ML13011A306

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Attachment 2 to Opening Brief for Petitioner - Curriculum Vitae and Affidavit of Arnold Gundersen
ML13011A306
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/09/2013
From: Gundersen A
Fairewinds Associates
To:
Atomic Safety and Licensing Board Panel
SECY RAS
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References
RAS 24007, ASLBP 13-924-01-CAL-BD01, 50-361-CAL, 50-362-CAL
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ATTACHMENT 2 Curriculum Vitae and Affidavit of Arnold Gundersen

CURRICULUM VITAE Arnold Gundersen Chief Engineer, Fairewinds Associates, Inc December 2012 Education and Training ME NE Master of Engineering Nuclear Engineering Rensselaer Polytechnic Institute, 1972 U.S. Atomic Energy Commission Fellowship Thesis: Cooling Tower Plume Rise BS NE Bachelor of Science Nuclear Engineering Rensselaer Polytechnic Institute, Cum Laude, 1971 James J. Kerrigan Scholar RO Licensed Reactor Operator, U.S. Atomic Energy Commission License # OP-3014 Qualifications - including and not limited to:

  • Chief Engineer, Fairewinds Associates, Inc
  • Nuclear Engineering, Safety, and Reliability Expert
  • Federal and Congressional hearing testimony and Expert Witness testimony
  • Former Senior Vice President Nuclear Licensee
  • Former Licensed Reactor Operator
  • Atomic Energy Commission Fellow
  • 40-years of nuclear industry experience and oversight o Nuclear engineering management assessment and prudency assessment o Nuclear power plant licensing and permitting - assessment and review o Nuclear safety assessments, source term reconstructions, dose assessments, criticality analysis, and thermohydraulics o Contract administration, assessment and review o Systems engineering and structural engineering assessments o Cooling tower operation, cooling tower plumes, thermal discharge assessment, and consumptive water use o Nuclear fuel rack design and manufacturing, nuclear equipment design and manufacturing, and technical patents o Radioactive waste processes, storage issue assessment, waste disposal and decommissioning experience o Reliability engineering and aging plant management assessments, in-service inspection o Employee awareness programs, whistleblower protection, and public communications o Quality Assurance (QA) & records Publications Published Lecture -- The Lessons of the Fukushima Daiichi Nuclear Accident published in the International Symposium on the Truth of Fukushima Nuclear Accident and the Myth of Nuclear Safety, August 30, 2012 University of Tokyo, Iwanami Shoten Publishers, Tokyo, Japan Author -- The Echo Chamber: Regulatory Capture and the Fukushima Daiichi Disaster,

Page 2 of 16 Lessons From Fukushima, February 27, 2012, Greenpeace, Co-author -- Fukushima Daiichi: Truth And The Way Forward, Shueisha Publishing, February 17, 2012, Tokyo, Japan.

Co-author -- Fairewinds Associates 2009-2010 Summary to JFC, July 26, 2010 State of Vermont, Joint Fiscal Office, (http://www.leg.state.vt.us/jfo/envy.aspx).

Co-author -- Supplemental Report of the Public Oversight Panel Regarding the Comprehensive Reliability Assessment of the Vermont Yankee Nuclear Power Plant July 20, 2010, to the Vermont State Legislature by the Vermont Yankee Public Oversight Panel.

Co-author The Second Quarterly Report by Fairewinds Associates, Inc to the Joint Legislative Committee regarding buried pipe and tank issues at Entergy Nuclear Vermont Yankee and Entergy proposed Enexus spinoff. See two reports: Fairewinds Associates 2nd Quarterly Report to JFC and Enexus Review by Fairewinds Associates.

Author Fairewinds Associates, Inc First Quarterly Report to the Joint Legislative Committee, October 19, 2009.

Co-author Report of the Public Oversight Panel Regarding the Comprehensive Reliability Assessment of the Vermont Yankee Nuclear Power Plant, March 17, 2009, to the Vermont State Legislature by the Vermont Yankee Public Oversight Panel.

Co-author Vermont Yankee Comprehensive Vertical Audit - VYCVA - Recommended Methodology to Thoroughly Assess Reliability and Safety Issues at Entergy Nuclear Vermont Yankee, January 30, 2008 Testimony to Finance Committee Vermont Senate.

Co-author Decommissioning Vermont Yankee - Stage 2 Analysis of the Vermont Yankee Decommissioning Fund - The Decommissioning Fund Gap, December 2007, Fairewinds Associates, Inc. Presented to Vermont State Senators and Legislators.

Co-author Decommissioning the Vermont Yankee Nuclear Power Plant: An Analysis of Vermont Yankees Decommissioning Fund and Its Projected Decommissioning Costs, November 2007, Fairewinds Associates, Inc.

Co-author DOE Decommissioning Handbook, First Edition, 1981-1982, invited author.

Presentations & Media Fairewinds Energy Education Corp 501c3 presentations:

  • A Mountain of Waste 70 Years High, Presentation: Old and New Reactors, University of Chicago, December 1, 2012
  • Congressional Briefing September 20, 2012; invited by Representative Dennis Kucinich
  • Presentations in Japan August/September 2012: Presentation at University of Tokyo (August 30, 2012), Presentation at Japanese Diet Building (members of the Japanese Legislature - August 31, 2012), Presentation to citizen groups in Niigata (September 1, 2012), Presentations to citizen groups in Kyoto (September 4 , 2012), Presentation to Japanese Bar Association (September 2, 2012), and Presentation at the Tokyo Olympic Center (September 6, 2012)
  • Multi-media Opera: Curtain of Smoke, by Filmmaker Karl Hoffman, Composer Andrea Molino, and Dramatist Guido Barbieri, Rome, Italy (2012-5-21,22)
  • Curtain of Smoke Symposium (2012-5-21), with Dr. Sherri Ebadi 2004 Nobel Laureate
  • The Italian National Press Club Rome (2012-5-21) with Dr. Sherri Ebadi 2004 Nobel Laureate: the relationship between nuclear power and nuclear weapons
  • Radio 3 Rome (2012-5-21) Discussion of Three Mile Island and the triple meltdown at Fukushima Daiichi (Japan),

Page 3 of 16

  • Sierra Club Panel Discussions (2012-5-5): Consequences of Fukushima Daiichi with Paul Gunter and Waste Disposal with Mary Olson,
  • Physicians for Social Responsibility Seattle (2012-3-17),
  • Fukushima Daiichi Forum with Chiho Kaneko, Brattleboro, VT (2012-3-11),
  • Physicians for Global Responsibility Vancouver (2012-3-11) Skype Video Lecture, University of Vermont (2 - 2011),
  • Boston Nuclear Forum, Boston Library (6/16/11),
  • Duxbury Emergency Management (6/15/11),
  • Vermont State Nuclear Advisory Panel (VSNAP), Elder Education Enrichment,
  • Quaker Meeting House,
  • Press Conference for Physicians for Social Responsibility (5/19/11),
  • St. Johnsbury Academy - Nuclear Power 101.

Educational videos on nuclear safety, reliability and engineering particularly Fukushima issues.

Videos may be viewed @ fairewinds.org (501c3 non-profit)

Expert commentary (many more unnamed): CNN (6), The John King Show (14), BBC, CBC, Russia Today, Democracy Now, KPBS (Radio & TV) VPR, WPTZ, WCAX, WBAI, CCTV, NECN, Pacifica Radio, CBC (radio & TV) (4), Rachel Maddow Show, Washington Post, New York Times, The Guardian, Bloomberg (print & TV), Reuters, Associated Press, The Global Post, Miami Herald, Tampa Times, Orange County Times, LA Times, Al Jazeera (print), The Tennessean, The Chris Martinson Show, Mainichi News, TBS Japan, Gendai Magazine, NHK television, Scientific American. Huffington Post (Paris) named Fairewinds.com the best go to site for information about the Fukushima Daiichi accident (5/9/11).

Patents Energy Absorbing Turbine Missile Shield - U.S. Patent # 4,397,608 - 8/9/1983 Committee Memberships Vermont Yankee Public Oversight Panel, appointed 2008 by President Pro-Tem Vermont Senate National Nuclear Safety Network - Founding Board Member Three Rivers Community College - Nuclear Academic Advisory Board Connecticut Low Level Radioactive Waste Advisory Committee - 10 years, founding member Radiation Safety Committee, NRC Licensee - founding member ANSI N-198, Solid Radioactive Waste Processing Systems Honors U.S. Atomic Energy Commission Fellowship, 1972 B.S. Degree, Cum Laude, RPI, 1971, 1st in nuclear engineering class Tau Beta Pi (Engineering Honor Society), RPI, 1969 - 1 of 5 in sophomore class of 700 James J. Kerrigan Scholar 1967-1971 Teacher of the Year - 2000, Marvelwood School Publicly commended to U.S. Senate by NRC Chairman, Ivan Selin, in May 1993 - It is true...everything Mr. Gundersen said was absolutely right; he performed quite a service.

