ML080740199

New England Coalition, Inc.'S (NEC) Final Witness List

ML080740199
Person / Time
Site:	Vermont Yankee
Issue date:	03/07/2008
From:	Tyler K New England Coalition, Shems, Dunkiel, Kassel, & Saunders, PLLC
To:	Atomic Safety and Licensing Board Panel
SECY/RAS
References
50-271-LR, ASLBP 06-849-03-LR, RAS M-6
Download: ML080740199 (19)

Text

IZNS H-~, DOCKETED USNRC March 7, 2008 (4:53pm)

OFFICE OF SECRETARY UNITED STATES RULEMAKINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICATIONS STAFF Before the Atomic Safety and Licensing Board In the matter of ENTERGY NUCLEAR VERMONT YANKEE, LLC ) Docket No. 50-271-LR and ENTERY NUCLEAR OPERATIONS, INC. ) ASLB No.06-849-03-LR Vermont Yankee Nuclear Power Station )

License Renewal Application )

NEW ENGLAND COALITION, INC.'S (NEC) FINAL WITNESS LIST Pursuant to Section 11.1 .C of the Initial Scheduling Order (November 17, 2006),

New England Coalition, Inc. (NEC) hereby submits its final witness list:

1. Joram Hopenfeld 1724 Yale Place Rockville, MD 20850-1116 Tele: 301-801-7480 Dr. Hopenfeld will testify concerning NEC's Contentions 2A (invalidity of Entergy's environmentally-assisted fatigue analysis and calculations); NEC's Contention 3 (steam dryer); and NEC's Contention 4 (flow-accelerated corrosion). His resume is attached hereto as Exhibit A.

2. Ulrich Witte 71 Edgewood Way Westville, Connecticut 06515 Tele: 203-389-7374 Mr. Witte will testify concerning NEC's Contentions 3 (steam dryer) and 4 (flow-accelerated corrosion). His resume is attached hereto as Exhibit B.

3. Rudolph Hausler Corro-Consulta 8081 Diane Drive Kaufman, TX 75142 Tele: 972-962-8287

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Dr. Hausler will testify concerning NEC's Contention 4 (flow-accelerated corrosion). His resume is attached hereto as Exhibit C.

March 7, 2008 New England Coalition by:

Karen Tyler Andrew Raubvoge SHEMS DUNKIEL KASSEL & SAUNDERS PLLC For the firm Attorneys for NEC 2

EXHIBIT A DOCKET 50-271 NEW ENGLAND COALITIONMHOPENFELD Curriculum Vitae for Dr. Joram (Joe) Hopenfeld A. Professional Expertise Technical analyst in the fields of nuclear safety, thermal hydraulics, corrosion, industrial instrumentation and environmental monitoring.

B. Current Position CEO, Noverflo Inc C. Education Engineering- University of California at Los Angeles: BS 1960, MS 1962, Ph.D 1967.

D. Summary of Work Experience I have 45 years of experience in industry and government primarily in the areas of thermal hydraulics, material corrosion, instrumentation and PWR steam generator testing and licensing. I have managed major international programs on steam generator performance during accidents involving various thermal transients. As a result of my work at the Nuclear Regulatory Commission, ("NRC") my position regarding the safety implication of steam generator tube degradation was adopted. Consequently, in 2001 the NRC launched a five-year major program on the effects of steam generator tube aging on core melt. This program is related to the 2002 reactor head failure at Davis-Besse. I have testified at great lengths before the Advisory Committee on Reactor Safety,

("ACRS") on steam generator tube degradation and related safety issues. In the last several years, I have consulted to law firms and citizen groups regarding steam generator issues.

I

I am the owner and CEO of a small Maryland company, Noverflo, Inc.. Noverflo is developing fiber optic sensors for the oil & gas, the transportation, and the environmental monitoring industries. In 2004 Noverflo has completed a three year program which was sponsored by the U.S. Department of Energy. The program produced a new system for automatic tank gauging. In 1994-1996 Noverflo has developed and commercialized a, shutoff valve for fuel tanks to comply with new EPA regulations.

