ML17339B055
| ML17339B055 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/22/1980 |
| From: | Coll N FLORIDA POWER & LIGHT CO., STEEL, HECTOR & DAVIS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8005280014 | |
| Download: ML17339B055 (46) | |
Text
0/ DocKEzEb USNRC UNITED STATES OF AMERICA 6 APR2 9 1980 p NUCLEAR REGULATORY COMMISSION. office of the SecretaO Dociretfng & Service BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ~ Branch
) Docket Nos. 50-250-SP
) 50-251-SP FLORIDA POWER & LIGHT COMPANY)
) (Proposed Amendments to (Turkey Point Nuclear Gen- ) Facility Operating crating Units Nos. 3 and 4 ) Licenses to Permit Steam
) Generator Repair)
)
)
LICENSEE'S RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS For its response to "Intervenor'ark P. Oncavage's Request For the Production of Documents from Licensee, Florida Power And Light Company" served March 18, 1980, FPL says:
- 1. The current-FPL Health Physics Manual will be produced, as previously indicated in responses served by FPL 12-17-79 to Request 2-32.
and 1""1;bd oppressive; not designed to lead to discovery of admissible evidence.
Response. Most of the Turkey Point Plant Procedures are not applicable to the steam generator repairs.
FPL has previously indicated it will produce identified proce-dures which have been requested that are applicable. See, e.g.
responses served by FPL 12-17-79 to Requests 13-3, 13-4, 13-6
(as revised 1-31-80), 13-9, 13-10, 13-13, 13-14, 13-15, 13-16, 13-19, 14-16, 14-17, 14-19, and responses served by FPL 1-31-80 to Requests 1-19, 1 20 2-31g 9 1g 13 5g 14 24
'b'
. p list is an improper discovery request under 10 CFR 2.741.
Response. As previously indicated in'esponses served by FPL 1-31-80 to Introductory Request E, FPL has not at this time identified the persons whom FPL intends to have testify as expert witnesses. When it does so, FPL will provide the Intervenor with the requested information.
- 4. As previously indicated in Responses Served by FPL 1-31-80 to Introductory Request G, FPL has not yet identified the documents that it intends to employ in presenting a direct case on the subject matter of the proceeding. When it does so, it will provide Intervenor with a list of the documents and, to the extent they have not been previously made available, will make. them available for inspection.
coolant chemistry specifications are "relevant h'rimary/secondary to Intervenor's Contentions 1 and 14", the statement is incor-rect, in that Contention 1 is now moot, and Contention 14 addresses fire protection.
Response. As previously indicated in responses served by FPL 1-31-80 to Request 1-10, FPL will'maintain coolant chemistry withi:n the new steam generatory assemblies in
accordance with the Turkey Point Plant approved chemistry i
specifications in effect at the time the new assemblies are placed into operation. FPL's chemistry specifications are continuously being reviewed by plant and technical support personnel to assure state of the art. FPL does not know at this time what precise specifications will be in effect following the steam generator repair.
- 6. As previously indicated in responses served by FPL 1-31-80 to Request 1-14, the Board has ordered FPL to provide information either in a revision to the SGRR or in testimony concerning the tests that are planned to assure containment building and reactor coolant system integrity following the repair. FPL will provide this information to the Board and the parties when
- 7. ~.
it is available.
h' information concerning local decontamination procedures are relevant to Contention 1, the statement is incorrect, in that Contention 1 is now moot.
Response. Current local decontamination procedures will be produced; same may be revised prior to the repair. Additional procedures are planned but not yet finalized.
for the repair.
- h. ~h' . " * "'
information concerning emergency procedures are relevant to Contention 1, that statement is incorrect, in that Contention 1 is now moot.
Response. As previously indicated in responses served by FPL 1-31-80 to Request 1-19 current Turkey Point Plant Emergency Procedure 20106, National Emergencies, and the Site Emergency Plan will be produced. Existing procedures are 9
9 currently being revised as part of an on-going emergency planning update.
- 9. ~b' . b'* 9 Production to the extent it seeks "All documents which refer or relate to your determination of the estimated capital costs for operating the Turkey Point Plant before, during, and after the repairs" on the grounds that it is vague and ambiguous, unlimited in scope as to time, irrelevant and immaterial to the issues and subject matter of the proceeding and not designed to lead to the discovery of. admissible evidence. Moreover, Inter-venor previously withdrew, upon objection, similar discovery requests. See, e.g. Request 1-33, withdrawn by Intervenor in his "Responses" served 12-17-79, p. 16.
Response. FPL will produce those documents which summarize the current estimate of capital costs for the steam generator repair.
- 19. ~b' . g ." 'g"" ~ b 9 oppressive, not designed to lead to the discovery of admissible evidence. Contention 7 relates only to the cost of, effluent releases from, and environmental degradation caused by a full flow condensate demineralizer system. FPL has provided such
information on 1-31-80 in response to Requests 1-30, 7-2, 7-3, 7-4, 7-11, 7-12, 7-16, 7-18, 7-23, 7-24 thru 7-27, and on 12-17-79 in response to Requests 7-1, 7-7, 7-14, 7-19, 7-20, 7-21, 7-22, 7-24, 7-25, 7-26, 7-28, and in the letter of March 18, 1980 from Dr. Robert E. Uhrig of FPL to the office of Nuclear Reactor Regulation in reply to the NRC staff letter of November 19, 1979, a copy of which was sent to the Board and the parties.
ll. A copy of the letter of March 18, 1980, in response to the NRC staff letter to Dr. Uhrig dated November 19, 1979, was provided to the Board and the parties March 21, 1980.
- 12. No specific document was prepared which contains the comparison. The documents which contain the information which was compared will be produced.
- 13. As indicated previously in its Response 1-31-80 to Request 9-1, these procedures will be produced.
- 14. Objection. Vague, ambiguous, irrelevant and immaterial, burdensome and oppressive, not designed to lead to the discovery of admissible evidence.
Response. FPL will produce copies of the annual reports it files with the Nuclear Regulatory Commission, and copies of the State of Florida, DHRS, reports to FPL, for the past 3 years.
- 15. The documents requested will be produced.
