ML20010C904

Responses to Applicants' Interrogatories Re Emergency Planning & TMI-2 Related Issues.Prof Qualifications & Certificate of Svc Encl.Related Correspondence

ML20010C904
Person / Time
Site:	05000471
Issue date:	08/17/1981
From:	Shotwell J MASSACHUSETTS, COMMONWEALTH OF
To:	BOSTON EDISON CO.
References
NUDOCS 8108210195
Download: ML20010C904 (43)

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} DXh& & 3: nice Ct;::!: d UNITED STATES OF AMERi?A U P

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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l BOSTON EDISON COMPANY et al. ) Docket No. 50-471

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I (Pilgrim Nuclear Generating )

Station, Unit 2) ) Q/

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COMMONWEALTH'S RESPONSE e q3 ,

TO APPLICANTS' INTERROGATORIES r h -m ON EMERGENCY PLANNING h, Y s: @  :/

AND TMI-2 RELATED ISSUES '/, #

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INTRODUCTION l

l l Taken literally, Applicants' Interrogatories request the l

Commonwealth to file its detailed contentions and direct testimony on the subjects of emergency planning and TMI-2 issues. To the extent the Interrogatories requc et this level of detail or finality the Commonwealth objects thereto on the grounds that they constitute an impermissille attempt to i circumvent the schedule established by the Board for the filing l

of contentions and pre-filed testimony. The Commonwealth also l objects to the Interrogatories to the extent they would require l

the Commonwealth to supplement the answers provided herein, since that could well necessitate daily revisions between the date hereof and the filing of direct testimony.  %$

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Without waiving its objtations as outlined above or in any

'way limiting its right to add to, delete from, or modify the I issues or facts identified below when filing its detailed contentions and prg-filed testimony, the Commonwealth hereby provides answers to the Applicants' interrogatories which l reflect the state of its thinking as of the date of this writing.

INTERROGATORIES

1. Question: Please state in detail each respect in which the Commonwealth of Massachusetts contends that the l Applicants' preliminary plans for coping with emergencies fails

[ sic.] to comply with the requirement of 10 CFR 50, Appendix E, Section II.

Answer: The Commonwealth contends that the Applicants have not properly accounted for local emergency response needs and capabilities in drawing boundaries for the plume exposure l pathway and ingestion pathway Emergency Planning Zones for Pilgrim II, as required by 10 C.F.R. Part 50, Appendix E. The Commonwealth further contends that the Applicants' PSAR fails to comply with the requirement of 10 CFR Part 50, Appendix E that it "contain sufficient information to ensure the l

l compatibility of proposed emergency plans for both onsite areas and the EPZs, with facility design features, site layout and site location . . . " because there is therein insufficient evidence of the feasibility of protective action in the event of a PWR-1 to PWR-7 accidental release, or the equivalent thereof, at Pilgrim II.

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! As regards the specific items required - by 10 CFR 50,

Appendix E,Section II to be included in the PSAR, the Commonwealth contends that the Applicants have failed to describe "how the public is-to be notified" of the need to take protective action or to provide "[a] preliminary analysis that projects the time and means to be employed in the notification of state and local governments and the public in the event of an emergency." The Applicants have also failed to comply with the requirement of Appendix E Section II regarding the calculation of evacuation times, because they have limited such calculations to an area, the size and shape of which were determined without reference to local emergency response needs and capabilities.

Finally, the Commonwealth contends that the PSAR fails to provide for timely and adequate notification of off-site authorities in the event of an emergency.

2. Question: Please identify each fact upon which the Commonwealth of Massachusetts relies in support of its answer to interrogatory number 1. Please identify each document, and the particular parts thereof, of which the Commonwealth is aware which supports-each fact so identified in this interrogatory. Please further indicate each such document which the Commonwealth intends to offer in evidence in this proceeding. For the purpose of this interrogatory, please utilize the same definition of the word " document" as provided in the Commonwealth's interrogatories to Boston Edison company.

l Answer:

Size of EPZ's In support of its contention that the Applicants have not l

l properly accounted for local emergency response needs and l capabilities in drawing boundaries for the Pilgri5 II EPZ's, the Commonwealth relies on the fact that the Applicants have failed to consider or account for the effect on local emergency response needs and capabilities of each of the following factors:

a. The large seascnal and transient populations on

Cape Cod during the summer months;

b. The limited road network on Cape Cod;

c. The limited access routes from Cape Cod to the mainland and the fact that those routes feed into the l

evacuation network for the population within 10 miles of Pilgrim II; '

d. Meteorological conditions specific to the Pilgrim area; I e. The proximity of the proposed plant to Cape Cod Bay and the groundwater conditions on-site, with their resulting implications for travel of radiation through a liquid pathway; l f. Pilgrim II fission product inventory; l

g. Pilgrim II fuel burn-up;

h. The number, location, and capacity of local l sheltering facilities and the degree of protection l from radiation afforded thereby;

i. The' time of year of accidental release from Pilgrim II; and

j. The heightened sensitivity to radiation (over that of the average healthy adult male) of the large number of children and pregnant women who are present on Cape Cod during the summer months.

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As of this writing, the Commonwealth knows of the following documents which support the fact cited above:

a. Pilgrim II PSAR, Amendments 40 and 41

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b. Response of Boston Edison Company, et al. to Commonwealth of Massachusetts' First Set of Interrogatories to Boston Edison Company Relative to Emergency Planning, [ hereinafter, " Answers to Interrogatories"] pages 2-6, 17-19, and 79.

These documents already form part of the official record of this proceeding and, therefore, need not be offered into evidence by the Commonwealth.

Feasibiltiy of Protection Action In support of its contention that the PSAR contains insufficient avidence of the feasibility of protective action 3

in the event of a PWR-1 to PWR-7 accidental release at Pilgrim II, the Commonwealth relies on the following facts:

a. The PSAR contains no evidence of plant-rpecific probabilities of PWR-1 to PWR-7 releases.

b. The P5TR contains no evidence of site-specific consequences in the event of PWR-1 to PWR-7 releases.

c. WASH-1400 provides no evidence of accident consequences where evacuation is restricted to a ten-mile radius,

d. WASH-1400 provides no evidence of the consequences resulting from releases through liquid pathways in the event of a reactor meltdown accident.

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e. The PSAR contains no evidence that WASH-1400's assumptions regarding medical treatment are applicable to Pilgrim II.

f. There is a large degree of uncertainty associated with WASH-1400's estimates of accident probabilities.

l f g. The assumptions upon which WASH-1400's estimates of accident probabilities and consequences are based are inconsistent with each of'the following factors:

l (1) Pilgrim II fission product inventory; l (2) Pilgrim II fuel burn-up; (3) The heightened sensitivity to radiation (over that of the average healthy l adult male) of the large number of children l

and pregnant women who are in the Pilgrim area curing the summer months; (4) The population density in the area of the Pilgrim site as reflected by the Applicants' own filinas in this proceeding; (5) Meteorological conditions specific to the Pilgrim site,

h. The PSAR contains insufficient information to assure that the assumptions upon which WASH-1400's estimates are based are consistent with the following factors:

(1) The degree of protection afforded by sheltering in the event of an accident at l Pilgrim II.

(2) Time-of-year dependent accident consequences at Pilgrim II.

i. Relocation centers have been located within twenty miles of the site.

j. The PSAR does not provide for direct lines of communication, and appropriate back-up, with the Secretary of DPH or the Governor during that period of time before those officials arrive at the Civil Defense Agency Headquarters EOC.

k. The evacuation time estimates submitted by the o Applicanta have been limited to a geographical area i determined without reference t'o local emergency response Eneeds and capabili ties.

