ML20070M210

Reply to Appeal Board 910222 Order.* Response Opposes ALAB-918 Issues Re Onsite Exercise Contention.W/Certificate of Svc

ML20070M210
Person / Time
Site:	Seabrook
Issue date:	03/11/1991
From:	Backus R, Curran D, Greer L BACKUS, MEYER & SOLOMON, HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SEACOAST ANTI-POLLUTION LEAGUE
To:	Atomic Safety and Licensing Board Panel
References
CON-#191-11529 ALAB-918, OL, NUDOCS 9103210114
Download: ML20070M210 (51)

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. C00tE1LO UMWC l UNITED-STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '91 IN 12 P3 53 ATOMIC SAFETY AND LICENSING APPEAL BOARD Before Administrative Judges:

Alan S.-Rosenthal, Chairman Thomas S. Moore *

(

Howard A. Wilber

)

In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL PUBLIC SERVICE COMPANY )

OF NEW HAMPSHIRE, ET AL. )

)

(Seabrook Station, Units 1 and 2) ) March 11, 1991

_ )

REPLY TO APPEAL BOARD ORDER OF FEBRUARY 22. 1991 In an order da.ted February 22, 1991 the Appeal Board directed interested parties to respond to a series of questions concerning the ALAB-918 issues remanded by the United States Circuit Court of Appeals for the District of Columbia in Massachusette v. NRC, No. 89-1306, F.2d (D.C. Cir. 1991). The Massachusetts i Attorney General, The New England Coalition on' Nuclear Pollution, and the Seacoast Anti-Pollution League ("the Intervenors") make the-following response to the Appeal Board's order:

1. While it is possible that the 1990 exercise mooted the 4 issues raised in the June 1988 On-Site Exercise Contention, there is no information in the record presently before this Board upon which to make such a conclusion. All that is presently known about the December 1990 exercise is that it purported to test the s

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T v.o;,a g g on-site emergency plan. See the attached inspection report, Exhibit A. While the inspection report shows no deficiencies in the December 1990 on-site exercise, there is no information as to specifically what steps the on-site operators took to meet the challenges posed in the exercise. For example, while the report indicates that ons of the activities observed was accident analysis and mitigation, it does not indicate how the staff 4

analysized the accident or what steps were taken to mitigate the accident. See page 4 of the report. The report gives no indication whether, for instance, the on-site operators sucessfully isolated the release path as the Pollard Affidavit alleged they failed to do during the June 1988 exercise.

Since the NRC Staff did not find deficiencies in the Septembcr 1989 exercise, nor in the June 1988 exercise, the o December 1990 exercise was not designad as a remedial one specifically to test faults observed in those exercises, such as the faults alleged in the on-Site Contention presently under consideration by this Board. The Pollard affidavit identified five examples of exercise weaknesses. At present, there is no information in the record as to whether the December 1990 exercise tested those five weaknessec, nor is there any }

information as to what steps the on-site personnel took demonstrating that those weaknesses have been corrected. To date neither the Applicants, nor NRC staff, have filed a motion to dismiss the on-site exercise contention as moot and have not provided any affidavits or other evidence that demonstrates it is moot.

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2. (a) The premise of ALAB-918 that the five- f actors set forth in 10 C.F.R., 5 2. 714 (a) (1) are solely procedural requirements cannot be squared with the Court's view in Massachusetta v. NRC, Id. It appears that under the Courc's opinion while a Licensing Board may consider the procedural requirements of 10 C.F.R., 52.714, at least as to factor III a Licensing Board must also consider the substance of the contention and any supporting af fidavits to see if an issue material to licensing is raised. While it is possible that the other four factors should also be considered in-some manner quite apart from being purely procedural requirements, that issue does not appear to be directly addre" .ed in Magsachusetto v. NRC.

Within this context, it is appropriate to take note of the Court's comments that application of the five factors is " odd" in the context of a late-filed contention based on a subsequent exercise.  ;

"On their f ace, the five factors listed in 52.714 (a) (1) as justifying intervention are not well suited to the question of whether a late-filed contention should be considered where based on deficiencies found in a subsequent exercise, and we think it odd that the NRC should choose to apply them in this context. An exercise contention will in practice almost always be filed out of time, so the question of " good cause" seems less central. Two of the other factors also do not make much sense here. Factor (iv) does not seem relevant because there would almost never be other parties already litigating the issues raised by the the new contention. And factor (v) is potentially inconsistent with UCS I's holding that emergency preparedness exercises are material to licensing; it should  ;

not be a strike against admitting the contention that it '

will be " broaden the issues" to include material questions ,

about the adequacy of preparedness. Massachusetts v. NRC, l Slip op. 41-42." .

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I / (b) A material issue is one that is relevant to a 1- -

l licensing proceeding such as issues raised by emergency ~  ;

i preparedness exercises. When such'an issue is presented in a contention, the contention cannot-be excluded on a' procedural l basis alone. In the Intervenor's on-site Exercise Contention-

! the allegaticn was made that the state of'on-site emergency j preparedness obscrved in the June 1988 exercise at Seabrook did 1 ,

not provide assurance that adequate protective measures could,

{ and would, be taken in the event of a radiological.nmergencyt as i

l- required-by 10 C.F.R. 5 50. 47 (d) .- The Contention also alleged i

j that the on-cite emergency plan failed to meet the specific

planning standards of 10-C. .R., 5 5 50. 4 7 (b) (2) , (b) (14 ) and i

i Part 50, Appeniix E, SIV.F sub-sectior (.b) (2) . Since the contention raised an issue concerning an emergency preparedness i

l exercise, under the Court of Appeal's reading of UCS I, it is 1.

j material to licensing. Slip Op. at 41-42.

t (c) If a material issue is raised in a contention,-the third factor weighs in favor of theLIntervenors sponsoring-the -

i contention. The third factor must stillibe balanced against f

i the other four factors and, theoretically, under:such a

balancing test the-contention might be rejected. However, in reality it is. unlikely tcr ever be _ rejected upon such a balancing test because factors (ii)-and (iv) will-almostEalways weigh.in favor of Intervenors. ;While factor _(v) will. almost i always weigh against the admission of a late. filed-contention, at.best, that-will result in a situation where factors

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~ (v) weigh against the admission of the Contention but factors (ii), (iii), and (iv) weigh in favor. Furthermore, as noted-above the Court of Appeal is of the opinion. that the-f application of factor (v) is potentially inconsistent with UCS I where a contention addresses an emergoney preparedness exercise issue. Under such a balancing test, the majority _of factors will almost always weigh-in favor of_ admission of a contention.

(d) It does-not appear that under-the Court's rationale a-determination of whether a " material issue" is raised is independent of factual issues. A material issue seemingly must be supported by factual allegations. Those facts are_then material to the issue-raised. It would appear that if facts -

are in dispute, there must be a hearing to resolve the issue.

(e) The Appeal Board's application of the-fundamental flaw test in ALAB-918 would appear to exclude" deficiencies in emergency personnel performance-from ever being considered a-fundamental flaw. Under that interpretation a-training deficiency could virtually always be'readily correctableiby further training. That leads to the anomalous result'that or could have-an emergency plan, but v'irtually no1 personnel-competent to implement the plan,' and:yet, that flaw.would--not

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be a hinderance to the issuance of an operating license. In ,

its-opinion, the Court of Appeals expressed its concern with i

that result.

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"We nevertheless recognized that even the best of plans may-be so poorly implemented that it would be foolhardy to license a plant until fundamental deficiencies detected in l

an exercise, such as serious shortcomings _in staff training, were substantially corrected." Id. Slip Op. at 44-45."

Where there are serious.chal~1enges to the adequacy of' operator-training, such as in the Intervenor's on-site contention, one cannot dismiss the contention by saying that_the deficiencies-are readily correctable through further training.

It would appear that if there are disputed facts, or disputed expert opinions, on this issue a hearing would be required to. resolve the issue. See the answer provided to-(d) aboVe.

3. In remanding the issue the Court of Appeals indicated that it was vacating ALAB-918 because of an error' grounded in "a lack of reasoned decision making." Id. -' at. 4 6:. _ : The Court declined to suspend or vacate the-operating license because it balanced that error "against imposing an immensely _ disruptive interim status quo that may itself be displaced." Id.-at 47.-.

Yet,'if one considers that " lack of reasoned decision making" in the context of what is required.for the issuance of a-full.

power operating, there appears to-be cause to; vacate and/or suspend the license cendente lite.

For an' operating license to' issue there has to be reasonable assurance that adequate-protective measures can and.

i will be taken in the; event of a radiological; emergency. Until there is a complete resolution of the issues raised.in the June-1983 l

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l On-Site Exercise Contentions as to the competence of-the i

plant's operating personnel, that assurance is lacking.

Attached to the Intervenors' Application Tor a Stay of  ;

LBP-89-32 is an affidavit signed by Steven Sholly and Gregory Minor pointing out the risks inherent in having unresolved .;

training issues. Exhibit B. That affidavit appears to apply with equal force in the present context. Until one can have-i full faith,in the competence of Seabrook Stations' operators, the plant should not be permitted-to operate.- As long as there is an open and unresolved on-site exercise contention, assurance of the emergency response capabilities of the plant personnel remains an-open question. For this-reason, the license should be vacated, or at least suspended, pending resolution of the matter.

Respectfully submitted,- l NEW ENGLAND COALITION ON SCOTT HARSHBARGER NUCLEAR POWER ATTORNEY - GENERAL

. .W humw le M 6 $ b Dianq Curran, Esq'. Leslie Greer Harmon, Curran-& Towsley Assistant Attorney General Suite 430 . Nuclear Safety Unit j 2001 S Street, N.W.- One Ashburton Place Washington, DC 20008 Boston, Massachusetts 02108 617-727-2200- i l

SEACOAST ANTI-POLLUTION LEAGUE-6W l s 9 { b $ (i Robert Backus, Esq.

Backus, Meyer & Solomon 116 Lowell-Street P.O. Box 516 Manchestcr, NH 03106 Dated: February 25, 1991 1983n a A e mm auJat-*---ps w e e.sr.np4 M.E e a = ..4c dE4 T'.4mJA Lg 4 + ah m-hams **.An, q m ed. h- 4.5Ap#4& SA-AS-fJu'simW$d4 E A- @w at .e.a.J 1e# M---h.i d e 4- 4 mg' rah, _f & e A,4.@ ,.NfJ-4 eJ..4

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Region I l Report No. 50-443/?0 85 i Docket No. 50 443 License No. NPF 86 Licensee: Public Service Company of New Hampshire New Hampshire Yankee Division Seabrook, New Hampshire 03874 Facility Name: Seabrook Station, Unit 1 inspection Dates: December 1114,1990 Inspection At: Bolton, Massachusetts, and Newington ud Seabrook, New Hampshire Inspector: b M ~

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C. G. Amat6, Regional Team Leader ' dhte NRC Region I N, Dudley, Senior Resident Inspector, Seabrook Station E. Fox, NRR/PEPB R. Fu rmeister, Resident Inspector, Seabrook Station Approved: / a. h ief, Emergency

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'Wg)[dar@Section, Preparedness DRSS Inspection Summary: Inspection on D6cember 1114,1990 (Inspection Report No. 50-443/90-85)

Areas Inspected: Announced, routine, safety inspection of the licensee's emergency preparedness exercise.

Results: No exercise weaknesses or plan defic!cncies were identified. The licensee demonstrated the ability to implement their emergency plan in a manner which would protect the health and safety of the public.

