ML20154B784
| ML20154B784 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/06/1988 |
| From: | George Minor, Sholly S SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20154B747 | List: |
| References | |
| OL-3, NUDOCS 8805170308 | |
| Download: ML20154B784 (44) | |
Text
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00CKETED AELA1ED GUNHt-MMPANM May 6.1988
'88 MY 10 P6 :53 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
[, o'c.([.. -1Mr,$ $,%
BRW Before the Atomic Safety and Licensing Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COL
.NY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
DIRECT TESTIMONY OF GREGORY C. MINOR AND STEYEN C. SHOLLY ON BEHALF OF SUFFOLK COUNTY REGARDING ' IMMATERIALITY" KIRKPATRICK & LOCKHART l
1800 M Street, N.W.
Washington, D.C. 20036 l
Attorneys for Suffolk County l
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May 6,1988 l
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8805170308 0005 22
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d
'May 6, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power
)
Station, Unit 2)
)
)
DIRECT TESTIMONY OF GREGORY C. MINOR AND STEVEN C.
SHOLLY ON BEHALF OF SUFFOLK COUNTY REGARDING "IMMATERIALITY" Q.
Please state your names and occupations.
A.
(Minor] My name is Gregory C. Minor, I am Vice-President of MHB Technical Associates.
A.
(Sholly] My name is Steven C. Sholly.
I am an Associate Consultant of MHB Technical Associates.
Q.
Please summarize your experience and professional qualifications.
~
l A.
[ Minor]
I received a bachelor of science degree in electrical engineering from the University of California at Berkeley in 1960 and a master of science degree in electrical engineering from Stanford University in 1986.
I have 27 years experience with nuclear power and related areas.
In particulxr, for 16 years I was employed by the General Electric Company where I worked on matters relating to the design, construction and operation of nuclear monitoring and safety systems, including hands-on experience at reactor sites.
I have been a consultant with MHB Technical Associates for 11 years, during which time I have been involved in a wide variety of consulting projects, many of them related to the probabilistic ritk assessments ("PRAs")
for nuclear power plants and reviews of nuclear plant safety and licensing. 'These include a PRA for the Barseback Nuclear Plant in Sweden and contribution to a PRA for the Caorso plant in Italy, plus testimony in the Shoreham proceeding on evacuation / sheltering issues using dose projections resulting from computer-generated accident and dose assessments.
I have testified as an expert witness in numerous proceed-ings before the Nuclear Regulatory Commission ("NRC") and other bodies, including both the health and safety and prior emergency 1
planning proceedings in this Shoreham litigation.
I am a member of the Nuclear Power Plant Standards Committee of the Instrument l
l
_2_
Society of America, and I served as a peer reviewer of the NRC's TMI Accident Investigation Report.
I am also co-holder of a patent on a nuclear monitoring system.
A statement of my professional qualifications has been provided as Attachment 1 to this testimony.
A.
[Sholly)
I have more than five years experience in the performance and review of probabilistic analysis of nuclear power plant safety issues, including the review of PRA studies and the applicatir,n of PRA results to the assessment of generic issues and emergency planning practices and procedures.
I have served as a member of the peer review group on regulatory applications of PRAs (NUREG-1050) and as a member of the Workshop on Contain-ment Performance Objectives (as p~ art of the NRC's Safety Goal Program).
I have testified in NRC proceedings on the Indian Point and Catawba plants concerning PRAs and their application to emergency planning.
A statement of my professional qualifications has been provided as Attachment 2 to this testimony. ___
(Minor, Sholly) We jointly sponsor this testimony.
Q.
What is the purpose of your testimony?
A.
The purpose is to address LILCO's immateriality argument which it has asserted as a defense to Contentions 1 and 2.
Those contentions, as rewritten by the Board,l/ read as follows:
Contentio.n_1 Whether LILCO's emergency plan and the best efforts response of the State and County governments will catisfy regulatory requirements concerning directing traffic.
Contention 2 Whether LILCO's emergency plan and the best efforts response of the State and County governments will satisfy regulatory requirements concerning blocking roadways, setting up barriers in roadways, and channeling traffic.
In essence, the above contentions address whethe: adequate traffic control measures can be implemented under LILT:O's Plan.
Appendix A of the Plan describes LILCO's traffic control scheme, including the use of traffic guides and other measures to direct traffic out of the EPZ.
It is LILCO's theory, however, that it makes no difference whether or not traffic control can be implemented because the time differential between a "controlled" 1/
Egg Memorandum (Extension of Board's Ruling and Opinion on LILCO Summary Disposition Motions of Legal Authority (Realism)
Contentions and Guidance to Parties on New Rule 10 C.F.R.
S 50.47(c)(1)), at 26 (Apr. 8, 1988).
4-
~
evacuation (i.e., one in which the Appendix A traffic control measures are imposed) and an uncontrolled evacuation is so insignificant as te be "immaterial."
Thus, LILCO argues, there would be little or no increase in dose to members of the public and no foreclosure of available protective actions as a result of LILCO's inability to implement traffic control.
We disagree.
The consequences of the absence of traffic control and the resulting longer evacuation times could have severe consequences for the public.
This testimony addresses two of those consequences:
(1) potentially higher doses of radiation to members of the public; and (2) the foreclosure of protective action options.
Q.
How would the absence of effective traffic control affect the risk to the population in the event of an emergency at Shoreham regulring evacuation of the EPZ?
A.
The absence of effective traffic control will increase evacuation times which, in turn, will increase the public's risk of radiation exposure.
The increase in evacuation times due to the absence of traffic control could also adversely affect the choice of protective actions.
4. -.
_ ~.
Evacuation times must be taken-into account at the time of an accident before a protective action can be chosen.
Thus, the LILCO Plan calls for consideration of evacuation time estimates (among other factors) in deciding upon a protective action.
As
.OPIP 3.6.1 (Plume Exposure Pathway Protective Action Recommendations) of the LILCO Plan states:
3.1 The dose-saving effectiveness of protective actions.can be influenced by many variable factors such as expected duration of releases, involved population, weather conditions, croiected evacuation times, and plant conditions.
Whenever possible, these factors should all be considered orior to the recommendation of cro-tective actions.
3.2 Sheltering is the preferred protective action if suffi-cient protection is offered by sheltering, or if no additional benefit is gained by evacuation.
The evac-uation of hospitals should be sought as a last means
. since sheltering is the least disruptive to the patients.
3.3 The evacuation time estimates used in this procedure,, account for variations in road condi-tions, seasonal population and mobilization of traffic guides.
The uncertainty in these values is i 1/2 hour.
In addition, the evacuation time estimates are sensi-tive to evacuee compliance with recommended routes, traffic shadow beyond ten miles and road accidents.
The effect of these factors on the time estimates is detailed in Attachment 7, Evacuation Time Estimate i
Sensitivity Study.
This study should be reviewed by the Radiation Health Coordinator and Evacuation Coordi-nator.2/
l Under LILCO's procedure, if evacuation shows a projected dose savings, it would be selected as the recommended protective action, rather than sheltering.
However, before evacuation can 2/
OPIP 3.6.1 at 2 (emphasis added).
I l
be chosen as the appropriate protective action, it is necessary to know how long it will take to complete the evacuation.
A number-of factors affect evacuation times.
Such factors recognized by the LILCO Plan include weather, road conditions, season, route compliance,3/ and shadow effect.
Accordingly, sensitivity analyses contained in the LILCO Plan show that for an evacuation, the estimated evacuation time may vary from less than 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> depending on the conditions which are assumed to prevail at the time of the accident.1/
Calculations conducted by LILCO demonstrate that the presence or absence of traffic control is also a factor significantly affecting evacuation times.