- 16. FPL will produce documents which contain a brief description of the Critical Path Network Method as employed by
FPL in connection with the steam generator repair program, and summary schedules concerning outage time for the repairs.
- 17. The various monitoring systems are referenced in the FSAR, in documents which contain descriptions of the systems, and in various other documents related to calibration, operation, maintenance, technical manuals, and drawings. The FSAR is equally available to Intervenor. FPL will produce the documents which contain descriptions of the systems. FPL objects to the production of any other documents on the grounds that the request is vague, ambiguous, burdensome and oppressive, lacks specificty, would require FPL to examine, review and compile a substantial amount of documents, and is not designed to lead to the discovery of admissible evidence.
- 18. FPL will produce documents related to design and specifications of the CVCS holdup tanks. The safety analysis is provided in the FSAR. FPL has no studies relating to durability.
- 19. As previously indicated in its response 1-31-80 to request 14-24, procedure 20107 will be produced. Other.
procedures to be employed in the event of a fire will be produced.
- 0. ~.
FPL's "load forecast used f ' '
to plan future generating units, g
including but. not limited to FPL's Ten Year Power Plant Site Plan 1979-1988" is irrelevant and immaterial to the issues and subject matter of the pending proceeding and not designed to lead to the discovery of admissible evidence.
E " 'E" the ". . . details, progress, results, and future projections of any energy conservation measures undertaken or planned by FPL is vague and ambiguous, unlimited in scope as to time, irrelevant and immaterial to the issues and subject matter of the pending proceeding, and not designed to lead to the discovery of admissible evidence.
- 22. A copy of the report requested has been provided to the Board and the parties March 21, 1980.
- 23. See response to Request 22.
- 24. FPL does not now have this document in its possession.
1 similar objection to similar previous Request 1-3 seeking the same document. On January 24, 1980 the Board entered an order which sustained that objection, specifically holding that the warranty "is not relevant to the health and safety and environ-mental concerns in this proceeding".
Respectfully submitted, STEELg HECTOR 6 DAVIS Co-Counsel for Licensee 14th Floor Southeast First National Bank Building Miami, Fl ida 33131 By:
Norman A. oil Dated: April 22, 1980 cc: See attached Certificate of Service.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-250-SP
) 50-251-SP FLORIDA POWER & LIGHT COMPANY )
) (Proposed Amendments to Facility (Turkey Point Nuclear, Generating ) Operating License to Permit Units Nos. 3 and 4) ) Steam Generator Repair)
CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of the attached Licensee's Response to Request for Production of Documents captioned in the above matter were served on the following by deposit in the United States mail, first class, properly stamped and addressed, l
on the date shown below.
Elizabeth S. Bowers, Esquire Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Oscar H. Paris Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washing ton, DC 20555
Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Mark P. Oncavage 12200 S. W. 110th Avenue Miami, Florida 33176 Docketing and Service Section Office of the Secretary U.S. Nuc'lear Regulatory Commission Washington, DC 20555 Steven C. Goldberg, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 Neil Chonin, Esquire Law Offices of Neil Chonin, P.A.
Counsel for Intervenor New World Tower Bldg., 30th -Flr.
100 N. Biscayne Blvd.
Miami, Florida 33132 Henry H. Harnage, Esquire Counsel for Intervenor Peninsula Federal Bldg., 10th Flr.
200 S. E. First Street Miami, Florida 33131 Harold F. Reis, Esquire Steven P. Frantz, Esquire Lowenstein, Newman, Reis, Axelrad 5 Toll Co-counsel for Licensee 1025 Connecticut Avenue, NW Washington, DC 20036 NORMAN A COLL STEEL H TOR & DAVIS 1400 So theast First National Bank Building Miami <. Flor ida 33131 Telephone: (305) 577-2863 Dated: April 22, 1980.
UNITED STATES OF A1KRICA Qpp NUCLEAR REGULATORY COMMISSION - gf i~he $ecr V+'ff/Qo g
'z".~ " $eAicgQ BEFORE THE ATO IIC SAFETY 6c LICENSING BOARD
/p In the Matter of ) Docket Nos. 50 ) 51-SP FLORIDA POWER 6 LIGHT COMPANY (Proposed Amen ments to
') )
Facility Operating to Permit License Steam Generator (Turkey Point Nuclear Generating )
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. 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.,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 statement. [43 Fed. Reg.
17798, 17799 (1978)]
- 3. A contention can be amended only with the approval of the presiding officer based on a balanc'ing of the factors 1 is ted n 10 C. F. R. g 2. 714 (a) (1);
GOOD CAUSE FOR FAILURE TQ 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 INTEREST MILL 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 it issues or denies the amendment. There exists no means, other than the Board,
~
to have the Atomic Safety Licensing Board o'rder and consider an environmental impact statement before it rules on the amendment to the operating license.
EXTENT TO MHICH THE PETITIONER'S EXPECTED TO ASSIST IN DEVELOPING The petitioner will offer the testimony of Dale G.
Bridenbaugh, Gregory C. Minor and Robert Anderson to-show 4
that 'the proposals of the licensee involve a material alteration
of the licensed fac'ility's 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 ETITIONER S INTEREST S T 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'efined in 38 Fed. Reg. 22796 (1973) and 39 Fed. Reg. 10554 (1974).
EXTENT TO WHICH THE ET TIOI S A T IPATION WILL BROADEN THE ISSUES OR 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 I
in Contention 1B. The scope of the inquiry on what would be Contention 1A will be much broader than the inquiry required under Contention 13. In order to avoid any delay, Contentions lA 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.
- 4. Under 10 C.F.R. 52.714(a)(3) a motion to amend contentions must satisfy the specificity requirements of 10 C.F.R. $ 2.712(a)(2).
THE INTEREST OF THE T T ONE N T E PROCEEDING By order of this Board dated August 3, 1979', Hark P.
Oncavage is a party-intervenor in this cause.
HOW THE PETITIONER'S INTEREST MAY BE AFFECTED Y THE U THE ROCEEDIN 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 (5) enhance the quality of renewabl re-sources and approach the maximum attainable re-cycling of depletable resources.
Additionally, 1'h . Oncavage, his wife and his son live
approximately 15 miles from the Turkey Point power facility.
