ML20140B223
| ML20140B223 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/11/1981 |
| From: | Bridenbaugh D, Hubbard R CALIFORNIA, STATE OF |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8109140105 | |
| Download: ML20140B223 (18) | |
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- 00vrm UNITED STATES OF AMERICA 2j SEP 101981 * ;-
NUCLEAR REGULATORY COMMISSION Ut CIn erce ne d ry
- k; & &,:ce BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARb' D*'
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In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY
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Docket Nos. 50-275 0.L.
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50-323 (Diablo Canyon Nuclear Power
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Plant, Unit Nos. 1 and 2)
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AFFIDAVIT OF DALE G. BRIDENBAUGH g
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AND RICHARD B. HUBBARD g
\\O BRIDENBAUGH and RICHARD B. HUBBARD, being cgj.7fy 9
DALE G.
duly sworn, state under oath as follows:
l 1.
In preparing this affidavit, affiant Richard 5.
Hubbard reviewed PG5E's proposed special low power test pro-gram as set forth in the low power license application and as further described in PGSE's safety analysis report provided to the NRC Staff on February 6, 1981.
He also attended, as a consultant to Governor Brown's counsel, all sessions of the recent low power test proceedings which were held in San Luis Obispo from May 19 to May 22, 1981.
Thus, he is familiar with the duration of the lou power tests as postulated by PG5E and Staff witnesses.
Further, he has reviewed the actual schedule for fuel loading, initial criticality and ::ero power testing, and low power testing of large Ph'R's which have occurred in the S
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. 8109140105 810811 PDR ADOCK 05000275 G
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post-TMI period, particularly North Anna-2, Salem-2, and Se-quoyah-1.
In addition, on July 10, 1981, Hubbard accompan-c ied Commissioner Gilinsky on his tour of the Diablo Canyon facility.
A recent statement of Hubbard's professional qualifications and experience is set forth in' Exhibit 16 of
" Opposition of Governor Edmund G. Brown, Jr. to the NRC Staff and Pacific Gas and Electric Company Motions for Reconsidera-tion and Summary Disposition," dated April 24, 1981.
2.
Affiant Dale G. Bridenbaugh is a Professional Nu-clear Engineer, technien1 consultant, co-founder and president of ?!HB Technical Associates, technical consultants on energy 4
j and environment, with offices at 1723 Hami3 ton Avenue, Suite X, San Jose, California.
He has participated as an expert witness l
in licensing proceedings before the U.S. Nuclear Regulatory l
Commission (NRC); has served as a consultant to the NRC; has J
testified at the request of the Advisory Committee on Reactor i
Safeguards; has appeared before various committees of the U.S.
i Congress and testified in various state licensing and regulatory 1-proceedings.
Additional details of Bridenbaugh's experience l
and qualifications are set forth in Attachment A, which is at-t b
tached hereto.
3.
The purpose bf this affidavit is twofold:
First, to I
estimate the elapsed time which is likely to be required after issuance of a low power cperating license to load fuel and to i
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complete the special low power tests at or below 5% of Rated Thermal Power as Pacific Gas and Electric Company has proposed for Diablo Canyon Unit 1; second, to identify the technical difficulties and increased costs associated with modifying the structures, sy;tems, and components of the plant should further modifications be required after fuel has been loaded and operation commenced.
The results of our review are sum-marized in the following paragraphs.
4 During Commissioner Gilinsky's tour of the Diablo Canyon facility, both NRC and PB6E personnel emphasized PG6E's readiness to load fuel.
The necessary fuel is presently onsite in a building immediately adjacent to the Containment Building.
Further, due to the duration of the licensing process, PG6E has had sufficient time to conduct, and in some cases reconduct, its pre-operational tests as set forth in Section 14.1 of the Finai Safety Analysis Report.