Consider the following table based on data provided by LILCO concerning evacuation times under "normal" summer conditions.
3/
Compliance is defined as the percent of the population following prescribed evacuation routes.
Egg OPIP 3.6.1,, at 3.
(Attachment 3 hereto).
i/
OPIP 3.6.1, Attachment 7, at 1-2 (Attachment 3 hereto),
shows that for Zones,A-S under normal winter conditions, controlled, 100% compliance, 0% shadow, the estimated evacuation time is 4.58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br />.
For adverse winter conditions, uncontrolled, 100% compliance, 50% shadow, evacuation time is 8.08 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. __.
Type of Degree of Evacuation Non-Compliance Evacuation Time (Controlled /
of Evacuating Public Time-Estimate Difference Uncontrolled f% Non-Comoliance)
(hrs / minutes (minutes)
Controlled-0%
5-05 35 Uncontrolled 0%
5-40 Controlled 25%
5-25 35 Uncontrolled 25%
6-00 Controlled 50%
5-25 60 Uncontrolled 50%
6-25 Controlled 0%
5-05 80 Uncontrolled 50%
6-25 Egg Affidavit of Edward B. Lieberman 14 (Dec. 15, 1987).
Accepting LILCO's data for the purposes of this testimony, they demonstrate that, under "normal" summer conditions, an uncontrolled evacuation can take anywhere from 35 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 20 minutes longer to complete than a controlled evacuation.
We believe that the upper bound of this range is more realistic because, as we understand Dr. Hartgen will testify, a great deal of non-compliance with LILCO's prescribed routing can be expected in an uncontrolled evacuation.5/
5/
In arguing that the absence of traffic controls is immaterial with respect to dose reduction, LILCO compares two scenarios which assume 100% public compliance with LILCO's prescribed evacuation routing:
controlled /0% noncompliance (5:05) and uncontrolled /0% noncompliance (5:40).
LILCO then concludes that the difference of 35 minutes is immaterial since the margin of error of the time estimates is i 30 minutes.
Egg LILCO's Motion for Summary Disposition of Contentions 1, 2 and 9
-- Immateriality, at 12 (Dec. 18, 1987).
LILCO's comparison is inapposite.
Because the absence of control will reduce compliance, the assumption of 0% non-(footnote continued)._-
Furthermore, taking into account the 30-minute margin of error in these estimates, the absence of traffic control could actually result in differences of approximately one to two hours between a controlled and an uncontrolled evacuation.6/
Thus, the absence of control could lead to a significant lengthening of the time evacuees may spend in the EPZ during an evacuation.
(footnote continued from previous page) compliance in an uncontrolled evacuation is unrealistic.
The proper comparison for identifying the impact of the absence of traffic control is between a controlled evacuation with 0%
noncompliance (5:05) and an uncontrolled evacuation with 50%
noncompliance (6:25).
The differential between these times is 80 minutes, only 15 minutes shorter than the 95 minute differential which this Board found to be significant in the PID.
Egg Partial Initial Decision on Emergency Planning, LBP-85-12, 21 NRC 644, 917 (1985).
It should also be noted that the calculated times for evacuation provided by LILCO reflect normal summer weather conditions.
LILCO calculates the effect of traffic control for the other seasons as follows (assuming 100% compliance):
Controlled Uncontrolled Difference Summer Adverse 6 hr. O min.
6 hr. 45 min.
45 Winter Normal 4 hr. 35 min.
5 hr. 10 min.
35 Winter Adverse 6 hr. 10 min.
7 hr. 5 min.
55 By focusing only on normal summer conditions, LILCO has availed itself of the most favorable assumptions in order to i
deflate the time differential between the controlled and uncontrolled evacuations.
Moreover, LILCO's analysis ignores shadow traffic.
5/
The 1-2 hour differential between a controlled and an uncontrolled evacuation is derived by adding the maximum limit of the margin of uncertainty (30 minutes) to: (1) the difference between a controlled and an uncontrolled evacuation, assuming 100% compliance with prescribed routing in both cases (35 minutes); and (2) the difference between a controlled evacuation with 100% compliance and an uncontrolled evacuation with 50%
i noncompliance (80 minutes).
The results are differentials of 65 minutes (30 + 35) and 110 minutes (30 + 80).
4
Q.
How would increased evac'uation times increase the public', risks of exposure to radiation?
A.
The najor impact of increased evacuation times due to the absence of traffic control would be that people would be confined to their cars in the EPZ for a longer period of time.
Thus, in an evacuation, EPZ residents potentially would be exposed to radioactive materials in their path, in the air, on their bodies, or on their cars, for a longer period of time.
This would result in larger doses than those which they would receive in a shorter evacuation employing effective traffic controls.
Furthermore, if people are stuck in a queue or are slowed due to ineffective or non-existent traffic control, their chances of being caught or overtaken by the plume would increase.
We understand that the State's traffic testimony will suggest that the effect of delays due to poor or absent traffic control would be to slow traffic and cause queues, which would prolong the presence of evacuees within the EPZ during the time the accident is developing.
As indicated above, we astimate the additional evacuation time as being between one and two hours.
During this additional time, the course and development of the accident could change.
The evacuees could be caught in queues while the accident may be developing into a release accident or the plume may be changing course. - -,
=
P' The development of an accident from an initiating event-to a release may occur in as few as one and one-half hours with as little as one hour warning time.1/
The duration of the release may be an hour or more, and other releases may develop in a
' matter of two or more hours.
These times from initiation to release are sufficiently short that an accident that has been misdiagnosed (one where it was thought there was time to evacuate or that evacuation would result in a.very low dose) may result in
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a release in a matter of only a few hours.
Releases occurring in this period would be capable of reaching evacuees caught in queues within the 10 mile EPZ while the evacuation is still underway.
Thus, prolonging the evacuation period by 1-2 hours could be highly significant in terms of increased dose to the population or exposure of additional segments of the population.
If a radioactive plume reaches the evacuees before they have left the EPZ, there is little or no effective shielding provided by an automobile.1/
Thus, they would receive estentially an unshielded cloud dose, plus a portion of the ground dose in the area they are traveling through.
Q.
Could the doses due to an extra 1-2 hours plume expo-sure be appreciable?
1/
Egg Shoreham 100% PRA Table 3.7-7 (1983) (attached hereto as ).
l/
The LILCO Plan assumes that the shielding factor of an evacuation is 1.0, 11g2, no shielding.
Sgg OPIP 3.6.1, at 4.,
A.
Yes.
In fact, evidence already submitted in these proceedings documents that significant doses are possible as the result of an incremental exposure of an additional 1-2 hours.
Egg Testimony of Fred C. Finlayson, Gregory C. Minor and Edward P. Radford on Behalf of Suffolk County Regarding Contention 61 (March 21, 1984) ("Testimony of Finlayson et al.").
Calculations underlying that testimony demonstrated that the chance of receiving a 30 REM dose at 2 miles and 10 miles from the plant is 35% and 15% respectively as the result of an incremental exposure of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.2/
Egg Attachment 5 hereto.
A 30 REM dose is far in excess of the EPA Protective Action Guidelines (1-5 REM whole body) and constitutes the threshold of early injury to the body.
It also represents a 21 percent increase in the chance of contracting cancer.
Testimony of Finlayson et al. at 4.
Q.
How could the absence of traffic control lead to the foreclosure of protective action options?
A.
In circumstances where evacuation would lead to dose savings, the LILCO Plan identifies evacuation as the preferred option.
