ML20010B596

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Affidavit by DG Bridenbaugh & RB Hubbard.Estimates Time Required After Issuance of OL to Load Fuel & Conduct Tests & Identifies Difficulties & Costs of Mods After Fuel Loaded. W/Prof Qualifications
ML20010B596
Person / Time
Site: Diablo Canyon  
Issue date: 08/11/1981
From: Bridenbaugh D, Hubbard R
JOINT INTERVENORS - DIABLO CANYON
To:
Shared Package
ML20010B594 List:
References
ISSUANCES-OL, NUDOCS 8108170305
Download: ML20010B596 (18)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION

)

In the Matter of

)

)

PACIFIC GAS AND ELECTRIC COMPANY

)

Docket Nos. 50-275 0.L.

)

50-323 0.L.

(Diablo Canyon Nuclear Power

)

Plant, Unit Nos. 1 and 2)

)

)

AFFIDAVIT OF DALE G. BRIDENBAUGH AND RICHARD B. HUBBARD DALE G. 3RIDENBAUGH and RICHARD B. HUBBARD, being first duly sworn, state under oath as follows:

1.

In preparing this affidavit, affiant Richard B.

Hubbard reviewed PG6E's proposed special low power test pro-gram as set forth in the low power license application and as further described in PG6E's safety analysis report provided to the NRC Staff on February 6, 1981.

He also attended, as a consultant to Governor Brown's counsel, all sessions of the recent low power

  • st proceedings which were held in San Luis Obispo from May 19 to May 22, 1981.

Thus, he is familiar with the duration of the low power tests as postulated by PG6E and f

Staff witnesses.

Further, he has reviewed the actual schedule for fuel loading, initial criticality and zero power testing, and low power testing of large PWR's which have occurred in the 8108170305 810811 \\

PDR ADOCK 05000275r C

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post-TMI period, particularly North Anna-2, Salem-2, and Se-quoyah-l.

In addition, on July 10, 1931, Hubbard accompan-ied Commissioner Gilinsky on his tour of the Diablo Canyon facility.

A recent statement of Hubbard's professional qualifications and experience is set forth in Exhibit 16 of

" Opposition of Governor Edmund G. Brown, Jr. to the NRC Staff and Pacific Gas and Electric Company Motions for Reconsidera-tion and Summary Disposition," dated April 24, 1981.

2.

Affiant Dale G. Bridenbaugh is a Professional Nu-clear Engineer, technical consultant, co-founder and president of MHB Technical Associates, technical consultants on energy and environment, with offices at 1723 Hamilton Avenue, Suite K, San Jose, California.

He has participated as an expert witness t

in licensing proceedings before the U.S. Nuclear Regulatory Commission (NRC); has served as a consultant to the NRC; has testified at the request of the Advisory Committee on Reactor Safeguards; has appeared before various committees of the U.S.

Congress and testified in various state licensing and regulatory proceedings.

Additional details of Bridenbaugh's experience and qualifications are set forth in Attachment A, which is at-tached hereto.

3.

The purpose of this affidavit is twofold:

First, to estimate the elapsed time which is likely to be required after issuance of a low power operating license to load fuel and to.-.

complete the special low power tests at or below 5% of Rated Thermal Power as Pacific Gas and Electric Company has proposed for Diablo Canyon Unit 1; second, to identify the technical difficulties and increas;d costs associated with modifying the structures, systems, and components of the plant should further modifications be required after fuel has been loaded and operation commenced.

The results of our review are sum-marized in the following paragraphs.

4.

During Commissioner Gilinsky's tour of the Diablo Canyon facility, both NRC and PB6E personnel emphasized PGSE's readiness to load fuel.

The necessary fuel is presently onsite in a building immediately adjacent to the Containment Building.

Further, due to the duration of the licensing process, PG6E has had sufficient time to conduct, and in some cases reconduct, its pre-operational tests as set forth in Section 14.1 of the Final Safety Analysis Report.

Thus, we conclude that Diablo Canyon Unit 1 equipment is in an advanced state of readiness to load fuel, and that virtually all preliminary testing (see FSAR Table 14.1-1) possible prior to fuel loading has been completed. /

Further, we conclude that PG6E should be able to promptly load fuel once such authorization is received from the NRC.

5.

We estimate that the fuel loading task should be com-pleted in less than one week elapsed time.

For example, at

  • /

A recent Nucleonics Week article indicates that all steps

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prior to fuel load will be completed by approximately August 12, 1981 (p. 4, Nucleonics Week, July 23, 1981).

