ML20154H662

Deposition of Gc Minor.* Transcript of Gc Minor Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence

ML20154H662
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/21/1988
From:	George Minor LONG ISLAND LIGHTING CO., MHB TECHNICAL ASSOCIATES
To:
References
CON-#288-6329 OL-3, NUDOCS 8805260021
Download: ML20154H662 (59)

Text

b 3 2-7' QanNa TIMNSCRIPTw 0

OF PROCEED {KA UNITED STATES OF A!!ERI h i :.;,,.:.,

E H ;. t NUCLEAR REGULATORY C0!!!!ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the flatter of :

Docket No. 50-322-OL-3

. GONG ISLAND LIGHTING Cn!!PANY (Emergency Planning)

(Shorehan Nuclear Power Station, Unit 1)

_ _ _ _.. _ _ _ _ _ _ _ _ _ _ _ _ _ _x I

I RJ DEPOSITION OF GRE C.

?!INOR h'a s hing ton,

D.

C.

Thursday, April 21, 1988 ACE-FEDERAL REPORTERS, INC.

Stenotyp' Ravrters

^3 444 North Capitol Street

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Washington, D.C. 20001 (202) M7-3700 Nationwide Coverage 8805260021 080421 09 800-336 6646 PDR ADOCK 050 2

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CORRECTIONS TO DEPOSITION PTRe line Correction: M.

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1 COX/ojg C) 1 UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION BEFORE THE 3

ATOMIC SAFETY AND LICENSING BOARD 4

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 5

In the Matter of:

Docket No. 50-322-OL-3 6

LONG ISLAND LIGHTING COMPANY (Emergency Planning) 7 (Shoreham Nuclear Power Station, Unit 1) 8

- - - - - - - - - - - - - - - - -x 9

10 DEPOSITION OF GREGORY C.

MINOR 13

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WP.ahington, D.

C.

12 Thuraday, April 21, 1988 13 Deposition of GREGOR".

C.

MINOR, called for examination 14 l

pursuant to notice of deposition, at the law offices of Hunwon d

15 I and Williams, 2000 P'nnsylvania Avenue, N.W., Conference Room 16 l Two, Ninth Floor, at 1:35 p.m. before WENDY S.

COX, a Notary I

I 17 Public within and for the District of Columbia, when were Present on behalf of the respective parties:

18 I

19 LEE B.

ZEUGIN, ESQ.

DAVID S.

HARLOW, ESQ.

20 l

Hunton 6 Milliams 707 East Main Street 21 P.

O.

Box 1535 Richmond, Virginia 23212 22 On behalf of Long Island

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Lighting Company.

I

-- continued --

ace FEDERAL REPORTERS, INC.

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202 347 3700 Nanonwide Cmerage w3%fe

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APPEARANCES (Continued):

l 2

RONALD R.

ROSS, ESQ.

J Kirkpatrick & Lockhart l

3 South Lobby, Ninth Floor 1800 M Street, N.W.

i 4

Washington, D.

C.

20036-5891 On behalf of Suffolk County.

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ACE. FEDERAL REPORTERS, INC.

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CONTENTS 2

WITNESS EXAMINATION Gr g ry C.

Minor 3

by Mr. Zeugin 4

5 EXHI B ITS MINOR DEPOSITION NUMBER IDENTIFIED 7

Exhibit 1 21 8

Exhibit 2 23 9

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12 13 14 15 16 17 18 19 20 21 22 ace.Fnonnat. REvonTnns, INC.

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I 1h PROCEEDINGS l

20 Whereupon, 9

3 ll GREGORY C. MINOR n

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

was examined and testified as follows:

6' EXAMINATION BY MR. ZEUGIN:

8 Q

Mr. Minor, my name is Lee Zeugin from the law firm 9) of Hunton & Williams.

I will be taking your deposition 10 today.

With me is David Harlow, also of our firm, who 11 y represents LILCO in this Shoreham proceeding.

The purpose of O

12 the deposition is to discuss your testimony on immateriality 13 j issues, particularly contentions 1 and 2 that have been filed 14,

in the Shoreham emergency planning proceeding.

If at any 15 time during this deposition you don't understand one of my I

questions, please let me know and I will be glad to try to l

16 N l

17 restate it for you.

1, 18 '

I would like to begin by having you state your l

i 19 -

name and business address for the record.

1 20 A

My name is Gregory Minor; my business address is 21 MHB Technical Associates, 1723 Hamilton Avenue, suite K, 22 San Jose, California 95125.

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Mr. Minor, could I ask you to explain for me your li 2 'l understanding of the scope of the testimony you are being i

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3l asked to present under contentions 1 and 27 t

a 4n A

Well, our part of the tectimony will probably --

5 hi and I say probably, because it isn't written at this point, 8

6" and I don't know what it entails in detail, but it inn't 7,

written, but it will probably be rocused on the aspects of H

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the possible increase in risk or dose experienced by the 1

9 L public during an evacuation during different types of 10 p controlling circumstances, such as impediments or delays due 11 to traffic controllers not being there or not being effective q

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in their control, and things of that nature.

4 i

13 ]

Q I take it, is your testimony going to cover i

14 l essentially accident sequences that could occur at the plant c

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and their off-site consequence as compared to alternatively, i

16 is it going to address the accuracy of the evacuation time 1

17 estimates that appear -- currently appear in the LILCO plan, 18 1 or will it cover both areas?

4 19 u MR. ROSS:

Are you asking the witness to speculate i

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20 0 as to testimony he stated isn't written?

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21 MR. ZEUGIN:

No, I am not asking him to speculate d

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22 :

as to the actual testimony.

I am merely asking the scope of

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1Ij what he foresees his testimony, which area he foresees his i

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testimony to be in.

N 3d MR. ROSS:

I think you are entitled to ask him i

4 f about the views-that he currently has, but he is not required 5 l.

to speculate as to views that he may or may nou form in the lj 6'

future.

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MR. ZEUGIN:

Are you instructing him not to l

8 h answer?

9p MR. ROSS:

Perhaps you would like to restate your 10 question.

11 '

MR. ZEUGIN:

Are you instructing the witness not

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1 2

,1 the answer that question?

13 MR. ROSS:

If you remember the question, you are i

14 free to answer.

15 THE WITNESS:

Well, I don't recall his exact 16 question, but let me answer by giving you the premise for my j.

17 P answer, which I think is basically your question.

The 18 perspective with which we will be approaching testimony is i

19 >

not focused on redoing the traffic analyets or redoing the I

20 estimate c f times for evacuation, that is not our purpose or l

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our intent in the testimony.

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However, we will be looking at the implications of,

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1d those differences in time for the various types of in U

i' 2j evacuations that have been outlined in LILCO's motion.

I am R

30 not sure that the correct terminology may be a motion, 0

4 affidavit, or some filing.

In any event, there have been 5q some new times identified, and we will probably rely on that 1

6 data plus the data from other witnesses who may be appearing 7

for the county who would do some looking at the traffic u

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estimate.

I 9

BY MR. ZEUGIN:

10 Q

In answering my question, Mr. Minor, at several j

11 d points you used the word "we."

Are you referring to yourself !

O 12 and Mr. Sholly as preparing this particular testimony?

13 A

Yes, in general.

But it may involve others from i

14 ;

MHB who were helping along the way to prepare the testimony 15 -

and do some of the analyses that we would like to have done 16 in addition to Steve and myself.

But Steve and I will 17 ;

sponsor the testimony.

18 '

Q Are there some particular areas, in sponsoring

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19 -

that testimony, that you believe you bring a special l

l 20 '

expertise to that Mr. Sholly does not?

l 21,

A Well, one obvious example, I think, would be the l

length of time I have been exposed to this proceeding, and to l 22 O

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LILCO's emergency planning and to the plan itself and its 2j numerous revisions.

3 Q

All right.

I take it that you are being offered 4,

as an expert on -- to offer expert testimony on this subject; ;

5.

is that correct?

6 A

That's correct.

7 Q

Mr. Minor, let me ask you when you were first a

contacted to be a witness on contentions 1 and 27 l

9 A

It was in early April, very near the first of 10 April.

I don't remember the exact date.

11 Q

Approximately how much time have you spent since O

12 that time thinking about your testimony or actually preparing i

13 it?

l 14 A

Well, there have only been two or three weeks l

15 elapsed in that period, so certainly it's less than that 16 amount of time.

17 Q

Significantly less, more than a day?

18 A

I couldn't give you an accurate guess, but I am 19 sure it's more than a day, but I don't think it's a number 4

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20 that I can give you very accurately, other than bracketed he hys 09 21 there, betweer. today and a couple of weeks, but I don't know 22 the exact numbers.

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Q I take it from your earlier answer that at this l

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point you have not yet drafted any testimony?

3 A

That's correct.

4 Q

Could you list for me the documents you have 5

reviewed since you were contacted in early April to be a l

6 witness in preparation for preparing your testimony?

l 7

A Well, we will have to use the word "reviewed" very l

l 8

loosely here.

There are several documents that I have 9'

thumbed through to see what information might be available in 10 them, with the idea that I would later decide whether I was 11 going to actually use that or not, and whether I would review !

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12 it in more depth.

Among those were some of the standards, l

13 NUREG-0654 and 10 CFR, and also, some of the past documents 14 that were in the caso earlier; and among those, of course, 15 the plan, the PRA created back in '82-83, the testimony that i

l 16 I submitted on contention 61 during the emergency planning i

17 proceedir.g, and I did take a quick look at some other pieces 18 of testimony that I had submitted since then in this 19 proceeding, to see if they had any bearing on the subject.