The effect of longer evacustion times due to the absence of traffic control would be to make sheltering the chosen option in certain accidents where a controlled evacuation would have 1/
In the County's testimony on Contention 61.B, a 30 REM dose was selected as a significant dose becaus'e it represents the threshold of early injury and a significantly increased chance of cancer to the population..-__
provided greater dose savings.
For those accidents, the public would be denied the greater dose savings that could have been achieved had evacuation not been foreclosed by the absence of traffic control.
LILCO may also incorrectly presume at the time of an accident that it can effectively implement traffic control.
In such cases, LILCO might erroneously choose evacuation over sheltering as a protective action.
Where evacuation was attempted, but the actual evacuation time turned out to be longer than estimated because of poor traffic control, additional population exposure could occur because:
(1) people in the tail end of the evacuation, who would'otherwise have escaped with little or no exposure, could be caught in the plume and therefore exposed to a greater dose; (2) there may be greater exposure of the evacuating population for a longer period of time due to the extended evacuation times; or (3) there may be an additional segment of the population exposed due to wind shift during the extended evacuation time which would change the trajectory of the plume.
However, by the time these consequences of LILCO's erroneous choice were discovered, the appropriate choice --
sheltering -- would have been foreclosed.
Q.
In your opinion, is the absence of traffic control material to the evaluation of LILCO's emergency planning for Shoreham?
A.
Yes.
The consequences of the absence of traffic control will be a prolonged EPZ evacuation which may result in:
(1) a lessened dose reduction; and (2) the loss of protective action response options.
Because the probable result of either consequence is a significant increase in dose exposure, the absence of traffic control is a material flaw in LILCO's emergency planning.
Q.
Does this conclude your testimony?
A.
Yes.
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t ATTACHMENT 1
ATTACHMENT 1 e
PROFESSIONAL OUALIFICATIONS OF GREGORY C. MINOR GREGORY C. MINOR MHB Technical Associates 1723 Hamikon Avenue Suite K San Jose, California 95125 (408) 266-2716 EXPERIENCE:
1976 to PRESENT Vice President - MHB Technical Associates. San Jose. California Engineering and energy consultant to state, federal, and private organizations and indisiduals.
Major activities include studies of safety and risk involved in energy generation, providing technical consulting to legislative, regulatory, public and private groups and expert witness in behalf of state organizations and citizens' groups. Was co-editor of a critique of the Reacter Safety Study (WASH 1400) for the Union of Concerned Scientists and co-author of a risk analysis of Swedish reactors for the Swedish Energy Commission. Served on the Peer Review Group of the NRC/TMI Special Inquiry Group (Rogovin Committee). Actively involved in the Nuclear Power Plant Standards Committee wrk for the Instrument Society of America OSA).
1972 1976 Manaaer. Advanced Control and Instrumentation Enaineerina. General Electric Comoany.
Nuclear Enerav Division. San Jose. California Managed a design and development group of thirty four engineers and support personnel designing systems for use in the measurement, control and operation of nuclear reactors.
Involved coordination with other reactor design organizations, the Nuclear Regulatory Commission, and customers, both overseas and domestic.
Responsibilities included coordinating and managing and design and development of control systems, safety systems, and new control concepts for use on the next generation of reactors. The position included responsibility for standards applicable to control and instrumentation, as well as the design of short term solutions to field problems. The disciplines involved included electrical and me-chanical engineering, seismic design and process computer control / programming, and equipment qualification.
1970 1972 Manaaer. Reactor Control Systems Desien. General Electric Comnany. Nuclear Enercy Division. San Jose. California Managed a group of seven engineers and two support personnel in the design and preparation of the detailed sptem drawings and control documents relating to safety and emergency systems for nuclear reactors.
Responsibility required coordination with other design i
1
f 1
organizations and interaction with the customer's engineering personnel, as well as regulatory personnel.
1 % 3 - 1970 Desian Enrineer. General Flectric Comoany. Nuclear Enerry Disision. San Jose. California Responsible for the design of specific control and instrumentation systems for nuclear Lead design responsibility for various subsystems of instrumentation used to reactors.
measure neutron flux in the reactor during startup and intermediate power operation.
Performed lead system design function in the design of a major system for measuring the power generated in nuciaar reactors. Other responsibilities included on site checkout and testing of a complete reactor control system at an experimental reactor in the Southwest.
Received patent for Nuclear Power bionitoring System.
1960 - 1 % 3 Advanced Encineerine Procram. General Electric Company-Assicnments in Washindon.
California. and Arizorts Rotating assignments in a variety of disciplines:
Engineer, reactor maintenance and instrument design, KE and D reactors, Hanford, Washington, circuit design and equipment maintenance coordination.
Design engineer, Microwave Department, Palo Alto, California. Work on design of cavity couplers for Microwave T aveling Wave Tubes (TWT).
Design engineer, Computer Department, Phoenix, Arizona. Design of core drising circuitry.
Design engineer, Atomic Power Equipment Department, San Jose, California.
Circuit design and analysis.
Design engineer, Space Systems Department, Santa Barbara, California.
Prepared control portion of satellite proposal.
Technical Staff Technical Military Planning Operation. (TEMPO), Santa Barbara, California. Prepare analyses of missile exchanges.
During this period, completed three year General Electric program of extensive education in advanced engineering principles of higher mathematics, probability and analpis.
Also completed courses in Kepner Tregoe, Effective Presentation, Management Training Program, and various technical seminars.
2
EDUCATION University of California at Berkeley, BSEE,1960.
Advanced Course in Engineering three. year curriculum, General Electric Company,1%3.
Stanford University, MSEE,1966.
HONORS AND ASSOCIATIONS Tau Beta Pi Engineering Honorary Society Co-holder of U.S. Patent No. 3,565 760, ' Nuclear Reactor Power Monitoring System February,1971.
Member: American Association for the Advancement of Science.
Member:
Nudear Power Plant Standards Committee, Instrument Society of America.
PERSONAL DATA Born: June 7,1937 Married, three children Residence: San Jose, California PUBLICATIONS AND TESTIMONY 1.
G. C. Minor, S. E. Moore, ' Control Rod Signal Multiplexing,' IEEE Transactions on Nudear Science, Vol. NS 19, February 1972.
2.
G. C. Minor, W. G. Milam, "An Integrated Cootrol Room System for a Nudear Power Pla NEDO 10658, presented at International Nudear Industries Fair and Technical Meeti October,1972, Basle, Switzerland.
3.
The above article was also published in the German Technical Magazine, NT, March,1973.
4 Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the Joint Committee on Atomic Energy, Hearing held February 18,1976, and published by the Union of Concerned Scientists, Cambridge, Massachusetts.
5.
Testimony of G. C. Minor, D. G. Bridenbaugh, and R. D. Hubbard before the California State Assembly Committee on Resources,l.and Use, and Energy, March 8,1976.
6.
Testimony of G. C. Minor and R. B. Hubbard before the California State Senate Committee on Public Utilities, Transit, and Energy, March 23,1976.
3
7.
Testimony of G. C Minor regarding the Grafentheinfeld Nudear Plant March Wurzbuerg, Germany.
16 17 1977 8.
Testimony of G. C. Minor before the Cluff Lake Board of Inquiry, Regina S Canada, September 21,1977.
n, 9.
The Risks of Nuclear Power Reactors A Review of the NRC Reactor Safety S 1400 (NUREG 75/014). H. Kendall, et al, edited by G. C. Minor and R. B Hub Union of Concerned Scientists, August,1977.
e 10.
Swedish Reactor Safety Study-January,1978 (Published by Swedish Department ofIndustry 11.
Testimony by G. C. Minor before the Wisconsin Public Senice Commission Loss of Coolant Accidents Their Probability and Consecuence.