In general, all pre-operational testing will be completed before fuel loading (FSAR, p. 14.1-8).

Salem-2, a Westinghouse-designed PWR similar in design and rat-ing to Diablo Canyon, fuel loading began on May 23, 1980 and was completed on May 27, 1980.

More specifically, a PGGE spokesman recently estimated that preparation and fuel loading of Diablo Canyon Unit 1 could be completed in about one month af ter issuance of a low power license (see July 18, 1981 ar-ticle from the San Francisco Chronicle, which is attached here-to as Attachment B).

Therefore, we conclude that it is reason-able to expect that fuel loading of Diablo Canyon could be com-pleted in one to two weeks and certainly no more than 30 days after the issuance of a low power test license. /

6.

The next phase of startup and testing includes initial criticality and low power testing.

FSAR Table 14.1-2 summar-i:es the normal tests which will be performed.

In addition, tl.e scope and duration of the special low power tests were des-cribed in detail during the recent low power proceedings in San Luid Obispo.

The Board, in the partial Initial Decision dated July 17, 1981, noted at page 24, paragraph 61, that PGSE has proposed a series of eight special low power-tests.

The propos-ed tests would probably last for no more than one onth and in actuality, as cited by the Board, would,erhaps take only about eighteen days (Tr. 10,726-10,728).

Other references to the "re-latively few days" encompassed by the proposed low power test

  • /

It has been reported that PGGE expects fuel loading to take no longer than two weeks (p. 4, Nucleonics Week, July 23, 1981).

4

prograr are set forth in the recent decision by the Board at page 2S (paragraph 65), page 32 (paragraph 82), and page 33 (paragraph 83).

Therefore, we believe that it is reasonable to expect tha;. absent major problems, initial criticality and low power testing can be conducted in an elapsed time.of less than 30 days.

Thus, assuming a 30-day period to complete fuel loading (which we believe to be very conservative), the entire fuel load and testing program can easily be completed in no more than 60 days.

7.

The reasonableness of a 60-day cycle from license is-suance to completion of the special low power tests was further confirmed during Commissioner Gilinsky's tour of the.Diablo Can-yon facility.

In response to a question, the Diablo Canyon Plant Manager. Robert C. Thornierry, stated in Hubbard's pre-sence that PGSE's current schedules forecast that fuel loading,

ero power testing, and the special low power test program will be completed approximately 58 days after receipt of a low power license.

Mr. Thornberry added that the schedule might need to be increased if major unanticipated problems were encountered during the test program.

8.

In order to be conservative, we believe it may be ap-propriate to add 15 to 30 days to the fuel loading and low pow-er testing schedule to allow time for resolution of any routine unanticipated events.

In reaching the_ preceding conclusions, we have assumed a routine startup during which no major acci-dent, such as a seismically induced LOCA, occurs.

Thus, we are not stating any conclusion on either the risk potential during low power testing or the probability of accidents oc-curring during such testing.

Our sole purpose is to express the view that absent unforseen events, the PG6E startup and low power testing program should require no more than 30 days to complete after fuel is loaded.

9.

The post-TMI experience and the current schedules for startup testing lend further support to the preceding conclu-sions.

The first plant granted an operating license in the post-TMI period was Sequoyah-1, which received a low power license on February 29, 1980.

Fuel loading commenced on March 2, 1980 and was completed on March 8, 1980.

Two major prob-lems thereafter seriously delayed the initial criticality of Sequoyah-1.

First, in response to ISE Bull. 79-14, TVA re-quired approximately 60 days to inspect and rework pipe hangers and supports.

Second, in parallel with the hanger reinspection, TVA conducted a base line inspection of the turbine blades.

The turbine reinspection required 4-5 weeks of elapsed time.

Routine maintenance problems and pre-operational testing re-sulted in further delays.

Initial criticality was achieved on July 5, 1980.

Following zero power testing, the special low power testing program began on July 12 and was completed on - -

July 18, 1980.

10.

The second plant to receive a post-TMI license to load fuel and conduct

,2cial low power tests was North. Anna-2.

The authorization to load fuel was issued on April 11, 1980 and the low power t ting was completed by July 1,1980, an elapsed time of less than 80 days.

The Salem-2 low power li-1 cense was issued on April 18, 1980.

As set forth in paragraph 5, fuel loading was completed on May 27, 1980.

Initial cri-ticality was achieved on August 2, 1980 and the s'pecial low power test program was completed on August 29, 1980.