20 I looked, of course, at the different filings, 21 briefings and opinions that have flowed back and forth in the ;

22 process here, related to this subject, to try to understand At i-Fi tii R si Ri inin ii ns. Im

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how it came to be in the form that it is now.

I think that's C

2f the general list.

I don't recall all of them now, but that's II 3S all that I recall at this time.

4j Q

Okay.

Let me ask you to describe for me your 5f understanding of LILCO's immateriality argument?

6 A

My understanding of LILCO's immateriality 7

argument?

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Q Yes.

9 A

Well, it would be far better for you to read your 10 own briefs than to get ny interpretation of it, because I am 11 not a lawyer.

I can't interpret what legal premise you are q

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putting it under and all of that.

I am not trying to e

13h interpret it that way.

But just as a technical perspective, 14 I view it as being an argument that says there may be 15 g impedimentstoevacuationthatwoulddelaytheactualleavingl l

16 of the zone by the people who.were the last to leave, let's j

say, people that take the longest to evacuate, by some number \\

17 18 '

of minutes or hours; and the basic argument that LILCO is j

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making is they think that is an immaterial difference, and it l f

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20 has no materiality in the decisions related to this a

21 particular aspect of the case.

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22 Q

You used the term "impediments."

By that did you l

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1 mean traffic accidents or do you have some other meaning for j

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that term, as you have used it?

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A Well, I look at it as two aspects, traffic control 4;

and impediments of the nature of obstructions or things j

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placed in the roadway, either as part of the exercise, as 6

they did during the exercise, or as the reality of what you f

7 are likely to find in a real evacuation.

Things are going to l 8

break down.

There are going to be some types of obstructions 9

they will have to work around in an evacuation.

f 10 Q

Let me just ask you a few follow-up questions on 11 the documents you have reviewed since being asked to be a l

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12 witness.

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11 You said you have looked at the plan, for I

14 example.

Are there any particular parts of the plan or any i

I 15 particular procedures that you may have looked at more

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16 closely than at others?

17 A

Well, it seemed to me in the file that the plan is 18 the estimates for evacuation.

It's either a direct part of WJ3 19 the plan or is something that-we filed with the plan, I am jD 20 not sure which.

But I wanted to look at what the estimates 21 had been in the past versus what they were now for the new 22 timing study.

So, looking at it in that perspective.

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Q That's the one you remember reviewing specifically 2

as compared to the plan in general?

3i A

Yes.

0 You also said that you looked at your previous 4

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testimony on contention 61, as well as some other testimony e

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that you had presented earlier in the Shoreham proceeding.

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With regard to the other testimony, did you identify any i

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testimony among that group that you thought may be relevant j

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to your upcoming testimony on contentions 1 and 2?

10 A

What was your question again?

11 Q

My question is, you said you reviewed your O

12 i testimony on contention 61.

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13 A

Yes.

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You also said that you looked, in a more general j

15 sense, at other testimony that you had provided earlier in l

16 the Shoreham proceeding.

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Yes.

18 Q

My question is, from that group of testimony, did i

19 you identify any specific testimony that you thought was l

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20 particularly relevant to the issues that are being presented I

21 by contentions 1 and 2?

l 22 MR. ROSS:

Counsel, maybe we need a O

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I am not sure that he characterized his 2

review of the other testimony as being in a more general 3

sense, which is the way yo.: just characterized it.

4 MR. ZEUGIN:

Maybe Mr. Minor can clear it up.

If 5

not, I will try to restate the question.

6 MR. ROSS:

I think he is trying to find out what 7

your testimony will be.

84 THE WITNESS:

As I understand your question, it is 9L to find out what, if any, of the testimonies that I looked at I

10 do I consider relevant to this particular action; is that

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BY MR. ZEUGIN:

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Exactly.

14 A

I looked at the testimony we presented on 15 contention 61, dealing with the question of sheltering versus 16 r evacuation, and this is testimony that I presented and 17 coauthored with Fred Finlayson and Ed Radford.

I thought 18 that that testimony was potentially relevant.

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l 19 testimonies I was looking at dealt with more issues in the l

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emergency plan and the exercise that I thought may have had l

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21 some potential, but when I just glanced through the

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22 conclusions and the subject matter, I decided they probably l

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1l were not relevant, j

1 2h BY MR. ZEUGIN:

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3j Q

That's fine.

Mr. Minor, I would like to ask you a l

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series of questions about a number of other documents that I

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am sure at one point in the Shoreham proceeding you probably

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E 6J have reviewed, and ask you about your familiarity with those 7

documents.

I take it you have previously reviewed

1 80 NUREG-0396.

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9j A

Yes.

i 10 Q

And are you familiar with that document?

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Generally, yes.

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12 0 Q

How about WASH-1400?

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Yes.

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How would you describe your knowledge of that F

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particular document?

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WASH-1400, of coursa, has a lot of historical 17I!

prominence, and, therefore, it's a document that was reviewed l

18 l a long time ago by me and others in our company; and I think i

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it sets the general tone for PRAs and, therefore, has l

i 20 importance in this case.

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21 !l Q

How about NUREG-1150, which I believe is a more l

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recent NRC publication.

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I have done some review of 1150, not a great c

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3j Q

Are there any other NRC documents that you feel 4dl have a bearing on contentions 1 and 27 e

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A Well, the answer has to be yes.

But I also could 6

not give you the title or number of the particular ones that a

7 may have that bearing.

There have been a lot of studies done i

8 ji recently with the -- excuse me, or from the point of view of 9o looking at particular accident sequences and how they develop 10 [

and what is going on and the methodology or the understanding n

i 11 k of the phenomenology of accident progression and how O

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accidents develop and what type of releases may occur from i

1 13 those accidents, and there have also been documents put out i

14 dealing with the type of emergency planning decisions that i

15 people have to make.

16 Now, I have given you very general descriptions of l 17,

these documents, because I honestly don't remember the

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18 J numbers of them at this point, j

19 Q

That's fine.

Let me ask you about your review of

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20 Shoreham specific PRAs.

I believe you mentioned earlier that s

21 I at least since early April you have at least glanced at 1

22 LILCO's PRA from that.

I believe the correct date is 1983; l

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A Yes.

This is the original 100 percent PRA.

l 3y Q

How would you describe your review of that i

4 0 document since April 1; was it brief?

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A Excuse me.

My review of that document since April 61 17 a

7 Q

Yes.

8' A

That was a very brief review to look for some of 1

9 the tabulations dealing with accidents and accident 10 c sequences.

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Q Have you reviewed that document in more detail at

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l 12 an earlier time?

13 A

Yes.

14 ;

Q Could you briefly describe for me when that 15 occurred end -- for example, give me some estimate of how 16 long that review took?

17 A

Well, this may actually predate your time with the 18 case,butseveralyearsago,whenwewereinsafetyhearings,l 19i in 1983, when the PRA was issued, and pieces of it became 20 '

available, we were looking at that in terms of an 21 understanding of the aspects of the case, such as ATWS, for 22 instance.

I looked at it in relationship to the testimony on

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1 that part of the hearing.

2h Q

Would you characterize your review as fairly N

31 detsiled at that point?

u 4k A

Certainly in those areas it was.

I didn't go I

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through the entire report in detail.

6 Q

I take it you really didn't conduct any other 7

review following that initial review until just recently when 8

you looked at it again; is that correct?

9 A

No.

It came up again during low power hearings, 10 when we were looking at relative risk, and I reviewed it 11 somewhat at that time.

O 12 Q

Have you reviewed the more recent PRA that was L

13 ~

prepared for 25 percent power operation?

14 A

What do you call reviewed?

I have briefly read a

15 through it to understand the nature and premise of it, but I i

16 have not studied it in detail.

l 17 0

When did you review it in the terms you just 18 described?

I 19 MR. ROSS:

Counsel, we are starting to stray a bit 20 into discovery on another issue.

I think you ought to tie i

21,

these issues to the matter at hand, and that is the l

22 immateriality thevry.

If you remember the question as stated j

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-- do you remember the question?

2 THE WITNESS:

I don't recall the date.

It was 3

shortly after it was issued and in preparation for a meeting 4

that was held at the Shoreham site to review some outstanding 5

questions with the different contractors that had helped l

6 prepare it.

j 7

BY MR. ZEUGIN:

8 0

And, again, I don't want to put words in your 9

mouth.

Your "review of that document," at least to this i

10 point, has been fairly limi*.ed to reading through it; is that 11 a fair description?

/~T 12 A

Yes.

I think if I were going to be testifying j

13 under it or doing something related to it in testimony, I 14 would certainly have to do a much more thorough review than I t l

15 have done so far.

16 0

Mr. Sholly also mentioned this morning that he had l i

17 at least briefly read also a recent filing of LILCO dealing l

18 with a more recent PRA that was a summary document that was i

19 prepared on a recent PRA that was done at 100 percent power, 20 comparing the plant with a supplemental containment system l

21 and one without.

Are you familiar with that document?

22 A

Yes.

I have seen that document also, and just O

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1 recently we obtained a copy.

It is very summary in nature, 2) though.

It is not a full PRA.

3]

Q I take it your review of that is basically just to 4f read through it?

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5i A

That's correct.