12.
Testimony by G. C Minor before the California Legislature Assembly Committ Resources, Land Use, and Energy, AB 3108, April 26,1978, Sacramento, California.
n 13.
(BMFT), Meeting on Reactor Safety Research, Man /
August 21, and September 1,1978, Bonn, Germany.
14.
Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard, befo and Licensing Board, September 25, 1978, Construction Permit Hearings, Tulsa, Oklahoma.in the tnatter of Black Fox Nuclear Power 15.
Testimony of G. C Minor, ASLB Hearings Related to TMI 2 Accident, Rancho Plant, on behalf of Friends of the Earth, September 13,1979.
16.
Testimony of G. C. Minor before the Michigan State Legislature, Special Joint C Nudear Energy, Imolications of Three Mile Island Accident for Nuclear Power Pl Michican. October 15,1979.
17.
A Critical View of Reactor Safety.
by G. C Minor, paper presented to the American Association for the Advancement of Science, Symposium on Nudear Reac 1980, San Francisco, California.
18.
Nudear Referendum, Stockholm, Sweden, March 1,1980,The Eff 19.
Minnesota Nuclear Plants Ga<eous Emissions Study. MHB Technical Asso 1980, prepared for the Minnesota Pollution Control Agency, Roseville, MN.
20.
Commission, Shoreham Nuclear Plant Construction S Lighting Company Temporary Rate Case, case # 27774 September 22,1980.
21.
Systems Interaction and Sincie Failure Criterion. MHB Technical Associates Ja prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sw 4
22.
Testimony of G. C. hiinor and D. G. Bridenbaugh before the Nev> Jersey Board of Public Utilities, Ov<ter Creek 1980 Refueline Outace investication. in the matter of the Petition of Jersey Central Power and Light Company for approval of an increase in the rates for electrical service and adjustment clause and factor for such service, OAL Docket No. PUC 3518-80, BPU Docket Nos. 804-285,807-488, February 19,1981.
23.
Testimony of G. C. hiinor and D. G. Bridenbaugh on PORV's and Pressurizer Heaters. Diablo Canyon Operating License hearing before ASLB, in the matter of Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), Docket Nos. 50-275-OL,50-323-0L, January 11,1982.
24.
Testimony of G. C. hiinor and R. B. Hubbard on Emercenev Resoonse Planninc. Diablo Canyon Operating License hearing before ASLB, Docket Nos. 50-275 OL,50-323-OL, Januar 11,1982, 25.
Systems Interaction and Sincie Failure Criterion:
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Phase II Reoort. MHB Technical Associates, February 1982, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
26.
Testimony of G. C. hiinor, R. B. Hubbard, M. W. Goldsmith, S. J. Harwood on behalf 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 Contention 7B, Sah Classification and Systems interaction. Docket No. 50-322 OL, April 13,1982.
27.
Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety and Licensing Board,in the rnatter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 11. Passive Mechanical Valve Failure. Docket no. 50 322-OL, April 13,1982.
28.
Testimony of G. C. Minor and R. B. Hubbard on t;chalf 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 Suffolk County Contention 27 and SOC Contention 3. Post-Accident Monitorine. Docket No. 50 322 OL, May 25,1982.
29.
Testimony of G. C. Minor and D. G. Bridenbaugh on behalf 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 Suffolk County Contention 22. SRV Test Procram.
Docket No. 50-322-OL, May 25,1932.
30.
Testimony of G. C. Minor and D. G. Bridenbaugh on behalf 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 Reduction of SRV Chattences. Docket No. 50 322 OL.
Junc 14,1982.
31.
Testimony of G. C. Minor on behalf 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 Environmental Oualification. Docket No. 50 322 OL, January 18,1983.
32.
Testimony of G. C. Minor and D. G. Bridenbaugh before the Pennsylvania Public Utility Commission, on behalf of the Office of Consumer Advocate, Recardinc the Cost of 5
Constructine the Sucouchanna Steam Electric Station. Unit 1. Re: Pennsylvania Power and Light, Docket No. R 822189, March 18,1983.
33.
Supplemental testimony of G. C. Minor, R. B. Hubbard, and M. W. Goldsmith on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nudear Power Station, Unit 1, regarding Safety Classification adv<tems Interaction (Contention 7BL Docket No. 50-322, March 23,1983.
34.
Verbal testimony before the District Court Judge in the case of Sierra Club et. al. vs. DOE regarding the Clean-t.p of Uranium Mill Tailings. June 20,1983.
35.
Systems Interaction and Sincie Failure Criterion: Phase 3 Reoort. MHB Technical Associate June,1983, prepared for and available from the Swedish Nudear Power Inspectorate, Stockholm, Sweden.
36.
Systematic Evaluation Procram: Status Report and initial Evaluation. MHB Technical Associates,' June,1983, prepared for and available from the Swedish Nudear Power Inspectorate, Stockholm, Sweden.
37.
Testimony of G. C. Minor, F. C. Finlayson, and E. P. Radford before the Atomic Safety and Licensing Board, in the Matter of Long Island Lighting Company, Shoreham Nudear Power Station, Unit 1, regarding Emergency Planninc - Evacuation Times and Doses (Contentions 65.
23.D and 23.HL Docket No. 50-322-OL-3, November 18,1933.
38.
Testimony of G. C. Minor, Sizewell 'B' Power Station Public Inquiry, Proof of Evidence Recardine Safety Issues. December,1983.
39.
Testimony of D. G. Bridenbaugh, L. M. Danielson, R. B. Hubbard and G. C. Minor before the State of New York Public Service Commission, PSC Case No. 27563, in the matter of Long Island Lighting Company Proceeding to Investicate the Cost of the Shoreham Nuclear Generatine Facility -- Phase It on behalf of County of Suffolk, February 10,1984 40.
Testimony of Fred C. Finlayson, Gregory C. Minor and Edward P. Radford before the Atomic Safety and Licensing Board, in the Matter of Long Island Lighting Company, Shoreham Nudear Power Station, Unit 1, on behalf of Suffolk County Regarding Emercency Plannine - Shelterine (Contention 611 Docket No. 50-322 0L, March 21,1984.
4L Testimony of G. Dennis Eley, C. John Smith, Gregory C. Minor and Dale G. Bridenbaugh before the Atomic Safety and Licensing Board,in the matter of Long Island Lighting compan Shoreham Nudear Power Station Unit 1, regarding EMD Diesel Generators and 20 MW Gas Turbine. Docket No. 50-322 0L, March 21,1934.
42.
Revised Testimony of Gregory C. Minor before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nudear Power Station Unit 1, on behalf of Suffolk County regarding Emercency Plannine - Recovery and Reentry (Contentions 85 and 88L Docket No. 50-322 0L, July 30,1984.
43.
Testimony of Dr. Christian Meyer, Dr. Jose Roesset, and Gregory C. Minor before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County, regarding Low Power Hearines - Seismic Canabilities of AC Power Sources. Docket No. 50-322-OL, July 1984 -
44.
Affidasit of Gregory C Minor, Emergency Planning Legal Authority Court Case, State Court of New York, September 11,1984.
45.
Surrebuttal Testimony of Dale G. Bridenbaugh, Lynn M. Danielson, Richard B. Hubbard, and Giegory C. Minor, Before the New York State Public Service Commission, PSC Case No.
27563, Shoreham Nuclear Station, Long Island Lighting Company, on behalf of Suffolk Cou and New York State Consumer Protection Board, regarding Investication of the Cost of the Shoreham Nuclear Generatina Facility, October 4,1984.
46.
Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C Minor on behalf of Massachusetts Attorney General, DPU 84-145, before the Massachusetts Department of Public Utilities, regarding Prudence of Ewenditures by Fitchbure Gas and Electric Licht comoany for Seabrook Unit 2. November 23,1984,84 pgs.
47.
Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C Minor on behalf of Maine Public Utilities Commission Staff regarding Prudence of Cests of Seabrook Unit 2.
Docket No. 84113, December 21,1984.
48.
Direct Testimony of Dale G. Bridenbaugh and Gregory C Minor on behalf of Suffolk County regarding Shoreham Emercenev Diesel Generator Loads. Docket No. 50-322 OL, January 25, 1985.
49.
Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson, and Gregory C. Minor on behalf of the Vermont Department of Public Senice, PSB Docket No. 5030, regarding Prudence of Central Vermont Public Senice Corsorations Costs for Seabrook 2. Novernber 11,1985.
50.
Surrebuttal testimony of Gregory C. Minor on behalf of the Vermont Department of Public Senice, PSB Docket No. 5030, Prudence of Central Vermont Public Senice Corocrations Costs for Seabrook 2. December 13,1985.
51.
Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price, and Steven C Sholly on behalf of State of Connecticut Department of Public Utility Control Prosecutorial Disision and Division of Consumer Counsel regarding the Prudence of Emenditures on Millstone Unit 3. Docket No. 83-07-03, February 18,1986.
52.
Direct Testimony of Dale G. Bridenbaugh and Gregory C Minor on behalf of Massachusetts Attorney General regarding the Prudence of Emenditures by New Enc!and Power Co. for Seabrook Unit 2. Docket Nos. ER 85-646-000, ER 85-647-000, February 21,19S6.
53.
Direct Testimony of Gregory C Minor on behalf of the Prosecutorial Division of CDPUC regarding CL&P Construction Prudence for Millstone Unit 3. Docket No. ER-85 720-001 March 19,1986.
54.
Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor en behalf of Massachusetts Attorney General regarding WMECo Construction Prudence for Millstone Unit 3. Docket No.85-270, March 19,1986.
55.
Direct Testimony of Dale C, Bridenbaugh and Gregory C Minor on behalf of Massachusetts Attorney General regarding WMECo's Commercial Ooeratine Dates and Deferred Caoital Additions on Millstone Unit 3. Docket No. 85 270, March 19,1986.
7
56.
Rebuttal Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding Rebuttal to New Encland Power Comoany's Seabrook 2, Docket Nos. ER 85-M6-001, ER 85-647-001, April 2,19S6.
57.
Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of State of Maine Staff of Public Utilldes Commission regarding Cpfstruction Prudence of Millstone Unit 3. in the matter of Maine Power Company Proposed Increase in Rates, Docket No. 85 212, Ap 1986.
58.
Imolleations of the Chernobyl-4 Accident for Nuclear Emercenev Plannina for the State of New York. prepared for the State of New York Consumer Protection Board, by MHB Technical Associates, June 1986.
59.
Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of the Vermont Department of Public Senice, regarding Prudence of Costs by Central Vermont Public Senice Cornoration for Millstone 3. Docket No. 5132, August 25,1986.
60.
Surrebuttal Testimony of Gregory C. Minor in the matter of Jersey Central Power and Light Company, regarding TMI Restart and Performance incentives. (Oral testimony), OAL Docket No. PUC 7939-85, BPU Docket No. ER851116, September 11,1986.
61.
Surrebuttal Testimony of Gregory C. Minor on behalf of State of Vermont Department of Public Senice, regarding CVPS/NU Construction Prudence related to Millstone Unit 3. Docket No. 5132, November 6,1986.
62.
Direct Testimony of Gregory C. Minor and Lynn K. Price on behalf of State of Vermont Department of Public Senice, regarding Prudence of Excenditures for Seabrook 1. Docket No.
5132, December 31,1986.
63.
Direct Testimony of Gregory C. Minor on behalf of Suffolk County, before the Atomic Sa and Licensing Board, concerning Shoreham Protective Action Recommendations (Contention EX 36L in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, Docket No. 50-322 OL 5, February 27,1987.
M.
Direct Testimony of Gregory C. Minor et. al. on behalf of the State of New York and Suffolk County, before the Atomic Safety and Licensing Board, regarding The Scone of the Emercency Plannine Exercise (Contentions EX 15 and 16L in the snatter of Long Island Lighting Com Shoreham Nuclear Power Station, Unit 1, Docket No. 50 322 0L 5, April 6,1987.
65.
Direct Testimony of Gregory C. Minor regarding Emercenev Plannine Recention Centers -
Monitorinc and Decontamination. Shoreham Docket 50-322 OL-3 (Emergency Planning), Apr 13,1987.
66.
Testimony of Gregory C. Minor, Steven C. Shelly et, al. on behalf of Suffolk County, regardi LILCO's Recention Centers - Planninc Buis, before the Atomic Safety and Licensing Bovd,in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, Docket No.50-322 OL 3, April 13,1987.
67.
Rebuttal Testimony of Gregory C. Mioor and Steven C. Sholly on behalf of Suffolk County regarding LILCO's Recention Centers (Rebuttal to Testimony of Lewis G. Hulmanh in the 8
matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, Docket No.
50-322 0L-3, May 27,1987.
68.
Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General, before the Federal Energy Regulatory Commission, regarding Canal Electric Comoany Prudence Related to Seabrook Unit 2 Construction Exnenditures. Docket No. ER86-704-00L July 31,1987.
69.
Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor before the Penns)hinia Public Utility Commission, Regarding Beaver Valley Unit 1, Docket No.179070318, OCA Statement No. 2, August 31,1987.
l 9
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ATTACHMENT 2
ATTACHMENT 2 PROFESSIONAL OUALIFICATIONS OF STEVEN C. SHOLLY STEVEN C. SHOLLY MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, California 95125 (408) 266-2716 EXPERIENCE:
September 1985 PRESENT Associate - MHB Technical Associates. San Jose. California Associate in energy consulting firm that specializes in technical and economic assessments of energy production facilities, especially nuclear, for local, state, and federal governments and private organizations.
MHB is extensively involved in regulatory proceedings and the preparation of studies and reports. Conduct research, write reports, participate in disco process in regulatory proceedings, develop testimony and other documents for regulator proceedings, and respond to client inquiries. Clients have included: State of California, State of New York, State ofIllinois.
February 1981 September 1985 Technical Research Associate and Risk Anahst Unio' of Concerned Scientists.
n DE Re$earch associate and risk analyst for public interest coup based in Cambridge, Massachusetts, that specialks in examining the impact of advanced technologies on soci principally in the areas of arms control and energy. Technical work focused on nuclear po plant safety, with emphasis on probabilistic risk assessment, radiological emergency p and preparedness, and generic safety issues. Conducted research, prepared reports and participated in administrative proceedings before the U.S. Nuclear Regulatory Commission developed testimony, analyzed NRC rule making proposals and draft reports and prepared comments thereon, and responded to inquiries from sponsors, the general public, and the media.
Participated as a member of the Panel on ACRS Effectiveness (1935), the Panel on Regulatory Uses of Probabilistic Risk Asses., ment (Peer Review of NUREG 1050; 1984),
in ited Observer to NRC Peer Resiew meetings on the source term reassessment (BMI 2104; 1983 1984), and the Independent Advisory Committee on Nuclear Risk for the Nuclear Risk Task Force of the National Association oflasurance Commissioners (1984).
1 I
January 1980. January 1981 Proieet Director and Research Coordinator - Three P file Island Public Interest Reso Center. Harrisbure. Penn<vivania Provided administrative direction and coordinated research projects for a public interest gro based in Harrisburg, Pennsylvania, centered around issues related to the Three Mile Island Nuclear Power Plant.