1. The evacuation ' time estimates submitted by the l npplicants fail to:

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, (1) Account for the full public transportation-dependent population; (2) Account for the effect on

' evacuation times of the bottlenecks at the Sagamore and Bourne rotaries; (3) Account for population growth over the life of the plant; (4) Account for the time required to evacuate special institutions; a

(5) Account for

] preparation / mobilization time; i

) (6) Account for adverse summer j weather conditions; l (7) Account for the effect on evacuation times of ordered or

spontaneous evacuation from Cape Cod l by means of the Sagamore and/or Bourne

, Bridgen.

4 (8) Account for traffic already within ten miles of the plant at the commencement of the evacuation period; (9) Account for. work-to-home travel prior to evacuation; (10) Account for the effect of all reasonably forseeable external events; (11) Use realistic assumptions as to

1. the knowledge available to evacuees when choosing evacuation-routes; 1

(12) Properly estimate the 1980 population of the Toiin of Plymouth; (13) Account for non-resident employees.

m. The evacuation time estimates prepared by Battelle Pacific Northwest Laboratories fail to:

l (1) Account for ordered or spontancous evacuation f rom Cape Cod via the Sagamore and/or Bourne Bridges; I

(2) Account for the public transportation-dependent population; l

l (3) Account for adverse weather l conditions; l

l (4) Account for work-to-home travel prior to evacuation; (5) Account for traffic already within ten miles of the plant at the commencement l of the evacuation period; (6) Use rea18stic free flow rate assumptions; (7) Use realistic pre-planned evacuation routes or routes consistent with those contained in actual plans; (8) Account for the time required to evacuate special facilities; ,

(9) Account for non-resident employees; (10) Use assumptions consistent with those employed by HMM Associates, Inc.;

, (11) Account for population growth over l the life of the plant; (12) Account for reasonaoly forseeable external evants; (13) Demonstrate any basis for the distribution of preparation times assumed or percentages of the population assigned to each time.

(14) Properly estimate the 1980 population of the Town of Plymouth,

n. The results of the Applicants' and Staff's evacuation time studies are inconsistent.

o. There is ir.aufficient evidence of the availability and adegoacy of local sheltering facilities; and

p. There are no established quantitative or qualitative standards by which feasibility can be judged.

As of this writing, the Commonwealth knows that the following documents support the facts cited above:

a. Applicant's' PSAR 3

b. Applicants' PSAR 1

c. WASH-1400

d. WASH-1400

e. Applicants' PSAR 1

WASH-1400

f. WASH-1400; NUREG/CR-0400, " Risk Assessment Review Group Report to the NRC," September, 1978; "NRC Statement on Risk Assessment and the Reactor Safety

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i Study Report (WASH-1400) in light of the Risk Assessment Revieu Group Report," January 18, 1979;

" Nuclear Power: Can We Live With It?," Technology

Review, June / July, 1979, at 34-35; Kendall, H.W.

Preliminary Review of the AEC Reactor Safety Study, November, 1974; NUREG/CR-0603, "A Risk Assessment of a Pressurized Water Reactor for Class 3-8 Accidents,"

October, 1979, Brookhaven National Laboratories; NUREG-0490, " Final Environmental Statement, San Onofre Units 2 and 3," April, 1981; "A Paper:

Probabilistic Risk Assessment Problems and Uncertainties--Remarks by R. M. Bernero at NRC Workshop on Safety Goals," July 23, 1981; MHB Technical Associates, ' Uncertainty in Nuclear Risk Assessment Methodology," January, 1980, prepared for Swedish Nuclear Power Inspectorate, Stockholm, Sweden.

g. WASH-1400 i

(1) Applichnts' PSAR (2) Applicants' PSAR (3) WASH-1400; Applicants' PSAR, SER Supp. No.

5 and other documents consituting part of the public record of this construction permit proceeding relating to the population in the Pilgrim area; NURGE-0348," Demographic Statistics Pertaining to Nuclear Power Reactor Sites"; single sheet bearing title " Memo,"

.i dated August, 1978, re traffic on Sagamore

{ and Bourne Bridges; Phillip B. Herr &

Associates, " Development Projections for Cape Cod," published April, 1976 (and underlying docuraentation) , and unpublished update, prepared August, 1978;

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(4) See (3) above.

(5) Applicants' PSAR, Section 2.3.

h. Applicants' PSAR, Amendments 40 and 1; WASH-1400 l i. Applicants' PSAR, Amendments 40 and 41; PNPS i

I l-Emergency Plan, Figure N6-5; Local Plans for reception communities.

J. Applicants' PSAR, Amendments 40 and 41; Answers to Interrogatories, p. 67.

. k. Applicants' PBAR, Amendments 40 and 41; Answers to i

Interrogatories, pages 2-6.

1. Applicants' PSAR, Amendments 40 and 41 (1) Answers to Interrogatories regarding public i transportation-dependent population 1

(2) SER Supplement No. 5 l (3) Metcalf & Eddie, Inc. Engineers and Planners,

" Growth-Related Impact of the Pilgrim II Nuclear Power Plant," December, 1979.

i (4) March 3, 1981 letter from R. C. Tedesco to R.M.

Butler regarding review of PSAR Amendment 40.

(5) Answers to Interrogatories re preparation /

mobilization time.

(6) --

(7) --

(8) Answers to Interrogatories regarding assumption of empty traffic network.

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i l l (9) Answers to Interrogatories regarding work-to-home travel.

(10) Answer to Interrogatory No. 31; PSAR, Section 2.3.

(11) --

(12) 1980 Census Data, Town of Plymouth.

(13) Answer to Interrogatory No. 17.

m. SER Supplement No. 5; Staff's " Voluntary" Answers to Nos. 51-59 of the Commonwealth's Interrogatories; local emergency plans;PSAR, Amendments 40 and 41; PSAR, Section 2.3; 1980 Census Data, Town of Plymouth; NUF.EG/CR-1745, " Analysis of Techniques for Estimating Evacuation Times for Emergency Planning Zones"; Metcalf & Eddie, Inc. Engineers and Planners, "Growtn-Relatad Impact of the Pilgrim II Nuclear Power Plant," December, 1979.

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n. SER Supplement No. 5; Applicants' PSAR, Amendments 40 and 41.

o. Applicants' PSAR, Amendments 40 and 41; Answers to Interrogatories re shelter facilities and documents cited therein.

The Commonwealth notes that, as of this writing, it has not yet reviewed documents produced by the NRC Staff which may lend l support to the facts identified herein.

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p. Federal Register Notices re NRC safety goal pcoject; i

l NUREG-0739, "An Approach to Quantitative Safety Goals for Nuclear Power Plants"; NUREG-0764, "Toward a Safety Goal: Discussion of Preliminary Policy Considerations."

The Commonwealth has not yet determined which, if any, of the above documents it will offer into evidence.

NOTIFICATION The Commonwealth relies on the following f acts in stipport of its contentions regarding notification of off-site authorities and the public:

a. The PSAP soes not provide for direct lines of communication, with appropriate back-up, with the Secretary of DPH or the Governor during the time before those officials arrive at the Civil Defense Agency Headquarters EOC.

l l b. The PSAR does not describe the notification I system to be employed to notify the public of the need for protective action.

l c. The PSAR contains no letters of agreement i providing for " prompt" (15 minute) protective action decision-making on a 24-hour basis by off-site agencies.

d. The PSAR does not provide, as required by NUREG-0654, for notification of off-site authorities within 15 minutes of the occurrence of an Unusual Event.

e. The PSAR does not call for provision of

sufficient information to off-site authorities upon

! the occurrence of an Unusual Event to assure that the purposes of such notification, as set forth in NUREG-0654, will be satisfied.

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l l l E. The P3AR, through its provisions for "First-line" and "Second-line" notification, does not

. assure that all off-site authorities responsible for j implementing protective measures will be notified l within fifteen minutes of the occurrence of an l emergency, as required by NUREG-0654.