6, Q

At any time have you previously reviewed the 7[

evacuation time estimate documentation for the Shoreham plan, t

8' for the evacuation time estimates that are contained in the 9 5 evacuation plan?

10 MR. ROSS:

Counsel, can you refer to the specific 11 1 estimates you are referring to, 1 through 97 O

1 2 !;

MR. ZEUGIN:

At any time in this proceeding.

I i

13' MR. ROSS:

There are several sets of time t

14 '

estimates here.

Can you clarify this question?

What time l

15 estimates are you asking him if he has reviewed?

l 16 BY MR. ZEUGIN:

17 Q

I would first like to ask if he has reviewed any l

18 time evacuation estimates.

Then I will get more specific.

i 19 A

I am aware of the time estimates that were 20 ;

originally put into the plan, and I am aware that there were

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21, revisions along the way of these estimates.

I didn't i

22, personally dig into the details and try to understand the l

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l 1 lj rationale for the revisions, nor did I dig into the details j

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did the most recent -- in the recent filing, so I can't say

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that I have really studied any of those different traffic l

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estimates.

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So, for example, you have never looked at the l

7q actual computer results that underlie the estimates that i

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8 appear in the plan; is that correct?

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9 A

That's correct.

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10 Q

I take it you have also not examined the specific g

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assumptions that underlie those evacuation time estimates, O

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such as roadway capacities, et cetera?

j i

l 13 h A

Well, I have looked at that in terms of the i

I

)

14 [

write-up that is in there, in the plan, both at the earlier l

l 15,

date and recently, just to make sure I understood what types lf

{

i i

16 of assumptions they were making.

But not in terms of i

17 attempting to redo it or anything of that nature, just to j

j

{

18 understand it.

l i

19 Q

I take it you don't consider yourself an expert in i

{

l i

1 30 traffic engineering; is that correct?

y 21 A

That is not my training, j

l l

I I

l 22 0

Let me move along, Mr. Minor, just briefly, your

!O l

i 1

1 I

f 1

i I

i 1

Act-Fi i>i a si Rii on11 Rs. lxc i

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l 34514.1 Cox 21 i

i professional qualifications.

I am sure we have gone over i

2 these with you so many times in the last year, that I will j

t 3

try to spend very little time on it.

Let me show you a 4

document I would like to have marked as Minor Exhibit 1.

5 (Minor Exhibit 1 identified.)

l 6

BY MR. ZEUGIN:

7 Q

I believe this statement of professional 8

qualifications was attached to your recent testimony on the l

9 school issues, which I bolieve was filed a week or two ago.

10 Do you recognize the document that I have had had marked here 11 as Minor Exhibit 17 i

O 12 A

You mean EBS issues?

13 0

Yes, could well be EBS, yes.

14 A

I am not sure this is the exact same copy, but I 15 think it is the same copy.

Looking at the last page, it has j

16 item 69, August 31, 1987, testimony date.

I believe there 17 has been another one since then, but I don't recall what it 18 is.

Probably fairly well up-to-date.

19 Q

Could I ask you to briefly just look through this 20 and see if there are any great changes from this document in 21 your professional qualifications?

22 A

I think this represents the current or almost Aci-Fi lit u si Ri imu li us. Isc Li

&to %.

,,,y,,.

r 34514.1 cox 22 exactly current rep: sentation of my resume, with the i

1 i

i l

2' possible exception there may be a 70th piece of testimony in 3

my list of publications and testimony that I am not 4

recalling.

i 5

Q Might have been the one you filed a week or two j

6 ago.

l 7

A Perhaps that's the one I am thinking about, f

8 Q

All right.

Mr. Ross, I would ask, if there is a i

9 more recent statement of professional qualifications, if l

10 there is one, we would like to receive it.

I think this is l

11 probably the last one we will receive.

i

)

I 12 A

Let me clarify.

If this is the one attached to l

13 the EBS testimony, then it is the most recent.

14 Q

That's where I got it.

I didn't know which p3.ece 15 of testimony it was, I knew it was one in the pile in my 16

office, i

17 Let me auk you just one other question about your 18 statement of professional qualifications, Mr. Minor, and that 19 is do you intend to review any of the 69 publications that 20 you have listed in your statement of professional 21 qualifications as part of your preparation to testify in 22 contentions 1 and 2; and, if so, could you please identify O

A UI -lil I)l.R \\1 }{l 14)R 11 R S. I NC wwJr i up y,,

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34514.1llj 23 cox e

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1e those for me.

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2j MR. ROSS:

If you have a present intention.

j u

3'j THE WITNESS:

Well, I am not sure whether I have

[

t 4(

properly evaluated item 37, which is the evacuation times and 1

a doses testimony.

I did look at item 40, and I probably would

[

1 5.

.I 6i rely on that to some extent, which is the emergency planning f -

7; regarding sheltering.

Contention 61 in the OL procedure.

J 8h Probably number 63, which is regarding contention EX-36, but i

9n I really am not sure about that.

That's probably a complete 0

10 [

list of the ones I might look at.

t 11 J BY MR. ZEUGIN:

O 6

12,

Q That's fine.

Mr. Minor, let me show you another 13 document that I would like to have marked as Minor Exhibit 2 I

b T

I l

14 I and ask you if you recognize this document?

I 15 s A

Yes, I do, i

r 16 [

(Minor Exhibit 2 identified.)

l 17 BY MR. ZEUGIN:

7 l

18 0

Can you describe for me what it is?

j

'i j

19 A

This is my January 29, 1988 affidavit that I l

i i

20 submitted in the OL-3 hearing relating to the LILCO motion f

21 '

for summary disposition of contentions 1, 2 and 9.

l 22 0

Could you tell me what documents you used or O

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1 relied on to prepare this affidavit?

2h A

Well, the motion that LILCO filed was clearly the i

4 4

j 3

starting document.

Attached to that was an affidavit of, I l

I i

41 believe, Mr. Lieberman, and I reviewed those to understand 1

~

50 what they were arguing was the basis for the summary 6

disposition motion.

I believe at this time I also went back r

i L

1 7) to look at the previous estimates of evacuation times.

I f

8g don't recall whether I looked at it at this time or I am 9

confusing that with a subsequent review of the old PRA, the j

10 100 percent PRA.

But I did look at accident development

[

I 11 '

times, and I believe it was connected with this affidavit.

i I

'O 12 l Q

The source of those accident progression times i

1 13 c.

would be the Shoreham PRA and not some other non-Shoreham j

t 14 !

specific PRA type document?

j t

~

j 15 !l A

At the time I prepared this, I believe that is I

16 correct.

I looked at the Shoreham PRA.

[

t 17 Q

But not a document like NUREG-0396 or WASH-1400?

4 i

i 18 A

That's correct.

Now, I may have looked at that i

setofdataonaccidentanddevelopmenttimesfromsomeotherl 19 i

t 20 source than the PRA; that's where I am a little fuzzy right 1

i 21 now where I got the set of accident times, accident l

J 22 development times, when I prepared this affidavit.

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Q Was it a particular table that you had to prepare h

2j

-- the accident time data you are talking about, what form i

3 ii was it in, to the best of your recollection?

1 t

H 4J A

I don't really recall, except that it was not in i

5 y the same form as Mr. Lieberman's affidavit.

So it makes some 6

translations between information I had and what Mr. Lieberman 7

had in his affidavit.

8i Q

Do you believe you still have this information 9I that you relied on at your offices in California?

l 10 A

Since I can't even remember what document it's s

i 11 3 from, I would have to say maybe, but I don't know.

I am not l

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O i

i 12 sure if I could locate it again.

If I had to locate it j

t 13 :

again, I would probably look in a different place.

I would l

l L

i 14 ;

probably look in the plan.

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15 MR. ZEUGIN:

Mr. Ross, I would in fact request 16 that Mr. Minor look for whatever document he may have relied f

i i

17 on in preparation of this affidavit, and we would like to

[

t 18 have it produced.

l i

i 1

)

19 MR. ROSS:

No, I think the practice in this case l

2 1

I 20, is for you to put your request in writing.

3 21 BY MR. ZEUGIN:

I l

22 Q

We will put it in writing after the deposition.

ll

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ii 34514.1 cox 26 1'

A Perhaps I can short-change it.

I did not roly on

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2' it in this affidavit.

I looked at it before I prepared the i

3 affidavit, but I did not rely on it.

There is nothing in I

l 4

this affidavit that relates to it.

{

l 5

0 In any caso, I would still like to have any l

6 documents that you consulte

are preparing the affidavit.

l 7

MR. ROSS:

I am ug to object to that 8

mischaracterization.

I think it mischaractorizes what tho l

l 9

witness said.

4 i

10 BY MR. ZEUGIN:

l 11 Q

I would like to go through a few of the statements ;

()

12 and ask for a little bit of an explanation.

l 1

13 A

All right, i

i 14 Q

Paragraph 1, last sentence, you state that "I am l

15 qualified to offer the following opinions regarding LILCO's j

16 motion."

Could you describe for me the bases that you 17 '

believe qualify you to offer the following opinions?

18 A

Yes, I think there's a combination of experience 19 and training here that I would say qualify me.

I have 20 testified on matters very closely related to this in this 21 proceeding; and that, by itself, is ono measure of 22 qualification.

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1l I have reviewed emergency plans, and I have i

i 2,

reviewed accident scenarios and accident sequences in various 3

db4 endeavors; and so I have the experience both from the jh) a 4j practical side and the testimony side to qualify me for 9

50 this.