I have funded and sponsored research and development work at the Engineering Department of the University of Virginia, which resulted in a novel method of measuring pipe wall thinning from erosion/corrosion I have published 14 papers in peer-reviewed technical journals in the areas of thermal-hydraulics, corrosion/ erosion, steam generator dose releases during accidents, steam explosions, sensors and ECM machining. I hold eight US patents and I am listed in the Engineers of Distinction published by the Engineers Joint Council and in American Men and Women in Science.

E. Recent Consulting

1. Winston & Strawn, 1400 L St. Washington D.C 2001 Provided assistance in connection with the February 2000 steam generator event at Indian Point.

2. C-10 Research and Education Foundation, Inc. 44Merrimac St. Newburyport, MA 2

2002-2003 Provided assistance in the preparation of a 2.206 petition to the NRC and other matters in connection with steam generator problems at the Seabrook Station

3. California Earth Corps (Sabrina D. Venskus, Attorney at Law, Santa Monica, CA) 2005 Provided testimony to the Public Utility Commission of the State of California on behalf of California Earth Corps in connection with the San Onofre steam generator replacement project F. Brief Employment History 1962- 1971 -Corrosion testing of materials for the design and operation of liquid metal cooled nuclear reactors. Atomics International, Canoga Park, Calif.

1971- 1973- Participated in the resolution of design issUes as related to material corrosion and thermal hydraulics of nuclear reactors. Atomic Energy Commission 1973 - 1978 Project Manager for the safety evaluation and testing of steam generators for liquid metal reactors. Department of Energy (and its predecessor ERDA).

1978 - 1982 Project Manager for the development of materials and instrumentation for high temperature steam generators for fossil plants. Responsible for the resolution of issues relating to corrosion/erosion. Department of Energy.

1982 - 2001 Program manager for the resolution of various material and safety issues primarily in relation to PWR steam generators. Nuclear Regulatory Commission.

PUBLICATIONS IN PEER REVIEWED JOURNALS 3

1. Distributed Fiber Optic Sensors for Leak Detection In Landfills, Proceeding of SPIE Vol 3541 (1998)

2. Continuous Automatic Detection of Pipe Wall Thinning, ASME Proceedings of the 9th, International Conference on Offshore Mechanics and Arctic Engineering. Feb. 1990 3 Iodine Speciation and Partitioning in PWR Steam Generators, Nuclear Technology, March 1990

4. Comments on "Assessment of Steam Explosion Induced Containment Failures" Letter to the Editor, Nuclear Science and Engineering, Vol. 103, Sept. 1989

5. Experience and Modeling of Radioactivity Transport Following Steam Generator Tube Rupture, Nuclear Safety, 26,286; 1985

6. Simplified Correlations for the Predictions of Nox Emissions from Power Plants. AIAA Journal of Energy, Nov.-Dec., 1979

7. Grain Boundary Grooving of Type 304 Stainless Steel in Armco Iron Due to Liquid Sodium Corrosion, Corrosion, 27, No. 11, 428, 1971

8. Corrosion of Type 316 Stainless Steel with Surface Heat Flux in 1200 Flowing Sodium, Nuclear Engineering and Design, 12; 167-169, 1970 9 Prediction of the One Dimensional Cutting Gap in Electrochemical Machining, ASME Transaction, J. of Engineering for Industry, p100 (1969)

10. Electrochemical Machining- Prediction and Correlation of Process Variables, ASME Transactions, J. of Engineering for Industry, 88:455-461, (1966)

11. Laminar Two-Phase Boundary Layers in Subcooled Liquids, J. of Applied Mathematics and Physics (ZAMP), 15, 388-399 (1964)

12. Onset of Stable Film Boiling and the Foam Limit, International j. of Heat Transfer and Mass Transfer, 6; 987-989 (1963) ) (co-author) 13 Operating Conditions of Bubble Chamber Liquids, The Review of Scientific Instruments, 34, 308-309. (1963); co-author

14. Similar Solutions of the Turbulent Free Convention Boundary Layer for an Electrically Conducting Fluid in the Presence of a Magnetic Field, AIAA J.

