ML17339A976

Request for Production of Documents Directed to Licensee Re Proposed Amends to OL to Permit Steam Generator Repair. Requests Health Physics Manual,Facility Procedures,List of Prospective Witnesses & Insps Tests.Certificate of Svc Encl

ML17339A976
Person / Time
Site:	Turkey Point
Issue date:	03/18/1980
From:	Chonin N CHONIN, N., ONCAVAGE, M.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8005050015
Download: ML17339A976 (74)

Text

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>ci;iR c 4:"uu ~ UNITED STATES OF AMERICA QJflvB oi 9L S~~X NUCLEAR REGULATORY C01'SCISSION BEFORE THE ATOMIC SAFE Y AND LICENSING BOARD

'THE fMTTER OF Docket No . 50-2 -SP l -251-SP FLORIDA POWER & LIGHT COMPANY, (Proposed Amendments to (Turkey Point Nuclear Facility Operating License Generating Units Nos. 3 6 4) To Permit Steam Generator Repair)

INTERVENOR, MARK P. ONCAVAGE'S REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM LICENSEE', FLORIDA POWEP. AND'IGHT COIIPANY Pursuant to 10 CFR f52.740 and 2.741, Intervenor, PARK P. ONCAVAGE, requests the production by Licensee, FLORIDA POWER AND LIGHT (FPL), o+ the following documents:

I. DEFINITIONS

l. "You" or "your" means Licensee corporation, any subsidiary or division owned or controlled in whole or in part, any property or interest owned or controlled in whole or in part, any predecessor or successor enti'ty, any agent, attorney, consultant, employee, representative or officer acting on behalf of'orporation or entity.

2. "Document" means each tangible thing recording or re-producing, in any manner, any visual or auditory data in your possession, control or custody, including without limiting the generality of its meaning, correspondence,-, memoranda, transcripts, photographs, stenographic or handwritten notes, studies, evaluation, analyses, reports, reviews, working papers, books, charts, telegrams, pamphlets, pictures, video or audio tapes, voice recordings, computer tapes, printouts or cards, micro ilming,

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microfiches, and any papers on which words have been written, printed, typed, or otherwise affized, and shall mean a copy where the original is not in the possession, control or custody of plaintiff, and shall mean every copy of every document where such copy is not an identical copy of an origina'1 ~

II. INSTRUCTIONS A. In producing these documents, you are requested to furnish all documents known or available to you regardless of whether these documents are possessed directly by you,. or by your agents, employees, representatives, or investigators, or by your attorneys or their agents, employees, representatives or investigators.

B. If any of these. documents cannot be produced in full, produce them to the extent possible, specifying your reasons I

for your inability to produce the remainder and stating whatever information, knowledge, or belief you have concerning the unproduced portion.

C. This Request is a continuing one. If, after producing the requested documents, you obtain or become aware of any further documents responsive to this Request, you are required to produce such additional documents to Intervenor.

D. With respect to those documents as to which you may claim privilege, attorneys'ork product or trial preparations,

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your counsel is requested to identify each such documents in writing on or before the date of production specified below, together with the following information; the nature, date,

Oi subject matter and author of any such document as well as the names and j ob titles, of all persons to or by whom such document was directed, addressed or received, and the paragraph of this reuqest to which such document responds. Your counsel is further required to set forth as to each document the basis for such claim.

E. 'he requested documents are to be produced at the offices of Neil Chonin or at such time and pl'ace as mutually agreed to by counsel for Intervenor, PARK P. ONCAVAGE, and FLORIDA POWER 6 LIGHT COMPANY, at which time someone acting on their behalf will examine originals or exact duplicate photographic copies of originals of the documents described below and designate which documents are to be reproduced for them. All documents should be produced in the same order and arrangement as they now exist. In making the production, FLORIDA POWER & LIGHT COMPANY should identify the title of the file drawer, file folder and subfolder in which the documents are contained.

III. DOCUMENTS'E UESTED

1. FLORIDA POWER 6 LIGHT COMPANY Health Physics '":.anual.

This document is relevant to the subject matter of this proceeding because FPL has indicated that it is of general applicability to Licensee's answers to Intervenor's interrogatories.

2. All documents which embody, refer or relate to Turkey Point Plant 'Procedur'es. The Turkey Point Plant Procedures are of general applicability to all of Intervenor's contentions.

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Intervenor is therefore in substantial need of all such documents in the-preparation of this case.

3. A list of the persons whom you intend to have testify as expert witnesses. Provide the name, address, educational background and professional qualifications of each such person.

4. All documents which you intend to employ in presenting a direct case. on the subject matter of this proceeding.

5. All documents which embody, refer or relate to the Turkey Point Plant approved chemistry specifications for the primary and secondary coolant systems which will be in effect at the time the new assemblies are placed into operation.

These chemistry specifications are relevant to Intervenor's Contentions 1 and 14.

6. All documents which embody, refer or relate to inspections or tests that are planned by you to assure contain-ment building and reactor coolant system integrity following the repair, including any revision to the SGRR. Such documents are applicable to Contentions 1, 2 and 3.

7. All documents which embody, refer or relate to local docontamination procedures which will be employed at Turkey Point, during and following the repairs; for equipment, structures and system components. Such documents are relevant to Contention l.