Page 4 of 16 Expert Witness Testimony and Nuclear Engineering Analysis and Consulting Expert Witness Report For Friends Of The Earth - July 11, 2012 San Onofres Steam Generators: Significantly Worse Thank All Others Nationwide Expert Witness Report For Friends Of The Earth - May 15, 2012 San Onofres Steam Generator Failures Could Have Been Prevented, Fairewinds Associates Expert Witness Report For Friends Of The Earth - April 10, 2012 San Onofre Cascading Steam Generator Failures Created By Edison: Imprudent Design And Fabrication Decisions Caused Leaks, Fairewinds Associates Expert Witness Report For Friends Of The Earth - March 27, 2012 Steam Generator Failures At San Onofre: The Need For A Thorough Root Cause Analysis Requires No Early Restart Expert Witness Report For Greenpeace - February 27, 2012 Lessons From Fukushima: The Echo Chamber Effect, Fairewinds Associates Nuclear Regulatory Commission - December 21, 2011 Expert witness report to Atomic Safety and Licensing Board: Prefiled Direct Testimony of Arnold Gundersen Regarding Consolidated Contention RK-EC-3/CW-EC-1 (Spent Fuel Pool Leaks)

New York State Department Of Environmental Conservation - November 15-16, 2011 Expert witness for Riverkeeper: hearing testimony regarding license extension application for Indian Point Units 2 and 3 - contention: tritium in the groundwater.

Nuclear Regulatory Commission - November 10, 2011 Expert witness report entitled: Fukushima and the Westinghouse-Toshiba AP1000, A Report for the AP1000 Oversight Group by Fairewinds Associates, Inc, and Video. Submitted to NRC by the AP1000 Oversight Group.

Nuclear Regulatory Commission - October 7, 2011 Testimony to the NRC Petition Review Board Re: Mark 1 Boiling Water Reactors, Petition for NRC to shut down all BWR Mark 1 nuclear power plants due to problems in containment integrity in the Mark 1 design.

New York State Department Of Environmental Conservation, October 4, 2011 Prefiled Rebuttal Testimony Of Arnold Gundersen On Behalf Of Petitioners Riverkeeper, Inc.,

Scenic Hudson, Inc., And Natural Resources Defense Council, Inc. To The Direct Testimony Of Matthew J. Barvenik (Senior Principal GZA Geoenvironmental, Inc.) Regarding Radiological Materials

Page 5 of 16 Southern Alliance for Clean Energy (SACE) submission to TVA Board of Directors - August 3, 2011- Expert witness report entitled: The Risks of Reviving TVAs Bellefonte Project, and Video prepared for the Southern Alliance for Clean Energy (SACE).

New York State Department Of Environmental Conservation, July 22, 2011 Prefiled Direct Testimony Of Arnold Gundersen On Behalf Of Petitioners Riverkeeper, Inc.,

Scenic Hudson, Inc., And Natural Resources Defense Council, Inc. Regarding Radiological Materials Nuclear Regulatory Commission - May 10, 2011 Comment to the proposed rule on the AP1000 Design Certification Amendment Docket ID NRC-2010-0131 As noticed in the Federal Register on February 24, 2011 Retained by Friends of the Earth as Expert Witness.

Nuclear Regulatory Commission - May 10, 2011 Comment to the proposed rule on the AP1000 Design Certification Amendment Docket ID NRC-2010-0131 As noticed in the Federal Register on February 24, 2011 Retained by Friends of the Earth as Expert Witness.

NRC Advisory Committee on Reactor Safeguards (ACRS) - May 26, 2011 Lessons learned from Fukushima and Containment Integrity on the AP1000.

Vermont Energy Cooperative (VEC) - April 26, 2011 Vermont Yankee - Is It Reliable for 20 more years?

Vermont State Nuclear Advisory Panel (VSNAP) - February 22, 2011 Testimony and presentation entitled the Vermont Yankee Public Oversight Panel Supplemental Report regarding management issues at the Vermont Yankee Nuclear Power Plant to the reconvened Vermont State Nuclear Advisory Panel.

Vermont State Legislature Senate Committee On Natural Resources And Energy February 8, 2011. Testimony: Vermont Yankee Leaks and Implications.

(http://www.leg.state.vt.us/jfo/envy.aspx)

Vermont State Legislature - January 26, 2011 House Committee On Natural Resources And Energy, and Senate Committee On Natural Resources And Energy Testimony regarding Fairewinds Associates, Incs report: Decommissioning the Vermont Yankee Nuclear Power Plant and Storing Its Radioactive Waste (http://www.leg.state.vt.us/jfo/envy.aspx). Additional testimony was also given regarding the newest radioactive isotopic leak at the Vermont Yankee nuclear power plant.

Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee Decommissioning the Vermont Yankee Nuclear Power Plant and Storing Its Radioactive Waste January 2011. (http://www.leg.state.vt.us/jfo/envy.aspx).

Page 6 of 16 U.S. Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards (NRC-ACRS) AP1000 Sub-Committee Nuclear Containment Failures: Ramifications for the AP1000 Containment Design, Supplemental Report submitted December 21, 2010. (http://fairewinds.com/reports)

Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee Reliability Oversight Entergy Nuclear Vermont Yankee, December 6, 2010. Discussion regarding the leaks at Vermont Yankee and the ongoing monitoring of those leaks and ENVYs progress addressing the 90-items identified in Act 189 that require remediation. (http://www.leg.state.vt.us/jfo/envy.aspx).

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB)

Declaration Of Arnold Gundersen Supporting Blue Ridge Environmental Defense Leagues Contention Regarding Consumptive Water Use At Dominion Powers Newly Proposed North Anna Unit 3 Pressurized Water Reactor in the matter of Dominion Virginia Power North Anna Power Station Unit 3 Docket No.52-017 Combined License Application ASLBP#08-863 COL, October 2, 2010.

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB)

Declaration Of Arnold Gundersen Supporting Blue Ridge Environmental Defense Leagues New Contention Regarding AP1000 Containment Integrity On The Vogtle Nuclear Power Plant Units 3 And 4 in the matter of the Southern Nuclear Operating Company Vogtle Electric Generating Plant, Units 3&4 Combined License Application, Docket Nos. 52-025-COL and 52-026-COL and ASLB No. 09-873-01-COL-BD01, August 13, 2010.

Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee - July 26, 2010 Summation for 2009 to 2010 Legislative Year For the Joint Fiscal Committee Reliability Oversight Entergy Nuclear Vermont Yankee (ENVY) Fairewinds Associates 2009-2010. This summary includes an assessment of ENVYs progress (as of July 1, 2010) toward meeting the milestones outlined by the Act 189 Vermont Yankee Public Oversight Panel in its March 2009 report to the Legislature, the new milestones that have been added since the incident with the tritium leak and buried underground pipes, and the new reliability challenges facing ENVY, Entergy, and the State of Vermont. (http://www.leg.state.vt.us/jfo/envy.aspx)

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB)

Declaration Of Arnold Gundersen Supporting Blue Ridge Environmental Defense Leagues Contentions in the matter of Dominion Virginia Power North Anna Station Unit 3 Combined License Application, Docket No.52-017, ASLBP#08-863-01-COL, July 23, 2010.

Florida Public Service Commission (FPSC)

Licensing and construction delays due to problems with the newly designed Westinghouse AP1000 reactors in Direct Testimony In Re: Nuclear Plant Cost Recovery Clause By The Southern Alliance For Clean Energy (SACE), FPSC Docket No. 100009-EI, July 8, 2010.

U.S. Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards (NRC-

Page 7 of 16 ACRS) AP1000 Sub-Committee Presentation to ACRS regarding design flaw in AP1000 Containment - June 25, 2010 Power Point Presentation: http://fairewinds.com/content/ap1000-nuclear-design-flaw-addressed-to-nrc-acrs.

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB)

Second Declaration Of Arnold Gundersen Supporting Supplemental Petition Of Intervenors Contention 15: DTE COLA Lacks Statutorily Required Cohesive QA Program - June 8, 2010.

NRC Chairman Gregory Jaczko, ACRS, Secretary of Energy Chu, and the White House Office of Management and Budget AP1000 Containment Leakage Report Fairewinds Associates - Gundersen, Hausler, 4-21-2010.

This report, commissioned by the AP1000 Oversight Group, analyzes a potential flaw in the containment of the AP1000 reactor design.

