ML20076D058

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Response to Interrogatories & Request for Documents. Certificate of Svc Encl.Related Correspondence
ML20076D058
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 05/16/1983
From: Albrecht V
BEVERIDGE, FAIRBANKS & DIAMOND, LOUISA COUNTY, VA
To:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OLA-1, ISSUANCES-OLA-2, NUDOCS 8305200659
Download: ML20076D058 (18)
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CG)';yJI' S/16/83 UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION

. 83 tmY19 MI22 i

) t In the Matter of )

) .

VIRGINIA ELECTRIC AND POWER ) Docket Nos. 50-338/339 COMPANY ) OLA-1 and OLA-2

) '

(North Anna Power Station, )

4 Units 1 and 2) )

)

(Proposed Amendments to Oceratinc ) ,

i. License to Allow Receipt and Storage )

of 500 Spent Fuel Assemblies from ) t Surry Power Station, Units 1 and 2, )

l and Expansion of Spent Fuel Pool )

) Storage Capacity) ) >

l i

i RESPONSE OF LOUISA COUNTY TO NRC STAFF INTERROGATORIES AND REQUEST FOR DOCUMENTS Louisa County, by its undersigned attorneys, responds to NRC

! Staff's first discovery request as follows:

_I_nterrogatory 1-1.

a. Upon what person or persons do you rely to substantiate your case on contention no. IV. i
b. Provide the addresses and education and professional qualifications of any persons named in your. response to a. above.
c. Identify which of the above persons you intend to call y

^i as witnesses on this contention in this proceeding.

d. Identify which of those persons identified in c. above you anticipate will appear voluntarily and which-under subpoena.

, i bK 0 b 0 PDR 50

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i Response: l 1 -

j- . a. The County has not yet determined who will be called as  ;

a witness on its behalf to testify regarding the admitted  !

contentions. The witnesses may include Dale G. Bridenbaugh and .

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. other consultants, as well as Vepco and/or NRC Staff personnel j

{ and others whose identities cannot be determined until discovery }

is complete. i f

j b. A copy of Mr. Bridenbaugh's resume is provided at '

i  :

Attachment A. Similar information for other potential County l 1

! witnesses will be provided after they are identified. [

c. See response to Interrogatory 1-la.

? i j d. It is anticipated that Mr. Bridenbaugh will appear  ;

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4 voluntarily (as a County consultant) if requested. Other  ;

1 j potential witnesses may or may not.

! Interrogatory 1-2. Provide summaries of the views,  :

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j positions, or proposed testimony on contention no. IV of all I i'

I persons named in response to Interrogatory 1-1, that you intend l to present during this proceeding. I

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. Response: Until the witnesses to be called on the County's i

behalf are known, the County will be unable to provide their ,

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l views, positions, or proposed testimony. ,

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j Interrogatory 1-3. State all bases, calculations, and  ;

1 l j references used that you intend to use during-this proceeding to

! support the positions stated in response to Interrogatory 1-2. i l The foregoing should be supplied with respect to both Louisa 'l f

! County's direct presentation and to such evidence as Louisa i

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-County may attempt to adduce upon cross-examination of w.itnesses ,

presented by' the Applicann and/or NRC Staff.

Response See response to Interrogatory 1-2.

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Interrogatory 1-4. Identify all documentary or other material which you intend to of fer as exhibits on this contention in this proceeding.

Response: The County has not completed its investigation and discovery _ so cannot provide a definitive answer to this question. A partial, potential list is provided as Attachment B.  !

Interrogatory 2-1.

a.. Upon what person or persons do you rely to substantiate t your case on contention no. VI. F

b. Provide the addresses and educational and professional qualifications of any person named in your response to a. above.
c. Identify which of the above persons you intend to call _ ,

i as witnesses on this contention in this proceeding.

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d. Identify which of those persons identified in c. above you anticipate will appear voluntarily and which under subpoena.

Response

a. See response to Interrogatory 1-la. ,
b. See response to Interrogatory 1-lb.
c. See response to Interrogatory 1-Ic. l
d. See response to Interrogatory 1-ld.

