ML20096F931

Transcript of EP Stergakos 840824 Deposition in Hauppauge,Ny Re Emergency Planning.Pp 1-49.Related Correspondence

ML20096F931
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Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	08/24/1984
From:	Stergakos E LONG ISLAND LIGHTING CO.
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Text

F ORIGINAL e ,

UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION

'llhWd'"

In the matter of; LONG ISLAND LIGHTING COMPANY 4 SfP'7 Aff @

Docket No.50-322-OL-3 (Shoreham Nuclear Power Station, . 1-Unit 1) 1 4

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Deposition of: Elias P. Stergakos l

Location: Hauppauge, New York Pages: 1 - 49 Date: Friday, August 24, 1984 l

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l pV TAYLOE Assoc!ATES Court Reporters 1623 i Satset. N.W. Swee 1004 washinston, D C. 20006 e mti 293-MM l k90 0 T

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Corrections to Deposition Transcript of Dr. Elias P. Stergakos, Dated August 24, 1984

. Loc a tion -Change page 1, line 16 Change "Stergokos" to "Stergakos" page 6, line 14 Change "McCaffery" to "McCaffrey"

- page 6, line 21 Change "Eddie" to "Ed" page 7, line 11 Change " Cold shutdown." to >-

" Cold shutdown?"

page 7, line 13 Change "or" to "and"

.page 8,,11ne 4 Add "are" after " consequences" and add "them" after "have"

page 9,.line 15 Change "that".to "if" page. 9, line 16 Add a comma after " events" page 10, line 15 Change "Randals" to "Randles" page 10, line 16 . Change "part" to " group" page 12, line 16 Change "at" to "of" page 16, line 14 Change " reflects" to " reflect" page 19, line 13 Change "115" to "15" page 23, line 22 Change "say" to "said" page 26, line 14 Add a comma after " evaluation" page 2.9, line 9 Change " don't" to "have only" page 33, line 13 Change "Any" to "In the" page 41, line 11 Change "my to "mine"; add "is" before "not"; and add "a" after "not"

-page 43, line 9 Add "not" after "do" page 45, line 12 Change "Tunay" to " Tunney" page 45, line 14 Change "Tunay" to " Tunney" page 45, line 15- Change "Tunay" to " Tunney" page 45, line 16 Change "Tunay" to " Tunney" page 46, line 16 Change "Tunay" to " Tunney"

.page 46, line 17 Change "Tunay" to " Tunney"

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1 3 Ulliti;D STATI:S OF AMI:RICA NUCLI: Alt it!? DOI.AToltY COMMISSION i N K[ rci) 2 "W

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, p in t.fio Ma t to r o f  : Docket. No. 50-322-01,-

IMNG ISI.AND I,1GitTING COMPANY

(1:mo rgoney . I'lann i ng 7

Procotturon)

(Shoreham Nuclear Power Stat.lon, '

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, Unit 1) 9 /. .................................

10 DI POSITION OF Et,I AS l'.11TEltGAK0!1

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11. I.co Donn i non llulltling illnth Ploor 13 Votorann Memoral liighway llauppaugu, New York 11707 Pri<1ay, Augunt 24, 1904 14 Doponi t ion of' 1:1,I A!! P. STI:ltGOKOS , callect for 17 oxaminnt.lon by counnot for lho intorvonor, takun bororo 18 Mary filmonn, Court Itoportor, buyinning at 10:20 a.m.,

19 purnuant to noreomont of counnol.

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[ '1' APPEARANCES:. , i' -i. j<'

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2 on Behalf'of the Applicant:

.. ,,l'f,, : ; ;( @ ~ r .1 3' LEE B. ZEUGIN; ESQUIRE ( 1 Hunton & Williams-

-4 707 E. Main Street-Richmond,. Virginia 23212

'S On Behalf of~ the Intervonor, Suf folk County:

4 CHRISTOPHER M. McMURRAY, ESQUIRE'

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7 MICilAEL S. MILLER, ESQUIRE -

Kirkpatrick,'Lockhart, 11111, ' Chris topher & .Phillips 3' 1.900 M Street, N.'W.-

Washington, D. C..20036

, 6 On Behalf of the Nuclear Regulatory Commission

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BERNARD BORDENICK, ESQUIRE

11. Office of Executivo Legal Director ,

Nuclear Regulatory Commission #

,12 ' Washington,' D. C.,.20555 -

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mWITNESS EXAMINATION BY _ -PAGE 3 .

ELIAS-P."STERGAKOS -

s 4 e By.Mr. McMurray 4'

. 1- By Mr. Zeugin *

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Whereupon,

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3 ELIAS P. STERGAKOS 4

the deponent, was called for examination by counsel for 5

Suffolk County and, having been first duly sworn by the 6

Notary Public, was examined and testified as follows:

MR. McMURRAY: Let the record reflect that this 8

deposition is being taken pursuant to the rules of 10 CFR 9

and pursuant to agreement among the parties.

r' EXAMINATION

-~'

11 BY MR. McMURRAY:

~I O Sir, would you please state your name and spell it 13 for the record?

14 A Dr. Elias.P. Stergakos. E-1-i-a-s P. Stergakos, 15 S-t-e-r-g-a-k-o-s.

16

-Q Mr. Stergakos, you are the Manager of the Radiation 17 Protection Division at LILCO?

18 A Correct.

19 0 What is your relation to Mr. Rigert within the

. ,) N structure of LILCO?

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A We are at the same level.

!, 3 22 .

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(,) _ 5 j{~ . _ _1 Q -You are at the same level.

2 I am looking right now at your. affidavit which 3 'was-submitted on August 3rd, 1984. Do you have that?

4 Ji Yes,-I do.

5- -Q When youisay you have the overall responsibility-

-6 for-the corporate overviewgand technical direction'of all 7 aspects of radiological protection in the design of rad waste 8 systems, could you be a.little b'it mo're specific about-your 9' duties and responsibilities?

10 A. Well, I am responsible ~ for-the; engineering' -

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11 aspects which pertain'to radiological consequences, systems,

.12 - et cetera.

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13 Q You are resonsible, for instance, for determining ,

'id 'what the onsite and offsite consequences of accidents would 15 be?- ,

16 A' Yes, I am responsible to determine it, or lett others 17 determine it for us.

18 How long have you been with LILCO?

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19- Ai One year'.

3(,3,) lE Q And you came from Burns and Roe, is that correct?-

.21! A Correct ~. .

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Q '22 TQ7 rc <, , Mr.iStergakosl(whendidyou.first-see-theBoard's

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,'e } 1 July 24th memorandum and order regarding the strike issues?

