ML20209G660

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Affidavit of Gc Minor & Sc Sholly.* Presents Preliminary Assessment of Technical Work & Time Required to Permit Suffolk County to Respond Meaningfully to Lilco Request to Authorize Operation at 25% Power.Certificate of Svc Encl
ML20209G660
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 04/24/1987
From: George Minor, Sholly S
MHB TECHNICAL ASSOCIATES
To:
Shared Package
ML20209G621 List:
References
OL-3, NUDOCS 8705010033
Download: ML20209G660 (47)
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I Attcchment 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

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AFFIDAVIT OF GREGORY C. MINOR AND STEVEN C. SHOLLY Gregory C. Minor and Steven C. Sholly, being under oath, depose and say as follows:

1. (Minor) I received a BSEE in electrical engineering from the University of California at Berkeley in 1960 and a MSEE in electrical engineering from Stanford University in 1966. I have 27 years experience with nuclear power. In particular, for 16 years I was employed by the General Electric Company where I worked on matters relating to the design, construction and opera-tion 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 projects, many of them related to the probabilistic risk assessments ("PRAs") for nuclear power 8705010033 G70427 PDR ADOCK 05000322 O PDR

plants. These include a PRA for the Barseback Nuclear Plant in Sweden and contribution to a PRA for the Caurso plant in Italy, plus testimony in the Shoreham proceeding on dose projections resulting from computer-generated accident assessments and dose projections.

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 planning proceedings in this Shoreham litigation. I am a member of the Nuclear Power Plant Standards Committee of the Instrument Society of America, and I served as a peer reviewer with the NRC's TMI Accident Investigation Report. I am also co-holder of a patent on a nuclear monitoring system. Further, details ,

regarding my education, experience and professional qualifica-tions are included in my resume, which is affixed as Attachment A to this affidavit.

(Sholly) I am an Associate Consultant with MHB Technical Associates. I have more than five years experience in the performance and review of probabilistic analyses of nuclear power plant safety issues, including the review of PRA studies and the application 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 t

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Containment Performance Objectives (as part of 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 qualifica-tions is provided as Attachment B hereto.

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2. MHB Technical Associates has been requested by Suffolk County to perform a preliminary technical review of a recent filing by Counsel for Long Island Lighting Company ("LILCO"). In this filing, entitled "Long Island Lighting Company's Request for q Authorization to Increase Power to 25%" (the " Request"), LILCO requests NRC suthorization to operate the Shoreham Nuclear Power Station at power levels up to 25% of full power. The LILCO Request consists of 146 pages, plus 4 affidavits and 11 appendices. The Request is accompanied by a " Motion for Expedited Commission Consideration" (the " Motion"), in which LILCO urges that the NRC's review of the Request be " expedited" and that the NRC "promptly authorize 25% power operation for Shoreham." Motion at 3.

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3. The purpose of this affidavit is to present a prelim-inary assessment of the technical work and the time required to permit Suffolk County to respond meaningfully to the LILCO

. Request. We also address briefly some of the issues which are raised by LILCO's technical analyses and our view that the NRC

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lacks any proper basis at this time to accept LILCO's assertion that Shoreham can operate safely at 25% power despite the out-standing emergency planning deficiencies.

4. Based upon the preliminary analysis which we have conducted, we reach several conclusions:

(a) There are a great deal of data which necessarily underlie LILCO's Request but which are not included therein. These data must be obtained by Suffolk County and the NRC (the Staff has implied that they lack these data as well) before any detailed or meaningful technical review can proceed very far.

(b) The actual technical review of the LILCO Request will necessarily take a long period of time, given the complex and diverse analyses upon which LILCO relies.

Suffolk County will n9ed to retain additional experts to perform that review. We estimate that once the necessary data are obtained and the consultants are retained, the review will take at least 12 months, and perhaps as long as 18 months. It is certainly impos-sible for any entity -- and we include the NRC Staff --

to perform any kind of meaningful review in a short period.

