ML20212D884
| ML20212D884 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/27/1987 |
| From: | George Minor MHB TECHNICAL ASSOCIATES, SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20212D439 | List: |
| References | |
| OL-5, NUDOCS 8703040222 | |
| Download: ML20212D884 (41) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY-COMMISSION Before the Atomic Safety and Licensino Board
-)
-In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
DIRECT TESTIMONY OF GREGORY C. MINOR ON BEHALF OF SUFFOLK COUNTY CONCERNING CONTENTION EX 36 February 27, 1987 8703040222 870227 PDR ADOCK 05000 2
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
TESTIMONY OF GREGORY C. MINOR ON BEHALF OF SUFFOLK COUNTY CONCERNING CONTENTION EX 36 Q.
Please state your name, address and position.
A.
My name is Gregory C. Minor.
I am Vice President of MHB Technical Associates, 1723 Hamilton Avenue, San Jose, California 95125.
Q.
Briefly summarize your experience and professional j
qualifications.
A.
I have 27 years of nuclear experience.
For 16 years I was employed by the General Electric Company and worked on matters related to the design, construction and operation of nuclear monitoring and safety systems, including hands-on l
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experience at reactor sites.
I have been a consultant with MHB j
Technical Associates for 11 years, during which time I have been
[
involved in a wide variety of projects, many of them relating to the operation and construction of, or emergency planning for, nuclear power plants.
I have testified as an expert witness in numerous proceedings before the Nuclear Regulatory Commission and other bodies, including both the health and safety and prior emergency planning proceedings in this Shoreham litigation.
I am a member of the Nuclear Power Plant Standards Committee of the Instrument Society of America, and I served as a peer reviewer of the NRC's TMI Accident Investigation Report.
I am also co-holder of a patent on a nuclear monitoring system.
The details of my education, experience and professional qualifications are included in the resume which is Attachment 1 to this testimony.
Q.
What is the purpose of this testimony?
A.
The purpose of this testimony is to address the matters raised in Contention Ex 36 arising out of the Exercise of LILCO's Offsite Emergency Plan for the Shoreham Nuclear Power Plant, which was held on February 13, 1986 (hereafter the " Exercise").
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Q.
Are you familiar with LILCO's Offsite Emergency Plan for Shoreham?
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A.
Yes.
In the earlier hearings on Shoreham emergency I
plans, I submitted testimony concerning the potential doses and radiological exposures following an accident at Shoreham, the l
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effects upon such doses of sheltering and evacuation as proposed in the LILCO Plan, and issues relating to protective action recommendations and procedures, recovery and reentry, and monitoring and decontamination instrumentation and procedures.
In preparing such testimony, I reviewed the pertinent portions of several revisions of LILCO's offsite and onsite emergency response plans for Shoreham.
Q.
What do you understand to have been the purpose of the Exercise?
A.
Under the NRC's regulations, before a license can be issued for full power operation of a commercial nuclear power plant there must be a FEMA-graded exercise of the offsite emergency plan.
The purpose of the exercise is to determine whether that plan can and will be implemented in the event of an j
actual emergency.
The NRC must then consider the findings of FEMA about the results of such an exercise in its decision on i
whether there is reasonable assurance that adequate measures to protect the public health and safety can and will be taken in the event of a radiological emergency.
I understand that it is LILCO's position in this litigation that FEMA's findings concerning the Exercise and the actions by LILCO players during the Exercise provide a basis for the NRC to conclude that the LILCO Plan can and will be implemented, and that there is reasonable assurance that adequate protective measures can and -
a will be taken to protect the public health and safety in the event of a real accident at the Shoreham plant.
For the reasons stated in this testimony, in my opinion the results of the Exercise cannot be used to make the affirmative approving finding sought by LILCO with respect to the subject covered by Contention Ex 36.
Q.
Please state Contention Ex 36.
A.
The Contention states as follows:
The exercise demonstrated a fundamental flaw in the LILCO Plan in that subsequent to their adoption of the original recommendations from the onsite staff at the EOF, LERO personnel made protective action recommendations without apparent basis, failed to consider alternative protective measures that could have resulted in more dose savings, and made inappropriate recommendations, in violation of 10 CFR S 50.47(b)(10), and NUREG 0654 S II.J.10.m.
Thus, LILCO failed to satisfy objectives EOC 8 and 12 and the exercise precludes a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham accident, as required by 10 CFR S 50.47(a)(1).
Specifically, LERO personnel had no apparent basis for the decision to recommend that i
people in the original downwind zones -- i.e.,
zones A-M, Q, and R -- should as late as 3:48 leave their homes and attempt to evacuate if they had not done so earlier.
EBS messages simulated every 15 minutes between 12:06 and l
3:48 contained such a recommendation.
The documents generated at the EOC fail to indi-I cate that any calculations or dose projections were performed to determine if this remained an appropriate recommendation for the entire period during which it was broadcast.
There j
is no indication that the continuing appro-
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priateness of such a recommendation was ever even carefully considered by LERO personnel in the EOC.
In fact, while such EBS messages were being simulated (beginning at 12:06), the EOF was projecting that a wind shift would direct the plume away from the original downwind zones as early as 3:00.
LERO personnel were aware of that projection.
In light of that projection, however, it may have been more appropriate, and resulted in more dose savings, for individuals who had not yet left their homes by, for example, 2:00 or 3:00, to remain sheltered in their homes until after the wind had shifted, rather than getting on the roads with no protection before the wind shift.