8. The Turkey Point Plant Emergency Procedure 20106, National Emergencies, the site Emergency Plan and any other procedures which would be followed by you in the event of a

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hurricane during or subsequent to the steam generator repair.

These documents are relevant to Contention 1 ~

9. All documents wh"'ch refer or relate to your determination of the estimated capital costs for: a) the steam generator repair; and b) for operating the Turkey Point Plant before, during and after the repairs. Intervenor is in substantial need of these documents in the preparation of the case as it relates to Contentions 1; 2 and 13.

10. All documents which embody, refer or relate to the planned condensate polishing demineralizer system. Such documents are relevant to Contention 7.

ll. A copy of your response to the IKC Staff letter to Dr. Uhrig dated November 19, 1979.

12. All documents which embody~ relate or refer to the comparisons of water quality characteristics of Biscayne Bay

'~later, cooling canal water and Card Sound water regarding the estimates of environmental degradation caused by all aspects of the proposed repairs. The information contained therein is relevant to Contention 7 ~

13. All documents which embody the following procedures which have been identified by you and are used by you for monitoring surveillance, measurements and testing in the radio-logical environmental monitoring program:

Procedure Number Procedure A. Ouality Control Procedure for Collection, Identification and Reporting of Intralaboratory Ouality Control.

B. Quality Control Procedure for Analysis and Reporting

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of Intralaboratory Quality Control,.

Sampling Procedure for Air Sampling.

Sampling Procedure for Biota Sampling.

III. Sampling Procedure for Gamma Background.

IV. Sampling Procedure for Hater and Precipitation.

V. Sampling Procedure for Vegetation.

VI. Sampling Procedure for Food Crops.

VII. Sampling Procedure for Silt.

VIII. Sampling Procedure for Soil.

IX. Sampling Procedure for Algae.

Sampling Procedure for Milk.

XI. Sampling Procedure for Collecting and Identifying Samples for Intralaboratory Quality Control Program.

XII. Sampling Procedure 'for Annual Garden Census.

XIII., Sampling Procedure for Milk-Semi Annual Dairy Animal Census.

Calibration of Thermoluminescent Dosimeters.

2. Calibration of Nuclear-Chicago Proportional Counter.

3. Calibration of Hewlett Packard Gamma Analyzer.

4. Calibration of Packard Tri-Garb Liquid Scintillation Spectrometer.

7. Calibration of Rockwell Gas Meters.

8. Calibration of Ion Chambers.

The foregoing procedures are relevant to Contention 9.

14. The reports containing the, test results of all environmental radiological sampling and analyses done since Turkey Point Units 3 and 4 began operations. This information

0 is relevant to Contentions 9 and 11.

15. The Turkey Point Technical Specifications and all other documents which embody, refer or relate to descriptions of the frequency, locations and dates of the most recent employ-ment of the monitoring procedures listed in Request )$ 13.

16. All documents which embody, refer or relate to the Critical Path Network Hethod,and all other methods used by you to determine outage time. These documents are relevant to Contention 11.

17. All documents which embody, refer or relate to The Turkey Point Plant Area Radiation Monitoring System and Process Monitoring System and any other monitoring systems which will be employed by you during the repairs. These documents are .relevant to Contention 13.

18. All documents which embody, refer or relate to the design and specifications of the CUCS Holdup Tanks, including but not limited to blueprints, safety evaluations, and studies relating to durability. These documents are relevant to Contentions 13 and 3.

19. All documents which embody, refer or relate to procedures employed by you in the event of a fire at Turkey Point Plant, including but not limited to Turkey Point Emergency Procedure 20107. These documents are relevant to Contention 14.

20. All documents which embody, refer or relate to your load forecast used to plan future generating units, including but not P

limited to FPL's Ten Year Power Plant Site Plan 1979-1988.

21. All documents which embody, relate or refer to the details, progress, results and future projections of any

energy conservation measures undertaken or planned by you.

22. The report by Dr. Robert Yiunin entitled Disposal of Spent Powdex Ion Exchange iiaterials. This report is relevant to Contention 7.

23. All documents which embody, refer or relate to all studies or reports on demineralizer effluents which you have relied upon in making decisions concerning the proposed repairs.

24. The .document cited in the SGRR entitled "Decontamination of a PWR Primary System, SENA Plant.," Volume 33, Proceedings of the American Power Conference, 1971.

25. All documents which embody, refer or relate to any warranty agreements between you and westinghouse Electric Corporation pertaining to the new steam generator lower assemblies.

To the best of Intervenor's knowledge, the foregoing documents are not available in FPL's Local Public Document Room. Intervenor.

is therefore unable without undue hardship to obtain the sub-stantial equivalent of these materials by means other than this Request for Production.

CERTIFICATE'F SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this day of Narch, 1980 to the attached list of addressees.

LAN OFFICES OF NEIL CHONIN, P.A.

Attorneys for Intervenor 100 N. Biscayne Boulevard 30th Floor, New 'world Tower Hiami, Florida 33132 Phone: 377-3023 Nei Chonzn

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Mark P. Oncavage Harold F. Reis, Esq.

12200 S.W. 110th Avenue Lowenstein, Newman, etc.

Miami, Florida 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 Richard A. Marshall, Jr., Esq.

