buried 12 The first question [ have is: Would it 12 waste on that site? 13 have been unlawful for Isotopes Specialties 13 A. No. My confirmatory survey did not get 14 Corporation to bury radioactive source materials on 14 into that type of an action. 15 its property prior to the decommissioning? 15 Q. Prior to the time that you conducted the 16 A. I don't really know the answer to that 16 decommissioning at Providencia site, did you work on 17 You would have to get into the Office of General 17 any site where, in fhct, the Atomic Energy Commission 18 Counsel to get an answer to that one. 18 permitted the burial of radioactive materials? 19 Q. You testified earlier that you were 19 A. I don't recall that I personally was 20 involved in the decommissioning of the property and 20 involved in such inspection activities. 21 had received instructions from Maryland as to what the 21 Q. Do you know what the criteria was for the 22 limits of the decommissioning would be; is that 22 Atomic Energy Comnmission deciding whether to permit 23 correct? 23 the burial of radioactive waste on a site? 24 A. I was involved in the confirmatory strvey, 24 A. Only in general terms do I remember the 25 and the people in Bethesda had informed us of what the 25 provisions in the regulations for burial on a

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licensee's site, but I wouldn't want - rm not sure 1 Q. My question was posed in the context of a 1 2 whether there were differentiations 2 enough to be able to get into the specifics of it. decommissioning, 3 the decommissioning of a licensee site that 3 Q. Could you just tell us what your general between 4 located in a residential area such as Providencia 4 recollection is today? was 5 versus an installation such as Hanford, for example. 5 A. My general recollection today is that it 6 A. No, the criteria would be the same for 6 had - there were limitations on what could be buried 7 release. 7 and there were limitations on the burial that could 8 In 1961, approximately, was there a 8 occur being a depth restriction and a separation Q. for sampling soil to determine 9 restriction from one burial to another. 9 methodology available contamination in soil? 10 Q. And under what circumstances other than the 10 if there was radioactive 11 A. Yes, there was a means of sampling soil. 11 limitations that were placed on someone for, in fact, 12 Q. Can you tell me what that sampling 12 burying wastes, under what circumstances would the was? 13 Atomic Energy Commission permit burial as opposed to 13 methodology 14 A. Well sampling that I got involved in would 14 cleanup? And by cleanup, I mean removal and taking - the ones I was 15 off site. 15 be taking soils - we were primarily were primarily surface soils so it wasn't 16 A. rm not sure I remember. 16 involved in So we would take samples from the 17 Q. I previously asked whether or not you 17 like taking a core. We would use a shovel and collect 18 personally had been involved in the decommissioning of 18 top of the earth. 19 and then have it analyzed. 19 a site that involved the burial of waste; am I correct the sample type of analytical methodology in 20 your answer to that was no? 20 Q. And what was used on those types 21 A. That's true. 21 the laboratory, if you know, 22 Q. Subsequent to the Providencia site, were 22 of samples? Well first thing they would do would be to 23 you involved in any of the decommissioning that 23 A. water pmblem, any interference 24 involved the burial of the radioactive waste at any 24 try to eliminate the 25 water. They would then, probably, do a gross 25 time in your career at the Atomic Energy Commission? from

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1 A. Not that I can remember. 1 count on the sample. And depending upon what they do an isotopic analysis. 2 Q. Now you have an amazingly good memory fix 2 were looking for, they might tests on the 3 things that happened 30 years ago. If you had been 3 Q. Did you conduct any such 4 involved, do you think you would remember if you had, 4 Providencia property? No. 5 in fact, been at a site where there was burial of 5 A. such tests on 6 waste? 6 Q. Why did you not conduct any 7 A. rm not sure I would or not The only 7 the Providencia property? the surfaces were all - were in 8 thing I do remember is that there were licensees that 8 A. Because violation of those 9 had done such activities within the area of the 9 place, and I was not aware of any of the 10 region, and that's all I remember. 10 surfaces. So if you don't have a violation 11 Q. Do you recall whether the Atomic Energy 11 surface, you can't get down below. of the 12 Commission differentiated between sites that were 12 Q. What do you mean by a violation 13 located in a residential neighborhood such as the 13 surface? to the extent that 14 Providencia site versus a nonresidential area such as, 14 A. A crack or deterioration 15 lees say, Hanford in Washington, which was a large 15 the underneath is exposed. sit here today, 16 installation? 16 Q. You actually recall as you yard of the 17 A. There would been different restrictions on 17 whether the asphalt paving in the rear no cracks in it? 18 what could take place in a site like Providencia 18 Providencia property had 19 versus a site like Hanford. 19 A. No, I do not remember. the 20 Q. Can you describe for us generally what 20 Q. Was there a methodology available in whether or not concrete 21 those different restrictions would be? 21 1960s, early 1960s, to sample 22 A. Yeah, there would be more restrictive use 22 material was contaminated? a part of the concrete 23 of the quantities and the types of isotopes that could 23 A. You mean taking 24 be used, primarily quantities more than anything else, 24 and the 25 but it would be - that would be the differentiation. 25 Q. Thas correct. A chip or a section of 191 193

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1 concrete and analyzing it 1 equipment was available or not? 2 A. Fm sure ther were ways of doing it, sure. 2 A. Yes. you did 3 Q. Well, I dondt want you to guess. Do you 3 Q. Can you tell me what, if anything, at the Providencia site 4 recall if there was a methodology for doing that? 4 to detect alpha contamination of your decommissioning? 5 A. Since I didn't get involved in the analysis 5 as part the wipe samples for alpha 6 of those types of samples, I guess the answer is I 6 A. Yes, I counted 7 don't know. 7 contamination. wipe sample you took 8 Q. Before I move on, prior to the Providencia 8 Q. Did you count every or only in the areas where you 9 decommissioning, had you conducted soil samples at any 9 for alpha contamination could be some alpha contamination? 10 of the other sites that you had been involved in 10 suspected there were counted for alpha 11 decommissioning, either directly or as part of your 11 A. All of them standard for 12 office? 12 Q. Was there a particular cleanup 196 1? 13 A. I don't really remember. 13 alpha contamination in approximately the specific numbers. 14 Q. Subsequent to Providencia, do you recall 14 A. I don't remember have differed from the cleanup 15 whether you conducted any deoimmissionings that 15 Q. Would they 16 involved the sampling of soil? 16 criteria that was in the letter that had been sent to with 17 A. I guess I don't even remember that with 17 Isotopes Specialties Corporation in connection I would be happy to show 18 respect to decommissioning. 18 the Main Street facility? need it 19 Q. What about with respect to - well, under 19 you a copy of that letter again if you 20 what other circumstances would the Atomic Energy 20 A. The only answer I can give you is that limits 21 Commission have been involved with conducting soil 21 alpha contamination limits were lower than the 22 samples at a facility? 22 for beta gamma. 23 A. Well, if there was an accident or a release 23 Q. I believe that this letter has already been 24 of activity from a facility, we would then take soil 24 marked as - rm referring to the - this is a letter Mr. Price. 25 samples to see the extent of the release of the 25 from Mr. Michaud to - excuse me, from

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1 activity. 1 MR. PATIERSON: Exhibit 1. 2 Q. You testified at length at our last 2 MS. McKErrH: Q. Exhibit 1. Okay. rm 3 deposition about the use of the Geiger-Muller to 3 going to go ahead and show you this letter again so we 4 detect surface contamination at the site. Do you 4 can go through it together. Do counsel need another 5 recall that? 5 copy of this letter? 6 A. Yes, I do. 6 Calling your attention to Item 2, "the 7 Q. Was the Geiger-Muller the state of the art 7 radiation level at three inches from the surface of 8 equipment at that time for detecting beta and gamma 8 the floor and walls shall not exceed two millirems in 9 rays or was there better equipment available in the 9 any one hour." Do you recall whether the cleanup 10 early 1960s? 10 criteria for alpha contamination would have differed 11 A. Well, I guess you would describe it as the 11 from that? 12 instrument that was used for most of the work as 12 A. The alpha requirement would not have been 13 opposed to a research-type instrument or an instrument 13 in the form of a radiation level, which is what this 14 that would be used for a very sophisticated 14 is, two millirem in any one hour is a radiation leveL 15 requirement 15 The alpha would have been in the form of a removable 16 Q. My question was: Was there better 16 contamination, which would typically be in 17 equipment available to conduct a survey at a site for 17 disintegrations per minute. 18 the detection of beta and gamma radiation in the early 18 Q. Do you know or see anything in this 19 1960s? 19 correspondence that refers to disintegrations per 20 MR. PATIERSON: Objection; vague. 20 minute and providing any alpha criteria? 21 MR. SHIMADA: Lacks foundation. 21 A. Item No. 1covers that. 22 THE WITNESS: I don't remember - because 22 Q. What do you interpret - could you read No. 23 of a time problem, I don't remember. 23 I for us, first of all? 24 MS. McKErrH: Q. So what you don' have 24 A. Sure. No. 1 says, "The radioactive 25 is a way is to place in time whether or not that 25 contamination must not be readily removable from the

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Combs & Greenley, A LegaLink Company (415) 512-1234 4 (Pages 194 to 197) Raymond F. Fish, Jr. 10-12-99 I 1 property." 1 contamination? amount of 2 Q. If there was alpha contamination in the 2 A. That's dependent upon the 3 soil, would you have considered that readily removable 3 activity that would be there and how much shielding detector. 4 from the property? 4 was between the radioactive material and my 5 MR. PATTERSON: Objection; vague. 5 Q. You had testified in your last deposition 6 MS. McKElTH: Q. Do you understand what 6 that concrete served as a shield for beta and gamma 7 rm asking? 7 rays. 8 A. Yeah, I understand what you're asking. I 8 A. That's true. for how 9 guess my answer is that that criteria No. 1 would not 9 Q. So could you tell us any guidelines 10 be applied to soil conditions. There would be a 10 much concrete it was required to shield? the question is 11 different requirement in there as it relates to soil. 11 MR. SHIMADA: Objection; 12 Q. Is there anything in this letter that 12 vague. 13 relates to soil conditions at all? 13 MS.McKEITH: Q. Do you understand my 14 A. Not specifically the soil. 14 question? 15 Q. Could you please explain to me your 15 A. I think I understand your question, and between 16 interpretation of Item 1 relative to the alpha 16 right now I can't tell you the relationship it 17 criteria for a release of nonrestricted use? 17 the thickness of concrete and the shielding 18 A. At this point in time, I don't remember the 18 provided. 19 numbers that were used to define readily removable, 19 Q. I believe you testified in connection with 20 but if that dealt with alpha, we would have had some 20 the swimming pool that if there had been contamination 21 kind of a number that we would be using to define 21 on the other side of the wall of the swimming pool. 22 readily removable, but I don't remember what the 22 you did not believe that your Geiger-Muller would pick 23 number is. 23 up on that contamination. Do you recall that? 24 Q. Do you really remember one way or the 24 A. Yeah, I remember saying that it would be activity 25 other, as you sit here today, whether there was a 25 possible for that sidewalk to shield the 200 198 i

1 number that you applied? 1 depending upon how much was there. 2 A. No, I do not. 2 Q. You've had a lot of years with radioactive 3 Q. So as you sithere today, you don't recall 3 materials. If you have a foot of concrete, can you 4 one way or the other if there was even a number that 4 tell us in percentages approximately how much that likely to emit 5 the Atomic Energy Commission had designated for this 5 would reduce the levels that would be 6 site for alpha removal? 6 through that concrete? 7 A. I do not remember specifically any such 7 MR. SHIMADA: Objection 8 number. 8 THE WITNESS: At this point I just do not 9 Q. Now, the impression I get from reading this 9 remember. 10 letter-- and correct me if rm wrong - is that the 10 MR. SHIMADA: - lack of foundation, calls 11 Atomic Energy Commission was concerned about levels of 11 for speculation. 12 radiation that remained at the surface at certain 12 MS. McKEITH: Q. Just because I can't 13 distances from the surface of a floor of a building or 13 recall from the last deposition, did you personally 14 from a wall. And if your Geiger-Muller recorded a 14 count the wipe samples or were the wipe samples 15 level that was beneath whafs designated in this 15 reviewed by someone other than you? 16 letter, then there was no longer a concern on the part 16 A. I counted the samples. 17 of the Atomic Energy Commission; is that a fair 17 Q. You've testified earlier today that alpha 18 interpretation of this letter? 18 contamination would have had a lower cleanup level 19 A. The numbers were set Numbers such as are 19 than beta or gamma. Can you tell us why that is? 20 described in the letter are set with the intent of 20 A. Alpha is a - creates more damage 21 limiting the exposure of the general public who would 21 exposure to alpha creates more damage to the 22 occupy those aeas after the decontamination. 22 individual; however, that only occurs if it's 23 Q. And if there was contamination, for 23 internally deposited. And because of the - it 24 example, beneath the conante, would your equipment 24 being - creating more damage if internally deposited, 25 have necessarily picked up the levels of that 25 the limits are held to be lower.

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preventing the removal of more than the amount of Q. What do you mean by "internally deposited"? 1 10-12-99 1 RaymondF.Fish, Jr.2 cobalt 60 from the storage unit at any one time." 2 Taken inside the body. A. 3 Q. You testified earlier that when you went to 3 Q. How is alpha contamination taken inside of 4 the facility you do not remember any open holes in the 4 the body? What are the 5 floor of the facility other than the swimming pool. 5 can either be taken in orally through A. It 6 Between your last deposition and today, have you or breathed through the nose or, 6 the mouth 7 recalled whether or not there were any subgrade holes theoretically, it could go in through a cut in the 7 8 that were open at the facility? 8 skin. 9 A. No, I don' remember. 9 MS. McKEITH: rm going to mark next in 10 Q. In looking at document No. 000309, does 10 line - is it 24? 11 this document at all refresh your recollection as to 11 MR. PATTERSON: Eighteen. 12 whether there were any holes at the facility? And my 12 (Whereupon, Plaintiffs 13 recollection is that you had been to the facility when 13 Exhibit 18 was marked 14 Isotopes Specialties Corporation was operational, is 14 for identification.) 15 that correct? 15 MS. McKEITH: Q. I'm going to give you my 16 A. I said I didn't remember whether I had made 16 copy. When yon•e done, could you give this to the 17 inspections at the facility or not 17 court reporter, please. 18 Q. So you don't recall having made inspections 18 I'm going to represent to you that these 19 there? 19 were attached to the license application documents 20 A. No. I guess I should point out that what I 20 that Isotopes Specialties Corporation had provided to 21 read here on page 305 does not necessarily mean this 21 the Atomic Energy Commission. I believe you've 22 is a below-floor storage facility. 22 testified previously that you reviewed the file prior 23 Q. Let me ask you this: If they had had any 23 to doing the survey for the decommissioning; is that 24 below grade storage facilities at all -- assume for a 24 correct? 25 moment that were correct and they did have some below 25 A. Yes, I did. 202 204

Q. And as part of the file at that time, would 1 floor storage facilities in their hot labs, were they 1 2 permitted to close those below-grade storage 2 it have contained the license applications for 3 facilities before you conducted your decommissioning 3 Isotopes Specialties Corporation? 4 survey? 4 A. Yes, it would. 5 A. No. 5 Q. Drawing your attention to document Bates 6 Q. So if they had closed those before you got 6 Stamp 000309. There's a reference to ten storage 7 there, that would have not been permitted by the 7 and I believe if you turn back to the prior holes, 8 Atomic Energy Commission? 8 page, 000305, there's a reference to those storage 9 A. If you're asking a legal question 9 holes. 10 Q. No. rm asking you whether or not at the 10 A. What was the first reference page? 11 time, if you had known they had closed something, 11 Q. 305? 12 whether that would have been right or wrong? 12 A. 305 1have. What was the other one? 13 A. It would have been wrong. 13 Q. The next one in line, which is 000309? 14 Q. Okay. Thank you. 14 A. Yes. 15 MR- SHIMADA: Objection; lacks foundation, 15 Q. Do you want to go ahead and read that. 16 calls for a legal conclusion. 16 A. The highlighted portion? 17 MS. McKEITH: Q. rm going to draw your 17 Q. Yes, please. You can go ahead and read it 18 attention to document No. 00315. It's the second 18 out loud, please. 19 document to the end under "Storage Area." Can you go 19 A. "The primary storage unit for the facility 20 ahead and read that 20 is a cylindrical cast with a 4-inch cavity and 10-inch 21 A. The two highlighted areas? 21 lead shielding. The plug for the cavity contains nine 22 Q. Yes, please. 22 storage holes. Each of which is stopped by remotely 23 A. "The building contains an experimental 23 removable lead plug with storage shelves below the 24 animal irradiation facility. Low-level packaged 24 plug. The unit is designed for storage of 25 radioactive waste is stored here." 25 approximately 200 curies in each hole. This design 203 205

Combs & Greenley, A LegaLink Company (415) 512-1234 6 (Pages 202 to 205) Raymond F. Fish, Jr. 10-12-99 I site to do the survey, would that have been 1 Q. And under "Storage Area." Yes. 1 the 2 A. And then under "Storage Area" it says, "A 2 permitted? 3 fenced, locked storage area is provided at the rear of 3 MR. SHIMADA: Objection; lacks foundation, 4 the main building. In addition to open storage, a 15 4 calls for speculation. I guess the answer is 5 foot by 24 foot double wall concrete lined pit with 2 5 THE WITNESS: Well, We would 6 feet of sand between the walls is used." 6 the same. I mean, legally, I don't know. 7 Q. Do you recall seeing a 15 foot by 24 double 7 if we found out about it, we would be very upset and 8 walled concrete lined pit when you went to do your 8 would force them to open it up so that we could survey 9 decommissioning? 9 it. 10 A. No, I do notremember any such facility. 10 MS. McKEIH': Q. Do you recall whether Company 11 Q. Do you want to turn to the next page, 11 you asked anyone at Isotopes Specialties 12 000316. Do you see -- this is actually atdocument 12 whether they closed any subsurface features prior to 13 that was also attached to their license. It is a bad 13 your arrival? 14 copy like so many of the copies we received from the 14 A. At this time I do not remember. 15 Nuclear Regulatory Commission, made worse by the fact 15 Q. Drawing your attention to the swimming pool 16 that I copied it in my fax machine. Do you see where 16 for a moment, while Isotopes Specialties Corporation 17 it says "pit area"? 17 was operating, youYe aware of the fact that that pool 18 A. Yes, I do. 18 had water in it, correct? 19 Q. Do you recall any subgrade pit in that 19 A. Yes. 20 area? 20 Q. And you'e aware of the fact that that pool 21 A. No, I do not remember any such pit. 21 would have been contaminated with radioactive 22 Q. Do you recall any fenced-in area in the 22 materials - the water in the pool? 23 area thaIs marked "storage yard"? See the reference 23 A. Yes. 24 to the fence? 24 Q. Did you personally witness Isotopes 25 A. Yeah, I see the reference. No, Idon't 25 Specialties Company disposing of that swimming pool

