ML19305E415

Motion to Amend Contention 1 to Include Contention 1B.Util Application for OL Amend Involves Matl Alteration of Facility.Alteration Requires CP Prior to Issuance of Amend. CP Requires Preparation of Eis.Certificate of Svc Encl

ML19305E415
Person / Time
Site:	Turkey Point
Issue date:	03/11/1980
From:	Chonin N, Harnage H, Oncavage M CHONIN, N., HARNAGE, H.H., ONCAVAGE, M.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8004240086
Download: ML19305E415 (28)

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UNITED STATES OF AMERICA -)- , , c 'US 7 1.':,.c " ",....g.g NUCLEAR REGULATORY COMMISSION .T O ny d,'Y3.?'QAo Q

1, BEFORE THE ATOMIC SAFETY & LICENSING BOARD - 'nW! $ .j Q \

In the Matter of ) Docket Nos. 50-250-SP

) 50-251-SP FLORIDA POWER & LIGHT COMPANY ) (Proposed Amendments to

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

MOTION TO AMEND. CONTENTIONS Intervenor, Mark Oncavage, noves 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 uhich requires a construction permit 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. 2.714(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 sarets evaluation or environmental impact statemen:. [43 Fed. Reg.

17798, 17799 (1978)]

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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. 52. 714(a) (1) ;

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

AVAILABILITY OF OTHER MEANS 171TEREEY THE PETITIONER' S INTEREST WILL 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 l 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 amendment to the operating license.

EXTENT TO WHICH THE PETITIONER'S PARTICIPATION RAY REASOITKELY BE

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EXPECTED TO ASSIST IN- DEVELOPING A SOUND 1[KCORD 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

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 I. .

EXTENT TO WHICH THE PETITIONER'S INTEREST WILL BE REPRESEfPfED BY EXISTING 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 material alteration of the licensed facility as that term is defined in 38 Fed. Reg. 22796 (1973) and 39 Fed. Reg. 10554 (1974).

EXTENT TO WHICH THE FETITIONER'S PARTICIPATION WILL BROADEN THE ISSUES OR DlLAY THE PROCEEDING 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 lA will 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.

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

4. Under 10 C.F.R. S2.714(a)(3) a motion to amend contentions must satisfy the specificity requirements of 10 C.F.R. 5 2. 712 (a) (2) .

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i THE INTEREST OF THE l PETITIONER IN THE

! 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 BY THE RESULTS OF THE PROCEEDING 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. 54331(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-desirabic 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 use which will permit hi of living and a wide sharing of life'ghs standards amenities; and (5) enhance the quality of renewable re-sources and approach the maximum attainable re-cycling of depletable resources.

Additionally, Mr. Oncavage,_his wife and his son live i.

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i 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 I

that the steam generator repairs at the Turkey Point facilitics j be performed in a fashion that will have as little adverse  :

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impact as possible on the natural environment. An obvious l r

i method for determining whether the repair activities will have a degrading impact on the environment is to have an Environmental i

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 i

by its disclosure in an Environmental Impact Statement, Mr. i i

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

l SUBJECT MATTER OF THE 3  ;

PROPOSED AMENDMENT TO k 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. 550.91. Alteration, as used in that regulation, means a change in a technical specification or a change which involves-an unreviewed safety question.

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38 Fed. Reg. 22796 (1973) and 39 Fed. Reg. 10554 (1974). An

! environmental impact will be prepared and circulated prior &

r to the issuing of a construction permit issued pursuant to 1

i 10 C.F.R. Part 50. See 10 C.F.R. S51. 5(a) (1) . ,

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The integrity of tubes in a Westinghouse steam generator [

is considered by the Nuclear Regulatory Commission to be an  :

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unresolved safety issue. NUREG-0410, N.R.C. Program for the Resolution of Generic Issues Related to Nuclear Power Plants, Categdry A Technical Activity No. A-3, U.S. N.R.C. Jan, 1978. t It is stated in the Environment Impact Appraisal at

$2.2 that As of May 1979, tube plugging for various  :

i 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. t Florida Power and Light has claimed at Section 2.2 of 1

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j its Steam Generator Repair Report that [

l Research, development and testing have J been utilized to select design parameters, 4

material and component configurations which '

1 will prevent degradation of the repaired

, steam generators. (Emphasis added)

In Intervenor's interrogatories 1 - 7 and 1 - 8 he asked licensee to provide all of its test data and calcu-lations in support of its allegation that with its newly installed steam generators it could prevent tube degradation. .

