ML17339A846

Motion to Amend Contentions Re Proposed Amend to OL to Permit Steam Generator Repairs.Questions Safety of Storage & Other Unreviewed Safety Matters.Certificate of Svc & Prof Qualifications Encl

ML17339A846
Person / Time
Site:	Turkey Point
Issue date:	03/11/1980
From:	Chonin N, Harnage H CHONIN, N., HARNAGE, H.H., ONCAVAGE, M.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8004080239
Download: ML17339A846 (58)

Text

j(/ g+

UNITED STATES OF AtKRICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY 6 LICENSING BOARD In the Matter of Docket Nos. 50- -SP 50-251-SP FLORIDA POLvER 6 LIGHT COMPANY (Proposed Amendments to Facility Operating License (Turkey Point Nuclear Generating to Permit Steam Generator Units Nos. 3 and 4) Repairs)

MOTION TO AIWND CONTENTIONS Intervenor, Mark Oncavage, moves the Board to permit an, amendment of Contention 1 to include Contention 1B: The application of Florida Power and Light for an amendment to its facility operating license involves a material alteration of a licensed facility which requires a construction permit to issue prior to the issuance of the amendment, which in turn requires the preparation of an environmental impact state'ment.

In support of his motion'ntervenor shows:

1. C'ontentions of an intervenor may be amended. 10 C.F'.R. 52.714(a)(3) as explained in 43 Fed. Reg. 17798 (1978).

2. It is the purpose of 10 C.F.R. 52.714(a)(3) that contentions can be expanded or amended because of new informa-tion which comes to light after petitioners have been admitted, such as information in the Commission staff's safety evaluation or environmental impact'tatement. [43 Fed. Reg.

17798, 17799 (1978)]

80.0408 088

lw 4i I

~ I

3. A contention can be amended only with the approval of the presiding officer based on a balancing of the factors lis ted in 10 C. F. R. g 2. 714 (a) (1);

GOOD CAUSE FOR FAILURE TO FILE ON TIME As will be shown in a discussion of the proposed amend-ment below, the contention has been primarily motivated by the licensee's responses to the Intervenor's interrogatories.

AVAILABILITYOF OTHER MEANS T T INTEREST HILL BE PROTECTED The Nuclear Regulatory Commission is presently consider-ing the licensee's application to amend its operating license.

The Atomic Safety Licensing Board has the authority to issue that amendment. The Board also has the authority to require an environmental impact statement before i't issues or denies the amendment. There exists no means, other than the Board, to have the Atomic Safety Licensing Board order and consider an environmental impact statement before it rules on the amendment to the operating license.-

EXTENT TO WHICH THE PETITIONER'S A N N EXPECTED TO ASSIST IN DEVELOPING The petitioner will offer the testimony of Dale G.

Bridenbaugh, Gregory C. Minor and Robert Anderson to show that the proposals of the licensee involve a material alteration

/

4~

of the licensed fac'ility as that term is defined at .38 Fed.

Reg. 22796 (1973) and 39 Fed. Reg. 10554 (1974). The curriculum vitae of these three experts are attached hereto as Exhibit EXTENT TO WHICH THE PETITIONER S INTE EST L ENT EXISTING ARTIES Neither the staff of the Nuclear Regulatory Commission nor the licensee hold the position that the;repairs at Turkey Point Units 3 and 4 involve a material alteration of the licensed facility,as that term is'defined in 38 Fed. Reg. 22796 (1973) and 39 Fed. Reg. 10554 (1974).

EXTENT TO WHICH THE

'T TIONE S A T IPATION MILL BROADEN THE ISSUES OR In the existing Contention 1 the Intervenor has contended that an Environmental Tmpact Statement should issue, but based its contention on grounds different from those contained in Contention 1B. The scope of the inquiry on what would be Contention 1A will be much broader than the inquiry required under Contention 1B. In order to avoid any delay, Contentions 1A and 1B can be heard together as part of the same proceeding.

Thus the broadening will be very small and the delay very if little the new contention is allowed.

Under 10 C.F.R. $ 2.714(a)(3) a motion to amend contentions must satisfy the specificity requirements of 10 C.F.R. $ 2.712(a) (2).

4i i THE INTEREST'F THE ET T OHE N T E PROCEEDING By order of this Board dated August 3, 1979, Mark P.

Oncavage is a party-intervenor in this cause.

HON THE PETITIONER'S YTE i VOTE ZNTE ST MAY BE AF ECTED PROCEEDIH At the present stage of this proceeding, the Intervenor is the representative of the present generation "as trustee of the environment for succeeding generations." See 42 U.S.C. )4331(b) (2). In this quasi-fiduciary position he has the responsibility to:

(1) assure for all Americans safe, healthful, productive, and esthetically and culturally pleasing surroundings; (2) attain the widest range of benefi-cial uses of the environment without degrada-tion, risk to health or safety, or other un-desirable and unintended consequences; (3) preserve important historic, cul-tural, and natural aspects of our national heritage, and maintain, wherever possible, an environment which supports diversity and variety of individual choice; (4) achieve a balance between population and resourse u'se which will permit high standards of living .and a wide sharing of life's amenities; and I

(5) enhance the quality of renewable re-sources and approach the maximum attainable re-cycling of depletable resources.

Additionally, Mr. Oncavage, his wife and his son live Qi approximately 15 miles from the Turkey Point power facility.

He owns a sailboat and cruises the waters of Biscayne Bay near Turkey Point'and engages in fishing, crabbing, swimming, skin diving and underwater photography.

In order to protect these interests Mr. Oncavage desires that the steam generator repairs at the Turkey Point facilities

'I i

be performed in a fashion that vill have as .little adverse impact as possible on the natural environment. An obvious method for determining whether the repair activities will have a degrading impact on the environment is to have an Environmental Impact Statement made. If a statement is not made Mr.