Prepared fundraising proposals, tracked progress of U.S. Nuclear Regulatory Commission, U.S. Department of Energy, and General Public Utilities aethities concerning cleanup of Three Mile Island Unit 2 and preparation for restart of Three Mile Island Unit 1, and monitored developments related to emergency planning, the financia! health of General Pubhc Utilities, and NRC rulemaking actions related to Three Mile h!and.
July 1978. January 1980 Chief Biolocical Process Goerator Wasawater Treatment Plant. Derry R shin Municinal Authority. Hershev. Pennsvivania Chief Biological Process Operator at a 2.5 million gallon per day terti.ry, activate 6 sludge, wastewater treatment plant.
Responsible for biolegical process monitoring and control, including analysis of physical, chemical, and biological test results, process fluid and mass flow management, micro-biological analysis of activated sludge, and maintenance of detailed process logs for input into state and federal reports on treatment process and effluent quality. Receised certification from the Commonwealth of Pennsyhunia as a wastewater treattnent plant operato Member of Water Pollution Control Association of Pennsylvania, CentralSection,1980.
July 1977 July 1978 Wastewater Treatment Plant Operator - Borouch of Lemovne.12movne. Pennsvivania Wastewater treatment plant operator at 2.0 million gallon per day secondary, activated sludg wastewater treatment plant.
Performed tasks as assigned by supenisors, including simple physical and chemical tests on wastewater streams, maintenance t.nd operation of plant equipment, and maintenance of the collection system.
September 1976 June 1977 Science Teacher West Shore School District. Camn Hill. Pennsvivania Taught Earth and Space Science at ninth grade level. Developed and implemented new course materials on plate tectonics, emironmental geology, and space sdence. Served as Assistant Coach of the district gymnastics team.
September 1975 - June 1976 Science Teacher - Carlisle Area School District. Cartkle. Pennsthania Taught Earth and Space Science and Environmental Science at ninth grade level. Developed and implemented new course materials on plate tectonics, emironmental geology, noise pollution, wates pollution, and energy. Served as Adsisor to the Science Projects Club.
EDUCATION:
B.S., Education, majors in Earth and Space Science and General Science, minor in Environmental Education, Shippensburg State College, Shippensburg, Pennsylvania,1975.
Graduate coursework in Land Use Planning, Shippensburg State College, Shippensburg Pennsykania,19771978.
PUBLICATIONS:
1.
' Determining hiercalli Intensities from Newspaper Reports,* Journal of Geological Education.
Vol. 25,1977.
2.
A Criticue of An Indeoendent Assessment of Evacuation Times for Three Mile Islan Power Plant. Three hiile Island Public Interest Resource Center, Harrisburg, Pennsylvania, January 1981.
3.
A Brief Review and Critiaue of the Rockland County Radioloeical Emercenev Prenaredness Plan. Union of Concerned Scientists, prepared for Rockland County Emergency Planning Personnel and the Chairman of the County legislature, Washington, D.C., August 17,1981.
4.
The Necessity for a Promet Public Alertine Canability in the Plume Exooture Pathwav EPZ at Nuclear Power Plant Sites. Union of Concerned Scientists, Critical Mass Energy Project, Nuclear Information and Resource Service, Environmental Action, and New York Public In-terest Research Group, Washington, D.C., August 27,1981.
- 5.
"Union of Concerned Scientists, Inc., Comments on Notice of Proposed Rulemaking, Amendment to 10 CFR 50, Appendix E, Section IV.D.3,' Union of Concerned Scientists, Washington, D.C., October 21,1981.
- 6.
"The Evolution of Emergency Planning Rules,' in The Indian Point Book A Briefine on the Saferv Investiestion of the Indian Point Nuclear Power Plants. Anne Witte, editor, Union of Concerned Scientists (Washington, D.C.) and New York Public Interest Research Group (New York, NY),1982.
7.
' Union of Concerned Scientists Comments, Proposed Rule,10 CFR Part 50, Emergency P!4nning and Preparedness: Exercises, Clarification of Regulations,46 F.R. 61134,* Union of Concerned Scientists, Washington, D.C., January 15,1982.
- 8.
Testimony of Robert D. Pollard and Steven C. Sbolly before the Subcommittee on Energy and the Environment, Cornmittee on laterior and lasular Affairs, U.S. House of Representatives, hiiddletown, Pennsylvania, hiarch 29,1982, available from the Union of Concerned Scientists.
9 "Union of Conterned Scientists Detailed Comments on Petition for Rulemaking by Citizen's Task Force, Emergency Planning,10 CFR Parts 50 and 70, Docket No. PRhi.50-31,47 F.R, j
12639,* Union of Concerned Scientists, Washington, D.C., hiay 24,1982.
L 10.
Supplements to the Testimony of Ellyn R. Weiss, Esq., General Counsel, Union of Concerned Scientists, before the Subcommittee on Energy Conservation and Power, Committee on Energy --
and Commerce, U.S. House of Representatives, Union of Concerned Scientists, Washingt I
D.C., August 16,1982.
11.
Testimony of Steven C Sholly, Union of Concerned Scientists, Washington, D.C., on behalf of the New York Public Interest Research Group, Inc., before the Special Committee on Nuclear Power Safety of the Assembly of the State of New York, hearings on 1.4@lative Oversight of the Emergency Radiologic Preparedness Act, Chapter 708, Laws of 1981, September 2,1982.
12.
' Comments on ' Draft Supplement to Final Environmental Statement Related to Construction and Operation of Clinch River Breeder Reactor Plant',' Docket No. 50-537, Union of Concerned Scientists, Washington, D.C., September 13,1982.
- 13.
"Union of Concerned Scientists Comments on ' Report to the County Commissioners', by the Advisory Committee on Radiological Emergency Plan for Columbia County, Pennsylvania,"
Union of Concerned Scientists, Washington, D.C, September 15,1982.
14.
' Radiological Emergency Planning for Nuclear Reactor Accidents,' presented to Kernenergic Ontmanteld Congress, Rotterdam, The Netherlands, Union of Concerned Scientists, Washington, D.C, October 8,1982.
15.
' Nuclear Reactor Accident Consequences: Implications for Radiological Emergency Planning presented to the Citizen's Advisory Committee to Review Rockland County's Own Nuclear Evacuation and Preparedness Plan and General Disaster Preparedness Plan, Union of l
Concerned Scientists, Washington, D.C., November 19,1982, t
16.
Testimony of Steven C Sholly before the Subcommittee on Oversight and Investigations, Committee on Interior and lasular Affairs, U.S. House of Representatives, Washington, D.C.,
Union of Concerned Scientists, December 13,1982.
i 17.
i Testimony of Gordon R. Thompson and Steven C Sholly on Commission Question Two, i
Contentions 2.1(a) and 2.1(d), Union of Concerned Scientists and New York Public Interest
{
Research Group, before the U.S. Nuclear Regulatory Commission Atomic Safety and Licensin Board,in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) and
~
the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos. 50-247 SP and 50 286-SP, December 28,1982.
- 18.
Testimony of Steven C. Sholly on the Consequences of Accidents at Indian Point (Commission Ouestion One and Board Ouestion 1.1, Union of Concerned Scientists and New York Public Interest Research Group, before the U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) and the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos.
50 247 SP and 50 286-SP, February 7,1983, as corrected February 16,1983.
- i 19.