The Commonwealth currently knows that the following i

documents support the facts cited above:

a. PSAR, Amendments 40 and 41; Answers to Interrogatories, p. 67.

b. PSAR, Amendments 40 and 41.

c. PSAR, Amendments 40 and 41.

d. NUREG-0654; PSAR Amendments 40 and 41.

e. NUREG-0654; PSAR Amendments 40 and 41.

f. NUREG-0654; PSAR Amendments 40 and 41.

The Commonwealth will request the Board to take administrative notice of NUREG-0654.

3. Question: Please state in detail each respect in which the Commonwealth of Massachusetts contends that the Applicants either fail to address or inadequately address the provisions of NUREG-0718, Revision 1, in their application for i

a construction permit, including the PSAR and amendments I

thereto.

Answer: The Commonwealth contends that the Applicants have failed to address the following provisions of NUREG-0718, Rev. 1, in their PSAR and amendments thereto: (Item Nos. taken f rom NUREG-0718, Rev.1, Appendix B) i

a. Item !.0.1. Applicants have failed to provide preliminary control room. design information at a level consistent with that normally required at the construction permit stage of review. Applicants have also failed to specify the design concept selected and the supporting design bases and criteria or to demonstrate that the design concept is technically feasible and within the state of the art or.that there exists reasonable assurance that the requirements will be implemented properly prior to the issuance of an operating license,

b. Item I.D.2. Applicants have failed to describe how they intend to meet the Staff criteria contained in NUREG-0696 for a plant safety parameter display console, to provide preliminary design information at a level

consistent with that normally required at the

construction permit stage of review, or to specify the design concept selected and the I

supporting design bases and criteria.

! Applicants have further failed to demonstrate j that the design concept is technically feasible

{ and within the state of the art or that there 4 exists reasonable assurance that the

requirements will be implemented properly prior j to the issuance of an operating license,

c. Item I.F.1. Applicants have failed to

expand their QA lists to include all items and

acti tities affecting safety as defined by Regulatory Guide 1.29 and Appendix A to 10 CFR Part 50.

l d. Item II.B.2. Applicants have failed to 1

perform adequate radiation and shielding design reviews to assess the need for plant shielding.

e. Item II.B.3. Applicants have failed to 4

demonstrate the ability to obtain and analyze samples in a prompt fashion. Applicants have also failed to review the radiological spectrum facility design and to modify the design on the basis thereof.

f. Item II.B.8. Applicants have failed to submit a program plan that-demonstrates how 2

their site / plant-specific probabilistic risk

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1 assessment program will be scheduled so as to influence system designs as they are being

. developed. Applicants have also failed to

! provide preliminary design information at a level consistent with that normally' required at the construction permit stage of review-to i demonstrate that the containment and~ associated i

systems will provide reasonable assurance that

, the post-accident atmosphere will not support j hydrogen combustion or that the systems necessary to ensure containment integrity will be designed to perform their function during and after being exposed to the environmental

conditions created by_ activation of the i distributed ignition system.

l g. . Item II.D.l. Applicants have failed to

[ commit to demonstrate the applicability of the generic tests descritud in the PSAR to Pilgrim

. II or to modify-their design on the basis of j plant-specific testing. '

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i h. Item II.D.3. Applicants have failed to j provide preliminary design information at a i

level consistent with that normally required at j the construction permit stage of review with

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! respect to relief and safety valve position

! indication. Applicants have further failed to l specify the design concept selected and the j supporting design bases and criteria or to l demenstrate that the design concept is j technically feasible and within tht j state-of-the-art or that there exisen reasonable

assurance that the requirements will ne

! implemented properly prior to issuance of the

] operating license.

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1. Item II.E.1.1. Applicants'have failed to I perform the reevaluation of their EFWS system required by sections (l) and (2) of this Item and l

have failed to provide a program to assure that

i the results of the reevaluation described in  !

section (3) will be factored into the-final

j. design.

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j. Item II.E.4.2. Applicants have not  !

committed to comply with Rev. 2 to R.G. 1.141. ,

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k. Item II.F.1. Applicants have failed to provide for preliminary design information at a level consistent with that normally required at the construction permit stage of review, to specify their design concept and supporting design bases and criteria, or to demonstrate that the design concept is feasible and within l

the state of the art, or that there exists reasonable assurance that the requirements will be implemented properly prior to the issuance of the operating license. Applicants have also failed to provide for continuous sampling of l

radioactive iodines and particulates in gaseous effluents from all potential accident release points, and for onsite capability to analyze and measure these samples.

l i. Item II.F.2 Applicants have failed to

! provide preliminary design information at a l

level consistent with that normally required at l the construction permit stage of review with

! respect to the design of their system for

! monitoring reactor vessel water level, nor have

! they demonstrated that the design concept is i technically feasible and within the state of the l art or that there exists reasonable assurance that the requirements will be implemented properly prior to the issuance of the operating license.

j. Item II.F.3. Applicants have failed to provide preliminary design information at a level consistent with that normally required at the construction permit stage of review with l respect to instrumentation for monitoring accident conditions. Applicants have failed to

specify design concepts and supporting design l bases and criteria or to demonstrate that their design concepts are technically feasible and within the state of the art or that reasonable l assurance exists that the requirements will be implemented properly prior to the issuance of the operating license.

k. Item II.K.2.16. Applicants have failed to provide a program to assure that the results of their evaluation of the potential for and impact of reactor coolant pump seal damage with loss of off-site power will be factored into their final design.

1. Item III.A.l.2. Applicants have failed to provide preliminary design information in accordance with the functional criteria in NUREG-0696 at a level consistent with that

normally required at the construction permit stage of review. They have failed to specify design concepts and supporting bases and criteria or to demonstrate that design concepts are technically feasible or within the state of the art or that there exists reasonable assurance that the requirements will be implemented properly prior to the issuanct of the operating license.

m. Item III.D.3.3. Applicants have failed to provide preliminary design information at a level consistent with that normally required at the construction permit stage of review with respect to in-plant radiation monitoring. They have failed to specify design concepts or to demonstrate that design concepts are technically feasible and within the state of the art or that

, there exists reasonable assurance that the requirements will be implemented properly prior to the issuance of an operating license.

4. Question: Please identify each fact upon which the Commonwealth of Massachusetts relies in support of its answer to interrogatory number 3. Please identify each document, and the particular parts thereof, of which the Commonwealth is aware which supports each fact so identified in this interrogatory. Please further indicate each such document which the Commonwealth intends to offer in evidence in this proceeding. For the purpose of this interrogatory, please utilize the same definiti,on of the word " document" as provided in the Commonwealth's interrogatories to Boston Edison Company.

Answer: The Commonwealth -urrently relies on the l inforaation contained in the Applicants' PSAR, Amendments 42 and 43 in support of its answer to Interrogatory 3 above, which 1

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Amendments are already part of the record in this proceeding.

For its contention that Applicants have failed to comply with Item II.B.8, Applicants also rely on the document referenced in SER Supp. No. 6, at page 20, and characterized as a "PRA program outline."

5. Question: For each item contained under the heading "TMI-2 Related Requirements" in the Staff's Supplement No. 6 to the Safety Evaluation Report for Pilgrim Unit 2 (which items are located oa pages 4-51 of that document) please state whether the Commonwealth agrees with the Staff's con. . 'Fion.

If the Commonwealth disagrees with a particular item in any res pec t , please state, in detail, all reasons for such l disagreement. If the Commonwealth takes no position or neither f agrees nor disagrees with a particular item, please state what efforts the Commonwealth has undertaken or intends to under*ake between now and the date of hearing to establish a position as to such item.