Vermont State Legislature House Committee On Natural Resources And Energy - April 5, 2010 Testified to the House Committee On Natural Resources And Energy - regarding discrepancies in Entergys TLG Services decommissioning analysis. See Fairewinds Cost Comparison TLG Decommissioning (http://www.leg.state.vt.us/jfo/envy.aspx).

Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee - February 22, 2010 The Second Quarterly Report by Fairewinds Associates, Inc to the Joint Legislative Committee regarding buried pipe and tank issues at Entergy Nuclear Vermont Yankee and Entergy proposed Enexus spinoff. See two reports: Fairewinds Associates 2nd Quarterly Report to JFC and Enexus Review by Fairewinds Associates. (http://www.leg.state.vt.us/jfo/envy.aspx).

Vermont State Legislature Senate Natural Resources - February 16, 2010 Testified to Senate Natural Resources Committee regarding causes and severity of tritium leak in unreported buried underground pipes, status of Enexus spinoff proposal, and health effects of tritium.

Vermont State Legislature Senate Natural Resources - February 10, 2010 Testified to Senate Natural Resources Committee regarding causes and severity of tritium leak in unreported buried underground pipes. http://www.youtube.com/watch?v=36HJiBrJSxE Vermont State Legislature Senate Finance - February 10, 2010 Testified to Senate Finance Committee regarding A Chronicle of Issues Regarding Buried Tanks and Underground Piping at VT Yankee. (http://www.leg.state.vt.us/jfo/envy.aspx).

Vermont State Legislature House Committee On Natural Resources And Energy - January 27, 2010 A Chronicle of Issues Regarding Buried Tanks and Underground Piping at VT Yankee.

(http://www.leg.state.vt.us/jfo/envy.aspx).

Submittal to Susquehanna River Basin Commission, by Eric Epstein - January 5, 2010 Expert Witness Report Of Arnold Gundersen Regarding Consumptive Water Use Of The

Page 8 of 16 Susquehanna River By The Proposed PPL Bell Bend Nuclear Power Plant In the Matter of RE:

Bell Bend Nuclear Power Plant Application for Groundwater Withdrawal Application for Consumptive Use BNP-2009-073.

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB)

Declaration of Arnold Gundersen Supporting Supplemental Petition of Intervenors Contention 15: Detroit Edison COLA Lacks Statutorily Required Cohesive QA Program, December 8, 2009.

U.S. NRC Region III Allegation Filed by Missouri Coalition for the Environment Expert Witness Report entitled: Comments on the Callaway Special Inspection by NRC Regarding the May 25, 2009 Failure of its Auxiliary Feedwater System, November 9, 2009.

Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee Oral testimony given to the Vermont State Legislature Joint Fiscal Committee October 28, 2009.

See report: Quarterly Status Report - ENVY Reliability Oversight for JFO (http://www.leg.state.vt.us/jfo/envy.aspx).

Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee The First Quarterly Report by Fairewinds Associates, Inc to the Joint Legislative Committee regarding reliability issues at Entergy Nuclear Vermont Yankee, issued October 19, 2009.

See report: Quarterly Status Report - ENVY Reliability Oversight for JFO (http://www.leg.state.vt.us/jfo/envy.aspx).

Florida Public Service Commission (FPSC)

Gave direct oral testimony to the FPSC in hearings in Tallahassee, FL, September 8 and 10, 2009 in support of Southern Alliance for Clean Energy (SACE) contention of anticipated licensing and construction delays in newly designed Westinghouse AP 1000 reactors proposed by Progress Energy Florida and Florida Power and Light (FPL).

Florida Public Service Commission (FPSC)

NRC announced delays confirming my original testimony to FPSC detailed below. My supplemental testimony alerted FPSC to NRC confirmation of my original testimony regarding licensing and construction delays due to problems with the newly designed Westinghouse AP 1000 reactors in Supplemental Testimony In Re: Nuclear Plant Cost Recovery Clause By The Southern Alliance For Clean Energy, FPSC Docket No. 090009-EI, August 12, 2009.

Florida Public Service Commission (FPSC)

Licensing and construction delays due to problems with the newly designed Westinghouse AP 1000 reactors in Direct Testimony In Re: Nuclear Plant Cost Recovery Clause By The Southern Alliance For Clean Energy (SACE), FPSC Docket No. 090009-EI, July 15, 2009.

Vermont State Legislature Joint Fiscal Committee Expert Witness Oversight Role for Entergy Nuclear Vermont Yankee (ENVY)

Contracted by the Joint Fiscal Committee of the Vermont State Legislature as an expert witness

Page 9 of 16 to oversee the compliance of ENVY to reliability issues uncovered during the 2009 legislative session by the Vermont Yankee Public Oversight Panel of which I was appointed a member along with former NRC Commissioner Peter Bradford for one year from July 2008 to 2009.

Entergy Nuclear Vermont Yankee (ENVY) is currently under review by Vermont State Legislature to determine if it should receive a Certificate for Public Good (CPG) to extend its operational license for another 20-years. Vermont is the only state in the country that has legislatively created the CPG authorization for a nuclear power plant. Act 160 was passed to ascertain ENVYs ability to run reliably for an additional 20 years. Appointment from July 2009 to May 2010.

U.S. Nuclear Regulatory Commission Expert Witness Declaration regarding Combined Operating License Application (COLA) at North Anna Unit 3 Declaration of Arnold Gundersen Supporting Blue Ridge Environmental Defense Leagues Contentions (June 26, 2009).

U.S. Nuclear Regulatory Commission Expert Witness Declaration regarding Through-wall Penetration of Containment Liner and Inspection Techniques of the Containment Liner at Beaver Valley Unit 1 Nuclear Power Plant Declaration of Arnold Gundersen Supporting Citizen Powers Petition (May 25, 2009).

U.S. Nuclear Regulatory Commission Expert Witness Declaration regarding Quality Assurance and Configuration Management at Bellefonte Nuclear Plant Declaration of Arnold Gundersen Supporting Blue Ridge Environmental Defense Leagues Contentions in their Petition for Intervention and Request for Hearing, May 6, 2009.

Pennsylvania Statehouse Expert Witness Analysis presented in formal presentation at the Pennsylvania Statehouse, March 26, 2009 regarding actual releases from Three Mile Island Nuclear Accident. Presentation may be found at: http://www.tmia.com/march26 Vermont Legislative Testimony and Formal Report for 2009 Legislative Session As a member of the Vermont Yankee Public Oversight Panel, I spent almost eight months examining the Vermont Yankee Nuclear Power Plant and the legislatively ordered Comprehensive Vertical Audit. Panel submitted Act 189 Public Oversight Panel Report March 17, 2009 and oral testimony to a joint hearing of the Senate Finance and House Committee On Natural Resources And Energy March 19, 2009.

http://www.leg.state.vt.us/JFO/Vermont%20Yankee.htm Finestone v FPL (11/2003 to 12/2008) Federal Court Plaintiffs Expert Witness for Federal Court Case with Attorney Nancy LaVista, from the firm Lytal, Reiter, Fountain, Clark, Williams, West Palm Beach, FL. This case involved two plaintiffs in cancer cluster of 40 families alleging that illegal radiation releases from nearby nuclear power plant caused childrens cancers. Production request, discovery review, preparation of deposition questions and attendance at Defendants experts for deposition, preparation of expert witness testimony, preparation for Daubert Hearings, ongoing technical

Page 10 of 16 oversight, source term reconstruction and appeal to Circuit Court.

U.S. Nuclear Regulatory Commission Advisory Committee Reactor Safeguards (NRC-ACRS)

Expert Witness providing oral testimony regarding Millstone Point Unit 3 (MP3) Containment issues in hearings regarding the Application to Uprate Power at MP3 by Dominion Nuclear, Washington, and DC. (July 8-9, 2008).

Appointed by President Pro-Tem of Vermont Senate Shumlin (now Vermont Governor Shumlin) to Legislatively Authorized Nuclear Reliability Public Oversight Panel To oversee Comprehensive Vertical Audit of Entergy Nuclear Vermont Yankee (Act 189) and testify to State Legislature during 2009 session regarding operational reliability of ENVY in relation to its 20-year license extension application. (July 2, 2008 to present).

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB)

Expert Witness providing testimony regarding Pilgrim Watchs Petition for Contention 1 Underground Pipes (April 10, 2008).

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB)

Expert Witness supporting Connecticut Coalition Against Millstone In Its Petition For Leave To Intervene, Request For Hearing, And Contentions Against Dominion Nuclear Connecticut Inc.s Millstone Power Station Unit 3 License Amendment Request For Stretch Power Uprate (March 15, 2008).