1:718-719 (1965) 4

LIST OF PATENTS

1. Automatic Shut-Off Valve for Liquid Storage Tanks, 5,522,415

2. Method and Apparatus for Detecting the Presence of Fluids, 5,200,615

3. Sensors For Detecting Leaks, 5,187,366

4. Method for Monitoring Thinning of Walls and Piping Components 4,922,748

5. Method for Monitoring Thinning of Pipe Walls, 4,779,453

6. Looped Fiber Optic Sensor for the Detection of Substances (5,828,798)

7. Coated Fiber Optic Sensor for The Detection of Substances (5,982,959)

8. Method and Apparatus for Analyzing Information of Sensors Provided Over Multiple Waveguides (6,870,607) 5

EXHIBIT B

. Ulrich-K.-Witte-71 Edgewood Way Westville, Connecticut 06515

, Home: 203 389 7374 Office: 860 577 8077 Mobile: 860 391 1183 Summary:

Over twenty-six years' of professional experience in engineering, configuration management, licensing, regulatory compliance of large scale commercial nuclear facilities. This includes management and implementation. of design change control programs, engineering standards programs, multi-departmentlmulti-functional licensing initiatives, plant design basis and engineering process improvement programs for six energy companies operating seven nuclear power plants. Responsibilities include:

• Systems solutions to plant operations, engineering modifications, safety analyses, design

• changes, installation and testing, software, drawing change programs, and training. Optimized function interfaces to insure proper coordination and synchronization for cost effective and compliant operation of the facility.

• Technical support management, and issue resolution programs that identified potential hardware, operational or equipment function issues, as well as document problems, data management problems and organizational enhancements

• Engineering Change Processes from change inception to document close-out

• Multi-department Configuration Management Program including technical approach, consensus, approval, and implementation. Managed a standing Configuration Management Programs Group. whose goal was to integrate ten functional areas under a corporate strategic plan encompassing two nuclear facilities.

• Vertical slice system design/operation'reviews, design bases / regulatory rule re'conciliation, and licensing bases reconstitution and transitioning projects

• Integration of plant equipment information systems with business processes within engineering, materials management, maintenance, and plant operations.

• Structured business process modeling. Application of functional analysis purely from a data prospective-to enhance change management, efficiency.

• Chaired ANSI certified industry guidance on cost effective, compliant, and institutionalized programs for successful configuration management. enhancement

• EPRI guidance on optimizing the Engineering Change Process

• Formal training to engineering department personal with specific courses on the engineering change process, plant safety analysis, and modification testing. Trained engineering personal on the requirements of the plant wide Configuration Management Program.

Ulrich K "Witte,- Page 2 Technical Consultant Northern Lights Engineering, L.L.C., 71 Edgewood Way, Westville, Connecticut 06515 (May 2002 -Today)

Established a consulting practice where I provided expertise in matters affecting the safe operation and regulatory compliance of commercial nuclear power facilities. This includes licensing andregulatory compliance issues, modification and implementation of industry standards, engineering design reviews, and configuration management analysis associated with an unexpected event, a design failure, or an elevated risk condition, and includes review of proposed changes to. the, plant operating license in preserving design efficacy.

Technical Advisor and Expert Witness to the law firm of Shems, Dunkiel, Kassel, & Saunders, PLLC Currently providing technical assistance in prefiled testimony regarding Entergy Nuclear Operations application for renewing the operating license of Vermont Yankee. This includes the Aging Review Management Program, in particular flow-accelerated corrosion issues, and finite element fatigue analysis reviews of susceptible components and a number of other contentions related to the safe operation of the.

plant beyond its 40 year license at 120% .oforiginal design power.

Technical Advisor, to the law firm of Leroche, Meyers, and Conswel, LLP.