After the shift, such persons may have been able to evacuate with a likelihood of less exposure and smaller doses.
The failure even to consider such an alternative protective action for those in the original downwind zones who had not yet evacuated is significant because the LERO players knew that as of 2:40, according to the exercise controller, there were still supposedly 20,550 people who had not yet evacuated.
l Q.
Do you agree with that Contention?
A.
Yes I do.
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Q.
Please describe generally the procedures set forth in the LILCO Plan which govern the making of plume exposure pathway protective action recommendations to the public.
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1 A.
OPIP 3.6.1 is the primary governing procedure.
It sets forth the responsibilitir e of various LERO personnel, and specific actions they should take in determining what plume exposure pathway protective. action recommendations should be made to the public.
The goal of protective actions according to the LILCO Plan is "to avoid or to reduce the projected dose when the benefits derived from such an action are sufficient to offset any undesirable features of the action."
- Plan, 3.6-1.
This is consistent with the guidance of NUREG 0654, which states that
"[t]he overall objective of emergency response plans is to provide dose savings.
" and "[t]he ability to best reduce potential exposure under the specific conditions during the course of an accident should determine the appropriate (protective action] response" for the plume exposure pathway.
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NUREG 0654 S I.D.1 at 6, 9.
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According to OPIP 3.6.1, the LERO Radiation Health Coordinator (hereafter, the "RHC") "is responsible for advising on Protective Action Determinations based upon recommendations provided by SNPS and if time permits, an independent development l
of Protective Action Recommendations based upon dose projections or offsite radiological monitoring survey data."
OPIP 3.6.1, S 2.1.
The RHC has " primary responsibility for calculating offsite dose projections based upon radiological release data and. _
meteorological conditions."
OPIP 2.1.1 at 12.
He also is responsible for "providing protective action recommendations to the Director of Local Response for both plume and ingestion pathways."
14 The LERO Nuclear Engineer is responsible for evaluating the plant's operational status and determining if protective actions are appropriate based upon potential degradation of plant condi-tions.
OPIP 3.6.1, at S 2.2.
The LERO Evacuation Coordinator is responsible "for providing input concerning offsite conditions,
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particularly road and weather conditions."
Id., S 2.4.
The LERO Director is ultimately responsible for making the final decision to implement protective actions for the public based upon the recommendations of the Radiation Health Coordinator.
OPIP 2.1.1 at 5, 12; OPIP 3.6.1, S 1.0.
OPIP 3.6.1 identifies several specific factors all of which should be considered prior to the recommendation of protective actions.
For example, OPIP 3.6.1 expressly states the following
" Precaution":
The dose-saving effectiveness of protective actions can be influenced by many variable factors such as expected duration of the releases, involved population, weather conditions, projected evacuation t,imes, and plant conditions.
Whenever possible, these factors should all be considered prior to the recommendation of protective actions....
OPIP 3.6.1, S 3.1.
In addition, in describing the evacuation time estimates used in the procedure and a related " Evacuation Time Estimate Sensitivity Study," the procedure cautions that the
" study should be reviewed by the Radiation Health Coordinator and Evacuation Coordinator."
Id.,
S 3.3.
OPIP 3.6.1 also describes in detail actions to be taken by the Nuclear Engineer to use data concerning plant status, meteorological conditions, survey data, dose projections, release data, and evacuation time estimates to determine protective action recommendations for review by the Radiation Health Coordinator.
The procedure includes detailed attachments describing the criteria to be used in comparing potential dose savings from sheltering and evacuation in order to decide which action to recommend.
See Attachments 2, 3, and 4 to thir testimony for examples of criteria provided in OPIP 3.6.1.
Sound judgment and personal assessments of the situation are also presumed to be part of the prc iss used in recommending and deciding upon protective action recommendations for the public.
i OPIP 3.6.1, S 1.0.
Q.
During the Exercise, what information or data were available to LERO personnel at the EOC to be used in making pro-I l
tective action decisions?
A.
The following types of data and information were avail-1 able to the EOC personnel:
Data on plant conditions including current and projected release rates and measurements,
Dose projections and protective action recommendations from the EOF Current and projected meteorological data Field survey data (smear samples and air samples)
In additica, pre-calculated evacuation time estimates and updated actual information about road conditions should have been available to the RHC from the Evacuation Coordinator.
Q.
The Contention refers to the LERO decision to recommend that people in zones A-M, Q and R should evacuate and EBS messages containing such a recommendation.
When was that decision made?
A.
According to exercise legs, at 10:10 a.m.,
the Director of LERO made the decision to adopt the RHC's recommendation to evacuate zones A-M, Q and R.
The broadcast of an EBS message containing such a recommendation was first simulated at approximately 10:24 a.m.
Q.
Please describe your understanding of how the decision to make that recommendation was arrived at during the Exercise.
A.
At approximately 9:58 a.m., the EOF recorenended to the EOC that there be an evacuation advisory for zones A-M, O and R.
At approximately 9:59, the RHC made the same recommendation to the LERO Director.
According to the RHC's Exercise log, his decision was " based on containment failure" and projected core failure in 2-3 hours.
Egg Transcript of Deposition of Richard Watts (December 3, 1986) at 66.
As of the time the REC made his recommendation to the Director of LERO, he had not yet performed any computer calcula-tions using scenario release data to determine protective action recommendations, although there had been some computer calcula-tions using hypothetical data.
His evacuation recommendation was based upon plant conditions and Attachments 4, 5 and 6 of OPIP 3.6.1. (OPIP 3.6.1 Attachments 3 and 4 are Attachments 2 and 3 hereto).