Oncavage loses a valuable tool for determining the degree to which the steam generator repairs will degrade the environment.

To the extent that the environment damage will be prevented by its disclosure in an Environmental Impact Statement, Nr.

Oncavage will:be greatly affected by the preparation of an Environmental Impact Statement.

SUBJECT MATTER OF THE HE CONTENTIONS If an I

application for an amendment to a license involves a material alteration to a licensed facility, a construction permit will be issued prior to the issuance of the amendment to the licensee.. 10 C.F.R. $ 50.91. Alteration, as used in that regulation, means a change in a technical specification or a change. which involves an unreviewed safety question.

(i 38 Fed. Reg. 22796 (1973) and 39 Fed. Reg. 10554 (1974). An environmental impact will be prepared and circulated prior to the issuing of a construction permit issued pursuant to 10 C.F.R. Part 50. See 10 C.F.R. '$51.5(a)(1).

The integrity of tubes in a Westinghouse steam generator is considered by the Nuclear Regulatory Commission to be an unresolved safety issue. NUREG-0410, N.R.C. Pro ram for the Resolution of Generic Issues Related to Nuclear Power Plants, Category A Technical Activity No. A-3, U.S. N.R.C. Jan.

1978.

It is stated in the Environment Impact Appraisal at

)2.2 that of Hay 1979, tube plugging for various

'f As reasons has resulted in removing about 17.5%

the steam generator tubes in Unit 3 and about 20.5% of the tubes in Unit 4.

Florida Power and Light has claimed at Section 2.2 of its Steam Generator Repair Report that Research, development and testing have been utilized to select design parameters, material and component configurations which will prevent degradation of the repaired steam generators. (Emphasis added)

In Intervenor's interrogatories 1 - 7 and 1 - 8 he asked licensee to provide all of its test data and calcu-

,lations in support of its allegation that with its newly installed steam generators it could prevent tube degiadation.

As can be seen from the answers to these questions, .provided by the licensee,. it has no test data or calculations or any

i+i empirical facts to support its claim that it can now prevent tube degradation.

I' ter receiving these answers Intervenor contacted his expert witnesses for an evaluation of the Florida Power and Light claims that it could prevent tube degradation. Dale G. Bridenbaugh and Gregory C. Minor will testify that the failure of multiple tubes in the steam. generator prior to or during a loss of coolant accident or a main steam line break accident could impact the ability of the emergency core cooling system to perform its intended function due to excess leakage between the primary and secondary coolants.

At the time of initial licensing, the FSAR indicated confidence in the design and reliability of the steam generators.

Mhat in fact happened was a large failure rate experienced in the tubes of the steam generators. There still remains no test data or calculations to support the claim that the new steam generators will encounter no tube denting and that degradation will be prevented. This is a safety question which has not been reviewed before.

The licensee claims in Steam Generator Repair Report 52.2.1.1 that the increased circulation ratio will prevent and inhibit corrosion. Dr. Robert Anderson will testify that corrosion problems tend to increase with increases in fluid velocity. At higher velocities turbulence is more pronounced which results in concentration gradients forming

~I igj by the eddy currents and erosion can increase. Dr. Anderson will testify that demineralized water is more aggressive to metal than non-demineralized water. In conjunction with the testimony of Messrs.. Bridenbaugh and Minor that the tube denting problem has not been solved, Dr. Anderson will testify that the blocking of those'ubes would redistribute

'I already existing sludge in a nhw manner causing further

'he tube failures.

ON-SITE STORAGE OF STEAM GENERATORS In -response to Interrogatory 6-11 the licensee lists the guidelines that will be followed in designing the steam generator storage facility. Of all of the guidelines listed,:

none .of them are Nuclear Regulatory Commission guidelines.

For the Nuclear Regulatory Commission this is an unreviewed question.

In response to Interrogatory 6-21, the licensee states that it .has no provisions for the collection of condensation inside the steam generator storage facility. As a conse-quence, condensation may form on the steam generators pro-viding a liquid pathway for removable nucleids or nucleids in solution.

In response to Interrogatory 6-11, the licensee has stated that the facility will be designed to withstand winds of 120 m.p.h. The Intervenor will offer testimony of

0 hurricanes that have passed through Dade County, Florida, along Biscayne Bay, with winds in excess of 120 m.p.h. In response to Interrogatory 6-35, Florida Power and Light admits that it has no final calculations evaluating the effects of a design basis hurricane upon the foundations of the steam generator storage facility. The totality of these answers would indicate that the storage facility will be the source of a potential radionucleid release to the environ-ment and that during a hurricane the integrity of the storage facility itself is in question. These are safety questions that are both material and have not been reviewed in the past.

Respectful sub itte By E." RY L

Attorneys for MARK A. ONCAVAGE, Intervenor

4l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY 6 LICENSING, BOARD In the Hatter of Docket Nos. 50-2'50-SP 50-251-SP

'LORIDA POWER 6 LIGHT COMPANY (Proposed Amendments to Facility Operating License (Turkey Point Nuclear Generating to Permit Steam Generator Units Nos. 3 and 4) Repairs)

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the forego'ing Motion to Amend Contentions was mailed this >Ah day of March, 1980, to the following individuals:

Norman A. Coll, Esq.

Steel, Hector 6 Davis 14th Floor Southeast First National Bank Building Miami, Florida 33131 b

li Elizabeth S. Bowers, Esq.

Chairman Atomic Safety and Licensing Board Panel iver ~

>~~

U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Oscar Paris Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555

0 Q Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Mark P. Oncavage 12200 S. W. 110 Avenue Miami, Florida 33176 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Steven C. Goldberg, Esq.

Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Bruce S. Rogow, Esq.

Joel V. Lumer, Esq.

Richard A. Marshall, Jr., Esq.

Counsel for Intervenor 3301 College Avenue Fort Lauderdale, Florida 33314.

Harold F. Reis, Esq.

Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue, N. W.

Washington, D. C. 20036 HENRY H. PApgAgp HENRX H. HARNAGE

gl 0

RES Ut1E GREGORY C. t1I HOR YiMB Technical Associates 1723 Hami 1 ton Avenue Sui te K San Jose, Cali fornia 95125 (408) 266-2716 EXPERIEHCE 1976 - Present:

Partner - t1HB Technical Associates, San Jose, California.

Engineering and Energy consul tant to state, federal and pri vate organizati ons and indi vi duals. t1ajor activities include studies of safety and risk involved in energy generation, providing tech-nical consul ting to legislative, regulatory, .public and'ri vate groups and expert wi tness in behal f of s tate organi zations and ci ti zens 'roups. l!as co-edi tor of a cri tique of the Reactor Sa fe ty Study (1!ASH-1400) for the Union of Concerned Sci enti s ts and co-author of a risk analysis of Swedish reactors for the Swedish Energy Commission. Served on the Peer Review Group of the NRC/THI Special Inquiry Group (Rogovin Commi ttee). Actively invol ved in the Hucl ear Power Plant Standards Commi t tee work for the Instrument Society of America (ISA) .

1972 - 1976:

t'lanager - Advanced Control and Instrumentation Engineering, General Electric Company, Hucl ear Energy Division, San Jose, Cal i fornia.

Hanaged a desi gn and development group of thirty-f'our engineers and support personnel designing systems for use in the measurement, control and operation of nuclear reactors. Involved coordination with other reactor design organizations, the Nuclear Regulatory Commission, and customers, both overseas and domestic.

Responsibilities included coordinating and managing the design and development of control systems, sa fety sys tems, and new control concepts for use on the next generation of reactors. The posi tion included responsibility for standards applicable to control and instrumentation, as well as the design of short-term solutions to field problems. The disciplines involved included electrical and 1 mechanical engineering, seismic design and process computer control /

programming.

~I 1970 1972:

Manager - Reactor Control Systems Design - General Electric Company, Nuclear Energy Division, San Jose, California.

Managed a group of seven engineers and two support personnel in the design and preparation of the detailed system drawings and control documents relating to safety and emergency systems for nuclear reactors. Responsibility required coordination with other design organizations and interaction with the customer' engineering personnel, as well as regulatory personnel.

1963 - 1970:

Design Engineer - General Electric Company, Nuclear Energy Division, San Jose, Cali fornia.

Responsible for the design of specific control and instrumentation systems for nuclear reactors. Lead desi gn responsibi1 i ty for various subsystems of. instrumentation used to measure neutron flux in the reactor during startup and intermediate power opera-tion. Performed lead system design function in the design of a major system for measuring the power generated in nuclear reactors.

Other responsibilities included on-site checkout and testing of a complete reactor control system at an experimental reactor in the Southwest. Received pa'tent for Nuclear Power Moni toring Sys tern.

1960 - 1963:

Advanced Engineering Program - General Electric Company, Assign-ments in Washington, Cali fornia, and Ari zona.

Rotating assignments in a variety of disciplines:

Engineer - Reactor maintenance and instrument design, KE and 0 reactors, Hanford, Washington, Circuit design and equipment maintenance coordination.

Desi gn Engineer - Microwave Department, Palo .Al to, Cali-fornia. Work on design of cavity couplers for TWT'.

Design Engineer - Computer Department, Phoenix, Arizona.

Design of core driving circui try.

Design Engineer - Atomic Power Equipment Department, San Jose, California. Circuit design and analysis.

'Design Engineer - Space Systems. Department, Santa Barbara, Cali fornia. Prepare control portion of satelli te proposal.

0 Technical Staff - Technical Nil itary Planning Operation.

(TEHPO), Santa Barbara, Cali fornia. Prepare analysis of missile exchanges..

During this period, completed three-year General Electric program of extensive education in advanced engineering principles of hi gher mathematics, probability and analysis. Also completed courses in Kepner-Tregoe, Effective Presentation, Hanagement Training Program, and various techni cal seminars.

E DUCAT ION Uni versi ty of Cali fornia at Berl el ey, BSSE, 1960.

Advanced Course in Engineering year Curri cul um, General Electric Company, 1963.

Stanford Uni vers i ty, HSEE, 1966.

HONORS AN D ASSOCIATIONS Tau Beta Pi Engineering Honorary Society Co-holder of U.S. Patent No. 3,565,760, "Nuclear Reactor Power Honi toring System," February 1971.

Hember: American Association for Advance of Science.

Hember: Nucl ea r Power Pl ant S tandards Commi t tee, Ins tru-ment Society of America.

PERSONAL DATA Born: June 7, 1937 Harried, three chil dren Resi dence: San Jose, Cal i fornia

4k 0 J

PUBL I CAT I OHS AHD TESTIMONY G.C. Minor, S.E. Moore, "Control Rod Signal Mul tiplexing.,"

IEEE Transactions on Hucl ear Science, Vol.. HS-19, February 1972.

2. G.C. Minor, W.G. Milam, "An Integrated Control Room System for a Huclear Power Plant," HEDO- 10658, presented at International Nuclear Indus tri es Fair and Techni ca Me'e tings,1 October 1972, Basl e, Swi tzerl and.

3.. The above arti cle was also published in the German Technical Miagazine, HT, March 1973.