Provided licensing and regulatory compliance expertise in legal claim and derivative action by the,board of directors of the First Energy Corporation against itscorporate officers in their role associated with the Northeast black out of August 2003, and the mismanagement of the Davis Besse Nuclear Power Plant.

Technical Advisor to the Union of Concerned Scientists Provided technical review of UCS analysis of the Davis Besse.reactor head corrosion event. This included analysis of the loss of integrity of the reactor vessel, and the immediacy of the reactor head failure.

Senior Scientist, Dominion Resources Inc, Millstone Station:

P.O. Box 128, Waterford, Connecticut 06385-0128 (December 1996 - 2002).

Project Manager, Licensing Commitments. Established the Regulatory Commitment Management Program. Developed a program that established senior management and department level control of more than 30,000 licensing commitment that was previously broken. The substantially enhanced program captured,. dispositioned, consolidated, and managed implementation of docketed commitments to the NRC.

Status, responsibility and clear communication were successfully implemented to allow Millstone to successfully restart Units 2 ard 3.

The effort required substantial procedure revisions, customer consensus building, and integration .of

'separate free-standing department specific database applications, as well as the station wide action item tracking system. A near term deliverable necessary for the successful restart of Unit 3 was to provide a workable,. compliant and functioning regulatory commitment management program.

Proiect Manager, 50.54(") Licensing Bases Transition Project. I led a team of 14 individuals to disposition and validate approximately 5100 regulatory commitments necessary for restart of Unit 3. The effort has led to a quality rate of more than 98 percent with production average of about four hours per commitment.

Manager, Configuration Management Program, New York Power Authority:

123 Main Street, White Plains New York 10621, Nuclear Generation Department, Engineering Division /

(November 1991 - November 1996)

Established the Configuration Management Program for the New York Power Authority's nuclear facilities. Included are 10 functional areas and integrated controls as authored in the corporate strategic plan. Management functions and technical skills include the following:

Ulrich K Witte, - Page 3

• Established Configuration Programs Group. This group and my position were established as a result of INPO Plant Evaluation calling for configuration management enhancement, and resolution of design control issues identified by the NRC in their DET Inspection of 1991 of the FitzPatrick Plant, as well as independent assessments. Recruited permanent staff, and supplemented the group with contracted staff on as needed basis to support both plants.

Modified the engineering change process. Areas of immediate attention included the Design Control and Modification Programs, where a series of working groups were established to correct teclhical.

content andimprove quality, ownership, and business efficiency of the design change process. This effort was achieved via: (1) a formal process to assess, model, and enhance the design change and modification process and interfaces to key functions; and (2) immediate changes to engineering procedures.

Assessed and enhanced the Plant Equipment Data Base and controls for each plant. Results of the assessment indicated that the IP3 Plant Equipment Database contained significant problems with component classification, equipment type and status, maintenance history etc. Prepared and implemented a.recovery plan and project team to reestablish the controls and content of database to be compliant with NRC Generic Letter 83-28 and to support the plant restart.,Streamlined and enhanced the component classification process for both plants. Established controlled and non-controlled segregation of plant equipment in accordance with recent EPRI guidance.

Automated and validated existing fragmented and corrupt sources of engineering information. These data sources were compiled, validated, and controlled and included multi-department areas such as set point controls, Electrical Cable and Raceway. Information Systems for JAF and 1P3, along with the fuse controls and data management.

Developed design basis problem resolution process, "Design Document Open Item". Established imethods for prioritizing, tracking and closing out design document issues. Established proper interface andcontrol room notifications as per tech spec requirements. Provided guidance on operability determinations and reportability. Provided oversight for classifying and tracking more than 1100 open design issues for IP3 and 300 for JAF. Defended program to the NRC.

• Established working groups between Nuclear Generation Department and the corporate wide Information Management Organization. Gained management endorsement for areas of data quality improvement and automation for the Nuclear Generation Department. This led to enhanced implementation of the equipment information systems for both. sites.;

Project Manager, Program to Assure Completion and Quality, Tennessee Valley Authority:

(December 1990 -..March 1991) Under contract by CYGNA Energy Services to the Vice-President, Engineering and Operations Department, Watts Bar Nuclear Plant.