6 Q

All right.

Let me have you turn to page 2 of the 7

affidavit and look at paragraph 3.

On the third line of that i

8 l

paragraph, you used the term "fast-developing accidents."

l t

9[

Could you please define that term for me, as you h

10 !

are using it in this affidavit?

4 11i!

A Certainly.

If you look at the accident sequences

()

b 12 1 that can result in core damage and/or releases to the 13 environment, they develop at different rates.

For instance, J

14 (

a very small break or a small leak in the primary pressure l

15 4 loop, primary loop of the reactor, in a boiling water H

4 I

16 ll reactor, is a potential loss of coolant, but it develops very L

17 a slowly; has been contrasted with a large break, which is 18 e rapid, with more rapidly developing LUCA event.

19 There are some events which take a long time to 20 result in core damage; some core damage results very 21 quickly.

What I am talking about are those events or l

22 sequences which, from the initiating activity or event, p

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1 whatever it is, to the time when they are in a vulnerable lI 2f state or already in a state of releasing radiation to the I

3; environment, there is a short period of time.

N 4 !!

And since this is a continuum of times, there's no 1

5[

one spe.cific time you say is short and one that is long.

But 6

it was, the ones I had in mind were the ones that would 7 ll certainly occur in less time than it took to evacuate the 8j people from the EPZ.

d 9A Q

Let me just follow up on a couple of things, to 4

10 make sure I completely understand your deposition.

I take it 11 because the Lieberman affidavit talked about total evacuation O

k 12 h times either being five hours and five minutes in the case of 13 ]

the controlled evacuation, or five hours 35 minutes in the d

14 g case of an uncontrolled evacuation, that in using this term, ll 15 ll you are talking about accidents that progressed from their 1

16 h initiating event to either a vulnerable state or release of 17 radiation off-site, that were less than those periods of 18 h time; is that correct?

19 '

A Yes.

Generally correct, yet.

20 Q

So these are generally less than five hour i

21 accidents?

i 1

l 22 A

I would say that's a good generalization of the O

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1t timing, yes.

Y.2 might say that there are some that are u

2j slightly shorter that would be more important, because those 3 yi that are shorter would have time for a release, and you would k

4" have time for the release to reach the evacuating people, be 1

5-they five, six, seven, eight, nine, 10 miles away from the 6

plant, before they actually escape the zone, and qualified to 7h be considered evacuated from the EPZ.

8 lI Q

Fine.

You used the term "vulnerable state" as a 9

plant condition.

Could you briefly explain that for me.

10 (

A Well, that's a term that was invented for the 11h Shoreham PRA.

It was meant to differentiate between the 12 :

danger of a core melt and a core melt, and there is a point 13,

where you are in danger of losing all of your cooling and c

14 j possibly melting the core.

In that state, you would say that h

u 15 ;

you were in a core vulnerable state.

That's a term of art 16 h that was used, mainly in the Shoreham PRA, and I haven't seen j 17 b it used a lot since then.

i i

18 Q

So, I take it then you aren't redefining the time j

19 ;

period from the way those are defined in the Shoreham PRA; 20 "

but, rather, you are using those terms equivalently with the l

21 g way they were used in the Shoreham PRA; is that correct?

22 A

I wasn't basing that definition on the Shoreham o

i i

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34514.1li cox 30 (1) 1 PRA.

It's a general reference to accidents that develop 2[

quickly as opposed to those that may take a day or two before 0

1 3!!

they release any radiation, h

ll 4)

Q The last part of that sentence has the phrase "or 5

for the full range of evacuation scenarios."

Could you 6g explain to me what you meant by that phrase?

7s A

Where are we?

I am having trouble,'inding the 8jj sentence.

1 9y Q

Actually, it's the third line, paragraph 3, and s

10 '

runs over onto the fourth line.

What I-am trying to do is c

i I

11 0 distinguish how -- what the full range of accident scenarios

()

12 [

means in comparison with the fast-developing accidents that 13 J you referred to just before that.

14 A

Would you repeat your question?

15 h Q

Yes.

I would just like you to explain to me what 16 you meant when you used the phrase "for the full range of 17 $

evacuation scenarioc" as it is used in this sentence.

i

'I 18,

A Well, I would have to go back a bit here to define '

l 19 L what I did mean.

I considered LILCO's analysis to be i

20 representative of a fairly idealized approach.

In LILCO's n

21 analysis, they were talking about the difference being 35 l

C) 25 minutes,somethingofthatnature,the!

22 minutes, I believe, l

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1i difference between a controlled and an uncontrolled s

4 2

evacuation with full compliance by the public.

What I

\\!

30 consider to be the full range of evacuation scenarios would

!1 8

4" include controlled and uncontrolled, but also compliant and o

5 $

noncompliant responses by the public.

6J Q

So when you are using the phraso full range of 1

7 evacuation scenarios, you are talking about the various 8j assumptions that were made in the testimony and ultimately in d

9 f, the plan with regard to people's compliance or noncompliance k

10 [

with the evacuation plan that is contained in the Shoreham 0

11 ij plan; is that correct?

Maybe I am not making myself clear.

}

As contrasted to, essentially, a full range of PRA 12y!

13 d accidents.

In other words, the entire universe of accidents 0

14 that could occur in a representative of PRAs.

15 h MR. ROSS:

Only if you understand the question.

li 16 '

THE WITNESS:

I can't answer it the way you asked, 17 j because I didn't do what you asked.

So let me answer by 18 [

first stating what I am interpreting your question to mean.

19 L I would answer that that there are two parts to this first l

L l

20 ?

sentence in paragraph 3.

I am talking about accidente, and I L

21 am talking about evacuation scenarios.

In terms of l

l l

22 accidents, I don't believe that the fast-developing accident

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(S) 0 1 ll is properly accounted for in deciding immateriality, in the

?i 2

j LILCO affidavit and brief.

And in terms of scenario, I don't 31 believe they considered what I would interpret to be the d

4]4 important comparison, and that is whether or not the public l!

h 5

is going to respond as directed, whether you have to consider 6

a compliant or a noncompliant public response.

Does that 7

answer your question?

8h BY MR. ZEUGIN:

9 Q

Yes.

I think that c]arified the sentence for me.

b 10 ]

Let me have you look at the next sentence.

In that sentence 11 you state, "in such accidents, it is possible that there

()

J 12 f!

could be a release sooner than LILCO 6xpects."

What did you 1

13 j mean or what did you have in mind was the release time that n

14 LILCO "expected"?

15 b A

Well, LILCO's premise was that the time difference 1

16,

between a controlled and uncontrolled evacuation was so small l

17 o that it would be immaterial on the terms of its impact, in l

I 18 s essence.

I am not trying to quote LILCO's position, but l

l, 19 "

that's my general interpretation.

1 20 '

What I am implying in the second sentence is

t. hat 21 it is my belief that there are possibilities of accidents 22,

which either misanalyzed, misinterpreted, or changed state l

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because of some variable or some misdirected mitigation n

v 2 h effort, and become a more rapidly developing accident after 3]

evacuation has been called for.

Once that happens, then you N

l 4L have people on the road, in their automobiles, with no d

u 5

effective shielding, subject to the possible doses they would 6,

r:aceive if the plume does catch up and overtake their 7g evacuation route.

h 8:

Q Let me restate what I think you just said, and 9 j!

tell me if I restated it correctly.

l!

10 i!

A All right.

d 11 j Q

What you are assuming, in this particular

()

12 "

sentence, then, is a situation in which LERO has made an 13 evacuation recommendation based on its belief of when a 14 release will occur at the Shoreham facility.

Intervening 15 !!

events subsequent to that protective action recommendation 16 speed up the ultimate release of radiation, so that it i

17 g actually occurs much before it was predicted to occur at the I

I l

18 time the protective action recommendation was made; is that t

19 correct?

I 20,

A Partly.

l l

21 h Q

How is that wrong?

I 22 A

You said intervening events caused it to release

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It may be that there were no intervening events, L

2 [il but it was misanalyzed.

They thought it was one type of 3]

accident developing when in reality it was somothing they 4,

overlooked that would have told them it was a different type 1

5h of accident.

It was already on a faster progression toward b

61 release, and they got caught by it after they have already 7H ordered people to evacuate, u

8 Q

Let me have you then look at the next sentence, 3,

9p where you conclude that while 35 minutes represents only 10 10 c percent increase in evacuation time -- this is the language I

!i 11 am interested in -

"it wculd represent a much larger

()

a 12 !!

increase in the dose received by the evacuees caught in the i

13 r tail end of the evacuation."

!i 14 !)

Can you explain to me the basis for that Jl 15 g conclusion?

16 0 A

Sure.

If you assume that an evacuation was 17 1 ordered on the premise that people would evacuate in time, 18 J before the plume got to the edge of the EPZ, let's say, then 19 '

the dose the people would receive would be zero.

If, indeed, l

l 20 the plume catches up with their evacuation, and does engulf 21

• them in the plume for a period of time, be it even 35 l

22i minutes, the dose they would receive would be infinitely l

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1 larger, because you are comparing it to zero otherwise.

2 I am not trying to say it would be infinite, of 3

course it would not.

But it would be a substantially larger 4'

increase than just 10 percent.

It's not as if they were

!j 5

already getting 1 rad and now they are getting 1.1 rad of 6

dose.