He also used the evacuation time estimates in the LILCO Plan which assumed a " Guided" evacuation, and he assumed that Traffic Guides would be in position and providing " guidance" throughout the Exercise, in arriving at his recommendation.
Watts Depo. Tr. at 51-52.
Subsequent to the RHC's initial evacuation recommendation to the LERO Director, the EOC did perform a calculation pursuant to OPIP 3.6.1 using dose projection data from the Exercise scenario.
Thus, the RHC noted in his log at 10:25 a.m. the following:
For the record, the maximum child thyroid pro-jected dose for a 9 hour1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> release period (taken from Case No. 3) would be 7.88 rem.
This substantiates the recommendation of evacuating zones A-M, Q, R.
Q.
What meteorological data were used in making the evacu-ation recommendation for zones A-M, Q and R?
A.
According to the Exercise logs of the RHC and the LERO Director, as of the time that recommendation was made, the wind was blowing from the ENE toward the WSW at five miles per hour.
At that time, it was projected to shift, so it would blow from WNW toward ESE, at approximately 6:00 p.m.
Q.
During the Exercise, were any protective action decisions made by LERO personnel subsequent to the original evacuation decision at 10:10?
A.
Yes, there were several.
First, at 10:35, the RHC recommended, and the Health Services Coordinator decided, to instruct LERO workers to ingest potassium iodide.
This recommendation was based on the REC's assessment that there was a potential for radioactive iodine to be released in significant quantities.
Watts Depo. Tr. at 76.
Second, at 11:46, the LERO Director decided to extend the evacuation recommendation to include zones N, O, P, and S, based on the recommendation of the RHC.
That recommendation was based on the RHC's anticipation that there would be significant i
releases of long duration which, in light of the expected wind shift, would impact those additional zones.
Watts Depo. Tr. at 77.
Third, at 1:31 p.m. the LERO Director decided to instruct people in zones A, B, F, G, K, and Q to report to the Coliseum for monitoring and possible decontamination, based on the RHC's recommendation.
According to the RHC's deposition testimony, this recommendation was based upon his review of evacuation routes, and determinations as to whether individuals would go through the plume during their evacuation trips.
In making his i
recommendation, the RHC assumed that evacuation would proceed according to the pre-calculated evacuation time estimates in the LILCO Plan, and that evacuation would have begun at the time the first evacuation recommendation was broadcast over the EBS.
Watts Depo. Tr. at 97-98.
Finally, every 15 minutes from 10:24 until noon, the evacu-ation recommendation for zones A-M, Q and R was re-affirmed by a simulated re-broadcast of the original 10:24 EBS message.
- And, every 15 minutes from approximately noon until approximately 3:45 p.m., the evacuation recommendation for the entire EPZ was reiterated in simulated EBS broadcasts.
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f Q.
During the Exercise, did any of the information upon which the original evacuation recommendation for zones A-M, Q and R was based change subsequent to the time of that original decision to recommend evacuation?
A.
Yes.
The meteorological data changed with respect to wind direction and the timing of the projected wind shift.
According to the LERO Director and RHC logs, as of 10:29 a.m.,
the wind shift was expected at 4:00 p.m.
As of 11:09, the shift was predicted for between 3:00 and 6:00 p.m.
At 11:52, the Director's log reflects a projection that the wind shift would be as early as 3:00 p.m.
Release data and dose projections also changed.
Specifical-ly, while the initial recommendation for evacuation was based upon plant conditions and one reading from the plant RBSVS moni-tor, subsequently field survey data from both air sampling and smear sampling became available as well as additional dose pro-jections.
In addition, subsequent to the initial evacuation recommen-dation, two major impediments to evacuation were introduced into the scenario at 10:40 and 11:00 a.m.
These impediments and their impact on evacuation traffic conditions are discussed in testi-mony on Contentions 40 and 41. _
a Q.
What is the significance of a wind shift with respect to an evacuation recommendation?
A.
The wind direction governs the direction of the plume.
It is one of the major factors to be considered in calculating dose projections and in making protective action recommendations.
Specifically, with the wind blowing from the ENE toward the WSW, as it was during the early part of the accident postulated in the Exercise scenario, the radioactive material would have been blown in the form of the plume in a WSW direction, roughly toward Nassau County.
Depending on the width of the plume, this would contaminate substantial portions of zones A, B,
F, G, K and parts of Q, R and L.1 geg Figure 2 from the LILCO Flan, App.
A, which is Attachment 5 hereto.
Once the wind shifted to be from the WNW toward the ESE, as it was projected to do during the Exercise, it would blow across the original path of the plume and clear out the contaminated air from the original downwind zones by blowing the plume over the zones further to the south and east.
This would cause subsequent 1
According to the LILCO Plan, this wind direction and the plant conditions during the Exercise, uould require the evacuation of zones of A-M, Q and R, as was recommended.
OPIP 3.6.1, Att. 6, Watts Depo. Tr. at 66-74.
a releases and the release material already in the plume to blow over zones E, J, O, P, S, and parts of D and I, rather than over the original downwind zones.2 Egg Attachment 5.
Q.
How does wind direction and the impact of the wind shift you have described affect doses?
A.
People in affected zones are susceptible to dose from two sources:
ground contamination and airborne contamination.
The ground dose is a result of contaminated particles which have landed on surfaces.