• Developed a comprehensive plan to measure progress and confirm quality of the in-progress design evolution of the plant. Developed a methodology for linking specific plant equipment to that equipment's respective design basis (and associated design attributes); license commitments; and numerous verification programs currently in place. The five phase program was presented to NRR in January and received approval as an activity to assist TVA, in removing the stop work order on construction of the facility.

Ulrich K Witte, - Page 4 Technical Manager, Configuration Management Program, Southern Nuclear Operating Company:

(December 19g8 - November 1991). Under contract by ABB Impell and CYGNA Energy Services to Corporat Engineering Manager, Edwin L Hatch Nuclear Plant, Georgia Power Company.

• Established and implemented the Hatch Configuration Management Program. Phase one of the effort included definition, establishment of management objectives, specification of the configuration management program scope and development of a reference manual.

• Developed and executed formal rigorous horizontal evaluations (the second phase of the project) of each relevant functional area including engineering design, implementation, plant operations and maintenance, procurement, information systems, document control and others. The program integrates functional areas across the plant, each architect engineer, and corporate (SONOPCO and Southern Company Services) organizations.

• Implemented enhancements to the program. This phase includes upgrading the design change process to achieve succe'ssfil integration across organizations; stricter adherence to closure activities; and formal.design engineering involvement in such activities as procurement of replacement items (equivalency). Additional controls were established such that misapplication of information obtained through informal design change processes such as the "Request for Engineering Assistance".

• Reconciling the plant's design basis. A second major activity of the program was to compile, consolidate, and ultimately, automate the plant's design basis.. A major objective is to provide access and retrievability of current design basis to each of the key users of each participant organization.

• Applied Structured Business Analysis including CASE tools in the evaluation and enhancement phases. The as-found configuration management activities of all relevant processes were modeled and analyzed with.this technique. Proposed enhancements are then tested on the model prior to actual implementation.

" Chaired the subcommittee for the Nuclear Information and Records Management. Association whichis developing a Technical Position Paper entitled, "Implementation. of a Configuration Management Enhancement Program for a Nuclear Facility".

Team Leader, NRC Safety System Functional Inspection Response Organizations:

Led the NRC Safety System Functional Inspection Response Teams for Georgia Power Company (1989),

and Sacramento Municipal Utility District (1987). Assisted as team coordinator in the GPC - Plant Hatch Electrical Distribution System. Functional Inspection Response Team (1991). Under contract by ABB Impel (December 1987 -. November 1990) to. the site Engineering Manager, Rancho Seco, SMUD. and CYGNA. Energy Services (December 1990 -.

November 1991) to the Corporate Engineering Manager, Edwin I. Hatch Nuclear Plant, Georgia Power Company.

I the case of GPC, the NRC SSFI resulted in validation of the in progress implementation of the In Hatch Configuration Management Program, and only one violation to the licensee.

• The effort included an SSFI self-assessment as well as managing the utility through the NRC inspection.

• For SMUD, developed and executed a plan for closure of both immediate findings and long term correctiveaction required. Assisted in defending the plan to the NRC.

• For GPC - Plant Hatch EDSFI in June .1991. Developed and implemented an EDSFI Preparation Plan for the Engineering. (both A/Es) and site organizations. This effort included management of a 27 man team preparation and inspection response team for the Hatch EDSFI.

Ulrich K Witte, - Page 5 Deputy Mechanical Engineering Manager, Engineering Department Under Contract to the Site Engineering Manager, Rancho Seoo, Sacramento Municipal Utilities District, Rancho Seco (April 1986 - September 1987)

Managed the implementation and closure of over 400 modifications to the plant. Provided the NRC with a basis for allowing a successful restart of the facility. (January 1986 to November 1986). Impell Lead Project Engineer, Class 1 Piping and Support Recertification Effort, SMUD.

• Developed an engineering department action plan to improve technical quality, reconstitute design basis for five systems, control costs of plant modifications, and improve adherence to schedule.