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DETAILS

1. PERSONS CONTACTED Unless indicated otherwise the following personnel are Public Senice Company of New Hampshire, New Hampshire Yankee Division, Seabrook Station (NHY) staff, who attended the exercise exit meeting at Seabrook on December 14,1990.

R. Boyd, Jr., Manager, Performance Services E, Darois, Health Physics Supenisor B. Drawbridge, Executive Director, Nuclear Production S. Ellis, Emergency Preparedness Manager, Response and Implementation T. Feigenbaum, President and Chief Executive Officer, New Hampshire Division, Public Service Company of New Hampshire G. Gram, Executive Director, Office of Emergency Preparedness and Community Relations T. Grew, Specialty Training Meaager J. MacDonald, Emergency Preparednese Technical Issues Coordinator D. McLain, Production Senices Manager D. Moody, Seabrook Station Manager J. Peschel, Corporate Support Manager J. Peterson, Assistant Operations Manager N. Pillsbury, Director of Quality Programs

< D. Scanzoni, Corporate Communications Manager S. Schultz, Vice President, Yankee Atomic Electric Company P. Stroup, Director, Emergency Preparedness W. Sturgen, Nuclear Senices Manuger D. Taill: art, Emergency Preparedness Manager D. Young, Scenario Depa +nt Supervisor The inspectors also inter y ad and observed the actions of other licensee personnel.

3 2. EMERGENCY EXERCISE The Saabrook Station, Unit No.1 announced, full participation exercise was condu:ted on December 13,1990, from 11:00 a.m. to 7:00 p.m. The State of New Hampshire, the New Hampshire Yankee Off-Site Response Organization, and surrounding New Hampshire Towns participated.

2.1 Pre exercise Activities The exercise objectives were submitted to NRC Region I on August 27,1990 and, the complete scenario package on September 24,1990 for NRC review and evaluation. Region I representatives had telephone conversations with the licensee's emergency preparedliess staff to discuss the scope and content of the scenario. As a result, minor revisions were made to the scenario which allowed

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3 adeqc te. sting of the major portions of the Seabrook Station Unit No.1 -

Emergency Plan and Implementing Procedures and also provided the' l

l opportunity for the licensee to demonstrate thosa areas previously identitled by 1 the NRC as in need of corrective action. NRC observers attended a licensee brie 5ng on December 13,1990. NRC suggested changes to the scenario made -

by the licensee were discussed during the brie 5ng. The licensee identified which emergency response medvities would be simulated and indicated that controllers-would intercede in exercise activities if necessary to prevent disruption to normal  ;

olant activities.

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2.2 Exercise Scenarlo The exercise scenario included the following events:

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• Initial condition equipment rat of servicet a charging pump, a containment spray pump, a Waste Building Exhaust Fan, and a Control Building Intake ,

Fan;

• A reactor coolant system loop piping weld fails'and a leak into the contamment results;

• Declaration of an Alert (reactor coolant leak greater than 70 gallons per minute);

. The irradiation specimen basket and specimens fall to the bottom of the reactor vessel;

• The resulting loose parts from the irradiation specimen basket caused fuel -

damage and the release of 5ssion products to the reactor coolant system 4 water;

• A high radiation alarm on let down system monitor occurs as a re att of high-fission product activity;

• Solar storm induced geomagnetic disturbances cause damage ~to unit substatior.: at the Seabrook_ Station site and the Newington Emstgency-Operations Facility (EOF). One alternating current supply to the EOF is lost and several Waste Proccuing Building electrical loads are lost; .

• The high range post lossef coolant monitor indicates exposure rates in excess of 2,500 rem /hr inside the containment as a result of the failed fuct and coolant system leak, causing declaration of a Site Area Emergency;;

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• The lealdng reactor coolant loop piping weld fails completely, r large break loss-of coolant accident followed by a reactor ,

inject!on; The loss-of coolant accident results in a hi General Emergency;

• As a result of a damaged containment spray pump, radioactiv released into the envirasunent.

2.3 Activities Observed During the conduct of the licensee's exercise, NRC Inspection t

made detailed observations of the activation and augmentation of Emergency Response Facilities and the Emergency Respo and actions of the Emergency Response OrganizationThe staff dur the Emergency Response Facilities in response to the dmulated eme following activities were observed:

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• Use of operations and emergency plan implementing procedures; i Detection, classification, and assessment of scenario events; -

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• Direction and coordination of emergency response;

• Notification of licensee and New Hampshire State governmen and communication of pertinent plant status information to Sta

! Communications /information flow, and record keeping;

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• Assessment and projection of off site radiological dose and co l protective actions;

Accident analysis and mitigation.

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3. CLASSIFICATION OF EXERCISE FINDINGS Emergency preparedness exercise findings are classified as follows:

Exercise Strengths Exercise strengths are areas of the licensee's staff response that provide strong positive indication of their ability to cope with abnormal plant conditions and implement the emergency plen implementing procedures.

Exercise Weaknesses Exercise weaknesses are areas of the licensee's staff response in which the performance was such that it could have precluded effective implementation of the emergency plan implementing procedures in the event of an actual emergency in the area being observed. Existence of an exercise weakness does not of itself indicate that overall response was inadequate to protect public health and safety.

Areas for Improvement An area for improvement is an area of the licensee's staff response which did not have a significant negative impact on the licensee's ability to implement the emergency plan and implementing procedures and response was adequate.

However, it should be evaluated by the licensee to determine if corrective action could improve performance.

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4. EXERCISE OBSERVATIONS The NRC team noted that the licensee's activation of the Emergency Response Organization, Emergency Response Facilities, and use of these facilities were consistent with their Emergency Plan and Emergency Plan Implementing Procedures.

! No exercise weaknesses were identified. Following are the detailed observations of j performance in each of the emergency response facilities.

l 4.1 Contrc3 Room The following strengths were identified:

1. Reactor operators recognized symptoms and selected the correct control room procedures and used them properly.

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2. Operators correctly interpreted changing containment conditions indicating a reactor coolant leak and took corrective action including estirnation of the j leak rate.

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02/20/91 12:36 NRC RI DOCKET ROOM to.881 P011.

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3. When control room habitability was challenged following loss of positive premure, air samples were taken and the correct evaluation was made l

preventing an unnecessary control room evacuation.

4. Operators responded correctly to an anomalous safety parameter display

- system indication for subcooling margin and reactor coolant system integrity.

No exercise weaknesses or areas for improvement were idemifled.

4.2 Technical Support Center (TSC)

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The following exercise strengths were identitled: .

1. Excellent command and control was demonstrated and frequent staff briefings were conducted.

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2. Data were trended and extrapolated. Problems were anticipated. As a result, the time to reach conditions justifying a Site Area Emergency l

declaration were accurately predicted.

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3. The need to identify plant vulnerabilities as early as possible led to a request to use probabilistic risk aucument..

4. Support resources from Yankee Nuclear Service Division engineers were appropriately requested and utilized..

No exercise weaknesses or areas for improvement were identified.

4.3 Operations Support Center (OSC)-

The following exercise strengths were identiSed.

1. The OSC was promptly staffed with i.4 Y1 physics penannel and the various j disciplines of maintenance personnel.

2. Command and control were excellent. OSC operations were conducted in a j quiet professional atmosphere,

! 3. Repeir teams were quickly established, well controlled, and dispatched with >

adecante protection from hazards.~

No weakneues or areas for Improvement were identified.

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4.4 Einergency Operations Feellity (EOF)

The following exercise strengtha were identifled:

1. There was excellent support of and interaction with representatives of the New Hampshire State government and the New Hampshire Yankee Massachusetts Off Site Response Organization.

! 2. There was prompt and correct response to a simulated loss of the main electrical supply to the EOF.

3. Dose assessment personnel anticipated possible release pathways and performed a "what if' calculation based on possible containment breach in anticipation of a possible release.

4 i 4. There was good command and control, frequent staff briefings and EOF manager's meetings, which included government repre sentatives and the NHY Massachusetts Off Site Response Organization.

5. Environmental monitoring teams were repositioned to minimize mission i

dose.

6. Feedback was obtained regarding implementation of off site protective i actions. This information was announced to EOF staff and relayed to other

! Emergency Response Facilities and Seabrook Station staff.

i No exercises weakneues were identified.

j The following areas for improvement were identified:

! 1. The responsibilities of the NHY staff member proccuing inhalation pathway samples should be reviewed to ensure that activities which might impede his -

performance are assigned to other response personnel.

2. The procedure for processing of inhalation pathway samples could be streamlined by restricting concerns to lodine and noble gas concentrations. -

4 $ Media Center -

The following strengths were 'dentified:

i 1. There were good press briefings using language understandable to the

, public.

2. There was good response to the inquiries of real and simulated reporters.-

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No exercise weaknesses or areas for improvement were identified.

4.6 Correction of Pnviously Identined Exercise Weaknesses and Areas fbr Improvement The inspectors observed licensee response in areas which had previously been identified as weaknesses or areas for improvement during the 1988 and 1989 evaluated emergency exercises.

Four exercise weaknesses were identhd during the June,1988 exercise. All of -

these weaknesses were re addressed and closed in a special inspection. The satisfactory resolution of the:: weaknesses is documented in NRC Inspection

. Report 50 443/8810.

Thr', areas for improvement were identlSed during the 1989 exercise:

1. Transfer of authority from the Short Term Emergency Director (Shift Supervisor) to the Site Emergency Director was not announced on the

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plant paging system.

2, Telephone line noise caused some minor communications problems in the Technical Support Center.

These items did'not recur., Performance in the above areas was acceptable during this exercise,

3. Boron concentration curves should be reviewed to verify that they cover all reasonably expected conditions.

This item was the result of the scenario which involved a core at end of-

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life while the plant was actually at beginning of core life. The curves

used during the exercise were appropriate for the actual plant

conditions.- As the core ages the licensee revises the curves as-appropriate. The inspector has no further concerns regarding this ~ item.

The inspector considers each of the previously identified weaknesses or-areas for improvement to be satisfactorily resolved.

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5. YANKEE A1DMIC ELECTRIC COMPANY (YAEC) SUPPORT OF SEABROOK STATIOP EMERGENCY PREPAREDNESS AC1TVITIES 5.1 Emergency Response Support Through contractual arrangement YAEC provides emergency response support to New Hampshire Yankee (NHY) (as well as several other New England area utilities)  !

to supplement emergency response funtions performed by the station emergency response orlanization. Generally, the support services provided are a back.up to functions performed by the NHY staff, however in two casas the functions are the l primary tasks of YAEC.

The first of these is the task of core damage assessment, which is conducted for NHY by the Yankee Nuclear Service Division (YNSD) of Yankee Atomic _Electrle Company at the YAEC Engineering Support Center. The relationship and function are described in the Seabrook Station Radiological Emergency Plan.- During the -

exercise, core damage assessments were conducted promptly, results were consistent with the scenario information available to the emergency response organization, and the information was promptly communicated to the Site Emergency Director in the TSC, The other emergency response task is the analysis of non altborne environmental samples (water, soil, milk, vegetation, etc.). As this exercise was not an ingestion pathway exercise, demonstration of this capability was not an objective of the

, exercise. The YNSD support personnel responsible for this function were observed l to arrive at the EOF and set up and test their equipment and would have been ready I

to perform the appropriate sample analyses if necessary.

5.2 Audit of YNSD Functions-The inspector interviewed YAEC Quality Assurance (QA) personnel'and NHY personnel to ascertain whether audits are performed of the emergency response.