18450 S.W. 212th Street Miami, Florida 33187 Norman A. Coll, Esq.

14th Floor, S.E. 1st Natl Bank Bldg.

Miami, Florida 33131 Elizabeth S. Bowers Chairman, Atomic Safety and Licensing Board Panel U.S. Nucl'ear Regulatory Commission Washington, D.C. 20555 Dr. Oscar Paris Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

'(ETIO Dr. Emmeth A. Luebke Atomic Safety and Licensing Board Panel UsNRG U.S. Nuclear Regulatory Commission '

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Atomic Safety and Licensing Board Panel U.S. Nuclear REgulatory Commission C~~g Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Steven C. Goldberg, Esq.

'ffice 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, Fla 33314 Henry H. Harnage, Esq.

Counsel for Intervenor Peninsula Federal Bldg. 10th Floor 200 S.E. 1st Street Miami, Florida 33131

4l 0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY 6 LICENSING BOARD In the Hatter of Docket Nos. 5 P 50-251-SP FLORIDA PONER 6c LIGHT COMPANY (Proposed Amendments to Facility 'Operating License (Turkey Point:Nuclear Generating to Permit Steam Generator ~

Units Nos. 3 and 4) Repairs)

NOTION TO AbIENDCONTENTIONS Intervenor, Nark 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'o its facility operating license involves a material alteration of a licensed. facility which requires a construction p'ermit to issue prior to the issuance of the amendment, which in turn requires the preparation of an environmental impact statement.

'In support of his motion Intervenor shows:

1. Contentions 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. $ 2. 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 statement. [43 Fed. Reg.

17798, 17799 (1978)J

4l 3.. A contention can be amended only with the approval of the presiding officer based on a balancing of the factors listed in 10 C.F.R. $ 2.714(a) (1);

GOOD CAUSE FOR FAILURE TO, FILE ON TIME 4

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'EANS MH T T l.

INTEREST MILL'E 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 it 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 l

amendment to the operating license.

EXTENT TO LEIGH THE PETITIONER'S Z T 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

i of the licensed facility 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 S I TERSEST THE'TXTIONER XXSTING PARTIES 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 mater'ial alteration of the licensed facility as that term is defined in 38 Fed. Reg. 22796 (1973) and 39 Fed. Reg. 10554 (1974).

EXTENT TO VHICH THE MILL BROADEN THE'SSUES'R In the existing Contention 1 the Intervenor has contended that an Environmental Impact 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 vill be much broader than the inquiry required under Contention 1B. In order to avoid any delay, Contentions lA and 1B can be heard together as part of the same proceeding.

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

Under 10 C.F.R. g2-. 714(a) (3) a motion to amend contentions must satisfy the specificity requirements of 10 C.F.R. 52.712(a) (2).

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THE INTEREST OF'HE

'TTONE'TE PROCEEDING By order of this Board dated August 3, 1979, Mark P.

Oncavage is a party-intervenor in this cause.

HOW THE PETITIONER'S INTEREST MAY BE AFFECTED PROCEEDIN i At the present stage of this proceed'ing, the Intervenor is, the representative of the present genexation "as trustee of the environment for succeeding generations." See 42 U.S.C. 54331(b)(2). In this quasi-fiduciary position he has the responsibility to:

(1) assure for all Americans safe, healthful, pxoductive,'nd esthetically and cultuially pleasing surroundings;.

(2) attain the 'widest range of benefi-cial uses of the environm'ent without degxada-tion', risk to health or safety, ox other un-desirable and unintended consequences; (3) pxeserve 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 use which will permit high standards of living and a wide shaxing of life's amenities; and (5) enhance the quality of renewable xe-sources and approach the maximum'attainable re-cycling of depletable resources.

Additionally, Ilr. Oncavage, his wife and his son live

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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 be performed in a fashion. that will have as little adverse impact as possible on the natural environment. An obvious method for determining whether the repair activities will have a degr'ading 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, Mr.

Oncavage will be greatly affected by the preparation of an Environmental Impact St'atement.

SUBJECT MATTER OF THE THE CONTENTIONS If an 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,'.R'.C'.'r'o ram 'for the Resolution of Gen'e'ri'c Is'su'es'e1'a't'e'dt'o'u'clea'r Pow'er Plants, Category A Technical Activity No. A-3, U.S. N.R.lC. Jan.

1978.

It is stated in the Environment,. Impact Appraisal at g2.2 that As .of May 1979, tube plugging for various reasons has resulted in removing about 17.5%

of the .steam generator tubes in Unit, 3; and

.about 20.5% of'he 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 componen't configurations which will 'preve'nt 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 degradation.

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

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

After 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.

What 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

$ 2.2.1..1 that the increased circulation ratio will prevent and inhibit corrosion. Dr. Robert Anderson will testify that corrosion problems tend to increase with in'creases in fluid velocity. At higher velocities turbulence is more pronounced which results in "concentration gradients forming

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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 tubes would redistribute the already'existing sludge in a new manner causing further 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'o withstand winds of 120 m.p.h. The Intervenor will offer testimony of

0~ Qi hurricanes that have passed'hrough Dade 'County, Florida, along Biscayne Bay, with winds in excess of 120 m.p.h. In respo'nse to Interrogatory 6-35, Florid'a 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< Rr Attorneys for NARK A. ONCAVAGE, Intervenor

Ql 0 RESUME GREGORY C. MI NOR MHB Technical Associates 1723 Hamilton Avenue Sui te K San Jose, Cali fornia 95125 USilH<C (408) 266-2716 MAR 2 5 i920> 4 oftiCa oft Sr'.f:rg EOCKCUilg 5, SOP;iCZ P ~Ail EXPERIENCE 1976 - Present:

Partner - MHB Technical Associates, San Jose, California.