The dose for airborne contamination, also referred to as a cloud dose, involves an inhalation dose, received through breathing air which contains gaseous radioactive fission products, plus a whole body dose received from the cloud.
With respect to the exercise scenario, for the people in the original downwind zones, the effect of the windshift would differ with respect to the ground dose and the inhalation dose they would be likely to receive.
The ground dose to that area, up to the time of the wind shift, would be the same with or without that shift.
After the shift, however, there would not be a 2
According to the LILCO Plan, the wind direction projected after the shift and the plant conditions would require the evacuation of zones A-J, O, P,
and S.
OPIP 3.6.1, Att. 6.
During the Exercise, LERO added zones N, O, P and S to the original evacuation order in response to the wind shift projection..
substantial addition to the radioactive material causing ground dose in the original downwind area.
The ground dose resulting from the pre-wind shift plume would continue.
The inhalation dose and the whole body dose for the original downwind zones would become smaller after the wind shift.
This is because the wind shift would have caused the plume to flow in a southeasterly direction and the airborne contamination would therefore be blown out of the original downwind area.
The impact upon dose for people in the zones which would become downwind after the windshift would be the reverse; that is, after the shift they would be subject to both a ground dose and an inhalation dose which, prior to the windshift, they would not have experienced.
Of course, the actual dose received by individuals in any zone is affected by the shielding provided by their surroundings.
A person in an automobile would receive essentially no protection from the cloud dose,3 and a relatively small amount of protection from the ground dose.
LILCO assumes that the shielding factor for an individual sheltered in the average Long Island residence is 0.7 for the cloud dose, and 0.2 for the ground dose.
This means that the average person would receive 70 percent of the 3
LILCO Plan, Table 3.6.5. _
cloud dose, and 20 percent of the ground dose.4 Thus, people in the original downwind zones, before the windshift, were subject to receiving both a ground dose and a cloud dose once the plume arrived over those zones.
If they were in their cars in those zones they would receive no shielding from the cloud dose and only a small reduction in the ground dose.
If they were in an average house, their exposure would be less, since, on the average, they would receive a 30 percent caduction in cloud dose (as opposed to none in their cars) and an 80 percent reduction in ground dose.
After the windshift, and after the plume had been blown away from the original downwind zones, those individuals would have continued exposure to a ground dose, but a smaller potential cloud dose.
Q.
During the Exercise, what data were available to the Radiation Health Coordinator concerning the location of the plume?
A.
According to the deposition testimony of the Radiation Health Coordinator, during the Exercise he received several smear readings, which provided data on the amount of deposition.
At least one of those readings, reflected in his log shortly after 2:00 p.m., was taken downwind approximately seven miles from the 2
plant in a WSW direction.
That reading was 2700 cpm /100 cm,
4 Egg LILCO Plan, Table 3.6.5; LILCO's Testimony on Conten-tions 60, 61, 62, and 64 (Protective Action Recommendations (March 21, 1984), at 20-22.
The RHC also stated that during the Exercise, based on survey data, he believed there would be significant iodine releases and significant ground deposition.
In addition, at 12:45 the RHC recorded in his log a reading of 3130 mR/hr at 0.5 miles downwind; at 12:10, he recorded that an air sample reading of 180 mR/hr was reported at two miles WSW of the plant.
Q.
In your opinion, in light of the changing meteorologi-cal and dose projection information available to the Radiation Health Coordinator during the Exercise, should he have done anything in addition to what he did?
A.
Yes.
The EBS messages repeated every 15 minutes from 10:2a through the end of the Exercise recommended that people in the original downwind zone should begin to evacuate if they had not already done so.
Each such message was, in effect, a new decision to reaffirm the original evacuation recommendation.
These messages were sent out, however, without any apparent calculation or other confirmation using updated information that it was still the proper decision -- that is, the one likely to result in maximum dose savings -- as time passed and conditions changed.
The new direction of plume travel likely after the projected windshift, and the updated survey data on deposition, should have resulted in some further assessment of the relative dose savings from sheltering and evacuation, in light of actual traffic o
conditions.
This was particularly important as the time of the projected wind shift came closer, and the LERO personnel learned that over 20,000 people in the original downwind zones had not yet left their homes as of 2:40 p.m.
It does not appear that these matters were considered during the Exercise following the original evacuation order.
Q.
Is it your testimony that in light of the changed timing of the projected windshift, LERO personnel should have rescinded the original evacuation recommendation for persons in zones A-M, Q, and R?
A.
No.
My point, as stated in Contention Ex 36, is that additional updated calculations of projected dose savings, for sheltering and for evacuation, should have been performed and evaluated when conditions began to change.
In other words, real analysis and comparison of the relative dose savings likely from sheltering and from evacuation, using actual updated data, should have been performed before it was decided to reaffirm the 10:10 a.m. decision that evacuation was the appropriate recommen-dation for people in zones A-M, Q and R.
LERO did not do this.
As a result, the repeated reaffirmation of the original decision, during the period from approximately noon through 3:45 p.m.,
lacked the analytical verification of dose savings.
Without having done the relevant calculations in light of changing - - -. - - -.
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weather and release data, taking into account the likely doses for people becinnino an evacuation trip late in the process, neither I nor LILCO can now validate the decision to continue calling for evacuation of the more than 20,000 people still in their homes at the time when changes were occurring or predicted to occur in wind and traffic conditions.
The decision may have been correct, but there was no review of the most important protective action criteria -- dose-savings.
Thus, LERO should have analyzed the new conditions.