It may be that they would receive many rem of dose 1

7 !!

when-before they might receive zero.

li 8

Q Have you attempted to quantify how much larger the 9jf dose may be?

10 h A

No, I haven't.

And any new or revised 11 [i calculations, I have not attempted to produce such O

!j; 12 0 calculations.

0 13 l

Q Do you contemplate doing so as part of your i

14 {

testimony on contentions 1 and 2?

i 15 l A

Well, that's a possibility.

16 li Q

How would you go about doing thIt calculation, if h

17 li you were to do so?

18 h A

Well, one possibility, I say it's only a possible, h

19h because I haven't really contemplated how I would do this, is 20 to look at the data we have already prepared in the past for 1

21 contention 61, which deals with evacuation and talks about 2 2.:

exposure of people in automobiles within the EPZ and O

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1 ll calculates the probabilities of them receiving doses within a 2 ly p io d l

couple of hours per-unit of exposure, (YS) ll 3 !!

Q In doing that calculation or preparing such an b

c 4 ll estimate, would one have to make assumptions about the 5[

off-site release that would occur as a result of the accident 4

6 at the plant?

u 7'

A Yes, that's inherent in the analysis that had d

8I already been done.

S 9c Q

I take it your prior testimony on contention 61 h

10 <

has already made certain assumptions with regard to the size i:

11 f of those off-site releases?

(

12 A

Yes.

13 Q

You would probably follow the same assumptions 14 j today, or you believe those assumptions remain valid today?

15 ')

A There's some factors that may even make them n

16 larger today.

17 Q

Those would essentially be the assumptions you g

18,

would use if you were to do this -- cr at lesst as of the 19 present time, those would be the assumptions you would use if l l

20 you were to do this calculation?

q 21 A

If I were to do this calculation by that 22 technique, which I just described as one possible way, that's

()

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what I would do.

N 20 Q

Mr. Minor, in paragraph 4, in the first sentence, 4

h 3j you talk about the difference in evacuation times that result l

4 kl from the assumption one makes with regard to compliance or 5

noncompliance of an evacuation order.

6 A

Yes.

7 ll Q

Do you believe that you are expert in drawing h8j conclusions about the amount of noncompliance that may result 4

9 l!

as a result of an uncontrolled evacuation?

10 j A

More likely, for that part of the testimony I I

11 !!

would rely on other witnesses to provide that input.

()

12 h Q

And so I take it, then, as far as your own F

13 j expertise is concerned, the part of this particular paragraph 14 4 that you feel qualified to testify to is the fact that there I

h 15 !!

is a greater likelihood of evacuees being affected by a fast h

16 '

moving plume if there is an 80-minute difference between 17 0 controlled and uncontrolled evacuations, than if there was a 18 35-minute; is that correct?

19 MR. ROSS:

Counselor, I am going to object to that 20 as a mischaracterization of the witness' statements.

He has 1

21 '

testified he is competent to testify to the matters there in 22 the affidavit.

You have mischaracterized about his role in

()

L Acr.-Fiionit AI. R Er>olt iliits. INc h

202 347 3;oo

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34514.1)l 38 cox j

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1 the upcoming testimony.

MR. ZEUGIN:

I think the witness.can correct me if 2

4 3

I was wrong.

4l MR. ROSS:

Do you remember the question?

i\\

h 5 fj THE WITNESS:

Yes, I believe I do.

I would like 6ff to go back to what is in my affi, davit, because that's the 7 h start of your question.

8N BY MR. ZEUGIN:

ii 9f Q

Fine.

10 A

What I am stating here is that from my position 11 [

and my belief, the important range of evacuation times to r

O k

12 [

consider is different than that chosen by LILCO in their n

13 li affidavit, in their motion or filing, and I believe that il 14 k based on my knowledge and experience with emergency planning 15 0 issues, and emergency plans per se, that it is important to 1

16 0 consider the range of variables that would be important in

l 17 j determining dose reductions.

And if you cannot assure i

i 18 yourself of dose reductions, when you consider the full 19 L range, then you have to make a different protective action 20 a decision.

That is where I state in paragraph 4 of my 1

21 '

affidavit I believe that LILCO's motion has fallen down.

l 22 Now, I don't know if that answers your question,

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34514.1ll cox P

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but I am trying to clarify the basis that I came f. rom in 2,l creating paragraph 4.

I 3h BY MR. ZEOGIN:

!iv 4]

Q Let me ask you, Mr. Minor, if you have attempted 5y at any point to quantify the probability of these 9

6" fast-developing accidents that you express concern about in D

7y both paragraphs 3 and 4?

r P.

8l A

Quantifying the probability?

9h Q

Their probability of occurrence?

10 4 A

I have not attempted to make a new 0

11 !

quantification.

There are quantifications around that I

('~'1 12 j could look at.

U 13 j Q

Could you identify those for me?

f 14 i A

The PRA, the 100 percent PRA has many accidents h

15 defined and defines their warning time, their release time, 16 4 duration of release.

You can get some values from those that h

17 !!

are representative of accidents.

a

!l 18 F Q

Do I take it the numbers you are talking about are i t

4 19 1 in documents that have been prepared by LILCO or LILCO's 20 0 consultants, as compared to independent assessments that you 0

21 g may have done in the past of those probabilities; is that 22 <

correct?

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A In making the statement I just completed and made 2 [l i

to you, yes, that is correct.

But it doesn't mean they il u

3 h aren't also elsewhere.

There may be some similar accident 4 h release times and so forth involved in the analysis done by 5

Dr. Finlayson and myself for contention 61.

But I have not B

6 gone back to that data, and I am sure I haven't.

)

7 Q

But that would be the other source you are aware 8]

of at this time?

d 9f A

Yes.

n 10 h Q

Are there any others?

11 L A

Oh, there are numerous other possibilities, but a

()

12 g lot of them are the theoretical work that's going on now to i

13 i, try to decide what would be a good standard to use in the 1

iI 14 y future.

And not many of those are in an accepted state at 4

15 ij this point.

D 16 Q

In paragraph 5, in the second sentence, you used 17 j the phrase "slow-developing" to define accidents.

Is your 18 h use of the term "slow-deve..oping" meant to encompass all 19 ;

accidents that aren't defined la the class of "fast-breaking I

20 accidents"?

h 21.1 A

Well, there's probably a gray zone in between I

l 22 them.

But it is meant to define those types of accidents i

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which are sufficiently slow that even if you had an extended 1

2j evacuation, the people had still left the EPZ by the time the 0

3 l release had reached the area, near the edge of the EPZ.

i 4 ;l So it would be -- well, I couldn't put a number on a

5I it exactly, but probably longer than the, let's say, 6-1/2 6

hours that we are talking about in the LILCO affidavit.

7 Q

You also used the phrase "idealized accidents."

p 8 d Could you define that phrase for me?

L 9

A Well, that was a reference in paragraph 3.

If you 10 ]

look at an evacuation, and you say this evacuation will occur 11 in a certain period of time, and the effect on the public, as O

12 F.

far as risk and dose, will be essentially zero, because they l

13 g evacuate before the release gets to the area they were 1

14 previously occupying, then you would say that was an d

15 idealized accident, and the accident wasn't allowed to get 16 h there before they had already left.

17 What I am trying to identify is the other types of y

18 accidents that may not follow that exact plan or scenario and j 19 :

may actually release earlier and arrive at that area while 20,

the public is still in the EPZ.

Does that clarify that?

I l

21 Q

Yes.

Let me ask you, Mr. Minor, if it is your i

l 22i understanding of the way the protective action recommendation O

l A CI - 121iDI: R AI RI POR ll:RS. INC.

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34514.1 !!

cox 42 1y proceduu2s of the Shoreham plan work, that that evacuation is (I,

2q recommended only in those cases where it can be completed in t

i 3 l-terms of the last person leaving the EPZ before a release l

4!

occurs from the plant?

Is that your understanding of the 0

5U cases in which evacuation was recommended?

J 6j A

No.

7' Q

Could you give me your understanding of how the 8

protective action recommendations work as they appear in the 9

Shoreham procedures?

10 A

Well, I don't know the exact words that come from 11,

the procedures, but, in essence, it's predicated on a dose O

F 12 4 reduction.

If you can achieve a substantial dose reduction 13 a by evacuating, compared to sheltering, you would recommend a

14 the evacuation.

Vice versa, if you could get more dose 15 reduction by sheltering than evacuating later, you would do 16 h that.

?

17 q MR. ZEUGIN:

I think this is a good place to take 1

18 q a good five-minute break.

Before we go on the break, though, l I

I 19 '

Ron, I wanted to ask you if you were aware yet of the status i

20 of the nine witnesses that I guess have.been proposed for l

21 /

next week?

22 MR. ROSS:

We can discuss that during the break, I ;

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1 think.

2[

MR. ZEUGIN:

Do you know yourself right now, or do l

3 you need to check back with your office?

I 4i MR. ROSS:

I think we can discuss it at a break.

I 5

MR. ZEUGIN:

Okay.

F 1

6 ]l (Recess.)

7, BY MR. ZEUGIN:

8h Q

Mr. Minor, maybe we can short-circuit what is left H

9p of this deposition.

Let me ask you if your current views li 10 regarding LILCO'e immateriality argument have changed since 11 (i the time you changed your January 29 affidavit?

C) t 12 g A

They have not changed.

?

13 !