F (c) Based upon our preliminary initial review, several critical issues can already be identified which cause us to question the bases for and merits of LILCO's Request. These include the question of how much credit is being assumed by LILCO for ATWS mitigation using the non-safety grade turbine bypass of 25% steam to the condenser (Request at p. 36). There also is doubt about whether all seismically-initiated failure modes have been included, whether high pressure melt ejection and direct containment heating have been correctly analyzed (such phenomena are capable, in principle, of resulting in early drywell failure and a substantial fission product release to the environment), and whether the added features claimed to improve safety at Shoreham, have been integrated into the plant systems, drawings, procedures, Technical Specifications, and training to ensure that they will be operated properly and that there are no "down-side risks" associated with their implementation. Although the Shoreham containment is intended to be inerted during full power operation, it is not required to be inerted during low power testing and power ascension. Thus, if the PRA assumes inerting, there must be some means of ensuring that the containment is inerted during sustained operation above power levels of St. There is also the question if LILCO is taking any technical credit for the containment filtered venting scheme which is not installed and apparently not even firmly committed to be constructed at Shoreham. (Request at p. 8, fn. 4).

There is also uncertainty about LILCO's reliance on containment venting as a means of mitigating accidents (agg Request at p. 39 and p. 45). There is also the question whether the reactor power level measurement that may be used for scram would be the IRM or the APRM, since both instruments are on scale at a 25%

power level. However, an APRM with a scram / trip point near full power would permit wider ranging transients before, stopping power excursions and causing a scram.

The PRA must account for these possibilities or the license must require lowered scram set points and specified instruments. Also, it is not clear how human error and sabotage have been considered as accident initiators and contributors to ineffective mitigation of accidents. Finally, it is unclear whether LILCO's analyses adequately account for effects such as aging, design and construction errors, and human errors of commission.

(d) Based upon our preliminary initial review of the Request, together with our knowledge of nuclear power plants more generally, we believe that there are acci-dents which can occur at 25% power which have the m

potential to result in significant offsite radiological consequences well beyond the one-mile circumference

which LILCO talks about in the Request. (Request at
p. 57). Given the inherent uncertainties in PRA analyses as well as the level of fission products available for release at 25% power operation, we believe there is no basis to conclude that the out-l standing licensing issues which are unresolved are insignificant for Shoreham at 25% power. Rather, we l

believe it would be contrary to the conservative l licensing principles relied upon in NRC practice to permit 25% operation in the absence of the full array of safety findings traditionally required for operation above 5% power.

l l Accordingly, it is our opinion that no basis exists upon which the NRC could justifiably grant expedited review of the LILCO Request. So-called " expedited" review would amount to almost no review at all, since a short review would result in little if any meaningful basis to judge the overall adequacy of the LILCO analyses. Accordingly, an " expedited" review could not l possibly be justified, unless the NRC were willing (which we hope is not the case) to license Shoreham without review and in a manner which departs significantly from the licensing criteria with which we are familiar. Rather, substantial technical issues tre presented such that a meaningful and thorough technical review clearly is necessary, assuming that the NRC decides to give the Request any consideration at all. Such a technical review, if directed by the NRC to be undertaken, could require as much as 12-18 months.

5. LILCO's Request to operate Shoreham at 25% power is accompanied by a summary of a PRA which purports to analyze such 25% power operation. This PRA is based in part on the LILCO PRA completed in 1983, and with which we are familiar. However, to a large extent, the LILCO Request is based on entirely new work which has not been heretofore publicly disclosed. We understand from news articles that the underlying technical studies upon which LILCO's Request relles were some 18 months in preparation.1 The information provided in LILCO's Request and accompanying affidavits and appendices is devoid of the sort of information which is required in order to conduct a meaningful review of the Request on its merits. Only summary results of most phases of the risk assessment were provided; none of the underlying detail is provided. Yet, it is precisely this underlying detail that must be reviewed to assess the technical merits of LILCO's l Request.

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1 Mr. Museier, a LILCO official, is reported in Newsday to l

i have stated that LILCO has been working on the Request for 18 '

i months. Newsday, April 14, 1987, p. 25.

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6. The LILCO Request references but does not include numerous technical studies which underlie the technical aspects of LILCO's Request. These underlying technical studies are reported to include at least the following:

(a) Delian Corporation, "Probabilistic Risk Assessment of the Shoreham Nuclear Power Station -- Initial Power Operation Limited to 25% of Full Power," 2-R-87-013 (March 1987).