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

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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 S2.2.1.1 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. i ON-SITE STORAGE OF STEAM GENERATORS -

In response to Interrogatory 6-11 the licensee lists the guidelines that will be followed in designing the steam ,

generator storage facility. Of all of the guidelines listed, none of them are Nuclear Regulatory Commission guidelines. '

For the Nuclear Regulatory Commission this is an unreviewed question.

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

in solution.

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

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

Respectfu sub itte ,

By 124ftf M fENR].$ARNAGE 6

$Ei b N3FL CEONIN Attorneys for MARK A. ONCAVAGE, Intervenor j

RESUME GREGORY C. MINOR d-11 MHB Technical Associates 'Nb' 1723 Hamil ton Avenue // EC D Suite K U22' San Jose, California 95125 \h (408) 266-2716 g

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- tahuq S tr.23 s EXPERIENCE c3 N. s--

1976 - Present:

Partner - MHB Technical Associates, San Jose, California.

federal and private Engineering organizations and and Energy consultant to state, Major activities include studies individuals.

of safety and risk involved in energy generation, providing tech-nical consul ting to legislative, re g ul a to ry , public and private groups and expert wi tness in behalf of s tate organizations and citizens' groups. Was co-editor of a critique of the Reactor Safety Study (WASH-1400) for the Union of Concerned Scientists and co-author of a risk analysis of Swedish reactors for the Swedish Energy Commission. Served on the Peer Review Group of Ac ti vely the NRC/TMI Special Inqui ry Group (Rogovin Commi ttee) .

involved in the Nuclear Power Plant Standards Committee work for the Instrument Society of America (ISA).

1972 - 1976:

Manager - Advanced Control and Instrumen ta tion Engineering, General Electric Company, Nuclear Energy Division, San Jose, Cali fo rnia .

Managed a design 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 Nuclea r Regula tory Commission, an d cus tomers , bo th overseas and domes tic.

Responsibilities included coordinating and managing the design and development of control systems, sa fety sys tems , and new con trol concepts for use on the next generation of reactors. The position included responsibility for s tandards 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.

1970 - 1972:

Manager - Reactor Control Systems Design - General El ec tri c Company, Nuclear Energy Division, San Jose, California.

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

1963 - 1970:

Design Engineer - General Electric Company, Nuclear Energy Division, 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~

flux in the reactor during startup and intermediate power opera-ti on . 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 - General Electric Company, Assign-ments in Washi ngton, Cali fornia, 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 equi pment maintenance coordina tion.

- Design Engineer - Microwave Department, Palo Alto, Cali-fornia. Work on design of cavity couplers for TWT's .

Design Engineer - Computer Department, Phoenix, Ari zona .

Design o f co re dri vi ng ci rcui try.

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

- Design Engineer - Space Systems Department, San ta Ba rba ra ,.

Cali f o rnia . Prepare control portion of satellite proposal.

Technical Staff - Technical Military Planning Operation.

(TEMPO), Santa Barbara, California. Prepare analysis of missile exchangese During this period, completed three-year General Electric program of extensive education in advanced engineering principles of higher ma thema ti cs , probabili ty and analysis . Also completed courses in Kepner-Tregoe, Effective Presentation, Management Training Program, and various technical seminars.

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EDUCATION University of California at Berkeley, BSSE, 1960.

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

S tan ford Unive rsi ty , MSEE, 1966.

HONORS AND ASSOCI ATIONS ,

- Tau Beta Pi Engineering Honorary Society

- Co-holde r of U.S. Pa tent No. 3,565,760, " Nuclear Reactor Power Moni toring System," February 1971.

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Member: American Association for Advance of Science.