O Have they been amplified in any way by thinking 14 about the issue more?

a 15 MR. ROSS:

Objection, asked and answered.

1 16 THE WITNESS:

I think there is more substantiating 1

17 [

evidence that the probability of fast-moving accidents is 18 "

quite high.

Therefore, the chance of getting into these 19 situations that I talk about in the affidavit are possibly l

20 l higher probability than I thought at the time I wrote it.

i 21 d BY MR. ZEUGIN:

22 Q

What is the basis for that different belief today

()

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than at the time that you wrote that, the January 29 2'

affidavit?

3 A

Just going back and looking over data in the 4[

meantime, such as the PRA, and reflecting on both timing and a

5 f probability.

iI 60 Q

So it isn't any generation of new data; it's N

7g rather more of an opportunity to consider the existing data; n

f 84 is that correct?

Y) 9 l]!

A That's correct.

10 Q

You also stated -- you just stated, Mr. Minor, 11 that the probability of fast-breaking accidents is, and I

()

b 12 y think I remember your words, "quite high."

Have you l'

13 Ij attempted to quantify in any way that probability?

il 14 ii A

Not on my own.

I had attempted to determine which 4

15 g portion of accidents analyzed in the 100 percent PRA would 16 h fit into the fast developing cc.tegory, and just looked at the E

17 part of the total probability of core melt and release that 9

18 )

could be categorized into the fast-developing bracket.

19 Q

What percent, to the best of your recollection, 20 ]

falls into that bracket?

1 21 ]

A I don't recall the number.

It's a substantial 22 part of the whole probability of core melt though.

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1d Q

More than 10 percent?

2 ll MR. ROSS:

Objection, asked and answered.

He said 3 f he doesn't recall.

/

4 THE WITNESS:

I don't really recall the number, 5y but it's a number you or I or anybody else could go look at

'I 6

the PRA and recreate.

It's just a matter of doing it.

7p BY MR. ZEUGIN:

il u

8:

Q Mr. Minor, is there anything you would like to add C

9) in the way of technical information or discussion to your 4

10 ;

expressed concerns about LILCO's immateriality argument that 11 h do not appear in your affidavit?

()

b 12 MR. ROSS:

Counsel, I am not clear.

Are you 13 "

asking him if he needs to modify this affidavit?

For what 14 purpose?

15 BY MR. ZEUGIN:

16 !;

Q Basically, my earlier question was have any of 17h your views changed since the time you drafted this

~

18 '

affidavit.

What I am now asking is are there other reasons 19 !

that Mr. Minor might have, in addition to the ones that are 20 laid out in his affidavit, for having -- for disputing n

21 j LILCO's immateriality argument.

1 22 j MR. ROSS:

The affidavit purports to support the l

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!i 1ll government's opposition to a motion for summary disposition.

2 i There's been a ruling on that motion.

There's no requirement 3

for Mr. Minor to come up with any additional reasons to 4

support the government's position on that motion.

q 5p BY MR. ZEUGIN:

e 6

Q You can answer the question, Mr. Minor.

i 7

A No.

g r

8' MR. ZEUGIN:

I have no further questions.

9j MR. ROSS:

Thank you.

10 (whereupon, at 2:55 p.m.,

the deposition was 11 :,

concluded.)

O 12,<

13 4A GREGORY l'. ?%NOR 14 !;

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CERTIFICATE OF NOTARY PUBLIC & REPORTER 47

[D U

W the officer before whom I, _ ENDY S.

COX the foregoing deposition wac taken, do hereby certify that the witness whose testimony appears in the foregoing deposition was duly sworn by me; that the testimony of said witness was taken in shorthand and thereafter reduced to typewriting by me or under my direction; that said deposition is a true record of the testimony given by said witness; that I am neither counsel

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

and, further, that I am not a relative or employee of any attorney or counsel

k employed by the parties

hereto, nor financially or otherwise interested in the outcome of this action.

v NotaryPublic2y,lumbia and for the District of do My Commission Expires NOVEMBER 14, 1992 O

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PROFESSIONAL QUALIFICATIONS OF GREGORY C. MfNOR GREGORY C. MINOR MHS Technical Associates 1723 Hamtton Avenue Suite K San Jose, Califomia 95125 (408) 266 2716 EXPERIENCE-i 1976 to PRESENT Vlee. President - MHB Technical Associates. San Jose Califomia Engineering and energy consultant to state, federal, and private organizations and individuals.

Major actMtles include studies of safety and risk involved in, energy generation, providing technica! consulting to legislatke, regulatory, public and prtvate groups and expert witness in behalf of state organizations and citizens' groups. Was co-editor of a critique of the Reactor Safety Study (WASH 1400) for the Union of Concemed Scientists and co author of a risk analysis of Swedish reactors for the Swedish Commission. Served on the Peer Review Group of the NRC/TMI Special Inquiry G (Rogovin Committee). Actively involved in the Nuclear Power Plant Standards Committe work for the instrument Society of America (ISA).

1972 1976 t

Manaaer. Advanced Control and Instrumentation Encineerino General Ele Nuclear Enerov DMslon. San Jose. Califomia Managed a design and development group of thirty four engineers and support person:

designing systems for use in the measurement, contrd and operation of nuclear reactors.

Involved coordination with other reactor design organizations, the Nuclear Regulat Commission, and customers, both overseas and domestic.

Responsibilities included coordinating and managing and design 'and development of contrd systems, safety systems, and new control concepts for use on the next generation of reactors.

i The position included responsibilty for standards applicable to control and instrumentation, as

(

weit as the design of short term solutions to field prot 9 ems.

The discipilnes involved included electrical and mechanical engineering, seismic design and process computer control /ps>gramming, and equipment qualification.

1970 1972

\\

Manaaer. Reactor Control Systems Deston. General E'ectric Comeanv. Nuetear Enerov t

DMalon. San Jose. Califemia (i

Managed a group of seven engineers and two support personnel in the design and preparation of the detaled system drawings and control documents relating to safety and emergency systems for nuclear reactors. Responsibalty required coordination with other O

.s.

i 1

4 l

h s

,c

-,,,-.,_-.-..nn,.,v.n-

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l design organizations and interacticn with the customer's engineering personnel, as well as regulatory personnel.

1963 1970 Deslon Encineer. General Beetric Comoany. Nuefear Enerov OMsion. San Jose. Canfomia Responsible for the desigra of specific control and instrumentation systems for nuclear reactors. Lead design responsibility for various subsystems of instrumentation used to measure neutron flux in the reactor during startup and intermediate power operation.

Performed lead system design function in the design of a major system for measuring the power generated in nuclear reactors. Other responsibaities induded on site checkout and testing of a complete reactor control system at an experimental reactor in the Southwest.

j ReceNed patent for Nuclear Power Monitoring System.

t960 1963

~

Advanced Enoineerina Procram. General Sectric Comcany: Assianments in Washi"G12D.

Canfomia. and Arf 20na Rotating assignments in a variety of disciplines:

Engineer, reactor maintenance and instrument design, KE and D reactors, Hanford, Washington, circuit design and equipment maintenance coordination.

Design engineer, Microwave Department, Palo Nto, Califomia. Work on design of cavity couplers for Microwave Traveling Wave Tubes (TWT)

Design engineer, Computer Department, Phoenix, Arizona. Design of core drMng circuitry.

Design engineer, Atomic Power Equipment Department, San Jose, Califomla.

Circuit design and analysis.

Design engineer, Space Systems Department, Santa Barbara, California.

Prepared control portion of satellite proposal.

Technical Staff Technical MD'tary Planning Operation. (TEMPO), Santa Barbara, r

Califomia. Prepare analyses of missue exchanges.

During this period, completed three-year General Electric program of extensNe education in advanced engineering principles of higher mathematics, probabDity and analysis. Also completed courses in Kepner.Tregoe, Effective Presentatien, Management Training Program, and various technical seminars.

O 2

EDUCATION UnNorsity of Califomia at Berkeley, BSEE,1960.

Advanced Course in Engineering three-year curriculum, General Electric Company,19 Stanford UnNersity, MSEE,1966.

HONORS AND ASSOCfATIONS Tau Beta Pi Engineering Honorary Society Co-holder of U.S. Patent No.

System,' February,1971.

3,565-760, ' Nuclear Reactor Power Monitoring Member: American Association for the Advancement of Science.

Member:

Nuclear Power Plant Standards Committee, Instrument Society of America.

PERSONAL DA.T,f Bom: June 7,1937 Married, three children Residence: San Jose, Califomia O

PUBUCATIONS AND TEST 1 MONY 1.

G. C. Minor, S. E. Moore, ' Control Rod Signal Muftlplexing,' IEEE Transactbns on Nuclear Science, Vol. NS 19, February 1972.

2.

G. C. Minor, W. G. Milam, 'An Integrated Control Room System for a Nuclear Power Plant,'

NEDO 10658, presented at intomational Nuclear Industries Fair and Technical Meetings, October,1972, Basle, Switzertand.

3.

The above article was also published in the German Technical Magazine, NT, March,1973.

4.

Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the Joint Committee on Atomic Energy, Hearing held February 18,1976, and published by the Union of Concemed Scientists, Cambridge, Massachusetts.

I 5.

Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the Califomia State Assembly Committee on Resources, Land Use, and Energy, March 8,1976.

6.

Testimony of G. C. Minor and R. B. Hubbard before the Califomia State Senate Committee on Public Ut#ities, Transit, and Energy, March 23,1976.