If that analysis had indicated a greater dose savings resulting from temporarily sheltering and then evacuating the 20,000 people in the downwind zones who had not yet left by mid-afternoon, LERO then could have decided if other factors involved (such as potential confusion to evacuees), justified one decision or another.
That would have constituted an appropriate and informed decision that the original recommendation, which was by then 3 or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> old, was still valid.
During the Exercise, however, the
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LERO personnel never engaged in that process.
Q.
Do you believe that the failure of LERO personnel to I
consider alternative protective actions is significant?
A.
Yes I do.
As noted above, the consideration of the relative dose savings from alternative protective actions is the fundamental premise and basis of LILCO's protective action recom-j -. - -..-. -
mendation procedure and the applicable regulations.
It is also a practical necessity due to the constantly changing environment inherent in an accident of the type hypothesized in the Exercise.
Once an evacuation has been started and radioactive releases have begun, there are real data available which should be used and evaluated to continually verify the appropriateness of protective action recommendations.
For example, rather than relying throughout an accident upon pre-calculated estimates of evacuation times, the RHC should analyze real data which become available as to the effectiveness of pre-ordained traffic routes or guidance and the impact of traffic impediments, and the validity of assumptions which went into the pre-calculated time estimates.5 He should also analyze data which become available concerning the number of people who are still in affected zones and thus subject to weather and release conditions different from those which may have led to early protective action recommendations.
Again, there is no evidence that this was done during the Exercise.
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5 I understand that the FEMA Accident Assessment Evaluator at the EOC made a similar observation that the RHC should be con-sulted when an impediment to evacuation is encountered because he needs to have the best available information on road conditions and evacuation times to factor into protective action decisions.
Deposition Transcript of Paul A. Giardina (January 22, 1987), at i
98-100. _. _, _ _ _
o-By making the' repeated recommendation as late as 3:45 p.m.
to begin evacuating, the LERO personnel were urging 20,000 people still in zones A-M, Q and R into the streets (which may have been blocked by impediments) in automobiles which provide no effective shielding from plume exposure.
That may have been the proper recommendation.
However, keeping those people in their homes (which do provide some shielding) for a few more hours and then asking them to leave when the plume was no longer in their vicinity, may have effected a dose-saving to a substantial number.
During the Exercise, LILCO never analyzed the alter-natives to make an informed determination.
Furthermore, the consideration of these alternatives was, in essence, part of the Exercise objectives.
Objective EOC 12 requires a demonstration of the ability to make appropriate protective action decisions after considering and analyzing appropriate information.
In light of the failure to consider or analyze the continued appropriateness of the 10:10 a.m.
evacuation recommendation in light of changed conditions and additional data, I do not believe objective EOC 12 was satisfied during the Exercise.
Q.
Does that conclude your testimony?
A.
Yes..
ATTACHMENTS Professional Qualifications of Gregory C. Minor i-OPIP 3.6.1, Attachment 3 OPIP 3.6.1, Attachment 4 OPIP 3.6.1, Attachment 5 I
LILCO Plan, Appendix A, Figure 2 i
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ATTACHMENT 1
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ATTACHMENT 1 PROFESSIONAL QUALIFICATIONS OF GREGORY C. MINOR GREGORY C. MINOR MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, California 95125 (408) 266-2716 EXPERIENCE:
1976 to PRESENT Vice-President - MHB Technical Associates, San Jose, California Engineering and energy consultant to state, federal, and private organi-zations and individuals.
Major activities include studies of safety and risk involved in energy generation, providing technical consulting to legislative, regulatory, public and private 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 Con-cerned Scientists and co-author of a risk analysis of Swedish reactors for the Swedish Energy Commission.
Served on the Peer Review Group of the NRC/TMI Special Inquiry Group (Rogovin Committee).
Actively in-volved in the Nuclear Power Plant Standards Committee work for the In-strument Society,of America (ISA).
1972 - 1976 Manager, Advanced Control and Instrumentation Engineering, General Elec-tric Company, Nuclear Energy Division, San Jose, California Managed a design and development group of thirty-four engineers and sup-port personnel designing systems for use in the measurement, control and operation of nuclear reactors.
Involved coordination with other reactor design organizations, the Nuclear Regulatory Commission, and customers, both overseas and domestic.
Responsibilities included coordinating and managing and design and development of control systems, safety systems, and new control concepts for use on the next generation of reactors.
The position included responsibility for standards applicable to control and instrumentation, as well as the design of short-term solutions to field problems.
The disciplines involved included electrical and me-chanical engineering, seismic design and process computer con-trol / programming, and equipment qualification.
1970 - 1972 Manager, Reactor Control Systems Design, General Electric Company, Nu-clear Energy Division, San Jose, California Managed a group of seven engineers and two support personnel in the de-sign and preparation of the detailed system drawings and control docu- -
ments relati32 to safety and emergency systems for nuclear reactors.
Responsibility required coordination with other design organizations and interaction with the customer's engineering personnel, as well as regu-latory personnel.
1963 - 1970 Design Engineer, General Electric Company, Nuclear Energy Division, San Jose, California Responsible for the design of specific control and instrumentation sys-tems for nucleat reactors.
Lead design responsibility for various sub-systems 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 responsibilities included on-site checkout and testing of a complete reactor control system at an experi-mental reactor in the Southwest.
Received patent for Nuclear Power Mon-itoring System.
1960 - 1963 Advanced Engineering Program, General Electric Company; Assignments in Washington, California, and Arizona Rotating assignments in a variety of disciplines:
Engineer, reactor maintenance and instrument design, KE and D re-actors, Hanford, Washington, circuit design and equipment mainte-nance coordination.