Testimony of G.C. Minor, D.G. Bridenbaugh, and R.B. Hubbard before the Joint Committee on Atomic Energy, Hearings held February 18', 1976, and published by the Union of Concerned Sci en ti s ts, Cambri dge, Massachusetts.

5. Testimony of G. C. Minor, D.G. Bridenbaugh, and R.B. Hubbard before the Cal i forni a State Assembly Commi ttee on Resources, Land Use, and Energy, March 8, 1976.

6. Testimony of G.C. Minor and R.B. Hubbard before the Californi<

State Senate Commi ttee on Publ i c Util i ti es, Trans i t, and Ene rgy, Ma rch 23, 1976.

7. Testimony .of G. C. Minor regarding the Gra fenrheinfel d Hucleai Pl ant, Miarch 16-17, 1977, Wurzburg, Germany.

8. Testimony of G.C. Minor before the Cluff Lake Board of Inqui'rg Regina, Saskatchewan, Canada, Sep'tember Zl, 1977.

9. The Risks, of Nuclear.Power Reactors: A Review of the HRC Reactor 3afet Stud MASM-1400 lMUREG-75701a~H. KendaIT, et al, edited by GC. Minor and RB. Hubbard for the Union of Concerned Scientists, August 1977.

10. Swedi sh Reactor Sa fet~ Study: Barseba'ck Risk Assessment, liMB Techni cal Associates Januar 1978. lPubl i shed by S wedi sh Department of Industry as Document SdI 1978:1)

Testimony by. G.C. Minor before the IA,isconsin Public Service Commis-sion, February 13, 1978, Loss of Coolant Accidents:

Their Probabil i t and Conse uence.

12. Testimony by G. C. Minor be fore the Cal i fornia Legislature

.Assembly Commi t tee on Resources Land Use and Energy, AB 3108, April 26, 1978, Sacramento, Ca 1 ifornia.

13. Presentation by G.C. Minor befo re the Federal Mini s try for Research and Technology (BMFT), Meeting on Reactor Safety Research, Man/t1achine Interface in Huclear Reactors, August 31 and 'September 1, 1978, Bonn, Germany.

4

~i

14. Tes timony by G. C. t)inor, D G. Bri denbaugh, and R B. Hubba rd before the Atomic Safety and Licensing Board, September 25, 1978, In the Hatter of the Black Fox Nuclear Power Station Construction Permit Hearings, Tulsa, Oklahoma.

15. G.C. Ilinor, D. G. Bri denba ugh, and R. B. Hubbard, Improving the

~Safet of LMR Power Plants, prepared for Sandia Laboratories by HHB Technical Associates, September 27, 1979.

~I ~i BIOGPJ.PH I CAL DATA HAl(E: Robert Neil Anderson ADDRESS: Hork: Department of materi al s Engineering San Jose State Vniversi ty San Jose, California 95192 (408/277-3781 or 277-2448)

Home: 3034 Stelling Drive Palo. Alto, California 94303 (415j494-7824)

PERSONAL I> FORlATIOll:

Date of Birth: tlovember 8, 1933 Place of Birtli: San Jose Harital Status: t/arried; t> o children EDUCATION I

B.S.,: Chemistry, University of San Francisco, 1956 B.S.,: Chemical Engineering, University of California - Berkeley 1958 N.S.;: Chemical Engineering, University of California - Berkeley 1959 Ph.D., f<etallurgy, Stanford University, 1969 Post Doctoral Study in f'<etallurgy - Stanford University, 1970-1973 PROFESSIONAL EXPERIENCE':

Academic:

S'an Jose State University, Professor 1978 - Current San Jose State University, Associate Professor, 1974-78 Stanford University, Associate Professor, 1973-74 Stanford University, Research l'metallurgist, 1972-73 Stanford University, Post Doctoral Research Associate, 1970-72 University of California, Berkeley, Research Assistant, 1958-59 University of San Francisco, Chemist, 1955-56 Industrial:',

V.S. Naval Radiological .Defense Laboratory, Operations Research Analyst, 1966-69 U.S.:Naval R diological Defense Laboratory, Research Engineer, 1959-66 Arabian American Oi'1 Company, Chem,st, 1954-55

~I 4>

PROFESSIONAL EXPERIENCE (continued)

Consulting:

California Public Utilities Commission, 1979 Standard Oil Company of Indiana, 1978 - present Lauirence Livermore Laboratory, 1978 - present Radiological Science Inc., 1977 - present California State Energy, Resources and Development Corrmission, 1977-79 Executive Office of the President of the United States Counci'1 on Environmental equality and Office of Science and Technology Policy, 1978 United States Congress, Office of Technology Assessment, 1979 Scientific Service Incorporated, 1977-78 HHB Associates, 1977 present Parlee-Anderson Corp., 1979 - present Accident Analysis, 1974 - present HcDermi tt Hine, 1976 - present-International Business Hachines, 1977-78 Hemorex, 1979 Electrical PovIer Research Institute, 1974 SRI, 1975-77 Brookhaven National Laboratories, 1977-78 Attornies (list on request)

PROFESSIONAL 'ACTIVITIES:

American Nuclear Society, American Institute of Chemical Engineers, American Chemical Society, American Instftute of Hetallurgical

.Engineers (Past Chairman of Northern California Section),

American Society of Hetals, National Society for Professional Engineers, American Society for Engineering Education, California Academy of Science, Alpha Chi Sigma, Tau Beta Pi and Sigma Xi.

CREDENTIALS AND LICENSES:

California Standard Teaching Credential.

Registered Hetallurgical Engineer, California.

Registered Nuclear Engineer, California.

Fallout Shelter Analyst.

Private Pilots License.

PUBLICATIONS:

Articles:.

