ML20206Q784
| ML20206Q784 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/02/1986 |
| From: | George Minor LONG ISLAND LIGHTING CO., MHB TECHNICAL ASSOCIATES |
| To: | |
| References | |
| CON-#287-3151 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8704220036 | |
| Download: ML20206Q784 (62) | |
Text
3/5/
ORIGINAL '1RANSCR11>1' -m-u OF PROCEEDLLS ms UNITED STATES OF AMERICA FFigi SjC,gIA[C{ y NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
- - - - - - - - - - - - - - - - - - -x In the Matter of: :
- Docket No. 50-322-OL-5 LONG ISLAND LIGIITING COf1PANY : (EP Exercise)
(Shoreham Nuclear Power Station, (ASLDP No. 86-533-01-OL)
Unit 1)
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 0 DEPOSITION OF GREGORY !!INOR Washington, D. C.
Tuesday, December 2, 1986 ACE-FEDERAL REPORTERS, INC.
Stetoty;v [4wtm 444 North Capitol Street L Washington, D.C.1U01 (202)347 3700 Nationwide Coverage 800 336-6646 G70422OO36 861202 PDR ADOCK 05000322 T PDR
ERRATA C\
(_) DEPOSITION OF GREGORY C. MINOR DECEMBER 2, 1986 Page Line Is Should Be 23 19 now. It is in the now that is in the 32 7& 8 12:06 time. I believe 12:06 time, I believe 43 20 evacuation evacuations 56 7 A radiation unit A radiation dose unit 56 8 Rank of equivalent men Roentgen-equivalent-man formed form 56 18 Rank in equivalent man Roentgen-equivalent-man O
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i 1 ,
1 UNITED STATES OF AMERICA >
CR 29070 Joe Walsh NUCLEAR REGULATORY COMMISSION 3 2 ATOMIC SAFETY AND LICENSING BOARD 3
4 ,
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__________________ ___________.._x 5 In the Matter of: :
6 LONG ISLAND LIGHTING COMPANY : Docket No. 5 0.- 3 2 2'-OL-5
- (EP Exercise) 7 (Shoreham Nuclear Power Station, :
Unit 1) : (ASLBP No. 86-533-01-OL) i 8 ----------------------------------X l 9
10 DEPOSITIO OF GREGORY MINOR 11 Washington, D. C.
o) x_ 12 Tuesday, December 2, 1986 13 Deposition of GREGORY MINOR, called for examination, 14 pursuant to notice, at the Law Offices of Kirkpatrick &
f 15 Lockhart, 1900 M Street, N. W., Washington, D. C. 20036, at j i
16 2:30 p.m., before Garrett J. Walsh, Jr., a Notary Public in l 17 and for the Commonwealth of Virginia at Large, when were ja present on behalf of the respective parties:
19 KARLA J. LETSCIIE , ESQ.
Kirkpatrick & Lockhart 20 1900 M Street, N.W.
Washington, D. C. 20036 21 On behalf of the Intervenor, the County of Suffolk 22
2 i f')
~s 1 APPEARANCES: (Continuing) ,
2 KATHY E. B. McCLESKEY, ESQ.
I Hunton & Williams 5
3 707 East Main Street P. O. Box 1535 ,,
4 Richmond, Virginia 23212 ,
on behalf of the Applicant, Long Island Lighting Company 5 f RICHARD J. ZAHNLEUTER, ESQ. [
6 Deputy Special Counsel to the Governor . .
Capitol, Room 229 7 Albany, New York 12224 <
On behalf of the Intervenor, the State of New York 8 i BERNARD M. BORDENICK, ESO. :
9 Office of General Counsel U. S. Nuclear RegOlatory Commission -
10 Washington, D. C. 20555 ,
On behalf of the NRC -
h 11 WILLIAM R. CUM?iING , ESQ.
12 Federal Emergency Management Agency Washington, D. C.
13 On behalf of FEMA 14 I 15 16 17 18 19 20 21 22 O
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3 -r 4 GREGORY MINOR Page j J
5 Examination by Ms. McCleskey 4 (
. j-6 Examination by Mr. Cumming -
45 I
q Examination by Ms. Letsche 57 ;'
G 8 Examination by Ms. McCleskey 58 h q
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[ 1 11 0 12 13 E X II I B I T S ,
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14 (None) i; i
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1 PRggggglggg 2 Whereupon, 3 .
GREGORY MINOR i
4 was called as a witness and, having first-been duly sworn, i 5 was examined and testified as follows:
i 6 DIRECT EXAMINATION 1
l 7 BY MS. McCLESKEY: "
8 Q Mr. Minor, it's good to see you again. I'm Kathy I l
9 McCleskey, and I represent Long Island Lighting Company.
10 I will be asking you some questions today about i 11 the Shoreham exercise, of the emergency plan that took place o/
s_
12 on February 13th, 1986. d I
13 Would you please state your full name and current 6 1
14 address for the record? !
15 A My name is Gregory Minor. My address is MHB 16 Technical Associates, 1723 Hamilton Avenue, San Jose, 17 California 95125.
Is O And, you are going to be a witness in the exercise 19 litigation on behalf of Suffolk County; is that right?
20 A That is currently the plan.
21 O Uhen did you find out that you were going to be a 22 witness?
O
5 7"S V 1 'A It was on'the order of.a month ago, but I don't 2 remember the exact date.
n 3 Q And, what is your understanding of what you are [
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. 4- going to testify about? jt i
s A- The issues that I am tentatively planning to [
~
testify on are the Issues 15, Subparagraph I, which is part I 6
v of the Contention 36, I believe; and, also Contention 37.
a 0 okay. b
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9 A I guess you could say that the other way around.
10 Contention 36 is part of 15.I. I'm not sure how the ordering ;
4 gg goes there.
12 0 We hope that mystery at some point will be cleared 1
13 up for all of us. ;
14 Were you at the exercise on February 13th? !
15 A No, I was not.
16 0 IIave you looked at any documents that were generat-17 ed during the exercise to try to figure out what went on at 18 the exercise?
19 A Yes, I have.
20 0 What have you looked at?
21 A I've looked at a vast part of the discovery, 22 particularly related to all radiological issues and the O
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1 communications to and from the EOC and EOF, the logs of the 2 participants, and some of the FEMA-originated documents dealing a with the exercise. I 4 Q Okay. When you say that you looked at the discovery , a 5 you mean the documents that Suffolk County has received from 6 LILCO? .
7 A That is correct, and from FEMA.
s Q Okay. And you said that you've looked at -- hs 9 part of the discovery that you have looked at the logs of 10 players during the exercise.
l 11 Are those the logs that you looked at?
O 12 A The term " player" has significance in this proceed-13 ing which I have to clarify now. Could you clarify for me <
i 14 what you mean by player?
15 0 Well, in that last sentence I simply meant people 16 who were participating in the exercise as respondents to 17 the postulated emergency.
18 A Yes. Yes, I have looked at those logs.
19 0 Okay. What do you mean by player when you use 20 player?
21 A Well, it depends on what game you are in. It can l
22 have a lot of different meanings. And that's sort of the way l
l I
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V I have been construing it. I just wanted to clarify that that 1
i 2 is what you meant by it.
0 Okay. Itave you looked -- in addition to the LERO ')
4 player logs, have you looked at the LERO messages?
5 A LERO messages, I have reviewed. Yes.
e Q Did you review all of the mernages or.a particular i g subset of the messages?
a A Well, that's one of those questions, you can never g be sure. I may have thought I reviewed them all but not have 10 had all of them in my possession. ;
11 I reviewed a substantial number of those messages, ;
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12 and I am fairly sure it was all of them. But, I have no way l 13 of Proving that.
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14 MS. LETSCIIE: If I can just clarify for the record,
- 15 Mr. Minor has not reviewed all of the LERO messages. I to think he has been provided with those related to the communi- ,
17 cations he mentioned earlier about the radiological matters 18 and the communications betwoon the EOC and the EOP.