Answcr: This question is repetitive of question 3. SER

Supplement No. 6 simply quotes, under the heading "TMI-2 Related Requirements" the requirements of NUREG-0718, Rev.1, and then states the Staff's view as to whether such requirements are satisfied by PSAR Amendments 42 and 43.

Therefore, the Commonwealth's answer to question 3, which outlines the respects in which it currently believes the PSAR fails to comply with N0aEG-0718, Rev. 1, answers this question j l

as well. The Commonwealth obviously disagrecs at this point in time with the Staff's conclusions that there has been

compliance with the Items identified in answer to interrogatory 3 above. Between the date of this writing and the date of the hearing the Commonwealth intends to engage in discovery and to review all relevant documentation so as to clarify further the nature and extent of the Applicants' noncompliance with NUREG-0718.

, 6. Question: Please identify each fact upon which the ,

Commonwealth of Massachusetts relies in support of its answer

to interrogatory number 5. Please identify each document, and the particular parts thereof, of which the Commonwealth is aware which supports each fact so identified in this interrogatory. Please further indicace each such document I

which the Commonwealth intends to offer in evidence in this proceeding. For the purpose of this i.:terrogatory, please i

utilize the same definition of the word " document" as provided h in the Commonwealth's interrogatories to Boston Edison.

Answer: See Answer to Interrogatory No. 4.

7& 8. Question 7: For each item labelled " Requirement" under the heading of "I;mergency Planning" in the Staff's Supplement No. 5 to the Safety Evaluation Report for Pilgrim Unit 2 (which items are locate 3 on pages 13.3-1 through 13.3-10 of that document) please state whether the Commonwealth agrees with the Staff's conclusion. If the Commonwealth disagrees

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with a particular item in any respect please state, in detail, l

l all reasons for such disagreement. If the Commonwealth takes l

no position or neither agrees nor disagrees with a particular l

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item, please state what efforts the Commonwealth has undertaken or intends to undertake between now and the date of the hearing to establish a position as to such item.

Question 8: Please identify each fact upon which the Commonwealth of Massachusetts relies in support of its ,

answer to interroaatory number 7. Please identify each document, and the particulai parts thereof, of which the Commonwealth is aware which supports each fact so identified in this interrogatory. Please further indicate each such document which the Commonwealth intends to offer in evidence in this proceeding. For the purpose of this interrogatory, please utilize the same definition of the word " document" as provided I in the Commonwealth's interrogatories to Boston Edison.

Answer:

A. The Commonwealth agrees with the Staff's

. conclusion.

l B. The Commonwealth agrees with the Staff's conclusion.

l C. The Com.monwealth disagrees that the Applicants j have described "how the public is to be  ;

notified and instructed," but otherwise agrees l with the Staff's conclusions. The facts upcn 1

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l which the Commonwealth bases its disagreement l

l with respect to the issue of notification, and the documents which support those facts, have already been identified in response to i

interrogatory 42.

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D and E. The Commonwealth agrees with the Staff's conclusion.

F. The Commonwealth agrees with the Staff's conclusion.

l G. The Commonwealth disagrees with the Staff's l

conclusion that Appendix E, Part II, Item G has l

been satisfied for the reason that the Applicants' evacuation time analysis has been limited to a geographical area determi sed without refere a, to local emergency response

, needs and capabilities in violation of 10 CFR l

l 50, Appendix E. The facts upon which the Commonwealth bases its contention with respect to the failure to consider local emergency response needs and capabilities in violation of 10 CFR 50, Appendix E, and the documents which support those facts, have already been j

identified by the Commonwealth in its answer to j interrogatory $2.

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The Commonwealth also disagrees, given the ,

i discrepancies between the results of the CLEAR and EVAC models and the methodological problems with the CLEAR model outlined in response to l

l interrogatory #2 above, that the results of the 1

CLEAR calculations indicate that the EVAC estimates are realistic. The documents supporting these facts also appear in tne Commonwealth's response to interrogatory #2.

The Commonwealth agrees that the Sagamore Rotary constitutes a possible bottleneck, but does not agree that the evaluation presented in Appendix A assures that this bottleneck will l

not result in unwarranted delays in effective l

j evacuation of the plume EPZ if consideration of it is incorporated into state and local governments' traffic management planning. The I

Commonwealth relies on the following facts in support of this disagreement:

1. There are no established quantitative or qualitative standards by which one can judge whether any delays would be i " unwarranted."

l 2. The evacuation tima e.stimates set forth l l

in Appendix A fail co ?ccount for ordered l or spontaneous evacuation from Cape Cod via the Sagamore and/or Bourne Bridges.

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3. The evacuation time estimate contained in Appendix A for the South Extended EPZ is 410 minutes, the highest estimate (along

. with the CLEAR estimate for the total 360 Extended EPZ) of any calculated by means of the CLEAR or EVAC models, according to SER Supplemnt No. 5.

4. The CLEAR model has all of the methodological problems outlined in answer to interrogatory #2 above.

The documents currently known to the Commonwealth which support these facts have already been identified in the Commonwealth's response to interrogatory #2.

As was stated above and in response to interrogatory #1, the Commonwealth disagrees that the Applicants have described a preliminary analysis that projects the time

and means to be employed in the notification of state and local governments and the public in the event of an emergency. The reasons for this disagreement, and documents relied upon, have already been outlined in response to interrogatory #2.

H. Because of the " preliminary" nature of what is required by this section, the Commonwealth agrnes with the Staff's j conclusion. However, as explained in answer to interrogatory number 3, the Commonwealth

does not agree that the requirements of NUREG-0718, Rev. 1, witn respect to these same matters have been met.

9. Question: Please identify each witness whom the Commonwealth of Massachusetts intends to have testify on its behalf on the subjects of emergency planning or TMI-2 related issues in this proceeding. Please s*. ate the televant qualifications and background of each such witness along with the subject matter upon which such witness is expected to testify and the substance of such witness's testimony.

Anawer: The Commonwealth currently intends to have the following individuals testify as a panel on the subject of emergency planning, with the latter two individuals also testifying as a panel on TMI-2 related issues.

(1) Phillip B. Herr (2) Richard B. Hubbard (3) Gregory C. Minor Resumes are attached. Up-dated resumes will be provided, if prepared.

Mr. Herr will prepare that portion of the Commonwealth's direct testimony relating to evacuation times, sheltering facilities, demography, road networks, access routes, and relocation centers. Messrs. Hubbard and Minor will jointly prepare the remainder of the Commonwealth's testimony on the matters relating to emergency planning identified in the foregoing responses and on TMI-2 related issues, including the inappropriate deferral of Action Plan Items for post-C,P.

review.

The Commonwealth agrees to supplement this response on a timely basis to the extent of notifying the Applicants of any additional witnesses which it will have testify on its behalf and of any expansion of the expected scope of its witnesses' direct testimony.

SIGNATURES The foregoing answers are true to the best of my knowledge, information, and belief.

By: = -

J NN SHOTWELL A oistant Attorney General Environmental Protection Division Public Protection Bureau Sworn to before me this /% day of August, 1981.

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// ANN SHOTWELTJ Wssistant Attorney General Environmental Protection Division Public Protection Bureau Department of the AP.torney General One Ashburton Place, 19th Floor Boston, Massachusetts 02108 (617) 727-2265 Dated: M /7 /9 gj

6 UNITED STATES OF AMERICA NUCLEAR hEGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

BOSTON EDISON COMPANY et al. ) Docket No. 50-471

)

(Pilgrim Nuclear Generating )

Station, Unit 2) )

)

)

CERTIFICATE OF SERVICE I hereby certify that the within Response has been served on the following by deposit of copies thereof in the United States Mail, first class mail, postage prepaid thin 17 day o f /@u ver, 1981 :

Andrew C. Goodhope, Esq. Henry Herrman, Esq.