The two months delay between fuel loading and initial criticality was 1crgely due to the need to conduct routine pre-operational-maintenance testing and surveillance testing (such as valve operability) which could have been accomplished prior to fuel load.

As presented in~ paragraph 4, we believe that these pre-operational tests will be accomplished at Diablo, Canyon prior j

to mid-August, 1981.

Thus, we conclude that the actual dura-tion of the Salem-2, North Anna-2, and Sequoyah-1 fuel loading and low power testing programs is not inconsistent with our conclusions for Diablo Canyon as set forth herein.

11.

Table I of the testimony of Applicant's witness, Dr. Brunot, in the low power test proceedings sets forth the fission product inventories which will be produced in the core during the proposed Diablo Canyon low power test program.

For _ _ - _ _ - _ _ - _

+

example, the inventory of iodine-131, one of the radionuclides which is a significant contributor to the dominant exposure modes for accidents requiring off-site emergency preparedness, is estimated by Dr. Brunot as 4,500,000 curies (approximately 1/20th the full power value as set forth in FSAR Table 11.1-4).

In contrast, for the design basis LOCA addressed by the Appli-cant in the FSAR for full power operation, only 192 curies of iodine-131 were postulated to be released to the environment in the first two hours (FSAR Table 15.5-12).

Therefore, be-cause of the relatively rapid buildup (half-life of hours to days) of the radioactive isotopes listed in Table 3 of NUREG-

  • /

0654 which dominate prompt health consequences resulting from postulated accidental releeses, we conclude that even at 5%

power the fission products available f,r release pose a sig-nificant potentir.1 hazard.

12.

Operation at low power will not only cause a buildup of fission products within the reactor core, making it in c-cessible for contact repair and/or modification but will also cause a spread of radioactive contaminants throughout the pri-mary portion of the steam supply system.

It will also contam-inate certain auxiliary systems such as the Chem al and Volume Control System, Equipment and Floor Drainage S ams, and the Liquid Radioactive Waste System.

If fu-1 f;

.s and/or steam generator tube failures or leaks are expericn_ed, a large number

  • /

NUREG-0654, Rev. 1 (FEMA-REP-1), " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Pre-paredness in Support of Nuclear Power Plants," November, 1980...

of other systems, including the turbine, condensate, and other components within the Steam and Power Conversion System could become contaminated.

Contamination and irradiation of such equipment greatly increases the care rcquired and the time and cost of future modifications that could be required at the plant.

It is, therefore, important that power operation, in-cluding low power testing, not be permitted until reviews and evaluations that could lead to required plant modifications have been completed.

13.

Based on the foregoing, we conclude that fuel loading, initial criticality, and low power testing, including the spe-cial low power tests, can be accomplished at Diablo Canyon Unit 1 within approximately 60 days, with an outside maximum elapsed time of approximately 90 days, after issuance of the low power operating license.

We further conclude that the fuel loading portion of the startup schedule should be completed within less than 30 days following issuance of the low power license.

Final-ly, we conclude that operation at low power will contaminate some of the facility's components and systems.

This unnecessary com-mitment of resources creates technical difficulties and increased costs associated with modifying the reactor, should further modi-fication be required after fuel has been loaded and power opera-tion commenced.,-

I have read the foregoing and swear that it is true and j

accurate to the best of my knowledge.

JA DALE G. BRIDENBAUGH M@

RICHARD B. HUBBARD

// c4 Subscribed and sworn to before me this day of August, 1981.

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ATMANWnna PROFESSIONAL QUALIFICATIONS OF DALE G.

B RI DENB AUGH DALE.

B RI DEN B AUGH 1723 3amilton Avenue Suite K Son Jose, CA 95125 (408) 266-2716 E XP E RIEN CE :

19 7 6 - PRESENT President - MHB Technical Associates, San Jose, California.

Co-founder _and partner of technical consulting firm.

Specialists in energy consulting to governmental and other groups interested in evaluation of nuclear plant safety and licensing.

Consultant in this capacity to state agencies in California, New York, Illi-nois, New Jersey, Pennsylvania, Oklahoma and Minnesota and to the Norwegian Nuclear Power Committee, Swedish Nuclear Inspectorate, and various other organizations and environmental groups.

Per-formed extensive safety analysis for Swedish Energy Commission and contributed to the Union of Concerned S cientis t's Review of WASH-1400.

Consultant to the U.S.

NRC - LWR S af ety Improvement Program, performed Cost Analysis of Spent Fuel Disposal for the Natural Resources Defense Council, and contributed to the Depart-ment of Energy LWR Safety Improvement Program for Sandia Labora-tories.