19 MS. McCLESKEY: Thanks, Ms. Letsche.
20 DY MS. McCLESKEY: (Continuing) 21 O Is that what you have looked at, the areas that --
22 A I should have qualified that, that I've reviewed O
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1 all of them in relation to the subject matter that I am 2 dealing with. l 3 Q Okay. 1 e4- A And, in general, I've only reviewed that part of [
5 the discovery file that relates to the issues that I'm con- ,
6 corned with. -
1 7 0 You have not, for example, read the messages on ,
1 8 traffic impediments? I t
9 A Correct. ,
to O All right. And, is the same true about the subject ,
11 matter of LERO player logs that you have reviewed?
(2) 12 A I'm sure there must be other players than the ones 13 I have reviewed. I have reviewed perhaps a dozen.of the logs f 14 of players. But I am sure there are more than that that I 15 haven't looked at.
16 0 Can you tell me which players that you remember?
17 A Well, obviously the Director of LILCO response, is the response manager, the rad health coordinator, the --
19 there was a rad health communicator, I believe. There also --
20 gosh, I don't remember the titles.
21 You people have developed an extensive set of 22 creative titles, but they don't always jump to your mind when O
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1 you are trying to'think about them in.a' vacuum. So, if I .
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2 had a list of all the titles I could probably check off the j 3 ones that I'think I've looked at. 4 d
4 Q Okay. But, as you said before, at the EOC, the 5 logs that you would have reviewed would have been the ;l a radiation health related positions.?
7 A And some of the primary players,'the people making a 1
8 the decisions and deciding when to issue the EBS messages 9 and things of that nature.
10 0 What about at the EOF 7 1
,, 11 A I reviewed some information from the EOF, and I J 12 was looking more for technical. data there than the other 13 type of information. But, it's a rather extensive' file. {1 14 I don't recall exactly which documents I looked at.
15 It's hard to separate the two pieces of discovery now. It 16 has been awhile since I looked at those.
17 0 When did you look at all of this material you have 18 been listing?
19 A Well, part of it was looked at after the exercise 20 and before the filing of contentions. And, part of it has 21' been looked at subsequent to that date, subsequent to the 22 filing of contentions as more discovery became available.
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1 And that isn't a very large amount in the ar s
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+ 3 0 .Now, you said that you also looked at FEMA docu- j
-x 4 ments. What FEMA documents have you looked at? ll 9
5 A Well, in some cases there was discovery provided N q!
6 by FEMA, which was very parallel .co the discovery provided by 4 0
i 7 LILCO. So, a lot of it was redundant.
i 8 And, there was also, however, some of the underly- [
1 9 ing documents of the scenario and the expectations of FEMA, I
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10 if you will, sort of the check list of information they were ',
. . I 11 looking for as they went along.
J 12 And, also the messages that they intr'oduced into 13 -the system and the free-play messages, or whatever they call s 14 them. That type of data.
15 But again, I don't have a list of it specifically.
16 0 Have you reviewed the FEMA post-exercise assess-17 ment?
18 A Yes, I have. The report, you mean?
19 0 Yes.
20 A Yes. Yes, I have.
i 21 Q I will call it the FEMA report, too. Mr. Miller 22 calls it the FEMA report.
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1 A Okay. .
2 O Have you reviewed Revision 6 of the plan which was j
~ i 3 used during that exercise?
f4 A Revision 6, yes. I understand now.it's up to, what, i
5 8? l 1
1' 6 Q Yes. Have you looked at the Revision.7 and 87 7 A I have, when I received them to insert into our a manual, our copy of the manual. I 1
9 Q So, you read the whole revision as part of your 10 filing process?
11 A~ Well, I've been sort of staying with Revision 6 l 12 in reviewing this process, because that was the part of the 13 plan that was in effect at the time.
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l i 14 I have taken a brief look through Revision 7 and 8, 1 15 though, to understand the nature of it. I've not tried to i i
l 16 integrate that into my thinking about the plan. The plan j i
l 17 is still Revision 6 in my mind at this time.
18 Q Have you looked at any other documents other 39 than discovery documents from LILCO and FEMA and the logs 20 and messages that you mentioned,and the plan and the FEMA l
21 report related to the exercise?
22 A Well, of course, there is an extensive amount of a,
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1 filing on the contentions and arguments about the contentions q tl 2 and so forth. And, I have been reviewing those as we went i 3 along.
l 4 I can't recall any large block of documents at i 5 this time that I haven't mentioned in that set. There may be i
6 some, but I just can't think of them at this time.
1
?
7 Q So, is it true to say that all of the information 1
8 you have about what happened at the exercise has come from 9 your review of the documents that you have been referring to to in answer to my questions previously? I k
11 A Yes. As I stated, I was not at the exercise but I O 12 did review this large body of documentation that came from 13 the discovery process resulting from the exercise. <
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- l, 14 Q I take it from your reference in answering my {
h 15 question about what you are testifying to, the 15.I, 36 and 37, y h
16 that you have read the contentions? f l
17 A Yes.
18 Q Have you read all of the contentions that were )
19 filed or just 15.I, 36 and 37?
20 A Well, I read a lot of the other contentions that 21 were filed, but I will not claim that I have read every one 22 of them.
13 i
e --
.jN.]g 1 Q Okay. Did you write the contentions?
2 A I participated in the editing and review of 3 contentions, but I did not actually draft.the wording of ,
4 these contentions. I did propose some wording for some of 5 these contentions, and that is all part of the melding process. l 6 But, I wouldn' t say I wrote them'.
7 Q Which contentions did you participate in editing 8 and reviewing? s 9 MS. LETSCHE- Let me just interrupt for a second.
10 I have no problem with Mr. Minor describing what it is that -- .
- i 11 what his current opinions are and what he has done to arrive $
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(x~-)/ 12 at those opinions or what analysis he has done in connection !
-13 with his testimony. l
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14 I do want to instruct him, however, not to --
15 in answering your questions -- get into discussions that he 16 had with counsel in connection with the drafting of conten-17 tions or similar matters that would be protected by attorney-18 client privilege.
19 BY MS. McCLESKEY: (Continuing) 20 0 Do you want me to repeat my question?
21 A Yes, please.
l-22 Q I believe I was asking you which contentions did I /~T V
14 -
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1 you focus on in your particular editing and review process?
2 A Well, the contentions as originally drafted, 3 Numbers 35, 36 and 3'7 I believe. And those were the ones
. . that I was particularly interested in.
5 Q I take it that having read-15.I, 36 and 37 and 6 having edited, at least 35 also, that you agree with those 7 contentions?
s A Yes, I do. I agree with 35 also.
9 Q Alas, 35 is gone, we think.
10 MS. LETSCHE: Yes, there is a pending objection.
11 So, we shall see.
12 BY MS. McCLESKEY: (Continuing) 13 0 Have you ever participated in develoDing any 14 scenarios for nuclear emergency drills or exercises?
15 A In actually preparing the scenario? Is that 16 your question?
17 Q Yes.
18 A No, I have not.
19 Q Ilave you worked in some other caDacity on the 20 scenarios for nuclear emergency drills or exercises?
21 A No. I have reviewed some of them, but I have not 22 participated in the preparation of them.
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1 0 IIave you reviewed scenarios for nuclear emergency 2 drills other than Shoreham drills?
3 A I have looked at some other plant scenarios. I 4 can't even recall which plants they were. But I did get ahold >
5 of a few others to 'ie s what type of scenario they had put in 6 front of the players for their exercise. -
7 Q Was that in connection with other work that you do, 8 or in connection with the Shoreham work? -
9 A Well, we had some of this information around the 10 office. It was quite some time ago when they were setting up il 11 the exercise and I was curious about what the scenarios may O
\"' include, and I went to look and see what others had included.
12 13 O So, your undertaking or review was in connection 4 t.
14 with your Shoreham work?