Member: Nuclear Power Plant Standards Committea, Instru-ment Society of America.

PERSONAL DATA Born: June 7, 1937 Ma rrie d, three children Residence: San Jose, California

PUBLICATIONS AND TESTIMONY

1. G.C. Mi no r , S .E . Moo re , " Con trol Rod Si gnal Mul tiplexi ng,"

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

2. G. C. Mino r, W.G. Mil am, "An Integrated Control Room System for a Nuclear Power Plant," NED0-10558, presented at International Nuclear Industries Fair and Technical Me'etings, October 1972, Basle , Swi tzerland.

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

Tes timony of G.C. Minor, D.G. Bri denbaugh , and R.B. Hubba rd 4.

before the Joint Committee on Atomic Energy, Hearings held Feb rua ry 18, 1976, and published by the Union of Concerned Scien tis ts , Cambri dge , Massachuse tts .

5. Tes timony o f G. C. Minor, D.G. Bridenbaugh, and R.B. Hubbard before the California State Assembly Committee on Resources, Land Use, and Energy, March 8, 1976. ,,

6. Tes timony of G.C. Minor and R.B. Hubbard before the California. -

Sta te Senate Committee on Public Utili ties , Transi t, and Energy, March 23, 1976.

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

8. Tes timony of G.C. Minor before the Cluf f Lake Board of Inqui ry Regina, Saskatchewan, Canada, September 21, 1977.

9. The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Safety Study WASH-1400 (NUREG-75/014), H. Kendall, et al, edited by G.C. Minor and R.B. Hubba rd for the Union of Concerned Scientists, August 1977.

10. Swedi sh Reacto r Safety Study: Barsebh*ck Risk Assessment, MHB Technical Associa tes , January 1978. (Published by Swedishl Department of Industry as Document Sdl 1978:1)

11. Testimony by G.C. Minor before the Wisconsin Public Service Commi s s i o n , Fe b rua ry 13, 1978, Loss of Coolant Accidents: '

Thei r Probabili ty and Consequence.

12. Testimony by G.C. Minor before the Cali fornia Legisla ture Assembly Committee on Resources, Land Use and Energy, AB 3108,;

April 26, 1978, Sacramento, Ca l i fo rn ia .

13. Presen tation by G.C. Minor before the Federal Mi nis try for Research and Technology (BMFT), Meeting on Reactor Safety Research, Man / Machine In terface in Nuclear Reactors , August 31 and September 1, 1978, Bonn, Germany.

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PUBLICATIONS AND TESTIMONY

14. Tes timony by G.C. Minor, D.G. B ridenba ugh , and R.B. Hubba rd before the Atomic Safety and Licensing Board, September 25,

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t 1978, In the Matter of the Black Fox Nuclear Power Station Construction Permit Hearings , Tulsa, Oklahoma.

15. G.C. Minor, D.G. Bridenbaugh, and R.B. Hubbard, Improving the Safety _of LWR Power Plants, prepared for Sandia Laboratories  :

by MHB Technical Associates, September 27, 1979. ,

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m I in, BIOGRAPHICAL DATA p gggmo t y c3ar.3 ,

rF u.3 2 5 E50> 'd NAME: Robert Neil Anderson .

cendBB W 6 6 escrt& CdG ADDRESS: Work: Department of Materials Engineering San Jose State University San Jose, California 95192 6

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p k (408/277-3751 or 277-2446)

Home: 3084 Stelling Drive Palo Alto, California 94303 (415/494-7824)

PERSONAL INFOPf4ATION:

Date of Birth: November'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 19 0 M.S., Chemical Engineering, University of California - Berkeley 1959 Ph.D. , Metallurgy, Stanford University,1969 Post Doctoral Study in Metallurgy - Stanford University, 1970-1973 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 Associate, 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 f.;EP!ID J A!! l 7 66b e e

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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 Quality and Office of Science.and Technology Policy, 1978 United States Congress, Office of Technology Assessment,1979 Scientific Service Incorporated, 1977-78 MHB Associates, 1977 - present Parlee-Anderson Corp., 1979 - present Accident Analysis, 1974 - present Mcdermitt Mine, 1976 - present International Business Machines, 1977-78 ,

Memorex, 1979 d Electrical Power Research Institute,1974 ,

SRI, 1975-77 Brookhaven National Laboratories, 1977-78 Attornies (list on request)

PROFESSIONAL ^ ACTIVITIES:

American Nuclear Society, American Institute of Chemical Engineers, American Chemical Society, American Institute of Metallurgical Er.gineers (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 S.igma Xi.