'En'gineering and Energy consultant to state, federal and private organizations and individuals. Major activities include studies of safety and risk involved in energy generation, providing tech-nical consulting to legislative, regulatory,,public and private groups and expert wi tness in behal f of state organizations and citizens'roups. Was co-editor of a critique of'he Reactor Safety Study (WASH-1400) for the Union of Concerned Scientists and coauthor of a risk analysis of Swedish reactors for the Swedish Energy Commission. Served on the Peer Review Group of the NRC/TMI Special Inquiry Group (Rogovin Commi ttee) . Acti vely invol ved in the Nuclear Power Plant Standards Committee work for the Instrument Society of America (ISA).

1972 1976:

Manager - Advanced Control and Instrumentation Engineering, General Electric Company, Nuclear Energy Division, San Jose, Cal i fo rni a.

Managed a desi gn and development group of thirty-four 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, safety systems, and new control concepts for use on the next generation of reactors. The posi tion included responsibility for standards appl icabl'e to control and instrumentation, as well as the design of short-term solutions to field problems. The disciplines involved included electrical and mechanical engineering, seismic design and process computer control/

prog'ramming.

4i .Oi 1970 1972:

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

Managed a group of seven engineers and two support personnel in the design and preparation- of the detailed system drawings and control documents rel.ating 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 Diversi.on, San Jose, California.

Responsible for the design of specific control and instrumentation systems for nuclear reactors. Lead design responsibility for various subsystems of instrumentation used to measure neutron f'lux in the reactor during star tup and intermedi'ate 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 patent for N'uclear Power Moni toring Sys tern.

1960 - 1963:

Advanced Engineering Program - General Electric Company, Assign-ments jn Washington, California, and Arizona.

Rotating assignments in a variety of disciplines:

Engineer Reactor maintenance and instrument design, KE and D reactors, Hanford, Washington, Circui t desi gn and equi pment maintenance coordination.

Desi gn Engineer - Microwave Department, Palo Alto, Cali-forn ia. Work on design of cavity couplers for TWT's.

Desi gn Engineer Computer Department, Phoenix, Ari zona.

Des i gn of core driving circuitry.

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

Design Engineer Space Systems Department, Santa Barbara, Cal i fornia. Prepare control portion of satel 1 i te proposal.

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Technical Sta'ff - Technical Military, Planning Operation.

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

During this period, completed three-year General Electric program of extensive education i,n advanced engineering principles of higher ma thema ti cs, probabi'1 i ty and analys is. Al so completed courses in Kepner-Tregoe, Effective Presentation, Management Training Program, and var ious technical seminars.

EDUCATION Uni versi ty, o'f Cal.i fornia at Berkel ey, BSSE, 1960.

Advanced Course in Engineering year Curriculum, General Elec tri c Company, 1963.

Stan ford Uni versi ty, 'MSEE, 1966.

HONORS AND ASSOCIATIONS Tau Beta Pi Engineering Honorary Society Co-holder of U.S. Paten't, No.',565,760, "Nuclear Reactor Power Monitoring System," February 1971.

Member: American Association for Advance of Science.

Member: Nuclear'ower Plant Standards Committee, Instru-ment Society of America.

PERSONAL DATA Born: June 7, 1937 Ma rri e d, three chi 1 dren Residence: San Jose,, California

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P VBL I CATI ONS AN D TES TI MONY G. C. Minor, S. E. Moore, "Control Rod Si gnal Hul tipl exing,"

IEEE Transactions on Nuclear Science, Vol. NS-19, February 1972.

2. . G.C. Minor, W.G. Hilam, "An Integrated Control Room System for a Nucl ear Power Plant," NED0-10658, presented at International Nuclear Industries Fair and Technical Me'etings, October 1972, Basle, Swi tzerl and.

3.. The above article was also published in the German Technical Magazine, NT, March 1973.

4 Testimony of G.C. Minor, D.G. Bridenbaugh, and R.B. Hubbard before the Joint Committee on Atomic Energy, Hearings held February 18, 1976, and published by the Union of Concerned Scientists, Cambridge, 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 California State Senate Committee on Public Util i ties, Transit, and Ene rgy, Ha rch 23, 1976.

7. Testimony of G. C. Minor regarding the Grafenrheinfeld Nuclear Plant, March 16-17, 1977, Wurzburg, Germany.

8. Testimony of G.C. Minor before the Cluff Lake Board of Inquiry, Regina, Saskatchewan, Canada, September 21, 1977.

9. The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Sa et Stu W SH-1400 NUREG-75/014, H. Ken a et al, edited by G.C. Hinor and R.B. Hubbard for the Union of Concerned Scientists, August 1977.