15 A Yes.
16 Q Do you recall -- were these for nuclear power plants "
17 A Yes.
18 Q Do you recall which plants the scenarios were --
19 A As I said earlier, no, I do not. And, I -- well, 20 I just don't recall. I'm sorry.
21 Q Were you looking at particular aspects of those 22 scenarios in comparing them to the Shoreham scenario?
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w 1 A Well, this is not an indepth study I'm talking about.
2 I just went and glanced at some documents that we had which 3 would indicate what type of emergency-drill or exercise they 4 had at other plants. t 5 My general conclusion was that they were reasonably
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6 similar. .
7 Q Similar? I'm sorry. >
8 A My first look was to see what they were. After the 9 drill, my conclusion was that they were generally similar.
10 Q Similar to the Shoreham drill? -
11 A Yes. !
12 Q Have you ever been an evaluator at a nuclear
(
emergency drill or exercise?
13 f I
14 A No, I have not.
15 Q Have you ever participated as a player, as someone 16 responding to the postulated emergency --
17 A No, I have not.
18 Q -- in a nuclear drill?
19 A No, I have not.
20 Q Have you ever attended a drill or exercise?
21 A No, I have not.
22 O We have all been familiar for quite some time with
l 17 '
, V 1 your background and resume, and I.just have a couple o'f quick l.
j 2 questions.
3 MS. McCLESKEY: Let's go off the record a minute. l l
. ,.4 (Off-the-record.) i 3 BY MS. McCLESKEY: (Continuing) j 1
6 0 I believe I was saying,I just ha'd a couple of l 7 questions about your background particularly related to j l
8 scenario and drill and exercise work. l g Do you have any specific degrees, or have you done 10 a significant' amount of course work in emergency response, 11 either radiological or non-radiological? l 12 MS. LETSCHE: I don't know what you mean by 13 emergency response work, i
14 MS. McCLESKEY: Emergency reponse.
15 BY MS. McCLESKEY: (Continuing) ;
j 16 Q Mr. Minor, do you know what I mean by emergency 17 response?
18 A Well, in terms of course work, because emergency 19 response is what you do in response to a base of knowledge 20 given a particular situation that exists. It's not something 21 you take very extensive course work in.
22 You train to prepare yourself for the responsibilities O
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%j .t 1 you have in the drill or the exercise or:the emergency re- ll i
2 sponse, then you.use your other training and knowledge to 3 implement that. q 9
4 Q Have you ever participated in that4 sort of train- f 0
5 ing program that you have just described?- g r y 6 A No, I have not.
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7 Q What about in radiation protection? ]
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8 A I've had some background in that area from my wo,rk N i
p 9 both at the Hanford reactor and the SEFOR reactor in F
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10 Arkansas and my work with General Electric, j
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11 Q What'about meteorology or any kind of atmospheric
-( ) 12 dispersion calculations?
13 A My only connection with that has been re' lated to f 14 probabilistic risk assessments we have done on'some plants 15 and the fact that you have to make those kind of assumptions 16 in order to create the different sequences that you are going 17 to analyze and sum up as a risk curve for the plant.
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- 18 And, in that you have to assume stability factors and r
19 dispersion characteristics for the plume.
20 Q What about environmental sampling?
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! 21 A I have not been involved in that directly. Of 22 course, I'm aware of what goes on in that process. But, I O
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\_ I 1 haven't been directly involved in.doing environmental sampl-i[
2 ing after a nuclear accident. [
3 O So, you haven't done it yourself?
f4 A I have not, ik 5 Q Have you been trained in it? Would you know how to )r 6 do it if someone sent you out to do it? I 7 A Well, see, there is training and'there is training. j 8 I know how to use radiation instruments, and I know that part 9 t
4 9 of the problem is to take the readings in an environment that -
i 10 is contaminated and to radio them back and all that.
I 11 That part of the training is not the hard part. I o
() 12 think understanding what the reading is and what the process 13 should be to get an accurate reading is, to get a differential, <
14 if you are trying to get a reading off of a canister before 1
15 and after it has been exposed. You want to be knowledgeable 16 of the basic steps.
17 But the actual training for how you go out and do 18 that, I don't think it's as important as the other steps.
19 Q Okay. Have you -- do you know how to do ingestion l
20 Pathway types of sampling?
l 21 A In that case, you would be taking water samples 22 and food samples, and you would be laboratory testing them to O
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1 determine their content of radioisotopes. Yeah, I' know general-2 ly how to do it, _but it's not something that I have personally 3 conducted.
Are you familiar with EPA 520? The title of it is i 4 Q 5 " Manual Protective Action Guides and Protective Actions for
. h 6 Nuclear Incidents?" It's the EPA. protective action guidance.. j 7 Are you familiar with that?
8 A I would not have remembered it by 520, but I 9 remember it by the title. And, I guess if you showed me I 10 would verify that that was 520. !.
O s
11 Q Okay. But, you think you have read a document that 12 is EPA's protective action guidance?
13 A Yes. I think this is the document that provides ,
0 14 some of the sort'of background for the EPA's plan on how to -- ,
15 what the guidelines mean in terms of what type things you 16 should do.
17 And, as I recall it, it's not a complete document.
18 I think there are some parts of it that are incomplete.
19 Q Is it fair to say that in your day to day work 20 that you don't usually use EPA 520?
21 A I haven't used it in several days, no.
22 O Only several days? Are you familiar with the O
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1 Federal Protective Action Guides for food stuffs, especially
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2 about ingestion pathway, promulgated by the Food and Drug f 3 Administration?- ,
4 A I know this only by reference. I have not personal- (
5 ly studied that document.
6 Q Did you bring any documents with you today?
7 A No, I did not. ,
8 0 Have you written anything about the exercise, any' i 9 memos, papers, studies?
10 MS. LETSCHE: Let me just instruct the witness, i
11 there are certain documents which Mr. Minor prepared that I O
V 12 have been identified in response to interrogatories promulgat-13 ed by LILCO; and, they have been withheld based on the 14 attorney work product privilege. .
15 Mr. Minor is certainly free to answer your question, 16 but I just wanted to note for the record that certain things i
17 have been withheld.
I 18 THE WITNESS: I have not written reports about the j
19 exercise. I have performed some compilations of data in 20 order to bring together the mass of paper that was presented
! 21 in discovery in the issues and areas that I was interested 22 in. And this was prepared for the attorneys at their request, e
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1 and I_ suspect that that's the type of document that Ms. Letsche
- 2 is referring to.
~ I 3 BY MS. McCLESKEY: (Continuing) . !
t A O What kind of computations have you -done, for what {
5 purpose?
l i
6 A I think I said compilations. ;
7 Q Compilations. I beg your pardon.' I 8 A And, it was mainly compiling the information, as J
9 I said, to make a': cohesive -- cohesive for me anyway -- set of f
10 information that I could use in attempting to translate and i L
11 determine what happened and might have happened at the exer-o 12 cise. i 13 Q When you say you compiled the information, for 14 example, are you making a list of times that things happened, f i
15 are you doing computer runs with the information that was i 16 given in the scenario to project doses?
17 What exactly are you compiling?
18 A Well, as I stated, it's taking the volume of infor-19 mation that exists and trying to compile it into a meaningful 20 arrangement of information so that you can draw some conclu-21 sions from it. It's not big computer calculations, if that's 22 what you mean.
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1 Q What subject are you compiling on? .-
k" 2 A On the rad health areas,.the areas related to the f
3 Contentions 35, 6 and 7 that would deal with the decisions 4 made and the information basis for the decisions related to .
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5 protective actions.
h 6 0 And, what conclusions have you drawn from this !.
7 compiling?
8 A Well, in general, this compilation was performed in P e
9 the period after the exercise and before the contentions were 10 submitted. And, the conclusions I drew are pretty well des- !