Thus, we conclude that Diablo Canyon Unit 1 equipment is in an advanced state of readiness to load fuel, and that virtually all preliminary testing (see FSAR Table 14.1-1) possible prior to fuel loading has been completed. /
Further, we conclude that PG6E should be able to promptly load fuel once such authorization is received from the NRC.
5.
We estimate'that the fuel loading task should be com-pleted in Icss than one week elapsed time.
For example, at
-*/
A recent Nucleonics Week article indicates that all steps prior to fuel load will be completed by approximately August 12, 1981 (p.
4, Nucleonics Week, July 23, 1981).
In general, all pre-operational testing will be completed before fuel loading (FSAR, p. 14.1-8).
r Salem-2, a Westinghouse-designed PWR similar in design and rat-ing to Diablo Canyon, fuel loading began on May 23,1980 and was completed on May 27, 1980.
More specifically, a PG6E spokesman recently estimated that preparation and fuel loading of Diablo Canyon Unit I could be completed in about one month af ter issuance of a low power license (see July IS, 1981 ar-ticle from the San Francisco Chronicle, which is attached here-to as Attachment B).
Therefore, we conclude that it is reason-l able to expect that fuel leading of Diablo Canyon could be com-j pleted in one to two weeks and certainly no more than 30 days after the issuance of a low power test license. /
6.
The next phase of star up and testing includes initial criticality and low power testing.
FSAR Table 14.1-2 summar-i es the normal tests which will be performed.
In addition, the scope and duration of the special low power tests were des-cribed in detail during the recent low power proceedings in San l
Luid Obispo.
The Board, in the partial Initial Decision dated j
l July 17, 1981, noted at page 24, paragraph 61, that eCSE has i
proposed a series of eight special low power tests.
The propos-ed tests would probably last for no more than one month and in 1
actuality, as cited by the Board, would perhaps take only about j
eighteen days (Tr. 10',726-10,728).
Other references to the "re-latively few days" encompassed by the proposed low power test 1
- /
It has been reported that PG6E expects fuel loading to take no longer than two weeks (p.
4, Nucleonics Week, July 23, 1981). '1
program are set forth in the recent decision by the Board at page 25 (paragraph 65), page 32 (paragraph 82), ard page 33 (paragraph 83).
Therefore, we believe that it is reasonable to expect that, absent maj or problems, initial criticality and low power testing can be conducted in an elapsed time of less than 30 days.
Thus, assur.ing a 30-day period to complete fuel loading (whith we believe to be very conservative), the entire fuel load and testing program can easily be completed in no more than 60 days.
7.
The reasonableness of a 60-day cycle from license
.o-to completion of the special low power tests was further suance confirmed during Commissioner Gilinsky's tour of the Diablo Can-yon facility.
In response to a question, the Diablo Canyon Plant Manager, Robert C. Thorn terry, stated in Hubbard's pre-sence that PGSE's current schedules forecast tnat fuel loading,
- ero power testing, and the special low power test program will be completed approximately 58 days after receipt of a low power license.
Mr. Thornberry added that the schedule might need to be increased if major unanticipated problems were encountered during the test program.
8.
In order to be conservative, we believe it may be ap-propriate to add 15 to 30 days to the fuel loading and low pow-er testing schedule to allow time for resolution of any routine unanticipated events.
In reaching the preceding conclusions, __
i i
we have assumed a routine startup during which no major acci-dent, such as a seismically induced LOCA, occurs.
Thus, we are not stating any conclusion on either the risk potential during low power testing or the probability of accidents oc-curring curing such testing.
Our sole purpose is to express the view that absent unforseen events, the PGSE startup and low power testing program should require no more than 30 days i
i to complete after fuel is loaded.
9.
The post-TMI experience and the current schedules for o
startup testing lend further support to the preceding conclu-l sions.
The first plant granted an operating license in the l
post-TMI period was Sequoyah-1, which received a low power i
license on February 29, 1980.
Fuel loading conmenced on March 2, 1980 and was completed on March 8, 1980.