He owns a sailboat and cruises the waters of Biscayne Bay near Turkey Point 'nd 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 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, Mr.
Oncavage will be greatly affected by the, preparation of an
'nvironmental Impact Statement.
SUBJECT MATTER OF THE HE ONTENTIONS 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
'I that regulation, means a change in a technical specification or a change. which involves an unreviewed safety question.
38 Fed. Reg. 22796 (1973) and 39 Fed. Reg, 10554 (1974). An environmental impact will be prepared and circulated pxior to the issuing of a constxuction permit issued pursuant to I 10 C.F.R..Part 50. See 10 C.F.R. '$51. 5(a) (1) .
The integrity of tubes in a Westinghouse steam genexator is considered by the Nuclear Regulatory Commission to be an unresolved safety issue. NUREG-0410,'.R.C. Pro ram for the Resolution of Generic Issues Related to Nuclear Powex Plants, Category A Technical Activity No. A-3, U.S. N.R.C. Jan.
1978.
It is stated in the Environment Impact Appraisal at 52.2 that As of Nay 1979, tube plugging for vaxious reasons has resulted in removing about 17.5%
'of 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 Generat'or .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 inte'rrogatories 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 pxevent 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
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'n 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 increases in fluid velocity. At higher velocities turbulence is more pronounced which results in concentration gradients forming
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 I
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
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 pas.t.
Respectful sub itte By EI RY L H Attorneys for HARK A. ONCAVAGE, Intervenor
UNITED STATES OF At%RICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY 6 LICENSING BOARD In the Matter of ) Docket Nos. 50-250-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 P~tb day of March, 1980, to the following individuals:
Norman A. Coll, Esq.
Steel, Hector 6 Davis 14th Floor Southeast First National Bank Bui'lding Miami, Florida 33131 Elizabeth S. Bowers, Esq.
Chairman 4 Atomic Safety and Licensing, Board Panel fgl i 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
Atomic Saf ety 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. 20595 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, Axelgad 6 Toll 1025 Connecticut Avenue, N. W.
Washington, D. C. 20036 HENRY H. HARNAGE HENRY H. HARNAGE
RESUHE GREGORY C. HINOR HHB Technical Associates 1723 Hami 1 ton Avenue Sui te K San Jose, Cali fornia 95125 (408) 266-2716 EXPERIENCE 1976 - Present:
Partner - HHB Technical Associates, San Jose, California.
Engineering and Energy consul tant to state, federal and private organizations and individuals. Hajor activities include studies of safety and risk involved in energy generation, providing tech-nical consul ting to legislative, regulatory, pUblic and'rivate groups and expert witness in behalf of state organizations and ci ti zens 'roups. llas co-edi tor of a cri tique of the Reactor Sa fe ty Study (/!ASH-1400) for the Union o f 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 Speci a I nquiry Group (Rogovin Commi t tee) . Acti vely 1
invol ved in the Nuclear Power Plant Standards Commi ttee work for the Instrument Society of America (ISA).
1972 - 1976:
Hanager - Advanced Control and Instrumentation Engineering, General Electric Company, Nuclear Energy Division, San Jose, Cali fornia.
Hanaged 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 wi th other. reactor design organizations, the Nuclear Regulatory Commission, and customers, both overseas and domestic.
I 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 applicable 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/
programming.
197Q - 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 relating to safety and emergency sys tems for nuclear reactors.. Responsibil i ty required coordination u i th 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, California.
. Responsibl e for the design of speci fic control and instrumentation systems for nuclear reactors. Lead design responsibility for various subsystems of. instrumentation used to measure neutron flux in the 'reactor duri ng 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 patent for Nuclear Power monitoring System.
1960 - 1963:
Advanced Engineering Program - Genera i Electri c Company, Assi gn-ments in 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 design and equipment maintenance coordination.
Design Engineer - Hicrowave Department, Palo Alto, Cali-fornia. Work on design of cavity couplers for TWT's.
Design Engineer - Computer Department, Phoenix, Arizona.
Design of core dri ving circui try.
Design Engineer - Atomic Power Equipment Department, San Jose, California. Circui t desi gn and analysis.
Design Engineer - Space Systems. Department, Santa Barbara, Cali fornia. Prepare control portion of satelli te proposal.
Technical Sta ff - Techni ca t1i i ta ry Pl arming Opera ti on.
1 1 (TEMPO), 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 higher mathematics, probability and analysis,. Also completed courses in Kepner-Tregoe, Effective Presentation, Management Training Program, and various technical seminars.
EDUCATION University of California at Berkeley, BSSE, 1960.
Advanced Course in Engineering year Curriculum, General Electric Company, 1963.
Stan ford Uni versi ty, CSEE, 1966.
HONORS AND ASSOCIATIONS Tau Beta Pi Engineering Honorary Society Co-holder of U.S. Patent No. 3,565,760, "Nuclear Reactor Power l1oni toring System," February 1971.
member: Ameri can Association for Advance of Science.
Member: Nuclear Power Pl ant Standards Committee, Instru-ment Society of America.
PERSONAL DATA Born: June 7, 1937 t1arried, three chil dren Residence: San Jose, California
P UB L 0
I CAT I OilS AN D T ES T I HON Y G. C. Minor, S. E. Mioore, "Control Rod Si gnal !1ul tipl exing.,"
IEEE Transactions on Nuclear Science, Vol. NS-19, February 1972.
- 2. G. C. Mi nor, h'.G. Mil am, "An Integrated Control Room System for a Nucl ear Power Plant," NED0-10558, presented at International Nuclear Indus tri es Fair and Techni cal He'etings, October 1972, Basle, Swi tzerl and.
3.. The above article was also published in the German Technical hagazine, NT, 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. Bridenbauoh, and R.B'. Hubbard before the California 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 Cali Senate Committee on Public Util i ties, Transit,'nd forni'tate Ene rgy, Ha rch 23, 1976.
- 7. Testimony of G. C. Minor regarding the Grafenrheinfeld Nucleai Plant, Harch 16-17, 1977, Wurzburg, Germany.
- 8. Testimony of G.C. Minor before the Cluff Lake Board of Inqui'ri Regina, Saskatchewan, Canada, September 21, 1977.