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB)

Expert Witness supporting Pilgrim Watchs Petition For Contention 1: specific to issues regarding the integrity of Pilgrim Nuclear Power Stations underground pipes and the ability of Pilgrims Aging Management Program to determine their integrity. (January 26, 2008).

Vermont State House - 2008 Legislative Session House Committee on Natural Resources and Energy - Comprehensive Vertical Audit: Why NRC Recommends a Vertical Audit for Aging Plants Like Entergy Nuclear Vermont Yankee (ENVY)

House Committee on Commerce - Decommissioning Testimony Vermont State Senate - 2008 Legislative Session Senate Finance - testimony regarding Entergy Nuclear Vermont Yankee Decommissioning Fund Senate Finance - testimony on the necessity for a Comprehensive Vertical Audit (CVA) of Entergy Nuclear Vermont Yankee House Committee on Natural Resources and Energy - testimony regarding the placement of high-level nuclear fuel on the banks of the Connecticut River in Vernon, VT U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB)

MOX Limited Appearance Statement to Judges Michael C. Farrar (Chairman), Lawrence G.

McDade, and Nicholas G. Trikouros for the Petitioners: Nuclear Watch South, the Blue Ridge Environmental Defense League, and Nuclear Information & Resource Service in support of

Page 11 of 16 Contention 2: Accidental Release of Radionuclides, requesting a hearing concerning faulty accident consequence assessments made for the MOX plutonium fuel factory proposed for the Savannah River Site. (September 14, 2007).

Appeal to the Vermont Supreme Court (March 2006 to 2007)

Expert Witness Testimony in support of New England Coalitions Appeal to the Vermont Supreme Court Concerning: Degraded Reliability at Entergy Nuclear Vermont Yankee as a Result of the Power Uprate. New England Coalition represented by Attorney Ron Shems of Burlington, VT.

State of Vermont Environmental Court (Docket 89-4-06-vtec 2007)

Expert witness retained by New England Coalition to review Entergy and Vermont Yankees analysis of alternative methods to reduce the heat discharged by Vermont Yankee into the Connecticut River. Provided Vermont's Environmental Court with analysis of alternative methods systematically applied throughout the nuclear industry to reduce the heat discharged by nuclear power plants into nearby bodies of water and avoid consumptive water use. This report included a review of the condenser and cooling tower modifications.

U.S. Senator Bernie Sanders and Congressman Peter Welch (2007)

Briefed Senator Sanders, Congressman Welch and their staff members regarding technical and engineering issues, reliability and aging management concerns, regulatory compliance, waste storage, and nuclear power reactor safety issues confronting the U.S. nuclear energy industry.

State of Vermont Legislative Testimony to Senate Finance Committee (2006)

Testimony to the Senate Finance Committee regarding Vermont Yankee decommissioning costs, reliability issues, design life of the plant, and emergency planning issues.

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB)

Expert witness retained by New England Coalition to provide Atomic Safety and Licensing Board with an independent analysis of the integrity of the Vermont Yankee Nuclear Power Plant condenser (2006).

U.S. Senators Jeffords and Leahy (2003 to 2005)

Provided the Senators and their staffs with periodic overview regarding technical, reliability, compliance, and safety issues at Entergy Nuclear Vermont Yankee (ENVY).

10CFR 2.206 filed with the Nuclear Regulatory Commission (July 2004)

Filed 10CFR 2.206 petition with NRC requesting confirmation of Vermont Yankee's compliance with General Design Criteria.

State of Vermont Public Service Board (April 2003 to May 2004)

Expert witness retained by New England Coalition to testify to the Public Service Board on the reliability, safety, technical, and financial ramifications of a proposed increase in power (called an uprate) to 120% at Entergys 31-year-old Vermont Yankee Nuclear Power Plant.

Page 12 of 16 International Nuclear Safety Testimony Worked for ten days with the President of the Czech Republic (Vaclav Havel) and the Czech Parliament on their energy policy for the 21st century.

Nuclear Regulatory Commission (NRC) Inspector General (IG)

Assisted the NRC Inspector General in investigating illegal gratuities paid to NRC Officials by Nuclear Energy Services (NES) Corporate Officers. In a second investigation, assisted the Inspector General in showing that material false statements (lies) by NES corporate president caused the NRC to overlook important violations by this licensee.

State of Connecticut Legislature Assisted in the creation of State of Connecticut Whistleblower Protection legal statutes.

Federal Congressional Testimony Publicly recognized by NRC Chairman, Ivan Selin, in May 1993 in his comments to U.S. Senate, It is true...everything Mr. Gundersen said was absolutely right; he performed quite a service.

Commended by U.S. Senator John Glenn for public testimony to Senator Glenns NRC Oversight Committee.

PennCentral Litigation Evaluated NRC license violations and material false statements made by management of this nuclear engineering and materials licensee.

Three Mile Island Litigation Evaluated unmonitored releases to the environment after accident, including containment breach, letdown system and blowout. Proved releases were 15 times higher than government estimate and subsequent government report.

Western Atlas Litigation Evaluated neutron exposure to employees and license violations at this nuclear materials licensee.

Commonwealth Edison In depth review and analysis for Commonwealth Edison to analyze the efficiency and effectiveness of all Commonwealth Edison engineering organizations, which support the operation of all of its nuclear power plants.

Peach Bottom Reactor Litigation Evaluated extended 28-month outage caused by management breakdown and deteriorating condition of plant.

Special Remediation Expertise:

Director of Engineering, Vice President of Site Engineering, and the Senior Vice President of Engineering at Nuclear Energy Services (NES) Division of Penn Central Corporation (PCC)

Page 13 of 16 NES was a nuclear licensee that specialized in dismantlement and remediation of nuclear facilities and nuclear sites. Member of the radiation safety committee for this licensee.

Department of Energy chose NES to write DOE Decommissioning Handbook because NES had a unique breadth and depth of nuclear engineers and nuclear physicists on staff.

Personally wrote the Small Bore Piping chapter of the DOEs first edition Decommissioning Handbook, personnel on my staff authored other sections, and I reviewed the entire Decommissioning Handbook.

Served on the Connecticut Low Level Radioactive Waste Advisory Committee for 10 years from its inception.

Managed groups performing analyses on dozens of dismantlement sites to thoroughly remove radioactive material from nuclear plants and their surrounding environment.

Managed groups assisting in decommissioning the Shippingport nuclear power reactor.

Shippingport was the first large nuclear power plant ever decommissioned. The decommissioning of Shippingport included remediation of the site after decommissioning.

Managed groups conducting site characterizations (preliminary radiation surveys prior to commencement of removal of radiation) at the radioactively contaminated West Valley site in upstate New York.

Personnel reporting to me assessed dismantlement of the Princeton Avenue Plutonium Lab in New Brunswick, NJ. The labs dismantlement assessment was stopped when we uncovered extremely toxic and carcinogenic underground radioactive contamination.

Personnel reporting to me worked on decontaminating radioactive thorium at the Cleveland Avenue nuclear licensee in Ohio. The thorium had been used as an alloy in turbine blades.

During that project, previously undetected extremely toxic and carcinogenic radioactive contamination was discovered below ground after an aboveground gamma survey had purported that no residual radiation remained on site.

Additional Education Basic Mediation Certificate Champlain College, Woodbury Institute 28-hour Basic Mediation Training September 2010 Teaching and Academic Administration Experience Rensselaer Polytechnic Institute (RPI) - Advanced Nuclear Reactor Physics Lab Community College of Vermont - Mathematics Professor - 2007 to present Burlington High School Mathematics Teacher - 2001 to June 2008 Physics Teacher - 2004 to 2006 The Marvelwood School - 1996 to 2000 Awarded Teacher of the Year - June 2000 Chairperson: Physics and Math Department Mathematics and Physics Teacher, Faculty Council Member Director of Marvelwood Residential Summer School Director of Residential Life The Forman School & St. Margarets School - 1993 to 1995 Physics and Mathematics Teacher, Tennis Coach, Residential Living Faculty Member

Page 14 of 16 Nuclear Engineering Work Experience 1970 to Present Expert witness testimony in nuclear litigation and administrative hearings in federal, international, and state court and to Nuclear Regulatory Commission, including but not limited to: Three Mile Island, US Federal Court, US NRC, NRC ASLB & ACRS, Vermont State Legislature, Vermont State Public Service Board, Florida Public Service Board, Czech Senate, Connecticut State Legislature, Western Atlas Nuclear Litigation, U.S. Senate Nuclear Safety Hearings, Peach Bottom Nuclear Power Plant Litigation, and Office of the Inspector General NRC.