Two major prob-lems thereafter seriously delayed the initial criticality of Sequoyah-1.
First, in response to ISE Bull. 79-14, TVA re-quired approximately 60 days to inspect and rework pipe hangers and supports.
Second, in parallel with the hanger reinspection, i
}
TVA conducted a base line inspection of the turbine blades.
The turbine reinspection required 4-5 weeks of elapsed time.
Routine maintenance problems and pre-operational testing re-sulted in further dela'ys.
Initial criticality was achieved on July 5, 1980.
Following zero power testing, the special low power testing program began on July 12 and was completed on i I 4
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July 18, 1980, 10.
The second plant to receive a post-TMI license to load fuel and conduct special low power tests was North Anna-2.
l l
The authorization to load fuel was issued on April 11, 1980 and the low power testing was completed by July 1, 1980, an elapsed time of less than 80 days.
The Salem-2 low power li-J cense was issued on April 18, 1980.
As set forth in paragraph 5, fuel loading was completed on May 27, 1980.
Initial cri-ticality was achieved on August 2, 1980 and the special low power test program was completed on August 29, 1980.
The two months delay between fuel loading and initial criticality was i
l ltrgely due to the need to conduct routine pre-operational j
maintenance testing and surveillance testing (such as valve I
operability) which could have been accomplished prior to fuel load.
As presented in paragraph 4, we believe that these pre-operate;nal tests will be accomplished at Diablo Canyon prior l
to mid-August, 1981.
Thus, we conclude that the actual dura-tion of the Salem-2, North Anna-2, and Sequoyah-1 fuel loading and low power testing programs is not inconsistent with our conclusions for Diablo Canyon as set forth herein.
11.
Table I of the testimony of Applicant's witness, Dr. Brunot, in the low power test proceedings sets forth the fission product inventories which will be produced in the core For during the proposed Diablo Canyon Ic. power test program.. _ _ _ _,
___,, _. -. ~. _ _ _. _ _, _ _ _ _ -. _, -. _
example, the inventory of iodine-131, one of the radionuclides which is a significant contributor to the dominant exposure 1
modes for accidents requiring off-site emerge:,cy preparedness, 4
is estimated by Dr. Brunot as 4,500,000 curies (approximately 1/20th the full power value as set forth in FSAR Table 11.1-4).
In contrast, for the design basis LOCA addressed by the Appli-cant in the FSAR for full power operation, only 192 curies of i
iodine-131 were postulated to be released to the environment in the first two hours (FSAR Table 15.5-12).
Therefore, be-cause of the relatively rapid buildup (half-life of hours to days) of the radioactive isotopes listed in Table 3 of NUREG-
- /
i 0654 which dominate prompt health consequences resulting from postulated accidental releases, we conclude that even at 5%
i power the fission products available for release pose a sig-nificant potential hazard.
12.
Operation at low power will not only cause a buildup of fission products within the reactor core, making it inac-cessible for contact repair and/or modification but will also cause a spread of radioactive contaminants thror,hout the pri-mary portion of the steam supply system.
It will also contam-inate certain auxiliary systems such as the Chemical and Volume Control System, Equipment and Floor Drainage Systems, and the J
Liquid Radioactive Waste System.
If fuel failures and/or steam generator tube failures or leaks are experienced, a large number
-*/
NUREG-0654, Rev. 1 (FEMA-REP-1), " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Pre-paredness in Support of Nuclear Power Plants," November, 19R0. I i
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of oaher systems, including the turbine, condensate, and other I
components within the Steam and Pcwer Conversion System could become contaminated.
Contamination and irradiation of such equipment greatly increases the care required and the time and cost of future modifications that could be require; on.-
plant.
It is, therefore, important that power operation, in-cluding low power testing, not be permitted 1:ntil rev2ews and d
evaluations that could lead to required plant modifications have been completed.
13.