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11 cribed in the contentions,
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f 12 There are problems with the exercise, and those 13 problems are, to a large extent, detailed in 35, 6'and 7 of 14 the contentions. il l
15 0 Are you. working on any-additional -- I shouldn't say ,
16 additional since you've said you haven't really produced any 1
i 17 papers. Are you working on any papers, studies, memos or q 4
18 additional compilations, post-contention compilations?
19 A There is nothing pending right now. It is in the 20 process of being prepared.
21 Q You know what LERO is, don't you?
22 A Yes.
1 24 j i
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1 Q In your opinion, as a result of your review of all 2 the ' documentation, did LERO follow its protective action 3 procedures ,in its re'sponse during the exercise? ;
4 A By protective action procedures, do you mean the 5 OPIPs?
i 6 Q Yes, the OPIPs. ,
7 A I think --
8 MS. LETSCHE: Let me just get a clarification. I r'
9 Are you referring just to the OPIPs relating to protective 10 action recommendations or all of the OPIPs? ;
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11 BY MS. McCLESKEY: (Continuing) t 12 O We can limit it'to -- in the areas that you have 13 studied -- the radiological health areas that you have studied, ;
14 the protective action areas, decision-making. j 15 A Uell, I feel they did not comply with the OPIPs.
4 16 It is essentially documented in the contentions.
17 I would say that the contentions also give some ,
18 credit for where they did comply with the OPIPs. For instance, 19 the notification, putting milk-producing animals on stored 20 feed after the site emergency within a certain distance and 21 so forth. There are some things that are actually identified 22 in there that are culled out by the OPIPs and they were done,
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1 and that we are not taking any exception to.
.2 There.are other things'in the contentions where we 3 say that this does not comply with the intent or what would I f4- have been appropriate under the OPIPs. i 5 Q Do you have a set of the contentions with you? f 6 A I didn't bring them with me.
7 MS. McCLESKEY: Do you have an extra set in your ;
8 office? !
i 9 MS. LETSCHE: I could go down and get one if you 10 give me a minute. ;
11 MS. McCLESKEY: Would you mind? We can go off the 12 record for a moment.
13 (Of f-the-record. ) I 14 BY MS. McCLESKEY: (Continuing) ;
15 Q I asked you whether in your view LERO had complied 16 with the appropriate procedures in its actions and response 17 to the exercise scenario. And, you said that where you l 18 thought they had and hadn't, it was documented in the con-l 19 tentions.
l 20 Would you turn to page -- for the record, we are 21 both looking at the August 1, 1986 emergency planning conten-l 22 tions related to the February 13, 1986 exercise, which were
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1 filed by Suffolk County. And that's the ccomplete set.
2 A Yes.
3 MS. LETSCHE: It was filed by all the Intervenors.
4 MS. McCLESKEY: Ms. Letsche is absolutely correct.
1 5 Suffolk County, the State of New York and the Town of South-6 ampton have filed-the contentions. -
7 BY MS. McCLESKEY: (Continuing) 8 Q Would you turn to Page 93 of this? ..
9 A Yes.
10 0 Okay. I'm looking at Contention 36 which deals 11 with protective action recommendations and whether they were i G
' J 12 dealt with properly, given the wind shift in the scenario.
l And my question to you is, do you think'that LERO, ln 13 i
i 14 in responding to the wind shift, followed its procedures?
15 A No.
16 Q Why not?
17 A Because part of the procedures call for calculating 18 both sheltering and evacuation options and the doses that 19 would be received from each of those alternatives in deciding 20 on the minimum dose level if they should take one action or 21 the other.
22 To my reading of the documents that have been made O
l 27 i
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i 1 available, this was not done with regard,to the~ wind shift in
'2 the late periods.of time of the scenario of'tthe-drill.
3 0 .So, just let me make sure I have it straight. You J
4 think that LERO did not follow its procedures.because in the :
5 documentation you reviewed you see no evidence that anyone did ,
6 any calculations later on during the drill; is that right?
7 A Well, I don't want to be quite that general. It's '
8 not that no one did any calculations.
9 I'm saying that there is no evidence that the de- ?
10 cisions to continue to broadcast the EBS message, or to f
11 broadcast EBS messages, regarding continued evacuation, in that Of 12 Process I did not find documentation which said:' We_have 13 evaluated the effects of sheltering; we have evaluated the j 14 effects of evacuation at this time and, therefore, we concluded ,
15 it's right to continue evacuating even in light of the pending 16 wind shift.
17 Q Okay. Could you turn the page to Page 94, Conten-18 tion 37?
19 A Yes.
20 0 Now, I see that you cite there specifically that 21 LERO didn't follou OPIP 3.6.6 in its ingestion pathway 22 activities.
l U
28 .
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1 A Well, it isn't exactly.on that page that we say 2 that but several. citations to 3.6.6 on subsequent pages talk j 3 about specifics.
,4 Q And, I take it from reading Part A.of the contention 5 that the basic complaint is that there wasn't an expansion of
)
6 the recommendation to shelter milk-producin'g -- to shelter 7 dairy animals outside the EPZ and place them on stored feed, 8 that that's what you would have liked to have seen during the :
g exercise. l 10 A That's for Subpart A, is that what you said?
t 11 O Right.
ry l 12 A Yes.
13 G Is that the only -- well, I'm sorry. In Contention k l
37 where you set -out the difficulties that you have with the !
14 15 way that ingestion pathway was dealt with, as far as dairy 16 animals, not looking at other animals and activities, or 17 other animals, and your assertion that LERO failed to make 18 protective action recommendations at all for drinking water, 19 fruits, vegetables, that sort of thing, are those the ways in 20 which you think that LERO did not comply with OPIP 3.6.6?
21 MS. LETSCHE: Let me object to the form of that 22 question. That was a very long lead in. Are you saying, are A
V m
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29 Jj
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A) 1 all the allegations made in Contention 37 the same as the
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4 2
. reasons Mr. Minor believes the OPIPs weren't followed? j s !I 3 MS. McCLESKEY: Yes. }
L 4 I-BY MS. McCLESKEY: (Continuing) 5 Q Do you understand what I just said and what Ms. d 6 Letsche just said, Mr. Minor?
s 7 A Well, let me, at the risk of confusing it, say it j 8 the way I think it is.
F 9 Q That would be great.
1, 10 MS. LETSCHE: Don' t you love witnesses like that? S k
i 11 (Laughter.)
n
~ ~
12 T H E 5 I'T'N'E S S : In Subparts A, B and C, we defined is three particular generic problems and specific parts of the ;t i-
! OPIP 3.6.6 which would call for some other action to be per- i 14
~ ~
15 formed. These actions include the trestm'edt~bf milk-l
! 16 producing animals, other animals, drinking water and so forth.
l 17 That does not apply to Subpart D, which is a l 18 different OPIP, although it's related to OPIP 3.6.6 also.
l l 19 BY MS. McCLESKEY: (Continuing) l I 20 0 Okay. I think you answered my question. In
'21 Contention 36, jumping back to 36 on Page 93, where do the 22 times that are listed in this contention come from?
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1 1
30 i -
.ym 1 N-1 A Say again? Where do the times what?
f.
2 0 Where.are the times listed in this contention 3 taken from?
4 A Now, by times you mean about-the middle of the ,
5 page where it says 3:48, 12:06 and 3:48 again? 7 0-6 Yes.
7 A Well, let's see, where did we derive those? My 8 recollection is that those were derived from the logs of some 9 of the players as the times when those events were implement- !
i 10 ed, I guess is the right word. '
11 Q .Okay. And, when you say that EBS= messages were
~
12 simulated every 15 minutes between 12:06 and 3:48, do these I
13 times mean to you that an EBS message was being broadcast at t':.
14 12:06? 't 15 Is that what you mean by simulated every 15 16 minutes between 12:06 and 3:48? ,
17 A I don't recall the exact timing of the EBS messages 18 and whether it was actually a broadcast at each on'e of those 19 intervals or just a consideration of it.