Served as expert witness in N RC and state utility commission hearings.

1976 - ( FEB RUA RY - AUGUS T)

Consultant, Project Survival, Palo Alto, California.

Volunteer work on Nuclear Saf eguard s Initiative campaigns in California, Oregon, W a s h in g t on, Arizona, and Colorado.

Numerous presentations on nuclear power and alternative energy options to civic, government, and college groups.

Also resource person for public service presentations on radio and television.

1973 - 1976 Manager, Pe.rfermance Evaluation and Improvement, General Electric 4

Company - Huclear 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, c o o r d in a t e d correction of causes of forced outages and of efforts to improve reliability and per-formance of BWR systems.

1

1973 - 1976 (Contd)

Responsible for development of Division Master P erf ormance Improvemant Plan as well as for numerous Staff special assign-ments on long-range studies.

Was on special assignment for the management of two different ad hoc proj ects formed to resolve unique technical problems.

j 1972 - 1973 Manager, Product Service, General Electric Company - Nuclear Energy Division, San Jose, California.

Managed group of twenty-one technical and four clerical personnel.

Prime responsibility was to direct interface and liaison personnel involved in corrective actions required under contract warranties.

Also in charge of refueling and service planning, performance analysis, and service commuaication functions supporting all com-pleted commercial nuclear power reactors supplied by General Electric, both domestic and overseas (Spain, Germany, Italy, Japan, India, and Switzerland).

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

Managed sixteen technical and six clerical personnel with the r e s p on s ib ility for all customer contact, planning and execution of work required after the customer acceptance of department-supplied plants and/or e qu ipmen t.

This included quotation, sale and delivery of spare and renewal parts.

Sales volume of p rts increased from $1,000,000 in 1968'to over $3,000,000 in 1972.

1966 - 1968 Manager, Complaint and Warranty 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 l

domestic and overseas.

1963 - 1966 Field Engineering Supervisor, General Electric Company, Installation and Service En g in e e r in g Department. Los An g e 1.e s, California.

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

During this period was responsible for the installation of eight different central station steam turb ine generator units, plus much maintenance activity.

Work included customer contact, prepa-ration of quotations, and contract negotiations.

1956 - 1963 Field Enginee r, General Electric Company, Installation and Service Engineering Department, Chicago, Illinois.

Supervised installation and maintenance of steam turbines of all sizes.

Supervised crews of from ten to more than one hundred men, depending on the j ob.

Worked primarily with large utilities but had significant work wi*h steel, petroleum and other process industries.

Had four years of experience at construction, startup, trouble-shooting and refueling of the first large-scale commercial tuelear power unit.

1955 - 1956 Engineering Training Program, General Electric Company, Erie, Pennsylvania, and Schenectady, New York.

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

1953 - 1955 United S tates Army - Ordnance School, Aberdeen, Maryland.

Instructor - Heavy Artillery Repair.

Taught classroom and shop disassembly of artillery pieces.

1953 Engineering Training Program, General Electric Company, Evandale, Ohio.

Training assignment with Aircraft Gas Turbine Department.

EDUCATION & AFFILIATIONS:

BS ME - 1953, South Dakota S chool of Mines and Technology, Rapid City, South Dakcta, Upper k of class.

P rof es sional Nuclear Engineer - Calif ornia.

Certificate No. 0973.

Member - American Nuclear Society.

Various Company Training Courses during career including Prof es-sional Business Management, Kepner Tregoe Decision Making, Effective Presentation, and numerous technical seminars. i

e H ON O RS & AWARDS:

Honorary Engineering Fraternity.

Sigma Tau 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:

S kiiin g, hikirg, work with Cub and Boy Scout Groups.

P UB LIC ATION S & TESTIMONY :

1.

Operating and Maintenance Experience, presented at Twelfth Annual S eminar f or Electric Utility Executives, Pebble Beach, California, October 1972, published in General Electric NEDC-10697, December 1972.

2.

Maintenance and In-Service Inspection, presented at IAEA Symposium on Experience From Operating and Fueling of Nuclear Power Plan ts, B ridenbaugh, Lloyd & Turner, Vienna, Austria, October, 1973.

3.

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

4.

Improving Plant Availability, presented at Thirteenth Annual Seminar for Electric Utility Executives, Pebble Beach, Cali-fornia, November 1973, published in General Electric NEDO-20222, January, 1974 5.

Application of Plant Outage Experience to Improve 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.