Based on the foregoing, we conclude that fuel loading, initial criticality, and lov power testing, including the spe-cial low power tests, can be accomplished at Diablo Canyon Unit I within approximately 60 days, with an outside maximum elapsed time of approximately 90 days, after issuance of the low power operating license.
h'e further conclude that the fuel loading portion of the startup schedule should be completed within less than 30 days following issuance of the low power license.
Final-ly, we conclude that operation at low power will contaminate some of the facility's components and systems.
This unnecessary com-l mitment of resources creates technical difficulties and increased J
costs associated with modifying the reactor, should further modi-fication be required 'after fuel has been loaded and power opera-tion commenced.
i
-9
I have read the foregoing and swear that it is true and accurate to the best of my Faowledge.
MM DALE G. BRIDENBAUGH
/
hd RICHARD B. HUBBARD Subscribed and sworn to before me this 8
day of August, 1981.
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g' OFFICIAL SEAL
/MiifD CARLO F. CARALu Notary Public
- T[,7El Notar, Puenc Cahfornia
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s"aE"c'iara $lun" My commission expires: /d/6/8g
,_,_,_,_,_ _g My commission encires Oct. 5,1984 3
I
AMXCHMENT A
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PROFESSIONAL QUALIFICATIONS OF DALE C.
B RI DENB AUGH DALE G.
B RI DENB AUGH 1723 Hamilton Avenue Suite Y.
San Jose, CA 95125 (408) 266-2716 EXPE RIENCE :
1976 - PRESENT President - MHB Technical Associates, San Jose, California.
Co-founder and partner of technical consult in g firm.
Specialists in energy consulting te governmental and other groups interested in evaluation of nuclear plant safety and licensing.
Consultant in this capacity to state agencies in California, New York, Illi-nois, New Jersey, Pennsylvania, Oklahoma and Minnesota and to the Norwegian Nuclear Power Committee, Swedish Nuclear Inspectorate, and various other organizations and environmental groups.
Per-formed extensive safety analysis for Swedish Energy Commission and contributed to the Union of Concerned S cientis t's Review of W AS H-14 00.
Consultant to the U.S.
NRC - LWR Saf ety Improvement Program, performed Cost Analysis of Spent Fuel Disposal for the Natural Resources Defense Council, and contributed to the Depart-ment of Energy LWR S af e ty Improvement Program for Sandia Labora-tories.
Served as expert witness in NRC and state utility commission hearings.
1976 - ( FEB RUA RY - AUGUS T)
Consultant, Project Survival, Palo Alto, California.
Volunteer work on Nuclear Saf eguards Initiative campaigns in California, Oregon, W a s h in g t on, Arizona, and Colorado.
Numerous presentations on nuclear power and alternative energy options to civic, government, and college groups.
Also resource person for public service presentations on radio and television.
1973 - 1976 Manager, Perf ormance Evaluation and Imptovement, General Electric Company - Nuclear Energy Division, San Jose, California.
Managed seventeen technical and seven clerical personnel with responsibility for establishment and management of systems to monitor and measure Boiling Water Reactor equipment and system operational performance.
Integrated General Electric resources in customer plant modifications, coordinated correction of causes of forced outages and of efforts to improve reliability and per-formance of BWR systems.
1973 - 1976 ( C on t d)
Responsible for development of Division Mas ter Perf 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 projectc formed to resolve unique technical problems.
1972 - 1973 Manager, Product Service, Gener,1 Electric Company - Nuclear Energy Division, San Jose, California.
Managed group of twenty-one technical and four clerical personnel.
Prime responsibility was to direct interface and liaison personnel involved in corrective actions required under contract warranties.
Also in charge of refueling and service planning, performance analysis, and service communication functions supporting all com-pleted commercial nuclear power reactors supplied by General Electric, both domestic and overseas (Spain, Germany, Italy, Japan, India, and Switzerland).
1968 - 1972 Manager, ?roduct Service, General Electric Company - Nuclear Energy Divis ion, San Jose, California.