Testimony of Steven C Sholly on Commission Question Five, Union of Concerned Scientists and New York Public laterest Research Group, before the U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in the hiatter of Consolidated Edison a
Company of New York (Indian Point Unit 2) and the Power Authority of the State of New York l
(Indian Point Unit 3), Docket Nos. 50-247.SP and 50-286.SP, March 22,1983
- 20.
' Nuclear Reactor Accidents and Accident Consequences: Planning for the Worst,' Union of Concerned Scientists, Washington, D.C presented at Critical Mass '83, March 26,19S3.
s I
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4-4 J
. - _ - _ _.. _ _ _,,..._ ____. _ _ _ _ _ _.._.-,_ _ _ ~,-_ _, _. - _. _. _
I 21.
Testimony of Steven C. Shouy on Emergency Planning and Preparedness at Commercial Nuclear Power Plants, Union of Concerned Scientists, Washington,D.C., before the Subcommittee on Nudear Regulation, Committee on Environment and Public Works, U.S.
Senate, April 15,1983, (with ' Union of Concerned Scientists' Response to Questions for the Record from Senator Alan K. Simpson,' Steven C. Sholly and Michael E. Faden).
22.
'PRA:
What Can it Reauy Teu Us About Public Risk from Nuclear Accidents?,' Union of Concerned Scientists, Washington, D.C., presentation to the 14th Annual Meeting, Seacoast Anti Pollution League, May 4,1983.
23.
"Probabilistic Risk Assessment: The Impact of Uncertainties on Radiological Emergency Planning and Preparedness Considerations,' Union of Concerned Scientists, Washington, D.C.,
June 28,1983.
24.
"Response to GAO Questions on NRC's Use of PRA,' Union of Concerned Scientists, Washington, D.C., October 6,1983, attachment to letter datcJ October 6,1933, from Steven C.
Sholly to John E. Bagnulo (GAO, Washington, D.C.).
25.
The Imoset of ' External Events' on Radiolocical Emercenev Re<nonse Plannine Considerations. Union of Concerned Scientists, Washington, D.C., December 22, 1983, attachment to letter dated December 22,1983, from Steven C. Sholly to NRC Commissioner James K. Asselstine.
26.
Sizewell'B' Public Inquiry, Proof of Esidence on: Saferv and Waste Manneement Imoliestions of the Si7ewell PWP, Gordon Thompson, with supporting evidence by Steven Sholly, on behalf of the Town and Country Planning Association, February 1984, induding Annex G, "A resiew of Probabilistic Risk Analysis and its Application to the SizeweU PWR," Steven Shouy and Gordon Thompson, (August 11, 1983), and Annex O, "Emergency Planning in the UK and the US: A Comparison,' Steven Shouy and Gordon Thompson (October 24,1983).
27.
Testimony of Steven C. ShoUy on Emergency Planning Contention Number Eleven, Union of Concerned Scientists, Washington, D.C., on behalf of the Palmetto Alliance and the Carolina Ensironmental Study Group, before the U.S. Nudear Regulatory Commission Atomic Safety and Licensing Board,in the Matter of Duke Power Company, et. al. (Catawba Nuclear Station, Units 1 and 2), Docket Nos. 50 413 and 50-414, April 16,19S4.
- 28.
"Risk Indicators Relevant to Assessing Nuclear Accident Liability Premiums' in Preliminary Renort to the Indeoendent Adsitory Committee to the NAIC Nuclear Rick Task Force.
December 11,1934, Steven C. Sholly, Union of Concerned Scientists, Washington, D.C.
29.
' Union of Concerned Scientists' and Nudear Information and Resource Senice's Joint Comments on NRC's Proposal to Bar from Licensing Proceedings the Consideration of Earthquake Effects on Emergency Planning,' Union of Concerned Scientists and Nuclear Information and Resource Senice, Washington, D.C., Diane Curran and Ellyn R. Weiss (with input from Steven C. Sholly), February 28,19SS.
- 30.
- Severe Accident Source Terms: A Presentation to the Commissioners on the Status of a Res of the NRC's Source Term Reassessment Study by the Union of Concerned Scientists,' Union of Concerned Scientists, Washington, D.C April 3,1985. '
S-
31.
- Severe Accident Source Terms for Light Water Nuclear Power Plants: A Presentation to the Illinois Department of Nuclear Safety on the Status of a Resiew of the NRC's Source Term Reassessment Study (STRS) by the Union of Concerned Scientists," Union of Concerned Scientists, Washington, D.C., hiay 13,1985, 32.
The Source Term Debate A Resiew of the Current Bath for Predictinc Severe Acci Terms with Snecial Emnhasis on _the NRC Source Term Reassessment Procram (
Q920, Union of Concerned Scientists, Cambridge, hiassachusetts, Stevea C. Sholly and Gordon Thompson, January 1986.
33.
Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price, and Steven C.
Sholly on behalf of State of C(enecticut Department of Public Utility Control, Prosecutorial Division and Disision of Consumer Counsel, regarding the prudence of expenditures on hiillstone Unit III, February IS,1986.
M.
Implications of the Chernobyl 4 Accident for Nuclear Emergency Ptanning for the State of New York, pre,nated for the State of New York Consumer Protection Board, by hfHB Technical Associates, June 1986.
35.
Review of Vermont Yankee Containment Safety Study and Analysis of Containment Ventine Issues for the Vermont Yankee Nuclear Power Plant. prepared for New England Coalition on Nuclear Pollution, Inc., December 16,19S6.
36.
Affidavit of Stuen C. Sholly before the Atomic Safety and Licensing Board, in the matter of Public Senice Company of New Hampshire, et al., regarding Seabrook Station Units 1 and 2 Off site Emergency Planning Issues, Docket Nos. 50-443-OL & $0-444-OL, January 23,1987.
37.
Direct Testimony of Richard B. Hubbard and Steven C. Sholly on behalf of California Public Utilities Commission, regarding Diablo Canyon Rate Case, PG&E's Failure to Establish its Committed Design OA Program, Application Nos. 84-06-014 and 85-08-025, Exhibit No.10,93 hiarch,19S7.
3S.
Testimony of Gregory C. hiinor, Steven C. Sholly et. al. on behalf of Suffolk County, regar LILCO's Reception Centers (Planning Basis), before the Atomic Safety and Licensing Board, the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, Docket No. 50-322-0L 3, April 13,19S7.
39.
Rebuttal Testimony of Gregory C. hiinor and Steven C. Sholly on behalf of Suffolk Count regarding LILCO's Reception Centers (Addressing Testimony of Lewis G. Hulman), Docket No. 50-322 OL-3, hia) 27,19S7.
40.
Resiew of Selected Aspects of NUREG 1150, "Reactor Risk Reference Document,' prepared for the Illinois Department of Nuclear Safety by hiHB Technical Associates, September 1987.
41.
Direct Testimony of Richard B. Hubbard and Steven C. Sholly on behalf of the Pennsylvania Office of Consumer Advccate, before the Pennsylvania Public Utility Commission, Evaluation of Beaver Valley Unit 2 Plant Costs, OCA Statement 6, Docket No. R-870651, October 23,19S7 42.
Final Report:
Sicnificant Factors Affectinc the Cost of Beaver Vallev Power Station. Unit 2, prepared for Pennsylvania Office of Consumer Advocate, by htHB Technical Associates, OCA Exhibit 6A, October 19S7.
-6
43.
Surrebuttal Testimony of Richard B. Hubbard and Steven C. Sholly before the Pennsyl Public Utility Commission, on behalf of the Pennsylvania Office of Consumer Advocat regarding Evaluation of Beaver Valley Unit 2 Plant Costs, OCA Statement 6-1, Docket No. R.
870651, December 7,1987.