• Responsible for the complete recertification of the Pressurizer Relief Line, Decay He'at System, and others. Responsible for expediting and implementing design changes as necessary through to closure.

Assisted in Utility responses to NUREG-0737, and I&E 79-14.

• Upgraded the Engineering Department procedures to gain credit for the relaxation of ASME code requirements in structural damping values. Initiated the FSAR changes as well.

Project Engineer, Fire Protection:

Under Contract to Sacramento Municipal Utilities District, Rancho Seco ( November 1984 to April 1986), SMUDFire Protection Coordinator, Fire Protection Program

• Developed the SMUD Appendix R Fire Protection Program. Established or substantially revised 110 plant and engineering procedures including shutdown procedures on total loss of the plant's control room, technical specification surveillance procedures, fire protection system maintenance procedures, and the development of a fire protection program manual.

Successfully defended the program to the NRC during the 1985 Appendix R Inspection, with no resulting findings or open items.

Additional Experience (6/78 through 8/84):

Senior Engineer, performed original pipe stress analysis and support placement for Duke Power's Catawba Plant. Qualified approximately 8 classone and two plant systems. (ABB Impell 6/78 - 12/79).

Non-linear finite element analysis of large diameter piping for EPRI. Analysis of production stress codes versus non-linear evaluation techniques, versus actual in situ-testing of the system. Results were published in EPRI Report "Seismic Piping Test and Analysis. (ABB Impell, 1980 -1981)

As Project Engineer, directed the preparation of the annual Emergency Plan exercises for Kansas Gas and Electric Company, Union Electric Company, and Texas Utilities. In two plants, the exercise. was installed on the plants simulator, and received recognition from the NRC for realism of the scenario. (ABB Impell 198241984).

EMPLOYER

SUMMARY

Northern Lights Engineering, L.L.C. 12/2002 -current 71 Edgewood Way Westville, CT 06515

Ulrich K Witte, - Page 6 Northeast Utilities /Dominion Resources Inc 12/1996 - 12/2002

• (Under Contract via Cataract Inc through 9/97.)

2500 McClellan Ave....

Pennsauken, NJ 08109

• New York Power Authority 11/1992- 12/1996 123 Main Street White Plains, New York 10671 Cygna Energy Services 11/1991 - 11/1992 5600 Glenridge Drive, Suite 380 Atlanta, Georgia 30075 ABB Impell Corporation 6/1978- 11/1991 333 Research Court Technology Park-Atlanta Norcross, Georgia 30095 EDUCATION:

University of California, Berkeley.

B.A. Physics, 1983 Senior level and graduate course work in Mechanical Engineering, and Electrical Engineering Quinnipiac University School of Law J.D expected June, 2009 PUBLICATIONS:

EPRI Report Number 108736, "Guidelines for the Optimization of the Engineering Change Process," March 1994.

. NIRMA PP-03, "Position Paper for a Configuration Management Enhancement Program for a Nuclear Facility,"

April, 1992. Subcommittee Chair.

EPRI Report Number 8480, Seismic Piping Test and Analysis," 1980.

PROFESSIONAL AFFILIATIONS AND AWARDS American Society of Mechanical Engineers, American Nuclear Society, Nuclear Information and Records Management Association, Who's Who For Rising Young Americans:

REFERENCES:

References available upon request.

EXHIBIT C Rudolf H. Hausler

SUMMARY

Over 30+ years planned, conducted, and directed advanced chemical research focused on oil production and processing additives. Acquired expertise in corrosion prevention, chemical inhibition, and materials selection, failure analysis, trouble shooting and economic analysis. Proficient in German, French, and Italian.

EXPERIENCE:

1996 - Present CORRO-CONSULTA (Dallas TX, and Kaufman TX)

President private Consulting Company Consulted with major Oil Companies on selection, testing and application of Oil Field Chemicals, primarily corrosion inhibitors.