, functions that YNSD provides under the Seabrook Emergency Plan. Although l YAEC performs audits of the support provided by YNSD to several utilities, the ,

i audits are not specific to services provided to NHY. NHY performs project.

managment reviews of the YAEC Nuclear Service Division program. A NHY i representative indicated that he believed that a combination of the YAEC audits,

YAEC program reviews, and the NHY management reviews adequately ensured the  ;

i quality of emergency response services provided by YNSD. However, based on the

inspector's concerns, NHY agreed to add the audit of the YNSD-supplied services to-i the routine 10 CFR 50.54(t) audit of the NHY emergency preparedness program.

The inspector had no further questions in this ares.

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No.661 M5 02/2o/91 12:36 NRC R1 DoCXET Room

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6. LICENSEE CRITIQUE The NRC team attended the licensee's exercise critique on December 14,1990 during which the licensee's lead controllers and observers discussed observations of the exercise. The licensee's critique was critical and thorough.

7. SEABROOK STATION EMERGENCY RESPONSE ORGANIZATION (ERO)

TRAINING STATUS To determine if an adequate number of personnel were qualified to implement the on site portion of the Seabrook Radiological Emergency Plan, the inspector reviewed training summaries, the qualification Ifst, and the drill schedule.

There are 242 positions described in the emergency response organization (ERO).

The training status at the time of this inspection indicated that 1088 persons were qualified to fill these positions. A check of the ERO qualification list indicated an adequate number of personnel were qualifted for each key position. During 1990 the licensee conducted 14 drills as follows: one dress rehearsal, six medical drills, one radiation monitoring drill, two evacuation drills, two combined functional drills, one NHY Off site Response Organization call in drill, and one Post Accident Sampling l

System drill.

Based on the above review, this portion of the licensee's emergency preparedness l program is acceptable. ,

l 8. EXIT MEETING l Following the licensee's exercise self critique, the NRC team met with the licensee's representatives listed in Section 1 on December 14,1990 to discuss findings as detailed in this report. The NRC team leader summarized the observations made j during the exercise. The licensee was advised that no exercise weaknesses were identified and that all previously identified exercise weaknesses and areas for improvement had been adequately demonstrated. The NRC team also determined i that within the scope and limitation of the scenario, the licensee's performance

demonstrated the capability to implement the Emergency Plan and Emergency Plan -

Implementing Procedures in a manner that would adequately protect the health and safety of the public.

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p -t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION

)

In the Matter of )

)

PUBLIC SERVICE COMPANY OF - ) Docket No. 50-443 0L NEW HAMPSHIRE, ET AL )

)- November 30,1989 (Seabrook Station Unit 1) )

, )

JOINT AFFIDAVIT GREGORY C. MINOR AND STEVEN C. SHOLLY I, Gregory C. Minor, do make oath and say:

1. My name is Gregory C. Minor. I am a Vice President of MHB Technical Associates. My business address is 1723 Hamilton Avenue, Suite K, San Jose, California 95125. I received a B.S. in Electrical Engineering from the University of California, Berkeley, in 1960 and a M.S. In Electrical Engineering from Stanford University in 1966.

2, I have over twenty five years experience in the design, development, research, start-

, up testing, and management of nuclear reactor systems. From 1960 1976, I worked for General Electric Company in the design, development, and testing of safety and control systems for nuclear i

power plants. My responsibilities included equipment and systems design, as well as management of a large engineering group responsible for new control room design.

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,- 3.

For the past thirteen years, I have been an independent technical consultant. In that capacity, I have participated in a variety of studies addressing nuclear facility economic, management, and safety issues for various organizations, including the Department of Energy /Sandia National Laboratories, the Swedish Government, and the offices of sever Attorneys General. I am currently a consultant on several nuclear plant cases in wh management, and compliance with existing regulations are being investigated.

4.

I am a member of the Nuclear Power Plant Standards Committee for th Instrument Society of America. Also, I participated in a Peer Review Group of the Nuclear Regulatory Commission's Three Mile Island Special Inquiry Group.Further details of my qualifications and professional experience are summarized in my Statement of Professional Oualifications which is appended to this affidavit at Attachment L 1, Steven C. Sholly, do make oath and say:

5.

My name is Steven C. Sholly. Since September 1985, I have been employed Associate Consultant by MHB Technical Associates. My business address is 1723 Hamilto Avenue, Suite K, San Jose, California 95125.

6.

I have been previously employed by the Union of Concerned Scientists as a Technical Research Associate and Risk Analyst from February 1981 to Septemb the Three Mile Island Public Interest Resource Center as Research Coordinator Director from January 1980 to January 1981. I also have non nuclear experience in the wastewater treatment and science education fields from September 1975 to January 1980. I received a D.S. in Education, with a major in Earth and Space Science and a minor in Environmental Education, from Shippensburg State College (now Shippensburg U Shippensburg, Pennsylvania, in 1975.

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7. For the last nine and a half years, I have been engaged in analyzing technicai nuclear safety, management, design, construction, and regulatory issues and providing technical advice to state and local governments (including the States of California, New York, Illinois, Pennsylvania, Maryland, Maine, Connecticut, and Massachusetts, and Suffolk County, New York) and independent organizations on these issues. I have presented testimony concerning these issues before the Connecticut Department of Public Utility Control on behalf of the Prosecutorial Division and Division of Consumer Counsel, before the California Public Utility Commission on behalf of the Division of Ratepayer Advocates, before the Pennsylvania Public Utility Commission

, on behalf of the Office of Consumer Advocate, and before the Massachusetts Department of Public Utilities on behalf of the Office of the Attorney General, Commonwealth of Massachusetts.

I have also participated as an expert witness in proceedings before the Atomic Safety and Licensing Board in the Indian Point Special Investigation and the operating license review of the Catawba nuclear plant, and have presented testimony before the United States Congress and the

Sizewell Inquiry (U.K.) on nuclear safety issues. Further details of my experience and que.iifications are contained in my Statement of Professional Oualificatiam which is appended to this affidavit as Attachment 2.

1 DISCUSSION

8. Cc May 26,1989, .4 >w Hampshire Yankee received a license from the U.S. Nuclear Regulatory Cornmission permitting low power operation (not to exceed 5% of full power, with certain other restrictions) of Seabrook Unit 1 (License No. NPF 67).

9. NRC regulations at 10 CFR 50, Appendix E, require the conduct of an exercise to test the operation license applicant's ability to respond to a radiological emergency. During such an exercise, an accident is simulated, and the applicant's ability to achieve certain objectives is 3- l

1. 9 evaluated by the NRC and the Federal Emergency Management Agency (FEMA), in June 1988, a FEMA /NRC graded exercise was conducted at Seabrook Unit 1. Among the established objectives for the exercise was to *(d)emonstrate the abilin* to analy:e station conditions, parameter l trends and develop potential solutions for placing the unit in a safe, stable condition". 1/ The j scenario for that exercise included a large break LOCA which occurred during efforts to restore an emergency feedwater pump. Notwithstanding the occurrence of the large break LOCA, plant personnel were directed to continue efforts to restore an emergency feedwater pump. This action was illogical since the emergency feedwater system cannot help achieve safe shutdown in the event of a large break LOCA, and the action would have accomplished nothing in a reallarge break LOCA event toward " develop [ing] potential solutions forplacing the unit in a safe, stable condition *.

Indeed, New Hampshire Yankee's own Seabrook Unit 1 probabilistic risk assessment 2/ studies do not include the emergency feedwater system in the system event tree for large break LOCAs for that very reason. Continuation of efforts to recover an emergency feedwater pump following a large break LOCA represented a very poorjudgment on the part of plant management. 3/

3 1/ Report of the 1988 FEMA /NRC Graded Exercise, at 2.2 2.

4/ A probabilistic risk assessment (PRA)is an analysis of the likelihood and conseg,uences of postulated severe accidents. The objective of a PRA is to *idendfy and delmente the

, combinations of events that, if they occwred, could lead to undesirable public comegences and to estimate the magnitude of those consequences and their respective probabilities . Su, i

Office of Nuclear Regulatory Research, U.S. Nuclear Renilatory Commission, Probabilistic Risk AssessmentMRA) Reference Document, Final Report, NUREG 1050, September 1984, at 10. He NRC has published a procedures guide for the conduct of PRAs. Su, U.S. Nucleas Regulatory Commission, FRA Procedures Guide: A Guide for the Performance of ProbabiHstic Risk Assessments for Nuclear Power Plants, NUREG/CR 2300, Vols.12, January 1983.

3/ New Hampshire Yankee has stated, and the NRC staff has agreed, that the EFW pump would be required to operate to support steam generator cooldown in the recovery chase and that continued repair actions were 3rudent (NRC Inspection Report 8810, Octo >er 6, 1988). This is not correct. Following a . arge break LOCA, the only heat transfer surface in the steam generators is that of containment atmosphere on the primary side (admittedly containing some steam), and, if EFW is available, water from the condensate storage tank on the secondary side. This is a ym inefficient heat transfer configuration, and one which would have no measurable effect on removing decay heat from the core or heat in general from the containment. Following a large break LOCA at Seabrook, the residual heat removal system would be relied upon to remove heat from the core and the containment spray system would be relied upon to remove heat from the containment. The EFW system p -rv-

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10. On May 3,1989, the Regional Administrator wrote a memorandum to the Director

.of the Office of Nuclear Reactor Regulation in which he noted a "possible dec'ining trend infacility performance", and observed that two events which constituted part of this trend involved " violations of the special zeropower licerue conditioru associated with locked valvet. Notwithstanding these concerns, however, the Regional Administrator recommended issuance of a low power license, which was granted less than three weeks later,

11. Operational performance has continued to decline. On June 23,1989, following an incident during the conduct of a natural circulation test (1 ST 22) at low power (described below),

the NRC Region I Administrator issued a Confirmatory Action Letter (CAL 8911) which, among other things, prohibits New Hampshire Yankee from operating Seabrook Unit 1 until the Regional Administrator grants his consent. The terms of CAL 8911 prohibiting operation until the Regional Administrator grants his consent remain in effect (CAL 8911 is provided as Miashment 3).

12. During low power testing on June 22,1989, involving a natural circulation test, plant

, i personnel failed to manually trip (i.e., shut down) the reactor in a timely fashion despite exceeding j the manual trip criterion. The reactor was later tripped manually only when it became clear that an automatic scram was inevitable (due to factors other than the one which caused the manual trip 9

simply cannot accomplish either of these safety functions (or any other safe function, for that matter) following a large break LOCA. In the event of a large EFW availability would be material only ahgI safe shutdown is reached, aficI the reactor is defueled, ahtI the large break LOCA break location is reaalred, afttI the reactor is refueled, and AhtI the reactor is restarted and some level of c ecay heat is accumulated in the core. These actions would almost certal have required weeks, if not months, to complete, and would have been taken well ter the accident was terminated and the Technical Support Center destaffed. Accordingly, EFW availability w"ould have had no impact whatsoever on " steam generator cooldown m the recovery phase , New Hampshire Yankee and NRC staff statements to the contrary demonstrate L remarkable level of ignorance about the capabilities of the emergency feedwater system and its role in recovering from a large break LOCA.