CREDENTIALS'AND LICENSES:

California Standard Teaching Credential.

Registered Metallurgical Engineer, California. -

Registered Nuclear Engineer, California.

Fallout Shelter Analyst.

Private Pilots License. s PUBLICATIONS:

Articles :

1. "The Activity of Titanium in Liquid Alloys," Accepted for publication

and presentation in the Fourth International Conference on Titanium l

19-22 May,1980, International. Conference Hall, Kyoto, Japan.

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

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

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

Nuclear Engineering International, ~0ctobar.,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 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 Conmission (August 30,1979).

7. "The Kinetics of UO2 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.

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

Solid Films, accepted for publication 1979.

11. "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 MHD to Smelt Metals: Industrial Research/ Development September 1978 (p.p.131-34),

13. "The Application of Magneto Hydro-Dynamics to Steelmaki.ng," 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 i Symposium on Contamination Control, 10-13 September 1978, Washington, D.C.

15. " Separation Technologies Reviewed," Nuclear Engineeri.ng International, August, 1978.

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,' PbBLICATIONS (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 Hu.eneme," 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 Nuc7 ear Waste 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 Quality, 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 Reprocessing and Radioactive Waste Disposal," report to State of California Energy Resources Conservation and Development Commission, January,1978.

22. " Methodology for Comparative Evalustion 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 Racycli.ng, V. 1, 1977.

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

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

Technical Repo.rt 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 for the Recovery of ,

Metals in the Non-Ferrous Pcrtion of Automobile Shredder Refuse,"  ;

. Proceedings of the Fifth Mineral Waste Utilization Symposium, April j 13-14, 1976.  ;

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PUBLICATIONS (continued)

30. " Evaluation 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," 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 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 Fonnation 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 H.igh Temperature Science, (with A-FUWA 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 Instit"te of Chemical Engineers, Dec. 1-15, 1974.

41. " Nitrogen-Nitride Equilibria in Molten 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).

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PUBLICATIONS (continued)

45. " Application of Nitride-Forming Reactions to Reprocessing of Spent Nuclear Fuels," Nuclear Technology, V.13, January,1972.

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

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

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

W. Germany 2,103,255 Jan. 25, 1971 U.S. Patent Applications 905,745 filed May 15, 1978 038,382 filed May 14, 1979 l

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~ Dale G. Bridanbaugh 1723 Hamilton Avenue, Suite K y

[e ocena cc:a 5

San Jose, CA 95125 (408)266-2716 Of L%R 2 5 EZ > {

Ofteotthe sect 1 F EXPERIENG,: 6 M{a 1976 - Present 4 y y Partner, MH3 Technical Associates, San Jose. California. Founder and partner of technical consulting firm. Specialises in energy consulting to governmental and other groups interested in evaluation of nuclear plant safety and licensing. Consultant in this capacity to State of California, Suffolk County, New York, New York Attorney General, Nor-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 ' Review of WASH-1400; consultant to U.S . NRC - LWR Safety Improvement Program, and performed Cost Analysis of Spent Fuel Disposal for NRDC.

1976 - (February - August) .

Consultant, Project Survival, Palo Alto, California. Volunteer work

on Nuclear Safeguards Initiative campaigns in California, Oregon, Washington, Arizona, and Colorado. Numerous presentations on nuclear i power and alternative energy options to civic, government, and college groups. Also resource person for public service presentations on radio and television.

1973 - 1976 Manager, Performnce Evaluation and Imorovement, General Electric Company - Nuclear Energy Division, San Jose, California. Managed seventeen technical and seven clerical personnel with responsibility for establishment and management of systems to monitor and measure Boiling Water Reactor equipment and system operational 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 Master Performancc Improvement .