- 9. The Risks of Nuclear Power Reactors: A Review of the NRC Reactor 8~get Stud MASH-1400 jMUREG-75/01~a, H. I:ends~,
et a, edited by G.C. Minor and R.B. Hubbard for the Union of Concerned Scientists, August 1977.
- 10. Swedi sh Reactor Safet~ Study: Barseback Risk Assessment, llHB Technical Associates Januar 1970. (Published by S wedi sh Department of Industry as Document SdI 1978:1)
Tes timony by. G. C. Hinor be fore the Mi s cons in Publi c Servi ce Commission, February 13, 1978, Loss of Coolant Accidents:
Their Probabil i t and Conse uence.
- 12. Testimony by G.C. Minor before the California Legislature
.Assembly Commi ttee on Resources, Land Use and Energy, AB 3108, April 26, 1978, Sacramento, Cali fornia.
- 13. Presentation by G.C. Minor before the Federal Ministry for Research and Technology (BHFT), Meeting on Reactor Safety Research, Han/Machine Interface in Nuclear Reactors, August 31 and 'September 1, 1978, Bonn, Germany.
4
PUBL ICATIDHS AHD TESTIHDHY
- 14. Testimony by G.C. Hinor, D.G. Bridenbaugh, and R.B. Hubbard before the Atomic Safety and Licensing Board, September 25, 1978, In the t1atter of the Black Fox Nuclear Power Station Construction Permit Hearings, Tulsa, Oklahoma.
- 15. G.C. liinor, D.G. Bri denbauph, and R.8. Hubbard, Improving the Safety of LMR Power Plants, prepared for Sandia Laboratories by HHB Technical Associates, September 27, 1979.
BIOGRAPFlICAL DATA HA.'lE: Robert Heil Anderson ADDRESS: 'Hork: Department of Materials Engineering San Jose State University San Jose, Cali forni a 95192 (408/277-3761 or 277-2OO6)
Hom: 3034 Stelling Drive Palo. Alto, California 94303 (4151494-7824)
PERSOHAL IHFOPiiATIOtl:
Date of Birth: Hovember 8, 1933 Place of Birth: San Jose Marital Status: Married; ti~o children EDUCATIOH B.S., Chemistry, University of San Francisco, 1956 B.S., Chemical Engineering, University of California - Berkeley 1958 M.S., Chemical Engineering, University of California - Berkeley 1 59 Ph.D., Metallurgy, Stanford University, 1969 Post Doctoral Study in l'ietallurgy - Stanford University, 1970-1973 PROFESSEOHAL EXPERIEHCE:
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 Stanfol d Unive'2 s i ty, Post Ooctol al Research Associate, 1970-72 University of California, Berkeley, Research Assistant, 1958-59 University of San'Francisco, Chemist, 1955-56 Industrial:
U.S. Haval Radiological Defense Laboratory, Operations Research Analyst, 1966-69 U.S. Haval R diological Defense Laboratory, Research Engineer, 1959-66 Arabian American Oil Company, Chemist, 1954-55
PROFESSIONAL EXPERIENCE (continued)
Consul ting:
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 Corrnission, 1977-79 Executive Office of the President of the United States Council on Environmental guali ty 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 PcDermitt ttine, 1976 - present.
International Business Machines, 1977-78 tlemorex, 1979 Electrical Power Research Institute, 1974 SRI, 1975-77 Brookhaven National Laboratories, 1977-78 Attornies (list on request)
PROFESSIONAL 'ACTIYITIES:
American Nuclear Society, American Institute of Chemical Engineers, American Chemical Society, American Insti'tute of t1etallurgical Engineers (Past Chairman of Northern California Section),
American Society of Hetals, National Society for Profe'ssional Engineers, American Society for Engineering Education, California Academy of Science, Alpha Chi Sigma, Tau Beta Pi and Sigma Xi.
CREDENTIALS AND LICEfUSES:
Cali forni a Standard Teaching Credenti al.
Registered Petallurgical Engineer, California.
Registered Nuclear Engineer, California.
Fallout Shelter Analyst.
Private Pilots License.
PUBLICATIONS:
Articles: .
- 1. "The Activity of Titanium in Liquid Allnys," Accepted for publication and presentation'n the Fourth International Conference on Titanium 19-22 tray, 1980, International Conference Hall, Kyoto, Japan.
- 2. "Internationally Safeguarded Atomic Fuel Exchange Center for the Asia-Pacific Basin," Proceedings in 2nd Miami International Conference
PUBLICATIONS (continued) on Alternative Energy 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.
- 5. The Gold Dagger of Tutankhamun, Grafico Publishing Co., Santa Clara, Ca., 1979 (available through the San Francisco De Young Huseum).
- 6. "Analysis of the Infrastructure of the Front End of the Uranium Fuel Cycle," San Jose State University, Hazerials 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 Availability through the Year 2010," San Jose State University, t1aterials Engineering Department, report prepared for the California Public Utilities Commission (July 1, 1979).
- 9. "The tlineral Industries and the'hallenges of the 80's," paper presented to the Pacific Southwest Hinerals Conference, San Francisco March 25, 1979.
- 10. "The Effect of Equipment Design,'perational 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 ttetals: 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, Washington, D.C.
- 15. "Separation Technologies Reviewed," fluclear Engineering International, August, 1978.
P"iiL>CM'>Des (continuO)
- 16. "SSpent Fuel Oisposal Costs," report to the Natural Resources Defense Council, July, 19?8.
II
- 17. e'xaminations of Radioactivity and Environmental Aspects of Antartic Soils at Point Hueneme," report to the California S 1'd P~ B d July, 1978.
- 18. 'nvited contributor to the Executive Office of tne President of the United States document on Nuclear Po::er and Nuclear!Haste Disposal for the President of the United States, June, 1978.
- 19. "Technical Review> of the Deutch Draft Report on Nuclear Haste Management," for the Council on Environmental guality, Executive Office of the President of the Unites States, l1ay, 1978.
Ii il
- 20. A Technica':,Assessment of Nuclear Fuel Reprocessing and Padioactive Haste Disposal," report to State of California Energy Resources Conservation and Development Cor6ission, fiarch, 1978.