20 Q Okay. So --
-21 A My recollection is that they were broadcast at 22 a different frequency. But, I would have to go back and look
P 31 '
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1 at the records to really show that. ,
2 O Okay. . So if you will look at perhaps the third 1:
3 -Paragraph ~in Contention 36 where it says, "Nhile such EBS
- q. messages were being simulated beginning at 12:06..." you don't i 5 know if being simulated means being considered or if the }
6 simulation of the broadcast began.at 12:06?
7 A You said the third paragraph. Am I on the right _
8 Paragraph?-
g Q It begins, In fact, while such EBS messages. . . " j 10 It's at the bottom of Page 93, the third line from.the bottom _
~b 11 of the page. g 4 cndnA 12 A Okay. 6 l
13 MS. LETSCHE: Can you restate the question for me? {
14 BY MS. McCLESKEY: (Continuing) 15 Q I just want to know what you mean by being simulated <
16 and what the 12:06 time refers to, if you know.
17 MS. LETSCHE: Let me just instruct the witness, 18 you should answer whatever it is that you know. Don't try to 19 speculate as to what -- I mean, the contention speaks for 20 itself. You can testify as to your opinion and your knowledge.
l l 21 It's getting confusing because you were saying i
22 "you" in reference to the contention. And, you know, the
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V 1 contention is a contention, and Mr. Minor's opinion an'd the 2 knowledge are his.
3 And I just want -the distinction to be clear.
4 THE WITNESS: Just one second.
5 (The witness is looking at a document.) ,
6 THE WITNESS: My recollection is that the EBS l
7 messages were broadcast at intervals between the 12:06 time. [
l 8 I believe that was the first one relating to this particular l' I
I g aspect, this particular decision, and 3:48 which, to my recol-10 lection, is one of the last ones before the wind shift that
~
11 still called for the people to evacuate. l
, j
(,T BY MS. McCLESKEY: (Continuing) i 12 q 13 Q Okay. ,
l 14 A I do not recall the exact interval at which they l
15 were broadcast, as I said earlier. And whether 15 minutes is 16 the exact interval at which they were broadcast or when they 17 were reviewed, I don't recall.
18 Q Okay, moving on into that paragraph, the contention 19 says that the EOF was projecting that a wind shift would 20 direct plume away from the original down-wind zones as early 21 as 3 o' clock.
22 A That's right, b>~-
E 33 ;
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1 .Q Just so that I understand -- and', I know that the ;
2 contention speaks for itself, but just so that I understand 3 what the contention is speaking, is it your understanding that )
4 the contention is asserting that the wind shift would begin at i I
5 3 o' clock? i 6 A The wind shift projection was given along with the 7 weather data at various intervals throughout the drill, the !
l 8 exercise. It changed in projected time throughout the course l 1
1 9 of the exercise.
i 10 At one point, it was projected to occur as early as ,
11 3 o' clock. At other times, it was projected to occur at 4 !
( 12 o' clock, 4:30, 5. It moved around. I think that explains the i
13 nature of this statement, that the time at which the shift g4 would occur was projected to be as early as 3 o' clock at one l point. !
15 16 Q Do you recall what time of the day the projection 17 of 3 o' clock was being given and for how long that projection 18 remained at 3 o' clock?
i 19 A I don't recall the exact time, but it was some 20 time after noon and before 3 o' clock.
21 Q So --
22 A But I don't recall the exact hour.
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1 34 .
I I
-Q 1
Q So, as far as you know; between about. noon and <
i 2 about 3 o' clock the wind shift projection was for 3 o' clock?
I 3 A No, I didn't say that. l 1
e4' O Okay. What do you mean?
5 A I mean that there was a period during that interval l l
6 when the prediction did come through as a 3 o' clock wind 7 shift, but I don't recall exactly how long that prediction !
8 persisted before it moved to another direction. As I stated .
I 8 earlier, that prediction did move around.
10 Q So, the prediction changed between then and 3 l
11 o' clock as far as you know? 8 (3 "# 12 A Yes, I think there was some variation that predict-13 ed the time of the wind shift during that interval.
14 O Right. And, your recollection is that the predic- l 15 tion kept going later and later?
16 A No, I wouldn't say that.
17 Q No?
18 A I don't recall it as having a fixed pattern of 19 constantly being later. As I recall, it moved around. For 20 awhile it was moving forward, and for awhile it was being 21 delayed. I would have to go back to look at the data to be i 22 sure of that. But, I don't recall it being a consistent steady i
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1 pattern.
2 0 And,.this shifting of time, in your view,' was that l i
3 pretty much par for the course for meteorological. forecasts? l 4 A You are trying to' determine when a.particular 5 front or frontal system would move through an area, and'that l
_ i 6 is subject to a lot of variations.much bigger than the LILCO !
l 7 exercise, and it's going to happen when it happens.
8 And, it's likely to vary a little bit one way.or 9 another. But, as you aet closer to the time of that wind i
10 shift -- I mean, you have weather data from surrounding areas ;
11 that can tell you when it has already occurred and what T I
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s- 12 direction it's going and what time, what rate of speed it is i
la Progressing, and you should be able to predict that'more l
14 accurately. l 15 Q Given the description of the facts in Contention 16 36, taking them as given, in your view, would you have. changed 17 the recommendation from evacuation to sheltering?
18 A The main thrust of the contention is that there 19 needs to be an evaluation at that time in light of the wind 20 shift that was projected to see if it was appropriate to 21 continue evacuation or if it would be more appropriate to 22 recommend sheltering or that people stay in their home until O
36 -
dg.
.1 they are given further notice so that you would achieve the 2 lowest dose to the public. That's the step that is missing.
~
3 It's not that it's absolute solthat I can tell !
i e4- you right now they would have saved 500 person rems if they i i
5 had only done that. I can't tell you that right now. l.
1 i
6 The question is whether they did the calculation to '
i 7 justify the action they took in light of the wind shift. ;
I 8 Q I understand that one of the key complaints in I 9 Contention 36 is that in the author's view that calculations 10 weren't performed, that that step wasn't taken. l
. . I 11 Assume that you had to make that determination, 'f 12 given these facts, would you have changed the recommendation 13 from evacuation back to sheltering?
14 A I would have changed the recommendation, to not !
15 Put out the message until I had the calculation to show that ;
16 it was the right calculation and the right analysis and the j 17 right decision.
18 Q So, you would have withheld the origina1' evacuation :
19 of -- is that what you just said?
20 A Which original are you speaking of? What is 21 original?
22 O You would have withheld the latest evacuation O
d 37 i
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- L/ -
1 recommendation; is that what you are saying', at'12:06 you 2 would have withheld that evacuation. recommendation?. t 3 A No. I'm not necessarily saying that. My feeling i
( 4 is that if you are going to recommend evacuation in a changing i 5 environment, you should not do that until you prove that .
6 'that changing environment wouldn't make it better to not 7 evacuate.
And, this is a decision which should be'made on a 8
)
1 9 moving basis. So, you have made the decision once you are 10 going to' evacuate. At that point, you are a long ways away i 11 from a wind shift. As you get closer to the wind shift, you
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12 need to reassess that decision. Is it still appropriate? Is 0
13 it still dose saving to evacuate?'
14 If you know particularly that there are 20 thousand i 15 People still out there in their homes, should I have them get l 16 n the road now or should I have them stay in their homes?
17 That's a decision that has to be made in light of some informa-18 tion and data.
)
19 And the data did not appear.
'l I take it from what you have just said that 20 0 Okay.
i' 21 you could conceive of situations where you would change an f
22 evacuation recommendation to a sheltering reconmendation based O
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38 j
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(_) i 1 on the changing conditions of wind shift? j .
1 2 A If I saw a dose saving -- j
?
d 3 0 ,You are talking about -- ;
1 4 'A -- for making that decision and,we.were not very far f
!i 5
away from the time of that wind shift and it has been predicted ;
0 6
throughout the process that it wo.uld occur and it has'not ]
)
9 ,gone away, and the calculations showed a dose saving, I could ;j 1
8 conceive of changing that decision.