Design engineer, Microwave Department, Palo Alto, California.
Work on design of cavity couplers for Microwave Traveling Wave Tubes (TWT).
Design engineer, Computer Department, Phoenix, Arizona.
Design of core driving circuitry.
Design engineer, Atomic Power Equipment Department, San Jose, Cal-ifornia.
Circuit design and analysis.
Design engineer, Space Systems Departaent, Santa Barbara, Califor-nia. Prepared control portion of satellite proposal.
Technical Staff - Technical Military Planning Operation.
(TEMPO),
Santa Barbara, California.
Prepare analyses of missile exchanges.
During this period, completed three-year General Electric program of extensive education in advanced engineering principles of higher mathematics, probab'ility and analysis.
Also completed courses in Xepner-Tregoe Effective Presentation, Management Training Program, and various technical seminars.
2-
EDUCATION University of California at Berkeley, BSEE,1960.
Advanced Course in Engineering - three-year curriculum, General Electric Company, 1963.
Stanford University, MSEE,1966.
HONORS AND ASSOCIATIONS Tau Beta Pi Engineering Honorary Society Co-holder of U.S.
Patent No. 3,565-760, " Nuclear Reactor Power Monitoring System," February, 1971.
Member: American Association for the Advancement of Science.
Member: Nuclear Power Plant Standards Committee. Instrument Soci-ety of America.
PERSONAL DATA Born:
June 7, 1937 Married, three children Residence:
San Jose, California PUBLICATIONS AND TESTIMON(
1.
G. C. Minor S. E. Moore, " Control Rod Signal Multiplexing," IEEE Trans-actions on Nuclear Science Vol. NS-19, February 1972.
2.
G. C. Minor, W. G. Milam, "An Integrated Control Room System for a Nu-clear Power Plant " NEDO-10658, presented at International Nuclear In-dustries Fair and Technical Meetings, October,1972, Basle, Switzerland.
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 Concerned Scientists, Cambridge, Mas-sachusetts.
5.
Testimony of G. C. Minor D. G. Bridenbaugh, and R. B. Hubbard before the California State Assembly Committee on Resources, Land Use, and En-ergy, March B,1976.
6.
Testimony of G. C. Minor and R. B. Hubbard before the California State Senate Committee on Public Utilities, Transit, and Energy, March 23, 1976.
O, p
7.
Testimony of G. C. Minor regarding the Crafenrheinfeld Nuclear Plant, March 16-17, 1977 Wurzbuerg, Germany.
8.
Testimony of G. C. Hinor before the Cluff Lake Board of Inquiry, Regina, Saskatchewan, Canada, September 21, 1977.
9.
The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Safety Study WASH-1400 (NUREG-75/0140). H. Kendall, et al, edited by G. C. Mi-nor and R. 8. Hubbard for the Union of Concerned Scientists, August, 1977.
10.
Swedish Reactor Safety Study:
Barseback Risk Assessment, MHB Technical Associates January, 1978.
(Published by Swedish Department of Industry as Document Ds! 1978:1) a J
11.
Testimony by G. C. Minor before the Wisconsin Public Service Commission.
February 13, 1978 Loss of Coolant Accidents:
Their Probability and
. Consequence.
12.
Testimony by G. C. Minor before the California Legislature Assembly Com-mittee on Resources. Land Use, and Energy, AB 3108, April 26, 1978, i
Sacramento, California.
4 13.
Presentation by G. C. Minor before the Federal Ministry for Research and Technology (BMFT), Meeting on Reactor Safety Research, Man / Machine In-terface in Nuclear Reactors Atgust 21, and September 1, 1978, Bonn, j
Germany.
14.
Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard, before the Atomic Safety and Licensing Board, September 25, 1978, in the matter of Black Fox Nuclear Power Station Construction Permit Hearings, Tulsa, Oklahoma.
15.
Testimony of G. C. Minor, ASLB Hearings Related to THI-2 Accident, Ran-cho Seco Power Plant, on behalf of Friends of the Earth, September 13, i
1979.
l 16.
Testimony of G. C. Minor before the Michigan State Legislature. Special Joint Committee on Nuclear Energy Implications of Three Mile Island Ac-cident for Nuclear Power Plants in Michigan, October 15, 1979.
17.
A Critical View of Reactor Safety, by G. C. Minor, paper presented to l
the American Association for the Advancement of Science Symposium on Nuclear Reactor Safety, January 7,1980, San Francisco, California.
18.
i The Effects of Aging on Safety of Nuclear Power Plants, paper presented i
at Forum on Swedish Nuclear Referendum, Stockholm, Sweden, March 1 1980.
4 19.
Minnesota Nuclear Plants Gaseous Emissions Study, MHB Technical Associ-ates, September 1980, prepared for the Minnesota Pollution Control Agency, Roseville, MN.
4
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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 Lighting Company Temporary Rate Case, September 22, 1980.
21.
Systems Interaction and Single Failure Criterion, MHB Technical Assoct-ates, January, 1981, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
22.
Testimony of G. C. Minor and D. G. Bridenbaugh before the New Jersey Board of Public Utilities, Oyster Creek 1980 Refueling Outage Investiga-tion, in the matter of Jersey Central Power and Light Rate Case, Febru-ary 19, 1981.
23.
Testimony of G. C. Minor and D. G. Bridenbaugh on PORV's and Pressurizer Heaters, Diablo Canyon Operating License hearing before ASLB, January 11, 1982.