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1 remember that. 1 water?. 2 Q. Now, are you aware of the fact that 2 A. No, I do not. 3 Isotopes Specialties Company received and repackaged 3 Q. Do you recall whether you reviewed any 4 waste from its customers at its facility? 4 documents to demonstrate that they properly disposed 5 A. As of today, I don't remember that. 5 of that water at a site licensed to receive such 6 Q. Had you known at the time that they 6 materials? 7 collected waste from their customers, would that have 7 A. At this time I do not remember. 8 made any difference in terms of a level of 8 Q. Would it have been part of your practice in 9 investigation you would have conducted in the outside 9 the early 1960s to require that they show you some 10 yard area of the facility? 10 documentation of that type? 11 MR. SHIMADA: Calls for speculation. 11 A. I guess I just don't remember whether we 12 MS. McKEITH: Q. You can answer it 12 would have or not. 13 A- It wouldnl have made any diflerence 13 Q. In connection with any other radioactive 14 because I would have made a thorough survey there. To 14 contamination materials that would have been generated 15 the extent that I was aware of that area the 15 during the decommissioning such as the chipping of the 16 evaluation would have been more thorough than just the 16 pool - you testified earlier that they had to chip 17 evaluation that was done on the driveway. 17 the sides of the pool because of the high levels of 18 Q. Now you testified at the last deposition as 18 contamination. That's correct, is it not? 19 to what you actually did in the backyard area. 19 A. Yes. High level being in excess of the 20 A. Yes. 20 release amount 21 Q. Do you recall whether you conducted a more 21 Q. Correct. Did you witness their packaging 22 thorough survey in that area? 22 of that material for purposes of disposal? 23 A. No, I don't recall it. 23 A. No, I did not. 24 Q. Had Isotopes Specialties Company covered 24 Q. Do you have any knowledge one way or the 25 over the pit with concrete prior to your arrival at 25 other whether that chipping, in fact, was disposed of

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properly? 1 seems like a lot for this particular type of license? 2 A. At this point in time, I do not. 2 A. Well two and a half tons is a lot of 3 MS. McKEITH: Exhibit 19. 3 material 4 (Whereupon, Plaintiffs 4 Q. You testified earlier that if someone has a 5 Exhibit 19 was marked 5 license to handle source materials, that they were 6 for identification.) 6 required to go through a decommissioning for release 7 MS. McKEITH: Q. Do you recognize this 7 for nonrestricted use when that license terminated; is 8 type of report? 8 that correct? 9 A. Yes, I do. 9 A. In this particular case, yes. 10 Q. Can you tell me what it is? 10 Q. And so decommissioning of the Research 11 A. Yeah, it's the results of an inspection 11 Chemical, Inc. facility would have taken place at some 12 that was conducted on October 16th, 1959. 12 point in time? 13 Q. My birth date, real birth date. 13 A. Yes. 14 A. And it's an initial inspection. 14 Q. Mr. Donaldson, the individual who conducted 15 Q. And what facility was that at? 15 the presurvey work prior to your decommissioning has 16 A. This is the - licensee is Research 16 been deposed in this case. Mr. Donaldson insists that 17 Chemicals. The address is 170 West Providencia Street 17 he never did any surveying at the Research Chemical 18 in Burbank, California, and the license is a source 18 facility. Do you recall doing a recommissioning for 19 material license. 19 the Research Chemical facility? 20 Q. And what on this document would indicate 20 A. Not specifically. 21 that this is a source material license? 21 Q. I want to turn your attention to the next 22 A. The license number and the type of material 22 page. Under paragraph 12 under "Facilities and 23 that was allowed to be possessed. It's a thorium 23 Equipment," it reads, "Most of the source materials, 24 source material. 24 approximately 4,300, pounds remains in the shipping 25 Q. Can you tell us how much thorium source 25 conmtiners" parentheses - I can't read how many

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1 material was permitted at the Research Chemical 1 barrels on my copy. Can you read that? 2 company?. 2 A. It looks like 20. 3 A. The license allowed them up to 5,000 pounds 3 Q. - "approximately 20 barrels, which are 4 of thorium source material 4 located in the fenced area in back of the building." 5 Q. Are you able to tell us approximately how 5 And just to reiterate, you previously testified you do 6 large a quantity of 5,000 pounds is by pointing to 6 not recall a fenced area in the back of the building 7 something in this room? 7 when you did your decommissioning? 8 A. No, rm not able to. 8 A. That's true. I don't remember. 9 Q. Is 5,000 pounds - you know, I think about 9 Q. Given the quantity of thorium materials 10 a ton. 10 that you see here today, was the wipe sampling you 11 A. Ifs two and a halftons. 11 conducted, in your own opinion, adequate to 12 Q. So this allows them to have two and a half 12 decommission the back portion of that site? 13 tons of thorium source material on site? 13 A. I can only state that the site - the wipe 14 A. That!s right. 14 samples were adequate to release the site for 15 Q. Relative to other facilities, is thata 15 unrestricted use. 16 lot? 16 Q. Can you recall the number of wipe samples 17 MR. BROWN: Objection; vague. 17 you would have taken on pavement in the backyard a 18 MR. SHIMADA: Lacks foundation. 18 of the site? You know what rm referring to? 19 MS. McKEITH: Its okay. 19 A. No, I dont 20 THE WITNESS: This is a significant amount 20 Q. You had discussed previously that you 21 of quantity for this type ofa license. There are 21 conducted a grid in the building where the operations 22 other source licenses where this would be a very small 22 were. 23 amount, but not for this one. It's a significant 23 A. Sort of a grid. Imean, youknow, it'sa 24 amount 24 matter of looking at one area and then moving to 25 MS. McKEITH: Q. What makes you say this 25 another area and moving to another until you basically

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to James Mason, Chief, Isotopes Branch. Division of 1 cover the whole area that was involved, and to that 1 2 Licensing and Regulation. This document reflects the 2 extent, it was a grid. 3 fact that 948 containers of radioactive waste were 3 Q. If you weren't aware of there being a 4 dumped in the ocean that had been previously been at 4 fenced area that had contained thorium materials in 5 the Providencia site. Can you tell me whether the 5 the backyard - well, let me strike that 6 Geiger-Muller that you used in the field and the wipe 6 Can you recall whether you conducted the 7 samples that you utilized would have identified the 7 same grid methodology in the paved area of the 8 type of contamination that would be generated by the 8 backyard or whether you took fewer samples outside? 9 types of radioactive materials that are identified on 9 A- I can't remember the details of that. 10 this list? 10 Q. You testified at the last deposition that 11 MR. SHIMADA: Objection; vague, lacks 11 you did sample the pipes inside of the building at the 12 foundation. 12 Providencia facility. 13 THE WITNESS: The Geiger-Muller tube would 13 A. The drains? 14 have detected some of them. 14 Q. The drains, right. 15 MS. McKEITH: Q. Can you tell us which of 15 A. Yes. 16 the chemicals identified on the Exhibit 20 were not 16 Q. Do you recall whether you had a schematic 17 susceptible to detection from the Geiger-Muller? 17 of the plumbing system at your disposal? 18 A- Polonium2l0isone. rm notsure about 18 A. No, I did not have a schematic. I was 19 the Thorium 232. It would not have detected the 19 looking at only what was there and measuning what was 20 Carbon 14. It would not have detected the Hydrogen 3. 20 there. 21 Those are the only ones I can identify. 21 Q. Approximately how many feet into any given 22 Q. Were the wipe samples that you conducted 22 pipe was your Geiger-Muller capable of detecting 23 capable of detecting the four types of contaminations 23 contamination? 24 that you've just identified - the Polonium 210 and 24 A. Well, assuming that the detector could get 25 Thorium 232 and Carbon 14 and Hydrogen 3? 25 in there, it was capable of going in 18 inches to two 214 216 + 1 A. It would have detected the polonium. The 1 feet 2 Thorium 232, 1 don't know what the radiation is on 2 Q. So if a pipe ran under a building for 25 or 3 that, but my guess is that it would have, because if 3 30 feet, and there was only one opening to that pipe, 4 it were an alpha emitter, it would have detected that 4 the maximum amount that that Geiger-Muller could 5 If it had beta gammas, it would have been detected. 5 detect would be approximately a foot and a half? 6 and Hydrogen 3 are both soft betas, and at 6 A. It's my guess. Carbon 14 7 point in time, I don't remember whether it would 7 Q. If a pipe had leaked at any given point in this 8 have been able to detect those soft betas. 8 time, would your Geiger-Muller have been capable of 9 Q. Can you tell me when you were doing the 9 detecting any contamination in soil underneath the 10 wipe samples, did you have to be looking for a certain 10 pipe that had leaked? 11 in order to identify it? rm 11 A. No, it wouldn't have detected the type of contamination 12 simply not aware of how the wipe sampling test works 12 contamination in the soil. 13 to know, for example, that the person doing the count 13 Q. Are you aware - were you aware of the fact 14 has to be looking for polonium 210, that if they are 14 when you conducted the survey at Providencia that 15 not looking for it, they are not going to find it. 15 Isotopes Specialties Corporation was permitted to 16 A. The samples are counted in such a manner 16 dispose into their sanitary sewer system radioactive 17 counts are detected, and so the particular 17 contaminated materials? that gross 18 isotope involved was not germane. In other words, it 18 A. To the extent it was permitted by the 19 counting. So we had total counts of alpha, 19 regulations, yes. was total 20 total counts of beta gamma and the 20 MS. McKEITH: Exhibit 20. and then we had of that activity was not important 21 (Whereupon, Plaintiffs 21 source you put the wipe sample under a 22 Exhibit 20 was marked 22 Q. Did 23 micrscope and, like, physically count? 23 for identification.) 24 No, ifs a scaler unit that had a gas flow 24 MS. McKEITH: Q. rm going to mark as A. 25 which is a - the wipe was put on a tray and 25 Exhibit 20 a January 19, 1961 letter from J.D. Vaden detector

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1 slid into the detector. The activity would then give 1 9/20 something - 1958. 2 off its radiation which would be sensed by the 2 A. 9/29 on the second page is what it says. 3 instrument and then recorded on a scaler. 3 It looks like there's been seven violations. 4 Q. Do you recall what the level of accuracy of 4 Q. Would you have considered this, if you had 5 that piece of equipment was? Everything is always 5 generated this letter, a facility that was in 6 plus and minus some margin. 6 compliance? 7 A. No, Idon'trememberanyofthat. Itwas 7 MR. SHIMADA: Objection; lacks foundation, 8 typical to put a standard in there in which you would 8 calls for speculation. 9 know the amount of activity. The disintegration per 9 THE WITNESS: This letter clearly indicates 10 minute coming off that sample, you would count that 10 they are not in total compliance with the regulations. 11 sample which then allows you to convert from the total 11 MS.McKEIT-: Q. Are these minor 12 number of counts that the instrument sees to the 12 violations or are some of these significant violations 13 number of the disintegrations that was in the sample. 13 in your 14 Q. If you weren't expecting to find alpha 14 MR. SHIMADA: Same objection. 15 contamination because you weren't expecting to find 15 MS. McKElTH: Q. - based upon what your 16 alpha emitters, would you necessarily have run a 16 view of the situation was back in the 1960s? 17 standard for alpha? 17 A. It's hard to understand from this wording 18 A. On this particular case, the samples were 18 what - in some cases what the violations are. In 19 all counted for alpha, and it was a two-step 19 other cases, ifs very clear, and I - and we would 20 operation. You counseled the samples for alpha, and 20 have, the Commission included, would have considered 21 you went back and counted them for beta and gamma. So 21 some of them significant violations. 22 it was automatic. 22 Q. Can you tell me what you consider 23 Q. And you recall actually conducting the 23 significant? 24 alpha tests on the wipe samples? 24 A. Well, No. 2. 25 A. Yes. 25 Q. Could you read that, please?

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1 Q. You recall that today? 1 A. "Film badge reports indicated that an 2 A. Yes. 2 employee exceeded the maximum permissible exposure 3 Q. But you just don't recall the cleanup 3 limits specified in Section 20.101(a) (1) exposure of 4 level? 4 individuals in restricted areas, during the weeks of 5 A. No, I dont. 5 September 13, 1957; September 27,1957; and October 6 MS. McKEITH: Exhibit 21. 6 11, 1957, when he received doses of 325 millirem, 930 7 (Whereupon, Plaintiffs 7 millirem, 400 millirem, respectfully. The 13-week 8 Exhibit 21 was marked 8 period cumulative dose in each instance exceeded 3 9 for identification.) 9 rem." 10 MS. McKEITH: Q. This is a draft letter 10 Q. And you can consider that a significant 11 from Mason to Isotopes Specialties Company. We do not 11 violation? 12 have the final version of this. Could you look at 12 A. Yes. 13 this letter, please, and I would like you to read to 13 Q. Just prior to that under paragraph 1, 14 yourself the entire letter. 14 there's a sentence which reads: "Concentrations in 15 A. Yes. 15 effluents" - e-f-f-l-u-e-n-t-s - "to unrestricted 16 Q. In connection with your activities at the 16 areas were not made as required by Section 20201(b), 17 Atomic Energy Commission, are you familiar with what 17 surveys." Do you know what that refers to? 18 type of letter this is? 18 A. Yes. That refers to the Section 20.103. 19 A. Yes. 19 Q. But I don't know what 20.103 is? 20 Q. Would this letter have been generated after 20 A. 20.103 discusses - sets limits for 21 the inspection at the Isotopes Specialties' facility? 21 concentrations in effluents to unrestricted areas. 22 A. It would have. 22 Q. What is meant by the word "effluent"? 23 Q. Can you tell us how many violations this 23 A. That's liquids. 24 letter reflects occurred at that facility at this 24 Q. What do you interpret that to mean, 25 pointin time? Looks to me like the date ofthis is 25 "effluents"?

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1 A. It means that effluents were released from 1 the storage yard was not posted. 2 the restricted area to the unrestricted area. 2 A. That's true. That could or could not be 3 Q. In some liquid form? 3 significant. From this information, it's hard to tell 4 A. Yes. Typically, it's water. 4 whether it was a - was posted, but not posted exactly 5 Q. Can you draw our attention to any other 5 according to the requirements. 6 violations in this notice of violation that you 6 Q. When a site was released for unrestricted 7 consider significant? 7 use back in the 1960s, did you understand that to mean 8 MR. SHIMADA: Same objections; lacks 8 that the property could be used for any purposes 9 foundation, calls for speculation. 9 whatsoever? 10 MS. McKEITH: Q. In your first deposition 10 A. Yes. 11 you testified that you were in the compliance branch 11 Q. Did you understand that to mean that 12 of the Atomic Energy Commission during this time 12 someone could tear down the building and reconstruct 13 period. 13 anything without risk of radioactive exposure above 14 A. Yeah, it was actually called the Inspection 14 the limits that were set in the decommissioning? 15 Group. 15 A. It meant the release criteria - anything 16 Q. Thank you. So in the course of your 16 could be done, including the dismantling of the 17 responsibilities, you would have been engaged in the 17 facility. 18 type of inspections that are being referenced in this 18 Q. And you could have built a school on that 19 letter? 19 property without any special handling or procedures; 20 A. Yes. 20 is that correct? 21 Q. And Mr. Mason, do you recall who he is? 21 A. That's correct. 22 A. Yes. 22 Q. In 1961, had someone contacted you to ask 23 Q. Did you work for Mr. Mason? 23 about the decommissioning, would you have told them 24 A. No. Mr. Mason was in the licensing group. 24 that he had no need to be concerned about any special 25 Q. Go ahead. Anything else? 25 handling in light of the fact that you had

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1 A. Well, No. 3 is almost as significant, which 1 decommissioned the site? 2 says that, having received these exposures described 2 MR. SHIMADA: Objection; calls for 3 in Item 2, the regulations would have restricted his 3 speculation. 4 fuarter exposure, and they didn't do it. 4 THE WrINESS: If we had in our hands a copy 5 Q. And is there anything else? 5 that the licensing people had sent to the licensee 6 A. Without having any - the backup material 6 sayng that the licensee had met the release 7 and the inspection report, it's hard to understand 7 requirements and that the site could be used for 8 whether No. 5 would have been significant, but those 8 unrestricted use, the answer was yes. 9 are the main ones that would have been considered 9 Q. So if Mr. Thomson had called you personally 10 significant. 10 in the mid-1960s and asked you whether to be concerned 11 Q. InNo. 5 it states that the effluent from 11 about purchasing that site, would you have indicated 12 glove boxes was not monitored as required by Condition 12 to him that he had to take any special precautions 13 No. 25 of license No. 40-580-7. The word "effluent," 13 because of the previous use of the property? 14 do you interpret that as liquid? 14 MR. SHIMADA: Same objections; lacks 15 A. No. 15 foundation. 16 Q. What do you consider that to be? 16 THE WITNESS: The office would not have 17 A. I would guess that it would be gaseous, but 17 would have told him he could use it any way he wanted; 18 I don't know. It could be liquid, but I don't know. 18 that there would not have been any restrictions 19 MR. SHIMADA: Based on the answer, lacks 19 associated with the use of that site. 20 foundation, calls for speculation. 20 MS. McKEITH: Q. In other words, there 21 MS. McKEITH: Q. So you don't know one 21 wouldnt have been anything to wory about? 22 way or the other 22 A. Thats true. 23 A. I don't know. 23 MS. McKE1TH: I have no frter questions 24 Q. -okay, as itrelates tothis? 24 at this time. 25 Now, there's also a reference to the way 25 MR. SHIMADA: Let's go off the record.