Interrogatory 2-2. Provide summaries of the_ views, positions or proposed testimony on contention no. VI of all 4

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=m. y --y , e -- g -

persons named in response to Interrogatory 2-2 that you intend to present during this proceeding.

Response: See response to Interrogatory 1-2. Also, the County is aware that when the Zion and Dresden spent fuel pools

, were re-racked, the licensees were required to monitor the

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effects of Boraflex and report their findings to the Commission.

The County intends to use these reports to support Contention VI.

d Interrocatory 2-3. State all bases; -calculations, and l references used that you intend to use'during this proceeding to j

support the positions stated in response to Interrogatory 2-2.

t The foregoing should be supplied with respect to both Louisa County's direct presentation and to such evidence as Louisa County may attempt to edduce upon cross-examination of witnesses presented by the Applicant and/or the NRC Staff.

l Response: See response to Interrogatory 1-3. i

)

l Interrogatory 2-4. Identify all documentary or other .

material which you intend to offer as exhibits -on this contention .

in this proceeding.

t 4  ?

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Response The County has not completed its investigation and discovery so cannot provide a definitive answer to this question. A partial, potential list is provided as Attachment C.

Pursuant to 28 U.S.C. { 1746, I declare under penalty of perjury that the foregoing is true and correct.

i May 16, 1983 \ r((me g e-J. MarshadlColeman ,

Christopher H..Buckley, Jr.

Cynthia A. Lewis 1 Robert Brager Virginia S. Albrecht Beveridge & Diamond, P.C. .

1333 New Hampshire Avenue, NW Washington, DC 20036 (202) 828-0200 Attorneys for Intervenors Of Counsel:

8 Richard W. Arnold, Jr.

County Attorney PO Box 276 Louisa, VA 23093 (703) 967-1650 t t

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-Attachm7nt AI '

PROFESSIONAL QUALIFICATIONS OF 3ALF.,G. B RI DENB AUGH }

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%' . 5 DALE G.1B RIDENB AUGH  !

i c1723 Hamilton Avenue  :

i S u i t e' K '

s v x San' Jose, CA 95125  :

.[(408):'266-2716 a -

l

' E XP E RI E N C E :  !

i ,

1976 ,_PRESENT '

f \.

President - MHB Technical Associates, San Jose, California. '

4, _ ~Co-founder and partner of technical consulting-firm., Specialists-2' in energy consulting to governmental and other groups interested. l in evaluation of nuclear plant ~ safety and licensing. Consultant  ;

a ingthis capacity to state agencies in California, New Yo rk, Illi--

nois,: Jew Jersey, Pennsylvania, Oklahoma'and Minnesota and to the  ;

N o r u'e g i an Nuclear Power Committee, Swedish Nuclear Inspectorate,-  ;

, and various other' organizations and environmental groups. Per- .

formed extensive safety analysis for Swedish Energy Commission

. and contributed to the- Union o f Concerned S cientis t's Review of 7' W ASH-14 00.- Consultant to the U.S. NRC - LWR S af ety Improvement  ;

s Program, performed Cost Analysis of Spent Fuel Disposal for the~ ,

l Natural Resources Defense Council, and contributed to the' Depart- -

ment of Energy LWR Safety Improvement Program for Sandia Labora-

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tories. Served as expert witness in NRC and state' utility F

> commis sion hearings. -

1976.w. (FEBRUARY - AUGUS T) s Censultant, Project Survival, Palo Alto, California.

t Volunteer work on Nuclear Safeguards Initiative campaigns - in '

J Calif ornia, Oregon, W a s hin g t on , Arizona, and Colorado. Numerous v

-presentations'on nuclear. power and. alternative energy options ;to- '

civic, government, and college groups. . Also resource.p'erson for  ;

public service presentations.on radio and television. -[

r 1973 - 1976

[. .

l- Manager,- Perf ormance Evaluation and1 Improvement, General Electric  ;

L ' Company.- Nuclear Energy Division,-San Jose, California..  !