Chairman Room 1045 Atomic Safety and 50 Congress Street Licensing Board Boston, Massachusetts 02109 3320 Estelle Terrace l Wheaton, Maryland 20906 Mr. & Mrs. Alan R. C]ecton l 22 Mackintosh Street Dr. A. Dixon Callihan Franklin, Massachusetts 02038 Union Carbide Corporation P.O. Box Y William S. Abbot, Esq.

Oak Ridge, Tennessee 37830 Suite 925 50 Congress Street Dr. Richard F. Cole Boston, Massachusetts 02109 Atomic Safety and Licensing Board Thomas G. Dignan, Jr., Esq.

U.S. Nuclear Regulatory Ropes '& Gray Commission 225 Franklin Street Washington, D.C. 20555 Boston, Massachusetts 02110 Patrick J. Kenny, Esq. Atomic Safety and Licensing Edward L. Selgrade, Esq. Appeal Board Deputy Director U.S. Nuclear Regulatory Mass. Office of Energy Commission Resources Washington, D.C. 20555 73 Tremont Street Boston, Massachusetts 02108

e .

1 Atomic Safety and Licensing Office of the Secretary Board Panel Docketing and Service Section U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555

[ Washington, D.C. 20555 i chief Librarian Jack R. Gcidberg Flymouth Public Library l Office of the Executive North Street Legal Director Plymouth, Massachusetts 02360

, U.S. Nuclear Regulatory l

Commission William S. Stowe, Esquire Washington, D.C. 20555 Boston Edison Company 800 Boylston Street l Thomas S. Moore, Chairman Boston, Massachusetts 02199 i Atomic Safety and Licensing

! Appeal Board Francis S. Wright, Esquire l

U.S. Nuclear Regulatory Berman & Leuenberg Commission 211 Congress St.

Washing tcn , D.C. 20555 Boston, Massachusetts 02110 Christine N. Kohl, Esquire Dr. John H. Buck Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Stephen H. Lewis R. K. Gad III l U.S. Nuclear Regulatory Ropes & Gray i Commission 225 Franklin Street l Office of the Executive Boston, Massachusetts 02110

( Legal Director l Washington, D.C. 20555 I

Michael Blume U.S. Nuclear Regulatory Commission Office of the Executive Legal Dir'stor Washington; d.C. 20555 O

J Ann Shotwell-istant Atto ney General Environmental Protection Division Public Protection Bureau Department of the Attorney General One Ashburton Place, 19th Floor Boston, Massachasetts 02108 (617) 727-2265

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PHILIP B. HERR l EDUCATION Massachusetts Institute of Technology, Masters in City Planning, J.C. Nichols Fellowship.

Rensselaer Polytechnic Institute, Bachelor of Architecture, Tau Beta Pi, Sigma Xi honoraries, Thesis Prize.

CURRENTLY Associate Professor of City Planning, M.I.T., Department of Urban Studies and Planning. Courses and research in growth and land use planning, participation, coastal zone management, design, impact analysis. g Principal, Philip B. Herr and Associates, consultants in land use planning, development regulation, impact analysis, partici-patory design.

Member, Revere Beach Design Review Board-(appointed by Secretary of Environmental Affairs).

Member, American Society of Planning Officials, Urban Land Institute.

Registered Architect, Commonwealth of Massachusetts.

RESEARCH PARTICIPATION Development Impact Assessment, funded by Massachusetts Department of Community Aff airs, through Herr Ansociates, 1975-1976, and Rockefeller Foundation, through M.I.T. Design of methods for local analyses of deselopment consequences. Publication:

Evaluating Development Impact, M.I.T. Laboratory for Archi-tecture and Planning, August, 1978.

f Environmental Impact Assessment, funded by Rockefeller Foundation and others through M.I.T. Laboratory for Architecture and  !

Planning, 1976-1978 (with Lawrence Susskind and others).

Studies of institutional considerations in assessing compre-hensive consequences of infrastructure systems design, case study of coastal zone management.

Maine Development Strategy, funded by Rockefeller Brothers Founda-tion and Maine Bureau of Public Lands, through M.I.T. Depart-ment of Urban Studies and Planning, 1974 (with Lloyd Rodwin and others). Design of an approach to utilization of state-owned lands through new organizational approaches. Publica-tion: Economic Development and Resource Conservation: A Strategy for Maine.

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PHILIP B. HERR -- Page 2 RESEARCH PARTICIPATION (continued)

Cambridgeport/Ecologue, funded by U.S. Office of Education, Office of Envi'ronmental Education, and others, through M.I.T. Depart-ment of Urban Studies and Planning, 1969-1972 (with Stephen Carr and others). Development of innovative methods for enabling community residents to develop neighborhood plans.

Publication: article in Progressive Architecture, December, 1976.

Mobility for the Poor, funded by U.S. Department of HUD, through the M.I.T.-Harvard Joint Center for Urban Studies, 1968-1970 (with Aaron Fleisher). Analysis of travel patterns and dis-abilities of the poor, and of possible remedies, based on survey data from Boston, Memphis, St. Louis, Milwaukee and Baltimore.

CONSULTING Participatory planning and design. Program design and technical l

• assistance for a variety of New England towns and regional planning agencies, f.ncluding Bourne, Edgartown, Franklin, Gloucester, Oak Bluffs, Rowe, Sharon, Sherborn, Sunderland,

and Tisbury, Massachusetts; Hanover, New Hampshire; Cape Cod Planning and Economic Development Commission.

l Innovative development control. Techniques designed have included

' growth timing (Bourne, Falmouth, Franklin, Greenfield, Sandwich);

performance zoning (Clinton, Franklin County, Gay Head, Sand-wich); transfer of development rights (TDR) (Sunderland);

I critical resource zoning (Sherborn, Sunderland); regional land use control (Franklin County, Martha's Vineyard Commission).

Other development control. Over twenty zoning bylaws and ordinances have been rewritten and adopted, numerous other controls de-signed and adopted in more incremental fashion.

Impact analyses. Cape Cod National Seashore (for National Park Service), open space acquisition (for Association for Preser-vation of Cape Cod), dog track (for Blackstone), PUD (for Natick), resort development (for Franklin County), nuclear ,

power plant (for Franklin County). l Central aren studies. Amherst, Andover, Gloucester, Lexington, Northampton, Salem, among others, in each case utilizing alternatives to conventional federal-aided urban renewal.

Regional efforts have included "208" Water Quality Management plan-ning for Cape Cod, creation of a regional housing authority and regional building inspection system for Franklin County, model cluster zoning legislation for Cape Cod.

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, PHILIP B. HERR -- Page 3 l

JOURNAL PUBLICATIONS American Institute of Planners, Planners Notebook, October, 1973,

" Performance Zoning

The Small Town of Gay Head, Massachusetts, l Tries It", with Kevin Lynch.

Eno Foundation, Traffic Quarterly, April, 1962, " Timing of Highway Impact".

l Urban Land Institute, Urban Land, February, 1960, Regional Impact of Highways".

! Descriptions of Herr's community work have appeared in Progressive l trchitecture, November and December, 1976; Journal of the American Institute of Planners, January, 1975; Journal of Housing, May, 1980; Land Use Law & Zoning Digest, March, 1980; PAS Memo, March, 1980; The Land Use Controversy in Massachusetts (L. Susskind, Ed., 1975); Performance Stan-dards: A Technique for Controlling Land Use, Gregon State University Extension Service.

PREVIOUS EXPERIENCE Chairman, Planning Subcommittee, Massachusetts Governor's Task Force on Coastal Resources.

Member, Steering Committee, Massachusetts Coastal Zone Management l Program.