2 A I cannot recall exactly, but I will say within 3 three or four days. I cannot say exactly.

4 O Who gave you the memorandum and order?

5 A I do not remember who gave it to me. I simply 6 do not know. Most likely my supervisor, but I can't remember 7 how I came by it. Or it could have been through the licensing 8 people. Most probably it came from the licensing people.

9 Q When you say the licensing people, who are you 10 referring to?

11 A The LILCO personnel who are responsible for

.12 licensing affairs.

13 0 What specific people are you referring to?

14 A Mr. Grunseich or Mr. McCaffery, either one of 15 those two persons could have given it to me. I can't recall.

16 0 Once you received the memorandum and order, were 17 you asked to do something about it?

18 A Yes. I was asked to look at it and evaluate 19 the subject matter from my field.

_j 20 0 Who asked you to do this?

21 A It was my supervisor, Mr. Youngling. Eddie

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(_)' 22 Youngling, simultaneously'of course with the licensing people.

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U 1 Q And did Mr. Youngling ask you to do this at 2 approximately the same time you first saw the document?

3 A Yes, right.

4 Q Could you be more specific with respect to what 5 Mr. Youngling asked you to do?

6 A Evaluate the problem pertaining to the radiologi-7 cal consequences as is questioned in this Board's questions 8 here. Look at all aspects ---

9 Q Look at all aspects of the consequences that 10 could occur if there was an accident during cold shutdown?

11 A Cold shutdown. Look not only at cold shutdown, 12 but start from.the beginning, in other words, from the

'- 13 operation or the consequences and go down step by step and 14 determine what the consequences would be, which leads down 15 to cold shutdown, et cetera. You look at the problem.

16 0 When you say look at the problem, was he asking 17 you to look at all consequences that could arise if there 18 was an accident at Shoreham at full power and then at low 19 power?

J 20 A Look at the consequences period, yes. I had-21 to determine.where to start and that was it.

22 O Well, are you saying then that you have done a

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( ') i consequence analysis for accidents at full power?

2 A No. I did not do an analysis at full power. I 3 looked at that and I determined'that at full power the 4 consequences as we have at the documents which exist at LILCO, 5 the FSAR, for example.

6 Q Did you look at the Pickert, Lowe and Garrick 7 consequence analysis?

8 A I looked at that, but I did not spend much 9 time when I looked at it. So I quickly was led to the 10 conclusion that I would go to cold shutdown and see the conse-

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11 queces of that position.

12 Q So you looked at the Board's concerns and you 13 concluded quickly that it would be a good idea to go to 14 cold shutdown during a strike?

15 A Yes.

16 Q What was the basis for your decision?

-17 A The criteria which I stipulate in my affidavit 18 to keep the doses to the pubIIc one rem whole body and five 19 rem. thyroid.

20 0 Let's start from the beginning. Once you 21 received instructions from Mr. Youngling, what did you do?

) 22 A -What did I do? I looked at all my references ,

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T 1 of course starting from the FSAR, NUREGs, NEPA documents, L. ;

2 standard review plans, et cetera, pertaining to the subject

-3 matter, _and as a good engineer I did my job.

4 'O That doesn't exactly tell me what you did, 5 Mr. Stergakos. You went and looked at the FSAR.

6 A Yes.

7 O When you looked at the FSAR what were you looking 8 for?

9 A Mostly Chapter 15 accidents.

10 Q And what about the Chapter 15 accidents?

I  ;

11 A Well, our conclusions are reflected in our 12 affidavits.

13 Q Tell me what your purpose was in looking at 14 the Chapter 15 accidents?

15 A My purpose was to see that any of the events, 16 Chapter 15 events will not exceed the criteria which we 17 established, that is one rem whole body and five rem thyroid.

18 Q Well, is it fair to say that you first looked 19 through the Chapter 15 accidents to determine which were

,J M possible and which were not possible at cold shutdown?

21 A~ That is-true.- We looked at the whole aspects 22 of the. problems.

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1 Q Now was that one of the first1 things you did was-2 ;to look at~ Chapter 15 accidents and see which were possible 3- and which were not at cold shutdown?

4 A I assume it-~was:one of the first-things.-: Since L5J .I could~have gone tolmy office and pick'ed up a-NEPA document

~6 'or the NUREGj396.- I car,' t say yes, that was the first thing,

' 7. but it was one of the first things, yes.

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, 8' Q~ Did'you do that yourselffor did you1have someone

-9 .-else do it-for you?

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',m 10_ A. There was a group of us who_did that. I did a

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- .11 lot of work,-yes.

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.12 Q .You did a lot'of-work?

. 13 A Yes. j 14 0 Who else-was in the group?

15 l A' My associates, Dr. Beer and Miss Mary Ann Randals,,

16 .I;and of. course-from.Mr. Rigert's part.

117  ; O' Was this the group that was charged with looking t

-4 18 at the, for lack of a better word, the technical aspects

~19 - - offthe problem' brought:up by.the Board?

y) ij 20 That,;but also, specific questions that I posed-a -A 7 25 :- : y ~ "

21 upon'them.

22 Q Were- y u[the head offthis group?

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[( 21- 'A Yes, I am ..in: our work.; f rom my ' group.  :. I will not 2 isay for Mr. Rigert's group.

3 0 Once=you and:your group determined which accidents 4~ were possible,~an'd I'am' talking about Chapter 15 accidents 5; -were possible an'd_which were not possible at cold shutdown,

. 6 what-did you do then?

7 A We proceeded to evaluate the' radiological 8  : consequences.

s 19- Q Evaluate ones which were possible?

i 10 A Yes. Your' question was which'was possible. That 4 y

L11 _ was'the question, right? -Possible as-defined'in the affidavit.

12: Q In consider.ng tlie consequences of. acciden65

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A 13 'at. cold shutdown,.I.take it you looked at.the Chapter.15 14  : accidents-as defined lin the FSAR, correct?-

15 A' C'orrect.

16 .O Did you look at-any other accidents?

'17- :A. Yes. We did'look at the Class 9~ accidents.

18 - And could you explain more how you looked at: the Q

19 ' Class-9 accidents?.

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-be developed and we~came torthe' conclusion they_were not

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Q Were there any. notes or memoranda or documents

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2; that.were-produced as a result of-you or your. group's-3 -evaluation of the Class.9 accidents?

q '4 A. No.

' 5 '- 'O 'None at all?

6 A None-at all. Produced you say?

7 Q. Produced, created or developed.

'8- A In the past, no, we have.not. Not produced.