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. Managed':seventeenitechnical and seven clerical personnel with-responsib'ility.for establishment andfmanagement'of.. systems'to, -

monitor and measure. Boiling Water -Reactor equipment;and; system i operational performance. Integrated Geners* ElectricDresources'  !

inicustomeri plan t' modifications , coordinated l correct' ion . of icauses.

of forced outages-and of efforts to' improve; reliability,and;per-' ~

L ;formance of BWR. sys tems.. 1 f r r

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, ,e c'

1973 - 1976 ( Con t d) 1

. Responsible for development of . Division . Mas ter P erf ormance Improvement Plan as well as for numerous Staff special assign- ,

ments on long-range studies. Was on special assignment for the

, management of two different ad hoc proj ec ts formed to resolve unique technical problems.

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

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

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

Also in charge of refueling and service planning, perfor=ance analysis, and service connunication fun c t ion s supporting all co=-

pleted commercial nuclear power reactors supplied by General Electric, both domestic and overseas-(Spain, Germany, Italy, Japan,'

India, and Switzerland) .

1968 - 1972'  ;

Manager, Product Service, General Electric Company - Nuclear Energy.

Division, San Jose, California.

Managed sixteen technical and six clerical personnel with the r e s p on s ib ility for all customer contact, plann'ing and execution of work required after the customer acceptance of department-supplied plants and/or equipment. This included quotation, sale and delivery of spare and renewal parts. Sales volume of_ parts increased f rom $1,000,000 in 1968 to over $3,000,000 in 1972.

1966 - 1968 .

, Manager, Complaint and Warranty S ervic e , GenerL1 Electric Company -

Nuclear Energy Division, San Jose, California. 7 Managed group of six persons with the responsibility for customer contacts, planning and execution of work required after customer acceptance of department-supplied plants and/or equipment--both domestic and overseas. .

I 1963 - 1966 Field Engineering Supervisor, General Electric Company, Installation and Service Engineering Department, Los Angeles, California.

Supervised approximately eight field representatives with responsi-bility for General Electric steam and gas tu rbin e installation and main ten an c e work in Southern California, Arizona, and S outhern Nevada. During this period was responsible for the installation of eight different cen tral s tation stcam turbine generator units, plus much maintenance activity. Work included customer contact, prepa-ration of quotations, and contract negotiations.

1956 - 1963 9

Field En ginee r, General Electric Company, Installation and Service ,

Engineering Department, Chicago, Illinois.

Supervisad installation and maintenance of steam turbines of all si=es. Supervised crews of from ten to more than one hundred men, depending on the j ob. Worked primarily with large utilities but [

t had significant work with steel, petroleum and other process industries. Had four years of experience at construction, startup, trouble-shooting and refueling of the first large-scale commercial nuclear power unit. ,

1955 - 1956 Ig3 taaering Training P rogram, General E12ctric Conpany. Erie.

Fe.nsylvania, and Schenectedy, New York.

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

1953 - l'955' ,

United States Army - Ordnance S chool, Aberdeen, Maryland.

Instructor - Heavy Artillery Repair. Taught classroom and shop  :

disassembly of artillery pieces.

1953 En g in e e rin g Training Program, General Electric Company, Evendale, Ohio.

Training assignment with Aircraft Gas Turbine Department.

l EDUCATION & AFFILIATIONS:

BSME - 1953, S outh Dakota S chool of Mines and Technology, Rapid City, South Dakota, Upper k of class.

P rof es sional Nuclear Enginee r - Calif ornia. Certificate No. 0973.

Member - American Nuclear Society.

Various Company Training Courses during career - including P rof es-sional Busines s Management , Kepner Tregoe Decision Making, Effective Presentation, and numerous technical seminars.

HONORS & AWARDS:

Sigma Tau - Honorary Engineering Fraternity.

General Managers Award, General Electric Company.

PERSONAL DATA: .

Born November 20, 1931, Miller, South Dakota.

Married, three children ,

6'2", 190 lbs., health - excellent Honorable discharge from United S tates Army Hobbies: S kiiin g , hiking, work with Cub and Boy Scout Groups.

i PUBLICATIONS & TES TIMONY :

1. , Operating and Maintenance Experience, presented at Twelfth Annual Seminar f or Electric Utility Executives , Pebble 3each, California, October 1972, published in General Electric NEDC-10697, December 1972.
2. Maintenance and In-Service Inspection, presented at IAEA Symposium on Experience From Operating and Fueling of Nuclear Power Plan ts , B ridenbaugh , Lloyd & Turner, Vienna, Austria, October, 1973.
3. Operating and Maintenance Experience, presented at Thirteenth-

, Annual Seminar for Electric. Utility Executives, Pebble Beach, California, November, 1973, published in General Electric NEDO-20222, January. 1974.