?
9 Q When you say the calculations showe~d a dose 10 savings, do you mean a short term dose savings or a~long-i 11 term?
12 A I'm talking daout the dose to the pop ~ulation in-13 volved. If they would benefit by staying indoors for a Period of time and then after the wind shift, after the i 14 15 Pl ume has blown another direction and the atmospheric portion 16 of the dose they would receive is reduced, then maybe having i 17 them evacuate. It may be worthwhile to do that.
18 0 In your view, is this typical emergency response 19 practice to change recommendations mid-stream, as it were, 20 that you are suggesting might have been done in Contention 36?
21 A Is it a common practice?
22 O Yes, a common practice, emergency response practice?
O
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LJ t 1 A Surely you don't want to do this' very many times, /
1 2 but if you can do it and save dose it's consistent with your l
'1!
3 guidelines for emergency planning. ,j e4' Q Do you know what the postulated deposition was in !
$ the scenario? ;j
- t 8 A I don't recall right now. The ground' deposition 7 in the area, you are talking about? ji
'I 8 Q Yes. '!
Y 9 A I do not recall right now.
I 10 Q Is that one thing you would want to know before <
9 you decided to switch your evacuation to sheltering? l 11
') -
12 A It is one of the factors that you would want to 13 know. But, the main factor you are evaluating'is the effect l 1
14 of the atmospheric plume moving through the area, and that 15 dose is the one that is variable. In one case it's going to 16 be there; and, in another case it's not, after the wind shift, 17 let's say.
18 And th~e ground deposition dose is going to be there i
19 regardless of when you leave, if you leave now or leave an 20 hour from now. It's still going to be there, a large part of l
21 it. Most of it would not have decayed away in that period of l
22 time.
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h rm i N_] N 1 Q Well, assuming for a moment that you made a j 2 decision based on the factors that you wanted to take into 4 it
~
3 account to switch from evacuation back to sheltering, based ;a 0
4 on the wind shift in the scenario, is it your thought that you d I;
would not have'to relocate those people later?
5 f;f 6 Was that part of your assumption? -
j 1
7 A Two things in your question. First, you said back h
8 to sheltering. My recollection is that they had'not told them .
i 9 to shelter before. ,
10 Q I'm sorry. I misspoke. To sheltering.
11 A Okay.
12 Q From evacuation to sheltering.
13 A The second is that maybe you were being'too exact j
.c 14 about it. The contention does not say they should absolutely il
,1 15 shelter and stay sheltered forever, and that would not be my 16 premise either. I would say that you may instruct the people 17 that it would be desirable for them to remain in their homes 18 if they are in their homes at that time, and await further 19 instructions for when it would be appropriate to evacuate.
20 In other words, a delayed evacuation where shelter-21 ing is the interim posture until you do decide it is the 22 right time to evacuate. And, all that is is a stalling mode to
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I
-2 different direction, j 1
3 0 . Chi the ingestion pathway contentions, 15.I and 37, j 4 I take it again when you said LILCO didn't do.certain calcula-5 tions or consider certain recommendations and that sort of 6 thing in line with its procedures, your only basis for knowing 7 what LILCO did is in the documentation that you reviewed; is i
8 that right? ,
9 9 A Yes. . .
10 Q Have you taken a look at'all at the special ;.
Y 11 facilities monitoring contention, Contention 47? I 12 A Yes, I did. But, I have not looked at it in con-l l
13 nection with this deposition, so not for quite awhile. e i
14 Q It's on Page 148. I 15 A Thank you.
16 MS. LETSCHE: Do you want him to read this whole 17 contention or are you going to -- what?
18 BY MS. McCLESKEY: (Continuing) 19 Q Would you take a minute to look at it, Mr. Minor?
20 (The witness is looking at the document.)
21 A Yes.
22 0 Mr. Minor, have you had a moment to look over O
42 '
j i
(-)
1 Contention 47_and refresh your memory about~it?
2 A Yes. .But, I want to. reiterate that this is not i
a one that I came prepared to testify on in.' this ' hearing nor to I i
,4 - discuss today.
5 Q -Did you read this contention before it was filed?.
6 Do you recall seeing it before it was filed? -
1 7 A Yes, I do recall seeing this in draft. It was one !
J 8 of the contentions that I saw in draft form. .And, of course, 9 I read it subsequent to the filing again.
10 0 But, you don't intend to be filing any testimony 11 on this?
C) -
12 A- Not at this time, we have no plans to.
i
]
13 0 Is this one that you helped edit or~ review with i
14 your technical expertise? !
i 15 MS. LETSCHE: Let me just note my objection for 16 the record. Since Mr. Minor is not going to be testifying on !
17 this contention and has so stated, I object to this line of I
i 18 questioning. l L
[ 19 THE WITNESS: Am I to answer that?
t 20 BY MS. McCLESKEY: (Continuing) i 21 Q Yes, you may answer.
1 22 MS. LETSCHE: I'm sorry. You may answer that.
O i
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43 3g
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1 THE WITNESS: I do not recall,. personally editing 2 this contention. There are other contentions in the set which 3 bear a strong resemblance to this Number .47, and I did edit l 4 one of those. But, I do not recall specifically editing this 5 one. t 1
6 BY MS. McCLESKEY: (Continuing) -
7 0 In your opinion, would you expect to see a lot of 8 contamination, skin contamination, on people who have been l 9 transported out of the EPZ from special facilities?
10 MS. LETSCHE: I must object to the form of the .
- i 11 question. I don't know-what the underlying assumptions are, b
12 BY MS. McCLESKEY: (Continuing) 13 0 Mr. Minor, do you understand my question'?
14 A Well, you say " expect to see." And that means 1.
15 to me that I have to put myself in the position of saying 16 are there situations where a person being evacuated from a 17 special facility could experience some contamination of their is clothing, skin, or what have you. And I can conceive of 19 situations where that would happen.
20 It could happen to be at a time evacuation were 21 delayed until the plume's presence had already reached that 22 area and they were moving them from the facility at a time
44 i -
(s_/
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1 when the deposition or~ plume deposition would occur on or 2 around the area where they were being transported. It could 3 conceivably.be on them as well.
4 4 There are~other situations where if. the evacuation-5 is done early enough and the plume deposition hasn't occurred 6 in that area, you wouldn't expect to see any. But, it could 7 have all the spectrum in between.
8 Q Is it fair to say that the risks for a'special !
9 facility would be no greater than for the general population 10 in terms of contamination?
11 A That's a tough one to answer. It's hard to compare O'- 12 the two because in one case you visualize the population moving 13 from their house to their car and then driving-away., And, ,
i 14 in another case you visualize people that may have to be moved I i
l 15 in wheelchairs, may have to be lifted and carried by other ,
16 people, there's a lot of handling and a lot of contact that 17 could potentially be contaminating.
18 It's not directly comnarable in my mind.
19 MS. McCLESKEY: I don't have any further questions.
20 Thanks very much.
21 THE WITNESS: Thank you.
22 MR. Z AIINLEUTER: I have no questions.
O
45 * ;
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(_)
1 MR. CUMMING: I have.some questions. With 'permis-2 sion of counsel,.could I come down to that end?
3 MS. McCLESKEY: Certainly. You may'even have my I l
i
.4- chair. .
5 CROSS EXAMINATION j 6 BY MR. CUMMING:
indexx 7 Q Mr. Minor, my name is William R..Cumming, and I 8 am counsel for the Federal Emergency Management Agency. j l
I have a copy of your resume here, and I don't I g
o 10 have copies to place it into exhibit form. -Could vou identify l 11 that for me and tell me whether you prepared that document? l n
12 (The witness is looking at the document.)
I 13 A Yes, I did. [
l 14 And, is it accurate to the best of your knowledge !
Q 15 and belief? ,
16 A Yes, I think it's accurate. There were some 17 typographical problems with a couple of entries in the list 18 being repeated, but I think we have corrected those. I 19 think it's accurate at this point.