Nuclear Engineering, Safety, and Reliability Expert Witness 1990 to Present Fairewinds Associates, Inc - Chief Engineer, 2005 to Present Arnold Gundersen, Nuclear Safety Consultant and Energy Advisor, 1995 to 2005 GMA - 1990 to 1995, including expert witness testimony regarding the accident at Three Mile Island.

Nuclear Energy Services, Division of PCC (Fortune 500 company) 1979 to 1990 Corporate Officer and Senior Vice President - Technical Services Responsible for overall performance of the company's Inservice Inspection (ASME XI),

Quality Assurance (SNTC 1A), and Staff Augmentation Business Units - up to 300 employees at various nuclear sites.

Senior Vice President of Engineering Responsible for the overall performance of the company's Site Engineering, Boston Design Engineering and Engineered Products Business Units. Integrated the Danbury based, Boston based and site engineering functions to provide products such as fuel racks, nozzle dams, and transfer mechanisms and services such as materials management and procedure development.

Vice President of Engineering Services Responsible for the overall performance of the company's field engineering, operations engineering, and engineered products services. Integrated the Danbury-based and field-based engineering functions to provide numerous products and services required by nuclear utilities, including patents for engineered products.

General Manager of Field Engineering Managed and directed NES' multi-disciplined field engineering staff on location at various nuclear plant sites. Site activities included structural analysis, procedure development, technical specifications and training. Have personally applied for and received one patent.

Director of General Engineering Managed and directed the Danbury based engineering staff. Staff disciplines included structural, nuclear, mechanical and systems engineering. Responsible for assignment of personnel as well as scheduling, cost performance, and technical assessment by staff on assigned projects. This staff provided major engineering support to the company's nuclear waste management, spent fuel storage racks, and engineering consulting programs.

Page 15 of 16 New York State Electric and Gas Corporation (NYSE&G) 1976 to 1979 Reliability Engineering Supervisor Organized and supervised reliability engineers to upgrade performance levels on seven operating coal units and one that was under construction. Applied analytical techniques and good engineering judgments to improve capacity factors by reducing mean time to repair and by increasing mean time between failures.

Lead Power Systems Engineer Supervised the preparation of proposals, bid evaluation, negotiation and administration of contracts for two 1300 MW NSSS Units including nuclear fuel, and solid-state control rooms. Represented corporation at numerous public forums including TV and radio on sensitive utility issues. Responsible for all nuclear and BOP portions of a PSAR, Environmental Report, and Early Site Review.

Northeast Utilities Service Corporation (NU) 1972 to 1976 Engineer Nuclear Engineer assigned to Millstone Unit 2 during start-up phase. Lead the high velocity flush and chemical cleaning of condensate and feedwater systems and obtained discharge permit for chemicals. Developed Quality Assurance Category 1 Material, Equipment and Parts List. Modified fuel pool cooling system at Connecticut Yankee, steam generator blowdown system and diesel generator lube oil system for Millstone. Evaluated Technical Specification Change Requests.

Associate Engineer Nuclear Engineer assigned to Montague Units 1 & 2. Interface Engineer with NSSS vendor, performed containment leak rate analysis, assisted in preparation of PSAR and performed radiological health analysis of plant. Performed environmental radiation survey of Connecticut Yankee. Performed chloride intrusion transient analysis for Millstone Unit 1 feedwater system. Prepared Millstone Unit 1 off-gas modification licensing document and Environmental Report Amendments 1 & 2.

Rensselaer Polytechnic Institute (RPI) 1971 to 1972 Critical Facility Reactor Operator, Instructor Licensed AEC Reactor Operator instructing students and utility reactor operator trainees in start-up through full power operation of a reactor.

Public Service Electric and Gas (PSE&G) 1970 Assistant Engineer Performed shielding design of radwaste and auxiliary buildings for Newbold Island Units 1

& 2, including development of computer codes.

Page 16 of 16 Media Featured Nuclear Safety and Reliability Expert (1990 to present) for Television, Newspaper, Radio, & Internet - Including, and not limited to:

CNN: JohnKingUSA, CNN News, Earth Matters; DemocracyNow, NECN, WPTZ VT, WTNH, VPTV, WCAX, RT, CTV (Canada), CCTV Burlington, VT, ABC, TBS/Japan, Bloomberg: EnergyNow, KPBS, Japan National Press Club (Tokyo), Italy National Press Club (Rome), The Crusaders, Front Page, Five OClock Shadow: Robert Knight, Mark Johnson Show, Steve West Show, Anthony Polina Show, WKVT, WDEV, WVPR, WZBG CT, Seven Days, AP News Service, Houston Chronicle, Christian Science Monitor, Reuters, The Global Post, International Herald, The Guardian, New York Times, Washington Post, LA Times, Miami Herald, St. Petersburg Times, Brattleboro Reformer, Rutland Herald, Times-Argus, Burlington Free Press, Litchfield County Times, The News Times, The New Milford Times, Hartford Current, New London Day, Vermont Daily Briefing, Green Mountain Daily, EcoReview, Huffington Post, DailyKos, Voice of Orange County, AlterNet, Common Dreams, and numerous other national and international blogs Public Service, Cultural, and Community Activities 2009 to Present -Fairewinds Energy Education Corp 501(C)3 non-profit board member 2005 to Present - Public presentations and panel discussions on nuclear safety and reliability at University of Vermont, Vermont Law School, NRC hearings, Town and City Select Boards, Legal Panels, Local Schools, Television, and Radio.

2007-2008 - Created Concept of Solar Panels on Burlington High School; worked with Burlington Electric Department and Burlington Board of Education Technology Committee on Grant for installation of solar collectors for Burlington Electric peak summer use Vermont State Legislature - Public Testimony to Legislative Committees Certified Foster Parent State of Vermont - 2004 to 2007 Mentoring former students - 2000 to present - college application and employment application questions and encouragement Tutoring Refugee Students - 2002 to 2006 - Lost Boys of the Sudan and others from educationally disadvantaged immigrant groups Designed and Taught Special High School Math Course for ESOL Students - 2007 to 2008 NNSN - National Nuclear Safety Network, Founding Advisory Board Member, meetings with and testimony to the Nuclear Regulatory Commission Inspector General (NRC IG)

Berkshire School Parents Association, Co-Founder Berkshire School Annual Appeal, Co-Chair Sunday School Teacher, Christ Church, Roxbury, CT Washington Montessori School Parents Association Member Marriage Encounter National Presenting Team with wife Margaret Provided weekend communication and dialogue workshops weekend retreats/seminars Connecticut Marriage Encounter Administrative Team - 5 years Northeast Utilities Representative Conducting Public Lectures on Nuclear Safety Issues Personal Married to Maggie Gundersen 1979. Two children: Eric, 32, president and founder of MapBox and Development Seed, and Elida, 29, paramedic in Florida. Enjoy sailing, walking, cross-country skiing, yoga, and reading. ---- End

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-361-CAL & 50-362-CAL SOUTHERN CALIFORNIA EDISON COMPANY )

) ASLBP No. 13-924-01-CAL-BD01 (San Onofre Nuclear Generating Station, )

Units 2 and 3) ) January 9, 2013

)

GUNDERSEN AFFIDAVIT I, __Arnold Gundersen__, being duly sworn, state:

(Print Name)

1. My name is Arnold Gundersen and I reside at 125 Northshore Drive, Burlington, Vermont.
2. My CV is attached. I have both Bachelors and Masters degree in nuclear engineering. I was an Atomic Energy Commission Fellow, a Licensed Reactor Operator, and I hold one nuclear plant patent.
3. My pertinent experience related to the Steam Generator matters being considered by this ASLB Proceedings include but are not limited to:

3.1. As the Senior Vice President of Inspection Services, I was responsible for a group of approximately 200 personnel performing ASME III and ASME XI non-destructive piping inspections at nuclear plants throughout the United States. These personnel used inspection techniques identical to those used on the San Onofre tube inspections.

3.2. As the Senior Vice President of Engineering Services, I was responsible for the development of the first ever modern steam generator nozzle dams that were sold to approximately 40 nuclear reactors in the US and Asia. Dams of a similar design are in use in San Onofres Replacement Steam Generators (RSG).

4. Friends of the Earth (FoE) has retained me to provide my expert opinion on several Factual Issues that this Atomic Safety Licensing Board directed FoE to consider.

Page 2 of 14 Issue #1: Does the Final Safety Analysis Report (FSAR) analyze a steam generator (S/G) tube failure event?

5. Yes, the FSAR does address a steam generator tube failure event.
6. One specific example of where steam generator tube integrity is addressed is in the San Onofre Technical Specifications1 that are part of the FSAR.