4. Improving Plant Availability, presented at Thirteenth Annual '

S eminar f or Electric Utility Execu tives , Pebble Beach, Cali-fornia, November 1973, published in General- Electric NEDO-20222, January, 1974.

5. Application of Plant Outage Experience to Improve Plant Per-formance, Bridenbaugh and Burdsall, American Power Conference, Chicago, Illinois, April 14, 1974
6. Nuclear Valve Testing Cuts Cost, Time, Electrical World, October, 15, 1974.

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7. The Risks of Nuclear Power Reactors: A Review of-the NRC

-Reactor Safety Study WASH-1400, Kendall, Hubbard, Minor &

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

i S. Swedish Reac tor 'S rafoty Study: BarsebTck Risk Asseesment,-

MHB Technical Associates, January, 1978. (Published by the -

-Swedish Department of Industry as Document DsI-1978:1)

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

the Calif ornia S tate Assembly Committee on Resources, Land Use, and Energy, March 8, 1976.

10. Testimony of D.G. Bridenbaugh, R.B. Hubbard, and G.C. Minor before the United States Congress, Joint Committee on Atomic Energy, February 18, 197 6, Washin gton, DC (Publishe by the Union of Concerned S cientis ts , Cambridge, Massachusetts.).
11. Testimony by D.G. Bridenbaugh before the California'. Energy Commission, entitled, Initiation of Catastrophic Accidents at Diablo Canyon, Hearings on Emergency Planning, Avila .

Beach, California, November 4, 1976. .

12. Testimony by D.G. 3ridenbaugh before the U.S. Nuclear Regula- >

tory Co= mission, subject: Diablo Canyon Nuclear Plant Perfor-mance, Atomic S afety and Licensing Board Hearings, December, l 1976.

13. Tes timony by D.G. B ridenbaugh . bef ore the California Energy i Cennission, subject: Interi= Spent Fuel S torag e Considerations , ,

March 10, 1977.

14. Testimony by D.G. Bridenbaugh before the New York S tate Public Service Commission Siting Board Hearings concerning the James-port Nuclear Power S tation, subject: Effect of Technical and Safety Deficiencies on Nuclear Plant Cost and Reliability, '

April, 1977.

15. Tes timony by D.G. Bridenbaugh bef ore the Calif ornia S tate Energy Commission, subject: Decommissioning of Pres surized Water Reactors, Sundesert Nuclear Plant Hearings, June 9,  ;

1977. ,

Testimony by D.G. Bridenbaugh before the California' State

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Energy Commission, subject: Economic Relationships of.

Decommissioning, Sundesert Nuclear Plant, for the Natural'  ;

'Pesources Defense Council, July 15, 1977.

17. Testimony by D.G. Bridenbaugh bef ore the -Vermont S tate B oard.

of Health, subject: -3peration of Vermont Yankee Nuclear' Plan t '

and Its Impact on Public Health and Saf ety, October 6, 1977.-

18. Tes timony by D. G. B ridenbaugh bef ore ' the . U.S . Nuclear Regula-tory Commission, Atomic Safety and Licensing: Board, subject:

Deficiencies in Safety Evaluation of Non-Seismic Is sues , Lack-l of a Definitive Finding of Safety, Diablo Canyon Nuclear Units October 18, 1977, Avila Beach,7 California. -

19. Tactimony.by D.G. Bride..bcugh:before the-Norwegian Commission on 'luclecr. Power, subjects Renctor-Safety / Risk, October 26, 1977.

2 0. - Testimony by D.C. Bridenbaugh before the Louisiana State Legislature, Committee on Natural Resources, subject: Nuclear Power Plant Deficiencies Impacting on Safety & Reliability, Baton Rouge, Louisiana, February 13, 1978.