10. Swedish Reactor Safet Stud: Barseback Risk Assessment, HHB Technical Associates, January 1978. Published by Swedish Department of Industry as Document SdI 1978:1)

Testimony by G. C. Minor before the Wisconsin Public Service Commission, February 13, 1978, Loss of Coo'lant Acci dents:

The'ir Probabil i't and Conse uence.

12. Testimony by G. C. Minor before the Cali fornia Legis) ature Assembly Committee on Resources, Land Use and Energy, AB 3108, April 26, 1978, Sacramento, Cali fornia.

13.- Presentation by G.C. Minor before the Federal Ministry fo)

Research and Technology (BMFT), Meeting on Reactor Safety Reseat ch, Han/Machine Interface i*n Nuclear Reactors, August 31 and September 1., 1978, Bonn, Germany.

lf PUBLICATIONS ANO TESTIMONY

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14. Testimony by G. C.,Minor, D.G. Bridenbaugh, and R.B. Hubbard before the Atomic Safety and Licensing Board, September 25, 1978, In the Matter of the B1ack Fox Nuc1ear Power Station Construction Permit Hearings, Tu1sa, Ok1ahoma.

15. G.C. Minor, D.G. Bridenbaugh, and R.B. Hubbard, Im rovin the Safet of LMR Power'1a'nts, prepared for Sandia Laboratories by HHB Techni ca Assoc'tes, September 27, 1979.

0 Cg BIOGRAPHICAL DATA ooc'x=-~<~

Qsg)P<,NR 2 6 ~-~~ +

NAME: Robert Neil Anderson gp Cdgg~

'g+<,gc fc GPati ADDRESS: ilork: Department of Materials Engineering BParc.

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Home:

San Jose State University, San Jose, California 95192 (408/277-3751 or 277-2446) 3084 Stelling Drive 9 /

p Palo Alto, California 94303, (4151494-7824)

PERSONAL'NFORMATION:

Date of Birth: Novenber'8, 1933 Place of Birth: San Jose Marital Status: Married; two children EDUCATION B.S., Chemistry, University of San Francisco, 1956 B.S., Chemical Engineering, University of California - Berkeley 1958 M.S., Chemical Engineering, University o. California - Berkeley 1959 Ph.D., Metallurgy, Stanford University, Doctoral Study in Metallurgy - Stanford University, 1970-1973 1969'ost PROFESSIONAL'EXPERIENCE:

Academic:

San Jose State University, Professor 1978 - Current, San Jose State University, Associate Professor, 1974-78 Stanford University, Associate Professor, 1973-74 Stanford University, Research Metallurgist', 1972-73 Stanford University, Post Doctoral, Research Associat'e, .1970-72

. University of California, Berkeley, Research Assistant, 1958-59 University of San Francisco, Chemist, 1955-56 Industrial:

U.S. Naval Radiological Defense Laboratory, Operations Research Analyst, 1966-69 U.S. Naval Radiological Defense Laboratory., Research Engineer, 1959-66 Arabian American Oil Company, Chemist, 1954-55

PROFESSIONAL' EXPERIENCE (continued)

Consulting:

California Public Utilities Commission, 1979 Standard Oil Company of Indiana, 1978 - present Lawrence Livermore Laboratory, 1978 - present Radiological 'Science Inc., 1977 - present California State Energy, Resources and Development Commission, 1977-79 Executive Office of. the President of the United States Council on

. Environmental guality 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 HcDermitt Mine, 1976 - present International Business Machines, 1977-78 Memorex, 1979 Electrical Power Research Institute, 1974 SRI, 1975-77 Brookhaven National Laboratories, 1977-78 Attornies (list on request)

PROFESS IONAL'ACTIVI TIES:

American Nuclear Society, American Institute of Chemical Engineers, Amer ican Chemical Society, American'Institute of Metallurgical Engineers (Past Chairman of Northern California Section),

American Society of Metals, 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'L'ICENSES'alifornia Standard Teaching Credential, Registered Metallurgical Engineer, California.

Registered Nuclear. Engineer, California, Fallout Shelter Analyst.

Private Pilots License.

PUBL'ICATIONS:

Articles:

1. "The Activity of"Titanium in-.Liquid-Alloys," Accejted for'publication and presentation in the 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,'roceedings in 2nd Miami International Conference

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PUBLICATIONS (conti nued) on Alternative Energy Sources, 10-13 December 1979, Miami Beach, Florida.

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

Nuclear Engineerin International,'Octob r, 1979.

"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, Museum).

6. "Analysis of the Infrastructure of the Front End of the Uranium Fuel.

Cycle," San Jose State University, Materials Engineering Department, technical report, prepared for the California Public Utilities Comnission

'(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 Availability through the'Year '2010," San Jose State University, Materials Engineering Department, report prepared "for the California Public Utilities Commission (July 1, 1979).

9. "The Mineral Industries and the Challenges of the 80's," paper presented to the Pacific Southwest Minerals Conference, San Francisco March 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'ublication 1979.

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

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

12. "Let's Use MHD to Smelt Metals: Industrial Research/Development September 1978 (p.p. 131-34}.

13. "The Application of Magneto. 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, Mashington, D.C.

15. "Separation Technologies Reviewed," Nuclear. Engineering International, August, 1978.