- 21. "A Program Assessment of Nuclear Fuel Peprocessing and Radioactive Haste 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. II Hydrometallurgical Separation of the Zinc-Base Fraction of Shredded Automobiles," Conservation and Recycling, V. 1, 1977.
- 24. IIS
.Survey of Reprocessing Technologies," Brookhaven National Laboratories Report 23082, June, 1977.
- 25. The Physical 5 Chemical Characteristics of Titanium-Copper Alloys,"
Technical Report to Regal@are, July, 1977.
- 26. "A tiethodology 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. "Yieet the ANF Reactor," Industrial Research Hay, 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 l1ineral Haste Utilization Symposium, April 13-14, 1976.
PUBLICATIONS (continued)
'0. "Evaluation of Mineral l(aste Utilization Processes and Strategies by Net Energy Analysis," Proceedings of the Fifth Mineral Haste Util i zati on Symposium, April 13-14, 1976.
- 31. Supply of Gallium and Arsenic," prepared for NASA Langley
. Research Center, Va., April 1976.
- 32. "Carbothermic Reduction of Refractory Metals." J. of Vacuum Science Technology., V. 13, No. 1, Jan/Feb 1976; "Nuclear Plant Can Ma);e
'Available 5
Gold," San Jose News, March 20, 1975; "What to Do kith Atomic 'tlaste,"
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. "Nitrog n 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 For'mation 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 .he Journal of High Temperature Science, (with A-FUl!A and N.A.D. Parlee).
- 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. of 67th Meeting of the American Institute of Chemical Engineers, Dec. 1-15, 1974.
- 41. "Nitrogen-Nitride Equilibria in flolten Pr-Sn Alloys," Journal of High Temperature Science, V. 5, 1973.
- 42. "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, 1973.
- 44. "Continuous Removal of Fission Products in a Nitride Fueled Reactor,"
Nuclear Technology, V. 13, March 1972 (297-300).
PUBLICATIONS (continued) 45; "Application o Nitride-Forming Reactions to Reprocessing of Spent Nuclear Fuels," Nuclear Technology, Y. 13, January, 1972.
- 46. "Reassessment of .the Copper-Boron Phase Diagram," Journal of the Less Common Metals, Y. 25, December 1971 (427-430).
4?. "Nitrogen-Nitride Reactions in Molten U-Sn Alloys," TMS-AIME Metallurgical Transactions, Y. 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'econtamination of Military Weapons," f(RA Riflemen, November, 1963.
r
- 50. "The Contamination-Decontamination o Fission Products in Sea llater," 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 MATERIALS 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 1,344,950 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, 19?8 038,382 filed May 14, 1979
D ale G. Bridenbaugh-1723 Hamilton Avenue, Suite K San Jose, CA 95125 (408)266-2716 EMEBZENM; 1976 - Present Pa tner, YRB Technical Associates, San Jps e . Cal' ornia. Founder anc partner oz tec. nx,ca consu t~ng z rm. spec~ a zsts n energy consulti-..
to governmental and other groups inte es ted in .evaluation oz nuclear plant safety and licensing.. Consultant in tnis capacity to State of California, Suzfolk County, New York, New York Attorney General, Nor-wegian Nuclear Power Committee, Public Advocates Office, New Jersey,
'and various other organizations'." and envi onmental groups. Performed extensive sazety analysis for'Swedish Energy Comm'ssion and contribute to Union of Concerned Scientists 'eview o2 HASH-1400; consultant to U.S. NRC - LWR Safety impiovement Prog am, and performed Cost Analysis oz Spent Fuel Disposal for NRDC.
1976 (February - August)
Consultant, Pxo-ect Survival, Palo Alto, 'Cal'ornia. Volunteer work on Nuc ear Sazeguards Initiative campaigns in Casizornia, Oregon',
Washington, Arizona, and Colorado.: Numerous presentations on nuclear power and alternative energy opt ons to civic, government, and college gxoups. Also resouxce'e son for p'uolic service presentations on radio and television..
1973 - 1976 Ywnaaer, Performance Evaluation and improvement, General Elect=i'c Comoan - Nuc eax Energy Division, San Jose, Ca izornia. Managed seventeen tecnnzca an seven c esca personne wx,tn responsibility for establishment and management oz systems to monitor and measure Boiling Water Reactor equipment and. system operational pe formance.
integrated General Electric resources in customer plant mod fications.,
coordinated cor ection of causes of forced outages and oz efforts to improve reliability and performance of BWR systems.
Responsible zor development of Division Master Performance improvement Plan as well as for numerous Staff special assignments on long-range studies. Was on special assignment zor the management of two different ad hoc projects formed to resolve unique technical problems.
1972 - 1973 Manager, Product Service, General Electric Conan' Nuclea= Energy Dzmsxon, San Jose, Calm o~z.a, Managed group oz twenty - o ne technical an zour c err.ca personne . Prime responsibility was to direct inter-face and liason pe sonnel involved in corrective actions required undex contract waxranties. Also in,charge oz refueling and service planning, performance analysis, and service communication functions supporting a completed commercial nuclear power reactors supplied by General Electri both domestic and overseas (Spain, Germany, T.taly, Japan,'ndia, and Swi tzexland) .
1968 - 1972
'i~~~ nager, Proauct Service, General Electric Comoan - Nuclear Enerzv Div sion, an Jose, Ca izornia.
a anaged sixteen techn ca and .six c erical personnel w'th'he responsibility for all'ustomer contact, planning and execution oz work requirea after the customer acceptance oz Depart=ent supplied plants and/or equ pment. This included quotation, sale and delivery of spa e and renewal parts. Sales volume oz parts increased zrom $ 1',000,000 in 1968 to over $ 3,000,000 in 1972.
1966 - 1968 Manager Nuclear Ener Comol.aint and Warranty Se~
, Division, San Jose California.
- ~ ~ >>>> ~ c Comoanv-I Ymaged group oz six persons w'th the responsibility for customer contacts; planning and execution of work requ'red after customer acceptance'f Department - suppliea plants and/or equipment both domestic and overseas.
1963 - 1966 Fiela "ngineerin Supervisor, General Electric Comoanv Installation ana aery" ce xnR"neerzn Department Los Pn eles California.