• Worked on Global Sourcing Team for Mobil Oil Company (major fulltime 6' months study) o Consulted for Mobil Oil Company on production chemical usage at Mobile Bay sour gas production field and prepared for changeover to altemate chemical supplier (two year project).

a Consulted for Arco Oil company

• on sour production in Middle East e reviewed North Slope corrosion data (statistical evaluation) a Consulted for Mobil Oil Company at major CO, flood in Oklahoma (extensive laboratory and field testing - two major publications) a Consulted with Teikoku Oil Company (Japanese National Oil Company) on various subjects of e drill string corrosion e amine unit.corrosion of 304 stainless steel a corrosion of 13%-Cr in sweet production and the chemical inhibition thereof

• identifying qualified corrosion testing laboratories in the US and the world

• application limits for 3% Cr-steels in oil and gas production a Consulted for Exxon Mobil on new sourcing study for combined Mobile Bay operations. (Developed novel approach for bid procedure and evaluation of bids on purely technical basis. Developed l9ng-range approach to streamlining operations with potentially large savings.)

• Consulting for Oxy Permian Ltd. on major gas gathering system (changing from dry gas gathering to wet gas gathering)

• Prepared several major publications (see list of publications)

• Major consulting contract for ExxonMobil in Indonesia e Consulting with various smaller Producers in the US (incl. Anadarko Petroleum Corp and Swift Energy Company)

I RHH

a Consulting with various engineering companies (e.g. Stress Engineering Services Inc.)

o Consultant on call for Blade Energy Partners 0 Consulted with various organization concerned with nuclear safety, including the safety of spent fuel storage casks.

1991 - 1995 MOBIL Oil Company (Dallas Research Center), Dallas, Texas Senior Engineering Advisor Developed corrosion testing facilities for basic research and to meet specific oil field.

requirements.

- Planned and developed H2 S corrosion test facility

- Planned safety and wrote safety manual

- Developed unique continuous flow-through corrosion test facility ($ 1.5MM)

- Developed test protocols and supervised operations of the FTTF

- Extensive consultation with Affiliates on problem solving and chemical usage

- Established supplier relationships and consulted with Affiliates on establishing Enhanced Supplier Relationships

- Developed theory and practice of novel approach to autoclave testing 1979 - 1991 PETROLITE CORPORATION St. Louis, Missouri Research Associate 1986 - 1991 Directed and conducted the development of novel corrosion inhibitors for extreme operating conditions

-New corrosion inhibitor to combat erosion corrosion of carbon steel in gas condensate wells

- Extensive studies on CO 2 corrosion aimed at establishing predictive corrosion model Developed the only qualified corrosion inhibitor for nuclear steam generator cleaning (EPRI publication NP-3030 June 1983)

Special Assistant to Executive Vice President 1985- 1987 Special Assignments focused at support of International Sales o Extensive travel to secure major accounts in Europe, Russia and East Asia SM onitored out-sourced R&D in Germany and England Senior Research Scientist 1979 - 1985 2 RHH

SD eveloped novel chemical composition under contract with EPRI for corrosion inhibition of cleaning fluids used in nuclear steam generators and methodology of application (only effective fonnulation still used today) o Developed unique corrosion model for CO 2 corrosion in oil and gas wells

• Conducted numerous detailed field studies to establish case histories of chemical performance and applications technology 1976 - 1979 Gordon Lab, Inc., Great Bend, Kansas Technical Director Responsible for all technical issues involving formulation, application and sales of sucker well production chemicals (corrosion, emulsion, scale, bacteria)

- Conducted failure analysis for customers and developed pertinent reports

- Supervised service laboratory

- Established technical training of sales and support personnel o Developed technical sales literature and company brochure 1963 - 1976 UOP (a division of SIGNAL COMPANIES) Des Plaines, Illinois Research Associate 1972 - 1976 Associate Research Coordinator 1967 - 1972 Research Chemist 1963- 1967 To conduct research in electrochemistry, analytical methods development, heat exchanger fouling processes and refinery process additives o Developed novel organic electrochemical synthesis procedure o D eveloped unique (patented) test apparatus for measuring anti-foulant activity

- Introduced statistical design and evaluation of experiments to R&D department and Developed 20. hr course on statistics.