9 Q It=looks like you are sort of focusing on the 10 tword. produced. Were-any notes taken at all-.in your group's

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11 . evaluation of.the Class 9 accidents?~

.12 - A- 'No. -At thatLtime weldid not-produce and we did 13 not take any notes.. Instead there was a group discussion. -

l14 0 You.say at that time.. .HaveLthere.since been any

, 15' documents developed'regarding Class 9' accidents?.

16 - A. We are verifying our: conclusionsat'that time 17 right now.

18 -

.-Q You are?

19 . .A~ yes.

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3 So"there are now' analyses that'are being conducted

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21- ' and may, be in ,writiing at\this time?

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.They are not analyses.

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) I evaluations of our conclusion.

2 Q And what stage are they in right now?

3 A I would say approaching the end of the evaluation.

4 Q. Are they done now?

5 A No, they have not been. As I stated, they are 6 approaching the end. They are not complete.

7 Q When do you expect they will be completed?

8 A Within a day or two. Complete means ---

9 Q You mean approved and reviewed ad things 10 like that?

)

11 A Yes. We know what the conclusions are right now.

12 Q There has been a draft produced by someone of 13 this scope ----

14 A In that sense I cannot say. I know the people 15 are doing the evaluation. So they are writing -- and I 16 don't know what your definition of a draft is. So I discussed 17 their' conclusions and that is all.

18 MR. McMURRAY: Mr. Zeugin, I would like to request 19 the immediate production of all documents pertaining to

_j 20 Mr. Stergakos' or his group's evaluation of Class 9 accidents 21 which may occur at cold shutdown and any analyses regarding

_, 22 the credibility or non-credibility of those accidents, and

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.i , -als'o'any possible subcontracted' work'on those same issues.

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'MR.:ZEUGIN: :To'the' extent'they are completed,

,3 :we-will produce them- .

) 4 MR. McMURRAY: .iWell,_ ILthink to.the extent:that y

5. they' exist *right now we are requesting them. Mr. Stergakos' 6 definition of complete seems to be a document that has gone f7- through the complete review process. .We would.like anything

8 that exists now, in the form it exists now, as well as its

9. completed product, completed form, and I would like it before y; 10 the trial begins on Tuesday.

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'11~ MR. ZEUGIN:

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We will do what we can.

,12 THE WITNESS: I must correct one statement. You

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13 said Mr. Stergakos' group. It is not'my group.

14 MR. McMURRAY: Well, the group.of which 15 - Mr. Stergakos is head.

16 . Do you still have any concern about that?

17 - . THE WITNESS: No. I just wanted.to make a' 18 : ' distinction that it is'not my people.over whom I have direct 19 contr'ol'. L '

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.j MR. McMURRAY: So it.could be also Mr. Rigert's H

21 shop 'whb i^s also looking at thdt problem?

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THE WITNESS': ;It is'his group.

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a 15 Okay.

1 MR. McMURRAY

It is his group.

2 Well, I would expand the scope of my request 3 to any work being done by Mr. Rigert's group or people under 4 Mr. Rigert's command and control.

5 BY MR. McMURRAY:

6 Q Was any of the evaluation of consequences of 7 accidents at cold shutdown subcontracted out?

8 A No.

9 Q They were all done internally?

_ 10 A Correct.

l 11 Q And all done basically by the people you have 12 mentioned already, Dr. Beer, Miss Randals , Mr. Rigert and 13 yourself?

14 JL That is not correct. The Class 9 accidents are 15 done by Mr. Rigert's group.

16 Q Okay.

17 A That does not mean that there is no consultation 18 between the two groups by any means, but the physical-aspects

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19 of those things are~under Mr. Rigert's group.

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) 20 Q 'Let me focus for a minute just on the Chapter 15 21 accidents.

l. 22 A Yes.

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.1 Q When _you : looked at the Chapter 15 accidents, v{')-

2 did you accept'all the assumptions associatediwith Chapter 3 15l accidents?

4~ A Yes, as stated.in the FSAR.

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5 Q As sta'ted in the FSAR. Okay..-

26 And did you then, and I am not talk'ing about 7 going to the Class 9's, did you make any further assumptions s

8 of possible failures beyond those defined in' Chapter:15?

9 A No.

..A- 10 Q How long did it take your group to 'look at tlie-(,);

x 11 Chapter 15 accidents and determine ~their consequences at

.12 cold shutdown?

13 A I cannot give the exact number of days or weeks.

14 I guess the documents which we provided you reflects the-15 approximate date on.that Chapter 15. So that is'perhaps when 16 we finished it.

' 17 0 Well,_I-have an affidavit dated August 3rd from 18 . you and-Mr. Rigert.'

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- '19 A Yes. .

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0. Ahd3 youi arelsaying that the analysis conducted

, 21 by youg(group was completed onjor about August 3rd?

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v bl- 22 A We had the results by that time.

17

) 1 Q Did you have the results daya before that time?

v 2 A No. I think it was very close, maybe the previous 3 afternoon or something like that. I cannot say,<but when 4 the affidavit was written, we had those results and we knew 5 what we were dealing with.

6 Q And when were you first asked or notified that 7 you might be a witness in this case?

8 A I can't answer that question. I don't keep 9 track of those things.

10 0 Well, we are dealing with a fairly short time

)

11 frame, Mr. Stergakos. It was obviously some time after the 12 Board's order.

13 A Yes, it was, as soon as I was given the-task

,- 14 to proceed and evaluate the things. I would say within days 15 thereafter it became apparent that I would be testifying.

16 0 It was within days after having received the 17 Board's order?

18 A Yes,-I would say. Yes, but I can't specify 19 the number of days or day. I don't know.

) 20 Q Did you have any discussions with attorneys for 21 LILCO regarding whether or not you would become a witness in J 22 this case?

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' 11 A- The question of whether-I should become a

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2 ~ witness or not, I'did not discuss it with him,.no.

3- Q Who was it who told you you were going to be.a-4~ witness.in this case?

,5 'A Mr. Youngling.

6 Q Mr. Youngling.

7 Other than the Chapter 15 accidents'and Class 8 9 accidents,:did your group or Mr. Rigert's group or anybody

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9 at'LILCO,_to the best of-your knowledge, look at the~.conse-

,e '10 quences of_any other accidents?

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'~5 11 ' A I don't know of any other' type of accidents. You

.12 mean the definitions of the types of accidents, and I: don't-13- know what you are talking about, to be honest with you'.

'O Did you postulate any accidents besides those 14 15, which are Class 9 or which are in Chapter 157 16 A No.

117 .Q

, Did,you do any accident analyses for the consequence of' accidents'at esthicted"po'wer' levels and not just at

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.19 cold shutdown? *

)()l - 20 A. No. i l_do not know what you mean by restricted.