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l criterion to be exceeded). The plant personnel in the control room who observed this condition included the entire five person licensed operator crew (including the Unit Shift Supervisor), all of whom had the authority to manually trip the reactor, as well as Startup Manager, the Test Director, the Assistant Operations Manager, and a host of additional management and operations i personnel. Following this event, the Vice President - Nuclear Production of New Hampshire Yankee *made a deculon to resume testing without completing a detailed and thorough analysis of the underlying causes of the event and without correcting the related luiman perfomtance deficiencies' (NRC Notice of Violation, October 25,1989). The next day, as noted above, the NRC Regional i Administrator issued a Confirmatory Action 12tter precluding further operation without his i

{, consent, and the terms of the CAL remain in effect. Moreover, subsequently (October 25,1989)

,i

the NRC staff issued a Notice of Violation and imposed a $50,000 civil penalty related to these i

< events. y

~l l 13. On September 15, 1989, the NRC staff informed New Hampshire Yankee that during the week of December 11,1989,it plans to evaluate the proficiency of all Seabrook shift crews under simulated accident conditions. This is an extraordinary measure that is, to our i knowledge, unprecedented. Once nuclear power plant operators have passed their NRC-administered operators' license examinations, as Seabrook's operators have, the NRC does not generally subject them to additional testing under simulated accident conditions. Moreover, this proposed test is unusual in that it will evaluate all of the Seabrook shift operating crews, not just the one crew on duty at the time of the June 1989 natural circulation test. In our view, the NRC's

) intention to require proficiency evaluations of all of the Seabrook operators under simulated

accident conditions accurately reflects the extremely serious nature of the problems evidenced during the failed natural circulation test on June 22,1989. (The NRC staff letter informing New Hampshire Yankee of the operator proficiency evaluations is provided as Attachment 5.)

y The NRC's Notice of Violation and proposed imposition of civil penalties is provided as

Attachment 4.

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t 14. The events discussed above give rise to serious questions about the judgment of New Hampshire Yankee personnel in operating Seabrook Unit I at power levels above 5% of full power. Human performance is well recognized as an important contributor to the risk of nuclear ,

power plant operation even when operational petformance is otherwise nominal. Fur instance, the NRCs "PRA Reference Document" (NUREG 1050), which summarized insights from dozens of PRA studies, indicated that human interactions with plant safety systems "are errremely important contributors to safety and reliability" oi nuclear power plants, that the tcllability oi human actions important to safety (as well as systems and components important to safety) ruust be maintained during operation, and that degradation in their reliability can " sharply increare the risk i or likelihood of core melt". 5/ Human reliability is also important specifically at Seabrook.

Among the twenty most likely accidents at Seabrook, New Hampshire Yankee's 1983 PRA study - -

of Seabrook identified several accident scenarios where human actions are an important factor i (i.e., actions such as recovering failed systems, failure to establish long term decay beat removal, I failure to establish feed and bleed cooling, failure to perform emergency boration, etc.). 6/

15. In addition, it is well recognized in the PRA field that the likelihood of core damage ,

frequency may be higher in the first year or two of full power operation. 'Diis is in part due to the well recognized fact that transient events which can initiate accidents are much more likely in the 1/ Office of Nuclear Regulatory Research, Probabilistic Risk Assessment (PRA) Re(gig,gg Document. Final Report, NUREG 1050, September 1984, a+. 6 and 64.

(/ Pickard, Lowe and Garrick, Inc., Seabrook Station Probabilistic Safety Assessment, PLG-0300, December 1983, at 2.310 and 2311. It should be noted, moreover, that Seabrook's

~

core damage frequency is estimated by that study to be 23 x 104per reactor year, or about one chance in 4,300 per reactor-year for a mature olant assuminn nominal humnu oerformance. IhkL Given declining human performance, one would gntrally

~

e > expect the ccre damage frequency to increase due to increasing human error rates. This expectation is confirmed in a recent Brookhaven National Laboratory study for the NRC staff (using the Oconec plant as a case study) which concluded that small chages in human error rates could have significant impacts on risk. Sag, T. Samanta, et al., Bd.Samitivity to Human EH.QI, Brookhaven National laboratory, prepared for the Office of Nuclear -Reactor Regulation, NUREG/CR 5319, April 1989, at ES-3.

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first two years of operation. For example, data for the peric<l of 19841988 compiled by Office for Analysis and Evaluation of Operational Data ildicate that mature Westinghouse have a frequency of transients resulting in reactor trip of 0.61 trips /1,000 critical hours, wh new plants had a frequency of 1.95 trips /1,000 critical hours - a <lifference of a factor o than three (on average). Similarly, personnel errors are a more frequent contributor to reactor trips for new plants than for mature plants - a rate of 0.17 trips /1,000 critical hours f compared with a rate of 0.53 trips /1,000 critical bours caused by personnel enors, a of more than three difference (on average). 2/

16. Given these circumstances, declining operational performance in the yer preceding the full power operation is a very serious matter. To allow Seabrook to initiate operatio power before resolving the problems identified above would pose an unacceptable unnecessary added risk to public health and safety.

17. In cases of declining performance involving operating plants, the hRC has not hesitated to step in and cause a cessation of operations (whether by Confirmatory Action Lette by Order) until the performance problems are corrected and a period of improved perf seen. $/ In the case of Seabrook Unit 1, which is licensed for low power testing, there is _

for more lenient treatment. In our opinion, the NRC should not consider issuance of a full powe

' license until the performance problems identified above are resolved, and until New Hamp Yankee demonstrates by a period of troublefree activities that it is fully and adequately prepar to undertake power operations. The NRC should assure itself of New Hampshire Yanke Office for Analysis and Evaluation of Operational Data,1988 Annual Reoort. NUREG-2/ 1272, Vol. 3, No.1, June 1989, at A 59, A-63, A 88, and A 92.

8/ For example, this was the staff practice in the case of Pil 'mand (sSutdown Peach Bottom under Confirmatory (Action Letter from April 1986 until December 1 U ,

exist as well (Calvert Cliffs Units 1 and 2, Rancho Seco, Davis Besse, Browns l'erry Un 2, and 3, and Sequoyah Units I and 2.

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, 8 i

~ m a m.m readiness to w&ly minduct power 9pratens by completion of the planned operator proficiency i

evaluation, and by conduct of a detailed operational readiness inspection by en inspection team consisting of experts in the various relevant operational d!sciplines (licensed operators, p i nonlicensed operators, training, radiological chemistry, health phpics, makitenance, management,  ;

and so on) (Such inspection have been performed at other p' ants which have been shut dowt. )

due to performance problems.)

/

9

18. A:cordingtv, we conclude that it is premature r issue a full power operating liceute until the problems identified above iuve been resolved. Indecu, le NRC has tacitly

)

acknowledge (! as aluch ty reae. iring a hall in low power operation -(CAL 8911) Mxi by equirir!',

an unprecedented operator proficiency evaluation of alllicenwd operators at Seabrook, Signed under 'he pain.s and penalties of perjury Sid0th day of November 1989.

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'hroved to rnes on the basis of Satisf actory eYidence

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}' NOMW PUB 00.CMODA within instruttent, and acknowledged that . executedit.

$VFA Cl#A CQUN'y j fgg5)% 1 W'iTr4ESS my hand and of ficial seal.

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iw 1 I T Signed under the pains and pena}tles of perjury 61st day of December 1989, Gregory C Minor

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J ATTACHMENT 1 5.atement of Professional Quallfications Gregory C. Minor I

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) I PROFE1510NAL OUALIFICATIONS OF GREGORY a MINOR 1

l GREGORY C. MINOR MHB Technical Associates 1723 Hrsnilton Awoue  !

Suite K San Jose, California 95125 (408) 2f62716 EKPERIENCE:

I 1975 to PRESENT Yice President . MHB %ehnical Anociatet. San fose. Californig Enginecting and energy consultant to stete, federal, and '

to leghlative, regulatory, public and private groups and e Union of Concerned Scientists and co author of a risk mlysis cf Sndish reacts ior the Su Energy Commission. Serwd on the Peer Review Grcrup of the NRC/TMI Special Inq (Rogovin Committec). Actively involwd in the Nudear Powr.r Plant Standards Co the instrument Sodety of America (ISA).

1972 1976 Manneer. Advanad Control and _instrumentatlo! LEG 8iECEin8 General Electric Comnan r

Engrev Division. SanJ_ar. Califernia l

I Managed a design and development group of thirty four engiriecrs and support pe l

j systems for use in the measurement, control and operat I Responsibilities included coordinating and managing and desip and overseas and domea. tic.

development of control Syr.tems, safety systems, and new ccattol concepts for use o generation of reattors. The position induded responsibi l

tradvd meluded electrical and mechanical engineering, seismic desip and procest. computer con-

' tsol/pugramming, an,1 equipment qualification.

1970 1972 Mananer. Reactor Control Syr.temt Deslan General Electric Comnanv. Nuclear Enerry hae. California

Managed a group of seven engineers and two suppo reactors. Responsibility required coordiution with other desip organizations and m customer's cagineering personnel, as well as regulatory personocl.

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1963 1970 D"len Enairger. General Eltetric comnanv. Ngde ar Enerry Djvidort San J oe. ca Responsible for the desip of specific control and intrumentatisn sy l

- design reApondbility for vadous subspterns Other of intru i

the _ design of t asjor system for measurQ the powe mental reactor lo the Southest. ReceJwd patent for Nude.u Power Monitoring Sptem 1 % 1963 I

6dynggd Enaineerior Procarc.ger:eral Eledric Comeany,2ssgamtn Anddt314 Rotating asdgnments in a variety of disdpliam Engineer, reactor maintenaces and lastrument dulgn, KE and D re Wahlapon, circu;t design and equipment maintenance coordhden.

Dedgn engineer, Microwan Deputment, Pab Alto, Californla. Work o couplers for Microwave Trawling Waw Tubes (TWT),,

Design engineer,Computet Department, Phoenk, Arizone. Desip of co Dedgn engineer, Atomic Power Equipment Department, San h.se, C and anal3 s.

Desip engineer, Space Sptems Department, Santa Bubua, Californ portion of satell".e proposat Technical Military Plannlog Operation. (TEMPO), Santa Bubars

- Technical Stan California. Prepart analpes of missile exchanges.

d During this period, completed three year GenerrJ Elcetric picgram of en '

engineering principles of bisher snatherandes, probability an Kepner.Tregoe, Eliurht j

semmara.

EDUCATION Univers3ty of California at Berkeley, ESEE,1960.

Advanced Course ic Engineering three year curriculum, General Electric Com Stanford University, MSEE,1966.

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N b HONORS AND ASSOCIATIONS Tau Bet!. Pi Erpeering Honorvy Society Co. holder of U.S. Patent No. 3,56$.760, 'Nudear Reactor Power Moni oring t System,'

February,1971.

Member: American Association for the Advancement of Science.

Member: Nuclear Power Plant Standards Cotornirtee,letrument Society of America.

PUBUCATIONS AND TES'ITMONY

1. G. C. Minor, S E. Moore, ' Control Rod Signal Multiplexing,' IEEE Tranuctions on Nuclear Science, W MS.19, February 1972.

2. G. C Minor, W. G. Milam 'An Integrated Control Room Systetu for a Nuclear Power Plant,' NEDO.

106.48, preunted at international Nudear Industries Fair and Technical Meetings October,1972, Bule, Switzerland.

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. 3. The above article w also pubikhed in the Germe.n Tuhnleal Magar.ine, N'T, March,1973.

4. Testimony of G. C. Mira, D. G. Bridenbaugh, and R. D. Ilubbed before the Joint Committee on Atomic Energy, Heartr.g held February 18,1976, and published by the Union of Concerned Scientists, Cambridge, Maundusetts.

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5. Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the California State Anembly Committee on Resources, Land 'Uw, and Energy, March a,1976.

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6. Teulmony of G. C Minor and R. B. Hubbard before the California State Seaate Committee on Public Utilities, Transit, and Energy, March 23,1976.

7. Tenimony of G. C Minor regeding the Grafentheinfeld Nudear Plant, March 1617,1977. Wurzbuerg, Germany.

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

9, The Rhks of Nuclear Pwn,Renetore A Review of the NRC Reactor Safety Study WASH.1400

, (NUREO.75/014L H. Kendal! et al, edited by G. C. Minor and R. B. Hubbard for the Union of Concerned Scientists, August,197/.