1. "The Activity of Titanium in Liquid Alloys," Accepted for publication and presentation'n ihe Fourth International Conference on Titanium 19-22 Hay, 1980, International Conference Hall, Kyoto, Japan.

2. "Internationally Safeguarded Atomic Fuel Exchange Center for the Asia-Pacific Basin," Proceedings in 2nd Hiami International Conference

I PUBLICATIONS (continued)

'n Alternative Erergy Sources, 10-13 December 1979, hiami Beach, Florida.

3. "Site Selection for Spent Fuel Storage Facilities in the Pacific Basin,"

Nuclear Engineering International, October, 1979.

4. "Survey of Nuclear Fuel Reprocessing Technologies,". Conservation and Recycling, October, 1979.

The Gold Dagger of Tutankhamun, Grafico Publishing Co., Santa Clara, Ca., 1979 (available through the San Francisco De Young tiuseum).

6. of the Infrastructure of the Front End of the Uranium Fuel 'Analysis Cycle," San Jose State University, ttazerials Engineering Department, technical report prepared for the California Public Utilities Commission (August 30, 1979).

7. "The Kinetics of UOq Reduction by Carbon in Liquid Tin," Lawrence Livermore Lab Technical Report, July, 1979.

8. "Analysis of the Front End of the Uranium Fuel Cycle, Including Uranium Resource Avai'lability through the Year 2010," San Jose State University, Materials Engineering Department, report prepared for the California Public Utilities Commission (July 1, 1979).

9. "The flineral Industries and the Challenges of the 80's," paper presented to the Pacific Southwest Hinerals Conference, San Francisco t1arch 25, 1979.

10. "The Effect of Equipment Design, Operational Parameters and Surface Conditions on Coatings Produced by Flame Spraying," Journal of Thin.

Solid Films, accepted for publication 1979.

"The Effect of Pressure on Interface Interactions Between Solids,"

Proceedings of the Conference on High-Level Radioactive Solid Waste Forms 19-21 December 1978, Denver, Colorado,

12. "Let's Use HHD to Smel t Hetals: Industrial Research/Development September 1978 (p.p. 131-34),

13. "The Application of Hagneto Hydro-Dynamics to Steelmaking," Industrial Research and Development, September, 1978.

14. "Cleaning and. Surface Preparation Technology and Other Factors on Coatings Produced by Flame Spraying," presented at the 4th International Symposium on Contamination Control, 10-13 September 1978, Washington, D.C.

15. "Separation Technologies Reviewed," Nuclear Engineering International, A'ugust, 1978.

4l PUBLICATIOHiS (cont!os

16. "Spent Fuel Disposal Costs," report to the Natural Resources ces D fense Council, July, 1978.

. 17. "Examinations of Radioactivity and Environmental Aspects of Antartic Soils at Point Hueneme," report to the Californi'a Sol'd 'l' d July, 19?8.

18. 'nvited contributor to the Executive Office of the President of the United States document on Nuclear Po;:er and Nuclear !Baste Disposal for the President of the United States, June, 1978.

19. "Technical Review( of the Oeutch Draft Report on Nuclear Haste Management," for the Council on, Environmental equality, Executive Office'f the President of the Unites States, flay, 1978.

20. "A Technica, T

C nssessm!ent of Nuclear Fuel Reprocessing, and Pad ive ioac Hast Disposal, report to State of California Energy Resources Conservation and Development Cotrnission, March, 1978.

21. "A Pr ogram Assessment of Nuclear Fuel Peprocessing and Radioactive Haste Disposal," report to State of California Eneroy Resources Conservation and Development Commission, January, 19?8.

22. Methodology for Comparative Evaluation of Nuclear Fuel Reprocessing Techniques for Advanced Lofti Proliferation Risks," Proceedirgs of the irst International Conference on Alternative Energy Sources, December,. 19?7, Coral Gables, Florida.

23. "Hydrometallurgical Separation of the Zinc-Base Fraction of Shredded Automobiles," Conservation and Recycling, Y. 1, 1977.

II

24. Survey of Reprocessing Technologies," Brookhaven National Laboratories S

Report 23082, June, 1977.

25. The Physical E Chemical Characteristics of Titanium-Copper Alloys,"

Technical Report to Regalviare, July, 1977.

26. "A Methodology for Evaluation of Alternative Technologies Applied to Nuclear Fuel Reprocessing," Brookhaven National Laboratory Report 50700, July, 1977.

27. "Comparative Evaluation of Nuclear Fuel Reprocessing Techniques for Advanced Fuel Cycle Concepts," report prepared for Brookhaven National Laboratory, September, 1976.

28. "Meet the ANF Reactor," Industrial Resea>ch. May, 1976.

29. "A Technical and Economic Analysis of Processes for the Recovery of Metals in the Non-Ferrous Portion of Automobile Shredder Refuse,"

Proceedings of the Fifth Mineral Haste Utilization Symposium, April VI' 13-14, 1976.

0 I

~ /

PUBLICATIONS (continued)

'0. "Evaluation of Mineral Haste Utilization Processes and Strategies Analysis," Proceedings of the Fifth llineral llaste by Net Energy U ti 1 i za ti on Sympos ium, Apri 1 13-14, 1976.

31. "Available Supply of Gallium and Arsenic," prepared for NASA Langley

. Research Center, Va., April 1976.

32. "Carbothermic Reduction of Refractory t!etals," J. of Vacuum Science E Technology., V. 13, No. 1, Jan/Feb 1976; "Nuclear Plant Can hake Gold," San Jose News, t1arch 20, 1975; "What to Do kith Atomic Haste,"

San Jose:News, 1975.