O 3

O m.

i l

7.

Testimony of G. C. Minor regarding the Grafenthoinfeld Nuclear Plant, March 16 17, 1977, Wurzbuerg, Germany.

Testimony of G. C. Minor before the Cluff Lake Board of Inquiry, Regina, Saskatchewan, 8.

Canada, September 21,1977.

9.

The Alsks of Nuclear Power Reactors:

A Review of the NRC Reactor Safety Study WASH _.

3400 (NUREG.75/014L H. Kendall, et al, edited by G. C. Minor and R. B. Hubbard fof the Union of Concemed Scientists. August,1977.

10.

Swedish Reactor Safety Study-Barseback Risk Assessment. MHB Technk:a! Associates, January,1978. (Published by Swedish Department of Industry as Document Osl 1978:1) 11.

Testimony by G. C. Minor before the Wisconsin Public Service Commission, February 13, 1978, loss of Coolant Acedents: Their Probability and Consecuence.

12.

Testimony by G. C. Minor before the Califomia Legislature Assembly Committee on Resources, Land Use, and Energy, AB 3108, Apri 26,1978, Sacramento, Califomia.

13.

Presentation by G. C. Minor before the Federal Ministry for Research and Technology (BMFT), Meeting on Reactor Safety Research, Man / Machine Interface in Nuclear Reactors.

August 21, and Sep* ember 1,1978, Bonn, Germany.

Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard, before the Atomic Safety 14.

and Ucensing Board, September 25,1978, in the matter of Black Fox Nuclear Power Station Constructbn Permit Hearings Tulsa, Oktahoma.

O Testimony of G. C. Minor, ASLB Hearings Related to TMI 2 Accident, Rancho Seco Power 15.

ri ni. on be8aif of Friemes of the earth. September is. i979.

16.

Testimony of G. C. Minor before the Michigan State Legislature, Special Joint Committee on Nuclear Energy, Imotications of Three Mife Isfand Accident for Nuefear Power Plants in Michican. October 15,1979.

17

& Crtticat V.ew of Reactor Safety. by G. C. Minor, paper presented to the American Associatbn for the Advancement of Science, Symposium on Nuclear Reactor Safety, January 7,1980, San Francisco, Califomla.

18.

The Effects of AcInc on Safety of Nuclear Power Pfants. paper presented at Forum on Swedish Nuclear Referendum, Stockholm, Sweden, March 1,1980.

19.

Minnesota Nucisar Ptants Gaseous Emissions Study. MHB Technical Associates.

September 1980, prepared for the Minnesota Pollution Control Agency, Rosevi!!e, MN.

20.

Testimony of G. C. Minor and D. G. Bridenbaugh before the New York State Public Service Commission, Shoreham Nuclear Plant Construction Schedule, in the matter of Long Island Ughting Company Temporary Rate Case, case a 27774 September 22,1980.

21.

Systems Interaction and Sincie Failure Criterion. MHB Technical Associates, January,1981, prepared for and available from the Swedish Nuclear Power inspectorate, Stockholm, l

Sweden.

4

'1 22.

Testimony of G. C. Minor and D. G. Bridenbaugh before the New Jersey Board of Public

(_")

Utiltles, Ovster Creek 1980 Refuelino Outace Investication. In the matter of the Petition of Jersey Central Power and Ught Company for approval of an increase in the rates for electrical service and adjustment clause and factor for such service, CAL Docket No. PUC 3518-80, BPU Docket Nos. 804 285,807 488 February 19,1981.

23.

Testimony of G. C. Minor and D. G. Bridenbaugh on PORV's and Prtigfzer Heaters. Diablo Canyon Operating Ucense hearing before ASLB, in the matter of Pacific Gas and Electric Company (Diablo Canyon Nudear Power Plant Units 1 and 2), Docket Nos. 50 275-OL 50-323-OL January 11,1982.

24.

Testimony of G. C. Minor and R. B. Hubbard on Emeroency Resoonse Plannino. Diablo Canyon Operating Ucense hearing before ASLB, Docket Nos. 50 275-OL 50 323-OL January 11,1982.

25.

Systems interaction and $1nde Failure Criterion-Phase ll Reoort. MHB Technical Associates, February 1982, prepared for and availatse from the Swedish Nuclear Power inspectorate Stockholm, Sweden.

26.

Testimony of G. C. Minor, R. B. Hubbard, M. W. Golcsmith, S. J. Harwood on behalf of Suffdk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting Company, Shoreham Nudear Power Station, Unit 1, regarding Contention 78, Safety Classification and Systems interaction. Docket No. 50422-OL Apri 13,1982.

27.

Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffdk County, before the Atomic Safety and Ucensing Board, in the matter of Long :tand Ughting Company, O

' Shoreham Nudear Power Station. Unit 1, regarding Su* folk County Contentbn 11. PassNe Michanical Vane Falure. Doaket no. 50422 OL Apri 13,1982.

28.

Testimony of G. C. Minor and R B. Hubbard on behalf of Suffolk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting Company, Shoreham Nudear Power Station, Un)t 1, regarding suffolk County Contention 27 and SOC Contention

3. Post-Accident Monitorino. Docket No. 50 322 OL May 25,1982.

29.

Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety and Ucensing Board, In the matter of Long Island Ughting Company, Shoreham Nudear Power Station, Unit 1, regarding Sudfdk County Contention 22. SRV Test Procram. Docket No. 50422-OL May 25,1982.

30.

Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffdk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting Company, Shoreham Nudear Power Station, Unit 1, regarding Peduction of SRV Cha4ences, Docket No. 50 322 OL, June 14,1982.

31.

Testimony of G. C. Minor on behalf of Suffdk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island ughting Company Shoreham Nuclear Power Station Unit 1, regarding Environmental Quamcation. Docket No. 50422-OL January 18, 1983.

O 5

---',-=#

hshony of G. C. Minor and D. G. Bridenbaugh before the Pennsylvania Public Utilty 32.

Commission, on behalf of the Office of Consumer Advocate, Pecardino the Cost of Constructino the suscuehanna Steam Electric Station. Unit f. Re: Penns%vania P Ught, Docket No. R 822189, March 18,1983.

Supplemental testimony of G. C. Minor, R. B. Hubbard, and M. W. Gddsmitn on behalf of 33.

Suffolk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting Company, Shoreham Nudear Power Station, Unit 1, regarding Safety Classification and Systems Interaction (Contention 74L Docket No. 50 322, March 23,1983.

34 Verbal testimony before the District Court Judge in the case of Sierra Club et. al. vs. DOE regarding the Clean-up of Uranium Mill TaHings, June 20,1983.

35.

Systems Interaction and Sin-'le Fallure Criterion: Phase 3 Reoort, MHB Technical Asso:iates, June,1983, prepared for and avaHable from the Swedish Nudear Power Inspectorate, Stockhdm, Sweden.

36.

Systematie Evaluation Proctam-Status Reoort and initial Evaluation. MHS Technical Associates, June,1983, prepared for and avaHable from the Swedish Nuclear. Power inspectorate, Stockholm, Sweden.

Testimony of G. C. Minor, F. C. Finlayson, and E. P. Radford before the Atomic Safety and 37.

Ucensing Board, in the Matter of Long Island Ughting Company, Shoreham Nuclear Power Station, Untt 1, regarding Emeroency Plannino Evacuation Times and Doses (Contentions

65. 23 D and 23 Hl. Docket No. 50-322-OL-3, Novembvr 18,1983.

38.

Testimony of G. C. Minor, Sizewell 'B' Power Station Public inquiry, Proof of Evidence Pecardino Safetyissues. December,1983.

Testimony of D. G. B:idenbaugh, L M. Danielson, R. B. hubbard and G. C. Minor before the 39.

State of New York Public Service Commission, PSC Case No. 27563, in the matter of Long Island Ughting Company Proceeding to Investicate the Cost of the Shoreham Nuclear Generatino Facility - Phase 11. on behalf of County of Suffdk, February 10,1984 40.

Testimony of Fred C. Finlayson, Gregory C. Minor and Edward P. Radford before the Alcmic Safety and Ucensing Board, in the Matter of Long Island Ughting Company, Shoreham Nudear Power Station, Urut 1, on behalf of Suffolk County Regarding Emercency Pfannino -

She'terino (Contention 61). Docket No. 50-322 OL March 21,1984 Testimony of G. Dennis Eley, C. John Smah, Gregory C. Minor and Dale G. Bridenbaugh 41.

before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting company, Shoreham Nuclear Power Station Unit 1, regarding EMD DietW Generators and 20 MW Gas Turbine. Docket No. 50-322-OL, March 21,1984.

42.

Revised Testimony of Gregory C. Minor before the Atomic Safety a4 Ucensing Board, in the mat *er of Long Island Ughting Company, Shoreham Nuclear Power Station Unft 1, on behalf of Suffolk County regarding Ernercency Plannino Recovery and Peentry (Contantions 85 and 88). Docket No. 50 322 OL July 30,1934.

43.

Testimony of Dr. Christian Meyer, Dr. Jose Roesset, and Gregory C. Minor before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting Company, O

+

a

e Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County, regardin Hearinos. Seismic Cacabilities of AC Power Sources. Docket No. 50-322-OL, July 1 44 Affidavit of Gregory C. Minor, Emergency Planning legal Authority Court Case, State Co of New York. September 11/1984.