24.
Testimony of G. C. Minor and R. B. Hubbard on Emergency Response Plan-
, Diablo Canyon Operating License hearing before ASLB, January 10, 25.
Systems Interaction and Single Failure Criterion:
Phase II Report, MHB Technical Associates, February 1982, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
26.
Testimony of G. C. Hinor, R. B. Hubbard, M. W. Goldsmith, S. J. Harwood on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Contention 78, Safety Classification and Systems Interaction, April 13, 1982.
27.
Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1 regarding Suffolk County Contention 11, Passive Mechanical Valve Fail-ure, April 13, 1982.
r 28.
Testimony of G. C. Minor and R. B. Hubbard on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Is-land Lighting Company, Shoreham Nuclear Power Station Unit 1, regarding Suffolk County Contention 27 and S0C Contention 3, Post-Accident Moni-t_o-ino, May 25, 1982.
29.
Testimony of G.
C.
Minor and D. G.
Bridanbaugh on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1 i
regarding Suffolk County Contention 22, SRV Test Program, May 25, 1982.
i I'
30.
Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1 regarding Suffolk County Contention 28(a)(vi) and SOC Contention 7A(6),
Reduction of SRV Challenges, June 14, 1982. t
, 31.
Tastimony of G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Com-Shoreham Nuclear Power Station - Unit 1, regarding Environmental
- pany, Qualification, January 18, 1983.
32.
Testimony of G. C. Minor and D. G. Bridenbaugh before the Pennsylvania Public utility Commission, on behalf of the Office of Consumer Advocate, Regarding the Cost of Constructing the Susquehanna Steam Electric Sta-tion, Unit I, Re: Pennsylvania Power and Light, March 18, 1983.
33.
Supplemental testimony of G. C. Minor, R. B. Hubbard, and M. W. Gold-smith on behalf of Suffolk County, before the Atomic Safety and Licens-ing Board, in the matter of Long Island Lighting Company, Shoreham Nu-clear Power Station, Unit 1, regarding Suffolk County Contention 78 Safety Classification and Systems Interaction, March 23, 1983.
34.
Testimony before the District Court Judge in the case of Sierra Club et.
al. vs. DOE regarding the Clean-up of Uranium Mill Tailings.
June 20, 1983.
l 35.
Systems Interaction and Single Failure Criterion: Phase 3 Report, MHB Technical Associates, June,1983, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
36.
Systematic Evaluation Program:
Status Report and Initial Evaluation, MHB Technical Associates, June,1983, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
37.
Testimony of G. C. Minor, F. C. Finlayson, and E. P. Radford before tne Atomic Safety and Licensing Board, in the Matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1 regarding Emergency Planning Contentions 65, 23.0 and 23.H. November 18, 1983.
38.
Testimony of G. C. Minor, Sizewell
'B' Power Station Public Inquiry, Proof of Evidence Recarding Safety Issues December,1983.
39.
Testimony of D. G. Bridenbaugh, L. M. Danielson, R. B. Hubbard and G. C.
Minor before the State of New York Public Service Consnission, PSC Case No. 27563, in the matter of Long Island Lighting Company Proceeding to Investigate the Cost of the Shoreham Nuclear Generating Facility --
Phase II, on behalf of County of Suffolk, February 10, 1984.
40.
Testimony of Fred C. Finlayson, Gregory C. Minor and Edward P. Radford before the Atomic Safety and Licensing Board, in the Matter of Long Is-land Lighting Company, Shoreham Nuclear Power Station, Unit 1 on behalf of Suffolk County Regarding Emergency Planning Contention 61 (Sheltering), March 21, 1984.
41.
Testimony of G. Dennis Eley, C. John Smith, Gregory C. Minor and Dale G.
Bridenbaugh before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting company, Shoreham Nuclear Power Station Unit 1, regarding EMD Diesel Generators and 20 MW Gas Turbine, March 21, 1984.
42.
Revised Testimoc.y of Gregory C. Minor before the Atomic Safety and Li-censing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County regarding Emergency Planning Contentions 85 and 88 (Recovery and Reentry), July 30, 1984.
43.
Testimony of Dr. Christian Meyer, Dr. Jose Roesset, and Gregory C. Minor before the Atomic Safety and Licensing Board, in the matter of Long Is-land Lighting Company, Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County, regarding Low Power Hearings (Seismic Capabilities of AC Power Sources), July 1984.
44.
Affidavit of Gregory C. Minor, Emergency Planning Legal Authority Court Case, State Court of New York, September 11, 1984.
45.
Surrebuttal Testimony of Dale G. Bridenbaugh, Lynn M. Danielson, Richard B. Hubbard, and Gregory C. Minor, Before the New York State Public Ser-vice Commission, PSC Case No. 27563, Shoreham Nuclear Station Long It-land Lighting Company, on behalf of Suffolk County and New York State Consumer Protection Board, regarding prudency of LILCO, October 4,1984.
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 the prudency of expenditures by Fitchburg Gas and Electric Light Company on 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 Comission Staff regarding Seabrook Unit 2 Docket No.84-113, December 21, 1984.
48.
Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor regarding Suffolk County's Emergency Diesel Generator Load Contention, Docket No.
50-322-OL, January 25, 1985.
49.
Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson, and Gregory C. Minor on behalf of the Department of Public Service, State of Vermont Public Service Board Docket No. 5030, Central Vermont Public Service Corporation, November 11, 1985.
50.