Directs of Planning (subsequent ly , President), Economic Development

.. ociates, Inc., Boston, Mass.

Research As Oiate, Greater Boston Economic Study Committee.

l Consulting Ass 'iate, Adams, Howard and Greeley, Cambridge, Mass.

Planner, City of terkeley, California.

Instructor, Boston 'Iniversity, Wentworth Institute, Boston Archi-tectural Center.

Architectural draftsman / designer, George W.W. Brewster, Warren C.

Obes, Boston, Mass.

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R I C H A .:.; E. h '. : E A :. s MH3 Technical Associates 1723 Hacilton Avenue Suite K San Jose, California 95125 (408) 266-2716 E XP E RIEN CE :

9/76 - P RESENT Vice-President - MH3 Technical Associates, San Jose, Ca l f o rn-i a .

Founder, and Vice-President of technical consulting firm. Special-is ts in independent energy assessments for government agencies, particularly technical and economic evaluation of nuclear power facilities. Consultant in this capacity to Oklahoma and Illinois Attorney Generals, Minnec o ta Pollution Co n e. r o l Agency, German Ministry for Research and Technology, Governor of Co lo ra do , Swedish Energy Commission, Swedish Nuclear Inspectorate, and the U.S.

Department of Energy. Also provided studies and testimony for various public interest groups including the Center for Law in the Public Interes t , Los An g el e s ; P u bi t e L aw U t il i ty Group, Baton Rouge, Louisiana; Friends of the Earth (F0E), Italy; and

- the Union of Concerned .e cien tis ts , Cambridge, Massachusetts.

Pro"(ded cestimony to the U.S. Senate / House Joint Committee on Atomic Energy, the U.S. House Cos=ittee on Interior and Insular Affairs, the California Asse bly, Land Use', and Energy Coe-ittee; the Advisory Committee on Reat t r S af e guards , and t !. e Atocic S af ety and Licensing Board. Perforced comprehensive risk analysis of the accident p r ob al ili t ie s and consequences at the Bars eback Nuclear Plant for the Swedish Energy Co=cission and edited as well as contributed to, the Union of Concerned Scientist's t e ch r. i c a l review of the N RC's Reactor S af ety Study (k' AS H- 14 00) . ,

I 2/76 - 9/76 Consul: ant, Project Survival, Palo Alto, California.

Volunteer work on Nuclear S af eguards Initiative campaigns in Cali-fornia, Oregon, Washington, Arizona, and Colorado. Numerous presentations on nuclear power and alternative energy options to Also resource person for civic, governnent, and college groups.

public service presentations on radio and television.

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. C n:rci and ins :utentatar lap 2: : r. i :  ; e r. r:1 I c;;ric C ; :.; s r " , 5:n J sc, California.

Report to the Department General Manager. Develop and implement quality plans, programs, nethods, and equip:ent which assure that products produced by the Depart =ent caet quality r equiremen ts as defined in SRC regulation 10 CFR 50, Appendix B, AS ME B o ile r and Pressure %ssel Code, custoaar contracts, and GE Co rpo ra te policies and procedures. Product areas include radiation sensors, reactor j

vessel internsls, fuel handling and servicin; tools, nuclear plant control and pro t ec tion instrumentation syste=s, and nuclear stea=

Responsible for supply and Balance of Plant control roos panels.

approximately 45 exe=pt personnel, 22 non-execpt personnel, and 129 hourly personnc1 with an expense budget of nearly 4 million l

dollars and equipment inves t en t budget of ap p r o xima t e ly 1.2

! =illion dollars.

11/71 - 5/75 i

Manager - Quality Assurance Subsection, Manufacturing S ec tion of l

Atomic Power Ecuipment Decartcent, General Electric Company, San

! Jose, California.

Report to the Manager of Manufacturing. Same functional and l

product responsibilities as in Engagement 01, except at a lower l

organizational report level. Developed a quality system which l The system was also success-j received NRC certification inand 1975. "NPT" symbol authorization in 1972 fully surveyed for AS ME "S" l

l and 1975, plus AS ME "U" and "S" sy=bol authorizations in 1975.

f Responsible for from 23 to 39 exempt personnel, 7 to 14 non-exempt personnel, and 53 to 97 hourly personnel.

3/70 - 11/71 l Manager - Application Engineering Subsection, Nuclear Instrumen-tation Department, General Electric Co mp any , San Jose, California.

I Responsible for the post order technical in terf ace with architect I engineers and power plant owners to define and schedule th e instru-men t a t io n and control systens for the Nuclear Stea= Supply and Balance of Plant portion of nuclear power generating stations.

Responsibilities included preparatien of the plant instrument list with approxicate location, review of interface drawings to define functional design require =ents, and release of functional require-

=en ts for detailed equipment designs. Personnel supervised inc lu d e d 17 engineers and 5 non-exempt personnel.

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T.e s ; c n s i t i e for a special : In terce rc;:rting to the :e;2rt:ent General Manager to define cethods to i=p ro v e the quality and reduce the installation time and cost of nuclear power plant control rooms. Study re sul tec in the conception of a f a c to ry-l fabricated control roo= consisting of signal conditioning and l

operator control panels counted on codular floor sections which are completely assembled in the factory and thoroughly tested for proper operation of interacting devices. Personnel supervised included 10 exempt personnel.

12/65 - 12/69 u anager - Proposal Engineering' Subsection, Nuclear Ins trumentation Department, General Electric Company, San Jose, California.

Responsible for tha application of instru=entation systems for nuclear poser teactors during the proposal and pre-order period.

l Responsible for technical review of bid specifications, preparation sf technical bid clarifications and exceptions, definition of material list for cost estimating, and the "as sold" review of c o n t r a c. t s prict to turnover to Application En g in ee rin g . Personnel sup e r v is ed varied from 2 to 9 engineers.

l 8/64 - 12/65 Sales Engineer, Nuclear Electronics B us ine s s Section of Atomic Power Equipment Department, General Electric Company, San Jose, l Calif o rn ia .

Responsible for the bid review , contract negotiation, and sale of ins t rumen ta t ic a systems and components for nuclear power plants, test reactors, and rad ia t io n hot cells. Also r e s po n s ib le for l

industrial sales of radiation sensing systems for neasurement of l

cherical properties, level, and density.

10/61 -

8/64 Application Engineer, Low Voltage Switchgear Department, General Electric Co mp any Phi}adelohis. Pennsylvania.

Responsible for the applicat. n and design of advanced diode and s ilic o n-con t r o lle d rectifier constant voltage DC power systems and va riable voltage DC power Sys" ems fr : industrial applications.

Designed, followed manufacturing and personally tested an advanced SCR power supply for product. in t e,du c t ion at the I ron and S teel Show.

P roj ec t Ingineer for a DC power syste= for an aluminum pot line sold to Anaconda begiaring at the 161KV switchyard and ercompassing all the eq uipmen t to convert the power to 700 volts DC at 160,000 amperes.

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9/60 - 1: ' 1 SE :::::irn:1 Trainin? ?regra:

Four 3-=onth assignments en the GE ?.e.;-i nal Iraining Progran for college technical graduates as follows:

a. Installation and Service Eng. - Detroit, Michican.

Installation and startup testing of the world's largest automated hot strip steel =111.

b, Tester - Indus try Con tro l - Roanoke, Virginia.

Factory testing of control panels for control of steel, paper, pulp, and utility = ills and power plants.

c. Engineer - Light Military Electronics _- Johnson City, New York.

De;ign of ground support equipment for te s tin g - th e auto pilots on the F-Id5.

d. Sales Engineer - Morrison, Illinois.

l Sale of appliance controls in c l u d i r.g range timers j and refrigerator cold controls.

l l

l EDUCATION:

l B achelor of Science Electrical Engineering, University of Arizona,

l. 1960.