Plan as well as for numerous 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 i Manager, Product Service, General Electric Company - Nuclear Enerq Division, San Jose, California. Managed group of twenty-one techn cal and four clerical personnel. Prime responsibility was to direct inter-face and liason personnel involved in corrective actions required under contract warranties. Also in charge of refueling and service planning,'

performance analysis , and service communication functions supporting al-completed commercial nuclear power reactors supplied by General Electri both domestic and overseas (Spain, Germany, Italy, Japan, India, and Switzerland) .

1968 - 1972 Manager, Product Service, General Electric Comoany - Nuclear Energy Division, San Jose, California.

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' Mafia [ed"sixtie'en technical and sh blerical' personneE#ith7he 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 of parts increased from $1',000,000 in 1968 to over $3,000,000 in 1972.

1966 - 1968 Manager, Comolaint and Warrantv Service. General Electric Company -

Nuclear Energy Division, San Jose, California.

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

both domestic and overseas.

1963 - 1966  ;

Field Engineering Supervisor, General Electric Ccmoany. Installation !

ano service Engineering Deoartment, Los Angeles. California.  !

Supervised approximately eight field representatives with responsi-bility for General Electric steam and gas turbine installati6n and ,

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

1956 - 1963 l

- Field Engineer, General Electric Comoany, Installation and Service l Engineering Department, Chicago, Illinois. l 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 primarily with large utilities but had significant work with steel, petroleum and other process industries. Had four years of experience at construction, startup, trouble-shooting and refueling of the first large-scale commercial nuclear power unit.

1955 - 1956 Engineering Training Program, General Electric Ccmpany, Erie, Pennsylvania, ano scnenectacy, New York.

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 Army - Ordnance School, Aberdeen, Maryland Instructor - Heavy Artillery Repair. Taught classroom and shop disassembly of artillery pieces.

1953 Engineering Training Program, General Electric Comoany, Evendale, Ohio; training assignment with Aircraft Gas Tur'oine Denartment. l

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l EDUCATION & AFFILIATIONS [

BSNE - 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, Kepner Tregoe Decision Making, Effective Presentation, and numerous technical seminars.

HONORS & AWARDS Sigma Tau - Honorary Engineering Fraternity.

General Managers Award, General Electric Company.

PERSONAL DATA Born November 20, 1931, Miller, 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 groups. .

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-c..  ; . i PUBLICATIONS & TESTIMONY ,

1. Operating and Maintenance Experience, presented at Twelfth -

Annual Seminar for Electric Utility Executives, Pebble Beach,

' California, October 1972, published in General Electric NEDC-10697, December 1972.

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2. Maintenance and In-Service Inspection, presented at IAEA ,

Symposium on Experience From Operating and Fueling of Nuclear  !

Power Plants, Bridenbaugh, Lloyd, & Turner, Vienna, Austria, i October 1973. j

3. Ocerating and Maintenance Experience, presented at Thirteenth r Annual Seminar for Electric Utility Executives , Pebble Beach, l California, November 1973, published in General Electric NEDO- l 20222, January 1974. ,

4. Imoroving Plant 1vailability, presented at Thirteenth Annual ,

Seminar for Electric Utility Executives , Pebble Beach, Californi(

November 1973, published in General Electric NED0-20222, Januaryg 1974. ,

5. Application of Plant Outage Experience to Imorave Plant Per- ,

formance, Bridenbaugh and Burdsall, American Power Conference, Chicago, Illinois, April 14, 1974.  ;

6. Nuclear Valve Testing Cuts Cost, Time , Electrical World, October ' -

15. 1974. .

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7. The Risks of Nuclear Power Reactors: A Review of the NRC Reactore Safety Study WASH-1400_, Kendall, Hubbard, Minor, & Bridenbaugh, .

et al, for the Union of Concerned Scientists , August 1977.

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8. Swedish Reactor Safety Study: BarsebEck Risk Assessment, MHB Technical Associates, January 1978. (Published by Swedish Depart l ment of Industry as Document DsI 1978;1) l

9. Testimony of D. G. Bridenbaugh, R. B. Hubbard, G. C. Minor to the!

' California State Assembly Committee on Resources , Land Use, and l Energy, March 8, 1976. l.