Supervised approx~mately eight field representatives with responsi-bi ity zor General Electric steam and gas turbine installation Sou"hem and maintenance work in Southern Calizornia, Arizona, and Nevada During this period was responsible for the installation of eight difzerent central station steam turbine generator uni'ts, plus much maintenance activity. Work included customer contact,, preparation of quotations, and contract negotiations.
(I 1956 - 1963 Field Engineer General Electric Comoan 'installation and Service Enaineerinz Department Chicago Tllinois.
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. Work'rimarily 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 zirst 1-rge-scale commercial nuclear power 1955 - 1956 Engineering Training Program, General Electric Company, Erie, ennsy vane.a, ana cnenectaay, ew ore.
Training assignments in plant facilities design ana in. steam tu-bine testing at two General Electric Factory 1ocations.
953 1955 United S tates A~v - Ordnance School, Aberdeen, i~wrvland Instructor - Heavy Artillerv Repair. Taught classroom and shop disassembly of artillery pieces.
1953 En n neering Training Program, Gene=a Elect=i c Company, "vendale, neo; t=aining assignment with Aircra:t Gas Turcine Depa-t-ent.
EDUCATION 6 A. FILIATIONS
-.'BSiZ - 1953 South Dakota School of 8'nes and Technology, Rapid City, South Dakota, Upper > oz class.
Professional Nuclear Engineer - California. Certificate No. 0973.
Hembe - >aerican Nuclear Society.
Various Company Training Courses during career includ'ng Profess.'onal Business Hanagemen-, Kepner Trezoe Decision Nakin~E." oct've Presentation,'nd numerous technical seminars.
HONORS 6 AWARDS Sigma Tau - Honorary Engineering Fraternity.'eneral Ymnagers Award, General Electric Company.
P.ERSONAL DATA Born Novembe 20, 1931, ?iiller, South Dakota harried, three ch'ldren.
6 '2", 190 lbs., health - excellent.
Honoraole discnarge from United States Army.
Hobbies: skiing, hiking, work with Cub and Boy Scout g oups.
PUBL'ZCATYONS 6 TESTl'.MONY
.Ooeratinr and Ma'ntenance xmerience, presented at Twe3.f"4
~
Annua Seminar zor E ect=ic Uti ity Executives, Pebble Beach,
'alifornia, October 1972, publishea in General Electric NEDC-10697, December 1972.
Plaint nance and l:n-Service Inspection, presented at l'.Ar"<
Symposium on Experience From Operating and Fueling oz" Nuclear Power Plants, Bridenbaugh, Lloyd, 6 Turner, Vienna, Aus 1973. tria,,'ctober
- 3. Ooeratin and Maintenance Experience, presented at Thirteenth Annual emznar zor E ectr c Utz x,ty Executives, Pebble Beach, California, November 1973, publ'shed in General E ectric NEDO-20222, January 1974.
Zwrovinz Plant Availabi1ity, presented .at Thirteenth Annual Seminar zor EL.ectric Uti ity Executives, Pebble Beach, Calizor;.
November 1973, publishea in General Electzic NED0-20222, Janua" 1974.
oz" Plant Outage Experience to lmrove Plant Per-Application
~c.
I, l.',
zo ~nce, Sriaenoaug an Burasas, American Power Conzerence, Ap*'1 lt, 197I.
- 6. Nuclear Valve Tes tin~ Cuts Cos t, T me, Electrical world, Octobe:
- 5. 1 7.
aze ty t a LvASH- L, The Risks of Nuclear Po~er Reactors: A Review oz the NRC Reactc Kenaas, Huo ar, ~fino",
et a, zor tne. Union of Concerned Scient'sts, August 1977.
riaenoaugn,
- 8. Swedish Reactor Safet Study: Barseback Risk Assessment, 1KB xecnnxca Assoc>ates, Janury s . ( u xsnea .y welsh Depar~
ment of Industry as Document Dsl 1978;1)
- 9. Testimony oz D.'. Bridenbaugh, R. B. Hubbard, G. C. Minor to thi California State Assembly Committee on Resources, Land Use, and Energy, March 8, 1976.
- 10. Tes timony o fUnitedG. States D,. Bridenbaugh, R.
Congress, B. Hubbard, and G. C. Minor Joint Committee on Atomic
'oezore the Energy, February 18, 1976, washington, DC. (Published by the Union oz Concerned Scientists, Canbridge, Massachusetts; )
the California Energy Testimony by D. G. Bridenbaugh beforeCztast=oo'.-.
Commission, entitled 'Zritiat"'on of c Accidents at Diablo Canyon,.Hearings on Emergency Planning, Avila Beach.,
California, November 4, 1976.
- 12. Testimony by D. G.
~
Bridenvaugh be"ore the U.S. Nuclea Regulato=
Commission, subject, Dizblo Canyon Nuclear Plant Performance, Atomic Sazety and L'censing Board Hearings, December 1976..
- 13. by D. G. Bridenbaugh bezore the California Energy 'est'mony Commission, subject, l:nterim Svent Fuel Storage Considerations, Pmrch 10, 1977.
Test'mony by D.'G. Bridenbaugh before New York State Public Service Co~ssion Siting Board Hearings concern'ng the Jamespo=
Nuclear Power Station, subject: Effect o echnicz znd Safety Deficiencies on Nuclear Plant Cost and Reliability,April 1977.
- 15. Testimony by D. G.'ridenbaugh before the California State Energy Commission, subject, Deco@a'ssioninz of Pres suri".e Rater Reactors, Sundesert Nuclear Plant Hear ngs, June 9, 1977.
- 16. estimony by D. G. Bridenbzugh bezore the Cali orniz.State Energy Co~ssion, suoject, Economic Relationships of Decozn~ssionin~, Smdesert Nuclear Plant, zor the Natural Resou-ces Defense Council, July 15, 1977.
- 17. Testimony by D. G. Bridenbaugh before the Uermont Stat Board oz Health, subject, Operation oz Vermont Y"nkee Nuclezr Plant and lts Tmoact on Public Health znd Safety, October 6, 1977.