Master o f Bus ine ss Administration, Un iv e r s i ty of Santa Clara, 1969.

1 r

P RO FES S ION AL AFFILIATION:

j Regis te red Quality Enginee r, License No. QU805, S tate o f Calif ornia.

Member of S ubconsit t ee 8 of the Neclear Power' Enginee ring Committee of the IEEE Power En gin ee rin g Socie ty responsible for the prepara-tfin and revision of the following 4 na tio nal Q . A. Standards:

a. IEEE 498 (ANSI N4 5. 2.16) : Supplementary Requirements for the Calibration and Control of Measuring and Test Equipment used in the Construction and Maintenance of Nuclear Power Generating Stations.

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TE: Tu: :in; Elc:tri: Equipscn: uring the Cens:::::icr rf ' :le:r Power Generating S ta tio ns .

c. IEEE 46) (ANSI 45.2.14): Quality Assurance P ro g ra:

Requiraments for the Design and Manufacture of Class IE Instrumentation and electric Equip =ent for Nuclear Power Generating S tations .

d. IEEE Dr tft: Requirements for Re p la c emen t Parts for Class IE Equipment Replacement Parts for Nuclear Power Gen era ting S ta tions .

PE RS ON AL DATA: .

Birth Date: 7/08/37 Married; three children Health: Excellent P U3 L I C ATION S AND TES TI MONY :

1. In-Core System Provides Continugus, Flux Map of Reactor Cores, R.3. Hubbard and C.E. Foreman, [ 3y r , November, 1967.

R .B . Hubbard,

2. Quality Assurance: Provid# 2 1 P oving It, Power, May, 1972.

3. Testimony of R.B. Hubbard, D.C. B ri 3 enbaugh , and G.C. Minor before the United States Congress, Joint Committee on Atomic Energy, Feb rua ry 18, 19 7 6, W as h in g to n, DC. (Published by the_ Union of Concerned S cientis ts , Ca= bridge, Massachusetts.)

Excerpts from testimony published in Quote Without Co mm en t ,

Chemtech, May, 1976.

4 Testimony of R .B . Hubbard, D.C. B ri d enb au gh , and G.C. Minor to the Cali f o rnia S tate Ass mbly Committee on Resources, Land Use, and Energy, Sacramento, California, March 8, 1976.

5. Testimony of R. B. Hubbard and G.C. Minor before California State Senate Committee on Public Utilities, Transit, and Energy, Sacramento, California, March 23, 1976.

6. Testimony or R.B. Hubbard and G.C. Minor, Judicial Hearings Regarding Crafenrheinfeld Nuclear Plant, March 16 & 17, 1977 Wur: burg, Germany.

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l S. Testimony of R.B. Hubbard to the Advisory Committee on Reactor Safeguards, August 12, 1977, Washington, DC, entitled, Risk Uncertainty Due to Deficiencies in Diablo Canyon Quality Assurance Program and Failure to implement Current NRC Practices.

l 9. The Risks of Nuclear Po:er Reactors: A Review of the NRC Reactor Safaty Study 'J A SA- 14 0 0 , Kendall, et a], edited by R.B.

l I

Hubbard .nd G.C. Minor for the Union of Concerned Scientists, j August, 1977.

10. Swedish Reactor Safety Study: B a rs eb E ck Ris k As s es smen t , MHB Technical Associatcm, January 1978 (Published by Swedish Depart-l ment of Indus try as Jocument DSI 1978:1).

11. T e s t imo ny of R.B. Hubbard before the Energy Facility S iting l

Council, March 31, 1978, in the matter of Pebble Springs Nuclear l Power Plant, Risk Assessment: Pebble Springs Nuclear Plant, Portland, Oregon.

12. Presentation by R.B. Hubbard before the Federal ' ' nis try for Research and Technology (3 MFT) , August 31 and Se,. amber 1, 1978, Meeting on Reactor Safety Research, Risk Analysis, Bonn, Germany.

13. Testimany by R.B. Hubbard, D.G. B'ridenbaugh, and G.C. Minor before the Atomic Safety and L i c ens ing Board, S ep t e=b er 25, 1978, in the matter of the Black Fox Nuclear Power Station Construction Permit hearings, Tulsa, Oklahoma.

14 Testimony of R.B. Hubbard before the Atomic Safety and Licensing Board, November 17, 1978, in the matter of Diablo Canyon Nuclear Power Plant Operating License Hearings, Operating Basis Earth-1 quake and Seismic Reanalvsis of Structures, Systems, and Com-ponents, Avila Beach, California.

15. Testimony of R.B. Hubbard and D.C. Bridenbaugh before the Louisiana Public Service Commission, November 19, 1978, Nuclear Plant and Power Generation Costs, Baton Rouge, Louisiana.

16. Testimony of R.B. Hubbard before the California Legialature, Subcommittee on Energy, Los Angeles, April 12, 1979.

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L -cer -i Scien:ists, Standards af. d Certi'ica:ica Proposed 7.u i o 16 CFR Part 457, May 18, 1979.

19. ALO-62, Improving the Safety af LWR Power Plants, MMB T=chnical Associates, prepaced for U.S. Departcent of Energy, Sandia N-2 t iona l L ab o r a t o r ie s , Seitember, 1979, available from NTIS.

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19. Testimony by R.B. Hubbard before the Arizona State L e g is l a t u r e ,

Special Interim House Committee on Atomic Energy, Overview of Nuclear Safety, Phoenix, AZ, September 20, 1979.

20. "The Role of the Technical Consulta.t," Practising Law insti-

" New York City and Chicago, tute program on " Nuclear Litigation i November, 1979. Available from PLI, New York City. -

21. Unce r ta in ty Lp Nucl ar Risk As s es smen t Methodology, MilB Technical Associates, January, 1980, prepared for and available from the Swed4sh Nuclear Power Inspectorate, Stockholm, Sweden.

22. Italian Reactor Sa'ety Study: Caorso Lisk Assessment, MHB

] Technical Associatts, Match, 1980, prepared for and available from Friends of the Earth, Rome, Italy.

23. Development o f S tudy Plans: Safety Assessment of Monticello and Prairie Island Nuclear Stations, MHB Technical Associates, August, 1980, prepared for and available from the Minnesota Po ll u t io n Co n t ro l Agency.

24 . Affidav1- o f Richa rd B . Hubba:d and Cregory C. Minor before the I llin o is Commerce Commission, In the Matter of an Investi-gation of the Plant Construction Program of the Commonwealth E d is on Co m p an y , prepared for the League of Woman Voters of Rockford, Illinois, November 12, 1980, ICC Case No. 78-0646.

25. Systems Interaction and Single F...'ure Criterion, MHB Tech-nical Associates, November, 1980, prepared for and available i

from the Swedish 1uclea r Power Inspec to ra t e, Stockholm, Sweden.

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MHB Technical Associates 1723 Ea:ilton Avenue Suite K San Jose, California 95125 -

(408) 266-2716 E XP E RI EN CE -

1976 - PP.ISENT Vice-P re s iden t - MH3 Technical Associates, San Jose, California.

Engineering and energy consultant to state, federal, an'd private organizations and individusals. Major activities include studies of safety and risk involved in energy generation, providing' tech-q nical consulting to legislative, regulatory, public and private groups and expert witness in behalf of state organizations and citi:cas' groups. Was co-editor of a critique of the Reactor S a f e ty S tudy (W ASH-1400) for the 'u n i o n of Concerned Scientists l

and co-author of a risk analysis of Swedish reactors for the Swedish Energy Commission. Served on the Peer Review Group of the -N RC/TMI Special Inquir; Group (Rogovin Committee). Actively involved in the Nuclear Power Plant standards Committee work for the Ins t rumen t Society of America (ISA).