Managed sixteen technical and six clerical personnel with the re s p on s ib ility for all customer contact, planning and execution of work required after the customer acceptance of department-supplied plan ts and/or equipmen t.
This included quotation, sale and delivery of spare and renewal parts.
Sales volume of parts increased from $1,000,000 in 1968 to over $3,000,000 in 1971.
1966 - 1968 Manager, Complaint and Warran ty Service, General Electric Company -
Nuclear Energy Division, San Jose, California.
Managed group of six persons with the responsibility for customer contacts, planning and execution of work required after customer acceptance of department-supplied plants and/or equipment--both domestic and overseas.
1966 1963 Field Eng inee ring S upe rvis o r, General Electric Company, Installation and Service En g in e e rin g Department, Los Angeles, California.
Supervised approximately eight field representatives with responsi-bility f or General Electric steam and gas turbine installation and main tenance work in Southern California, Arizona, and Southern Nevada.
During this period was responsible for the installation of eight different cen tral s tation steam turb ine generator units, plus much maintenance activity.
Work included customer contact, prepa-ration of quotations, and contract negotiations. _
1956 - 1963 Field Enginee r, Gene ral Electric Company, Installation and Service Engineering Department, Chicago, Illinois.
Supervised installation and maintenance of steam turbines of all sizes.
Supervised crews of from ten to more than one hundred men, depending on the j ob.
Worked primarily with large utilities but had significant work with steel, petroleum and other process industries.
Had four years of experience at construction, startup, trouble-shooting and refueling of the first large-scale commercial nuclear power unit.
1955 - 1956 Engineering Training Program, General Electric Company, Erie, Pennsylvania, and Schenectady, New York.
Training assignments in plant facilities design and in steam tu rbin e testing at two General Electric Factory locations.
1953 - 1955 Ordnance School, Aberdeen. Maryland.
United S tates Army 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, Evandale, Ohio.
Training assignment with Aircraft Gas Turbine Department.
EDUCATION & AFFILI ATIONS :
BS ME - 1953, South Dakota S chool of Mines and Technology, Rapid City, South Dakota, Upper k of class.
P rof es sional Nuclear Enginee r - California.
Certificate No. 0973.
Member - American Nuclear Society.
Various Company Training Courses during career including Profes-sional Busine s s Management, Kepner Tregoe Decision Making, Effective Presentation, and numerous technical seminars. _
4 HONORS & AWARDS:
Sigma Tau - Honorary Engineering Frat'ernity.
General Managers Award, General Electric Company.
PERS ONAL DATA:
Born November 20, 1931, Miller, South Dakota.
Married, three children 6'2",
190 lbs., health - excellent Honorable discharge from United States Army Hobbies:
S kilin g, hiking, work with Cub and Boy Scout Groups.
PUBLICATIONS & TES TIMONY :
1.
Operating and Maintenance Experience, presented st Twelfth Annual Seminar f or Electric Utility Executives, Pebble Beach, California, October 1972, published in General Electric NEDC-10697, December 1972.
2.
Maintenance and In-Service Inspection, presented at IAEA Symposium on Experience From Operating and Fueling of Nuclear Power Plan ts, Bridenbaugh, Lloyd & Turner, Vienna, Austria, October, 1973.
3.
Operating and Main tenanc e Exp e rien ce, presented at Thirteenth Annual Seminar for Electri Utility Executives, Pebble Beach, California, November, 1973, published in General Electric NED0-20222, January. 1974 4
_I_m p r o v in g Plant Availability, presented at Thirteenth Annual Seminar for Electric Utility Executives, Pebble Beach, Cali-fornia, November 1973, published in General Electric NEDO-20222, January, 1974 5.
Application of Plant Outage Experience to Improve Plant Per-formance, Bridenbaugh and Burdsall, American Power Conference, Chicago, Illinois, April 14, 1974 6.