21. Spent Fuel Disposal Costs, report prepared by-D.G. Bridenbaugh'
for the Natural Resources Defense Council (NRDC), August 31, 1978.
22. Testimony by D.G. .Bridenbaugh, G.C. Minor, and R.B. Hubbard before the Atomic Safety and Licensing Board, in the. matter of the Black Fox Nuclear Power Station Construction-Permit Hearings, September 25, 1978, Tulsa, Oklahoma.
23. Testi=ony of D.C. Bridenbaugh and R.B. Hubbard before the Louisiana Public Service Commission, Nuclear Plant and ? ewer-Generation Costs, November 19, 1978, Baton Route, Louisiana.-

2 4 ., T,estimony by D.G. Bridenbaugh before the City Council and Electric Utility Commission of Austin,-Texas, Design, Con-struction, and Operating Experience of Nuclear Generating-Facilities, December 5, 1978 Austin, Texas.

25. Testimony by D.G. Bridenbaugh for the Co=monwealth;of Massachusetts, Department of Public Utilities, Impact of Unresolved Safety Issues, Generic Deficiencies, and Three Mile Island-Initiated Modifications on Power Generation Cost at the Proposed Pilgrim-2 Nuclear Plant, June 8, 1979.
26. Improving the-Safety of LWR Power Plants, MHB Technicalt Associates, prepared for U.S. Dept. of Energy, Sandia.

Laboratories, September 28, 1979.

27. SWR Pipe and Nozzle Cracks, MHB Technical Associates, for the Swedish Nuclear Power Inspectorate (SKI), October, 1979.
28. Uncertainty in Nuclear' Risk Assessment' Methodology. MHB Technical Associates, for the Swedish Nuclear Power InspectoratC (SKI), January,.1980.
29. Testimony of D.G. Bridenbaugh and G.C. Minor before the Atomic Safety and Licensing Board, in the. matter of Sacramento Municipal Utility District, Rancho-Seco_ Nuclear Generating Station following TMI-2 accident, subject:

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Opera to'r Tra ining and Human-Factors' Engineering,-for the' California Energy _ Commission, February-11, 1980.

30. Italian Reactor Safety Study:- Caorso Risk Assessment. MHB Technical Associa tes , for. Friends of the Earth, Italy, March ~, 1980.

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31. Decentamination of' Krypton-85 from Thron Mile Island' Nuclear Pinnt, H. Kendell, R. Pollard, & D.G. Bridenbaugh, et al,  ;

The Union of Concerned Scientists, delivered to-the Governor of Pennsylvania, May 15, 1980.

32. Testimony by D.G. Bridenbaugh before the New Jersey Board of <

Public Utilities, on behalf of New Jersey Public Advocate's '

Office, Division of Ra te Counsel, AnalysLs of 1979 Salem-1 Refueling Outage, August, 1980.

33. Minnesota Nuclear Plants Gaseous Emissions Study,-MHB Technical Associates, for Minnesota Pollution Control Agency, September, 1980. -

t 34 Position Statement. Proposed Rulemaking on the Storage and [

Disposal of Nuclear Waste, Joint Cross-Statement of Position i of-the New England Coalition on Nuclear Pollution and the Natural Resources Defense Council, September, 1980. ,

35. Testimony by D.G. Bridenbaugh and Gregory C. Misor, before the New York State Public Service Commission, In the. Matter of Long Island Lighting Company Temporary Rate Case, prepared for-the,Shoreham Opponents Coalition, September 22, 1980, Shoreham Nuclear Plant Construction Schedule.
36. Supplemental Testi=ony by D.G. Bridenbaugh before the New Jersey Board of Public Utilities, on behalf of New Jersey Public Advocate's Office, Divisio n of Rate Counsel, Analysis [

of 1979 Salem-1 Refueling Outage, December, 1980.

37. Testimony by D.G. Bridenbaugh and Gregory C. Minor, before the New Jersey Board of Public Utilities, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, Oyster Creek 1980 Refueling Outage Investigation, t February, 1981.
33. Economic Assessment: Ownership Interest in Palo Verde Nuclear e I

Station, MHB Technical Associates, for The City of Riverside, September 11, 1981.

39. Testimony of D.G. Bridenbaugh before the'Public Utilities '

Commission of Ohio, in the matter of-the Regulation of the i

Electric Fuel Component Contained Within the Rate Schedules of the Toledo Edison Company and Related Matters, subject:-

! Dcvis-Besse Nuclear-Power Station 1980-81 Outage Review, October, 1981.