7.

The Risks of Nuclear Power Reactors:

A Review of the NRC Reactor S af ety S tudy WASH-1400, Kendall, Hubbard, Minor &

Bridenbaugh, et al, for the Union of Concerned S cientists,

August, 1977.

1.- -

o 8.

Swedish Reactor Safety Study:

BarsebEck Risk Assessment, MHB Technical Associates, January, 1978.

(Published by the Swedish Department of Industry as Document DsI 1978:1) 9.

Testimony of D.G. Bridenbaugh, R.B.

Hubbard, G.C.

Minor to the California State Assembly Committee on Resources, Land Use, and Energy, March 8, 1976.

10.

Testimony of D.G.

Bridenbaugh, R.B. Hubbard, and G.C.

Minor before the United S tates Congress, Joint Committee on Atomic Energy, February 18, 197 6, Was hin gton, DC (Published by the Union of Concerned S cientis ts, Cambridge, Massachusetts.)

11.

Testimony by D.G. Bridenbaugh before the California Energy Commission, entitled, Initiation of Catastrophic Accidents at Diablo Canyon, Hearings on Emergency P lanning, Avila Beach, California, November 4, 1976.

12.

Testimony by D.G.

Bridenbaugh before the U.S. Nuclear Regula-tory Commission, subject: Diablo Canyon Nuclear Plant Perfor-mance, Atomic S afety and Licensing Board Hearings, December, 1976.

13.

Testimony by D.G.

Bridenbaugh before the California Energy Commission, subject: Interim Spent Fuel S torage Considerations, March 10, 1977.

14.

Testimony by D.G.

Bridenbaugh before the New York S tate Public Service Commission Siting Board Hearings concerning the James-port Nuclear Power S tation, subject: Effect of Technical and Safety Deficiencies on Nuclear Plant Cost and Reliability, April. 1977, 15.

Testimony by D.G.

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 Calif ornia S tate Energy Commission, subject: Economic Relationships 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, subj ect : Operation of Vermont Yankee Nuclear Plant and It s Imoac t on Public Health and Safety, October 6, 1977.

18.

Testimony by D.G. Bridenbaugh before the U.S.

Nuclear Regula-tory Commission, Atomic Safety and Licensing Board, subject:

Deficiencies in Safety Evaluation of Non-Seismic Is sues, Lack of a Definitive Finding of Saf ety, Diablo Canyon Nuclear Units October 18, 1977, Avilt Beach, California...

19.

Testimony by D.G. Bridenbaugh before the Norwegian Commission on Nucliar Power, subject: Reactor S af ety/Ris k.

October 26, 1977.

20.

Testimony by D.G.

B ridenbaugh bef ore the Louisiana S tate Legislature Committee on Natural Resources, subject: Nuclear Power Plant Deficiencies Impacting on Safety & Reliability, Baton Rouge, Louisiana, February 13, 1978.

21.

Spent Fuel Disposal Costs, report prepared by D.G.

Bridenbaugh for the Natural Resources Lef ense Council (NRDC), August 31, 1978.

2 ?..

Tes timony by D.G. B ridenbaugh, G.C. Minor, and R.B. Hubbard before the Atenic S af ety and Licensing B oard, in the matter of the Black Fox Nuclear Power S tation Construction Permit Hearings, September 25, 1978, Tulsa, Oklahoma.

23.

Testimony of D.G.

Bridenbaugh and R.B.

Hubbard before the Louisiana Public Service Commission, Nuclear Plant and Power Generation Costs, November 19, 197 8, B aton Rouge, Louisiana.

24.

Testimony by D.G. Bridenbaugh before the City Council and Electric Utility Commission of Austin, Texas, Design, Con-struction, and Operating Experience of Nuclear Generating Facilities, December 5, 1978, Austin, Texas.

25.

Testimony by D.G.

Bridenbaugh for the Commonwealth of Massachusetts, Department of Public Utilities, Impact of Unresolved S af ety Issues, Generic Deficiencies, and Three Mile Island-Initiated Modifications on Power Generation Cost, at the P ropc Ted Pilgrim-2 Nuclear Plant, June 8, 1979.

26.

Improving the Safety of LWR P ower Plan ts, MHB Technical Associates, prepared for U.S.

Dept. of Energy, Sandia Laboratories, September 28, 1979.

27.

3WR Pipe and Nozzle Cracks, MHB Technical Associates, for the Swedish Nuclear Power Inspectorate (SKI), October, 1979.

28.

Testimony of D.G.