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PUBLI CAT IONS ( continued )

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

17. "Examinations of Radioactivity and Environmental Aspects of Antartic Soils at Point Hueneme," report to the California Solid Waste Board, July,, 1978.

18. Invited contributor to the Executive Office of the President of the United States document on Nuclear Power and Nuclear Haste Disposal for the President of the. United States, June, 1978.

19. "Technical Review of the Deutch Draft Report on Nuclear Waste Management," for the Council on Environmental guality, Executive Office of the President of the Unites States, May, 1978..

20. "A Technical Assessment of Nuclear Fuel Reprocessing and Radioactive Waste Disposal," report to State of California Energy Resources Conservation and Development Commission, March, 1978.

21. -"A Program Assessment of Nuclear Fuel Peprocessing and Radioactive Waste Disposal," report to State of California Energy Resources Conservation and Development Commission, January, 1978.

22. "Methodology for Comparative Evaluation of Nuclear Fuel Reprocessing Techniques for Advanced Low Proliferation Risks," Proceedings of the First International Conference on Alternative Energy Sources, December, 1977, Coral Gables, Florida.

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

24. "Survey of Reprocessing Technologies," Brookhaven National Laboratories Report 23082, June, 1977.

25. The Physical 5 Chemical Characteristics of Titanium-Copper Alloys,"

Technical Report to Regalware, 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 Research May, 1976.

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

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

0 PUBL'ICATIONS (conti nued)

30. of Mineral Waste Utilization Processes and Strategies by Net Energy Analysis," Proceedings of the Fifth Mineral Waste Utilization Symposium, April 13-14, 1976.

31. "Available Supply of Gallium and Arsenic,"

'Evaluation prepared for NASA Langley Research Center, Va., April 1976.

32. "Carbothermic Reduction of Refractory Metals," J. of Vacuum Science 8 Technology, V. 13, No. 1, Jan/Feb 1976; "Nuclear Plant Can Make Gold," San Jose News, March 20, 1975; "What to Do With Atomic Waste,"

San Jose News, 1975.

33.. "Thermodynamics of Nitride Formation 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. Molten Y-Sn Alloys, "Journal of High Temperature Science, V. 6, 1974'.

36. "The Kinetics of Uranium Nitride'Formation in U-Sn Alloys," Journal of High Temperature Science, V.',6, 1974.

37.. "Thermodynamics of Nitride Formation in, Liquid U-Gd-Sn Alloys,"

Journal of High Temperature'Science, Abstract in Journal of Metal, January, 1974.

38. "Nitrogen-Nitride Equilibria in Molten Y-Sn Alloys," Submitted to the Journal of High Temperature'Science, (with A-FUWA and N.A.D. Parlee).

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

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

40. . Application of Solution Thermodynamics in High. Temperature Metallurgical Processes, Proc.'f 67th Meeting of the Amer'ican Institute of Chemical Engineers, Dec. 1-.15, 1974.

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

4'2. "Nitrogen-Nitride Equilibria in Molten Gd-Sn Alloys," Journal of High Temperature Science, V. 5, 1973.

43. "Nitrogen-Nitride Equilibria in Molten Gd-Sn Alloys," Journal of High Temperature Science, V. 5, of Fission Products in Nitride Fueled Reactor,"

1973.'Continuous

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

~I PUBLICATIONS (continued)

45. "Application of Ni-tride-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 Comnon Metals, V.; 25, December 1971 '(427-430).

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

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

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

50. "The Contamination-Decontamination of Fission Products in Sea Water," Nuclear Detonations and Marine Radioactivity Symposium, Kjeller, Norway, 1963.

51. "Two Phase Heat Transfer," Industrial and Engineering Chemistry, Y. 51, 1959.

PATENTS ISSUED IN THE FIELD OF MATERIA S SCIENCE:

U.S. Patents 3,794,482 Feb. 26, 1974 3,843,765 Oct, 22, 1974 3,843,766 . Oct. 22,. 1974 Canadian 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,'34'4,950 Jan. '18, 1971 1,323,474 Nov. 13, 1970 1,323,475 Nov. 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 k(. Germany 2,103,255 Jan. 25, 1971 U.S. Patent Appl.ications 905,745 filed May 15, 1978 038,382 filed May 14, 1979

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Dale G. Bridenbaugh 1723 Hamilton Avenue, Suite San Jose, CA 95125 (408)266-2716 office 6f the Secre>erg g B)cg",bi1$ 8 Zpp,'ic>>

EXPERIENCE;.'

1976 Pres ent:

Partner, MHB Technical Associates, San .Jose California. Founder and partner ol: tec nx,ca consu t~ng rz.rm. peer,a zsts xn energy consulting to governmenta1. and other groups interested in evaluat:ion of nuclear plant safety and licensing. Consultant in this capacity to State Nor- of California, Suffolk County,,New York, New York Attorney General, wegian Nuclear Power Committee, Public Advocates Office, New Jersey, and various other organizations and environmental groups. Performed extensive safety analysis for Swedish Energy Commission and contributed to Union of Concerned Scientists 'eview of MASH-1400; consultant to U.S. NRC - LWR Safety Improvement Program, and performed Cost Analysis of Spent Fuel Disposal for NRDC.