6.1. Specifically, page 505 of the Technical Specifications has as a Limiting Condition of Operation "Steam Generator tube integrity shall be maintained":

5.5.2.11 Steam Generator (SG) Program (continued)

b. Performance criteria for SG tube integrity. SG tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational LEAKAGE.

Structural integrity performance criterion: All in- service steam generator tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, and cool down and all anticipated transients included in the design specification) and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials.

6.2. A second example where steam generator integrity is addressed on page 510 of the San Onofre Technical Specifications that states that the limiting design basis accident is a "double ended rupture of a single tube":

The steam generator tube rupture (SGTR) accident is the limiting design basis event for SG tubes and avoiding an SGTR is the basis for this Specification. The analysis of a SGTR event assumes a bounding primary to secondary LEAKAGE rate equal to the leakage rate associated with a double-ended rupture of a single tube.

7. Eight replacement steam generator tubes failed their pressure tests in 2012 and more than 1,000 others have been plugged.
8. Therefore, a review of the evidence makes it clear that the San Onofre Replacement Steam Generator tube damage discovered in 2012 was so severe and extensive that both reactors have been operating in violation of their NRC FSAR license design basis as defined in their Technical Specifications.

1"http://pbadupws.nrc.gov/docs/ML1125/ML11251A100.pdf"

Page 3 of 14

9. The Main Steam Line Break with radiological leakage through the steam generator tubes is one of the bounding conditions in emergency plan evaluation and the extent of steam generator tube failures directly impacts the FSAR analysis.
10. The Replacement Steam Generator (RSG) modifications at San Onofre increased both the likelihood of equipment failure and the radiological consequence of such failure and therefore directly affect the FSAR Current Design Basis.
11. In a Pressurized Water Reactor (PWR), the Containment barrier includes the steam generator tube sheet and the steam generator tubes. Edison modified the San Onofre Units 2 and 3 tube sheets by removing the stay cylinder from the original Combustion Engineering design and modified the tubes by adding 377 additional tubes to each RSG.

Therefore, by taking this action, Edison chose to modify the San Onofre containment design by installing the radically different Replacement Steam Generators.

12. General Design Criteria 50 of 10 C.F.R. § 50 Appendix A (Containment design basis.)

states: This margin shall reflect consideration of (1) the effects of potential energy sources which have not been included in the determination of the peak conditions, such as energy in steam generators. (2) the limited experience and experimental data available for defining accident phenomena and containment responses.

13. The rapid and extraordinarily severe wear that resulted in the 2012 failures of all of Edisons San Onofre Replacement Steam Generators was the result of Edisons 2005 decision to radically change the RSG design and to claim that the Part 50.59 licensing process did not apply. These unlicensed unapproved design changes to the containment boundary violated General Design Criteria (GDC) 50 and therefore the FSAR must be amended to reflect Edisons significant modifications.
14. General Design Criteria 16 of 10 C.F.R. § 50 Appendix A (Containment design) states:

Reactor containment and associated systems shall be provided to establish an essentially leak-tight barrier against the uncontrolled release of radioactivity to the environment and to assure that the containment design conditions important to safety are not exceeded for as long as postulated accident conditions require.

15. The degraded condition of the tubes in the RSGs at San Onofre make it clear that Edison had violated GDC 16 and that Edisons modifications to the containment boundary must undergo the rigorous review of a formal FSAR license amendment process including the requisite public hearings.
16. In my opinion, San Onofres RSG modifications violated both GDC 16 and GDC 50 and created an unanalyzed accident the significance of which was not considered in its Final Safety Analysis Report.
17. In order to determine whether the consequences or severity of accidents analyzed in the Final Safety Analysis Report (FSAR) may be affected by any proposed change activity, the NRC regulations require that plant design changes be implemented through the 10 C.F.R. § 50.59 process. This process is used to evaluate whether any changes to plant design or operation require prior NRC approval.

Page 4 of 14

18. The nuclear industry realized that the FSAR itself might lack sufficient details on proposed changes; therefore, the nuclear trade organization Nuclear Energy Institute (NEI) developed a set of specific guidelines for utilities and energy companies to follow in order to account for deficiencies in the each FSAR. The NRC approved the use of the NEI process.
19. One of the cornerstones to the NEI guidelines is determining if the proposed changes might have an adverse impact on plant safety. Adverse safety consequence is the driving factor for requesting NRC approval of a 50.59 change, not merely the like-for-like changes claimed by Edison.
20. While the NRC Augmented Inspection Team (AIT) briefly described how Edison addressed its 50.59 requirements, the evidence shows that Edison did not comply with the NEI guidelines for implementing 50.59.
21. Published reports indicate that the strategic decision made by Edison that the 50.59 process would not be applied to the RSGs was made by corporate officials before any engineering personnel had actually performed the 50.59 engineering analysis.

Consequently, Edison made a management decision to claim that the 50.59 process did not apply and therefore San Onofre was not required to seek NRC approval for the proposed changes at San Onofre Units 2 and 3. The Edison decision to ignore the 50.59 process for San Onofres steam generators, enabled to avoid modification of its FSAR commitments as well as avoid analysis on steam generator performance and accidents

22. Proper operation of a steam generator is a major safety issue for each PWR. In addition to providing the containment barrier to radioactivity and producing steam, the steam generator has many other important safety functions. Therefore any RSG design changes clearly have potential safety consequences that are acknowledged in the FSAR.

Consequently, any design and/or fabrication change made to the steam generator must be thoroughly evaluated for its safety implications.

22.1. The RSG is the major component in the plant that contributes to safety during transients and accidents.

22.2. The RSG provides the driving force for natural circulation and it facilitates heat removal from the reactor core during a wide range of loss of coolant accidents.

23. The NRC has acknowledged the fact that Edison employed a new methodology not reviewed or recognized in the FSAR to calculate the heat transfer, velocities, levels and water/steam distribution on the secondary side of both the Unit 2 and Unit 3 Replacement Steam Generators. And to date, the NRC has released no findings regarding the full impact of Edisons unreviewed and undocumented changes to its FSAR as a result of such radical design and fabrication changes to San Onofres RSGs.
24. The overall performance of the Original Steam Generators was based upon a one dimensional computer code known as CRIB described in the FSAR, while the design and performance of the RSGs was based upon an unreviewed and un-benchmarked three dimensional code known as FIT-III which is not described in the FSAR.

Page 5 of 14

25. Knowing the standards applied and benchmarked for the RSG computer codes CRIB and FIT-III is critical information in the FSAR because the RSG computer code determines the thermal hydraulic performance during normal and accident conditions.
26. The AIT report indicated that the change to the FIT-III evaluation methodology was not discussed as part of Edisons 50.59 screening because the details of thermal hydraulic models used for the design of the OSG were not discussed in the original FSAR.
27. It should have been obvious to Edison that FIT-III has not been benchmarked and had not been previously used in licensing procedures showing that the use of FIT-III might have an adverse effect on the FSAR safety analysis thus necessitating the entire license amendment review and public hearing process.
28. As noted by the AIT, Edison approved the use of FIT-III code even though the code was not benchmarked nor identified as acceptable in the FSAR. Consequently, Edison operated San Onofre without knowing the uncertainties in the Replacement Steam Generators performance characteristics. Predicted liquid levels, pressure drops, vibrations, and temperatures at both Units 2 and 3 were all subject to unknown uncertainties during both normal and abnormal operations.
29. In my opinion, by approving the use of an un-benchmarked and untested design tool like FIT-III, Edison did not did not meet the requirements expected from a nuclear licensee.

Use of an un-benchmarked computer code that is not included in the FSAR protocol demands a formal FSAR license amendment process including the requisite public hearings.

30. The AIT makes no reference to a NRC review or lack of review of the requisite 50.59 screening evaluation or whether the NEI criteria involving safety significance were included in Edisons analysis.
31. Design changes of the magnitude created by Edison to the San Onofre RSGs should have triggered a Request for Additional Information from the NRC. No RAI was issued by the NRC, because Edison never notified the NRC of the significant modifications its San Onofre operating license.
32. The AIT reported that FIT-III predictions differed considerably in comparison to an Electric Power Research Institute developed code named ATHOS. FIT-III predicted lower flow velocities and void fractions that were not conservative compared to ATHOS.

The AIT Report neglected an analysis of the root cause of the critical differences between FIT-III and ATHOS, and the negative impact such lax calculational modeling had on the design, fabrication, and successful operation of the San Onofre RSGs. Had Edison sought the required FSAR license amendment, comparisons between FIT-III and ATHOS would have been identified six years ago.