21 If you mean less than a hundred percent or hundred and two

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j .O- Yes.. For instance, at.various levels below a

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2 h'undred percent, say, fifteen percent or twenty percent.

3 A- No. We didn't go. steps. ~We were trying to 4 envelope the evaluations.

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5 :Q. So you.didn't look at.possible accidents.that could 6 occur in the interval between1 full power and cold shutdown?

7 A What you -are asking me'is different from what-8 you were asking me before, and I don't know where-you are 19 going now.

Pq 10 0 Well, you don't have to know where I am going.

1- 11 You just have to answer the' questions.

.12 -(Laughter.)-

13 -A. You said before at '115 :and such step . intervals, '

14 and now you jumped to coldishutdown, which'is a different 15 situation.- I'am not at any-power'at cold: shutdown. That 16 is what-I am trying to tell you. .

- 17 l -Qw+, I think.youLprobably-misunderstood me.

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A i 19 in the' transition 'from/ full? power.to cold shutdown?

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• No .' . .

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21 (Pause while counsel. confer.)'

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~ (,) 22 Q Are you now'looking at any of.the consequences i

.) 20 of accidents that could occur between full power and cold

) 1 2 shutdown?

3 A No.

4 MR. ZEUGIN: Let me make sure that question 5 is clarified, Mr. Stergakos, for a proper answer.

6 - Are you now referring to the descent from full 7 power to cold shutdown, or are you talking about intermediate 8 power levels that the plant may be run at?-

9 MR. McMURRAY: The d6 scent.

10 THE WITNESS: No, we did not look at the descent.

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11 We did not look period.

12 BY MR. McMURRAY:

13 Q What about Mr. Rigert's group?

14 A I am not-aware of them doing such a thing.

15 Q Are you aware of anyone at LILCO or any 16 subcontractors doing that work?

17 A I am not aware of such~a thing.

18 0 'I.take it from.Mr..Zeugin's clarification that 19 you or someone at LILCO is now looking at conseq'uences of

, 20 accidents at intermediate power levels?

21 A No, I don't take it as such.

s/ 22 Q And such an evaluation was not done by your group?

~# 21

(~ ; i A No. At different power levels, no, we did not J

2 do that.

3 Q Once your group completed its analyses of the 4 Chapter.15 accident consequences, what sort of memoranda or

.5 other sorts of documents were produced?

6 A Exactly what you have and nothing more.

7 O The County has received all documents produced?

8 A Yes.

9 Q Did the County receive all notes?

10 A We have no notes.

11 Q Were any internal memoranda produced?

12 A No memoranda were produced.

13 Q During the course of your group's evaluation 14 were you in contact'with the staff, the NRC staff?

15 A They called us.

16 Q They did call you?

17 A Yes.

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18 Q. Who from the.NRC staff called you?

19 A , I did not.take names down, but one gentleman's 20 name is --

21 (Witness confers with his counsel.)

22 -- it was Mr. Hodges that I remember.

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22

i O When did Mr. Hodges contact you?

v 2 A I think it was Monday or Tuesday. I don't 3 remember.

4 O Monday _or Tuesday when? There have been a couple 5 since the Board's order.

6 A Usually you refer to the last one.

7 Q Okay. A couple of days ago?

8 A Yes. That is what I recall and that is what 9 I believe is the case.

10 Q Is that the first contact that your group or 11 LILCO has had on this matter of the strike issues with the 12 staff?

13 A That is when we were contacted.

14 Q Did you attempt to contact the staff before that?

15 A No.

16 Q -When Mr.' Hodges called, what was the purpose 17 of his call?

18 JA To.ask questionc. pertaining to affidavits.

19

.CL' And what were theiquestions that Mr. Hodges q 20 asked?

21 A Questions pertaining to whether we had looked 22 further than the Chapter 15 accidents.

n -

I ir'Y 4 23

i

%d N '1 Q- ;And why did he ask you that?

V-' '

?I assume -because we do' not - .and this is zul

.2 'A a :3 assumption -- ~ we dk) not explicitly. refer.to~anything else 4 in our affidavit directly.or explicitly besides those S E, raccidents.

6; Q- Did he. express any concern about'.the fact that-7? accidents other than Chapter:15: accidents weren't referred:

8_ -to~in your affidavit?

'9 'A lha asked the question.

y,,. .10 < -Q He asked the question why they weren't there?.

( 't -

11 . Al No. He' asked'whetherswe had looked, et-cetera. .

.12 .Q. What other questions-did he ask you?

13 .A' That was it really, and we had a discussion:why 14 we did not include tho'se things, et.~cetra..

15 Q And you told him what?

. ..m. ,

y 16 ' A' $ !WeCthld'.him,Jor'..themNreally, because it was

'17 a'grouhaddI[jusEmentioned,'one'~

- s , ;.y person,'thatourevaluations s

,' . ., i, 18 - showed.that the Class 9 accidents were not credible.

' ' . v'"

' , , } l,8 s

19 --

O':' . 'And t then.what did"Mr. Hodges say to you?

h _r I) N -A LOh, we discussed the situation and we discussed 21 the' assumptions and different conditions and that is it.

yy V 22 ~We closed.and say good-bye.

N

___/ 24 Q Did Mr. Hodges advise you to do anything?

~./

2

_A No. I mean in the sense that_we discussed with him what we were doing. He did not tell us to go ahead and do this, or something like that, no.

Q Did he suggest that it would be better if you 5

went ahead and did the evaluation?

A What evaluation?

7

, if y u in luded an analysis of Chapter 8

9 accidents in your affidavit or in other materials?

9 A I don't recall him saying that sort of thing.

Q S what you are saying is that the scope of 11 y ur discusions with Mr. Hodges were restricted to your 12 eXP l anation of why you felt Class 9 accidents weren't 13 34 credible?

A Yes.

15 l

O' And:he expre~ssed no opinions one way or the 16 other on your conclusion?

17 ,

18 A He gave, for example, in one example, Brunswick, 19 where some of the ---

3 Q Excuse me, was that Brunswick?

A I believe that was it, where some of the RHR 21

( ') coolers failed, and he brought that example up, and we 22

' > 25

( ', 1 could go ahead and discuss, us engineers could discuss 2 different aspects of the problems.