1976 - (February - August)

Consultant, Pro ect Survival, Palo Alto, California. Volunteer work on Nuc ear Sazeguards Initiative campaigns in Ca i ornia, Oregon, washington, Arizona, and Colorado. Numerous presentations on nuclear power 'and alternative energy options to civic, government, and college groups. Also resource: person for public service presentations on radio and television.

1973 - 1976 er, Performan'ce Evaluation and Improvement, General Electric Mana Co an - Nuc ear Ener seventeen tec @ca an seven c esca i

Division, San Jose, Ca ornia. Managed personne wz. responsibility for establishment and management of systems to monitor and measure Boiling Hater Reactor equipment and system operat:ional performance.

Integrated General Electric resources in customer plant modifications.,

coordinated correction of causes of forced outages and of efforts to improve reliability and performance of BWR systems.

Responsible for development of Division Mast:er Performance Improvement Plan as well as for numer'ous Staff special assignments on long-range studies. Was on special assignment for the management of two different ad hoc projects formed to resolve unique technical problems.

1972 - 1973 Mana - Nuclear Ener er, Product S'ervice, General E'lectric Comtian twenty-one Division, San Jose, Cali. ornia. Managed group o was to direct technical an our c era,ca personne . - Prime responsibility inter-face and liason personnel .involved in corrective actions required under contract warranties. Also in,charge of refueling and. service planning, all performance analysis, and service communication functions supporting Electric completed commercial nuclear .power reactors supplied by General both domestic and overseas (Spain, Germany, Italy, Japan, Tndia, and Switzerland) .

-0 1968 1972 Manager, Product Servi.ce, General Electric Comoan Nuclear Ener Di~sion, an Jose, Ca x, ornia.

Managed, sixteen technical and, six clerical personnel wi,th the responsibility for all customer contact, planning and execution of work required after the customer acceptance of Department supplied plants and/or equipment. This included quotation, sale and delivery of spare and renewal parts. Sales volume oZ parts incxeased fxom $ 1',000,000 in 1968 to ovex'3,000,000 in .1972.

1966 - 1968 Mana er Comolaint and Wazxant Se C Nuc ear En'er 'ivision, San Jose California.

Managed group of six persons with the responsibility for customer contacts, planning and execution of work required aSter customer acceptance of Department - supplied plants and/or equipment .--

both domestic. and overseas.

1963 - 1966 Field'ngineerin Su ervisor, General Electric Comoan installation ana exv ce n xneerzn Department Los An eles California.

Supervised approximately eight field representatives" with responsi-bility for General Electric steam and gas turbine installation and maintenance work in Southern California, Arizona, and Southern Nevada.

During this period was responsible for the installation of eight different central station steam turbine generator units, plus much maintenance activity. Work included customex contact, preparation of quotations, and contract negotiations.

1956 - 1963

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Field, En ineer General Electric Comtian installation and Service En ineerin De artment Chica o Tllinois.

Supervised installat ion and maintenance of steam turbines of all sizes.

Supervised crews of from ten to more than one hundred men, depending on the job. Work primarily with large utilities but had significant wox'k with steel, petroleum and other process industries. Had four years of experience at construction, startup, trouble-shooting and refueling. of the first laxge-scale commercial nuclear power unit.

1955 - 1956 Engineering Training Program, General Electric Company, Erie, ennsy vane.a, an cneneccaay, c ew orz,.

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

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1953 - 1955 United States A -. Ordnance School, Aberdeen, Iw~ land Instructor - Heavy Artillery Repair. Taught classroom and shop disassembly of artillery pieces.

1953 En ineerin Trainin Pro ram, General Electric Comoan, Kvendale, io; tzaining assignment wi Aizczazt Gas Tnz z.ne Depaztment.

EDUCATION 6c AFFILIATIONS BSME 1953 South Dakota School of Mines and. Technology, Rapid City, South Dakota, Upper > of class.

Professional Nuclear Engineer - California. Certificate No. 0973.

Member American Nuclear Society.

Various Company Training Courses during career including Professional

.'Business Management, Keener Tregoe Decision Making;, Effect.ve

.Presentation, and numerous technical seminars.

HONORS 6c AWARDS Sigma. Tau - Honorary, Engineering Fraternity.

General Managers Award, Gener'al Electric Company.

PERSONAL DATA Born November 20, 1931, ".liller, South Dakota Married, three children.

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

Honorable discharge from United States Army.

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

~i i PUBLlCATXONS 6 TESTTMOKY 0 crating and Maintenance Experience, presented at Twelfth Annua em2.nar or E ectric Uti ity Executives, P.ebble Beach, California, October 1972, published in General Electric NEDC-10697, December 1972.

2. Maintenance and Zn-Service Xns ection, presented at on- Experience From Operating and Fueling of Nuclear 3M'mposz.um, Power P1ants,'ridenbaugh, Lloyd, 6 Turner, Vienna, Austria, October 1973.

3. 0 ezatin and Maintenance Experience, presented at Thirteenth Annua emznar or ectn.c tx. sty Executives, Pebble Beach, California, November 1973, published in General Electric NEDO-20222, January 1974.

Xamrovin Plant Availabili ., presented at Thirteenth Annual eao.nar or E ectrzc Utx, z.ty Executives, Pebble Beach, California, November 1973, published in General Electric NED0-20222, January, 1974.