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I

1 VIDEO OPERATOR: Going off the record. The 1 As I understand it, primary licensing 2 time on the monitor is 1:54. 2 authority was handled by the Atomic Energy 3 (Break in proceedings.) 3 Commission's facility or offices in the Bethesda, 4 VIDEO OPERATOR: Coming back on the record. 4 Maryland; is that correct? 5 The time on the monitor is 1:56. Please begin. 5 A. That's true. 6 EXAMINATION BY MR. SHIMADA 6 Q. So they would have been the primary 7 MR. S-TMADA: Q. Mr. rFsh, as rye 7 repository of all documents relating to the licensing; 8 indicated to you before, my name is John Shimada, and 8 is that true? 9 I represent Nucor Corporation as a defendant in this 9 A. Those files would have been the official 10 lawsuit. rm going to apologize ahead of time. rm 10 files. 11 going to be jumping because, frankly, most of my 11 Q. And do you recall, was it the agency's 12 questions are based on the questioning of the other 12 normal practice to keep duplicate sets of files at the 13 counsel and they're mostly things I didn't understand 13 various regional offices pertaining to the licensees 14 or some things I wanted to follow up on. So it will 14 in those regions? 15 be sort ofjumping around. And if in doing so, I 15 A. The regions kept files on each license. 16 confuse you as to exactly what rm asking you about, 16 Q. Is it your understanding that every piece 17 please tell me that you're not clear as to what rm 17 of documentation relating to a particular license that 18 asking you about, and IUbe happy to try to make it 18 would be found in Bethesda files would also be found 19 clear and give you a little bit more context for what 19 in the local region's files, in this case, the San 20 rm inquiring about. Fair enough? 20 Francisco office? 21 A. Al right 21 A. No, there was no guarantee that we had a 22 Q. If I understood you correctly, is it true 22 copy of all the documents that were in the file. 23 that the Geiger-Muller detector that you recall using 23 Q. Did you have any steps you normally took to 24 as part of your confirmatory survey at the Providencia 24 see whether there were documents of note that were 25 facility would not have detected carbon 14? 25 contained in Bethesda's files that were not contained

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1 A. It's not likely that it would have detected 1 in your local offices files at the time you went out 2 the carbon 14. 2 to any given facility? 3 Q. And similarly, is it not likely that the 3 A. The answer to that is no. If the region 4 wipe sampling would have detected carbon 14? 4 became aware of a document that they did not have, 5 A. Idon'tknowthat. At this point in time, 5 they would call the people in Bethesda and probably 6 I don't remember. 6 ask. Normally they would ask for a copy to be sent to 7 Q. Do you recall being aware that there was a 7 them, but only if we became aware of its existence, if 8 portion of the Providencia facility that was sometimes 8 we didn't have it as a normal course of business. 9 referred to in the licensing documents as being the 9 Q. So it's entirely possible that the AEC's 10 C-14 or the carbon 14 lab? 10 files in Bethesda, Maryland might contain documents 11 A. As part of this experience, I have seen a 11 that weren't contained in the files that you had 12 diagram that identifies a carbon 14 lab. 12 access to prior to your confirmatory survey at 13 Q. Do you have a specific recollection of 13 Providencia Street? 14 seeing that document during the course of your review 14 MR PATrERSON: Objection; speculation, 15 of materials in preparation for conducting your 15 lacks foundation. 16 confirmatory survey? 16 THE WITNESS: It's possible. 17 A. No, I do not. 17 MR SHIMADA: Q. Mr. Fish, quite a number 18 Q. As you sit here today, you don't recall 18 of the questions that have been asked of you in the 19 what documents you may have reviewed prior to actually 19 past day and a half regarding practices and procedures 20 conducting the survey; is that true? 20 of both yourself and the Atomic Energy Commission in 21 A. I do not recall what specific documents I 21 relationship to the release of facilities for 22 reviewed. 22 unrestricted use have been couched in terms of what 23 Q. Now, you've been shown various documents 23 you recall the procedures being in 1961. Do you 24 from what was referred to - well, let me try that 24 recall whether the survey that you conducted at 25 again. 25 Providencia, in fact, was conducted in 1961?

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1 A. I do not know the date when I made the 1 Q. By format, youre referring to how the 2 survey. I don't remember. 2 cleanup - regardless of what the actual numeric 3 Q. Do you recall, was it in the '60s? 3 cleanup criteria were, there was a change in how those 4 A. It would have been in the '60s. 4 numerical criteria were presented as just a matter of 5 Q. Is there something that leads you to 5 format? 6 believe it would have been in the '60s? 6 A. Format, right. 7 A. Well, one thing is that around 1968my 7 Q. Do you recall - as you sit here today, you 8 responsibilities changed from looking at all kinds of 8 don't recall if there were changes in the numerical 9 licenses to being primarily, almost essentially, 9 cleanup criteria? 10 involved with reactors and large facilities such as 10 A. No, I do noL 11 Valacitas. So I know it was before that. 11 Q. Is it that you don't believe that there 12 Q. So it would have been before 1968? 12 were changes or you don't recall one way or the other? 13 A. It would have been before 1968, but I 13 A. I don't recall one way or the other. The 14 cannot pinpoint it. 14 release criteria were on an individual facility basis, 15 Q. And during the time period between 1961 and 15 but I don't recall the numbers. 16 1968, do you recall there being changes in the 16 Q. You've testified that the detection limits 17 requirements and criteria that were applied for 17 of the Geiger-Muller that you had available in about 18 decommissioning facilities? 18 1961 to conduct your confirmatory survey would have 19 A. I recall that there was a change in the 19 been a tenth of a milliroetgen per hour is that 20 description, but I don't recall whether there was a 20 corect? 21 change in the numbers. 21 A. Thafs my recollection, but it might be a 22 Q. What do you mean by a change in 22 hundredth. I just don't remember that lower range. 23 description? 23 Q. Assuming for the moment it was a tenth of a 24 A. Well, one of the exhibits here shows a 24 milliroetgen. Is my math correct, does that equal to 25 letter from 1959 and 1960, in which its just a letter 25 hundred microroetgens?

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1 with a section that describes four items. Later on I 1 A. That's true. 2 was shown a table that was - I think had a 1970 date, 2 Q. When using a Geiger-Muller - let me back 3 and that format was in a table format as opposed to 3 up. A Geiger-Muller that detects radiation in 4 just being part of the letter - of the transmitting 4 increments of milliroetgens per hour, is the amount of 5 letter, but I don't know that there was a difference 5 milliroetgens per hour that you measure dependent in 6 in the numbers. 6 part on how long you leave the detector over a given 7 Q. Let me, in an attempt to understand your 7 spot? 8 answer, ask you to look at Exhibit No. 1. Do you have 8 A. No. 9 that handy? 9 Q. So whether you leave such a detector over a 10 A. Is that the letter of 10 spot that had radioactive contamination for a minute 11 Q. There's a copy of the deposition transcript 11 versus 10 minutes, the level of radiation shown on the 12 in front of Mr. Patterson. Perhaps he could hand that 12 meter would be the same? 13 to you. 13 A. Yes, itwould. Now the only exception to 14 A. There's a 1959 letter, December 1959 14 that is if you move it very quickly so that the meter 15 letter. 15 is not able to respond to the maximum amount of 16 Q. Yes. From Mr. Price to Mr. Michaud? 16 reading. 17 MS. McKEITH: rn give you another. I 17 Q. Is there a- well let me ask it in this 18 have plenty. 18 way. Inthe 1960s, sayinand around 1961 or'62,in 19 THE WlTNESS: Yes, I have that one here. 19 that - in the early '60s, did you have a standard 20 MR. SHIMADA: Q. Is this the letter 20 procedure that you followed in using a Geiger-Muller 21 you're referring to in your last set of answers? 21 detector in terms of how long or how slow you would 22 A. This is the format, and there was a 22 sweep the detector across the surface? Would you, for 23 follow-up letter that dealt with Providencia. This is 23 instance, leave it over a given spot for 30 seconds or 24 one format, and then the other one I was shown I think 24 a minute before moving on? Did you have a normal 25 had a 1970 date which was in a table format. 25 practice or procedure?

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1 A. Are you talking about a formal procedure or 1 length of the lead on the detector just wasn't long 2 are you talking about the normal way of conducting 2 enough? 3 using the equipment? 3 A. That's correct. 4 Q. Lets talk about the way you would normally 4 Q. So you don't even know if you went all the 5 do it, if you recall. 5 way down the entire length of the wall; is that 6 A. The inspectors were aware of the 6 correct? 7 limitations of the instrumentation so that you would 7 A. I don't remember. I really don't remember 8 make the survey in such a manner that you would not be 8 how deep the pool was. 9 getting inaccurate information from the meter 9 Q. Do you recall there being some - do you 10 readings. 10 recall that the detector wasn't long enough, but you 11 Q. And as part of the using the meter, did you 11 don't recall how short it fell? Would that be 12 personally have a practice of - as to how long you 12 accurate? 13 would leave the Geiger-Muller over a given spot and 13 A. Well, I remember the length of the cord 14 take a reading before moving on to the next spot? 14 that was attached - approximately, to the cord that 15 A- When you make a survey, you don't normally 15 was attached to the detector, but I don't recall how 16 hold it over one spot for a period of time. That 16 deep the pool was. 17 gives me the connotation that youre making 17 Q. Approximately, how long was the cord? 18 measurements similar to doing some analyses that were 18 A. The cord was approximately 18 inches to two 19 done here in which they accumulated counts. With a 19 feet, ff I remember right 20 survey meter, you go over it and you would move only 20 Q. Was there any way that you had to add some 21 as fast as you are assured that you get the maximum 21 sort of extension cord to the detector? 22 reading. Once you get the maximum reading, you can 22 A. Make it longer? 23 then move on. 23 Q. Right 24 Q. Prior to conducting your initial survey at 24 A. No. 25 Providencia, do you recall speaking with anyone 25 Q. I don't know if- my next question simply

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1 employed by U.S. Nuclear? 1 is whether or not you recalldoing this or not Isit 2 A. About the Providencia facility? 2 your recollection that you leaned over into the pool 3 Q. Yes. 3 and draped your arm down over the lip of the pool and 4 A. No, I do not. 4 tried to go as deep as you could with the detector?. 5 Q. Do you recall speaking with anyone employed 5 A. I don't recollect exactly, but my guess is 6 by U.S. Nuclear dining the time you were conducting 6 I would have done something like that to get as far as 7 your confirmatory surveys? 7 down as I could. 8 A. Not specifically. I remember that I was 8 Q. So it's your best recollection that you 9 involved with somebody when I made the visits to the 9 would have only been able to lower the detector no 10 Providencia facility, but today I cant tell you 10 deeper than the length of your arm plus about two 11 whether that person was an employee of U.S. Nuclear or 11 feet? 12 not 12 A. Thafs my recollection. 13 Q. Was it only one individual that you recall 13 Q. And in doing so, that survey, you, in fact, 14 being involved with during your confimatory survey at 14 found some elevated levels of radioactive 15 Providencia, or were there more than one such 15 contamination in the pool walls, correct? 16 individuals that you were involved with? 16 A. Idid. 17 A. I don't remember the exact number. My 17 Q. And you directed that those areas be 18 recollection is there was only one person that I was 18 removed or dealt with in some manner; is that true? 19 working with when I actually visited the site. 19 A. I informed them that the pool did not meet 20 Q. Now am I correct that you did not survey 20 the criteria and that they had to do additional 21 the bottom of the pool that was at Providencia? 21 conamination work to meet the criteria 22 A. I don't remember, but my recollection is 22 Q. Do you recall did you specify the areas 23 the detector would not go all the way to the bottom. 23 within the pool that needed father work? 24 MS. McKE1TH: Didn't want to climb in. 24 A. I don't recall whether I specified the 25 MR. SHIMADA: Q. And that's because the 25 areas.

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1 Q. Do you recall - now, you have a 1 Q. Do you have a recollection that the pool 2 recollection of observing areas of chipped concrete 2 was deep? 3 out of the pool walls, correct? 3 A. Well, there was sufficient depth to provide 4 A. Yes. 4 adequate water for shielding of a significant amount 5 Q. Do you recall how far down the pool walls 5 of cobalt 60, and, you know, as I would guess that it 6 that chipped concrete extended? 6 would have been at least 10 feet, and so 14 is 7 A. No, I don't. 7 perfectly reasonable. 8 Q. Now, when you last saw the pool, the pool 8 Q. Is that based on your recollection of 9 was empty, correct? 9 seeing other cobalt storage pools and observing how 10 A. That's correct. 10 much water was used to shield the cobalt sources? 11 Q. And by that, there was no water, there was 11 A. Yes, it is. 12 no soil, there was nothing in the pool itself? 12 Q. So if the pool, for instance, was lOfeet 13 A. That's right 13 deep, you would have only been able to survey with 14 Q. Would you have expected U.S. Nuclear to 14 your Geiger-Muller approximately half the height of 15 notify the AEC had it buried radioactive material in 15 that wall, no more than five feet or so, correct? 16 the pool? 16 A. No, I don't specifically recollect that 17 A. Yes, I would have. 17 kind of detail, but the answer is that's as far down 18 Q. And why was that? 18 as the detector would have reached; however, since 19 A. Well, because we were making a confirmatory 19 it's cobalt 60 contamination and that has a high 20 survey to confirm that there was only minimum -di 20 energy gamma, in the air it would travel a significant 21 minimus amounts of activity there and that the 21 amount of distance so that you would be able to see 22 facility would be released for unrestricted use, and 22 radiation levels down on the bottom of the pool 23 anything that would change that condition, we would 23 Q. Would that depend on how much radiation was 24 expect them to notify the commissioa 24 actually present? 25 Q. As you sit here today, you don't recall 25 A. Sure.

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1 receiving any such notification from U.S. Nuclear with 1 Q. How much radioactive material 2 respect to the pool at Providencia, correct? 2 A. Yes, it would. 3 A. No, I do not. 3 Q. So you really have no way of knowing 4 Q. Do you recall seeing any steel plates 4 whether your detector could have detected cobalt 5 attached to the floor at Providencia? 5 contamination on the bottom of the pool because you 6 A. No, I do not. 6 dont know how much contamination there was; is that 7 Q. rm going to ask you to take a look at 7 true? 8 Exhibit 18. Do you have a copy of that in front of 8 A. I don't even remember the specifics of 9 you, sir? It begins with page 311. 9 maling the survey to be able to answer that question 10 A. Yes. 10 any more than I have. 11 Q. If you could turn to page 313. 11 Q. Do you recall if cesium 137 was stored in 12 A. Yes. 12 the pool? 13 Q. First, do you recall seeing this particular 13 A. I don' recall that cesium was stored in 14 page during your review of the file concerning the 14 the pool. I recall that cesium was there in the 15 Providencia property prior to your confirmatory 15 facility, and since it was used as sources, I could 16 survey? 16 imagine that it would in there, but I can't 17 A. No, I do not have any recollection of 17 specifically recollec that cesium was there. 18 seeing this. 18 Q. If you could go back to Exhibit 2, which is 19 Q. Now this diagram indicates that the 19 the January 30, 1961 letter from Mr. Mason. 20 interior depthofthe poolis 14 feet. Doyou see 20 A. What l have here is the front page. I 21 that? 21 think that's the one you're talking about. 22 A. Yes, I do. 22 Q. You really need to have the full document 23 Q. Does that refresh your recollection as to 23 in front of you. 24 how deep the pool was? 24 A. I don't have that second page. 25 A. No, it doesn't 25 MR. SHIMADA: Can we show Mr. Fish that

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1 copy? 1 document that's a September 27, 1999 letter to you 2 MR. PATTERSON: rm going to provide you, 2 from the Proskauer Rose firm. And I apologize, this 3 Mr. Fish, with a copy of the transcript of your first 3 is my only copy; this is the copy I got from 4 day of deposition. It has the exhibits attached to 4 Mr. Patterson during the first day of your deposition. 5 it, including Exhibit 2. 5 But I place it before you and ask you to look at it 6 MR. SHIMADA: Q. Now you have Exhibit 2 6 particularly with respect to the second paragraph 7 .in front of you, correct? 7 of- excuse me, the second page of the letter, which 8 A. Ido. 8 contains the following paragraph. "One of my 9 Q. Do you see anything in this letter that 9 questions is: Did the Isotopes branch have the 10 specifies what portions of the Providencia facility 10 authority to do what they did and was this the cleanup 11 should be surveyed for the presence or absence of 11 criteria in total? You seem to remember more specific 12 radioactive contamination? 12 guidelines." So if you could take a look at this 13 MR- PAITERSON: Objection; vague and 13 letter, and in particular that paragraph, and then I 14 ambiguous. 14 have a question or two for you about that. 15 THE WITNESS: There's nothing in here that 15 A. Well, I see the statement. 16 is specific except to the extent that it says: "You 16 Q. Now, in that letter, immediately prior to 17 are requested to notify this office of contamination 17 the language that I quoted for the record, there's a 18 levels which remain in the building." Thafts the only 18 reference to the January 30, 1961 letter which is 19 thing that's specific at all. 19 Exhibit 2 that we looked at a moment ago, correct? 20 MR. SHIMADA: Q. Do you have any 20 A. That's true. 21 recollection of reviewing any documents from AEC 21 Q. Do you recall, as you sit here today, there 22 headquarters that defined the locations that should be 22 being some other guidelines that were applicable to 23 surveyed as part of the confirmatory survey at 23 the confirmatory survey at Providencia apart from the 24 Providencia? 24 language that's quoted in that letter, which is 25 A. I would not. I don't recall anything, but 25 contained in Exhibit 2 to this deposition?