33. "Thermodynamics of Nitride FoFmation in Liquid U-Gd-Sn Alloys,"

Journal of High Temperature Science, V. 7, 1975.

34. "Study of Interdiffusion in Electroplated Si-Ni on Au," Solid State Technology, November 1974'.

35. "Nitrogen Nitride Equilibria in t1olten Y-Sn Alloys, "Journal of High Temperature Science, V. 6, 1974..

36.: "The Kinetics of Uranium Nitride Formation in U-Sn Alloys," Journal of Hi gh Temperature Sci ence, V. - 6, 1974.

37.. "Thermodynamics of Nitride For'mation in Liquid U-Gd-Sn Alloys,."

Journal of High Temperature Science, Abstract in Journal of tletal, January, 1974.

38. "Nitrogen-Nitride Equilibria in Molten Y-Sn Alloys," Sub'mi ted to .he Journal of Hi gh Temperature Science, (with A-FUl!A and N.A.D. Parlee).

39., "The Kinetics of Uranium Nitride Formation om'iquid U-Sn Alloys,"

submitted to Metallurgical Transactions (with, T. Schnicks and N.A.D. Parlee) (Abstract in Journal of t1etals, January, 1974).

40. .Application of Solution Thermodynamics in High Temperature Hetallurgical Processes, Proc. of 67th Meeting of the American Institute of Chemical Engineers, Dec. 1--15, 1974.

41. "Nitrogen-Nitride Equilibria in tlolten Pr-Sn Alloys," Journal of High Temperature Science, V. 5, 1973.

42. "Nitrogen-Nitride Equilibria in Holten Gd-Sn Alloys," Journal of Hi gh Temperature Sci ence, V. 5, 1973.

43. "Nitrogen-Nitride Equilibria in tlol ten Gd-Sn Alloys," Journal of High Temperature Science, V. 5, 1973.

44. 'Continuous Removal of Fission Products in a Nitride Fueled Reactor,"

Nuclear Technology, V. 13, March 1972 (297-300).

41 PUBLICATIONS (continued) 45; "Application o Nitride-Forming Reactions to Reprocessing of Spent Nuclear Fuels," Nuclear Technology, V. 13, January, 1972.

46. "Reassessment of. the Copper-Boron Phase Diagram," Journal of the Less Common Yietals, V. 25, December. 1971 (427-430).

47. "Nitrogen-Nitride Reactions in Molten U-Sn Alloys," TMS-AIME Metallurgical Transactions, V. 2, June, 1971

48. "Standard Free Energy of Nitride Formation From the Elements, A Estimation Technique," Journal of High Temperature Science, Y. 2, 1970.

49. "Ultrasonic Decontamination of Military Weapons," NRA Riflemen, November, 1963.

50. "The Contamination-Decontamination of Fission Products in Sea Hater," Nuclear Detonations and Marine Radioactivity Symposium, l(jeller, Norway, 1963.

5l. "Two Phase Heat Transfer," Industrial and Engineering Chemistry, V. 51, 1959.

PATENTS ISSUED IN THE FIELD OF YiATERIALS SCIENCE:

U.S. Patents 3,794,482 Feb. 26, 1974 3,843,765 Oct, 22, 1974 3,843,766 Oct. 22, 1974'anadian Patents 931,672 Aug. 7, 1973 931,673 Aug. 7, 1973 950,683 July 9, 1974 Great Britain 1,342,991 Jan. 18, 1971 1,344,950 Jan. 18, 1971 1,323,474 .

Nov. 13, 1970 1 323 475 Ncv. 13, 1970 Mexico 119,105 Jan, 30, 1971 New Zealand .163,527 Jan. 15, 1971 South Africa 71/0273 Jan. 18, 1971 Sweden 1166/71 Feb. 1, 1971 M. Germany 2,103,255 Jan. 25, 1971 U.S. Patent Applications 905,745 filed May 15, 1978 038,382 filed Hay 14, 1979

i

, Dale G. Bridenbaugh.

1723 Hamilton. Avenue, Suite K San Jose, CA 95l25 (408)266-2716 EME HZ EN CZ;:

1976 - Present Pa tner, HiB Technical Associates, San Jose. Cal'ornia. Founder anc pax'tner oz tec. nz.ca consu cxng zxrm. Spectra z.s ts. Ln energy consul tiz to governmental and othex groups inte es ted in evaluation oz nuclear plant safety and licensing.. Consultant in this capacity to State oz California, Suzfolk Coun+i,, New York, New York Attorney General, Nox'-

wegian Nuclear Power Committee, Public Advocates Office, New Jersey, and various other organizations and envi onmental groups. Performed extensive sazety analysis or Swedish Energy Comm'ssion and contribute to Union of Concerned Scien'tis ts 'eview of HASH-1400; consultant to U.S. NRC - LWR Safety lmprovemen't Program, and performed Cost Analysis oz Spent Fuel Disposal zor HRDC.

1976 (February - August)

Consu" tant, Pro-ect Survival, Palo Alto, Cal~ fornia. Volunteer work on Nuc ear Sazeguaras initiative campaigns in Ca izornia, Oregon, Washington, Arizona, and Colorado. iiumerous presentations on nuclear power and alternative energy options to civic, government, ana college groups. Also resource pe son for public service presentations on raaio and tel.evision..

1973 - 1976 Ymnazer, Performance Evaluation and Zcnrovement, General Elect=ic Comoan - Nuc ea- Enexg Division, San Jose, Ca izornia. managed seventeen te cnnx ca an seven c esca p ersonne wx, tn responsibility for establishment and,management oz systems to monitor and measure Boiling Water Reactor equipment and system operational pe ormance.

integrated General Electric resources in customer plant modifications.,

coordinated correction of causes oz forced outages and oz efforts to improve -reliability and perfoxmance of BWR systems.