20 Q I notice that you have a Bachelor of Science in 21 electrical engineering from the University of California at 22 Berkeley. Was there a so-called power option when you were i
~
a,-
46 s- gs
-O 1 taking your undergraduate degree in engineering? '-
2 A It was.
3 O Were you enrolled in that power option?
7 t
4 A 'Yes, I was. . ;
5 0 Would it be fair to characterize your expertise as !
i a nuclear engineer, in your judgment? I 6
l 7 A My educational background is electrical engineering 8 and electronics. My experience throughout my -- whatever it f
9 has been, 26 years of experience has been almost entirely 10 related to nuclear matters. ;
I 11 And, so by experience I would say yes, I'm more l Ds/ 12 of a nuclear engineer than an electrical engineer.
i I
13 MR. CUMMING: For the record, since I'm "not making l
L 14 this an exhibit, this is an eight page document.
15 BY MR. CUMMING: (Continuing) i 16 Q Mr. Minor, on Page 3 there is a list of your 17 publications and testimony. Are you familiar with the term 18 with respect to scientific publications or technical publica-19 tions, " peer group review?"
20 A Yes.
21 Q What does that mean, in your judgment? l 22 A It is generally used with the publication of O
i 47 i
/ 's N
I articles or reports in the form where they 'are sent, not draft 2 at least, but at least final draft form around to other people g h
a for review.and comments before their final issue.
4 Q I don't want to spend too long with this, but if '
5 it's'possible would you go through the items listed under' 6 Publications and Testimony -- and. I'll hand you this exhibit --
7 and tell me whether any of those documents -- and you can l 8 just identify them by the numbers -- were, in fact, submitted .
9 to peer group review? '
10 A It depends on whether we want to talk formalized t
11 or informal. There are several of these that have been peer j
/~T i l reviewed at least to some level. Probably none of them are l 12 13 of the nature of the formalized peer review process you would <
14 see in todav's publications.
15 But, let me go through the ones that I think are 16 applicable. The very first one, for instance, was done as l
17 an IEEE transaction. It has to be submitted in advance and 18 they review it. It was also reviewed by people internal to 19 General Electric when I was working there for their concurrence j 20 with its contents.
21 The same for Number 2. Number 3 was a German 22 magazine article that picked up item Number 2. So, it's O
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1 48 W
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1 basically the same.
2 Number 10, the Swedish Reactor Safety Study, I 3 would say that was of that nature. We spent a lengthy time 4 ~ reviewing and debating that against the parallel study that d 5 was done by the internal Swedish organization. P t
6 We did ours in the United States. The'y did theirs-7 in Sweden. We came together before an Arbitrating Board,. if ,
)
1 8 you will, and debated the issues and differences on the two 1
9 studies. So that, in a sense, is a peer review. S 10 And the item Number 9, which is the Risk of 11 Nuclear Power Reactors, which is the review of WASH 1400, was i
(% ~
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12 actually a compilation of many persons' thoughts and writings 13 on the subject. And we performed editing processes on their 14 writings and some of ours and pulled that together as a book 15 and had to recycle those edited versions back to the people is that wrote them and to others, so there were many people that 17 reviewed the content of that before it went out. ,
18 Those are the ones I would cite. The rest of them 19 are generally testimony where you would put it out in the 20 form of testimony or a specific report, contracted by someone 21 that is interested in it in a specific subject and would like 22 our comments on it. They are not looking for the consensus of
l r 49 }
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i the United States. They would like our comments on it. j i
2 So, those are not generally put through a peer 3 review process.
q 4 0 Have you ever participated in any panel of the 5 National Academy of Science on any subject?
N 6 A Yes. I recall presenting a paper. It was a speech j o
7 more than a paper, I guess, because it's not a document, at !l
.I 8 San Francisco in probably about 1980, dealing with the matter 9 of nuclear power plants and the changes that were occurring ,
d 10 in the nuclear power plant requirements at that time. 1; 11 It was post-TMI and it was the panel that had V 12 Erdmann from SAI, another author from Berkeley and myself.
13 That's the only one.that I recall. f 14 Q But you were not on the panel? ;
15 A Yes, I was. ,
16 Q You were on the panel?
17 A I was one of the speakers on the panel.
18 Q And, was there a report issued by that panel?
19 A No. It was not for the purpose of making a report.
20 It was for the purpose of presenting a panel discussion at 21 the San Francisco Symposium, and it was on the subject of 22 nuclear power regulations, in effect, and the future of nuclear O
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-2 Q Have you ever participated in a ' panel of the l O
3 National Research Council?
~
e4- A No, I have not. I guess another one'I would mention 5 of the peer review type, I participated as a peer reviewer of 6 the Ragovin Committee report on Three Mile Island.
7 Q You are currently an employee or'an officer of i
8 MHB Technical Associates? ,
9 A I'm an offi er and principal.
10 Q And, who has retained you to work on the Suffolk t
- 4 11 County case?
O 12 A I have been retained by the Suffolk County Legisla-13 ture in this case. <
1 14 0 As a firm or in your individual capacity?
15 A The firm has been retained. ,
16 Q Have you ever conducted a literature search on 17 emergency response or evacuation?
18 MS. LETSCilE: I object to the form of the question.
19 It's very vague.
20 BY tiR. CUMtiING: (Continuing) 21 Q Do you know what a literature search is, ?!r. liinor?
22 A Well, I know what it may be but it could be at O
.o,.
51 j '
l n
Xl 1 various. levels. I mean, I can't -- 1 i
2 _Q If I define literature search as a technical 3 literature, technical in the sense of scientific or engineer-l 4 ing literature, would you understand what-I meant by that if [
h 5 I defined it in that way?
E 6 A That would help bracket one aspect of it. But, 7 ere you talking about all aspects of emergency planning and
- l 8 tha technical literature relating to all aspects of emergency I n
I g planning?
. i 10 Q That's correct.
11 A No, I have not done that.
12 O IIave you conducted a search of any aspect, litera-13 ture search of any aspect of emergency response?
14 A Well, again this can take several levels of 15 literature search. -Yes, I have done some searches for parti- ,
16 cular areas.
17 For instance, I have presented a paper in Italy on 18 the size of the EPZs and how they came to calculate the EPZs .
19 for California nuclear plants. And to do that, I had to 20 review quite a bit of the literature related to those 21 particular EPZs and the decisions related to those.
endT1 22 O Are you familiar with the term " health physicist?"
O
! (_)
52 3 i
/~;
V 1 A Yes.
2 Q Would.you describe yourself as a health physicist?
3 A .Not by training or certification, but I'm j 4 familiar with the field. i 5 0 What is a health physicist, in your words, to your ;
y 6 understanding? j 7 A A person who is knowledgeable and cognizant of a the effects of radiation on human beings and the actions and i 1
9 steps that should be taken to protect and reduce dose where 10 possible and to assess where there has been dose.
11 Q In your own words, without referring to the copy
' in front of you, what does contention 35 state?
12 13 MS. LETSCHE: I object to that question. <
14 MR. CUMMING: Objection noted. Can the witness 15 answer that question?
16 MS. LETSCllE: The witness may answer it if he is 17 able to, if he is subject to that restriction then he is not 18 allowed to refresh his recollection.
19 THE WITNESS: You mean 35, the one that has been 20 disallowed?
21 BY MR. CUMMING: (Continuing) 22 O That's correct.
n v
53 '
(n,1 1 A This is interesting. -
2 MS. LETSCHE: If you can, answer it, go ahead.
3 THE WITNESS: I haven't really!been paying very !
e4- much attention to that contention since it was disallowed. +
5 BY MR. CUMMING: _(Continuing) '
6 O So, you cannot state what that contention was in 7 your own words?
8 A Well, let me reflect on it a minute and see if it 9 comes back. ,
/
10 (Pause.)