Av lication of Plant Outa e Experience to Improve Plant Pex-oxmance, Bra. en aug an Bur sa , Amerxcan Power Con erence, K g, 111 . Ap 1 10, 1974.

6. Nucle'ar Valve Testin Cuts Cost, Time, Electxical world, October Review of the

7. The Risks abet et. a,

'uorof Nuclear H-e Unz.on Power Reactors:

, Ken a , Hu A

ar Mnor, Br~

of Concerned Scientists, August 1977.

NRC en Reactor aug

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8. Swedish Reactor Safe Stud: Barseback Risk Assessment, >KB e'c xca ssocxates, anuary . u z.s e y we sh Depart-ment of Industry as Document DsZ 1978;1)

9. Testimony ox D. G. Bridenbaugh, R. B. Hubbard, G. C. Minor to the California State Assembly Committee on Resources, Land Use, and Energy, March 8, 1976.

10. Testimony of D. G. Bridenbaugh, R. B. Hubbax'd, and G. C. Minor before the United States Congress, Joint Committee on Atomic Energy., February 18, 1976, washington, DC. (Published by the Union o f Concerned Scientis ts,, Cambridge, Massachusetts. )

Testimony by D..G. Bridenbaugh before the California Energy Commission, .entitled, lnitiat on of Catastroohic Accidents at Diablo Can on, Hearings on Emergency Planning, Avila Beach, Califnxnia, November 4, 1976.

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12. Testimony by D. G. Bridenbaugh before the U.S. Nuclear Regulatory Commission, subject, Diablo Can on Nucleaz'lant Performance, Atomic Safety and Licensing Board Hearings, December 1976.

13. Testimony by D. G. Bri.denbaugh before the California Enezgy Commission, subject, Interim Spent Fuel .Stora e Considerations, March 10, 1977.

Testimony by D. G. Bzidenbaugh befoze New York State Public Service Commission Siting Board Hearings concerning th'e Power Stations subject: Effect of Technical and Sazet Jamesport'uclear Deficiencies on Nuclear Plant Cost and Reliabili ,April 1977.

15. Testimony by D. G: Bridenbaugh before the California State Energy Commission, subject, Decommissioning of Pressurize Rater Reactors, Sundesert Nuclear Plant Hearings, June 9, 1977.

16: Testimony by D. G. Bridenbaugh before the Califoznia State Energy Commission, subject, Economic Relationshivs of Decommissionin, Sundesert Nuclear Plant, for the Natural Resources Defense Council, July 15, 1977.

17. Testimony by D. G. Bridenbaugh before the Vermont State Board of Health, subject, Operation of Vermont Yankee Nuclear Plant and Tts Impact on Public Health and Sa etv October 6, 1977.

18. Testimony by D. G. Bridenbaugh before= the U.S. Nuclear Regulatory Gummiest.on, Atomic Safety and Licensing Board, subject, Defi-ciencies in Sa~e Evaluation of Non-Seismic l'sauce Lack of a De initive Findin o Sa e , Biablo Canyon Nuclear Units, Octo er , , Avi a Beac , California.

19. Testimony by D. G. Bridenbaugh before the Norwegian Commission-on Nuclear Power, subject, Reactor Safet /Risk, October 26, 1977.

20.

P1DeI'sf Testimony by D.

Rouge, Loui,siana, G. Bridenbaugh before the Louisiana State Legis-lature Committee on Natuzal Resouzces, subject, Nuclear Power February 13, 1978.

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

22. Testimony by D.G. Bridenbaugh, G.C. Minor, and R.B. Hubbard before the Atomic Safety and Licensing Board, in the matter of the Black Fox Nucleaz Power Station Construction Permit Hearings, September 25, 1978, TuLsa, Oklahoma.

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PUBLlCATXONS,AÃ3 TESTlNONY 23., Testimony of D.G. Bridenbaugh and R.B. Hubbard before the Louisiana Public Service Commission, Nuclear'lant and Power Generation Costs, November 19, 1978, Baton Rouge, Louisiana.

24. Testimony by D.G. Bridenbaugh before the City Council and Electric Utility Commission of Austin, Texas, Desi, Con-s true ti'on, and'peratin Experience o f Nuclear eneratxn Faci ities, Decem er Austin, Texas

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY 6c LICENSING BOARD In the Matter of Docket Nos. 50-250-SP 50-251-SP FLORIDA POWER Bc LIGHT COMPANY (Proposed Amendments to Facility Operating License

'to (Turkey Point Nuclear Generating Permit Steam Generator Units Nos. 3 and 4) Repairs).

CERTIFICATE'F SERVICE I HEREBY CERTIFY that a true copy of the foregoing Motion to Amend Contentions was mailed this 11th 9a<< of March, 1980, to the following individuals:

Norman A. Coll, Esq.

Steel, Hector 6 Davis 14th Floor Southeast First National Bank LfN~ 2 6 i660>

Building Miami, Florida 33131 Otiics o7 8s Screlarg Ssrhi~x a Anim

- WivllA Elizabeth S. Bowers, Esq. 0~

Chairman Atomic Safety and Licensing Board Panel 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

i i 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 6 Toll 1025 Connecticut Avenue, N. W.

. Washington, D. C. 20036

.ENRY H. HARNAGE 'J

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