- 18. Testimony by D. G. Bridenbaugh before the U.S. Nuclear Regulato:
Commission, Atomic Safety ~d Licensing Board, subject, De='-
ciencies in Safetv Evaluation of Non-Se'smic Issues. Lack or z Dezinit'e Findinm oz Sazetv, Biablo Canyon Nuclear Units, Octooer Avi a Beacn, California.
- 19. Testimony by D. G. Bridenbaugh before the Norwegian Commission on Nuclear Power, subject, Reactor Safety/Risk, October 26, 197.
- 20. Testimony by D. G. Bridenbaugh before the Louisiana StatePowerLegis-lature Committee on Natural Resources, subject, Nuclezr Plant Deficiencies Imoactinz on Safety 6 Reliabi t , Baton Rouge, Louisiana, February 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. Bridenbaugh, G.C. Minor, -nd, R.B. Hubbard the matter of before tne Atomic Safety and Licensing Board, in Permit'Hearing'.
the Black Fox Nuclear Power Station Construction Septemoer 25, 1978, Tulsa, Oklahoma.
,PUBLZCATZONS AND TKSTXi~fONY
- 23. Testimony oz D.G. Bridenbaugh and R.B. Hubbard before the Louisiana Public Service Commission, Nuclear Plant and Pover Generation Costs, November 19, 1978, Baton Rouge;- Louisiana.
- 24. Testimony by D.G. Bridenbaugh before the City Council and i ectric Utility Commission of Austin, Texas, Des'~, Con-struction, and Ove ating Experience of Nuc ear Generate nR "
- ac lities, Decem er a, Aus tin, Texas
~
n se
+
g5t8 AEONS pw)
I 0
te t UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 t
ss
~>>*<<~ March 6, 1980 Elizabeth S. Bowers, Esqs Chairman s Dr. Emmeth A. Luebke Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel
.U. S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D. C. 20555 Dr. Oscar H. Paris Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of Florida Power and Light Company (Turkey Point Nuclear Generating Unit Nos. 3 and 4)
Docket Nos. 50-250 e~(proposed Amendments to Facility Operating Licenses to Permit Steam Generator Re air)
Dear Members of the Board:
On March 4, 1980, the Commission issued a Memorandum and Order directing the issuance of an environmental impact statement in connection with the Surry steam generator repair operation. A copy of that Memorandum and Order is enclosed, This action eliminates a principal matter in controversy in this proceeding (embodied in contention 1) concerning whether such a statement should be prepared. The Staff will advise the Board and parties when a schedule for issuance of the impact statement has been established.
Sincerely, Steven C. Goldberg Counsel for NRC Staff
Enclosure:
As stated cc w/enclosure:
Mr. Mark P. Oncavage Atomic Safety and Licensing Harold F. Reis, Esq. Board Panel Norman A. Coll, Esq. Atomic Safety and Licensing Neil Chonin, Esq. Appeal Board Panel Henry H Harnage, Esq.
~
Docketing and Service Section
CLI 4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CO) iMISS IONERS:
John F. Ahearne, Chairman Yictor Gilinsky Richard T. Kennedy Joseph M; Hendrie Peter A. Bradford In the Matter of VIRGINIA ELECTRIC POWER CO. Docket Nos. 50-280 50-281 (Surry Nuclear Power Station, Units 1 and 2)
For Relief Under 10 CFR 2.206 MEMORANDUMi AND ORDER The Commission has before it for sea ~s onte review three decisions by the Director of the Office of Nuclear Reactor Regulation on petitions-1/ filed under 10 CFR 5 Z.Z06 involving the steam generator repair at the Sur ry Nuclear Power Station. On January 29, 1980, the Commission, pursuant to 10 CFR ii 2.206(c)(l),
took review of the three decisions on the issue of the need for an environmental impact statement regarding the proposed repair.
1/ The three petitions are from the North Anna Environmental Coalition (filed December 29, 1978; denied February 1, 1979); the Environmental Policy Institute (filed February 20, 1979, denied April 4, 1979); and the Potomac Alliance, Citizens Energy Forum, Inc., Truth in Power, Inc., and the Yirginia Sunshine Alliance (filed April 18, 1979, denied October 24, 1979).
2/
The primary issue presented by the repair, and the sole issue considered on the merits in this Comoission review, is whether the NRC's action in approv-ing the repair is one "significantly affecting the quality of the human environ-3/
(NEPA), and there-ment" for purposes of the National Environmental Policy Act fore one that requires an environmental impact statement. This admittedly vague test, and the lack of definitive criteria that can be used in applying it, leaves the Commission and its Staff with a difficult decision in many cases.
The circumstances of this case presented the Director with just such a difficult decision.
Qur review has focused on the occupational radiation exposure that the repair program will entail because we believe that this adverse environmental impact is the only one associated with the repair program that might be considered significant. Me have carefully examined the Director's Decisions and the bases therefor, and are unable to determine from the data and arguments presented by the Director whether the occupational radia.ion exposure involved here is signi-ficant. The Director's Decisions rest, essentially on a comparison of the impact of the radiation exposure resulting from the repair with the net savings in total occupational exposure resulting from operation using repaired steam generators 2/ When this issue first arose, both units at Surry were the subject of the petitions. At this point however, repairs at Unit 2 are essentially completed and the repairs at Unit 1're scheduled to begin in June of 1980. Hence, the need for an environmental impact sta .ement for the Unit 2 repairs is moot. However, the issue of the need for a statement for the
-. Unit repair 1 is very much alive and is the focus of this Comnission review.
3/ The National Environmental Policy Act of 1969, Pub. L. Ho.91-190, 83 Stat.
852 as amended by Pub. L. 94-83, 89 Stat. 424, 42 U.S.C. 55 4321 et sece.
instead of defective ones, and a comparison with the incidence of cancer for the worker population due to causes other than the repair at Surry. The first com-parison is relevant to the question whether the expected benefits of the action outweigh the environmental costs, which is distinct from the question whether the expected environmental impact of a federal action is sufficiently great to require an impact statement. Even if on balance the result of the Federal action 'is beneficial, the proper criterion on which to base the decision whether to prepare an EIS is the significance of the action. Hence, "the fact that the occupational exposure at Surry (2070 man rems for the repair at each unit) is expected to be less than the occupational exposure resulting from continued operation with defective steam generators over a period of four years is a valid consideration in assessing the merits of the repair once the requirements of ti PA h~ve been satisfied, but has no bearing in determining ihe threshold ques-tion of the "significance" of the exposure and the attendant decision whether to prepare an environmental impact statement.