3 Q Well, what opinions did he express during the 4 course of this phone call?

5 A I_will have to ask you to be specific. I don't 6 know what you are talking about, opinions.

7 Q What opinions did he express about the credibility 8 or non-credibility of Class 9 accidents during cold shutdown?

9 A I don't recall him expressing opinions whether 10 they are credible or non-credible and the extent that the t

~'

11 Class 9 accidents should be evaluated, et cetera.

12 O What did he say happened at Brunswick?

13 A What I just mentioned.

14 Q And he felt this was a concern that you should 15 look at?

16 .A No. _He brought it up as an example because, as 17 I ~ stated,'.we did not include Class 9 accident type events 18 in the, affidavit, and;he, brought it as an example.

19 Q Well, what was his purpose in raising that example?

y 20 A It could be the instigating event type of thing,

.)

21 you know.

m

' _) 22 O So the implication was that this was something you

26 I '; I ought to look at, right?

v 2 A That is your conclusion. We discussed the Class 3 9 accidents and other parameters that led to the conclusion 4 that Class 9 accidents are not credible.

5 0 Well, what conclusion did you draw after Mr. Hodges 6 told you about the Brunswick example?

7 A I remained stedfast with my decisions, the decisions 8 we had made because those type of things were considered 9 before we wrote the affidavit, although not the specific 10 examples that those situations were contemplated.

t 11 Q Now you have said, you or your group were now 12 in the process of developing _a document regarding the Class 13 9 accidents.

14 A I didn't say that. We are doing evaluation 15 scoping,- 1I think that was- the- proper word that I said, 16~ calculations. ,

17 And this will be on paper, right?

Q 18 A Yes.

19 When I use the word " document," I just mean 0

(, 20 something on paper.

21 A I do not know. They are scoping. I must under 22 line that. As far as I know, they are not official or anything

'N

^

,m; i ( ,/

27 m

.~ ~like that.in'the sense:of calculations,.and I am not aware

(v '  ;. 1

'2 to the extent that they'willicarry them.

3. Q- When was work on this document conmenced,;this 4 scoping document?

5 A 'I would . say within ~ a ' week or so.

6. O Within a week oriso?

7' A. Yes.

8 Q Was it. begun prior'to.Mr. Hodges'-phone call?

9 A- Discussions.were going on'before Mr. Hodges' ---

+

10 'Q. You are talking about the' preparation ofcthe.

j- s 11 document?

12 A' I don't know. I-can't say the preparation. To-

~

13= start preparing a document you ha'e v to have discussions. You:

14 .can',t3 just go and jump in preparing the document or writing

~

'~ '

15 down things.

r ' -

16 Q,_ _

so'yoil:arejsayingjthatthediscussions' pertaining 17 to whether or..not there.should be suchta document. began fe .;;

18 :before Mr. .Hodges' phone call?

19 A The discussion pertaining to the whole aspect

.,m

' !.j 20 of Class 9.

21 -Q That was before Mr. Hodges' phone call?

/s V 22 -A' Yes.

J

.).

, ip

~(

Ns/ *-

28 j'.A.f.N - fl -Q. Okay. Now the prepartion.of the document, the 2' scoping l document, took place after Mr. Hodges' phone call, 3 right?

'4 _A .You: keep ~ on saying preparation of the document.

Engineers do work and they come up with conclusions, et cetera,

. 6 'sometimes.

7 -Q Mr. Stergakos, before Mr..Hodges' phone call, 8 was there.any'. intention to put-down this scoping or!to' write 9 .down this scoping document?

[,.s _ 10 A: That question I cannot answer-because I'do not:

't )

il' ' give directions to'the other group.-

12 -Q' Do you know whether there wasiany intention?

! 13 '- LA L Whether'there was anyLintention? I do not know. t

.14 .Q ' 'i iDo'.lyoucknow.whether'it was discussed, whether

. L , .,.. < ~ , T .

- < . +,

, . or not,_such a scoping document,should be produced?.

16- LA'  : Producie ? b No, 'I don' t' know.

' l7 -(Q { . 5When:youtsay scoping document or scoping report,;

18 whatever the term'was, what do.you mean?

' 19 - A- I mean something which does not necessarily p-(). 20 reflect the procedu'res-that we have established for producing

~ 21 ' calculations, approving, checking and signing off and

~ ,-.;

^

i(_

~

22 documenting them, et cetera, or a full-blown analysis, any

o ,

, s.

e

/

/

/

y= Q 'f

() . y 29 one o'f2th'ose things.-

[G3 I must underline a full-blown analysis, 2 -

1

_.g

.2 for detailed analysis.

3 IQ- Toithe'best of your knowledge,'how long is this

s. -

4 document:in its present sta'te?

- 5 AL I.do not know how long'it is.

6' -Q 'Have you seen it?

A'- No, I have not seen it. 'I have seen people a writing onEpieces of paper, but I don't know how long it-is, 9 I don't discussed the conclusions.

10- -Q Let's go.to Attachment 1 of your affidavit.

f3

- 11 (Pause while the witness looks through documents.)

- 12

, _ Would you agree with me that with respect to the

. 13 Chapter 15: accidents that you have divided them into three c -.- _ . .-.s _ ,. .,

groups', /those - wh'ere' thh event zis not pbbsible; second i's -

- 14

- 15 where.'the) event"ispossible-buttheconsequencesareincon-7 J s, . i- ,.

sequential or non-existent and'the third is where the event-

. 16 pm, , w q ..

17 ' is possible but 'the~ consequerices are below' PAG limits?

18 A- Correct.

-19 Q What did you mean when you said the consequences

,6 Q 20 of some accidents would be inconsequential?

~

21 A In the sense that orders of magnitude are far, m

.U 22

~

far less'than the criteria which we established.

% __si._m. _ _ _ _ . _ _ _______A

1 r ,

j

-- 1

-l

, . , , 30

.i ): .

v

< ,, 'I Q By the crideria you established, do you mean the

'2. PAG limits?.

23 ' A Yes.

4: Q, When-you say orders of magnitude, would it be 5' one order of. magnitude ~or two'or three?

4 6 A No.

7 -Q- Many?

8 A '.We already-discussed.those.in paragraph.7, for

.s

<y '9 example, c

j,_g 10 - Q' .An accident that hadiproduced conhequences of

( )'

11 one order of magnitude below the-PAG's would not fall in the .

12 second group, but would fall in the third group?

13 wA .On.a. general basis, yes.-

s . . > ~

. .,<: n _ y .L .o 14 0 Of the I believe-14 accidents in the second group, y ,

. ., 7

^ 15 which have consequences which'bre not non-existent,-but'which

~

16 .' are inconsequential? ,n , s l

, - 4 ., i 's ,  ;

17 A What are you looking at?

• - 18 -

Q. I am looking at the 14 accidents in the second I' group.

p.,

Q 20 A Yes.

s~- ,

21 0 'Now some have' consequences which are non-existent' im Nd 22 -and some have, consequences which are inconsequential.