40. Supplemental Testimony of D.G. Bridenbaugh before the Public >

Utilities Commission of Ohio, in the matter of the Regula tion of the Electric Fuel Component Contained-within the Rate Schedules of the Toledo Edison Company and Related Matters,.

subject: Davis-Besse Nuclear Power Station 1980-81 Outage Review,-

November, 1981.

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41. Systems Interaction and Single Failure Criterion, Phase 2 Report, MHB Technical Associates for the Swedish Nuclear.

Power Inspectorate (SKI)., January, 1982. ,

42. Testimony of D. G. Bridenbaugh and Gregory'C. Minor on ,

behalf of Governor Edmund G. Brown Jr.,;before the Atomic,  ;

Safety and Licensing 1 Board, regarding Contention 10, [

Pressurizer Heaters, January 11, 1982.

43. Testimony of. D. G. Bridenbaugh and Gregory C. Minor on behalf I of Governor'Edmund"G. Brown Jr., before theLAtomic Safety. ,

I and Licensing Board, regarding Contention 12,' Block and Pilot Operated Relief Valves, January 11, 1982.

44. Testimony of_D. G. Bridenbaugh before the Commonwealth-of  ;

Massachusetts, Department of Public Utilities, on behalf-

  • of the Massachusetts Attorney General, Pilgric Nuclear Power Station, 1981-82 Outage Investigation, March 11, 1982.
45. Testimony of D. G. Bridenbaugh before the Pennsylvania Public . Utility. Commission,oon behalf of the_ Pennsylvania Office of Consumer Advocate, Beaver Valley Outage, ,

March, 1982. -

46. Interin testimony of D. G. Bridenbaugh.before the? Illinois Commerce Commission, on behalf of the Illinois Attorney ,

General's Office, Expected-Lifetimes and Performance of ,

Nuclear Power Plants, March, 1982. l

47. Testimony of D. G. Bridenbaugh and G. C.= Minor before the .

Atomic Safety and Licensing Board, on behalf of-Suffolk [

County, in the matter of Long Island Lighting Company, >

Shoreham Nuclear Power Station, Unit 1,,regarding Suffolk i County Contention 11, Passive Mechanical Valve Failures, April 13, 1982.

48. Testimony of D. G. Bridenbaugh and R. B. Hubbard, in the Matter of Jersey-Central-Power and Light Company For An Increase in Rates for Electrical Service, on behalf of i New Jersey Department of the Public Advocate, Div ision of Rate Counsel, Three Mile-Island Units 1-& 2, Cleanup and Modification Programs, May, 1982.
49. Testimony of D. G. Bridenbaugh and G. C. Minor on-b'ehalf of Suffolk County, before the Atomic' Safety and Licensing Board, in the matter of Long Island-Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding: Suf folk ~

County Contention 22, SRV Test Program, May 25, 1982.

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50. Testimony of D. G. Bridenbaugh and G. C.' Minor on behalf 4 of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, l Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 2 8 (a ) (vi) and SOC Contention 7A(6),- ,

Reduction of SRV Challenges, June 14, 1982.-

51. Testimony of D. G.'Bridenbaugh.before the Illinois Com=erce Commission, on behalf of the Illinois Attorney General's 3

Office, Expected Lifetimes and Performance of Nuclear Power Plants, June 18, 1982.

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r Attachment B i t l

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1. Safety Evaluation by the Office =of Nuclear Reactor.

Regulation Relating to Modification of the Spent Fuel ~ '

Storage Racks. Facility Operating License No. NPF-4. ,

Virginia Electric and Power Co., North Juuna Power Station ,

Units 1 and 2. Docket No. 50-338 and 50-339. January 29, 1979.. ,

2. Environmental Impact Appraisal by the Of fice of Nuclear  ;

Reactor Regulation-Relating to the Modification of the Spent Fuel Pool. Facility Cperating Licensa DPR-39 and DPR-45. ,

Zion Nuclear Power Station Units 1 and 2. Docket No. 50-295.  :

and 50-304. March 29, 1979.  !