The Director's second basis, comparing the occupational exposures to the number of worker deaths due'to cancer from risks unrelated to the repair, neces-sarily entails a judgment regarding the significance of these other risks. Yiore specifically, it implies the proposition that these other risks are either not significant or that a small percentage of them is not significant. However, nothing in the Director's Decisions establishes this proposition. Thus the comparison, without more, does not enable us to determine whether the exposures here are significant.
4/ See Regulations For Implementing The Procedural Provisions of NEPA, 40 CFR 1508.27(b)(1).
Given this, and given the controversy in the scientific community as to the effects of such exposures, we are unable to determine whether the environmental impacts here aresignificant. Therefore, we believe that the preferable course of action in the circumstances of this case is to prepare an environmental impact statement on the repair.
Accordingly, we hereby direct the Staff to expeditiously prepare and issue an environmental impact statement on the proposed repair at Unit l.
dissent from this decision. 5/
Chairman Ahearne and Commissioner Hendrie It is so ORDERED.
For the Commission SAMUEL J CHILK Secretary of tP Commi s s i on Dated at Mashington, D.C.,
this day of t1arch, 1980.
5/ Section 201'f the Energy Reorganization Act, '.2 U.S.C. 5 5841 provides that action of the Commission shall be determined by a "majority vote of the members present." Had Commissioner Gilinsky been present at the meeting he would have voted with the majority. To enable the Commission to proceed with this case without delay, Chairman Ahearne, who was a member of the minority on the question up for decision, did not partici--
pate in the formal vote. Accordingly, the formal vote of the Comnission was two to one in favor of the decision.
%0t:fiET MUiV<BER ~ ~~
PROD. & LPjlL. FAC %0
~ ~ ~
JOIIN R. NElvELL 241 YORTHEhST SPAYISH TRAIL Boch RATQN, FLQRIDh 33432 February 15, 1980.
The Secretary Nuclear Regulatory Commission Nashington, D.C. 20555
Dear Sir:
I am very concerned. about the proposed. repairs .
to the steam generators at the Turkey Point Nuclear Power plant of the Florida Power and. Light Co. which I understand are to be accomplished. in the near future. I also am told that a public hearing on the proposed. alterations and. the methods to be used. Co handle and. d.ispose of the damaged.
generators is to be held. in Iiiami before this work is" commenced,,"
I wish to be present and. possibly to speak at this hearing and. would. therefore appreciate information and.
timing concerning this hearing at your early convenience."
I am a former member of the Atomic Industrial Forum ~~ ~ ~ ~~ ~
and. a retired shipbuilder of naval vessels with a consider-able background. in nuclear safety problems and. may have some helpful information to present at the hearing.-'ery
~
truly yours,
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i/IJ- LAW OFFICCS LowENSTEIN, NEwMAN, REIS, AxELRAD 8c TQLL I 025 CONN CCTI CUT AVENUCe N. W ROSCRT LOWCNSTCIN WASHINGTON, D. C. 20036 JACK R, NCWHAN HAROI.D F RCIS MAURICC AXLLRAD 202 '62- 8400 DAVID R, TOLL KATHLCCN H SHCA J, A. 8OVKNIOHT JR, C OREOORY 8ARNCS HICHAEL A SAVSCR DCSORAH L, SERNSTCIN ALBERT V. CARR, JR.
ROSERT H. CULP PETER O. FLYNN WILLIAMJ FRANKLIN FRLDERIC S DRAY April 1, 1980 OOVOLAS 4 ORCCN Elizabeth S. Bowers, Esq. Dr. Oscar H. Paris Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board U..S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: In the Matter of Florida Power 6 Light Company (Turkey Point Nuclear Gen rain~
Units Nos. 3 and 4 Docket Nos. 50-250- P and 50-251-SP; Proposed Amendments to Facility Operating Licenses to Permit Steam Generator Re airs)
Dear Members of the Board:
Enclosed are copies of (1) the Steam Generator Repair Report, Revision 7, March 1980, for Turkey Point Units 3 and 4 and (2) letter of March 28, 1980, from Robert E. Uhrig, Vice Presi-dent, Advanced Systems 6 Technology, FPL, to Darrell G. Eisenhut, Acting Director, Division of Operating Reactors, U.S. Nuclear Reg-ulatory Commission, transmitting and summarizing item l.
Si erely arold F. Reis cc: (w/encs.): See attached Certificate of Service
.HFR/ae
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-250-SP
) 50-251-SP FLORIDA POWER & LIGHT COMPANY )
) (Proposed Amendments to (Turkey Point Nuclear Generating ) Facility Operating Licenses Unit Nos. 3 and 4) ) to Permit Steam Generating Repairs)
CERTIFICATE OF SERVICE I hereby certify that copies"of the attached letter of April 1, 1980 to Members of the Board, together with the two en-closures thereto, captioned in the above matter, were served on the following by deposit in the United States mail, first class, properly stamped and addressed, on the date shown below:
Elizabeth'. Bowers, Esq.
Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Oscar H. Paris Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington,. D.C. 20555 Dr. Emmeth A. Leubke
'Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 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
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 Mr. Mark P'. Oncavage 12200 S.W. 110th Avenue Miami, FL 33176 Neil Chonin, Esq.
Law Offices of Neil Chonin, P.A.
Counsel for Intervenor New World'ower Bldg., 30th Flr.
100 N. Biscayne Blvd.
Miami, FL 33132 Henry H. Harnage, Esq.
Counsel for Intervenor Peninsula Federal Bldg., 10th Flr.
200 S.E. First Street Miami, FL 33131 Norman A. Coll, Esq.
Steel, Hector 6 Davis 1400 Southeast First National Bank Building Miami, FL 33131 HAROLD F . R S I
LOWENSTE IN g NEWMANg RE S g AXELRAD 6 'TOLL 1025 Connecticut Avenue, N.W'.
Washington, D.C. 20036 Telephone: (202) 862-8400 Dated: April 1, 1980