I~

c-i 31 1 A Yes.

-w-2 I want to know which ones have consequences Q

3 which are inconsequential.

4 A Well, if you notice the asterisk, it-says 5 inconsequential or non-existent. There is not a clear i

6 distinction between the two. Right now I cannot say. Well, 7 I can go down the line and more or less predict non-existent-8 or inconsequential, but we have not in this document devised 9 or indicated them differently.

10 Well, I understand that you haven't done it in Q

i j

~

11 this document, and I'want to know which ones are non-existent 12 and which ones are inconsequential.

^'

g

~

13 You want!'to go down the line and perhaps I can I4 draw some conclusions'from this.

15 Q Olday. Let's start with No. 7, feedwater control 16 failure. -

I7 A I would say those are non-existent.

18 Q Okay. How about No. 9?

19 A Non-existent.

4 20

' _/ Q Let's go to No. 15.

21 A Non-existent.

22 Q No. 18?

v 32

(~'j i A I would say non-existent.

V 2 -Q No. 19?

3 A Non-existent.

4' Q. 20?

5 A Non-existent.

6 Q Was that non-existent?

7 A Yes.

8 Q 22?

9 A The same thing, non-existent.

,-m.

10 And non-existent, 23.

t )

11 Q Okay. 24?

12 A Non-existent.

13 ~Q.- 25?- -

14 Non-existent.

l 15 0 26?.

16 "I N6n-existent.

17 0 30?

18 A Inconsequential.

19 0 347 M -A Inconsequential.

1 21' Q And 37?

r 8,

(_) 22 A Inconsequential.

)

l l

l l

/

33

~' '

1 Q Now when you say that the consequences for a 2 particular accident, the radiological consequences would be 3 non-existent, you are speaking in absolute terms that there 4 just would be no radiological consequences?

5 MR. ZEUGIN: Where are you defining no radiological 6 consequences, at the boundary of the plant or within~the 7 p'lant?

8 MR. McMURRAY: I will let Mr. Stergakos define

'9 it.

m 10 THE WITNESS: If I am talking about -- well, we 11 can go down the line and I will tell you in my opinion where 12 I believe whether~it ,would be non-existent or inconsequential.

13 .Any plant or anywhere else, I can tell you that.

,14 BY.'MR. McMURRAY:

15 Q When you were going down the line just right 16 now and giving me your definition, were you talking about 17 ~ at the plant boundary?

18 A No. I mean really as far as non-existent, I had 19 in mind even, people within'---

/

20 Q Even within the plant?

21 A Within the plant, yes.

22 Q Mr. Stergakos, are you saying that the consequences

p 34

(~') 1 for these accidents we have just been discussing would be

.2 _ non-existent because there wouldn't be a fuel failure and 3 therefore no release?

4 A Fuel failure, yes.

5- Q You were focusing on fuel failures?

6 _A Yes.

7 Q Now you mentioned earlier also that you could go 8 down the line and sort of tell me at what point, whether 9 the plant boundary or wherever, the consequences would be.

10 inconsequential, and I was wondering if you could do that.

i 11 MR. ZEUGIN: I take it you are asking this question

^

12 with regard tolItems 30,f34 and 37?

13 MR. McMURRAY: Well, Mr. Stergakos just said 14 he could go down the list.

15 THE: WITNESS: iStarting with 30, okay, for example, 16 I would say when we'say inconsequential, we have to define 17 what we mean by that because even within the plant if we 18 take the limits thct the operating people t;.n have, I would 19 say even this event will be inconsequential within the

' 20 plant limits.

21 BY MR. McMURRAY:

7 s,

( _) 22 Q This is for 30?

n

(  !

~ . , .

35 I A Yes.

~.-

2 (Pause.)

3 Again, using the criteria that the dose that the 4

people can get in the plant, that is operators, et cetera, 5

and taking into consideration the fact that we are dealing 6

with the event occurring after the 24-hours period, 34 will 7'

fall into the same catetory.

8 O Mr. Stergakos, I didn't quite understand that, 9', and that is because I am a layman. So if you could just 10 run through that again slowly, especially why the 24-hour 11 time. frame was.important.

- 6, A Because all'these are under that condition.

13 Q Under what condition?

14 A. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />., The reactor has been brought down to 15 cold shutdown and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have been passed.

16 Q 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have been passed since the notice of the 17 strike or since the cold shutdown has been achieved?

18 A No, from the initiation.to shut down the reactor, 19 the-hteps-that they would take to shut down the reactor to the point that we are talking about.

21 0 37 is the same?

~3' i 12 A Yes.

-~

36 1 Q So you are saying for 34 and 37 it would be 2 inconsequential at the site boundary?

3 A Not only that, but I went a step further and 4 I said inconsequential using the criteria that the plant 5 people can -- as far as the dose which they can get any time, 6 and that can be considered inconsequential for them,.too.

7 Q Is that the same as the PAG levels?

8 A No, they are not.

9' Q What criteria are you talking about then?

10 - A The plant operating criteria.

)

11 Q Would you explain-what the plant operating 12 criteria are for exposures?

13 'A They are.in the ranges of rem, and I personally 14 do not'know'the. exact figures that they have in the plant 15 procedures right now, but I know they are in the fractions 16 of rem. So that is what I am talking about.

17 Q Fractions of rems?

18 A Yes.

II Q Let me refer you to the three-star category.

l N (Pause.)

21 A three-star category is where any accident

,m 22 that occurred, according to your analysis, would not have

l I

l l

37 l

's 1 consequences above the PAG limits at the site boundary, 2 correct?

3 A Correct.

4 (Pause while counsel confer.)

5 Q Mr. Stergakos, let me refer you to the fuel 6' handling accident which is No. 36 on your attachment to 7 your affidavit.

8 A Yes.

9 0 I have seen your analysis on the fuel handling 10 accident, and I just want to know if the assumptions made 11 were the'same a's.in Chapter'15?

12 A They were exactly the same, all of the 13 assumptions. 'As a matter of fact, we used the results of 14 Chapter 15, 16 : rem 'or .something.

15 Q So you said 16 rems?

16 A For the calculation we used 16 rem. I believe 17 that came out,of Chapter 15.

Everything came out of Chapter 18 15.

19 0 okay. All the assumptions made were Chapter 15 20 assumptions, correct?

21 A Yes.

-m

_, 22 Q Mr. Stergakos, let me refer you to the license

I m

38 a

) I condition. Do you have that in front of you?

2 A Which one is that?

3 Q. LILCO pn) posed license condition. I think it is 4 within Mr. Cordaro's affidavit. I am sure you must have a 5 copy of it somewhere.