B ridenbaugh and G. C.

Minor before the Atomic Safety and Licens ing B oard, in the matter of Sacramento Municipal Utility District, Rancho Seco Nuclear Generating S tation f ollowing TMI-2 accident, subject:

Operator Training and Human Factors En g in e e r in g, for the California Energy Commission, February 11, 1980.

29.

Italian Reactor Safety Study:

Caorso Risk Assessment, MHB Technical Associates, for Friends of the Earth, Italy, March, 1980.

30.

Decontamination of Krypton-85 from Three Mile Island Nuclear

Plant, H.
Kendall, R.

Pollard, &

D.G.

Bridenbaugh, et al, The Union of Concerned S cientis ts, delivered to the Governor of Pennsylvania, May 15, 1980. 1

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31.

Testimony by D.G. Bridenbaugh before the New Jersey Board of Public Utilities, on behalf of New Jersev Public. Advocate's Office, Division of Rate Counsel, Ana'

.s of 1979 Salem-1 Refueling Outage, August, 1980.

32.

Position S tatement, Proposed Rulemaking on' the S torage and Disposal o f Nuclear Was te, Joint Cross-Statement of Position L

of. the New -England Coalition on Nuclear Pollution and the Natural Resources Defense Council, September, 1980.

i 33.

Testimony by D.G. Bridenbaugh-and Gregory C.

Minor, before the New York S tate Public Service Commission, In the Matter i

of Long Island Lighting Company Temporary Rate Case, p re p ar e'd j

_for the Shoreham Opponents Coalition, September 22, 1980, Shoreham Nuclear Plant Construction Schedule.

34.

Supplemental Testimony by D.G. Bridenbaugh before the New Jersey Boad of Public Utilities, on behalf of New Jersey i

Public Advocate's Office, Division of Rate Counsel, Analysis of 1979 Salem-1 Refueling Outage, December, 1980.

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New Flop Over Security a aw.a'

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7//r/?t(p.D Liablo Licensing Go-head prob.bij be spr. red because tr e n

of the plant's phpical securny Wa hm; ion this seek sere 'able to sneak a apprah board ha> alread.s clo>ed

The N ut ica r Rc;'ula to-umulated weapon. parked in it> ret ord ry ( o m r m s s u n,6 atomic Luette. past plant dmetion A

E spokesman. Dick saf,ety and licensing bnsrd

. equipment.

Dasin. play ed dos n the abihty yefterday re c o rn m e n d ed "We cor. sider that to be just of NRC inspectors to get the a low -pow er testing t h*g t another significact impediment simulated weapon inside the liiense be issued to Pacific in the licensing of that in fated plant perimeter. "It was just a Cas and Electric Co.'s new plant," said Haney Resenfield toy gun," he said. "It was a Dl3blo Canyoo nis elc a r of Ralph Nader's Congress traimng eseresse. It was a plant' Watch group.

Fuard's first day at work, and be didru retornire it. He uin now."

The.ction, s hich rnust be 3!iles said the tor nt:ssion Davm said'PGiE security man.

redes ed bv the Nucicar 8 tee'.;la.

could revies the lirensing ree.

afers were aware of the test to-I Cummisoon before ady b ommendat on withm 10 days.

s hi]e it u as under wav.-

ache tan be irsued, tame as but that n sculd not begin until a licensing appeals board If the los.pos er license is fr9 i or.tros er>y crupted in the

}'linti lent battle for a in ense.

reathed a decision on the plant's appros ed t;uickly. Davin said.

I' Clare Stiles. a icmminion phpical security plarL Ro en.

lo.dinF of the v3 tens of fuel repreentain e. confirped that field said the breach of Security could be fimshed m about one NRC officials conducting a test d etect ed on Thursday w ould month. A f ull pteu ct brense, which PCLE hopes for in No.

sember. might lirrmit the plant

,., to operate a full repaeny early ne.st leu.he uv1.

A low poser license allows

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Ic. ding of nuclear f u;el in the reactor and its bperation at '5 peri ent of full c:apacity. This allous te. sting af the facility in advance of issuance of a full.

pos er license.

Nuclear opponents have fought long and hard to block the Inensing of Diablo Canyon, partly because they think it is too cles.e to an carthquake fault.

The $2 billion Diablo Cao-3 on p!.nt. near San Luis Obispo, has sat unuwd as the battle r< red os er the past several y cars The utilny first raeived a i t.r:strui tain perrnst for one of the is so reettur> at the plant in 19'd

.4.r. A l '.P.

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