33. The AIT did not address the possibility that the lack of conservatism in FIT-III predictions, in addition to causing tube vibrations, could also result in non-conservative predictions of the behavior of the steam generator pressure vessel and associated main steam piping during accident conditions that are required to be analyzed in the FSAR.

Page 6 of 14

34. The AIT noted that the non-conservatisms in FIT-III are a contributor to the failure by Edison to adequately calculate the San Onofre RSG tube vibrations.

34.1. But equally important, the AIT failed to address that FIT-III could also create non-conservative predictions of the behavior of the steam generator pressure vessel and associated main steam piping during accident conditions that are required to be analyzed in the FSAR.

34.2. Such a conclusion implies that damage to the steam generator pressure vessel itself, and not just the tubes, might have occurred at San Onofre and remains unanalyzed by either Edison or the NRC.

35. The probability of an accident exceeding the plants Current Design Basis is increased by the radically different Edison Replacement Steam Generators.

35.1. For example, uncertainties in predicting the thermal hydraulic performance of the steam generator nozzle may lead to stratification and early fatigue failures in the steam generator itself or associated main steam piping.

35.2. Hence, the operational risks involved in operating the San Onofre RSGs have created a licensing condition that should have been addressed as part of an FSAR license amendment and hearing process.

36. It is my professional opinion that Edison should have applied for the 50.59 process so that the FSAR license amendment evaluation and public hearings would have occurred six years ago, prior to creating an accident scenario and facing losses that by the end of this process will easily total more than $1 Billion.
37. The seriousness of the licensing and safety impact of the damaged RSGs at San Onofre cannot be overstated or underestimated.

37.1. Any Design Basis Accident (DBA) as defined in the FSAR needs to be accurately modeled in order to protect public health and safety.

37.2. The FSARs DBA analysis including the extent of tube leakage in the event of a Main Steam Line Break significantly impacts the design and implementation of Emergency Evacuation Plans.

38. In the event of a steam line break accident in the San Onofre Replacement Steam Generators with the degraded condition of the tubes, an accident would have occurred that is more severe than any design basis accident scenario previously analyzed by Edison in the FSAR.
39. Such a DBA steam line break accident would render the San Onofre emergency plan totally inadequate and most likely cause an evacuation of a large portion of Southern California.

Page 7 of 14

40. Edison dramatically increased the radiation risk to the public as a result of San Onofre with Replacement Steam Generators that were extremely flawed beginning with their original design. The fact that 8 tubes failed the pressure tests in Unit 3 indicates that those tubes would have failed during a main steam line break (MSLB).
41. It is uncertain if a reactor operator would have been able to shut the plant down without melting the core. A simultaneous rupture of 8 tubes would have caused a primary to secondary leak of radioactive coolant of about 5000-6000 gallons per minute. This leakage would have begun to drain the nuclear core as well as releasing radioactive primary coolant to the atmosphere.
42. The ability of a reactor operator to control the water level in the affected steam generator with this high leakage rate and keep the nuclear reactor core cooled has never been analyzed or tested. An accident of this magnitude is outside ANY reactors Current Design Basis (CDB).
43. The evidence presented by Edison and the NRC AIT shows that the real reason San Onofre had to plug 1300 tubes (and not just the eight that failed the pressure test) was that the San Onofre units were operating outside their Current Design Basis as defined in the FSAR and were in an unanalyzed, unlicensed condition.
44. Not only have Edisons modifications to the RSGs increased the severity of an accident, but also the Replacement Steam Generator modifications have increased the likelihood of a main steam line break. Even the NRCs AIT concluded that the probability of a MSLB was double what it had been with the OSGs.
45. In my opinion, thermal stratification and changes in the outlet steam flow from the Replacement Steam Generators would have induced stresses in the main steam piping that would likely increase the probability of a MSLB even beyond the NRCs conclusion.
46. Therefore, both the probability and the consequences of an accident have increased beyond those in the FSAR and the plants Current Design Basis as a result of Edisons replacement team generator modifications.
47. The evidence clearly shows that Edison has been operating outside the design basis of its Final Safety Analysis
48. The modifications to the Replacement Steam Generators at San Onofre and the fact that eight tubes failed critical pressure tests significantly raises the potential for radiation bypassing the containment during severe accidents such as a main steam line break accident (MSLB), station blackout (SBO) and anticipated transients without scram (ATWS) events. This situation violates General Design Criteria 16 and 50 and thus triggers the commencement of a formal FSAR license amendment process including the requisite public hearings.

Page 8 of 14 ISSUE # 2 Figure 4-3 in the report entitled Operational Envelope for Large U-bend Steam Generators, SONGS U2C17 Steam Generator Operational Assessment for Tube-to-Tube Wear [hereinafter Tube-to-Tube Report] compares the bulk velocity ratio and void fraction ratio to several successfully operating large S/Gs, and it notes that [a]t 100% power, the thermal-hydraulic conditions in the u-bend region of the SONGS replacement [S/Gs] exceed the past successful operational envelope for U-bend nuclear [S/Gs] based on presently available data. Tube-to- Tube Report at 17.

How similar to the SONGS S/Gs are these other S/Gs? Do the other steam generators, for example, use alloy 670 tubes and have similar spacing, similar support structures, etc.?

49. The Combustion Engineering (CE) designed original steam generators (OSG) are not at all similar to the Mitsubishi RSGs, nor are the Mitsubishi RSGs similar to any other steam generators with which Edison is attempting to make a comparison.

49.1. No other Replacement Steam Generator design in the country has been modified in the extreme manner that those at San Onofre Units 2 and 3 have been altered.

49.2. Combustion Engineering built the OSGs at San Onofre. Because CE used only two steam generators, these OSGs were very large and had a tight tube pitch. To assure proper water flow the OSGs had egg crate tube support plates with a region at the center with no tubes and no heat load where a stay cylinder was located.

49.3. Mitsubishi Heavy Industry, the fabricator of the Replacement Steam Generators (RSG), is a Westinghouse licensee and is not prepared to manufacture the tight tube pitch and the egg crate tube supports of the San Onofre RSG design.

50. Edison instructed Mitsubishi to replace the OSG egg crate design with broached tubes and to remove the OSG stay cylinder to add additional tubes to an area where there formally was no heat load. Edison also instructed Mitsubishi to add many other modifications to the RSG that are simply too numerous to list in this affidavit.
51. To the best of my knowledge and belief, no other steam generator in the nation is as large as those at San Onofre with broached tube supports, a tight Combustion Engineering tube pitch, and no stay cylinder. Therefore, comparing San Onofre to several other successfully operating large S/Gs is simply not a valid engineering or scientific comparison.
52. My professional experience shows that the actual root cause of the steam generator tube degradation is the 2005 strategic decision by Edison to remove the stay cylinder, change the tube sheet, change the tube support structures and add an additional 400 tubes in the Replacement Steam Generator design while still claiming that this significant design modification was a like-for-like replacement. These changes have created Replacement Steam Generators unlike any other in the nation.
53. Adding almost 400 additional tubes to the central location where the stay cylinder had been previously located increased the heat load where it was already the highest.

Page 9 of 14

54. At the same time, Edison removed the egg crate tube supports and replaced them with broached tube supports that reduced cooling flow.
55. These three changes (additional tubes, removal of stay cylinder and egg crate removal) caused a unique and unanalyzed heat load to the interior of the Replacement Steam Generators that will continue to cause the tubes to vibrate and fail even after some have been plugged.
56. The center section of the original San Onofre steam generators contained a key structural element called a stay cylinder and no steam generator tubes. In 2005 or early 2006, Edison made a management decision to eliminate this vital support pillar and add additional tubes in its place.
57. In the original steam generator design, there was no heat input in this central area of the steam generator, because there were no tubes to add the heat. When Edison added almost 400 tubes (4% of the tubes) to the center of the tube bundle in the San Onofre Replacement Steam Generators, Edison effectively increased the power distribution to the center of the steam generator.
58. This radical and unanalyzed design change moved 4% of the heat to the inside of the tube bundle while reducing the heat by 4% to the outside of the tube bundle.
59. Adding this heat to the center of the bundle was then exacerbated by removing the egg crate tube supports and replacing them with a broached tube support plate design that further reduced flow to the center of the steam generator.
60. As the NRC confirmed in its AIT report, a large steam void has developed near where the additional tubes were added in the Replacement Steam Generators (called fluid elastic instability) that allows many types of excess vibrations to occur.
61. Fairewinds review of Figure 1 below from Edisons Condition Report clearly shows that the location within the steam generators where the steam fluid elastic instability has developed is precisely the region where the extra heat created by the 400 new tubes would create an excess of steam and various vibrational modes.
62. While 4% may seem like a small change, it is not. Each San Onofre reactor generates a total thermal output of approximately 3400 megawatts of heat. If one mathematically converts 4% of 3400 megawatts of heat, it equals 135 megawatts, or to illustrate it differently: 180,000 horsepower of thermal heat that was transferred from the outside of the tube bundles to the center.