10. S.wedkh Reactor Safety Stude Barseback Risk Aucument. MMB Technical Anociates, January,1978. ,

(Pubthhed by Swedish Department of Industry as Document Dsl 1978:1)

11. Testimony by G. C Minor before the Wiscouin Public Service Commiulon, February 13,1978, Loss of farlant Accidentr Their Probability and Conseqqtug.

12. Testimony by G. C Minor before the California Legislature Auembly Committee on Resources, Land Use, and 81nergy, AB 3108, April 26,1978, Sacramento, California.

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13. Presentation by G. C. Minor before the Federal Ministry for Research and Tc4hnology (BMfT),

Meeting on Reactor Safety Research, Man / Machine Interface in Nuclett ReACLQIA, August 21, and September 1,1978, Bonn, Germany.

14. Testimony of G. C. Minor, D, G. Bridesosugh, and R. B. Hubbard, before the Atomic Safety and ucensing Board, September 23,1978,in the matter of Black Fox Nudear Power Station Coratruction Perinit Hearmgs, Tulsa, Oklahoma.

15. Testimony of G. C. Minor, ASLD Hearinp Related to TMI 2 Accident, Rancho Seco Power Plae, on behalf of Friends of the Earth, September 13,19Ts.

16. Testimony of G. C. Minor before the Michigan State 1.4gislature, Spedal Joint Committee on Nudear Energy,Imolications of Th tt e Mile Island Accident for Nuclear Power Plants in Midigga, October L5, 1979.

17 /LQritical View oLEeactor Safem by G. C. Minor, paper presented to the American Ar.seciation for the Advancement of Science, Symposium on Nudear Reactor Safety, January 7,19R San Francisco, California.

18. The Effects of Acine on Safety of NughgPower Plants, paper presented at Forum on Swalish Nuclear Referendum, Stockholm, Sweden, March 1,1980.

19. hiinnuQin Nuclear Plants GastaLEmir,sions Study, MHB Technical Associates, September IbO, prepaicd for the Minnesota Pollution Control Agency, Roseville, MN.

, 20. TestimouY of < i C. Minor and D. G. Dridenbaugh before the New York State Public Servke I Commission, Doreham Nuclear Plant Construction Schedule. In the matter of 1.org Island Ughting Cornpany Temptaary Rate Case, case # 27D4 Septembet 22,1980.

21. Dired testimony of Dale G. Bridenbaugh sad Gregory C. Minor before the New York State Public Senice Commission, Kaiser Engineers Power Corporation Review, Shoreham Nuclear Power Station Costs and Schedule. in the teatter of L.ong Isled Ughting Company Temporar; Rate Case, Case Number 27D4, September 29,1980.

22. Sntems Interaction and Sincie Failure Crittti2D, MHB Technical Associates, Jtuuary,1981, prepared for and available from the Swedah Nudear Power inspectorete, Stockholm, Swed :n.

23. Tesduony of G. C. Minor and D. G. Bridenbaugh before the New Jersey Board of Public Utilities, Onter Creek 1980 Refueline Outace Invettiption, in the matter of the Petition of Jersey Central Power and Ught Company for approval of an increase in the rates for electrical senice and adjustment clause and factor for such service, OAL, Docket No. PUC 3518 80, BPU Docket Nos. 804 285, 807 488, February 19,1981.

24. Testimony of G. C. Minor and D. G. Bridenbaugh on PORV's trid Presseriter Heaters, Diablo Canyon Opers: ting Ucense bearing before ASLB,in the matter of Pacific Gas and Electric Company (Diablo Cany.,n Nuclear Power Plant Units 1 and 2), Docket Nos. 50 275 OL.,50 323 OL, January 11,1982.

! 21 Testimony of G. C. Minor and R. B. Hubbard on Emercency Response Plannine. Diablo Canyon Operating Ucense hearing before ASL.B, Docket Nos. 50 275-OL,50 323-OL, January 11,1982.

26. Systems Interaction and Sincle Failure CritrIjenfhait.[LEtpct1, MHB Tuhaical Associates, February l 1982, prepared for and availab?e from the Swedish Nuclear Power irgectorate, Stockholm, Sweden.

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27. Testimony of O. C. Minor, R. B. Hubbard, M. W. Goldsmith, S. J. Harwood on behalf of Suffolk County, before the Atomic Safety and Ucendng Board, in the matter of long Island ughting Company, Shoreham Nuckar Pour Station, Unit 1, regarding Contention 7B, Saferv c'taul6cition and Sntemt inttraction. Docket No. 50 322 01, AprU 13,1982.

28. Testi'nony of G. C. Minor and D. O. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety and Ucendng Board,in the saatter of Long Island Ughting Company, Shoreham Nudcar Power Station, Unit 1, reguding Mg1 County Contentian 11. Panive Mechanleal Valve Failure. Docket no. 50 322-OL April 13,1982,

29. Testimony of G. C. M!not and R. B. Hubbard on behalf of Suffolk County, before the Atomic Safety and ucendag Board, in the atatter of long Island ughting Company, Shoreham Nudcar Power Station, Unit 1, regarding Suffolk County Contention 27 and SOC Contention 3. Post Aecident Manitorina.

Docket No. 50 322 01, May 2.5,1982.

30. Testimony of G. C. Minor and D. O. Bridenbaugh on behalf of Suffolk County, before the Atomk Safety and Ucendng Board,in the matter of Long Idaad ughting Company, Shoreham Nudear Pour Station, Unit 1, regarding suffolk County Corgention 21 SRV Test Prontam. Docket No,50 322 01, May 25, 1982.

31. Testimocy of G. C. Minor and D. G. Bridenbaugh on behall of Suffolk County, before the Atomic Safety and Ucensing Board,in the matter of Long Island ughting Company, Shoreham Nudear Power Station, Unit 1, regardicg Reductine of SRV rk=Nagu, Docket No. 50 322 014 June 14,1982.

32. Testimony of G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Ucensing Board, in the matter of long Idaad ughting Company, Shoreham Nudear Power Station Unit 1, regarding Endranmenimi Ou=Wattan Docket No. 50 322 01, January 18,1983.

33. Testimony of O. C. Minor and D. O. Bridenbaugh before the Pennsyhania Public Utility Commission.

on behalf of the Office of Consumer Advocate, Reemedine the Coat of Canarructine the Sunnughggng steam Clectriejtitlan Unit 1. Re: Pennsylvania Power and Usht, Docket No. R 822189, March 18, 1983.

34. Supplemental testimony of G. C. Minor, R. B. Hubbard, and M. W. Goldsmith on behalf of Suffolk County, before the Atomic Safety and Ucensing toard, in the matter of Long Island Ughting Company, Shoreham Nudear Pour Station, Unit 1, regarding Safetv Ct="ification and Sntems Interaction (Contention 7BL Docket No. 50 322, March 23,1983.

35. Verbal testimony before the District Court Judge in the case of Sierra Club et. al. vs. DOE regarding the Chan up of Uranium MillTaihngs. June 20,1983.

% Swtems Internetinn and Rinete Failure Criterion: Phas 3 Renort. MHB Technical Associates, June, 198% prepared for and available from the Swedish Nuclear Power laspectorate, Stockholm, Sweden.

37. Sntematte Evalumilan Proaramt Status Renort and lettial Evaluation. MHB Technical AsAcciates, June, 1983, prepared for and available from the Swedish Nudear Power laspectorate, Stockholm, Sweden.

38. Testimony of 0. ' .linor, F. C. Finlayson, and E. P. Radford before the Atomic Safety and Ucensing Board, in the Matter of long Island ughting Company, Shoreham Nuclear Power Station, Unit 1, regarding Emereenev Plannina Evacuation T*unes and Dntes fContentions 65. 23.D and,3MD, Docket No.50 322 01 3, November 18,1983.

39. Testimony of G. C. Minor, Shewell 'B' Power Station Public inquiry, Proolof Evidence Recardine Safety Issuel December,1983.

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40. Testimony of D. G. Bridenbaugh, L M. Danielson, R. B. Hubbard and G. C Minor before t'4 Stsie of New York Public Ser sce t'a==1ulaa__ PSC Case No. 27563, in the matter of Img Idaad ughting Company Pra**Aiaa to Instinate the Coat of the Shoteka= Nudene Generatina F=Allry - Phma, II, on behalf of County of Suffolk, February 10,1964.

41. Testimony of Pred C f*mlayson, Gregory C. Minor and Edward P. Radford before the Atomic Safety

• and Ucensing Board, in the Matter of leeg Island ughting Company, Shotcham Nudear Power Station, Unit 1, on behalf of Suffolk County Regarding Emereena Plaaata . Shelte-ine (Cantentinn 611 Docket No. 50 322 OL, March 21,1964.

42. Teatimony of G. Dennis Eley, C JoLa Smith, Gregory C. Minor and Dale G. Bridenbaugh before the Atomic Safety and Ucensing Board, in the matter of long Ishnd Ughting company, Shoreham Nudcar Power Station Unit 1, regarding EMD Diesel Generators arl 20 MW Gas 'hirbine. Docket No. 50 322 01, March 21,1984.

43. Revised Testimony of Gregory C Minor before the Atomic Safety and ucensing Board, in the matter of long Idaad ughting Company, Shortham Nudear Power Station Unit 1, on behalf of Suffolk County regarding Fmerrency Plane.ir.a Recovery and Reentry (Contentinne R$ ==A 881 Docket lu. 50 322 01, July 30,1964.

44. Testimony of Dr. Christha Meyer, Dr. Jose Roesset, and Gregory C. Minor before the Atomic Safety and Ucensing Board,in the matter of Long Idand Ughting Company, Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County, regarding low Power Hearinet Seismie t'anabilitica of AC Power Sources. Docket No. 50 322 OL, July 1984.

45. Sunebuttal Teatimony of Dale G. Bridenbaugh, Lynn M. Danielson, Richard B. Hubbard, ar d Gregory C. Minor, Before the New York State Public Service Commission, PSC Case No. 27563, Shoecham Nudear Station, Long Idand ughting Company, on behalf of Suffolk County and New York State Consumer Protection Board, regarding Instination of the Cost of the Shoreh== Nndear Generatine Eas;ihty, October 4,1964.

)

, 46. Direa Testimony of Dale O. Bridenbaugh, Lynn M. Danielson and Grescry C Minor on behalf of Massachusetts Attorney General, DPU 84145, before the Massachusetts Depa-tment of Pubbe Utilities, I

regarding Prudence of Fmenditures tv f~itchburg Gas and Electric l_leht Comnany for Seabrook Unit 1 Nonmber 23,1984,84 pgs.

47. Direct Testimony of Dale G. Bridenbaugh, Lyoa M. Danielson and Gregory C Minor on behalf of Maine Public Utilities Commission Staff regarding P_rydence of Costs of Seabrook Unit 1 Docket No.

84113, December 21,1984.

48. Direct Testimony of Dale G. Bridenbaugh and Gregory C Minor on behalf of Suffolk County regarding Shoreham Emereenev Diesel Generator loadt Docket No. 50 322 OL, January 25,1985.

49. Dired Testimony of Dale G. Bridenbaegh, Lynn M. Danielson, and Gregory C. Minor on behalf of .he Vermont Department of Public Service, PSB Docket No. 5030, regarding Prudence of Central Vermont Public Service Corporations Costs for Seabrook 1 November 11,1985.