6 (Pause.)

7 A I have it.

8 Q I would like to refer you to sub-item No. 2, 9 where it says "LILCO would be permitted to conduct such other s

10 operations as the staff shall approve," et cetera.

11 A Okay.

12 -Q Sub-item No. 2, do'you see that?

13 A Yes.

14 0 What are the other operations that LILCO is 15 considering there?

16 A That I do not know, but I do know that they shall 17 not be anything which would violate radiological consequences.

18 0 When you say that, you mean where the consequences l9 would not exceed the PAG limits at the site boundary?

20 A As specified, yes.

21 Q How would that be determined?

22 A Because I would have to do the analysis.

c .:

'4.-

t 1

I M'w/ 39 Qb -

i Q. -And the analysis would have to-be done.at the V

2 Ltime of:the strike?

3 'A .That is a postulation on your part. I mean, yes, 4- I would assume [that.

~5 Q In other.words, you haven't been asked now to 6 ' consider what the consequences would be for a group of 17 "other' operations" at cold shutdown, correct?

3- .A Correct.

'9 Q Who would know what the term "other operations" q 10' is intend,ed.to. cover?.; , ,

' s }.a.L : 1 ,

'~f

'L ,

11 A I do not know who decides what they-want to do-l{ [* ' : ,' * ._ ~, e. r

.12 orwh,atwould(beldonet.I.willhavethe'responsibilityto 13 s ' determine the:radiologicaleconsequences.

< v ;- ,

_a,; _ 4 1<4 .Q Would Mr. Scalice know what the term "other.

15' - operations"Lis' meant ~to cover?

' 16 A That you have to.ask,him.

17 - Q You really have no idea what operations are 18 considered here?

19 A No.

N I J- 20 Q I believe using the steps described in Mr. Scalice's 21' affidavit it takes about 12 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> to descend to cold -

. shutdown fromIfull power; is that correct?

~

22 I

-- 40

)- i A I believe that is what is stated in there. I 2 didn't decide that.

3 Q You didn't decide that, and you haven't done 4 any analysis to determine whether or not that is true?

5 A No, I have not done it.

6 Q That is really not your area,-is that what you 7 are saying?

8 A The rate at which they want to shut down the 9 reactor? No, that is not my area.

~

10 'O And also the statement in Mr. Scalice's affidavit I -

11 that cold shutdown could be. achieved in eight hours by

.12 scramming the reactor, also you'have done no analyses to determine! whether or . not th'at is true?

~

-13 14 A No.

15 (Pause while counsel confer.)

16 0 I would like to go back to the analysis that has 17 been done on Class 9 accidents. What criteria were used 18 to determine whether or not a Class 9 accident was considered 19 to be credible or not credible?

20 A The criteria that we are presently using are of 21 course the steps that have to be taken or the events that 22 will have to follow to reach to the final accident conditions,

\

41

~'

i the steps that the operators and the systems will take, the 2 automat'ic systems, and also under the most incredible conditions, 3 assuming that they do occur, the time available for us to 4 react and see that the fuel does not fail.

5 Q You said the most incredible conditions. How 6 do you define whether conditions are credible or incredible?

7 A An incredible condition will mean just capriciously 8 assuming that you lost all coolant.

9 Q Is that an exampla of something that is incredible,

,_ . 10 or that is-how you' define' incredible?

11 A , That is my, not definition, but as an example 12 of what I mean by incredible, incredible in the sense that 13 I assume instiataneous loss of~all coolant.

14 0 I take it that you don't really have objective 15 criteria for credible or incredible, but it is more sort of 16 subjective using your engineering judgment as to what is 17 credible or incredible, correct?

18 A That is always the truth I believe.

19 (Pause while counsel confer.)

J 20 0 Mr.'Rigert's group is the one.that has focused 21 on the class 9 accidents, correct?

22 A Mr. Rigert's group is the group that he is doing

.F .

L h

~

,~

42

-l(a)/

[/ 1 written documentation,'if you want_itsas_-such, yes.

.v.

2 ,: 0- -I believe you said you have discussed the

~

3: conclusio$swithMr. Rigert?

2

- - '4-

• YA Not Mr. Rigert. Mr. Rigert is on vacation.

5' 'O With whom have you discussed the. conclusions?

6. -A With the mancunder him which'is Mr. John Valente.

f

7. O =And what has Mr. Valente told you are the con-8 c'lusions?

-9 ~- As * ,

The conclusions _that we came up with-are that

. 1. - .> c ,

10 - our' original _ assumptions were valid.

- L O, e ,

,s , ,,

y ? ~ 11 e. 'Q :

+ ., .

..When youisay yoilr' original assumptions, would you-

.12 elaboratelon(what you/mean?;r

, - 3 113 #-

A That wevhave plenty under the most incredible

'14 scenario, which1I stated before, we have enough time for

' 15 - either the systems or the people to react. 3 16 01 Itavelany of the initial conclusions of your group 17 . that the' Class 9 accidents were inconsequential been altered Il8 ~in any;way-as a result of conclusions reached by Mr. Valente?

i 19 A' No.

g)

(_ ' 20 -(Pause while counsel confor.)

21 O' Mr. Stergakos, do you know whether the scoping n.

' i-) 22 ~ document that we have been discussing is going to be submitted

43

^] 1 to the Atomic Safety and Licensing Board next week during 2 the hearings on this issue?

3 A That was not brought up.

4 Q I am trying to determine what Class 9 accidents 5 could occur at cold shutdown. What was the list of accident 6 sequences that you used to try and come up with the Class 7 9 accidents?

8 A We did not use a sequence of events because we 9 cannot really see a sequence of events. At least I do know 10 personally of an enumeration of events that relate to such 11 and such. -I' told you the worst possible situation.

12 Q Well, did you look at the SA1/PRA for guidance 13 at all?

14 A Well, the-PRA does not discuss such events under 15 these conditions.

16 Q By under these conditions you mean cold shutdown?

17 A Cold shutdown conditions because they are 18 incredible to begin with.

19 Q PRA does discuss low-power conditions, doesn't it?

20

(  ;

A That I cannot answer.

21 0 Did you consider any Class 9 accidents that could

) 22 in the transition or the , descent from full power to cold

pn ;i m

~

1

,~

f i , . A -'

s

.,(p) --

.w.

44 qt] f~ i. shutdown?. ,

2' A. I:already answered that' question.

3: 'O~ . Your~ answer isLno?..

1 4 li Yes,. sir.

E' . !5L Q .Are those types'of accidentsiconsidered in.these.

6; -scoping documents:that we have been discussing?