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1 it was not normal for headquarters to notify us of the 1 A. I guess the answer is I didn't recollect 2 areas to be surveyed. 2 the criteria that were in that letter, the January 3 Q. Normally, the inspectors would make those 3 letter. And if somebody had asked me, I would have 4 determinations on their own? 4 guessed it would have been in a different form, but I 5 A. I guess the answer is yes, but it would be 5 don't - that's just my recollection. 6 based upon review of the file and review of the 6 Q. Was it your -- is it your expectation that 7 licensee's survey that was submitted in connection 7 the cleanup criteria would have been more specific? 8 with the release. 8 A. No. 9 Q. And as you sit here today, you recall 9 Q. What do you mean by a "different form"? 10 surveying the inside of the building at Providencia, 10 A. Well, it means that the radiation levels 11 correct? 11 would have been at two distances: one at a close 12 A. Ido. 12 distance and one at a larger distance. I would have 13 Q. And as you sit here today, you recall 13 expected some statement to be in terms of removal 14 surveying the driveway along the side of the building 14 contamination in a different form. This one just 15 as well as the back asphalt area, correct? 15 says - the letter - the December '59 letter just 16 A. Ido. 16 says there should be no removal contamination, and I 17 Q. As you sit here today, you have no 17 would have recollected something with some specific 18 recollection of surveying the back bays on the 18 numbers. 19 property; is that correct? 19 MR. SHIMADA: We'll mark that letter as the 20 A. That's true. 20 next exhibit, which is Exhibit 22. 21 Q. In fact, as you sit here today, you don't 21 (Whereupon, Defendant's 22 have any recollection of going inside those bays? 22 Exhibit 22 was marked 23 A. At this time, I have no recollection of 23 for identification.) 24 going in thre. 24 MR. SHIMADA: Q. Mr. Fish, if you could 25 Q. Mr. Fish Im going to show you a copy of a 25 look at Exhibit 9 to the deposition, which has a

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1 figure 3-8 from the September 1999 Rogers & Associates 1 rest of the building was open and vacant? 2 report It's a figure that has a lot of colored dots 2 A. That's my recollection. 3 on it. Do you have that in front of you? 3 Q. You don't recall any other interior walls? 4 A. Ido. 4 A. No, I don'. 5 Q. Now, is it your understanding that this 5 Q. Do you recall seeing any signs that it 6 figure reports the various detected gamma radiation in 6 looked as if there had once been walls that had been 7 mltiples of background. Do you see that? 7 removed? 8 A. Yes. 8 A. No, I dont recollect that, no. 9 Q. And regardless of what the actual 9 Q. Apart from the swimming pool or the pool 10 background. numeric background. reading was, would you 10 that we've already talked about, would you have 11 have expected the Geiger-Muller detector used by you 11 expected U.S. Nuclear to advise the AEC had it filled 12 in your confirmatory surveys to detect gamma radiation 12 in or otherwise covered up any other holes that might 13 that was in access of a thousand times background? 13 have been present at Providencia? 14 A. Well, I guess that depends. This figure is 14 A. I would have expected that to come out 15 showing counts that are accumulated over a period of 15 during the discussions of visiting the site, yes. 16 time, not in an instantaneous reading. So ifs 16 Q. And as you sit here today, you don't recall 17 different kind of measurements. 17 that topic being discussed? 18 Q. Understanding that the methodology used is 18 A. No, I do not 19 different, nevertheless, you understand that this 19 Q. Apart from seeing the chipping away of some 20 figure reports gamma ray readings that are 20 of the concrete in the walls of the pool, do you 21 representative of a given level of radioactive 21 recall seeing any other evidence that any portion of 22 activity, correct? 22 the asphalt or concrete work at the Providencia 23 A. This is an accumulation of counts over a 23 property had been removed in any manner? 24 period of time. 24 A. I don't recall that, no. 25 Q. That are attributable to gamma ray sources. 25 Q. Do you recall seeing any signs of that

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1 A. That's right. 1 concrete or asphalt had been freshly poured? 2 Q. And in some cases, this report or figure 2 A. I do not recall that at this time. 3 indicates that the amount of gamma radiation that was 3 MR. SHIMADA: Mr. Fish, thank you. I 4 detected using this methodology was in some cases over 4 dont have any other questions for you. 5 a thousand times background, correct? 5 MR. PATTERSON: Can we go off the record 6 A. Yeah, thafs what it says. 6 for a minute. 7 Q. Given that order or orders of magnitude 7 VIDEO OPERATOR: This concludes Videotape 8 difference over background, would you have expected 8 No. 4 in the deposition of Raymond Fish. Going off 9 the Geiger-Muller detector used by you to have 9 the record, the time on the monitor is 2:40. 10 detected gamma radiation sources of the levels that 10 (Break in proceedings.) 11 are apparently present, given this figure? 11 VIDEO OPERATOR: Here begins Videotape No. 12 MR. PATTERSON: Asked and answered. Calls 12 5 in the deposition of Raymond Fish. Coming back on 13 for speculation. Lack of foundation. 13 the record, the tirne on the monitor is 2:51. Please 14 THE WITNESS: Well as I said before, one 14 begin. 15 of the problems I have with this report is I don't 15 EXAMINATION BY MR. BROWN 16 have a conversion from the counts per minute that they 16 MREBROWN: Q. Mr. Fish, my name is Byran 17 have here into radiation levels. And so, you know, I 17 Brown, and I represent Rhone-Poulenc, who is another 18 cant say that a thousand times background here would 18 defendant to this lawsuit. And I guess I probably 19 be or would not be detectable by the GM tube, the 19 should have done this while we were on our break 20 Geiger-Muller tube. You know, in some cases these 20 waiting, but could you take a look at Exhibit 19 once 21 counts were accumulated over one hour. 21 again and just kind of read it over to yourself 22 MR, SHIMADA: Q. And am I correct, its 22 including the second page? I don't know if you have 23 your recollection that when you first saw the interior 23 the whole document. Is it cut off at the bottom? 24 of the building at Providencia in connection with your 24 MS. McKE1TH: Yeah. The part that said 25 survey, that once you got past the front offices, the 25 this really doesn't count?

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1 MR- BROWN: Do you have another copy. 1 A. I can't read that whole line. 2 16? 2 MS. McKEITH: No, but we could get a Q. Youcan'treadanyofthatinparagraph 3 A. No, I really can't I can see the line 3 complete copy. 4 4 MR. BROWN: I have a complete copy. It's below it. 5 Q. Maybe if you could look at this copy, I 5 the only one I have. 6 clearer than that one. Why don't you 6 Q. Here you go, Mr. Fish. Here is a complete think it's maybe and read the whole paragraph. 7 copy of that document. 7 go ahead 8 This one says: "Two bottles contain 100 8 Mr. Fish, did you create the original of A. 9 like it was 500 grams of thorium total, 9 this document? to" it looks have had some ink 10 A. Iguessldid. My signature - my name is 10 but this copy looks like it may to - it's 11 there, so the answer is yes. 11 changes to it or maybe it's an attempt but it's of the order 12 Q. So, it was if your name is there, that 12 something 500. It might be 580, of thorium total in those bottles. 13 means normally you would have created this document? 13 of 5- to 600 grams 14 A. Ido. 14 Q. Five to 600? two bottles contain 100 to whatever 15 Q. And there's no reason why you believe you 15 A. No, the I can't read it 16 didn't create the document? 16 that second number is, and because 500 and 600 17 A. No. The stamp says the original was signed 17 exactly, my guess it's somewhere between 18 by me. 18 grams. sentence? 19 Q. Can you explain the what the term "thorium 19 Q. Can you read the second says: 'This is about 20 source material" means? 20 A. The second sentence which according to 10 CFR 21 A. Yeah. Source material was certain 21 100 microcuries maximum, require a labeL" 22 materials that were not - had lesser effects on 22 20.203 F2 does not give you any kind 23 people. They were low concentrations of radioactive 23 Q. Does that second sentence scratched 24 material. Naturally uranium was a source material as 24 of indication of what the number is that's 25 well as thorium. 25 out?

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i

1 Q. When this says that the license - the 1 A. No. thinking - we 2 scope of the license for 5,000 pounds of- strike 2 Q. So the maximum there, youe over 100? 3 that. 3 can't tell Basically, it's something 5 to me. 4 Let's look at paragraph 11 on the next 4 A. Yeah, the first one looks like a 500, 5 page. 5 And looks originally - like originally it was 6 A. Urn-hum. 6 but I don't know because there are marks here. But it 7 Q. It says that the licensee purchased 4,860 7 looks like it's 100 to 500 grams of thorium is what 8 pounds of source material from GSA. Does this mean 8 looks like was typed there originally. I think 9 that the licensee purchased 4,860 pounds of thorium? 9 Q. And if you look back at paragraph 10 A. No. The total weight of the material was 10 itwas 11, it said that 400 to 500 pounds of this 11 4,860 pounds. It wouldn't be total thorium. If it 11 thorium source material that was purchased was 500 12 were total thorium, it would be in the form of a 12 processed and the thorium residue was this 100 to 13 metal Soit's notin the form of a metal. Sothat's 13 or whatever that number is. 14 not 4,860 pounds of thorium. That's the total weight 14 A. Grams. of 15 of the material t's there of which a portion of it 15 Q. Grams. Could you tell what percentage 16 is thorium. 16 thorium was in that source material, mathematically, 17 Q. If you reference paragraph 16 below 17 from those two references? could. 18 first of all. In paragraph 11, the second sentence 18 A. Well, I guess you for 19 says that some of this material, referring to the 19 MS. McKEITH: Objection; calls 20 4,860 pounds of source material has been processed 20 speculation. 21 and the thorium collected as a residue and stored in 21 THE WITNESS: You know, there's 454 grams 22 twobottles. In paragraph 16, if you look at that, it 22 to the pound. So if you multiply, say, the 400 pounds 23 discusses those two bottles and it says "these bottles 23 times the 454 grams per pound, that gives you the 24 contain 100" and then something scratched out. Can 24 total grams tha's inthere. And if you put the 100 25 you read what that says? 25 or even put the 500 grams of thorium over that, you

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come up with a percentage. It's very, very small. 1 those 400 to 500 or that - assuming 500 pounds of 2 MR. BROWN: Q. And this -- I'm sony, 2 thorium pxocessed, .27 percent is a conservative 3 could you repeat that question equation? 3 approximation of how much thorium was contained in the 4 A. Yeah. If you take the 100 or the 500, say 4 source material? 5 the second number is 500 grams of thorium that's 5 A. In that 400 pounds. 6 total, and divide it by the number 400, if you use the 6 Q. Okay. Fim going to show you another 7 lower number up above, and you take the 400 and 7 document here, Mr. Fish, this is a letter from -- to 8 multiply it by 454 grams per pound, that 8 Research Chemicals from Kber Price dated May 18th, 9 multiplication will give you the total grams in the 9 1961. In the last paragraph of the letter it 10 400 pounds. And you just use that as a dividend -- a 10 references "unimportant quantities of source 11 divisor and put the 500 over it, and whatever that 11 material." Do you see that? 12 numbers comes out, will give you the percentage of 12 A. Yes. 13 thorium that's present. 13 Q. What does that mean? 14 Q. Is this equation that you just discussed 14 A. Without looking up the old part 40, my 15 based on speculation or does that come from your 15 guess is that what it refers to is a general license, 16 experience? 16 which a person would have access to without getting an 17 A. No. No, that'sjust a way of doing it. 17 actual license and applying for it It's for small 18 Q. Could you, mathematically, figure that out 18 unimportant quantities. In other words, small 19 for us? 19 quantifies. 20 A. Sure. 20 Q. But again, not being able to reference the 21 MS. McKE1TH: Excuse me, what is he 21 regulations at the time, you couldn't tell exactly 22 figuring out? 22 what that amount was? 23 THE WITNESS: He wants to know what the 23 A. No, it's to the order of pounds, you know, 24 percentage of the thorium is in the 400 pounds. 24 40 pounds, 50 pounds, something like this, as opposed 25 MS. McKE1TH: Are we looking at the 5,000 25 to the larger quantities that were in the license.

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1 pounds of source material? 1 Q. rm going to show you one more document 2 MR. BROWN: No, we're looking at the second 2 can we mark that as the next exhibit. 3 page, Malissa. 3 (Whereupon, Defendant's 4 MS. McKEITH: Or the approximately 4,300 4 Exhibit 23 was marked 5 pounds that remained in the shipping. 5 for identification? 6 MR. BROWN: We're looking at paragraph 16. 6 MR. BROWN: Q. This is a letter to 7 MS. McKEITH: Well, good, we'll have him do 7 Research Chemicals, again, from Kber Price dated 8 the same thing for No. 12 then, won' we. 8 August 29th, 1961. In the second paragraph -can you 9 MR. BROWN: That's fine. I think that 9 go ahead and take a look and read that to yourself. 10 would be the same if we extrapolate that same 400 10 A. Yeah, rve read it. 11 pounds comes from the 4,860. 11 Q. Does that refresh your recollection as to 12 MS. McKEITH: Well, rl just have a 12 what level an unimportant quantity of source material 13 running objection because he doesnl have any idea at 13 is? 14 all what actually was on the site. 14 A. This appears to indicate that there is a 15 MR. BROWN: But we can do it for the 400 to 15 second part of the regulations which deals with this 16 500 pounds that was processed. 16 kind of a situation and refers to thorium content that 17 THE WITNESS: So its about 0.27 percent 17 didn't exceed 0.25 percent by weight And I think 18 MR. BROWN: Q. 0.27. And that's an 18 that was not the section I was referring to in my 19 approximation? 19 previous discussions where I said that I thought there 20 A. Approximation. And that's using 400 pounds 20 was a general license for certain small quantities. 21 and 500 grams. 21 Q. It says that for - this letter says that 22 Q. And that's the most conservative estimate 22 for products containing not more than .25 percent by 23 gven those numbers, right? 23 weight of source material are exempt from the 24 A. Yes. 24 licensing requirement 25 Q. So based on your calculation, at least for 25 A. That's what it says.

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1 Q. -Part 10CFR -excuse me, Title 10CFR 1 23 once again, the prior letter dated May 18th, 1961? 2 2 Part 40; is that right? Under the paragraph numbered 1 there, is it your 3 A. What it says is that without a specific 3 understanding that this means that Research Chemicals 4 license. 4 did not have any AEC license? 5 Q. rm sorry. 5 A. What this is saying is that the residues 6 A. Well, there's a difference between a 6 exceeded the 7 general license, which a person would have had by 7 Q. I'm speaking about the paragraph numbered 8 virtue of it being in the regulation as opposed to a 8 1, the very first paragraph there. 9 specific license where you need to make an application 9 A. That's what rm reading. Where it says 10 and a specific license was issued by the Commission. 10 "although the rare earth"? 11 And because I don' remember the details of this, I 11 Q. No. The paragraph preceding that. 12 don't know whether this is talking about this as being 12 A. Okay. It says, "You possess source 13 done under a general license, which would be there by 13 material without valid AEC license in violation of 14 virtue of it being in the regulation or whether this 14 Section 40.10 restrictions on tranfers." 15 regulation says you just don't need it, period. 15 Q. Stopping there, does that make you believe 16 There's a difference between general license and no 16 that Research Chemicals did not have an AEC license? 17 license. 17 A. That's what that says. That - for the 18 Q. But, unfortunately, we don't have the 18 material they possessed, they did not have a valid AEC 19 regulations in front of us, but by reference to those, 19 license. 20 we would be able to tell that distinction, right? 20 Q. And under the definition - it also said 21 A. That's right, we would. 21 under the definition of source material that that was 22 Q. So the estimate that you had calculated 22 a violation in the rest of that No. 1. 23 earlier of .27 percent for that assuming 500 pounds of 23 A. You know, that's what it's saying. It says 24 thorium source material processed 24 that material that's in those bottles met the 25 A. I assumed 400 pounds, and I assumed 500 25 definition of source material.