50. Surrebuttal testimor,y of Gregory C Minor on behalf of the Vermont Department of Public Serdce, PSB Docket No. 5030, hudence of central Vermont Public Service Cornorations Costs for Seabrook 1 December 13,1985.

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St. Direct Testimony d Dale G. Bridenbaugh, Gregory C. Minor, Lyon K Price, and Stena C. Sholly on

. behalf of State of cr M ent i Department of Public Utility Control Prosecutorial Division and Division

! of Consumer Counsel tr$arding the Prugleper of Emadituras na Millstane Unh ). Da.ket No. R.t07 03, February 18,1986.

52. Direct Testimony of Dale G. Brideabaugh and Gregory C. h8isor on behalf of Maunchusetts Attorney General regarding the Pradaa~ of W----%res by New Faaland Power Co for whook Unit i Docket Nos. ER.85446000, ER45447 000, February 21,1906,

53. Direct Testimony of Gregory C. Minor os behalf of the Prosecutorial Divisloa of CDPUC regarding C1AP Constructiop Prudence for Mdistane Unit 3. Docket No. ER45 730001 March 19,1995.

54. Direct Testimony of Dale G. Bri!cabaugh and Gregory C. M'aor ce behalf of Maunchusetts Attorney i

Gemment regarding WMEco constructina Prudenne for Millstaae Unh 3. Docket No. 85 270, March 19, ,

1986. J 7

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55. Direct Testimony of Da!s G. Brideabaugh and Gregory C. Minor on behalf of Maunchusetts Attorney

, General regarding WMEco's ca=mercial Onermela. Daten and Deferred raaleal A AAhtaan on '

Mdistone Unit i Docket No. 85 270, March 19,1996.

56. Rebuttal Teethnomy of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Manachusetis Attorney

! General regarding Retv.'tal to New England Power Compaav's Seabraak 1 Docket Nos. ER4544&001,

ER45447 001, April 2,1986.

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57. Direct Testimony of Dale G. Bridenbaugh end Gregory C. Minor ou behalf of State of Maine Staff of  !

i Pubbe Utilities Comminion regarding paastruellan Prggaes c4 Millstone Unit 1 in the matter of

, Maine Power Company Proposed increase la Rates, Docket No. 85 212, April 21,1986.

i e 58. lugliggimu[the rheanhwl 4 A,,iA*at for Nnelane #==*aaagPiannine for the State of New Yort prepared for the State of New York Consumer Protection Beard, by MHB Technical Auomatea, June i 1906.

l $9. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of the Vermont Department  ;

j of Public Service, regarding Prma. at e hv canical Ver-a=* Puhtie Service Corooration for i j Millstone 1 Docket No. 5132, August 25,1986.

i

60. Surrt,buttal Testimony of Gregory C. Minor in the matter of Jersey Central Power and Light Compnay,

, regarding IMUtestart and Performaan Ia'aadven. (Oral testimony), OAL Docket No. PUC 793945,

! BPU Docket No. ER851116, September 11,1986.

I

! 61. Surrebuttal Testimony of Gregory CiMinor on behalf of Staic of Vermont Department of Public i

Service, regarding CVPS/NU rnaaernesian Prudsnce talasad to Mllisione Unit 1 Docket No. 5132, November 6,1986.

! 62, Direct Testimony of Gregory C. Minor and Lyna K Price on behalf of State of Vermont Department of -

1 Public Service, regarding PraA-aaa of F===adituren for Em*heook L Docket No. $132, December 31,-

1986.

63. - Direct Testimony of Gregory C. Minor on behalf of Suffolk Couary, before the Atomie 56ety and -

13 ceasing Board, concerning Shoreham Protactive Action Racam=a Adians fraataatine EX 'W. in 4

the matter of laag Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, Docket No. $0 -

. 322 01 5, February 27,1987. -

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64. Dired Testimony of Gregory C Minor et. at on behalf of the State of New York ted Suffolk County, before the Atomic Safety and Ucensing Boud, regarding The Seone of thLEmurtney Planniar Etercise (Cententiom EY 15 and 18, in the matter of Long Island Ughting Company, Shoreham Nuden Power Station, Unit 1, Docka No. 50 322 Ob5, April 6,1967.

65. Direct Testimony of Gregory C. Minor regarding fattttney Plannine Recention Centgn Monitorinc and Decontamhtion. Shoreham Dociet 50 322 0b3 (Emergeoey Planning), Apru 13,1987,

66. Testimony of Gregory C. Minor, Steven C ShoDy et. al. on tchalf of Suffolk County, regarding IR CO's Recendon Centen Plannine Bas, before the Atomic Safety and Ucendog Board, in the matter of Long Island Ughting Compacy, Sbotcham Nuden Power Station Unit 1, Docket No. 50 322 Ob3, .

April 13,1967.

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67. Rebuttal Testimony of Gregory C Minor and Steven C ShoDy on behalf of Suffolk County regarding Lil.CO's Raiglion Centers (Rebuttal to Testimony of Lewis G. Hulmant in the matter of Long Island

)

l Ughting Company, Shoreham Nudear Power Station, Unit 1, Docket No. 50 322 Ob3, May 27,1987. '

68. Dired Testimony of Dale G. Bridenbaugh tad Gregory C Minor or behalf of Mast.achusetts Attorney General, before the Federal Energy Regulatory Commissbrs regarding CanaLElectric Company Prudence Related to Seabrook Unit 2 Construction Enenditwng, Docket No. ER66 704 001, July 31, 1987.

69. Dired Tesdmony oi Dale G. Bridenbaugh and Gregory C Minor before the Pennsyh1tnia Public Utility Commission, Regarding kam Wilev Unit 11979 Outace. Docket No.179070318, OCA Statement No.

2, August 31,1987.

70. Oral testiroony of Gregory C Minor Before the Illinois Pollution Control Board on behalf of Reed-Custer Co:nmunity Unit School District No. 255 U, re: hdispod Cooline Eond Sepcmber 8,1988, Case PCB 87 209.

l 71. Testimony of Gregory C. Minor in the U. S. District Court, Brooklyn, New York, Sepember 31,1988, re: County of.luf[alk vs LILCO et al Case CV 87 646.

l 72. GE Reed Reoort Safety Inue Revien Issues 5,10, and 24, prep..ed by MHB Technier) Associates for l

The Oh!o State University Nuclear Engineering Program Expert Review Patel, Public Utility Commission of Ohio, October 1988.

73. Dired Tenimony and Exhibits of Dale G. Eridenbaugh, Gregory C. Minor and Steven C Sholly on Behalf of Massachusetts Deputaient of the Attorney General, Re: Pilgrim Nudear Power Station, j Investication of Pilcrim Outare. DPU 8& 28, November 30,1988, PROTECPED INFORMATION.

74 Supplemental Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of Ma.uachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station, Investication of Pilcrim Outare. DPU 8& 28, January 20,1989, Exhibit AG 2.

75. Testimony of Gregory C Minor, U. S. District Coert, Brooklyn, New York, February 3,1989, re: CotatY of.SufInlLis. LILCO et. mL Case 87 CIV. M6 (JBW).

76. Surrebuttal Testimony of Dale G. Bridenbaugh, Gregory C Minor and Steven C. Sholly on Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nudear Power Station,lovesticatiua of filgum.QulAgg, DPU 88 28, Februuy 13,1989, Exhibit AG 74.

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77. Surrebutal Testimony of Dale G. BrWembaush, Gregory C. Minor and Stews C. ShoDy os Behalf of Massachusetts Department of the Attorney Ocneral, Re: Pilgric Nuclear Power $tation, Smadption of i

! Paprim Outap. DPU alL28, Fehnary 17,1999, Esk%t AO 93.

78.

Hidary maA Perfor=== of Ww. Pattern MSIVs in Miina Water R*metart report prepared for Paul, Weiss, Rifkind, Wharton & Garrison by MH8 Technical Associatu, October 1999 i

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A T-T A C H M E N T - 2 Ststement of Professional Qualifications Steven C. Sholly .

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PROPRttlONAL OUAl rFICAT10NS OF STEVEN C.1HO11Y l

l STEVEN C. SHO11Y MHB Technical Associates 1723 Hamilton Avenue

! Suite K San Jose, California 95125 i (408) 266 2716

EXPERIENCE

! September 1985. PRESENT

. Aaaaelmee . MMB Taeknfral Ataaetatea tan jnaa. r'alirornla Ammaelate in energy consulting firm that spaetan -a in technical and *-Ir assessments of energy i

production facilities, especially nudear, for local, state, and federal governments and private l or alutta== MHB is emicasively levolwd in regulatory proceedings and the preparation of studies and reports. Conduct research, write reports, participate in discovery prooses in regulatory proceedings, dewlop testimoey and other documents for regulatory proceedings, and respond to client laquiries. -

Clients han included: State of California, State of New York, State of Illinois, commoeweakh of Massachusetts, and Commonwealth of Pennsylvania. l

, February le81. September 1985 Taehnical Ramaa ch Amaadase ==A Risk Analvar . U=taa of r'e==d O'=^L:n W 'an D.C.

i

, Reaearch associate and risk analyst for public interest group based in Cambridge, Massachusetts, that I specializes in esamining the impact of edunced technologies os society, principally in the areas of arms I control and energy. : Technical work focused on nuclear power pleet safety, with emphasis ce prahaP"le risk assessment, radiological emergency planales and preparada as, and generie safety issues. Coeducted research, prepared reports and studies, participated in admu.intratin proceedings before the U.S. Nuclear Regulatory Commission, dewloped testimony, analysed NRC rule. making '

proposals and draft reports and peepared comments thereon, and responded to inquiries from sponsors, the general public, and the media. Participated as a member of the Panel on ACRS Effectiwatas (1985), the Panel on Regulatory Uses of Probabilistic Risk Assessment (Peer Review of NUREG 1050; 1984), invited Obserwr to NRC Peer Renew meetings on the source term reassessment (BMI.2104; 19831984), and the ladependent Advisory Committec on Nuclear Risk for the Nuclear Risk Task Force .

i of the National Ansaciarios ollasurance Comaksioners (1984).

l p January 1980. January 1981 l Prelad Director and Raaa=*ch t'aardinator . Three Mile tala-A Puhl:e Interent Rman:a fgig[gg,

Harrisburg. Pennsylvania i

Provided adelaistratin direction and coordinated research projects for a public laterest group based in .

Harrisburg, Pennsylvania, centered around issues related to the Three Mile Island Nuclear Power Piant.

1 Prepared fundraising proposals, tracked progress of U.S. Nuclear Regulatory Commission, U.S.

Department of Energy, and General Public Utilities actMties concerning cleanup of Three Mile Island-Unit 2 and preparation for restart of Three Mile Island Unit 1, and monitored dowlopments related to

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$ V emergency planning, the financial health of General Public Utilities, and MtC rulemaling actions related to Three Mile Island.

Ju!y 1978. January 1980 Chief Bioloaical Proceu Ooerator Waggynter Treatment Plant Derry Towmhin Munidpal Authgd;y, He shev. Pennsyhunia Chief Biological Proccu Operator at a 2.5 million gallon per day tertiary, activated sludge, wastewater treatment plant. Responsible for biological proceu monitoring and control, induding analysis of physical, chemical, and biological test results, proceu Duld and mass flow managemet t, micro biological analpis of actlysted aludge, and maintenance of detailed procen logs for loput i.W state and federal reports on treatment process and etDuent quality. Received certification from the Commonwealth of Pennsylvania as a wastewater treatment plant operatot. Member of Water Pollution Control As.ociation of Pennsyhsnia, Centtal Section,1990.