Responsible zor development of Division Has ter Performance improvement Plan as well as for numerous Staff special assignments on long-range stuaies. Was on special assignment zor the management of two diffex'ent ad hoc projects foxmed to resolve unique, technical problems.

1972 - 1973 Hang e, Product Service, General Electric Company - Nuclea= Enexzv Dr~saon, San Jose, Calx. opia. H~naged group oz twenty on e t e chnical an our c erxca personne . - Prime- responsibility was to direct inter-face and liason pe sonnel involved in corrective actions required under contract warranties. Also in,charge of refueling and service planning, perzormance analysis, and service comm~ication functions supporting a completed commercial nuclear power reactors supplied by General Electri both domestic and overseas (Spain, Germany, Italy, Japan,'ndia, and Switzerland) .

<0 1968 1972 ifanaRer, Product Service, General Electric Comoan Nuclear Enerzv Div"sion, San Jose, Ca izornia.

managed sixteen technical and;six clerical pe sonnel with" tHe responsibility for all customer contact, planning and execution of work required after the customer acceptance oz Department supplied, plants and/or equipment. This included quotation, sale and delivery of spa e and renewal pa ts. Sales volume oz parts inc eased zrom $ 1',000,000 in 1968 to over $ 3,000,000 in 1972.

1966 - 1968 Khazer Complaint and ~4arr Nuclear Energy Div sion, San Jose California.

Managed group of six persons w'th the responsibility or customer contacts, plann ~g and execution of work requ'red after customer acceptance'f Depar~~ ent - supplied plants and/or equ pment both domestic and overseas.

1963 -. 1966 Field Engineerin Supervisor, General Electric Comaanv Installation anc ~cry" ce anz"neerxn Department. Los An eles California.

Supervised approx~mately eight field representatives with responsi-bility zor General Elect ic steam and gas turbine installation -nd maintenance work in Southern California, Arizona., and Sou"hem Nevada During this period was responsible for the installation of eight di zerent central station steam turbine generator uni'ts, plus much maintenance activity. cwork included customer contact, preparation of quotations, and contract negotiations.

1956 - 1963 Field Engineer General Electric Comoan , 'installation and Service En ineerinz Department Chicago Illinois.

Supervised installation and maintenance of steam turbines of all size.

Supervised crews of from ten to more than one hundred men, depending on the job. 'Pork primarily with large utilities but had significant work with steel, petroleum and other process industries. Had four years of. experience at construction, startup, trouble-shooting and unit.

refueling oz the first large-scale commercial nuclear power 1955 - 1956 Engineering Training Program, General Electric Company, Er e, ennsy vanya, ana crenectaay, ew ore.

Training assignments in plant zacilities design and in steam turbine testing at two General Electric Factory locations.

IO 1953 -. 195'5 United States Amv - Ordnance School, Aberdeen, lzfrvland instructor - Heavy Artillery Repair. Tauoht class oom and shop disassemb y oz -rtillery pieces.

1953 n';ineering Training Program, General le et=i c Comoanv, vendale,

~ ."

t=aining assignment with Aire a" t Gas Turn ne Deca- ment.

EDUCATT.:ON 6 A FZL T %TALONS BSiZ - 1953 South Dakota:School of Mines and Technology, Rapid City, South Dakota, Upper 3- oz class.

Prozessional Nuclear Engineer - California. Certificate No. 0973.

Y mbe - P erican Nuclear Soc'ety.

Various Company Training Cou ses during career includi..g Professional Business Managemen-, Keener Trezoe Decision Mekino,, E.-- ct e .

Presentation,. and numerous technical seminars.,

HONORS Ec AWARDS Sigma Tau - Honorary Engineering fraternity.

Gene al Ywnagers Award, General Electric Company.

PERSONAL DATA Born Novembe 20, 1931, ".iiller, South Dako ta harried, three children.

6'2", 190 lbs., health - excellent.

Honorable discharge from United Stat s Army.

Hobbies: skiing, hiking, work with Cub and Boy Scout groups.

~I

~ i

~

PUBLiCATZONS & TESTIMONY

'ODe at" nz and Ha. ntenance Exoe ence, presented at Twe 1=:"4 Annua Seminar zor E ec"=ic Uti icy Executives, Pebb" e Beach, Cal'ornia, October 1972, published in General Electric hr.DC-10697, December 1972.

Ym~~tenanc ana ln-Se v~ ce inspection, presented at l~:-4 S~~osium on Expe ience F om Operating and Fueling oz Nuclear Power Plants, B=idenbaugh, Lloyd, 6 Turner, Vienna, Aus tria, Octooez'973.

3. Ooeratin and Maintenance Experience, presentea at Thirteenth P~uax emxnar zor Exect c Uti x.ty Executives, Pebble Beach, Cali ornia, November 1973, puolished in General Electric NEDQ-20222, January 1974.

1~roving Plant Availab~"litv, presented at Th'rteenth Annual eminar =or ELectric Uti ity Executives, Pebble Beacn, Califor-..

November 1973, published in General Electric il<D0-20222, Januaz 1974.

Application oz Plant Outage Experience to T~~i =ove Plant Per-zo tE'- K, -'-'-',

-nce, Bxiaenoaug an BurasaL., American Power Conzerence,

'1 10, l 97k.

6. Nuclear Valve Testing Cuts Cost, T" me, Electr cal world, Octobe

o. 1 74.