Available from the U.S. Nuclear Regulatory Commission, Public Document Room, Lobb 1717 H Street, N.W., Washington, D.C.
i 7
i I
h ATTACHMENT 3
ATTACHMENT 3 OPIP 3.6.1 Page 44c of 44 Att ac hment 7 Page 1 of 3 EVACUATION TIME ESTIMATE SENSITIVITY STUDY 0 - 5 Mile Evacuacion Zones A - J 10 - 20*
EVACUATION CONTROLLED /*
PERCENT
- MILE TIME SEASON
- WEATHER
- UNCONTROLLED COMPLIANCE SHADOW (HOURS)
Summer Normal Cont rolled 100%
0%
4.92 Summer Adverse Cont rolled 100%
0%
5.75 Summer Normal Uncont rolled 100%
0 5.06 Summer Adverse Uncont rolled 100%
0%
5.83 Winter Normal Cont rolled 100%
0%
4.42 Wint er Adverse Cont rolled 100%
.................................................. 0%
5.63 Winter Normal Unc ont rolled 100%
0%
4.58 Winter Adverse Uncont rolled 100%
0%
6.00 Summer Normal Cont rolled 50%
.................................................. 0%
4.42 Sumser Normal Unc ont rolled 50%
0%
4.75 0 - 10 Mile Evacuation Zones A - S Summer Normal Cont rolled 100%
0%
5.08 Summer Adverse Controlled 100%
0%
6.00 Summer Normal Uncontrolled 100%
0 5.67 Summer Adverse Uncontrolled 100%
0%
6.83 Winter Normal Cont rolled 100%
0%
4.56 Winter Adverse Cont rolled 100%
0 6.17 Winter Nor=al Uncontrolled 100%
0%
5.17 Winter Adverse Unc ont rolled 100%
0%
7.08 Summer Normal Cont rolled 100 25%
5.58
- See definition on page 3 of this attachment.
Rev. 5
OPIP 3.6.1 Page 44d of 44 Att ac hment 7 Page 2 of 3 EVACUATION TIME ESTIMATE SENSITIVITY STUDY (continued) 0 - 10 Mile Evacuation Zones A - S 10 - 20*
EVACUATION CONTROLLED /*
PERCENT
- MILE TIME SEASON
- VEATHER*
UNCONTROLLED COMPL7ANCE
_ SHADOW
_(HOL%S)
Summer Normal Cont rolled
- 1007, 507, 7.00 Summer Normal Uncontrolled 1007.
2 57.
6.00 Summer Normal Unc ont rolled
..................................... 1007.
- 507, 7.00 Wint er Adverse Unc ont rolled 100%
50%
6.06 Summer Normal Cont rolled with 100%
07, 5.06 t
4 Accident s Summer Normal Cont rolled wit h 100%
07.
5.08 4 Accidents Summer Normal Cont rolled
......................................757.
07, 5.42 Summer Nor=al Controlled 5 07.
07, 5.42 Summer Normal Uncont rolled 757 07, 6.00 Summer Normal Uncont rolled 5 07.
07, 6.42
- See definition on page 3 of this attachment.
I
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Rev. 5 i
OPIP 3.6.1 Page 44e of 44 Att ac hment 7 Page 3 of 3 EVACUATION TIME ESTIMATE SENSITIVITY STUDY (cont inued)
Definit ions Season:
Sum =er - Additional population in EPZ from Memorial Day to Labor Day Winter - All other times Weather:
Normal - Dry roads Adverse - Wet roads or partially snow covered Cont rol :
Controlled - LERO Traffic Guides in place Uncontrolled - No Traffic Guides Compliance:
Percent of population following prescribed evacuation routes Shadow:
Percent of population between 10 and 20 miles of Shoreham who evacuate i
Rev. 5
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3 466
G i
i a
ATTACHMENT 5
O 6
.,l TABLE 1 TYPE OF SHELTER (Shielding Factors)
CHANCES OF RECEIVING HEALTH THREATENING DOSES
- AT GIVEN DISTANCES FROM TME PLANT b 30 Rem
) 100 Rem
)200 Rem 1-2 mi.
10 mi.
1-2 mi.
10 mi.
1-2 mi.
LILCO Average for 301 12%
94
~ 11 21 Long Island Housing (0.7 cloud, 0.2 ground)
Wood Frame 30%
151 204 14
'2%
without Basement (0.9 cloud, 0.4 ground)
Maconry or Brick 304 84 5%
<lt**
lt 1/2 with Basement (0.5 cloud, 0.1 ground)
Vehic.ies 354 15s (1.0 cloud, 0.7 ground)
< lt Calculated for a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> exposure except for vehicles where 2 hrs 14 chance of doses exceeding 100 rems at 5 miles exposure was used
.O
-8 m
gELAJED CORRESPONDEN91 198biffk May 6, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 16 MY 10 P6.5 Before the Atomic Safety and Licensina Board 0FV!CE.
00CXibbsi
.jo Brag.
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of DIRECT TESTIMONY OF GREGORY C. MINOR AND STEVEN C. SHOLLY ON BEHALF OF SUFFOLK COUNTY REGARDING "IMMATERIALITY" have been served on the following this 6th day of May, 1988 by U.S. mail, first class, except as otherwise indicated.
James P. Gleason, Chairman
- Mr. Frederick J. Shon*
Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washingtor.,
D.C.
20555 Washington, D.C.
20555 James F. Gleason, Chairman William R. Cumming, Esq.*
513 C11moure Drive Spence W. Perry, Esq.
Silver Spring, Maryland 20901 Office of General Counsel Federal Emergency Management Agency Dr. Jerry R.
Kline*
500 C Street, S.W.,
Room 840 Atomic Safety and Licensing Board Washington, D.C.
20472 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 W. Taylor Reveley, III, Esq.*
Hunton & Williams Fabian G. Palomino, Esq.
P.O. Box 1535 Richard J. Zahnleuter, Esq.*
707 East Main Street Special Counsel to the Governor Richmond, Virginia 23212 Executive Chamber, Rm 229 State Capitol Albany, New York 12224 i
I e
Joel Blau, LSq.
Anthony F. Earley, Jr.,
Esq.
Director, Utility Interventic.:
General Counsel N.Y. Consumer Protection Botrd Long Island Lighting Company Suite 1020 175 East Old Country Road Albany, New York 12210 Hicksville, New York 11801 E. Thomas Boyle, Esq.
Ms. Elisabeth Taibbi, Clerk Suffolk County Attorney Suffolk County Legislature Bldg. 158 North County Complex Suffolk County Legislature Veterans Memorial Highway Office Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 Mr. L. F.
Britt Stephen B.
Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S.
Nuclear Regulatory Comm.
195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C.
20555 Alfred L. Nardelli, Esq.
Hon. Patrick G. Halpin New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H.
Lee Dennison Building Room 3-118 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O.
Box 231 San Jose, California 95125 Wading River, New York 11792 Mr. Jay Dunkleburger Richard G. Bachmann, Esq.*
New York State Energy Office Edwin J. Reis, Esq.
Agency Building 2 Office of the General Counsel Empire State Plaza U.S.
Nuclear Regulatory Comm.
Albany, New York 12223 Washington, D.C.
20555 David A.
Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W.
43rd Street New York, New York 10036 l
l Douglas J. Hynes, Councilman Adjudicatory File l
Town Board of Oyster Bay Atomic Safety and Licensing Board Town Hall Panel Docket (ASLBP)
Oyster Bay, New York.11771' U.S. Nuclear Regulatory Commission Washington, D.C.
20555 L
.AA.'
l_
g Ronald R. Ross KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 By Federal Express 1 _
_