~

P '

7 'A I AsEI know, no, and I mus't' underline that.

8 QL Let' r.

me ask you.about your contacts with-

')",? ,

[*' g j w at +

.- ' L ~

.9 .Mr.:Hodges.9 Have*you had2any contacts'with anyone else from

- =-

'10 , ' the NRC ' about', these issdes:'we have been discussing today,

/" .; n ~, <

r ,,.,,

-D]'" 11 since your discussion, with Mr. Hodges over the phone?

; -c - , ,

e;ns( .m

. + . . .

, n .. _ .

6 g,- .12 ~ -A .I answered that question,-too,.and the answer 13 .is no.

14 . .

--Q Has anybody else at LILCO, to the-best of your~ ,

15 knowledge,'had any contacts with anybody at the NRC about,

, -16 ,.this issue since'your discussion with Mr. Hodges?

+ 17 .A I.cannot-answer that question because I.do not

/ . ^,

Y 18 know.

o L; 19 ~ -

Q ,

To the best of your knowledge, the answer is no?

R' , .

L f% ,

,'E d. . _ 20 A; Yes, "no."

21 (Pause while counsel confer.)

22 - MR. McMURRAY: Thank you, Mr. Stergakos.

w_--_.--_ -___.'_.--:

i

, ]f Oh-h l

. b[ ,

45  !

h itJD .1 ,

.I.have no further questions.

2: THE. WITNESS: .The only thing which I -- oh,

' 3. _I am sorry.

4

.(The witness and~his counsel confer.)

~5 -

EXAMINATION

, - 6' BY MR. ZEUGIN:

7. Q -There is one thing ~that Mr. Stergakos would

'8 like torclarify. s -e . ,.

s

,- .. .\C' 9 _

Mr. Stergakos, was there anyone who was at your J.

. - 10 . initial meeting.that:you711st'ediMr. Rigert and two other

' l~ l ' '.

11 people," s other than the'three other people that you listed?

4 . ,

12 A Yes. There was Mr. Bill Tunay,. the LILCO person.

13- MR. McMURRAY: Mr. Bill'who? ,

' 14 THE WITNESS: Tunay. Don't ask me how to~ spell.

~

15 his name; . T-u-n-a-y.

16 MR. McMURRAY: Who is Mr.'Tunay?

'17 THE WITNESS: He is ' a Division Manager of Fuels. '

18 -I don't remember exactly his exact title, but he is on the-I' ' same level as'I am.

~

20 MR. McMURRAY: Okay. And he is also part of i 21 this group that you ---

p.

d ) .c 22 THE WITNESS: No. He partook in the original t

! 'E.

46 I discussion. He is presently acting for Mr. Youngling.

2 EXAMINATION 3 BY MR. McMURRAY:

4 Q Was Mr. Tunay's participation with respect to the 5 issue of fuel handling?

6 A No. He participated fully.

7 Q He participated fully. What was the role he 8 played?

9 A Well, he played as any engineer in looking at N

10 all events and consequences,'et cetera, in the original 11 discussion. -

. 12 O He took Mr. Youngling's place because Mr. Youngling 13 wasn't there?

14 A No. Presently since Monday. Maybe I am wrong.

15 I think it is since last Friday Mr. Youngling is out and 16 Mr. Tunay is acting on his behalf I believe.

17 Q Did Mr. Tunay participate at all after the first 18 meeting with the group?

19 A Yes. I think there was another meeting that we 20 had and he was present, yes. He was present in another 21 meeting, but we are working as a group and he knows how we 22 are progressing. It is his'po'sitio'n'right now to know.

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47 jy ,Q Is'he sort of a supervisor for the group?

. C/ -

A He is the Department ~ Manager. I.have not seen 2 '-

a memo-calling him the. Acting Department Manager or anything 3

-like that, but'he is acting on: behalf of Mr. Youngling right 4 ,

5

6. (Pause while counsel confer.)'

7

Q I just ,want to get-one thing. perfectly clear.

E l ',, C Y O A; . ,,

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We have gotten all documents thati have been produced _by 'your '

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(. .3 .; ,

l '; E 9 group [.onthis?particu;lar.. issue lofcold~ shutdown, correct, 10 -

Mr. Storgakos?.,.,c qu nq, s y ,,,

,q ,

! .( , 3 E ' N) , gg A Yes,fyou have.

t Q I am not-talking'about-the Class 9. document now.

12:

A Yes.

. '13 14 Q And there is nothing, for' instance, other than'

-15 what we'have receive ~d which shows how the Chapter 15 accidents .

16

, were divided into three different groups?

.17 ' A Absolutely nothing, except what you have received.

18 MR..McMURRAY: I have no further questions.-

.19 :_ Thank you very'much.  ;

) 20 ' - (Whereupon, ' at 11: 32 a .m. , the Deposition of v

l 21 ELIAS P. STERGAKOS concluded.)

22 -

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',, 48

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X 2

' s I;have read the foregoing pages 31 -

4 through 47, inclusive, of ' my 4' deposition and> find it to be true.

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5 and accurate to the best of my F ~

6. knowledge and belief. Signature-s4_ , y .q - .

7 '

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. l,is.su ject-to corrections.

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> 9 ELIAS~P STERGA S

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9 12 Ia 00^24)lE*/f/?he Psico: a Notary Pub 11c ,

Oous0M in .and for- the : Jfate of A(cu;%rk' of So&ht O am witnessing I 13 b

p

- 14 the signing-'of the' Deposition of ELIAS P. STERGAKOS on this 15 '2O day of ' 'u Ocah , 1984.

T i* O.A. N

.- ,_ GN.A.

17 NoW ry Public in agd for the S & d)* h Q h L \1 h un b U

oQ ts

-19 My Commission expires NNEMARfA PARDU A0TARY PU8 tlc, State of New You

[- 20' OLAcl 30 R% comar!:"'i 7,, g, 21 j

22 1

'l l

- 49 1 CERTIFICATE OF COURT REPORTER 2

3 I, MARY SIMONS, Court Reporter, do hereby certify l l

4 that I reported in Stenomask the deposition of ELIAS P.

5 STERGAKOS.

l 6 I further certify that said transcript contains y a true and correct transcription of the answers given to 8 the questions herein asked.

9 I further certify that said transcription was

~

10 transcribed by me to the-best.of my ability.

11 I further certify that I have no interest, 12 financial or otherwise, in the outcome of this litigation.

13 Given under my hand this 24th day of August, 14 1984.

15 -

W "

M%

17 Mary Simons Notary Public in and for 18 the District of Columbia 39 My Commission expires

,3 August 14, 1989

) 20 21

/ 22