11 Rather than speculate on what its content is, I O)
\'
12 would rather.look at it. And if you don't want me to look at, 13 I would rather not speculate.
14 0 That's fine. How about Contention 36? Could you 15 state that in your own words?
16 MS. LETSCHE: I object to this question. This 17 isn't a memory test of this witness. What is it you are 18 trying to do here?
19 MR. CUMMING: Well, the witness previously testi-20 fled that he had participated in the drafting. I just want 21 to hear in his own words what that contention states.
22 O
-m t,-
54
~
/ ~N
\ )
1 BY MR. CUMMING: (Continuing) 2 O If you can.
3 A In essence, Contention 36 discusses the need for 4 additional consideration of the potential. dose savings that 5 would occur if sheltering were'the recommended protective
~
e action late in the Shoreham exercise instea'd of e.vacuation in 7 light of the pending wind shift.
8 And, it questions whether this is consistent with 9 the OPIPs, 10 CPR 50.47 and NUREG 0654.
10 0 In your own words, what does Contention 37 state?
11 MS. LETSCHE: Is the witness permitted to review l h
(~J
' 12 the contention to refresh his recollection?
13 MR. CUMMING: Without referring to the d'ocument 14 in front of you. In your own words, if you can remember.
I 15 MS. LETSCHE: I object to the question. !
16 MR. CUMMING: Objection noted. ,
i 17 THE WITNESS: Contention 37 deals with the ingestion 18 pathway and the decisions that were made during the Shoreham 19 exercise with regard to the ingestion pathway.
20 It deals with the lack of decision regarding the 21 placement of milk animals beyond the 10-mile EPZ on stored 22 feed, it deals with the lack of direct attention of other food
~)
55 i
b 1 chain items such as additional livestock or poultry or 2 animals of that nature, and water supplies. And, it deals a with;the question of whether there should.have been notifica-4 tion of potential contamination of fruits-and. vegetables out 5 in the ingestion pathway.
6 It also deals with the. question 'fo whether there 7 .w as a proper handling of a form that is called for in one of 8 the OPIPs and is referenced in OPIP 3.6.6 that would have been a filled out as part of the activities related to the ingestion i
10 pathway. It calls for the specific -- excuse me.
11 It calls attention to the specific aspects of OPIP g(> 3.6.6 and 3.5.4, I believe the other nunber is, where these 12 13 items are mentioned or referred to in the plan. .
I 14 BY MR. CUMMING: (Continuing) 15 0 I'm almost done, Mr. Minor. Are you a registered to professional engineer in any state?
17 A No, I'm not.
18 Q You have some background in instrumentation based 19 on your resume. What is a dosimeter?
20 A What is a dosimeter?
21 O Yes.
22 A It's a device that a person would normally carry
56 ,
e
.r3
\J~ .
I with him to attempt to give a reading which-is comparable to '
2 the dose his body would be receiving, and it is read 3 periodically to make that assessment of what dose the person l t
,4 may be receiving. j 5 Q What is a rad in the context of a radiological
?
6 accident or exposure? ,
7 A A radiation unit. It is a measure that is commonly i
8 used in the rank of equivalent men formed to determine if i g you measured the number of rads a person receives; for instance, 10 you can determine at what level you might ex9ect certain 11 physiological ...ianges to the body, everything from a lower
(
x' 12 level where you would expect to see thyroid changes, for 13 instance, a certain number of rads to the thyroid, or where .
I 14 you would expect to see the potential physiological change up f r
4*
15 to the LD 50 where you would have a fifty percent chance of a [
16 lethal dose. (
17 Q What is a rem? 4 A A rank in equivalent man. That's what I was ;
18 f
19 referring to earlier. .,
20 0 IIave you ever personally used a dosimeter or read 21 a dosimeter? <
t 22 A Certainly.
l i
$a n
I 57 l
. i 4
m if Are you familiar with the name Carl Siebentriett?
1 ~Q 2 I believe it's spelled S-i-e-b-e-n-t-r-i-e-t-t.
I 3 A That name does not ring a bell right off the bat. t 4 MR. CUMMING: I' have no further questions.
[
5 MS. LETSCHE: I just have one question on redirect. [
l t
indexx 6 EXAMINATION . - 1; I,
7 BY MS. LETSCHE: .!
L 8 O Mr. Minor, you-described for Ms. McCleskey,-having I L
i.
9 glanced through certain scenario-related materials from other 0 10 than the Shoreham exercise.
t 11 Could you be a little more specific as to what, in .
~
l
' A-12 those other exercise scenarios, you were focusing on, if any- l 13 thing? ,
14 A Yes. 'I was looking to see what accident sequences 15 were involved in some of the other drills. In particular, I 1 t
i 16 wanted to know was the type of event-that was postulated at 17 Shoreham as severe, less severe or typical of the type of 18 event that was simulated in other plants. .
19 And, as I stated earlier, I found that they were 20 reasonably comparable.
21 MS. LETSCHE: That's all I have.
l 22 O
i
f I
58 3
('8 w/
\
ind;xx' 1 REDIRECT EXAMINATION 2 BY MS. McCLESKEY:
4 3 Q Well, Mr. Minor, when you were looking at these 4 scenarios, is that all you looked at?
5 A That was the aspect of them that I was looking at j 6 at that time. )
.]
7 Q So you --
8 A The particular details of what kind of~ events they ;
5 9 were postulating to occur.
~
l to Q So, about how many scenarios did you look at?
1 11 A There were three other plants, at least three or
12 four. Something of that nature, not a large number.
13 O And, you just flipped through the scenario to s i
14 the postulated accident section and --
- l 15 A Actually, what I think I did, if I recall correctly, ,
l 16 is I sought out that information from the PDR where I could 17 get the details of the plant sequence, the accident sequence.
18 And so that's part of the entire drill or plan or 19 scenario that I had. And, I didn't have the whole plan --
20 excuse me, didn't have the whole exercise.
21 Q How did you measure severity? What does severity 22 mean?
e
'I I.
59
~$
em N-]
1 A Well, I didn't measure.it in terms of did I i t
2 calculate the amount of curies released from this accident -
j 3 versus another one. I did not do that, e4 My goal was just to determine whether the events l
.i 5
leading up to the accident were as distinguishable or were 6
they more clearly indicative of impending core melt, what 7 kind of warnings, warning time, did they have, did the other >
8 events lead to core melt; and, if so, how long was the release q
- 1 g allowed to continue, those type of characteristics, to make 1 10 sure that they were comparable.
i 11 Q Why did you want to know?
i r' i
(_)T 12 A Curiosity. I 13 Q Curiosity? r 14 A Yeap. I didn't want LILCO to get. unduly exercised, \
15 that's all. I thought maybe there would be some differences 16 one way or the other.
17 0 But, you didn't find any?
18 A I found it reasonably comparable.
19 MS. McCLESKEY: Okay. Thanks a lot.
20 AND FURT!!ER Tile DEPONENT SAITII NOT.
21 (Whereupon, the taking of the deposition was 22 concluded at 4:07 p.m., Tuesday, December 2, 1986.)
y:v.
60' U)' 1 CERTIFICATE OF NOTARY PUBLIC 2
3 I, GARRETT J. WALSH, JR., the. officer before whom 4 the foregoing deposition was taken, pages 1 through 59, do 5 hereby certify that the witness whose testimony appears in 6 the foregoing deposition was duly. sworn by me; that the 7 testimony of said witness was taken by me and thereafter ,
8 reduced to typewriting by me or under my direction; that said 9 deposition is a true record of the testimony given by the 10 witness; that I am neither counsel for, related to nor 11 employed by any of the parties to the action in which this 12 deposition was taken; and further, that I am not a relative 13 or employee of any attorney or counsel employed by'the parties 14 hereto, nor financially or otherwise interested in the out-15 come of the action.
1 GARRETT f WALSH, JR. /
18 Notary Public in and for the tg Commonwealth of Virginia at Large 20 21 My commission expires: January 9, 1989 22 O
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