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1 grams. 1 Q. Okay. Refrencing the other letter - or 2 Q. Right 2 reading this letter and that other letter that we just 3 A. That's worst case. 3 read combined, does that make you believe that the 4 Q. If that had been below .25 percent, it 4 sentence in the second letter, referring to exceptions 5 would not have required a specific license? 5 from licensing requirements, means that no license at 6 A. That's true. 6 all is required? 7 MS. McKEITH: Can we just clarify whether 7 MR. SHIMADA: Objection; calls for 8 it would have required a general license. 8 speculation, lacks foundation. 9 MR. BROWN: I don't think we can clarify 9 MS. McKErrH: Speculation. 10 that because we haven't referenced the regulations. 10 THE WITNESS: The one thing that I can't 11 He was not sure just in referencing 11 tell is whether what's in the August 29, 1961 letter 12 A. IfI saw Part 40, specifically 40.13 paren, 12 is the result of an amendment that occurred subsequent 13 looks like, e or c and paren 1, if I saw that, I could 13 tothe May l8th letter. Soit could have been 14 tell you whether that, in fact, was a general license 14 there coukl have been a change in the regulations 15 that allowed this activity or whether it said that 15 which resulted in the August 29 letter that clarified 16 this didn't require any kind of a license. 16 all this and eliminated all the problems identified in 17 MR. BROWN: Q. Can you reference 17 the May 18th letter. 18 Exhibit 18 MR- BROWN: Q. But without knowing the 19 A. You want to make this an exhibit? 19 contents of those changes, you wouldn't be able to 20 MR. BROWN: Let's mark that the next 20 A. Thats true. 21 exhibit, Exhibit 24. 21 MR. BROWN: I guess thats all the 22 (Whereupon, Defendant's 22 questions I have, Mr. Fish. Thank you. 23 Exhibit 24 was marked 23 MR. PAT1ERSON: Go off the record for a 24 for identification.) 24 minute. 25 MR. BROWN: Q. Can we reference Exhibit 25 VIDEO OPERATOR: Going off the record, the

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1 time on the monitor is 3:18. 1 A. The confirmatory survey is done to, in 2 (Break in proceedings.) 2 essence, confirm the results of the licensee's survey 3 VIDEO OPERATOR: Coming back on the record. 3 so that the Commission can take reliance on the 4 The time on the monitor is 3:20. Please begin. 4 results of the licensee's survey. 5 FURTHER EXAMINATION BY MR. PATTERSON 5 Q. Is the fact that you did not use a 6 MR. PATTERSON: Q, Good afternoon, 6 scintillator in your confirmatory survey, that that 7 Mr. Fish. My name is Greg Patterson. I've already 7 fact alone does not mean that the survey failed to 8 asked you a series of questions. I just have a few 8 meet the cleanup criteria; is that correct? 9 more. 9 A. No. I guess rim having trouble with that 10 Can you tell me what the term "whole body 10 question. 11 dose" means? 11 MR. SHIMADA: And r0 object. It's vague. 12 A. The whole body dose is differentiated from 12 MR. PATTERSON: Q. You testified that you 13 extremity dose, extremities being hands and feet, and 13 use a Geiger-Muller instrument to do your survey, 14 the whole body is the rest of the body, which contains 14 correct? 15 the organs and things like that that would be 15 A. Yes, I did. 16 susceptible to radiation exposure. Your hands and 16 Q. And you do not recall using a scintillator? 17 feet can take more radiation without having a visible 17 A. I did not use a scintillator. 18 effect than the whole body. So therefore, the 18 Q. Did not use a scintillator. The fact that 19 numbers - the exposure limits are different for those 19 you did not use a scintillator, that doesn't mean one 20 two items. 20 thing or the other with respect to whether the 21 Q. So the exposure limits would be higher for 21 ultimate cleanup criteria were met; is that right? 22 feet and hands? 22 A. No, it has no bearing on it. 23 A. Yes. 23 Q. And your recollection today is that you 24 Q. Can you explain to me what the relationship 24 confirmed by review of the survey results, as well as 25 is between the cleanup criteria that would be 25 your own results, that the properties have been

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1 established similar to those that we have in Exhibit 1 1 cleaned up to the terminating criteria expressed in 2 and whole body dose? Is there a relationship? 2 Exhibit 2 of your deposition? 3 A. Well, yeah. The requirements would be 3 A. The release criteria. 4 oriented towards restricting exposure in the area of 4 MS. McKEHTH: rmi going to object to the 5 whole body as opposed to extremities because ifs a 5 extent that "property" is vague and ambiguous, and the 6 lower number. 6 fact that the witness has already testified he did not 7 Q. Now, you testified that you would have 7 survey the entire property. 8 reviewed the survey reports done by U.S. Nuclear of 8 MR- SHIMADA: Also mischaracterizes the 9 the Providencia property, the initial survey report, 9 testimony. The witness has already testified he was 10 prior to conducting your own confirmatory report; is 10 not sure what documents he specifically saw prior to 11 that right? In other words, you would have seen 11 the confirmatory survey. 12 whatever report they had put together based 12 MR. PATTERSON: Q. Do you recall the 13 A. Their survey report that they made to 13 question after that? 14 confirm that the facility had been cleaned to the 14 A. No, I guess I don't. 15 criteria and then submitted to the Commission, I would 15 MR. PATTERSON: Could you read it back, 16 have reviewed that. 16 please, my question. 17 Q. Do you recall whether the survey report for 17 (Record read.) 18 Providencia indicated that the survey included the use 18 THE WITNESS: Iguess my answeris: My 19 of a scintillator? 19 recollection is that my survey and the survey - the 20 A. I do not recall that survey report at this 20 final survey results of a licensee confirmed the 21 point 21 facility had been cleaned to the release criteria, and 22 Q. And as I understand it, the purpose of your 22 I can't confirm the statement with respect to that 23 confirmatory survey is not to duplicate what was done 23 letter. 24 by the persmon who was conducting the decontamination, 24 MR. PATTERSON: Q. I understndIrIm 25 but merely to confirm the sampling results? 25 going to jump around here a little bit and I

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1 apologize. Was the GM tube, the Geiger-Muller tube, 1 chip away or remove some materials, right? 2 that you used made of steel glass or aluminum? 2 A. That's correct 3 A. I can't specifically say I know which one 3 MR. PATTERSON: I have no further 4 it was at this time. 4 questions. 5 Q. There was some testimony earlier regarding 5 FURTHER EXAMINATION BY MS. McKElTH 6 your efforts to survey the pool. Do you recall that? 6 MS. McKEITH: Mr. Fish, I have some 7 A. Yes. 7 follow-up questions for you this afternoon, but I will 8 Q. And you made a statement that because of 8 be brief. I believe you testified in your first day 9 you made the statement that you thought the instrument 9 of deposition that you would have been doing the 10 would be able to detect gamma radiation coming from 10 decommissioning prior to the time that the Atomic 11 the bottom of the pool based on the method that you 11 Energy Commission designated California as a licensee 12 used? 12 state; is that correct? 13 A. Yes. 13 A. I can't specifically state that because I 14 MS. McKEITH: Objection; misstates the 14 don't remember when it was. 15 testimony. He said depending on the levels. 15 Q. But if California had been a licensing 16 MR PATITERSON: Q. Based on the method 16 state, would you have done the decommissioning of this 17 that you used, do you believe that the instrument 17 site? 18 would have been able to detect gamma radiation coming 18 A. No. 19 from the bottom of the pool if the radiation was above 19 Q. So therefore we can assume that it occurred 20 the release criteria? 20 prior to the time that California became a licensing 21 MR. SHIMADA: Objection; calls for 21 state? 22 speculation. 22 A. That's true. 23 THE WITNESS: That, I don't know at this 23 Q. So if we can determine what that date was, 24 point in time. 24 then we know it was prior to that date; is that 25 MR- PATTERSON: Q. Mr. Fish, the 25 correct?

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1 decontamination of a facility at that time in 1960, 1 A. Yes. Well, they became an agreement state 2 '61, it was not intended to remove all the residual 2 in September of 1962. 3 radioactive contamination on the property; is that 3 Q. Okay. So, for purposes of your answer to 4 right? 4 Mr. Shimada's question about when you recall doing the 5 A. That's correct. 5 decommissioning, it would have been before September 6 Q. Radioactive materials could remain on the 6 of 1962; is that correct? 7 property as long as it's determined that whatever 7 A. You reach that conclusion that way, yes. 8 levels were remaining were not posing a risk to 8 Q. That's a fine way to reach a conclusion. 9 occupants of the properties; is that correct? 9 The Geiger-Muller, is it possible for the 10 MS. McKEITH: Objection; misstates the 10 Geiger-Muller to be saturated if it comes into contact 11 testimony to the extent that materials were buried on 11 with very high levels of gamma ray emissions? 12 site. 12 A. Very high levels, yes. 13 THE WITNESS: The answer is yes. 13 Q. In the event that it comes in contact with 14 MR. PATTERSON: Q. And Ms. McKeith just 14 very high levels, what happens to the Geiger-Muller? 15 referred to materials that might have been underneath 15 A. It can go to zero. 16 the ground, subsurface materials that were buried. At 16 Q. Now I recognize that you're a very 17 the time there was no requirement on your part to 17 competent individual, and you were probably quite 18 conduct subsurface testing; is that right? 18 experienced when you did the survey. Is there any 19 MR. SHIMADA: Objection; the question is 19 possibility that because of the levels of 20 vague 20 contamination that were detected that the 21 MR. PATTERSON: Q. Let me rephrase that. 21 Geiger-Muller went to zero and you interpreted that is 22 There was no requirement for you to conduct subsurface 22 a nondetect? 23 testing unless your instruments showed there was 23 A. No. 24 radioactivity coming from that area above the release 24 Q. I want to draw your attention again to 25 criteria. In that instance, there may be some need to 25 000305, and you'e correct that the highlighted blue

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read from previously, in fact, did not 1 Q. Mr. Donaldson testified that it came in 1 area that you 2 liquid10-12-99 form also? holes. But if you go down to the 2 reference the ten 3 A. Can be in liquid form also. and read - do you see the 3 last paragraph of that page 4 Q. So how do you know whether thsis liquid the ten holes down there? Begins with 4 reference to 5 or solid form that's being referred to? "in the floor of the enclosure." 5 the sentence, 6 A. Because if we're talking about sealed 6 A. Yes. 7 sources, were talking about powder form because of 7 Q. Could you read that sentence, please. 8 physical size. In other words, the source needs to be 8 A. "In the floor of the enclosure are ten 9 as small as possible and liquid is - takes up much 9 two-inch holes extending six feet below grade designed 10 more room than the powdered form. 10 for the storage of up to," looks like, "500 curies 11 Q. Do you know one way or the other whether or 11 Each hole is topped by a remotely removable each. 12 not Isotopes Specialties Company had liquid cesium 137 storage shelves," something, "beneath. 12 lead plug with 13 on their premises? 13 two-foot thickness shielded enclosure is designed The 14 A. I do not, no. 14 the handling and transfer of up to 100 curies of for 15 Q. I believe you testified previously that the 15 cesium 137 in a bottle at a time." 16 Atomic Energy Commission would inspect a licensee site 16 Q. You don't remember these ten holes when you 17 such as Isotopes Specialties Corporation approximately 17 went out to the facility; is that correct? 18 once per year; is that correct? 18 A. I do not remember them. 19 A. Well, we had a system that was -- the 19 Q. If somebody had disposed of cesium 137 in 20 inspection frequency was related to the activities 20 the first foot at the bottom of this hole, and then 21 that were permitted under the license. And my best 21 covered it up with the 5 feet of concrete, do you 22 guesstimate at this time is that that kind of a 22 believe your Geiger-Muller would have detected that 23 situation would be on the order of once a year. 23 contamination? 24 Q. And that's based upon your review of the 24 A. It would have to be an awful lot of cesium 25 Isotopes Specialties Corporation license that's at 25 down there for me to detect it through that much 270 272

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concrete. 1 issue in this litigation? 1 2 A. Certainly, what was permitted by the 2 Q. What do you consider to be an awful lot? 3 license would be a major factor in the determining the 3 Over what limit? 4 frequency. 4 A. Well, probably, talking hundreds of curies. 5 Q. Would it be correct to say that there was 5 Q. Well, how much physical space does - this 6 an element of trust, then, that your licensees were, 6 document here refers to - here meaning 000305, refers 7 in fact, reporting honestly when they had a release at 7 500 curies. How much physical space does 500 to 8 the facility? 8 curies of liquid cesium 137 take up? 9 A. Yes, there is an element of trust in it 9 A. First of all, cesium would be in a powder 10 Q. Can you tell us what Mr. Goldstein's, the 10 form. Typically, cesium chloride, and that's not very 11 president of Isotopes Specialties Corporation and 11 big volume. 12 ultimately the president of U.S. Nuclear, reputation 12 Q. The 500 curies, how much mass are we 13 was at the Atomic Energy Commission? 13 referring to? 14 MR. SHIMADA: Objection; lacks foundation, 14 A. Probably, that part of my thumb. 15 calls for speculation. 15 Q. You)re referring to your nail and maybe to 16 THE WITNESS: Well, I only knew 16 the first knuckle? 17 Mr. Goldstein in association with U.S. Nuclear. 17 A. Yeah. Its not very big. 18 MS. McKEITH: Q. What was your opinion of 18 Q. So if one were to leave in the holes 19 his handling of radioactive materials at U.S. Nuclear? 19 something the size of what you just described - your 20 A. My opinion of Mr. Goldstein was that some 20 thumb to your knuckle - it would fit well within that 21 of the activities could lead to philosophies involved 21 first foot of space? 22 in the activities. They could lead to violation of 22 A. Yeah, that's a two-inch diameter space. 23 the regulations. 23 Q. You indicated that cesium 137 is in powder 24 And what were those philosophies? 24 form? Q. 25 A. Well, one I remember is Alan said thathe 25 A. Typically, its in powder form, yes. 271 273

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1 thought that the regulation permitted him to expose 1 what their view of the Isotopes Specialties' 2 people up to the limits, whereas the proper radiation 2 operations were? 3 safety opinion is you keep the exposures as low as 3 A. No, I did not. 4 possible in addition to being below the limit. 4 Q. I showed you previously one inspection 5 Q. Did you think he was a-- strike that. 5 report from Mr. Mason? 6 What other philosophies did you differ with 6 A. A letter from Mr. Masont 7 Mr. Goldstein. if any? 7 Q. Correct Are those the kind of violations 8 A. Well. that was the main philosophy, and it 8 that would have given you pause in terms of deciding 9 wasn't only exposure. That philosophy was with 9 whether or not the operator of a facility had or had 10 respect to all of the regulations. I mean, the 10 not properly reported to the AEC when there were 11 regulations said that he could do up to this. And 11 releases of contamination? 12 from a radiation safety standpoint, you do as low as 12 MR SHIMADA: Objection. The question is 13 you can below the limits, and you aren't in violation 13 vague, calls for speculation. 14 if you go up to those limits. 14 THE WITNESS: You mean the draft on Exhibit 15 Q. Did you personally consider Mr. Goldstein 15 21? 16 trustworthy? 16 MS. McKElTH: Q. Yes, exactly. 17 A. There were times when I had some questions. 17 A. Well, of course Exhibit 21 applies to 18 Q. Could you give us some examples of those 18 Isotopes Specialties Company. 19 times? 19 Q. That's crect. rm referring to them. 20 A. I guess I really cant give you specific 20 A. Some of the things here are in that 21 examples now. I can tell you that we made an 21 category. 22 unannounced inspection in the early part of the year. 22 Q. And notwithstanding that fact, you never 23 came in unannounced on a Monday, and we were informed 23 did any special investigation at that facility beyond 24 by Mr. Goldstein that we couldn't have picked a poorer 24 just doing sturface readings during your 25 time to come because they had moved radioactive waste 25 decommissioning?

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1 that previous weekend. And when we did our inspection 1 A. Isotopes Specialties facility? 2 and surveys, we found contamination in areas that 2 MR- PATFERSON: Objection - 3 shouldn' have been, including out on the front 3 MS. McKeith: That's correct. 4 sidewalL 4 MR. PATTERSON: Misstates his testimony 5 Q. The front sidewalk, meaning where 5 considerably. 6 pedestrians walk? 6 THE WITNESS: No, I didn't do anything 7 A. Yes. 7 special as a result of my feelings about 8 Q. Did you have your attitude - was your 8 Mr. Goldstein. 9 attitude about Mr. Goldstein formed prior to the time 9 MS. McKE1TH: Q. No. I mean in terms of 10 he was - had moved to the Lake Street location? 10 the violations 11 MR. PATTERSON: rm sorry to 11 A. Oh, the violations? 12 MS. McKEITH: Q. When you were 12 Q. Yes. 13 decommissioning the Isotopes Specialties facility, did 13 A. No, I didn't. 14 you already have your opinion of Mr. Goldstein formed? 14 Q. Would the Atomic Energy Commission have 15 A. My opinions about Mr. Goldstein were 15 permitted occupancy by a nonlicensee at that facility 16 generated as a result of his relationship with U.S. 16 prior to terminating the license? 17 Nuclear. 17 A. No. 18 Q. So prior to that time, you did not really 18 Q. Now we had a series of documents that were 19 know that Mr. Goldstein pushed the envelope, so to 19 shown to you with respect to Research Chemical, the 20 speak? 20 first of which was a license that you, in fact, 21 A. I had never met Mr. Goldstein prior to his 21 signed; it was the two-page document? 22 forming U.S. Nuclear. 22 A. The inspection report? 23 Q. When you began to conduct your 23 Q. No. Yeah, it was a compliance inspection 24 decommissioning survey at the Isotopes Specialties 24 repol. 25 Corporation, did you inquire of other people at AEC 25 A. That was an inspection report.