The Risks oz Huclear Power Reactors: A Review oz the NRC React are tv t. a MASH-l, Kenaas, Huo ar, i'~~nor, Bra,aen augn, e t a, zor ue Union o f Concerned S c'ntis ts, Augus t 1977.-

8. Swedish Reactor Safet Stua: Barseback Risk Assessment, LRB xecnnxca Associates, January '

. ( u zsnea .y welsh of Industry as Document Dsi 1978;1)

Depar'ent

9. Tes timony oz D. G. Bridenbaugh, R. B. Hubbard, G. C. Minor to th Calizoznia State Assemoly Committee on Resources, Land Use, and Energy, March 8, 1976.

10. Tes timony -o fUnited D. G.. Bridenbaugh, R.

States Congress, B. Hubbard, and G. C. M.nor Joint Committee on Atomic before tne Energy, r eb~ary 18, 1976, washington, DC. (Published by the Union oz Concerned Scientists, Cambridge, Massachusetts; )

Testimony by D. G. Bridenbaugh 'oefore the California Energy Conmission, entitled, Znitiat"'n of Catastroo~ic Accidents at Diablo Canyon, Hearings on Emergency ? lanning, Avila Beach.,

Cali=amia, November 4, 1976.

12 Testimony by . G. Briden~augh .before the U.S. Nuclear Regulato=

Commission, subject, Diablo Canyon Nuclear Plant Perzormss ance, Aeomic Safety and Licensing Boarci Hearings, December 1976..

13. mony by D. G. Bridenbaugh be "ore the Cal'ornia Energy 'est.

Commission, subject, interim Spent Fuel S torque Consicierations, Y~rcn 10, 1977.

L4. Testimony by D.'G. Bridenbaugh before New York State Puolic Service Co~ssion Siting Board Hearings conc ming the Jamespo-

'Nuclear Power Station, subject: E feet of Technics>'nd Safety Def'iencies on Nuclea- Plant Cost and Rel'bility,April 1977.

Testimony by D. G.'ridenbaugh be~ore ehe California State Energy Commission, subject, Decossion'n" o Pressuri"-e 4'ates Reactors, Sunciesert Nuclear Plant Hear ngs, June 9, 1977.

16. estimony oy D. G. Bricienbaugh before the California State Energy Cession, suoject, Economic Relationsnios of.

Decorum" ssn onin~, Sundesert Nuclear Plant, for the Natural Resources Def ense Council, July 15, "977.

17. Testimony by D. G. Bricienbaugh before the Vermont Seat Board of Health, subject, Operation of Vermont Yankee Nuclear 1977. Plant and Tts Tract on Puolic Health and Sa=etv October 6,

18. Tes ti ony by D. G. Briden'oaugh before the U.S.

Comm'ssion, Atomic Safety ~d Licensing Board, Nuclez Regulato=

subjec", De='-

ciencies in Sa=etv Bvaluat on o= cion-Se"'snit Issues Lack of a Dezinitive Finding or Sazetv, Diablo Canyon Nuclear Units, Octooer Avi a Beacn, California.

19. Testimony by D. G. Bridenbaugh before the Norwegian Commission on Nuclear Power, subjece, Reactor Sa eev/Risk, October 26, 197.

20. Tes timony by D. G. Bridenb augh before the Louis iana State Legis-lature Commit tee on Natural Resources, sub j ect, NuclearBaton Power P1ant Deficiencies Imoactinz on Safety 6 Reliabi tv, Rou g e Louisiana, Februa 13, 1978.

21. Spent Fuel Disposal'osts, report prepared by D.G. Bridenbaugh or the Natural Resources Defense Council (NRDC), August 31, 1978.

22. Testimony by D.G. Bricienbaugh, G.C. Hinor, anci R.B. Huooard er of before the Atomic Safety and Licensing Board, in the mat Hearings the Black Fox Nuclear Power Station Construction Permit Sep temoer 25, 1978, Tulsa, Oklahoma.

.4p

~ ~

,PUBLXCAT10NS AND TZSTIifONY

23. Testimony oz D..G. Bridenbaugh and. R.E. Hubbard before the Louisiana Public Service Coaznission, Nuclear Plant and Po -er Generation Costs, November 19, 1978, Baton Rouge, Louisiana.

24. Test'-ony by D.G. Bridenbaugh before tne City Counc.l and ect-ic Utility Commission oz Austi'n, Tezas, Des. w, Con-Eac ities, Decem er a, z, Aus tin, Texas 4i ii

-"-:3 March 10, 1980 Mr. Hark P. Oncavage 12200 S.W. 110th Avenue CPM elf$8.re% <<:NA.

Rou In the Matter of Florida Power and Light Company (Turkey Point Nuclear Generating Unit Nos. 3 and 4)

Docket Nos. 50-250 & 251

Dear Mark:

Per your request of Marshall Grotenhuis of the NRC Staff, I have enclosed copies of the most recent l.icense amendments, involving the Turkey Point steam generator inspections and tube plugging. Please direct any future such in-quiries to me.

S inc erel y, Steven C. Goldberg Counsel for NRC Staff, f

Enclosures:

Amdt. 43 to Unit 4,. dated Dec.. 14, 1979 Amdt. 52 to Unit 3, dated Jan. 25, 1980 Amdt. 44 to Unit 4, dated Feb. 22, 1980 cc w/o encl.:-

Neil Chonin, Esq. Internal Distribution:

Harold F. Reiso, Esq. NRC 'Central OELD-FF (2)

Shapar/Enqelhardt Christenbury/Scinto Goldberg/Chron (2)

Olmstead

,Moore M.Grotenhuis - 316 Phillips "g OrrICC~ OELD J'CGoldberg.e OQ IMIAII4 W OATa~ 3@O/8O SEC PORSC 318 (9.76) NRCSC 0240 5 Vol OOVRRRMRRT MIRTIRO ORPICRI I ~ 1 ~ N$ 70 ~

4 I