- Developed full 3 credit hour corrosion course to be taught at HlT and DeSoto Chemical Company EDUCATION ° Ph.D. Chemical Engineering; Swiss Federal Institute of Technology, Zurich Switzerland

- B S, MS Chemical Process Technology, same as above PROFESSIONAL ASSOCIATION

- American Chemical Society

- The Electrochemical Society

- Society of Petroleum Engineers o NACE International (Corrosion Engineers) o American Society fro Metals (ASM) 3 RHH

Active in NACE on local, regional and national level RECOGNITION N ACE Technical Achievement Award (1990)

• NACE Fellow Award 2003 ACHIEVEMENTS - 17 patents, 58 publications and more than 100 technical presentations o Registered Professional Engineer (Corrosion Branch, California)

• NACE certified Corrosion Specialist 4 4 RIH

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

Entergy Nuclear Vermont Yankee, LLC ) Docket No. 50-271-LR and Entergy Nuclear Operations, Inc. ) ASLBP No. 06-849-03-LR

)

(Vermont Yankee Nuclear Power Station)

CERTIFICATE OF SERVICE I, Christina Nielsen, hereby certify that on March 7, 2008, I sent New England Coalition, Inc. 's (NEC)Final Witness List and attachments by email and by First Class Mail, in a sealed and properly stamped envelope to the attached service list:

Administrative Judge Office of the Secretary Alex S. Karlin, Esq., Chair Attn: Rulemaking and Adjudications Staff Atomic Safety and Licensing Board Mail Stop: O-16C1 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: hearingdocket@nrc.gov E-mail: ask2@nrc.gov Sarah Hofmann, Esq.

Administrative Judge Director of Public Advocacy Thomas S. Elleman Department of Public Service Atomic Safety and Licensing Board Panel 112 State Street, Drawer 20 5207 Creedmoor Road, #101 Montpelier, VT 05620-2601 Raleigh, NC 27612 E-mail: sarah.hofmann@state.vt.us Emmail: ellemangeos.ncsu.edu Lloyd B. Subin, Esq.

Office of Commission Appellate Adjudication Mary C. Baty, Esq.

Mail Stop: O-16C1 Office of the General Counsel U.S. Nuclear Regulatory Commission Mail Stop 0-15 D21 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission E-mail: OCAAmailgnrc.gov Washington, DC 20555-0001 E-mail: lbs3@nrc.gov; mcb1@nrc.gov Administrative Judge Dr. Richard E. Wardwell Atomic Safety and Licensing Board' Panel Anthony Z. Roisman, Esq.

Mail Stop T-3 F23 National Legal Scholars Law Finn U.S. Nuclear Regulatory Commission 84 East Thetford Road Washington, DC 20555-0001 Lyme, NH 03768 E-mail: rewgnrc.gov E-mail: aroisman@nationallegalscholars.com

Marcia Carpentier, Esq. David R. Lewis, Esq.

Atomic Safety and Licensing BoardPanel Matias F. Travieso-Diaz Mail Stop T-3 F23 Pillsbury Winthrop Shaw Pittman LLP U.S. Nuclear Regulatory Commission 2300 N Street NW Washington, DC 20555-0001 Washington, DC 20037-1128 E-mail mxc7@nrc.gov E-mail: david.lewis@pillsburylaw.com matias.travieso-diaz@pillsburylaw.com Peter C. L. Roth, Esq.

Office of the Attorney General 33 Capitol Street Concord, NH 03301 Peter.roth@doj .nh. gov SHEMS DUNKIEL KASSEL & SAUNDERS, PLLC by: (4/L~ A ý Christina Nielsen, for Andrew Raubvogel, Esq. and Karen Tyler, Esq.

91 College Street Burlington, VT 05401 802 860 1003

/802 860 1208 (fax) araubvogelgsdkslaw.com ktylergsdkslaw.com for the firm Attorneys for New England Coalition, Inc.