July 1971 July 1978 Wastewater Trgatment Plant Ooerator . Borousth of Lejgpag,Jjempagfennsyhenh Wastewater trestratat plant operator at 2.0 million gallon per dav secondary, activated sludge, wanewater treatment plant. Performed tuks as .essigned by supervisors, inchding simpic physical and chemical tests on wastewater streams, maintenance and operation of plant equipment, and maistenance of the collection sptem.

September 19'6 June 1977

$dgnee Teacher . West Shore School District. Camo Hill Pennsyhanta Taught Earth and Space Science at ninth grade level. Developed and implemented new course rusterials on plate tedonics, environmental geology, and space science. Served as Asdstant Coach of the district gymnastics team.

September 1975 June 1976 Science Teacher Carlisle Area School District. Carlisle.P,gnnsvhania Taught Earth and Space Science and Environmenian Science at nL - s de level. Developed and irnplemented new course materials on plate tectonics, environmental Uslogy, noise pollution, water pollution, and energy. Served as Advisor to the Science Projects Club.

EDUCATION:

B.S., Education, majors in Earth and Space Science and General Science, minor in Endronmental Education, Shippensburg State College, Shippensburg, Penns)hsala,1975.

Graduate coursework in Land Use Planning, Shippensburg State College, Shippensburg, Pennsylvania, 1977 1978.

Short Course on Individual Plant Examinations, Massachusetts Institute of Technology, Cambridge, Manachusetts,1989.

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l PUBLICAT10NS-

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, 1. 'Determlalag Mercalli latensities from Newspaper Reports,' hrmal of C*ala-iral 8'A'"**laa Vol. 25, l 1977.

A Crittaue of: An Iadenad A ia**-ant of Evarumelam T--- far hree M11, t t==A Nuel ., Pawar

) 2.

flan 1, Three Mile !aland Public laterest Resource Center, Harrisburg, Pennsylvania, January 1M1,

! 3. A Brief Rd.n maA Crittaua of the Raelelm-A P, av a z'!.C =1 sr-- = e ?;== ' - - Pimm

! Union of Concerned Scientists, prepared for Rockland County Emergency Flamaing Forsommel and the Chairman of the County 1.egislature, Washington, D.C., August 17,1981.

l 4, ne d'*,* mal *v for a Pir m at 7.1'.!r Akria P===Milev la the P - 8= ==e Pathway EPZ at N+ =+ -! '

! Pawar Plas t Sitas. Union of Concerned Scientists, Critical Mass Energy Projem, Nuclear lafa saatica I and Resource Service, Environmental Action, and New York Public laterest Research Group,.

l Wasington, D.C., August 27,1981. *

$. ' Union of Concerned Scicatists, lac., Comments on Notice of Proposed Rulemaklag, Amendment to 10 l CFR 50, Appendia E, Season IV.D.3,* Union of Concerned Scientists, Waeleston, D.C., Ocsober 21, i j 1981.* ,

t i

6. 'The Evolution of Emergency Planalag Rules,' in The ladian Palat Bank: A Briefing as the Safaty j lavendgation at the ladian Point Nuclear Power Plants. Anne Witte, editor, Union of Coseermed Seise.

tists (Washington, D.C.) and New York Public laterest Research Group (New York, NY),1982.

[ l l 7. ' Union of Concerned Scientists Comments, Proposed Rule,10 CPR Part 30. Emergency Planning and i Propw:':::* Esercinas, Clarincation of Regulatlass,46 F.R. 61134,' Union of Concerned Scisatists, l Washington, D.C., January 15,1982.

• i ,

4 8. Tutimony of Robert D. Pollard and Steven C. S before the Subcosamittee os Ener8y and the ,

l Environment, Pa==lttee on laterior and lasular Aff U.S. House of Representatives, Middletown, j l Pennsylvania, March 29,1982, available from the Union of Concerned Scientists.

i

9. ' Union of Concerned Scientists Detailed Comments on Petition for Rulemaklag by Cithea's Task Force, i I

Emergency Planaios,10 CFR Paru $0 and 70, Docket No. PRM.5031,47 F.R.12639,' Union of Concerned Scientists, Washington, D.C., May 24,1982. 4 i

10. Supplements to the Testimony of Ellyn R. Weiss, Esq., General Counsel, Union of Concerned Sdentists, before the Subcommittee os Energy Conservation and Power, Committee on Energy and Commerce, U.S. House of Representatives, Union of Concerned Scientists, Washington, D.C., August 16,1982. . j 1

l 11. Testimony of Steven C. Sholly, Union of Concerned Scientists, Waeington, D.C., on behalf of the New York Public IMerest Research Group, lac., before the Special Committee on Nuclear Poser Safety t,f

! the Assembly of the State of New York, hearings on tagislative Oversight of the Emergency Radiologic j Preparedness Act, Chapter 708, Laws of 1981, September 2,1982.

i l 12. 'Cosaments on ' Draft Supplement to Final Environmental Statement Related to Construction and

! Operation of Chach River Breeder Reactor Plant',' Docket No. 50 537, Union of Concerned Scientists, l i

Washington, D.C., September 13,198?. _* -

13. ' Union of Concerned $ dentists Commenu on ' Report to the County Commissioners', by the Advisory

}

- Costalttee on Radiological Emergency Plan for Columbia County, Pennsylvania,' Union of Concerned

!- Scientists, Wadington, D.C., September 15,1982. j i

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' Radiological Emergency Manning for Nuclear Raamor Accidents,' pressated to Kormonergie Oatmantend Congrees, Rotterdam, ne Netherlands, Union of Concerned Seisatists, Washlagton, D.C.,

Odober 8,1982, 15.

' Nuclear Roamor Accident Consequences: Implications for Radiological Emergency Planalag,' I p.neated to the Citinen's Advisory Committee to Review Rocidaad Comary's Own Nuclear Evacuation med Preparedeen Man and General Disaster Preparedaeas Mr.n, Union of Concerned Soendata Waab.

lagton, D.C., November 19,1982.

16.

Tutimony of Stews C. Shouy before the Subcommittu on Overnight and legatigations, Coimmittee on laterior and lasular Affairs, US. Houac of Representatives, Washington, D.C., Union of Concerned Sci.

entists, December 13,1982. '

i 17.

Toadmony of Gordon R. nompaos and Steven C. Shouy on Commission Queados ho, Coateadoes 2.1(a) and 2.1(d), Union of Concerned Sciendats and New York Public laternet Research Group, before the US. Nucle >ar Regulatory Commisalon Atomic Safety and 1Joensing Board, it the Matter of Consolidated Edison Company of New York (ladian Point Unit 2) and the Power Authority of the State of New York (ladian Point Unit 3), Docket Nos. S247.SP and S286 SP, December 28,1932, '

18. a '

Tutimony of Steven C, Shouy on the Conseqwness of Accidents at ladian Point (Cos=66 Questlos One and Board Question 1.1, Union of Concerned Scientists and New York Public laterut Research Group, before the US. Nuclear Regulatory Comminaion Atonde Safety and IJeansing Board, in the Matter of Consolidated Edinos Company of New York (ladian Point Unit 2) and the Power Authority of the State of New York (ladian Point Unit 3), Docket Nos. S247.$P and 30 286.SP, February 7,1983, as l

corrected February 16,1983.

• 19.

Toadmony of Steven C. Sholly on Commianica Question Mvs, Valon of Concerned helata and New York Public interest Research Group, before the US. Nuclear Regulatory ('=ulaa6 Atomic Safety and ucendag Board, in the Matter of Consolidated Edinos Company of New York (ladian Point Unit 2) -

and the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos. S247.SP and S 286 SP, March 22,1983. '

20.

' Nuclear Renaor Accidents and Accident Conasquences: Planalag for the Worst,' Unlor. of Concerned ' I Scientists, Washington, D.C., presented at Critical Mass '83, March 26,1983.'

i 21.

Testimony of Steven C. Shouy on Emergency Planalag and Preparedness at Commercial Nuclear Power Plants, Union of Concerned Scientists, Washington, D.C., before the Subcommittu on Nuclear Regulath,a, Committee on Environment and Public Works, US. Senate, Apru 15,1983, (with ' Union of l

Concerned Scientists' Response to Questions for the Record from Senator Alan K. Simpsoa,' Steven C.

Shouy and Michael E. Fades), . .

22.

'PRA: What Can it RoaUy Teu Us About Public Risk from Nuclear Accidents?,' Union of' Concerned -

Scientists, Washington, D.C, presentation to the leth Annual Meeting, Scacoast Anti. Pollution league, -

May 4,1983, 23.

'Probabilistic Risk Assessment: The impad of Uncertalaties on Radiological Emergency Planning and Preparedness Considerations,' Union of Concerned bia-al=** Washington, D.C., June 28,1983, .

24.

'Ruponse to GAO Questions on NRC's Use of PRA,' Union of Concerned Scientists, Washington, l D.C., Oaober 6,1983, attachment to letter dated October 6,1983, from Steves C. Shouy to John E.

Bagnulo (GAO, Washington, D.C.).

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The Imnad of 'Ea'ernal Eventn* on Radioloniemi Emereenev Rnenw Plannine Coraiderationt Union of Concerned Scienthts, Wuhmgton, D.C., December 22,1963, attachment to letter dated December 22, i 1983, from Stewn C She'Jy to NRC Commluioner James K. Auchtine.

26.

SizeweU 'B' Public Inquiry, Proof of Evidence on: $dgmand Waste Mennaement imetication of the Kinwell PWR. Gordon Thompson, with supporting evidence by Steven ShoUy, on behalf of the Town l

and Country Planning Anodation, February 1984, induding Annes G, 'A review of Probabilhtic Risk ,

Analysh and its Application to the Sizewtu PWR,' Steven Shouy and Gordon nompson, (August 11, 1963), and Anner O,' Emergency Planning in the UK and the US: A Comparison.' Stewn Shouy and <

Gordon Thompson (October 24,1963),

27.

Testimony of Stenn C ShoUy on Emergency Planning Contention Number Eleven, Union of Concerned Scienthts, Wuhington, D.C., on behalf of the Palmetto Alliance and the Carolina Environmental Stud  ;

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Group, before the U.S. Nudear Regulatory Commiulon Atomic Safety aH Licer.aing Board, in the Matter of Dde Pcmr Company, et. al. (Catawba Nudear Station, Units 1 sti 2), Docket Nos. 50-413 and 50-414, April 16,1984, *

)

28. 'Rhk ladicatort Relevant to Aucuing Nudcar Accident Llability Premiums,' in Preliminary Reoort to the ir denendent Advisory Committee to the NAIC Nuclear Risk Task Fotgg, December 11,1984, Steven C. ShoUy, Union of Concerned Scientists, Washington, D.C 29.

' Union of Concerned Sdentists' and Nudear Information and Resource Service's Joint Comm NRCs Proposal to Bar from Licensing Procee41ings the Consideration of Earthquake Effects on Emergency Planning,' Union of Concerned Scienthis and Nudear Information and Resource Service,  !

Washington, D.C., Diane Curran and Ellyn R. Weiss (with input from Stewn C Shouy), February 28, 1985.*

30.

• Severe Accident Source Terms: A Presentation to the Comminioners on the Status of a R NRCs Source Terin Renautement Study by the Union of Concerned Scientists,' Union of Concerned Scientists, Washington, D.C., April 3,1985.

• 31.

' Severe Accident Source Terms for light Water Nudear Power Plants: A Presentation to the Illinois Department of Nudear Safety on the Status of a Review cf the NRCs Source Term Reauessmen (STRS) 13,1985.

by the Union of Concerned Scientists,' Union of Concerned Scienthts, Washington, D.C.,

i 32.

t The Source Term Debate: A Review of the Current Basis for Predictine Severe Accident Sou with Soccial Emohanit l on the NRC Source Term Reassessment Prorram (NUREG.0956). Union of Concerned Scienthts, Cambridge, Manachusetts, Stewn C. Shony and Gordon Thompson, January 1986.