Surrebuttal Testimony of Dale G. Bridenbaugh, Lynn M. Danielson, Richard B. Hubbard 45.

Gregory C. Minor, Before the New York State Public Service Commission, PSC Case No 27563, Shoreham Nuclear Station, Long Island Ughting Company, on behalf of Suffolk County and New York State Consumer Protection Board, regarding Investloation of the Cost of the Shoreham Nuclear Generatino FacilRv. October 4,1964.

46.

Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C. Minor on behalf of Massachusetts Attorney General, DPU 84-145, before the Massachusetts Department of Public Utilities, regarding Prudence of Excenditures by Fitchburo Gas and Efectric Ucht Comoany for Seabrook Unit 2. November 23,1984,84 pgs.

47.

Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C. Minor on behalf of Maine Public Utilities Commissbn Staff regarding Prudence of Costs of Seabrook 1).ni_t 2, Docket No.84-113, December 21,1984.

48.

Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Suffolk C regarding Shoreham Emercenev Diesei Generator Loads. Docket No. 50-322 OL, Janua 25,1985.

49.

Direct Testirnony of Dale G. Bridenbaugh, Lynn M. Danie< son, and Gregory C. Minor on behalf of the Vermont Department of Public Service, PSB Oocket No. 5030, regarding O

Prudence of Central Vermont Pubite Servko Corocrations Costs for Seabroo 11,1985.

t 50.

I Surrebuttal testimony of Gregory C. Minor on behalf of the Vermont Department of Public Service, PSB Docket No. 5030, Prudence of Central Vermont Pubne SeMee Corocrations Costs for Seabroek 2, December 13, 1985.

51.

Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price, and Steven C.

Sholly on behalf of State of Connecticut Department of Public Utilky Control Prosecutorial DMslon and DMsion of Consumer Counsel regarding the Prudence of Eroenditures on Mmstone Unit 3. Docket No. 83 07 03, February 18,1986.

52.

Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attomey General regarding the Prudence of Eroendtures by New Encfand Power Ce for Seabrook Unit 2. Docket Nos. ER 85 646-000, ER 85-647 000, February 21,1986.

53.

Direct Testirnony of Gregory C. Minor on behalf of the Prosecutorial DMslon of CDPUC reguding CL&P Construction Prudence for Mastone Uni 3, Docket No. ER 85 720 001 March 19,1986.

54.

Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attomey General regarding WMECo Construction Prudence for MMstone Uni 3, Docket No.

85 270, March 19,1986.

O 7

I

Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachus 55.

Attomey General regarding WMECo's Commercial Ooeratino Dates and Deferred Cu AM% on Milstone UnM 3. Docket No. 85 270, March 19,1986.

O j

56.

Rebuttal Testimony of Dale G. Bridenbaugh arid Gregory C. Minor on behalf of Massachusetts Attomey General regarding Rebuttal to New Endand Power Concanv's Seabrook 2. Docket Nea. ER.85446 001, ER 85447 001, April 2,1986.

57.

Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf d State of Malne Staff of Public Utilties Commission regarding Construction Prudence of MRistone Unit 3. In the matt 6r of Maine Power Company Proposed increase in Rates, Docket No. 85 212, A 21,1998.

58.

!molications of the Chemobvf4 Accident for Nuclear Emeroency Pfannino for the State of New Y.gric,, prepared for the State of New York Consumer Protection Board, by MH8 l

Tochtscal Associates. June 1986.

i 59.

Ottoct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of the Vermont Department of Public Service, regarding Prudence of Costs by Central Vermont.Pubre Service Corocration for MMstone 3. Docket No,5132, Abgust 25,1986.

60.

Surrebuttal Testimony of Gregory C. Minor in the matter of Jersey Central Power and U Company, regarding TMI Restart and Performance incentNes. (Oral testimony), OAL Docket No. PUC 793945, BPU Docket No. ER851116, September 11,1986.

61.

Surrebuttal Testimony or Gregory C. Minor on behalf of State of Vermont Department of Public Service, regarding CVPS/NU Construction Prudence related to Milstone Unt 3.

Docket No. 5132, November 6,1966.

62.

Direct Testimony of Gregory C. Minor and Lynn K. Price on behalf of State of Vermont Department of Public Service, regarding Frudence of Excend!tures for Sankrook 1. Docket No. 5132, December 31,1986.

63.

Direct Testimony of Gregory C. Minor on behalf of Suffolk County, before the Atomic S and Uconsing Board, concoming Shoreham - ProtectNe Action Recommendations (Contention EX 38). In the matter of Long Island Ughting Company, Shoreham Nuc' ear Power Station, Unit 1, Docket No. 50 322 OL 5, February 27,1987.

64.

Direct Testimony of Gregory C. Minor et. al. on behalf of the State of New York and Suffolk County, before the Atomic Safety and Uconsing Board, regarding The Scone of the Emeroenev Pfannino Exercise fContentions EX 15 and 16). In the matter of Long Island Ughting Company, Shoreham Nuclear Power Station, Unit 1. Docket No. So-322 OL 5, Apri 6,1987.

55.

Ditect Testimony of Gregory C. Minct regarding Emercenev Plannina Receotion Centers -

Monitorina and Decontamination. Shoreham Docket 50-322-OL-3 (Emergency Planning),

Apri 13,1987.

SS.

Testimony of Gregory C. Minor, Steven C. Shofly et. al. on behalf of Suffolk County, rogarding ULCO's Recction Cen'ers Plannino Basis, before the Atomic Safety and i

O n

Ucens!ng Board, in the matter of Long Island Ughting Company, Shoreham Nuclear Power Station Unit 1, Docket No. 50 322 0L 3, Apri 13.1987, 67.

Rebuttal Testimony of Gregory C. Minor and Steven C. Shott on behatt of Suffolk Coun f

regarding ULCO's Reecetion Centers (Rebuttal to Testimony of Lewis G. Ht/mant in the matter of Long Island Ughting Company, Shoreham Nuclear Power Station, Unit 1. Docket No. 50-3224L 3, May 27,1987.

68.

Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attomey General, before the Federal Energy Regulatory Commission, regarding C1041 Electric Comoany Prudence Related to Seabrook Unit 2 Constnsetion Excenditures. Docket No. ER86 704 001, July 31,1967, 69.

Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor before the Pennsknla Public UtAity Commission, Regarding Beaver Valley Unit 1, Docket No. 179070318. OCA Statement No. 2, August 31,1987.

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January 29, 1988 O

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMTSSION Before the Atomic Safety and Licensina Board l

)

In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

)

Docket No. 50-322-OL-3

)

(Emergency Planning)

(Shoreham Nuclear Power

)

Station, Unit 1)

)

-)

AFFIDAVIT OF GREGORY C.

MINOR

()

Gregory C. Minor, being duly sworn, hereby deposes and says e

as fol?.ows:

1.

I am Vice President of MHB Technical Associates of San Jose, California, a consulting firm specializing in energy-I L

related issues.

I have appeared several times previously before this Board as an expert on emergency planning issues; including i

accident consequences.

I have read and am familiar with LILCO's Motion for Summary Disposition of Contentions 1, 2 and 9 --

Immateriality (December 18, 1987) (the "Motion") which seeks summary disposition of Contentions 1, 2 and 9 on grounds of "immateriality."

I am qualified to offer the following opinions

()

regarding LILCo's Motion.

I 1

i

2.

The basis for LIICO's Motion is its assertion that the alleged 35-minute differance between a controlled and uncontrolled evacuation is "immaterial."

Accordingly, LILCo argues that if it were incapable of implementing any traffic control, the protective actions available to it would not be unacceptably limited.

I do not agree with LILCO's unqualified statement.

~

3.

While the basis for LILCO's argument may be true when considering idealized accident and evacuation scenarios, it does not necessarily hold true for fast-developing accidents or for the full range of evacuation scenarios.

In such accidents, it is possible that there could be a release sooner than LILCo expects,

(}

and that such a release could be of sufficient severity for the radioactive plume to overtake and immerse late evacueer in the plume.

Although 35 minutes represents only about 10% increase in LILCo's projected evacuation time for a controlled, fully-compliant evacuation, it would represent a much larger increase in the dose received by evacuees caught in the tail end of the evacuation.

Such evacuees could be exposed to doses in excess of the EPA's protective actions guidelines (pAGs) and possible I

health consequences could restit to those evacuees experiencing such doses.

4.

The more important range of evacuation times to be consider 6d is the range between a controlled / compliant evacuation 2

and an uncontrolled /50% non-compliant evacuation.

Here the difference is 80 minutes, rather than 35 minutes, and represents s/

an even greater likelihood of delayed evacuees being effected by a fast-moving plume from an unexpectedly fast-developing accident.

The doses received in this case would be even larger.

5.

On this basis, it is apparent that the premise of LILCO's Motion does not hold true in all cases.

Proper emergency planning requires that one address a range of accidents, not just the slow-developing or idealized accidents which would support LILCO's Motion.

Fast-developing accidents with severe releases, such as is discussed above, must also be considered.

When all factors are censidered, LILCO's Motion is not factually valid.

6.

The above facts and opinions are true and accurate to the best of my knowledge and belief.

I am competent to testify to such matters and would so testify in any formal proceeding on this matter.

GREGORY %. MINOR subscribed to and sworn before me this J f day of January, 1988.

OFFICIAL 3EAL e Y:.cutthawr h

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My commission expires:

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