Nuclear Valve Testing Cuts Cost, Time, Electrical World, October, 15, 1974.
7.
The Risks of Nuclear Power Reactors:
A Review of the NRC Reactor S af ety Study WASH-1400, Kendall, Hubbard, Minor &
Bridenbaugh, et al, for the Union of Concerned S cientists,
August, 1977. i
8.
Swedish Reactor Safety Study:
BarsebWek Risk As sessment, HHB Technical Associates, January, 19/6.
(Published by the Swedish Department of Industry as Document Ds1 1978:1) 9.
Testisony 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, 1976, W a s hin g t on, DC (Published by the Union of Conc erned 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. Bridenbaugh before the U.S. Nuclear Regula-tory Commission, subj ec t : Diablo Canyon Nuclear Plant Perfor-mance, Atomic S af ety and Licensing Board Hearings, December, i
1976.
13.
Testimony by D.G. Bridenbaugh before the California Energy Commission, subject: Interim Spent Fuel S torage Considerations, March 10, 1977.
14.
Testimony by D.G. 3ridenbaugh before the New York S tate Public Service Commission Siting Board Hearings concerning the James-port Nuclear Power S tation, subject: Effect of Technical and Safety Deficiencies on Nuclear Plant Cost and Reliability, April, 1977.
15.
Testimony by D.G. Bridenbaugh before the Calif ornia S tate Energy Commission, subject:
Decommissioning of Pressurized Water Reactors, Sundesert Nuclear Plant Hearings, June 9, 1977.
16.
Testimony by D.G.
Bridenbaugh before the Calif ornia S tate Energy Commission, subject: Economic Relationships of Decommissioning, Sundesert Nuclear Plant, for the Natural
' Resources Defense Council, July 15, 1977.
17.
Testimony by D.G. B ridenbaugh bef ore the Vermont State Board of Health, subj ect : Operation of Vermont Yankee Nuclear Plant and Its Impact on Public Health and Safety, October 6, 1977.
18.
Testimony by D.G. Bridenbaugh before the U.S.
Nuclear Regula-tory Commission, Atomic S af ety and Licensing Board, subj ec t :
Deficiencies in Safety, Evaluation of Non-Seismic Issues, Lack of Saf ety, Diablo Canyon Nuclear Units of a Definitive Finding ~
October 18, 1977, Avila Beach, California..
19.
Testimony by D.G. Bridenbaugh before the Norwegian Commission on Nuclear Power, subject: Reac tor S af etv/Ris k.
October 26, 1977.
20.
Testimony by D.G.
Bridenbaugh before the Louit,iana S tate Legislature Committee on Natural Resources, subject: Nuclear Power Plant Deficiencies Impacting on Safety & Reliability, Baton Rouge, Louisiana, February 13, 1978.
21.
Spent Fje! Disposal Costs, report prepared by D.G.
Bridenbaugh f or t' e Natural Resources Defense Council ( NRDC), August 31,
- 1978, 22.
Testimony by D. G. B ridenbaugh, G.C. Minor, and R.B. Hubbard before the Atomic Saf ety and Licensing B oard, in the matter of the Black Fox Nuclear Power S tation Construction Permit Hearings, September 25, 1978, Tulsa, Oklahoma.
23.
Testimony of D.G. Bridenbaugh and R.B.
Hubbard before the Louisiana Public Service Commission, Nuclear Plant and Power Generation Costs, November 19, 1978, B aton Rouge, Louisiana.
24 Testimony by D.G.
Bridenbaugh before the City Council and Electric Utility Commission of Austin, Texas, Design, Con-struction, and Operating Experience of Nuclear Generating Facilities, December 5, 1978, Austin, Texas.
25.
Testimony by D.G. Bridenbaugh for the Commonwealth of Massachusetts, Department of Public Utilities, Impact of Un re solved S af e ty Issues, Generic Deficiencies, and Three Mile Island-Initiated Modifications on Power Generation Cost at the P ropos ed P ilgrim-2 Nuclear Plant, June 8,
1979.