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24 (Pages 274 to 277) Raymond F. Fish, Jr. 10-12-99 I Q. Have you seen any documents here today that 1 in the regulatior 2 And we don't have those regulations? lead you to conclude that license No. C-4013 had been Q. 3 A. No, but that would, you know - anything tenninated? 4 permitted. It would put an upper A. No, I haven't seen anything that lead - under that would be 5 limit on the amount of the percentage - amount of except from my conclusions that the site was - I made 6 thorium present. a confirmatory survey and the process would be to send thorium in a source the report to headquarters. and then there were no 7 Q. So if it had 50 percent it would have been under a different subsequent inspections prior to turning it over to the 8 material, example of how the State of California that I can recall. 9 license; is that kind of an would Q. I understand that. What I'm referring to 10 regulations of source is Exhibit 23. Exhibit 24. and I believe Exhibit 22. 11 A. It wouldn't meet the definition These documents that Mr. Brown had shown you that were 12 material be something else. dealing with the percentage of 13 Q. Any longer. It would MR. BROWN: Mr. Fish. I believe it's 14 Can you tell from C-4013 whether this was a general Exhibit 19. It was the long pages that she's 15 license or specific license? a specific license. referring to. 16 A. C-4013 is differ from THE WITNESS: Oh, yeah. Well, that's the 17 Q. And how does a specific license inspection report 18 a general license? that a MS. McKEITH: Q. And then we had a letter 19 A. A general license is a license fact that it was being dated May 1961 to Research Chemical Corporation. 20 person has by virtue of the A. It's these two. 21 written in the regulations. It would, for instance, be a Q. I thought it was 23 and 24. 22 there might be a general license, and there would that a person MR. BROWN: You previously marked the 23 number assigned to it, and it would say of source THE WITNESS: Yeah, it's Exhibit 23 and 24. 24 could possess maybe up to three pounds MS. McKEITH: Q. Is there anything in 25 material That would be a general license. A person

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1 these letters that lead you to conclude that Research 1 wouldn't have to make an application to the commission would just have it by 2 Chemical Company's license had been terminated? 2 for up to that amount. They in the 3 A. No, not in these documents. 3 virtue of the fact that it being written 4 Q. Now, in Exhibit 19, the long document, it 4 regulation. That's a general license. asked you whether your 5 indicates 5,000 pounds of thorium source material in 5 Q. Mr. Patterson had that, in fact, 6 the form of residues for processing. And we went 6 decommissioning was based upon a survey the survey results of Isotopes 7 through an exercise whereby you calculated where you 7 was intended to confirm that was 8 thought a portion of the residue material - what 8 Specialties Corporation and you indicated correct? 9 percentage of thorium was in that portion. Is there 9 of our survey. 10 anything in the documents that you've seen that would 10 A. That's the intent not conduct a survey 11 have prevented - that designated the percentage of 11 Q. If Mr. Donaldson did area of the site, 12 thorium that was permitted in a pound of source 12 for the Research Chemical Company's 13 material that would have been on the property under 13 on what would you have been relying? 14 C-4013? 14 A. If that facility was part of what was being if 15 A. Would you repeat that rm not sure I 15 released, we would have surveyed it ourselves even 16 understand what your question is. 16 he had not have had anything 17 Q. Sure. That's okay. I think Mr. Brown was 17 Q. Okay. But you would not 18 trying to demonstrate what a small percentage of 18 to rely on to confirm the results? recollection is that 19 thorium was in a pound of thorium that was on the 19 A. That's true, but my by the 20 property. What rm asking is: Is there anything in 20 all of the areas that I surveyed were covered 21 the license that would have limited the percentage of 21 survey report that was submitted. know 22 thorium that could be in a pound of thorium source 22 Q. Is there any possibility, you 23 material under these licensing 23 Research Chemical Corporation and Isotopes Specialties 24 A. In these licenses, it would have been 24 Company were divided by a wall Is there any a wall that 25 limited by the definition of source material which was 25 possibility - do you remember there being

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1 divided the building that you were in9 1 Q., Could you reference Exhibit 19 one more 2 MR. BROWN: Objection: asked and answered. 2 time? It's the long document I guess it's being 3 THE WITNESS: No. As I stated earlier, 3 called. I believe it's underneath that pile you're 4 what I remember is the back part of the building was 4 holding right there on top. I believe it's this one 5 all open. There were no walls there. 5 here. 6 MS. McKErIH: Q. And you're certain that 6 A. Okay. 7 was the entire building as opposed to there being any 7 Q. It has an expiration date on that document 8 other portion that was contiguous to the portion that 8 under the license. Does that mean that the license 9 was all open? 9 did not have to be terminated? 10 A. Yes. 10 A. It had an expiration date of May 31, 1959, 11 Q. It's a mystery. 11 and what that means is that he either has to renew 12 MR. PATTERSON: The mystery walL 12 that license to maintain it, or if there were no 13 MS. McKEITH: Q. Can you tell me how many 13 application for renewal, the Commission would have 14 conversations you had with Greg Patterson at Ptoskauer 14 made inquiry with respect to the status of the 15 Rose or anyone who works for Mr. Patterson? 15 facility and would have, you know, asked questions 16 A. Oh, boy. rve had quite a few. 16 about whether they had any materials and things like 17 Q. More than ten? 17 that. So there would have been a follow-up action on 18 A. Probably in that ballpark. 18 the part of the licensing people if there was not a 19 Q. Can you remember how many conversations you 19 renewal application. 20 had with Loeb & Loeb? 20 Q. Were there any follow-up activities if 21 A. At least two or three. 21 there was not a renewal application on the part of the 22 Q. Are you still intending to sign the 22 licensee? 23 declaration that was being drafted for your signature 23 A. I don't know. 24 by Mr. Patterson? 24 Q. You don't know or you don't recall? 25 A. I don't know. He hasn't asked me to. 25 A. I don't recall.

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I MS. McKE1TH: I have no further questions 1 Q. Would that - whether or not there was, 2 at this time. 2 would that depend on the questions presented to them 3 FURTHER EXAMINATION BY MR. PATTERSON 3 by the AEC? 4 MR. PATTERSON: Q. Ifl could jump in 4 A. It could You know, Ijust don't know 5 since rve got the mike on. Just to try to narrw 5 there are different points in time, and so I don't 6 this time period when you may have conducted your 6 have any information of what happened when the 7 confirmatory sampling. Is it fair to say you would 7 licensee was faced with this date. I would suspect 8 not conduct a confinnatory sampling after Isotopes 8 there would be correspondence on the matter between 9 Specialties'licenses had been terminated? 9 licensing and the licensee. 10 A. No. The survey would have to have been 10 Q. Generally, though, when that license 11 before the licensing people would terminate the 11 expired, the licensee would not have to do anything 12 license. 12 assuming they did not apply for a renewal, they did 13 Q. And since this was brought up, could you 13 not have to do anything to have the license 14 tell me what Mr. Richard Donaldson's reputation was at 14 terminated? 15 the AEC? 15 A. No, except that the issue of the cleanup of 16 A. Within our office, Mr. Donaldson had a good 16 the facility and the disposal of any material would 17 reputation. 17 have been raised and there would have been a final 18 Q. Was he considered trustworthy? 18 survey made. 19 A. Yes. 19 MR. BROWN: All right. Thank you. 20 MS. McKEITH: Unlike Mr. Goldstein. 20 FURTHER EXAMINATION BY MS. McKEITH 21 THE WITNESS: Yes. he was. 21 MS. McKEITH: Q. I have a couple more 22 MR. PATTERSON: No further questions. 22 questions. Isn't it a condition of the license that 23 FURTHER EXAMINATION BY MR. BROWN 23 when the license is being terminated, there be a 24 MR. BROWN: I have one quick question, 24 decommissioning of the facility that's been a licensed 25 Mr. Fish. 25 facility?

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MR- PATTERSON: I don't have any further 1 A. No. 1 2 questions. 2 Q. Were the regulations that were in place at 3 MR. SHIMADA: I don't have any further 3 the time, did they require that there be a 4 questions. 4 decommissioning when there was a termination of a 5 VIDEO OPERATOR: Here marks the end of 5 license? Videotape No. 5 in the deposition of Raymond Fish. 6 A. No, the regulations didn't require that 6 7 will be retained by Video 7 Q. You testified earlier that a site that had The original videotapes 8 Solutions at 50 First Street, San Francisco, 8 a license to utilize isotopes would, in fact, be off the record the time on the 9 decommissioned; is that correct? 9 California. Going 10 monitor is 3:56. 10 A. When the licensee no longer intends to do 11 MR. PATTERSON: Back on the record. Pose a 11 any activities there, then he would ask permission to 12 stipulation that both days of Mr. Fish's testimony, 12 terminate the license and that would trigger the 13 be sent directly to Mr. Fish 13 process. both original transcripts Mr. Fish will have 30 days to read 14 Q. And if a licensee failed to ask permission 14 for his review. provide my office with 15 to terminate, would the AEC have followed up to find 15 the deposition transcripts and 16 testimony. That I will thereafter 16 out why subsequent to a termination or an expiration any changes to that of any changes that 17 they hadn't heard from anybody? 17 inform all of other counsel makes to his testimony. And that the court 18 A. Yes. If the expiration date occurred and 18 Mr. Fish to retain the 19 there had been no correspondence or contact from the 19 reporter be relieved of her duty 20 and that the original be maintained at my 20 licensee, the Commission would have taken action to original will lodge it with the court or do 21 follow up on that 21 office, and that we 22 to do with the original based on 22 Q. Are you aware of the fact that whatever else we need 23 Mr. Donaldson was not on the site throughout the time 23 the parties requests. MS. McKE1TH: So stipulated. 24 period that the survey was conducted - that he 24 So stipulated. 25 conducted the survey? 25 MR. BROWN:

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1 A. No, rm not aware of that. 1 MR. SHIMADA: So stipulated. (Whermupon, the deposition was 2 Q. You said that Mr. Donaldson had a good 2 3:56 p.m.) 3 reputation, and I think you indicated that 3 adjourned at 4 Mr. Goldstein did not share such a good reputation. 4 -oOo 5 rm not misquoting 5 penalty of perjury that 6 A. The reputations of those two individuals 6 I declare under 7 were not the same. 7 the foregoing is true and correct Subscribed at 8 Q. Are there other individuals who worked for 8 , California, this day 9 Isotopes Specialties Company who did not share 9 of. 1999. 10 Mr. Donaldson's good reputation? 10 11 MR. SHIMADA: Objection; lacks foundation, 11 12 calls for speculation. 12 13 THE WrTNESS: Since I didn't - my 13 14 association with Mr. Goldstein and Mr. Donaldson were 14 15 primarily from U.S. Nuclear. 15 16 MS. McKE-IT: Q. I understand. So at 16 Signature of the witness 17 U.S. Nuclear, were there people who didn't share 17 18 Mr. Donaldson's good reputation? 18 19 A. Not that I can remember. Ijust - those 19 20 two I can remember, and I know there were other people 20 21 there, but I can't comment about that because I don't 21 22 remember them specifically - specifically enough to 22 23 answer the question. 23 24 MS. McK : Thank you very much for your 24 25 time, Mr. Fish. I donl have any more questions. 25

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1 CERTIFICATE OF REPORTER 1 SIGNATURE AND ERRATA SHEET 2 2 3 (To be signed by deponent) 4 I, JULIE ANNE ZEIGLER, a Certified 3 5 Shorthand Reporter, hereby certify that the witness in 1,RAYMOND FISH. do hereby declare under the 4 6 the foregoing deposition was by me duly sworn to tell penalties of perjury that the foregoing testimony is 7 the truth, the whole truth and nothing but the truth 5 8 in the within-entitled cause; true and correct (with the exception of the following 9 That said deposition was taken down in 6 changes listed below): 10 shorthand by me, a disinterested person, at the time 7 11 and place therein stated, and that the testimony of Page Line Change/Correction Reason 12 the said witness was thereafter reduced to 8 9 13 typewriting, by computer, under my direction and 10 14 supervision; 11 15 I further certify that I am not of 12 16 counsel or attorney for either or any of the parties 13 14 17 to the said deposition, nor in any way interested in 15 18 the event of this cause, and that I am not related to 16 19 any of the parties thereto. 17 18 20 19 21 DATED: 1999. 20 22 21 Executed this __ day of - 1999, 23 22 At 23 24 24 25 JULIE ANNE ZEIGLER, CSR 9570 25 RAYMOND FISH

290 292

1 1 November 15. 1999 2 Raymond Fish 2 SIGNATURE AND ERRATA SHEET, 12 Dotal Drive 3 (To be signed by deponent) 3 Morass.CA 9 ,556 4 Re: Joseph and Vrgmna Thomson vs. ICN 4 I, RAYMOND FISH. do hereby declare under the Pharmacu cas. Inc.. et al.

5 penalties of perjury that the foregoing testimony is Dear Mr. Fish: 6 true and correct (with the exception of the following 6 Please be adviwDd that the original umfript of your 7 changes listed below): 7 deposition taken November 8. 1999 in the above-enuttled miter is available for reading and 8 Page Line Qtange.Correction Reason a a ing. After eading at sgning the erigmal. 9 please send the original oal your corretions to the 9 offices of: 10 10 Proskalaer Rose L'P 11 AtnmC regcsy 1. Panerson It 2049C smnrayPark EasmSuite 3200 12 LosAn Seles, CA 90067-3206 12 13 for thirty (30) di ys in accordance with FederalRules 14 13 of CivilProced ee Section 30(e). If you do not sigp your dqto•i• within 30 days, it may be utse as 15 14 fully as thoughlssimgt 15 If youawerep oSed by coetasel in this mattar, you 16 Maywish to ask your assey bow to proceed If you 17 16 weenotrepresms ai by co•nsel madwish to review your tratKript, Ptea Soacts our office for a muntally 18 17 conveieapt aumnent to review your depositicn. 18 fTsankycu for y our cooperation in this matter. 19 19 20 Sisemely your. 20 21 Executed this __ day of. 1999, 21 22 Julie Anne Zei* C.CSR9570 at 22 23 23 cc-.Original wa GREGORY. L PATtVERSON.Attorney at Law 24 24 IOHN H.SH IMADA. Attorney at Law 25 RAYMOND FISH MALISSAIHATHAWAY McKEITH. Atnoney at Law 25 BRYAN K BROWN. Attorney at Law

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Raymond F. Fish, Jr. 10-12-99

T T T A AEC 238:15 242:21 293:11 213:17,24,25 214:1,4 195:9,17 196:1 232:17 293:7 able 190:2 211:5,8 248:11 260:4,13,16 animal 205:24 214:7 222:2,2 243:15 217:8 233:15 237:9 260:18 275:25 276:10 anne 182:23 185:19 263:4 267:24 270:1 Avenue 186:17 240:13,21 241:9 283:15 285:3 286:15 290:4,25 293:21 281:12 aware 193:9 207:2,15 256:20 258:20 261:19 AEC's 229:9 another 190:9 197:4 areas 196:9 199:22 208:17,20 214:3 266:10,18 after 187:9 199:22 213:25,25 231:17 205:21 221:4,16,21 215:13,13 217:12 about 194:19 195:3 219:20 265:13 283:8 249:17 250:1 256:6 237:17,22,25 238:2 227:7 229:4,7 234:6 199:11208:7 211:9 293:8 answer 187:16,18 243:2 275:2 281:20 286:22 287:1 216:18 224:23,24 afternoon 262:6 268:7 188:11 189:4 190:20 arm 237:3,10 away 248:19 268:1 awful 270:24 271:2 225:11,21 226:16,18 again 196:19 197:3 194:6 196:20 198:9 around 226:15 230:7 226:20 232:17 234:1 227:25 249:21 256:20 207:12 208:5 223:19 233:18 265:25 B 234:2,4 235:2 237:10 257:7 260:1 269:24 225:8 229:3 231:8 arrival 207:25 208:13 241:21 244:14 248:10 agency's 228:11 240:17 241:9 243:5 art 195:7 back 203:7 213:4,6,12 252:20 255:17 258:12 ago 191:3 244:19 245:1 250:11 265:18 asked 190:17 208:11 218:21 220:16 224:7 260:7 269:4 272:6,7 agreement 269:1 267:13 269:3 287:23 225:10 229:18 245:3 226:4 233:2 241:18 275:9,15 277:7 ahead 197:3 203:15,17 answered 247:12 282:2 247:12 262:8 281:5 243:15,18 249:12 284:16 287:21 205:20 222:25 226:10 answers 231:21 282:2,25 284:15 253:9 262:3 265:15 above 224:13 254:7 252:7 257:9 anybody 286:17 asking 198:7,8 205:9,10 282:4 288:11 266:19 267:24 air 240:20 anyone 208:11 234:25 226:16,18 279:20 background 246:7,10 above-entitled 293:7 al 293:4 235:5 282:15 asphalt 193:17 243:15 246:10,13 247:5,8,18 absence 242:11 Alan 273:25 anything 191:24 196:3 248:22 249:1 backup 223:6 access 229:12 246:13 allowed 210:23 211:3 197:18 198:12 222:25 assigned 280:23 backyard 207:19 256:16 259:15 223:5 224:13,15 associated 225:19 213:17 214:5,8 accident 194:23 allowing 188:6 225:21 238:23 242:9 Associates 246:1 bad 206:13 accordance 293:12 allows 211:12 218:11 242:25 277:6 278:4 association 273:17 badge 221:1 according 224:5 252:21 almost 223:1 230:9 278:25 279:10,20 287:14 ballpark 282:18 accumulated 234:19 alone 264:7 280:3 281:17 285:11 assume 204:24 268:19 barrels 213:1,3 246:15 247:21 along 243:14 285:13 assumed 258:25,25 based 220:15 223:19 accumulation 246:23 alpha 196:4,6,9,10,11 apart 244:23 248:9,19 assuming 214:24 226:12 240:8 243:6 accuracy 218:4 196:13,21 197:10,12 apologize 226:10 244:2 232:23 256:1 258:23 254:15 255:25 263:12 accurate 236:12 197:15,20 198:2,16 266:1 285:12 266:11,16 272:24 across 233:22 198:20 199:6 201:17 apparently 247:11 assured 234:21 281:6 288:22 action 189:10,14 201:20,21 202:3 appeared 185:20 186:5 Atomic 189:9,17,22 basically 213:25 253:3 284:17 286:20 217:4,19 218:14,16 186:9,14,19 190:13,25 191:11 basis 232:14 actions 189:1 218:17,19,20,24 appears 257:14 194:20 199:5,11,17 Bates 203:5 activities 189:20 191:9 already 196:23 248:10 applicable 244:22 202:21 205:8 219:17 Bates-stamped 183:15 219:16 272:20 273:21 262:7 265:6,9 275:14 application 202:19 222:12 228:2 229:20 184:5,7 273:22 284:20 286:11 although 260:10 258:9 281:1 284:13 268:10 272:16 273:13 bays 243:18,22 activity 194:24 195:1 aluminum 266:2 284:19,21 277:14 bearing 264:22 200:3,25 217:21 always 218:5 applications 203:2 attached 202:19 206:13 became 229:4,7 268:20 218:1,9 238:21 amazingly 191:2 applied 198:10 199:1 236:14,15 239:5 269:1 246:22 259:15 ambiguous 242:14 230:17 242:4 before 185:19 194:8 actual 232:2 246:9 265:5 applies 276:17 Attachment 183:14 205:3,6 226:8 230:11 256:17 amendment 261:12 apply 285:12 attempt 231:7 252:11 230:12,13 233:24 actually 193:16 206:12 America 183:19 applying 256:17 attention 197:6 203:5 234:14 244:5 247:14 207:19 218:23 222:14 amount 200:2 204:1 appointment 293:17 205:18 208:15 212:21 269:5 283:11 227:19 235:19 240:24 209:20 211:20,23,24 approximately 192:8 222:5 269:24 began 275:23 255:14 215:4 218:9 233:4,15 196:13 201:4 203:25 attitude 275:8,9 begin 187:4 226:5 add 236:20 240:4,21 247:3 211:5 212:24 213:3 Attn 293: 10 249:14 262:4 addition 206:4 274:4 256:22 280:5,5 281:2 214:21 215:5 236:14 attorney 186:4,8,14,18 begins 186:22 239:9 additional 237:20 amounts 238:21 236:17,18 240:14 290:16 293:15,23,24 249:11 270:4 address 210:17 analyses 234:18 255:4 272:17 293:24,25 behalf 186:5,9,14,19 adequate 213:11,14 analysis 193:2 194:5 approximation 255:19 attributable 246:25 being 190:8 201:24 240:4 analytical 192:20 255:20 256:3 August 184:7 257:8 209:19 214:3 222:18 adjourned 289:3 analyzed 192:19 • area 191:9,14 192:4 261:11,15 227:7,9 229:23 230:9 advise 248:11 analyzing 194:1 205:19 206:1,2,3,17 authority 228:2 244:10 230:16 231:4 235:14 advised 293:6 and/or 188:17 206:20,22,23 207:10 automatic 218:22 236:9 244:22 248:17 Angeles 186:3,7,12,17 207:15,19,22 213:4,6 available 192:9 193:20 256:20 258:8,12,14 ...... I...... Combs & Greenley, A LegaLink Company (415) 512-1234 Page 2