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

11. Testimony by D. G. Bridenbaugh before the California Energy Commission, entitled, Initiation of Catastrochic Accidents at Diablo Canven_, Hearings on Emergency Planning, Avila Beach, Califgrnia, November 4, 1976.

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12. Testimony by D. G. Bridenbaugh before the U.S. Nuclear Regulatory Commission, subject, Diablo Canvan Nuclear Plant Performance, Atomic Safety and Licensing Board Hearings, December 1976

13. Testimony by D. G. Bridenbaugh before the California Energy Commission, subject, Interim Soent Fuel Storage ConsideratLons_,

March 10, 1977.

14. Testimony by D. G. Bridenbaugh before New York State Pub 7.ic Service Commission Siting Board Hearings concerning the Jamesport Nuclear Power S tation, subject: Effect of Technical and Safetv Deficiencies on Nuclear Plant Cost and Reliability, April 1977.

15. Testimony by D. Gl Bridenbaugh before' the California State Energy Commission, subject, Decommissioning of Pressurized Water Reactors , Sundesert Nuclear Plant Hearings, June 9, 1977.

16. Testimony by D. G. Bridenbaugh before the California State Energy Commission, subject, Economic Relationshios of Decommissioning, 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, Ooeration of Vermont Yankee Nuclear Plant and Its Imoact on Public Health and Safetv, October 6, 1977.

18. Testimony by D. G. Bridenbaugh before the U.S. Nuclear Regulatory Commission, Atomic Safety and Licensing Board, subject, Defi-ciencies in Safety Evaluation of Non-Seismic Issues . Lack of a Definitive Finding of Saf e ty , Diablo Canyon Nuclear Units ,

October 18, 1977, Avila Beach, California.

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

20. Testimony by D. G. Bridenbaugh before the Louisiana State Legis lature Committee on Natural Resources , subject, Nuclear Power Plant Deficiencies Imoacting on Safe ty & Reliabilitv_, Baton Rouge, Louisiana, February 13, 1978. ,

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

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22. Testimony by D.G. Bridenbaugh, G.C. Minor, and R.B . Hubbard l before the Atomic Safety and Licensing Board, in the matter of l the Black Fox Nuclear Power Station Construction Permit Hearings j Sep tember 25, 1978, Tulsa, Oklahoma.

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.s PUBLICATIONS AND TESTIMONY  ;

23. Testimony of D.G. Bridenbaugh and R.B. Hubbard before the I Louisiana Public Service Cor: mission, Nuclear Plant and Power Generation Costs, November 19, 1978, Baton Rouge, Louisiana.

24. Testimony by D.G. Bridenbaugh before the City Council and l Electric Utility Commission of Austin, Texas, Design, Con-struction, and Ooerating Exoerience of Nuclear. Generating i Facilities, December 5, 1978, Austin, Texas I

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD In the Matter of ) Docket Hos. 50-250-SP

) 50-251-SP FLORIDA POWER & 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 th'e foregoing Motion to Amend Contentions was mailed this lith day of March,1980, to the following individuals:

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Norman A. Coll, Esq. s ,

Steel, Hector & Davis (/ C;0'Z:D Ei ba3; 14th Floor 9 _,

So h a t First National Bank f.BR 2 5 Ec0 > 3.,

" O!Rsoits keday  !

Miami, Florida 33131 Elizabeth S. Bowers, Esq. O * >g e,-

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

a c 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 , ,

1 Mr. Mark P. Oncavage 12200 S. W. 110 Avenue Miami, Florida 33176 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Steven C. Goldberg, Esq.

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

Joel V. Lumer, Esq.

Richard A. Marshall, Jr., Esq.

Counsel for Intervenor 3301 College Avenue Fort Lauderdale, Florida 33314 Harold F. Reis, Esq.

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

. Washington, D. C. 20036

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w..' f f' ' 'll & c; j.ENRYH.HARNAGEJ N

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