Page 10 of 14

63. Contour Of Steam Quality2 Figure 1
64. This data shows that a significant quantity of additional heat has been transferred to an area that previously had no tubes. That heat must be removed from this central area, yet Edison also reduced flow by replacing the egg crate supports with broached supports.
65. These design changes by Edison created too many steam bubbles that are causing various vibration modes and degradation in all four steam generators.
66. The data reviewed shows that the decision by Edison, to add almost 400 tubes to the center of the four Replacement Steam Generators, changes flow patterns by removing the stay cylinder. This decision by Edison also reduces flow by removing the egg crate tube supports and created the excess heat that is the causative factor in the fluid elastic instability in the Replacement Steam Generators at San Onofre.
67. No other steam generator in the United States was ever modified in a similar fashion and therefore comparisons to other steam generators at other reactors is not relevant or applicable.

2"Condition'Report:'201836127,"Revision"0,"5/7/2012,"Figure"2:"Contour"of"steam"quality"at" the"height"of"the"maximum"quality"in"UIbend"region"for"Thot"="598"F"(Figure"8.1I2"(a)"in" Reference"[2]),"Page"74.""

Page 11 of 14 Issue #3: Figure 5-1 in the Tube-to-Tube Report compares the same parameters as in Figure 4-3, but for operation at 70% power. It appears from Figure 5-1 that the bulk fluid velocity for SONGS is at the high end of the experiential range. Given the likely differences between the SONGS generators and those cited in the discussion, can one conclude that operation at 70% power is conservative?

68. The request by Edison to operate San Onofre Unit 2 at 70% power is not a conservative decision.
69. To focus on Fluid Elastic Instabilities and tube-to-tube interactions is to miss the significant problems with the defective San Onofre Replacement Steam Generators.
70. Fluid Elastic Instability (FEI) causes the tubes to vibrate abruptly at large amplitudes, so it would be imperative that the velocity is maintained below the critical values that create dynamic instabilities. Both the NRCs AIT and Edisons Cause Report neglect the criticality of accurate predictions in the relationship between power and local velocities would be required to restart Unit 2.
71. However, Vortex Induced Vibrations (VIV) and Turbulence Induced Vibration (TIV) might be created if San Onofre Unit 2 were allowed to operate at reduced power, and once again, the NRC and Edison have neglected to review and acknowledge these scenarios.
72. Significant tube damage from fatigue and wear during relatively long periods of operation can cause FEI, VIV, and TIV. Therefore the restart of San Onofre Unit 2 should not be considered because Edison and the NRC reviewed and addressed these issues in their pro-forma reviews.
73. Additionally, properly scaled physical mockups of the San Onofre Replacement Steam Generators, not inadequate computer simulations, are needed and must be required to accurately assess tube wear and vibrational risk created by the possible operation of Unit 2.
74. Computer codes cannot operate and be assessed with out a full-scale mockup prepared by which to provide benchmarks for the computer codes. Once a complete assessment of full-scale mockups is completed, then the computer codes should have the capability to predict local heat transfer rates, pressure drops, void fraction, and velocities.
75. Focusing on measuring and plugging tubes that have become thinner as a result of internal vibrations does not verify San Onofres RSGs. Edison is attempting to avoid the serious and necessary scientific analysis that would determine which unplugged tubes have become cracked from vibrations and yet are not deemed thin enough to require plugging.
76. Thus, prior to considering the restart of San Onofre Unit 2 at reduced power, Edison and the NRC must also prove to the public that the undetected cracks, which may have been already produced, will not suddenly fail during an unanticipated swing in reactor

Page 12 of 14 conditions (called an operational transient in the nuclear industry) and/or a design basis accident (DBA) that the plant must be built to withstand.

77. Restart of San Onofre Unit 2 should not be considered unless both Edison and the NRC are able to clearly demonstrate that the relationship between plant power and tube vibration is well understood and that FEI, VIV, or TIV will not add to tube wear and create additional safety risks.

Issue #4: Section 8.0 in the Tube-to-Tube Report states that [t]he desired margin is a projected maximum stability ratio of 0.75 with 0.95 probability at 50% confidence over the next inspection interval of 5 months. Tube-to-Tube Report at 104. Does a confidence level of 50% meet the reasonable assurance requirement in the regulations?

78. In my opinion, a confidence level of 50% does not provide reasonable assurance of anything related to nuclear safety.

Issue #5: Throughout the Tube-to-Tube Report, the term operational assessment is used. How is the term operational assessment different than or the same as the terms test and experiment used in 10 C.F.R. § 50.59?

79. Operating the damaged San Onofre Unit 2 at reduced power is an experiment by Edison on steam generators that are unlike any other steam generators that have been designed and fabricated anywhere in the world. The term operational assessment is a euphemism employed by Edison to avoid meeting its regulatory requirements.
80. Edison has already acknowledged to the NRC that a research experiment, not an operational assessment, will be performed and at San Onofre Unit 2 during its proposed five-month period of reduced power operation.
81. Unfortunately, the official transcript of the December 18 meeting between the NRC and Edison is not yet publically available, but Michael Blood of the Associated Press quotes Edison consultant Mike Short as saying research will be performed on tube vibrations when the plant operates at 70% power. Specifically, according to AP: "Short said the data collected by the system could be used in future research examining vibrations picked up by the monitors." 3
82. I note that this pattern of avoiding the intent of the NRCs regulation by relying on euphemism and carefully parsing words is a persistent mode of operation by Edison dating back to its earliest licensing decision to knowingly avoid the rigorous 50.59 process for the Replacement Steam Generators at San Onofre.

3"San"Onofre:"Edison"backpedals"on"claim"that"retooling"will"aid"safety,"Associated"Press,"

December"18,"2012,"http://www.ocregister.com/news/plant-381083-edison-unit.html"

Page 13 of 14 List of documents4 used to conduct my analysis and arrive at my opinions:

1. San Onofre Technical Specifications http://pbadupws.nrc.gov/docs/ML1125/ML11251A100.pdf
2. General Design Criteria 50 of 10 C.F.R. § 50 Appendix A
3. General Design Criteria 16 of 10 C.F.R. § 50 Appendix A
4. Nuclear Energy Institute (NEI) 50.59 guidelines http://pbadupws.nrc.gov/docs/ML0037/ML003771157.pdf
5. Edison Management Strategic Decision Not To Implement 50.59: Improving Like-For-Like Replacement Steam Generators by Boguslaw Olech of Southern California Edison and Tomouki Inoue of Mitsubishi Heavy Industries, Nuclear Engineering International, January 2012, page 36-38. http://edition.pagesuite-professional.co.uk/launch.aspx?referral=other&pnum=36&refresh=K0s3a21GRq61%20

&EID=af75ecb1-5b23-49be-9dd6-d806f2e9b7b5&skip=&p=36

6. NRC SAN ONOFRE REPLACEMENT STEAM GENERATOR AIT REPORT:

http://pbadupws.nrc.gov/docs/ML1218/ML12188A748.pdf

7. STEAM GENERATOR FAILURES AT SAN ONOFRE: THE NEED FOR A THOROUGH ROOT CAUSE ANALYSIS REQUIRES NO EARLY RESTART, Fairewinds Associates, Monday, Mar 26, 2012:

http://www.fairewinds.com/content/steam-generator-failures-san-onofre

8. SAN ONOFRE CASCADING STEAM GENERATOR FAILURES CREATED BY EDISON: IMPRUDENT DESIGN AND FABRICATION DECISIONS CAUSED LEAKS, Fairewinds Associates, Monday, Apr 9, 2012 http://www.fairewinds.com/content/san-onofre-cascading-steam-generator-failures-created-edison
9. SAN ONOFRES STEAM GENERATOR FAILURES COULD HAVE BEEN PREVENTED, Fairewinds Associates, Monday, May 14, 2012 http://www.fairewinds.com/content/san-onofres-steam-generator-failures-could-have-been-prevented
10. SAN ONOFRES STEAM GENERATORS: SIGNIFICANTLY WORSE THAN ALL OTHERS NATIONWIDE, Fairewinds Associates, Tuesday, Jul 10, 2012 http://www.fairewinds.com/content/san-onofres-steam-generators-significantly-worse-all-others-nationwide 4"No"documents"were"provided"by"Edison,"and"no"documents"are"covered"in"any" confidentiality"agreement"between"the"parties."
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