Raymond F. Fish, Jr. 10-12-99 I 220:18,19 247:2,4 clearer 252:6 200:10,17 201:3,6 brown 183:7 186:16,18 cases 206:5,8 207:25 238:2 262:13 272:5 274:4 247:20 clearly 220:9 281:3,14,25 211:17 249:15,16,17 238:6 248:20,22 280:20 cast 203:20 climb 235:24 250:1,4 254:2 255:2,6 249:1 270:21 271:1 282:7,23 284:2 category 276:21 close 205:2 245:11 255:9,15,18 257:6 condition 223:12 285:23 cause 290:8,18 closed 205:6,11 208:12 200:19 259:9,17,20,25 238:23 285:22 believe 196:23 cavity 203:20,21 closedown 189:7 203:7 261:18,21 278:12,14 conditions 198:10,13 200:22 202:21 cc 293:23 cobalt 204:2 240:5,9,10 232:11 250:15 278:23 279:17 282:2 conduct 193:3,6 195:17 230:6 CENTRAL 182:3 240:19 241:4 266:17 283:23,24 285:19 232:18 267:18,22 260:15 261:3 185:3 collect 192:18 268:8 270:22 272:15 288:25 293:25 275:23 281:11 283:8 Century 186:6 293:11 collected 207:7 251:21 278:11,14 284:3,4 BRYAN 186:18 293:25 conducted 189:15 certain 188:6 199:12 colored 246:2 193:11 203:23 building 199:13 205:23 194:9,15 205:3 207:9 below 217:10 250:21 257:20 combined 261:3 251:17 206:4 213:4,6,21 207:21 210:12 212:14 204:24,25 282:6 come 248:14 254:1,15 252:4 259:4 270:9 214:11 215:2 224:12 213:11,21 214:6 Certainly 273:2 274:25 274:4,13 291:7 292:6 242:18 243:10,14 215:14 216:22 229:24 CERTIFICATE 290:1 comes 254:12 255:11 below-floor 204:22 247:24 248:1 282:1,4 229:25 283:6 286:24 Certified 185:19 290:4 269: 10, 13 below-grade 205:2 282:7 286:25 certify 290:5,15 coming 218:10 226:4 beneath 199:15,24 built 224:18 conducting 194:21 cesium 241:11,13,14,17 249:12 262:3 266:10 270:12 Burbank 210:18 218:23 227:15,20 270:15,19,24 271:8,9 266:18 267:24 best 237:8 272:21 burial 189:18,23,25 234:2,24 235:6 271:10,23 272:12 commencing 185:16 beta 195:8,18 196:22 190:7,9,13,19,24 263:10,24 CFR 252:21 258:1,1 comment 287:21 200:6 201:19 217:5 191:5 confirm 238:20 263:14 change 230:19,21,22 commission 189:9,17 217:20 218:21 buried 188:22 189:8,11 263:25 264:2 265:22 232:3 238:23 261:14 189:22 190:13,25 betas 217:6,8 190:6 238:15 267:11 281:7,18 changed 230:8 191:12 194:21 199:5 Bethesda 187:25 228:3 267:16 confirmatory 187:24 changes 230:16 232:8 199:11,17 202:21 228:18 229:5,10 bury 187:14 188:3,9,16 189:13 226:24 227:16 232:12 252:11 261:19 205:8 206:15 219:17 228:25 burying 188:7 190:12 229:12 232:18 235:7 Bethesda's 288:16,17 291:7 220:20 222:12 229:20 195:9,16 business 229:8 235:14 238:19 239:15 better 292:6 238:24 258:10 263:15 between 191:12 192:3 Byran 249:16 242:23 244:23 246:12 Change/Correction 264:3 268:11 272:16 200:4,16 204:6 206:6 263:10,23 264:1,6 C 291:8 292:7 273:13 277:14 281:1 230:15 252:17 258:6 265:11 278:6 283:7,8 Chemical 211:1 212:11 284:13 286:20 258:16 262:25 285:8 c 259:13 confirmed 264:24 212:17,19 277:19 Commission's 228:3 beyond 276:23 CA 293:3,11 265:20 278:20 279:2 281:12 company 187:1 188:9 271:11,17 calculated 258:22 226:16 big 281:23 189:8 207:3,24 confuse birth 210:13,13 279:7 connection 188:21 chemicals 184:4 210:17 208:11,25 211:2 bisgaard 185:17 186:11 calculation 255:25 196:17 200:19 209:13 216:16 256:8 257:7 219:11 272:12 276:18 bit 226:19 265:25 california 182:3 185:3 243:7 247:24 260:3,16 281:24 287:9 219:16 blue 269:25 185:19 186:3,7,13,17 connotation 234:17 Chief 216:1 Company's 279:2 body 202:2,4 262:10,12 187:2 210:18 268:11 conservative 255:22 chip 193:25 209:16 281:12 262:14,14,18 263:2,5 268:15,20 278:9 256:2 268:1 competent 269:17 both 217:6 229:20 288:9 289:8 consider 220:22 221:10 chipped 238:2,6 complete 250:3,4,6 288:12,13 call 229:5 222:7 223:16 271:2 chipping 209:15,25 compliance 183:16 bottle 270:15 called 185:23 222:14 274:15 248:19 220:6,10 222:11 bottles 251:22,23,23 225:9 284:3 considerably 277:5 chloride 271:10 277:23 252:8,13,15 260:24 Calling 197:6 198:3 220:4 circumstances 188:6 computer 290:13 considered bottom 235:21,23 calls 201:10 205:16 220:20 223:9 283:18 190:10,12 194:20 concentrations 221:14 240:22 241:5 249:23 207:11 208:4 220:8 contact 269:10,13 Civil 293:13 221:21 250:23 266:11,19 270:20 222:9 223:20 225:2 286:19 293:16 clarified 261:15 concern 199:16 Boulevard 186:2 247:12 253:19 261:7 contacted 224:22 clarify 259:7,9 concerned 199:11 boxes 223:12 266:21 273:15 276:13 contain 229:10 251:24 cleaned 263:14 265:1 224:24 225:10 boy 282:16 287:12 252:8,15 265:21 concerning 239:14 branch 216:1 222:11 came 272:1 274:23 contained 203:2 214:4 cleanup 190:14,14 conclude 278:2 279:1 244:9 capable 214:22,25 228:25,25 229:11 196:12,15 197:9 concludes 249:7 break 226:3 249:10,19 215:8 216:23 244:25 256:3 201:18 219:3 232:2,3 conclusion 205:16 262:2 carbon 216:20,25 217:6 212:25 232:9 244:10 245:7 269:7,8 containers breathed 202:6 226:25 227:2,4,10,12 216:3 262:25 264:8,21 conclusions 278:5 brief 268:8 career 190:25 257:22 285:15 concrete 193:21,23 containing brisbois 185:17 186:11 case 212:9,16 218:18 203:21 205:23 226:17,19 194:1 199:24 200:6 contains brought 283:13 228:19 259:3 clear 220:19 I Combs & Greenley, A LegaLink Company (415) 512-1234 Page 3

Raymond F. Fish, Jr. 10-12-99

T T 244:8 262:14 238:9,10 239:2 271:4,7,8,12 239:24 240:2,13 270:22 contaminated 193:22 240:15 242:7 243:11 customers 207:4,7 deeper 237:10 detecting 195:8 214:22 208:21 215:17 243:15,19 244:19 cut 202:7 249:23 defendant 182:12 215:9 216:23 contamination 192:10 246:22 247:5,22 CV-97-5220 182:8 185:23 186:9,15,19 detection 195:18 195:4 196:4,7,9,10,13 264:8,14 267:5,9 185:8 226:9 249:18 216:17 232:16 196:21 197:10,16,25 268:2,12,25 269:6,25 cylindrical 203:20 Defendants 185:12 detector 200:4 214:24 198:2 199:23 200:1 270:17 272:18 273:5 C-14 227:10 Defendant's 245:21 217:25 218:1 226:23 200:20,23 201:18 276:7,19 277:3 281:9 C-4013 278:2 279:14 257:3 259:22 233:6,9,21,22 235:23 202:3 209:14,18 286:9 289:7 291:6 280:14,16 define 198:19,21 236:1,10,15,21 237:4 214:23 215:9,12 292:5 defined 242:22 237:9 240:18 241:4 216:8 217:11 218:15 corrections 293:8 D definition 260:20,21,25 246:11 247:9 233:10 237:15,21 correctly 226:22 D 183:1 279:25 280:11 detects 233:3 240:19 241:5,6 correspondence 197:19 damage 201:20,21,24 Delaware 182:10,10 deterioration 193:14 242:12,17 245:14,16 285:8 286:19 Daniel 183:23 185:10,10 determinations 243:4 267:3 269:20 270:23 couched 229:22 date 186:23 210:13,13 demonstrate 209:4 determine 188:22 275:2 276:11 counsel 186:5,9,14,19 219:25 230:1 231:2 279:18 189:10,11 192:9 contaminations 216:23 187:18 197:4 226:13 231:25 268:23,24 depend 240:23 285:2 268:23 content 257:16 288:17 290:16 293:15 284:7,10 285:7 dependent 200:2 233:5 determined 267:7 contents 261:19 293:16 286:18 depending 193:1 201:1 determining 273:3 context 192:1 226:19 counseled 218:20 dated 183:18,21,23 266:15 di 238:20 contiguous 282:8 count 193:1 196:8 184:5,7 256:8 257:7 depends 246:14 diagram 227:12 239:19 continue 187: 10 201:14 217:13,23 260:1 278:20 290:21 deponent 291:3 292:2 diameter 271:22 continued 183:14,15 218:10 249:25 day 229:19 242:4 244:4 deposed 212:16 differ 274:6 280:17 184:1 counted 196:6,11 268:8 289:8 291:21 deposited 201:23,24 differed 196:15 197:10 convenient 293:17 201:16 217:16 218:19 292:21 202:1 difference 207:8,13 conversations 282:14 218:21 days 288:12,14 293:12 deposition 182:16 231:5 247:8 258:6,16 282:19 counting 217:19 293:13 186:23 195:3 200:5 different 191:17,21 conversion 247:16 counts 217:17,19,20 dealing 278:13 201:13 204:6 207:18 198:11 245:4,9,14 convert 218: 11 218:12 234:19 246:15 deals 257:15 214:10 222:10 231:11 246:17,19 262:19 cooperation 293:18 246:23 247:16,21 dealt 198:20 231:23 242:4 244:4,25 280:8 285:5 copied 206:16 couple 285:21 237:18 245:25 249:8,12 differentiated 191:12 copies 206:14 course 222:16 227:14 Dear 293:5 265:2 268:9 288:6,15 262:12 copy 183:17 196:19 229:8 276:17 December 231:14 289:2 290:6,9,17 differentiation 191:25 197:5 202:16 206:14 court 182:2 185:2 245:15 293:7,13,17 differentiations 192:2 213:1 225:4 228:22 202:17 288:18,21 deciding 189:22 276:8 depth 190:8 239:20 directed 237:17 229:6 231:11 239:8 cover 214:1 declaration 282:23 240:3 direction 290:13 242:1,3 243:25 244:3 covered 207:24 248:12 declare 289:6 291:4 describe 191:20 195:11 directly 194:11 288:13 244:3 250:1,3,4,7 270:21 281:20 292:3 described 199:20 223:2 discussed 213:20 252:5,10 covers 197:21 decommission 213:12 271:19 248:17 254:14 cord 236:13,14,17,18 crack 193:14 decommissioned 187:9 describes 23 1:1 discusses 221:20 251:23 236:21 cracks 193:18 225:1 286:9 description 183:12 discussions 248:15 core 192:17 create 250:8,16 decommissioning 184:2 230:20,23 257:19 corporation 182:10,10 created 250:13 187:15,20,22 188:18 design 203:25 disintegration 218:9 182:11,11 183:19,22 creates 201:20,21 188:21 189:6,16 designated 199:5,15 disintegrations 197:17 185:10,10,11,11 creating 201:24 190:18,23 192:2,3 268:11 279:11 197:19 218:13 186:15 187:14 188:3 criteria 188:1 189:21 194:9,11,18 196:5 designed 203:24 270:9 disinterested 290:10 196:17 202:20 203:3 192:6 196:16 197:10 202:23 205:3 206:9 270:13 dismantling 224:16 204:14 208:16 215:15 197:20 198:9,17 209:15 212:6,10,15 detail 240:17 disposal 209:22 214:17 226:9 272:17,25 224:15 230:17 232:3 213:7 224:14,23 details 214:9 258:11 285:16 273:11 275:25 278:20 232:4,9,14 237:20,21 230:18 268:10,16 detect 195:4 196:4 dispose 215:16 281:8,23 244:11 245:2,7 269:5 275:13,24 215:5 217:8 246:12 disposed 209:4,25 correct 187:23 190:19 262:25 263:15 264:8 276:25 281:6 285:24 266:10,18 270:25 270:19 193:25 199:10 202:24 264:21 265:1,3,21 286:4 detectable 247:19 disposing 208:25 204:15,25 208:18 266:20 267:25 decommissionings detected 215:11 216:14 distance 240:21 245:12 209:18,21 212:8 CSR 182:23 290:25 194:15 216:19,20 217:1,4,5 245:12 224:20,21 228:4 293:21 decontamination 217:17 226:25 227:1 distances 199:13 232:20,24 235:20 cumulative 221:8 199:22 263:24 267:1 227:4 241:4 246:6 245:11 236:3,6 237:15 238:3 curies 203:25 270:10,14 deep 236:8,16 237:4 247:4,10 269:20 distinction 258:20

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Raymond F. Fish, Jr. 10-12-99

DISTRICT 182:2,3 243:14 236:2,10 287:22 244:19,25 245:20,20 212:18,19 214:12 185:2,3 duly 185:24 290:6 entire 219:14 236:5 245:22,25 249:20 219:21,24 220:5 divide 254:6 dumped 216:4 265:7 282:7 257:2,4 259:18,19,21 224:17 226:25 227:8 divided 281:24 282:1 duplicate 228:12 entirely 229:9 259:21,23,25 263:1 228:3 229:2 232:14 dividend 254:10 263:23 entitled 183:14,16 265:2 276:14,17 235:2,10 238:22 Division 216:1 during 209:15 221:4 envelope 275:19 278:11,11,11,15,24 241:15 242:10 263:14 divisor 254:11 222:12 227:14 230:15 equal 232:24 279:4 284:1 265:21 267:1 270:17 document 183:14,16,20 235:6,14 239:14 equation 254:3,14 exhibits 183:11,13,22 273:8 275:13 276:9 203:5 204:10,11 244:4 248:15 276:24 equipment 183:14 184:1,3 230:24 242:4 276:23 277:1,15 205:18,19 206:12 duty 288:19 195:8,9,17 196:1 existence 229:7 281:14 284:15 285:16 210:20 216:2 227:14 d'amato 185:17 186:11 199:24 212:23 218:5 expect 238:24 285:24,25 229:4 241:22 244:1 234:3 expectation 245:6 fact 188:22 189:17 249:23 250:7,9,13,16 E ERRATA 291:2 292:1 expected 238:14 245:13 190:11 191:5 206:15 256:7 257:1 271:6 e 183:1 184:6 259:13 essence 264:2 246:11 247:8 248:11 207:2 208:17,20 277:21 279:4 284:2,7 each 203:22,25 221:8 essentially 230:9 248:14 209:25 215:13 216:3 documentation 209:10 228:15 270:11,11 established 263:1 expecting 218:14,15 224:25 229:25 237:13 228:17 earlier 187:19 201:17 estimate 255:22 258:22 experience 227:11 243:21 259:14 264:5 documents 202:19 204:3 209:16 212:4 et 293:4 254:16 264:7,18 265:6 270:1 209:4 227:9,19,21,23 258:23 266:5 282:3 Eugene 184:4 experienced 269:18 273:7 276:22 277:20 228:7,22,24 229:10 286:7 evaluation 207:16,17 experimental 205:23 280:20 281:3,6 286:8 242:21 265:10 277:18 early 193:21 195:10,18 even 194:17 199:4 expiration 284:7,10 286:22 278:1,12 279:3,10 209:9 233:19 274:22 236:4 241:8 253:25 286:16,18 factor 273:3 doing 194:2,4 202:23 earth 192:18 260:10 281:15 expired 285:11 failed 264:7 286:14 212:18 217:9,13 East 186:6 293:11 event 269:13 290:18 explain 198:15 250:19 fair 199:17 226:20 226:15 234:18 237:1 effect 262:18 every 196:8 228:16 262:24 283:7 237:13 254:17 268:9 effects 250:22 Everything 218:5 expose 274:1 familiar 219:17 269:4 276:24 effluent 221:22 223:11 evidence 248:21 exposed 193:15 far 237:6 238:5 240:17 Donaldson 212:14,16 223:13 exact 235:17 exposure 199:21 fast 234:21 272:1 281:11 283:16 effluents 221:15,21,25 exactly 224:4 226:16 201:21 221:2,3 223:4 fax 206:16 286:23 287:2,14 222:1 237:5 252:17 256:21 224:13 262:16,19,21 features 208:12 Donaldson's 283:14 efforts 266:6 276:16 263:4 274:9 Federal 293:12 287:10,18 Eighteen 202:11 EXAMINATION exposures 223:2 274:3 feelings 277:7 done 191:9 202:16 either 194:11 202:5 183:3,5,6,7,8,9 187:5 expressed 265:1 feet 206:6 214:21 215:1 207:17 224:16 234:19 284:11 290:16 226:6 249:15 262:5 extended 238:6 215:3 236:19 237:11 237:6 249:19 258:13 element 273:6,9 268:5 283:3,23 extending 270:9 239:20 240:6,12,15 263:8,23 264:1 elevated 237:14 285:20 extension 236:21 262:13,17,22 270:9 268:16 eliminate 192:24 examined 185:25 extent 188:24 189:3,4 270:21 Doral 293:2 eliminated 261:16 example 192:5 199:24 193:14 194:25 207:15 fell 236:11 dose 221:8 262:11,12 emissions 269:11 217:13 280:9 214:2 215:18 242:16 fence 206:24 262:13 263:2 emit 201:5 examples 274:18,21 265:5 267:11 fenced 206:3 213:4,6 doses 221:6 emitter 217:4 exceed 197:8 257:17 extrapolate 255:10 214:4 dots 246:2 emitters 218:16 exceeded 221:2,8 260:6 extremities 262:13 fenced-in 206:22 double 206:5,7 employed 187:1 235:1 except 242:16 278:5 263:5 few 262:8 282:16 down 193:11 224:12 235:5 285:15 extremity 262:13 fewer 214:8 236:5 237:3,7 238:5 employee 221:2 235:11 exception 233:13 291:6 e-f-f-l-u-e-n-t-s 221:15 field 216:6 240:17,22 270:2,4,25 empty 238:9 292:5 Figueroa 186:12 290:9 enclosure 270:5,8,13 exceptions 261:4 F figure 246:1,2,6,14,20 DOYLE 186:16 end 205:19 288:5 excess 209:19 F 182:17 185:21 247:2,11 254:18 draft 183:20 219:10 energy 189:9,17,22 excuse 196:25 244:7 faced 285:7 figuring 254:22 276:14 190:13,25 191:11 254:21 258:1 facilities 183:14 204:24 file 188:25 202:22 drafted 282:23 194:20 199:5,11,17 Executed 291:21 205:1,3 211:15 203:1 228:22 239:14 drains 214:13,14 202:21 205:8 219:17 292:21 212:22 229:21 230:10 243:6 draped 237:3 222:12 228:2 229:20 exempt 257:23 230:18 flies 228:9,10,12,15,18 draw 205:17 222:5 240:20 268:11 272:16 exercise 279:7 facility 194:22,24 228:19,25 229:1,10 269:24 273:13 277:14 exhibit 197:1,2 202:13 196:18 203:19 204:4 229:11 Drawing 203:5 208:15 ENERSEN 186:16 210:3,5 215:20,22,25 204:5,8,12,13,17,22 filled 248:11 Drive 293:2 engaged 222:17 216:16 219:6,8 231:8 205:24 206:10 207:4 Film 221: 1 driveway 207:17 enough 190:2 226:20 239:8 241:18 242:5,6 207:10 210:15 212:11 final 219:12 265:20