26.
Improving the Safety o f LW R P owe r Plants, MHu Technical Associates, prepared for U.S.
Dept. of Energy, Sa^dia Laboratories, September 25, 1979.
27.
BWR ?ipe and Nozzle Cracks, MHB Technical Auraciates, for the Swedish iuclear Power Inspectorate (SKI), October, 1979.
28.
Testimony of D.G.
Bridenbaugh and G.C.
Minor before the Atomic Safety and Licens ing B oard, in the matter of Sacramento Municipal Utility District, Rancho Seco Nuclear Genera ting S ta tion f ollowing TMI-2 accident, subject:
Operator Training and Human Factors Engineering, for the California Energy Commission, February 11, 1980.
29.
Italian Reactor Safety Study:
Caorso Risk Assessment, MHB Technical As sociates, for Friends of the Earth, Italy, March, 1980.
30.
Decontamination of Kryp ton-85 from Three Mile Island Nuclear
- Plant, H.
- Kendall, R.
Pollard, &
D.G.
B r id enb au gh, et al, The Union of Concerned S cien tis ts, delive red to the Governor of Pennsylvania, May 15, 1980. _
O o
F 31.
Testimony by D.G. Bridenbaugh before the New Jersey Board of Public Utilities, on behalf of New Jersey Public Advocate's Office, Division of Rate Counsel, An aly s is of 1979 Salem-1 Refueling Outage, August, 1980.
32.
Position S tatement, Proposed Rulemaking on the S torage and Disposal o f Nuclear Waste, Joint Cros s-S ta tement of Position of the New England Coalition on Nuclear Pollution and the Natural Resources Defense Council, September, 1980.
33.
Testimony by D.G. Bridenbaugh and Gregory C. Minor, before I
the New York S tate 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.
34 Supplemental Testimony by D.G. B ridenbaugh bef ore the New Jersey Boad of Public Utilities, on behalf of New Jersey Public Advocate's Office, Division of Rate Conusel, Analy s is of 1979 Salem-1 Refueling Outage, December, 1980.
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- erers s ere ss are of the test tus Cemm
- srion before any h.
* ; ^ *
- d 3 * ' 0" vnhin M days.
Jhue n su under way.
s ebe tan be sourd. i ame as but that n s.omd no: kin urnD f r te. i or.tre.cra erumed :n the b
I j'!inti irr" b3ltft- [Gr s II; t **5e.
reat hed s der.:sen or. :he p' ant 5
.ppresed c;we.d). Dasin said.
Ir,d.ng cf tr.e v3 tens of fuel l Care '.!iles. s ecm:.fi-ion phy sical securit) F a..
F.e en.
reuld be f:n:=hed in about one sr;a e-en: sin e confir;ned that
'.el isid the i. cart c' s-rurny ce:e :ed c:: Tburse v i. cule men:b. A f t!! reu er beense.
u hab PGl.E n..res for in No-NRC cffw:al> condur:;nt s tes:
~
winber mighi 1,.rnut the piant tu cperzte a full t r.cn carly r e. t y e ar, he -.id-s a
A loopes er hi erne allous h,,d:ng of ructrar f uel in the rf a(tor and 115 ' operation at 5 per s ent of f ull opacity. This alleus testing of the facility in ad acre of iifuance of a fud-p2b er lif e*.*.Se.
NUCIPar o ppO D e rits have fough; long.nd h.rd to block the L.enur.g of D;abio Canyon.
pa r t!) betsuse they think n is l
too (lese to sr carthquake f ault.
The $2 bilhon Diablo Cao-l y on r!.nt, ne r San Luis Obispo, has 'at unu+d as the battle
.' < ;.-d m et the past several ycan Tre u:ih:3 fint retelved a s o::st r ui t or. T.er r,it for one of the : c r c.nion at the plant in W$
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