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 Utility Control Prosecutorial Division and Division of Con-sumer Counsel regarding the prudence of expenditures on Millstone Unit
- 3. February 18, 1986.
51.
Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding the prudence of expenditures by New England Power Co. on Seabrook Unit 2 February 21, 1986.
52.
Direct Testimony of Gregory C. Minor on behalf of the Frosecutorial Di-vision of CDPUC regarding CL&P Construction Prudence for Millstone Unit 3 March 19, 1986.
53.
Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding WMEco Construction Prudence for Millstone Unit 3. March 19, 1986.
54.
Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf Dates and Deferred Capital Additions on Millstone Unitof M 1986.
3 March 19, 55.
Rebuttal Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf Seabrook 2 Rebuttal, April 2,1986.of Massachusetts Attorney Gene 56.
Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of State of Maine Staff of Public Utilities Commission regarding Con-struction Prudence of Millstone Unit 3, April 21,1986.
57.
Implications of the Chernobyl-4 Accident for Nuclear Emergency Planni for the State of New York, prepared for the State of New York Consumer Protection Board, by MHB Technical Associates, June 1986.
58.
Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of the Vermont Department of Public Service, regarding Tariff Filing of Central Vermont Public Service Corporation Requesting a 12% Increase in Rates, Docket No. 5132, August 25, 1986.
59.
Surrebuttal Testimony of Gregory C. Minor in the matter of Jersey Cen-tral Power and Light Company, regarding TMI Restart and Performance In-centives, OAL Docket No. PUC 7939-85, BPU Docket No. ER851116 September 11, 1986.
60.
Surrebuttal Testimony of Gregory C. Minor on behalf of State of Vermont Department of Public Service, regarding CVPS/PSNH Construction Prudence of Millstone Unit 3, Docket No. 5132, November 6, 1986.
61.
Direct Testimony of Gregory C. Minor and Lynn K. Price on behalf of State of Vermont Department of Public Service, regarding Seabrook 1 Costs, Docket No. 5132, December 31, 1986.
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ATTACHMENT 2
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s ATTACHMENT 2 OPIP 3.6.1 Page 43 of 44 THYROID GUIDANCE CHART IF THEN Projected dose (Item 19) is No action less than 5 rem Shelter dose (Item 23) is less Shelter
- than 25 rem Shelter dose (Item 23) is equal Shelter
- to or greater than 25 rem and evacuation dose (Item 21) is equal to or greater than shelter dose Shelter dose (Item 23) is equal Evacuate to or greater than 25 rem and evacuation dose (Item 21) is 4
less than shelter dose Shelter is to be with ventilation control.
Ventilation control means turning off air conditioners or fans, closing doors and windows thus preventin basement if available.g access of outside air.
Proceed to a 1
WHOLE BODY GUIDANCE CHART IF THEN Projected dose (Item 16) is No action less than 1 rem Shelter dose (Item 22) is less Shelter
- than 5 rem Shelter dose (Item 22) is equal Shelter
- to or greater than 5 rem and evacuation dose (Item 20) is equal to or greater than shelter dose Shelter dose (Item 22) is equal Evacuate to or greater than 5 rem and
)
evacuation dose (Item 20) is less than shelter dose Shelter is to be with ventilation control.
Ventilation control means turning off air conditioners or fans, closing doors and windows thus preventing access of outside air.
Proceed to a basement if available.
Rev. 2
1 -
ATTACHMENT 3
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EPA PAC GUIDE Projected Dose (poe) to the Population Reconsended Actions (a)
Commente Wale body et No planned proteettve sottone.(b)
Freetously recommended l
1.ERO mer issue an edelsory to seek shelter end swett protective eettons any Thyroto e5 further instruettene.
be reconsidered or Montter environmental radiation levels, teretnoted.
Whole body 1 to e5 Seek shelter as a sinteue.
If constrainte esist, Consider evacuation. Evneuste unless constrainto make special consideretton Thyroid 5 to e25 it impraetteal.
1 should be given for Monitor environmental radiation levels, evarustion of children Control access, and pregnant women.
l Whole body 5 and above conduct suindatory eveeustion.
Seektna shelter would be Honitor environmental radiation levels and adjust aree an alternative if Thyroid 25 and above for mandatory evacuation based on these levels, evacuation were nnt Control access.
tamediately possible.
Projected Dose (pes) to Emergency Team Workers 1
l Whole body 25 Control esposure of emergency tese members to these Although reeptrators and levele except for lifesaving stestens. (Appropriate stable lodine should be Thyrold 125 controls for emergency workers, include time used where effective to llettattans, respirators, and stable lodine.)
control dose to emergency team workere, Whole body 75 Control esposure of emergency team members performing thyrnld dose may not be lifesaving missions to this level. (Control of time a lletting factor for i
of esposure will be most effeettve.)
lifesaving elssions.
pg i
d (a)These settone are recosamended for planning purposes. Proteettve action deelefone at the ttee of the tnotdent O>
xo must take aulating conditions into conntderation.
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(b) At the time or the inoldent, offletale may toplement low-tapant protective acti ms in keeping with the m re mN -
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ATTACHMENT 4 Pego 44a of 44 Attcchmunt 5 Page 1 of 1 PREDETERMINED PROTECTIVE ACTION RECOMENDATIONS FOR GENERAL EMERGENCY CLASSIFICATIONS 1
2 CORE CONTAINnENT PAR TO BE FAILURE FAILURE CONSIDERE0 CONO.
NO NO 2 NILES CTION CONO.
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