Combs & Greenley, A LegaLink Company (415) 512-1234 Page 5

Raymond F. Fish, Jr. 10-12-99

T T 273:14 287:11 226:23 232:17 233:2 255:21 259:1 205:21 269:25 285:17 Grand 186:17 him 225:12,17 255:7 find 217:15 218:14,15 four 216:23 231:1 233:3,20 234:13 Greg 262:7 282:14 274:1 286:15 Francisco 185:18 187:2 240:14 246:11247:9 gregory 186:8 293:10 hold 234:16 269:8 228:20 288:8 247:20 264:13 266:1 fine 255:9 293:23 holding 284:4 firm 244:2 frankly 226:11 269:9,10,14,21 grid 213:21,23 214:2,7 hole 203:25 270:11,20 first 185:24 187:12 Fred 184:6 270:22 gross 192:25 217:17 holes 203:7,9,22 204:4 192:23 197:23 203:10 frequency 272:20 273:4 general 187:17 189:24 ground 267:16 204:7,12 248:12 222:10 239:13 242:3 freshly 249:1 190:3,5 199:21 group 222:15,24 270:2,4,9,16 271:18 244:4 247:23 251:18 Fresquez 183:23 256:15 257:20 258:7 GSA 251:8 honestly 273:7 253:4 260:8 268:8 from 183:18,20,23 258:13,16 259:8,14 guarantee 228:21 hot 205:1 270:20 271:9,16,21 184:4,6 187:10,21 280:14,18,19,22,25 guess 194:3,6,17 195:11 hour 197:9,14 232:19 277:20 288:8 190:9 192:17,25 281:4 198:9 204:20 208:5 233:4,5 247:21 fish 182:17 183:23 194:24 196:15,25,25 generally 191:20 209:11 215:6 217:3 hundred 232:25 185:21 186:23 187:6 197:7,11,25 198:4 285:10 223:17 237:5 240:5 hundreds 271:4 226:7 229:17 241:25 199:9,13,14 201:13 generated 209:14 216:8 243:5 245:1 246:14 hundredth 232:22 242:3 243:25 245:24 204:2 206:14 207:4,7 219:20 220:5 275:16 249:18 250:10 252:17 Hydrogen 216:20,25 249:3,8,12,16 250:6,8 215:25 216:17 218:11 germane 217:18 253:18 256:15 261:21 217:6 256:7 261:22 262:7 219:11 220:17 222:1 getting 234:9 256:16 264:9 265:14,18 266:25 268:6 278:14 223:11 224:3 227:24 give 196:20 202:15,16 I 230:8,25 231:16 218:1 226:19 231:17 274:20 284:2 283:25 287:25 288:6 185:9,23 234:9 239:1 241:19 252:23 254:9,12 guessed 245:4 ICN 182:9 288:13,14,18 291:4 293:4 242:21 244:2,3,23 274:18,20 guesstimate 272:22 186:9 291:25 292:3,25 idea 255:13 246:1 247:16 248:9 given 213:9 214:21 guidelines 200:9 244:12 293:2,5 183:11 248:19 251:8 253:17 215:7 229:2 233:6,23 244:22 identification Fish's 288:12 184:1 202:14 210:6 271:20 254:15 255:11 256:7 234:13 246:21 247:7 fit H 215:23 219:9 245:23 five 240:15 252:14 256:8 257:7,23 261:5 247:11 255:23 276:8 H 186:13 293:24 257:5 259:24 floor 185:18 197:8 262:12 266:10,19 gives 234:17 253:23 212:2 identified 189:2 216:7,9 199:13 204:5 205:1 267:24 270:1 274:12 glass 266:2 half 211:11,12 240:14 216:16,24 261:16 239:5 270:5,8 276:5,6 278:5 280:14 glove 223:12 215:5 229:19 231:12 identifies 227:12 flow 217:24 280:17 286:17,19 GM 247:19 266:1 hand 287:15 go 197:3,4 202:7 handle 212:5 identify 216:21 217:11 follow 226:14 286:21 II 182:20 286:15 front 231:12 239:8 203:15,17 205:19 handled 228:2 followed 233:20 imagine 241:16 following 244:8 291:6 241:20,23 242:7 212:6 222:25 225:25 handling 224:19,25 immediately 244:16 292:5 246:3 247:25 258:19 234:20 235:23 237:4 270:14 273:19 225:4 262:13,16 important 217:21 follows 185:25 275:3,5 241:18 249:5 250:6 hands full 241:22 252:7 257:9 261:23 262:22 impression 199:9 follow-up 231:23 268:7 inaccurate 234:9 284:17,20 fully 293:14 269:15 270:2 274:14 handy 231:9 184:4 further 183:5,8,9 187:5 going 187:10 197:3 Hanford 191:15,19 inc 182:9,11 foot 201:3 206:5,5,7 185:9,11,24 186:10 215:5 270:20 271:21 223:4 225:23 237:23 202:9,15,18 205:17 192:5 186:20 212:11 293:4 force 208:8 262:5 268:3,5 283:1,3 214:25 215:24 217:15 happened 191:3 285:6 inches 197:7 214:25 289:7 290:6 283:22,23 285:20 226:1,10,11 239:7 happens 269:14 foregoing 236:18 291:5 292:4 288:1,3 290:15 242:2 243:22,24,25 happy 196:18 226:18 included 188:25 220:20 222:3 F2 252:22 249:8 256:6 257:1 hard 220:17 223:7 form 197:13,15 263:18 245:4,9,14 251:12,13 261:25 265:4,25 224:3 including 224:16 242:5 271:10,24,25 272:2,3 G 288:9 HATHAWAY 186:4 249:22 275:3 272:5,7,10 279:6 G 183:14 Goldstein 183:20 293:24 increments 233:4 formal 234:1 gamma 195:8,18 273:17,20 274:7,15 having 185:24 204:18 264:9 independent 189:10 format 231:3,3,22,24 196:22 200:6 201:19 274:24 275:9,14,15 223:2,6 262:17 INDEX 183:3 231:25 232:1,5,6 217:20 218:21 240:20 275:19,21 277:8 headquarters 242:22 indicate 210:20 257:14 formed 275:9,14 246:6,12,20,25 247:3 283:20 287:4,14 243:1 278:7 indicated 221:1 225:11 forming 275:22 247:10 266:10,18 Goldstein's 273:10 heard 286:17 226:8 263:18 271:23 found 208:7 228:18,18 269:11 good 187:6 191:2 255:7 height 240:14 281:8 287:3 237:14 275:2 gammas 217:5 262:6 283:16 287:2,4 held 201:25 indicates 220:9 239:19 195:21 gas 217:24 287:10,18 her 288:19 foundation 247:3 279:5 201:10 205:15 208:3 gaseous 223:17 grade 204:24 270:9 high 209:17,19 240:19 indication 252:24 211:18 216:12 220:7 Geiger-Muller 195:3,7 grams 252:9,13,18 269:11,12,14 individual 201:22 222:9 223:20 225:15 199:14 200:22 214:22 253:7,14,15,21,23,24 higher 262:21 235:13 229:15 247:13 261:8 215:4,8 216:6,13,17 253:25 254:5,8,9 highlighted 203:16 212:14 232:14

______I_____ I______h Combs & Greenley, A LegaLink Company (415) 512-1234 Page 6

Raymond F. Fish, Jr. 10-12-99

T r T ______I I -I 192:16 194:5,10,16 kind 198:21 240:17 least 240:6 255:25 286:5,8,12 269:17 licensed 209:5 285:24 194:21 214:1 217:18 246:17 249:21 252:23 282:21 individuals 182:6 185:6 licensee 192:3 210:16 230:10 235:9,14,16 257:16 259:16 272:22 leave 233:6,9,23 234:13 187:8 221:4 235:16 271:18 225:5,6 251:7,9 287:6,8 273:21 276:7 280:9 legal 205:9,16 265:20 268:11 272:16 inform 288:17 irradiation 205:24 kinds 230:8 LegaLink 187:1 284:22 285:7,9,11 information 224:3 isotope 217:18 Kleber 184:4 legally 208:6 286:10,14,20 234:9 285:6 isotopes 187:13 188:2,9 knew 273:16 length 195:2 236:1,5,13 licensees 191:8 228:13 informed 187:25 189:7 191:23 196:17 know 187:16 188:2,8 237:10 273:6 237:19 274:23 202:20 203:3 204:14 189:21 192:21 194:7 lesser 250:22 licensee's 190:1 243:7 initial 210:14 234:24 207:3,24 208:11,16 197:18 208:6 211:9 let 204:23 214:5 227:24 264:2,4 263:9 208:24 215:15 216:1 213:18,23 217:2,13 231:7 233:2,17 licenses 211:22 230:9 ink 252: 10 219:11,21 244:9 218:9 221:17,19 267:21 279:24 283:9 inquire 275:25 272:12,17,25 273:11 223:18,18,21,23 letter 183:18,23 184:4,6 licensing 216:2 222:24 inquiring 226:20 275:13,24 276:1,18 227:5 230:1,11 231:5 196:16,19,23,24 225:5 227:9 228:1,7 inquiry 284:14 277:1 281:7,23 283:8 236:4,25 240:5 241:6 197:3,5 198:12 257:24 261:5 268:15 inside 202:2,3 214:11 286:8 287:9 247:17,20 249:22 199:10,16,18,20 268:20 279:23 283:11 243:10,22 isotopic 193:2 253:6,21 254:23 219:10,13,14 284:18 285:9 insists 212:16 issue 273:1 285:15 256:23 258:12 260:23 215:25 219:18,20,24 220:5,9 light 224:25 inspect 272:16 issued 258:10 266:3,23 268:24 222:19 230:25,25 like 191:18,19 192:17 inspection 189:3,20 Item 197:6,21 198:16 272:4,11 275:19 231:4,5,10,14,15,20 206:14 212:1 213:2 210:11,14 219:21 223:3 280:3 281:22 282:25 231:23 241:19 242:9 217:23 219:13,25 222:14 223:7 272:20 items 231:1 262:20 284:15,23,24 285:4,4 244:1,7,13,16,18,24 220:3 237:6 252:9,10 274:22 275:1 276:4 287:20 J knowing 241:3 261:18 245:2,3,15,15,19 253:4,5,7,8 256:24 277:22,23,25 278:18 262:15 270:10 J 186:8 293:10,23 knowledge 209:24 256:7,9 257:6,21 259:13 inspections 204:17,18 284:16 James 183:18 216:1 known 205:11 207:6 260:1 261:1,2,2,4,11 222:18 278:8 201:5 227:1,3 January 183:18 215:25 knuckle 271:16,20 261:13,15,17 265:23 likely inspectors 234:6 243:3 274:4 280:5 241:19 244:18 245:2 276:6 278:19 limit 271:3 installation 191:16 190:6,7,11 JOB 182:23 L letterhead 183:19 limitations 192:5 234:7 instance 221:8 233:23 john 186:13 226:8 lab 227:10,12 letters 279:1 191:15 225:25 limited 279:21,25 240:12 267:25 280:21 293:24 label 252:22 let's 259:20 limiting 199:21 instantaneous 246:16 joseph 182:6 185:6 laboratory 192:21 234:4 251:4 197:7,13,14 limits 187:22 196:21,21 instructions 187:21 187:7 293:4 labs 205:1 level 199:15 201:18 207:8 201:25 221:3,20 instrument 195:12,13 jr 182:17 183:23 lack 201:10 247:13 185:21 lacks 195:21 205:15 209:19 218:4 219:4 224:14 232:16 262:19 195:13 218:3,12 262:21 274:2,13,14 266:9,17 julie 182:23 185:19 208:3 211:18 216:11 233:11 246:21 257:12 264:13 line 202:10 203:13 234:7 290:4,25 293:21 220:7 222:8 223:19 levels 199:11,25 201:5 instrumentation 240:22 252:1,3 291:8 292:7 267:23 jump 265:25 283:4 225:14 229:15 261:8 209:17 237:14 instruments lined 206:5,8 281:7 jumping 226:11,15 273:14 287:11 242:18 245:10 247:10 intended 267:2 lip 237:3 282:22 just 190:3 201:8,12 Lake 275:10 247:17 266:15 267:8 intending liquid 222:3 223:14,18 286:10 207:16 209:11 213:5 language 244:17,24 269:11,12,14,19 intends 271:8 272:2,3,4,9,12 intent 199:20 28 1:10 216:24 219:3 221:13 large 191:15 211:6 lewis 185:17 186:11 230:25 231:4 232:4 230:10 license 202:19 203:2 liquids 221:23 interested 290:17 list 216: 10 interference 192:24 232:22 236:1 245:5 larger 245:12 256:25 206:13 210:18,19,21 listed 291:7 292:6 interior 239:20 247:23 245:14,15 249:21 last 187:10 195:2 200:5 210:22 211:3,21 litigation 273:1 248:3 254:10,14,17 255:12 201:13 204:6 207:18 212:1,5,7 223:13 little 226:19 265:25 201:23,24 258:15 259:7,11 214:10 231:21 238:8 228:15,17 251:1,2 internally LLP 185:18 186:2,6,11 202:1 261:2 262:8 267:14 256:9 270:3 256:15,17,25 257:20 186:16 293:10 interpret 197:22 221:24 271:19 276:24 281:2 Later 231:1 258:4,7,9,10,13,16,17 local 228:19 229:1 223:14 283:5 285:4 287:19 Law 186:5,8,14,18 259:5,8,14,16 260:4 located 191:13 192:4 interpretation 198:16 J.D 183:18 215:25 293:23,24,24,25 260:13,16,19 261:5 213:4 199:18 lawsuit 226:10 249:18 272:21,25 273:3 location 275:10 interpreted 269:21 K lead 203:21,23 236:1 277:16,20 278:2 locations 242:22 investigation 207:9 K 186:18 293:25 270:12 273:21,22 279:2,21 280:9,15,15 locked 206:3 276:23 Kber 184:4,6 256:8 278:2,4 279:1 280:16,17,18,19,19 lodge 288:21 involved 187:20,24 257:7 leads 230:5 280:22,25 281:4 loeb 186:2,2 282:20,20 189:20 190:18,19,23 keep 228:12 274:3 leaked 215:7,10 283:12 284:8,8,12 long 233:6,21 234:12 190:24 191:4 192:14 kept 228:15 leaned 237:2 285:10,13,22,23

Combs & Greenley, A LegaLink Company (415) 512-1234 Page 7

Raymond F. Fish, Jr. 10-12-99

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Combs & Greenley, A LegaLink Company (415) 512-1234 Page 8 Raymond F. Fish, Jr. 10-12-99

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Raymond F. Fish, Jr. 10-12-99

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. & ______Combs & Greenley, A LegaLink Company (415) 512-1234 Page 10

Raymond F. Fish, Jr. 10-12-99

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Combs & Greenley, A LegaLink Company (415) 512-1234 Page 11

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Combs & Greenley, A LegaLink Company (415) 512-1234 Page 14 Raymond F. Fish, Jr. 10-12-99

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Combs & Greenley, A LegaLink Company (415) 512-1234