1972 -

1976

.!an a g e r . Advancad Control and I n s t r u m en t a t i_o n Engineering, f General Electric Company, Nuclear Energy Division, San Jose, i California.

Managed a design and development group of thirty-four engineers and support personnel designing sys tems for use in the measurement, control and operation of nuclear reactors. Involved coordination with other reactor design organizations, the Nucicar Re3ulatory Commission, and customers, both overseas and domestic. Responsi-bilities 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 position included responsibility for standards applicable to control and instrumentation, as well as the design of short-term solutions to field problems. The d is cip lin es involved included electrical and nechanical engineering, seisnic design and process computer control / l progranming.

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> M naged 2 group of seven en gin e e rs and two support personnel in the design and p rep ara tion of the detailed system drawings and control documents relating te safety and emergency syste=s.

for nuclear reactors. Resp::sibility required coordination with I o t h e r 'd e s i g n organizations and interaction with the customer's engineering persennel, as we'_1 as regulatory personnel.

1963 - 1970 Design Engineer, Gene ral Ele c:ric C o :_ p a n y , Nuclear Energy Division, San Jose, California.

Responsible for the design of specific control and ins trumen ta tion syste=s for nuclear reactors. Lead design r e s p on s ib ili ty for various subsystems of instrumentation used to measure neutron fluxPerformed in the reactor during startup and intermediate power operation.

! lead system design function in the design of a majorOther syste=responsi-for measuring the power generated in nuclear reactors.

bilities included on-site checkout and testing of a complete reactor Received control systet at an experisental reactor in the S ou thwe s t.

l p a ten t for Nuclear P owe r Monitoring Sy s tem.

l l

l 1960 - 1963 Advanc ed Engineerin g P rogran. General Electric Company; Assignments in W ashin g ton , California, and Arizona.

Rotating assignments in a varie cy of disciplines:

- En g in e e r , reacto r main t enan ce and instrument design, KE and D reactors, Hanford, W a s h in g t on , circuit design and equipment m a in t e n an c e coordinat ion.

l l

' - Design engineer, Microwave Department, Palo Alto, Cali-f o rn ia. . Worked on design of cavity couplers f o r TNT 's .

l

- Design engineer, Computer Department, Phoenix, Arizona.

Design of core driv.ng c ircu i t ry .

- Design e n g in e e r , Atomic P:ver Equipment Department, San Jose, California. Circuit design and analysis.

- Design engineer, Space Systems Department, Santa Sarbara, California. Prepared ccatrol portion of satellite proposal.

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During this period, completed three-year General Electric program of er. tensive education in advanced engineering principles of high-er rathematics, probability and analysis. Also completed courses in K ep n er-T r ego e , Effective F r es ent a t io n , Management Training Pro- -

grac, and various technical se=inars.

EDUCATION Unive r s ity of California at Berkeley, BSEE, 1960.

Advanced Course in Engineering - three-year curriculuc, General Electric Company, 1963.

Stanford University, MSEE, 1966.

HO NO RS AND AS S O CI ATIONS

- Tau Beta Pi E ngineering Hono rary Society.

- Co-holder of U.S. Patent No. 3,565-760, " Nuclear Reactor Power Monit o rin g S ys te=," F eb ru a ry , 1971.

- Memb e r : American Association for Advance of Science.

- Me=ber: Nuclear Power Plant Standards Committee, Instru-ment Society of Anerica.

PE RS ON AL DATA Born: June 7, 19^7 Married, three children Residence: San Jose, California 1

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IEEE !: 1 1972.

2. G.C. Minor W.G. Milam, "An Integrated Control Room System for a Nuclear Power Plant," NEDO-10658, presented at In-ternational Nuclear Indus tries Fair and Technical M e e t in g s ,

October, 1972, Basle, S w i t z e r la n d .

3. The above article was also published in th e Ger..an Technical Magazine, NT, March, 1973.

D.G. Bridenbaugh, and R.B. Hubbard 4 Testimony of G.C. Minor, before the Joint Committee on Atomic Energy, Hearings held February IS, 1976, and published by the Jn io n of Co n c e rn e d S cientis ts , Cambridge, v

.assachusetts.

5. Testimony of G.C. Minor, D.G. B r ide nb a u gh , and R.B. Hubbard before the California State Assembly Committee on Resources, Land Use, and Energy, March S, 1976.

6. Testimony of G.C. Minor and R.B. Hubbard before the Cali-f ornia S tate Senate Com=ittee on Public Utilities, Transit, I and Energy, March 23, 1976.

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7. Tes timo ny of G.C. Minor regarding the Grafenrheinfeld Nu-clear Plant, March 16-17, 1977, Wurzburg, Germany.

8. Testimony of G.C. Mino r b ef o re the Clu f f Lake Board of In-quiry, Regina, Saskatchewan, Canada, September 21, 1977.

9. The Risks of Nuclear Power Reactors: A Review of the NRC j Reactor S af ety Study W AS H -14 0 0 (SUREG-75/0140), H. Kendall, et al, e d it ed by G.C. Minor and R .B . Hubbard for the Un io n of Concerned S cientis ts , August, 1977.

S w e d is h Reactor S a f e ty S tudy : B a r s eb 'i c k Risk Assessment, 10.

MH3 Technical Associates, January, 1973. (Pub'ished by Swedish Department o f Indus try as Document SdI 1978:1)

11. Tes tia.Sny by G.C. Minor before the Wis consin Public Service Co mmis s io n , Feb ruary 13, 1978, Loss of Coolant A c c i d e n t s.:

Their P rob ab ility and Consequence.

12. Testimony iur G.C. Minor before the California L e g is la tur e As s emb ly Committee on Resources, Land Use, and Energy, A3 3108, April 26, 1973, Sacramento, Calif o rnia .

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August 21, and September 1, 1975, Sonn, Jer:any.

14 Testinony by G.C. Minor, D.G. Bridenbaugh, and P.B. Hubbard, before the Ato ic Saf ety and Licensing Board, Septe ber 25,

! 197S, in the estter of the Black Fox Nuclear Power Station Construction Pernit Hearings, Tulsa, Oklahoma. -

15. Testimony cf G.C. Miner, ASLB H e a rin g s Related to TMI-2 Accident, Rancho S co Power P lan t , on behalf of Friends of the Earth, Septenber 13, 1979.

16. Testimony of G.C. Minor before the Michigan S ta t e i,e girla-ture, Special Joint Connittee on Nuclear Energy, Inc lica t ion s

! of Three M i_1_e_I_s,1,a n d Accident for Nuclear Power Plants in

• 'chigan. 10/15/79

17. A Critical View of Reactor Safetv, by G.C. Minor, paper presented to the American As s o ci a t io n for the Advancement of Science, Symposium on Nuclear Reac tor S a f e ty , . January 7, 1980, San Francisco, California.

18. The E f f ects of Aging on S af ety of Nuclear Power Plants, j paper presented at Forum en Swedish Nuclear Referendum,

! Stockholm, Sweden, March 1, 1980.

19. Minnesota Nuclear Plants Caseous Emissions Study, MHB

! Technical Associates, September, 1980, prepared for the Minn es o ta Pollution Con t ro l Agency, Roseville, MN.

20. Testimony of G.C. Minor and D.C. Bridenbaugh before the New York S tat e Public S erv ic e Commission, Shorehac Nuclear Plant Construction Schedule, in the matter of Long Island Lighting Company Temporary Rate Case, S ep t emb 22, 1980.

l 21. Testimony of G.C. Minor and D.G. Bridenbaugh before the New Jersey Board of Public Utilities, Oyster Creek 1980 Re f uelin g Outage Investigation, in the matter of Jersey Central Power and Light Rate Case, February 19, 1981. _,

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