3. Environmental Imoact Anoraisal bv the Office of Nuclear' >

Reactor Regulation Relating to the Modification of-the Spent f Fuel Pool. Salem Nuclear Generating Station Unit 1. Docket t 50-272. t

4. Safety Evaluation by the Office of Nuclear Reactor

, Regulation Relating to the Modification of the Spent Fuel Storage Pool. Salem Nuclear Generating Station Unit No.

1. Docket No. 50-272.

j 5. Safety Evaluation Report for North Anna Power Station . Units 1 and 2 and documents referenced therein.  !

6. Final Safety Analysis Report for North Anna Power Station Units 1 and 2 and documents referenced therein. r
7. Occupational Radiation Exposure at Commercial Nuclea'r Power Reactors. 1980. NUREG-0713, Vol. 2. ,

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8. Amendment to Operating Licensea SPF-4 and NPF-4, August 20, 'l 1982 (and Attachments).  ;

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l. Spent Fuel Storage A Summary of Information in -Support of  ;

Increasing the Spent Fuel Storage Capacity-at North Anna Power Station Units 1 and 2. Virginia Electric and Power j Co. August 1982.

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2. Summary of Information in Support of the Storage of Surry -  :

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Spent Fuel at North Anna Power Station Unit Nos. 1 and 2.  ;

Virginia Electric and Power Co. July 1982.

3. NRC Of fice of Inspection and Enforcement. IE Bulletin No.

79-26. November 20, 1979. " Boron Loss from BWR Control  !

Blades." -

4. An Evaluation of Potential Chemical / Mechanical Degredation i Processes Af fecting Fuel and Structural Materials Under l Lo ng-Te rm Wa te r S to rage . G. E. Zima. Batelle. May 1979.

NUREG/CR-0668. PNL-2379.

l S. Safety Evaluation by Office of Nuclear Reactor Regulation Relating to the Modification of the Spent Fuel Storage ,

Pool. Salem Nuclear Generating Station Unit No. 1. Docket ,

. No. 50-272.

6. Safety Evaluation Report for North Anna Power Station Units  ;

1 and 2 and documents referenced therein.  ;

7. Final Safety Analysis Report for North Anna Power Station  ;

Units 1 and 2 and documents referenced therein.  :

8. J. R. Weeks, Corrosion of Materials in Spent Fuel Storage Pools, Brookhaven National Laboratories, BNL-NUREG 23021 (July 1977).  :!
9. J. R. Weeks, Corrosion Considerations in the Use of-Boral in Spent Fuel Storage Racks, Brookhaven Na tional Laboratories,
  • BNL-NUREG 25582 (January 1979).

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CERTIFICATE OF SERVICE ,

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.I hereby certify 'that I have this day ' served the foregoing - i

$ Response of Louisa. County to NRC Staff Interrogatories and i ,

Request For Documents upon each of the persons nmned below by j l 4

i depositing a copy in the United States mail,' properly stamped and [

addressed to him at the address set out with his name:

Secretarv -

i U.S. Nuclear Regulatory Commission

! Washington, D.C. 20555 _

i l

Attention: Chief, Docketing and Service Secticn ,

I .

3 Sheldon J. Wolfe, Chairman  !

Atomic Safety and Licensing Board Panel  !
U.S. Nuclear Regulatory Commission  !

I Washington, D.C. 20555 i t i Dr. Jerry Kline  ;

] Atomic Safety and Licensing Board ,

U.S. Nuclear Regulatory Commission

! l j Washington, D.C. 20555  ;

< i j Dr. George A. Ferguson I

School of Engineering 7
Howard University  ;

i 2300 5th Street, N.W. i

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l Washington, D.C. 20059 4

Henry J. McGurren, Esquire U.S. Nuclear Regulatory Commission j Washington, D.C. 20555 i James B. Dougherty, Esq.

3045 Porter Street, N.W. j

Washington, D.C. 20008 1  ;

$ Atomic Safety and Licensing Board i U.S. Nuclear Regulatory Commission  !

Washington, D.C. 20555 l 4

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! Michael W. Maupin:

Hunton & Williams P.O. Box 1535 Richmond, VA' 23212 May 16, 1983

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