33.

Direct Testimony of Dale G. Bridenbaugh, Gregory C Minor, Lynn K. Price, and Stewn C. Shouy on I

behalf of State of Connecticut Department of Public Utility Control, Prosecutorial Divklon and Divhion of Consumer Counsel, regarding the prudence of expenditures on Milhtoce Unit III, February 18,1986 ,

34, implications of the Chernobyl 4 Accident for Nuclear Emergency Planning for the State of New York, prepared for the State of New York Consumer Protection Board, by MMB Technical Anociates, June 1986.

! 35.

Review of Vermont Yankee Containment Safety Study and Anahsh of Containment Ventina lisues for i

the Vermont Yankee Nuclear Pmver Plant. prepared for New England Coalition on Nudear Pouution, loc., December 16,1986.

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36. Amdant of Steven C. Shouy before the Atomic Safety and Licensing Board, in the matter of Puttc Service Company of New Hampshire, et al., regarding Seabrook Station Units 1 and 2 Of6 site Emergency Planning luues, Dociet Nos. 50 443-OL & S444-Ot., J anuary 23,1967.

37, Direct Testimony of Richud B. Hubbud and Steven C. Sholly on behalf of California Public Utilities Comminion, regarding Diablo Canyon Rate Case, PG&E's Failure to Establkh its Committc<l Design OA Program, Application Nos. 84 04014 and 8548425, Exidbit No.10,935, March,1987,

38. Testimony of Gregory C. Minor, Stenn C. ShoUy et. al. on behalf of Suffolk County, regarding ilLCO's Reception Centen (Planning Basis), before tbc Atomic Safety and Licensing Board, in the matter of Long Idand Lighting Cepany, Shoreham Nuclear Power Station Unit 1 Dociet No. 50 322 OL 3, April 13,1987.

39. Rebuttal Testimony of Gregory C. Minor and steven C. Shouy on behalf of Suffolk County reguding LILCO's Reception Centers (Addrening Te4timony of Lewis G. Hulman), Docket No. 50 322 01 3, May 27,1987.

40. *Sciunic Events,' Presentation at Severe Accident Policy implementation (Lcternal Events Workshop, sponsored by U.S. Nuclear Regulatory Commisdon, August 4 5,1987 Annapolis, Maryland.

41. Review ei$thsttd Asoe(1s of NURI!G.1150. Reactor Rhk ReferinLDCmiment. prepared for the Illinois Deputment of Nuclear Safety by MHD Technical Associates, September 1967.

42. Direct Testimony of Richard B. Hubbard and Steven C Sholly on behalf of the Pennsylvania Omce of Consumer Advocate, before the Pennsylvania Public Utility Cornminion, Evaluation of Beaver Vauey Unit 2 Plant Costs, OCA Statement 6, Docket No. R 870651, Octoter 23,1987.

43. Egal Reoort- $lenificant Factors Affeettna the Cost of Beaver Vallev Power Station. Unit 1 prepued for Pennsylvania Omcc of Consumer Advocate, by MHD Technical Associatet, OCA Exhibit 6A, October 1987.

44 Surrebuttal Testimony of Richard B. Hubbard and Steven C. Shouy before the Pennrgvania Public Utility Commiulon, on tchalf of the Pennsylvania Omce of Consumer Advocate, regarding Evaluation of Pcaver Valley Unit 2 Plant Costs, OCA Statement 61, Docket No. R 870651, December 7,1987.

l 45. Testimony on Diablo Canyon Rate Case, Desien Quality Anutangg, Supplemental and Rebuttal Testimony of Richard B. Hubbard and Steven C. Sholly, on t< half of the California Public Utilities Commhsion, Division of Ratepayer Advocates, Application Nos. 64 06014 and 85 03425, Exhibit No.

16,690, September 1988.

46. Testimony on Diablo Canyon Rate Case, j';,ygindon.sipA Reoultanients add Their Understandinc By l'htSMghar Industry- Quality Assu11Dre As A Manacement Tool, Volumes I and 11. Supplemental and Rebuttal Testirnony of Richard B. Hubbard and Steven C. Sholly on behalf of the California Public Utilities Commusion, Divkion of Ratepayer Advocate, Application Nos. 8446 014 and 85 06 025, l Exhibit No.16,650, Septemter 1988.

47. GE Reed Report Safety issue Reviews, Issues 1,6, and 14, prepared by MHB Technical Auociates for The Ohio State University Nuclear Engineering Program Expert Revi:w Panel, Public Utility Commhsion of Ohio, October 1988.

l

48. Direct Testimony and Eshibits of Dale G. Bridenbaugh, Gregory C. Minor and Steven C, Sholly on Behalf of Manachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station, investigation of Pilgrim Outage, DPU 88 28, November 30,1988, PROTECTED INFORMATION.

h 'h

' 49. Supplemental Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Shony on Behalf of Manachusetts Department of the Attorney Genera Re: Pilgrim Nuclear Power Station,lovestigation of Pilgrim Outage, DPU 88 28, January 20,19W,1Mibit AG 1.

50. Surrebuttal Testimooy of Dale G. Bridenbau6h, Gregory C. Minor and Steven C. ShoUy on Behalf of Mauschusetts Department of the Attorne) Genera Re: Pilgrim Nudear Power Station,innstigation of Pilgrim Outage, DPU 88 28, February 13,1989. ExMbit AG.74.

31. Surrebuttal Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. ShoUy on Behalf of Manachusetts Department of Attorney Genera Re: Pilgrim Nudear Power Station, Investigation of Pilgrim Outage, DPU 88 28, February 17,1989, Exhibit AG 93.

$2. Final Report: Senre Accidents aL'are> Mile idand Unit it Severe Accidtat Charngristica . fat Radiotorical Emernency Reiponte Plan Deveicoment prepared for lastitute for Resourcs and Security Studies, February 1989.

$3. A Limited Scone Revie u of the Second Draft of NUREG 11$, prepared for the Illinois Department of Nuclear Safety, November 1989.

AWlable from the U.S. Nuclear Regulatory Commlulon, Public Document Rootn, Lotiby,1717 H Street, N.W., Wuhington, D.C.

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l Signed under the pains and pnalties of perjury this 1st dr.y of Decernber 1989,  !

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Gregory C. Mino'r i 4

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State of DUtE On this the day of JMC 19b bef ore me, 4 NM

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the undersigned Notary Publ!c, personally appeared j

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SANTA C'.AAA COUNTY A"

> W comm.Dwes sen 30.1993 within matrument, an3 acknowledged that executed it,

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UNITED STATES OF AMERICA UdfdjfU NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING APPEAL BOARD 14 MR 12 P3:53 Before Administrative Judges

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Alan S. Rosenthal, Chairman  ? "M j" Q ,, " El Thomas S. Moore Howard A. Wilber

)

In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL PUBLIC SERVICE COMPANY )

OF NEW HAMPSHIRE, EI AL. )

)

(Seabrook Station, Units 1 and 2) ) March 11, 1991

)

1 CERTIFICATE OF SERVICE I, Leslie Greer, hereby certify that on March 11, 1991, I i made service of the enclosed Reply to the Appeal Board order of February 22, 1991 by Federal Express as indicated by (*) and by i first class mail to Ivan W. Smith, Chairman Kenneth A. McCollom Atomic Safety & Licensing Board 1107 W. Knapp St.

U.S. Nuclear Regulatory Commission Stillwater, OK 74075 East West Towers Building 4350 East West Highway Sethesda, MD 20814 i

Dr. Richard F. Cole Robert R. Pierce, Esq.

Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Naclear Regulatory Commission U.S. Nuclear. Regulatory Commission East West Towers Building East West Towers Building 4350 East West Highway 4350. East West Highway Bethesda, MD 20014 Bethesda, MD 20814.

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5

• Docketing and Service

• Thomas G. Dignan, Jr.1/ '

O.S. Nuclear Regulatory Commission Ropes & Gray i Washington, DC 20555 One International Place Boston, MA 02110

• Elaine Chan Mitti A. Young, Esq. Philip Ahrens, Esq. i Edwin J. Reis, Esq. Assistant Attorney General .

U.S. Nuclear Regulatory Commission Department of the Attorney General Office of the General Counsel Augusta, ME 04333 31555 Rockville Pike, 15th Floor ,

Rockville, MD 20852 H. Joseph Flynn, Esq.

• Atomic Safety & "tcensing Asristant General Counsel Appeal Board Office of General Counsel U.S. Nuclear Regulatory Commission Federal Emergency Management Washington, DC 20555 Agency ,

500 C Street, S.W. i Washington, DC 20472 Robert A. Backus, Esq. Atomic Safety & Licensing Board  !

Backus, Meyer & Solomon U.S. Nuclear Regulatory Commission 116 Lowell Street Washington, DC 20555 P.O. Box 516 Manchester, NH 03106  ;

Jane Doughty Diane curran, Esq.

Seacoast Anti-Pollution League Harmon, curran & Townley Five Market Street Suite 430 Portsmouth, NH 03801 2001 S Street, N.W.

Washington, DC 20008 Barbara St. Andre, Esq. Judith Mizner, Esq.

Kopelman & Paige, P.C. 79 State Street 77 Franklin Street Second Floor Boston, MA 02110 Newburyport, MA 01950 Charles P. Graham, Esq. R. Scott Hill-Whilton, Esq.

[ Murphy & Graham Lagoulis, Hill-Whilton & Rotondi

! 33 Low Street 79 State Street

! Newburyport, MA 01950 Newburyport, MA 01950 l Ashod N. Amirian, Esq. Senator Gordon J. Humphrey I 145-South Main Street U.S. Senate P.O. Box 3B Washington, DC 20510 Bradford, MA 01835 (Attn: Tom Burack) '

Senator Gordon J. Humphrey John P. Arnold,. Attorney General One Eagle Square, Suite 507 Office of the Attorney General i Concord, NH 03301 25 Capitol Street (Attn: Herb Boynton) Concord, NH 03301 1/ Hand delivery was made on March 12, 1991 by 10:00 a.m. *

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I Paul McEachern, Esq. Michael sinclair Shaines & McEachern Graystone Emergency Mant.gement 25 Maplewood Avenue, Associates Portsmouth, NH 03801 13 Summer Street Hillsboro, NH 03224 G. Paul Bollwerk, Chairman

• Alan S. Rosenthal Atomic Safety & Licensing Atomic Safety & Licensing Appeal Board, 5th FL. Appeal Board, 5th PL.

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Bethesda, MD 20814 Bethesda, MD 20814

• Howard A. Wilber Jack Dolan Atomic Safety & Licensing rederal Emergency Management Agency Appoal Board, 5th FL. Region 1 U.S. Nuclear Regulatory Commission J.W. McCormack Post Of fice &

Bethesda, MD 20814 Courthouse Building, Room 442 Boston, MA 02109 George Iverson, Director

• Thomas S. Moore, Chairman N.H. Office of Emergency Management Atomic Safety & Licensing State House Office Park South Appeal Board 107 Pleasant Street U.S. Nuclear Regulatory Commission Concord, NH 03301 Washington, D.C. 10555 Respectfully submitted, SCOTT HARSHBARGER ATTORNEY GENERAL

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Leslie Greer Assistant ?.ttorney General Departmer t ol' the Attorney General one Ashbr.rton Place Boston, FA 02108 (617) 7?7-2200 Dated: March 11, 1991 3-

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