(b) NUS Corporation, " Major Common-Cause Initiating Events Study -- Shoreham Nuclear Power Station," NUS-4617

! (February 1985).

(c) NUS Corporation, " Major Common-Cause Initiating Events (MCCI) Contribution to Shoreham Nuclear Power Station Core Damage Frequency: Early Plant Operations at 25%

Power," NUS-4842 (March 1987).

(d) E.T. Burns, et al., " Individual Plant Evaluation Methodology (IPEM), Delian Corporation, IDCOR, Revision i

2 (March 1987)

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r-(e) NUTECH Engineers, Inc., " Evaluation of Typical RHR and CS Injection Class 2 Piping to Withstand a Maximum Postulated Intersystem LOCA; Shoreham Nuclear Power Station Unit 1" (December 1986).

(f) 2.T. Mendoza, et al., " Containment and Phenomenological Event Tree Evaluation at 25% Power Level for the Shoreham Emergency Planning Study," Science Applications International Corporation, SIC-87/1563 (March 1987).

(g) Fauske & Associates, " Severe Accident Analysis of the Shoreham Nuclear Power Station -- 25% Power," FAI/87-14 (March 1987).

(h) Stone & Webster, Inc., " Containment Structural ,

Analysis," (June 1986).

(1) Stone & Webster Engineering Corporation, " Environmental Source Terms for Three Shoreham Severe Accidents Initiated from 25 Percent Power" (April 1987).

The foregoing list may not necessarily include all the additional documents which must be reviewed. For example, although several references were made to calculations performed using the MCT and SWNAUA codes (att Request at Appendix 7, page 2), no report was cited as the source for these calculations.

Similarly, although extractions from the review group findings are included in the Request, there is no documentation provided of the extent, depth or detailed findings of the reviewers.

7. The work performed by or for LILCO which underlies the 25% power operation Request corresponds to the principal tasks of a full-scope PRA. It is well-recognized that the review of such a study (particularly where, as in this case, novel analytical methods and assumptions were employed) is a difficult and time-consuming process. Moreover, the results of the PRA itself are necessarily associated with large uncertainties, whether explicitly identified or not. A PRA review is a major undertaking even under the best of circumstances, i.e., when the utility and its consultants cooperate with the review, when there is reasonable access to the plant, plant documentation, emergency procedures, etc., when computer codes are provided or are well-known, when input decks for the codes used in the study are provided to the reviewers to facilitate the review process, and when there is access to plant personnel and the utility's PRA consultants to answer questions, provide clarifications, and provide documents. He have concern whether these conditions will be met in connection with the County's review of the LILCO Request. Based upon our experience with LILCO, particularly over the last 5 years, it must be expected that LILCO will resist, at least to some degree, providing the foregoing data and access to

County consultants. This may result in the need for counsel to become involved in filing motions, etc., to obtain the data and access to the plant and personnel which are reqired in order to conduct a thorough review. Thus, it is reasonable to conclude that a proper technical review of the LILCO data which underlie LILCO's 25% power Request will be even more time-consuming than would normally be expected.

Further, LILCO's analyses involve alternative and convoluted interrelationships between several consultants' studies. (Eng Figure II.C.1-1, Request ff. p. 18). This necessitates a detailed review to ensure that the assumptions or bases for each individual study are consistent and non-contradictory with respect to the results of other studies. Again, this will necessarily increase the time required for a careful review.

8. To provide some perspective on the amount of work involved in a minimally-adequate PRA review, Brookhaven National Laboratory ("BNL") has estimated that about 24-40 man-months of technical work would be required to review the portion of a PRA up through core damage, but n21 including accident phenomenology, containment failure analysis, source term assessment, and acci-dent consequence analysis. This level of effort was described by BNL as a "necessary minimum" for this type of review. A. El-Bassioni, et al., PRA Review Manual, Brookhaven National Laboratory, NUREG/CR-3485, BNL-NUREG-51510, September 1985, Section 1.3. For a review of a full-scope PRA study (including containment, source terms, and consequences), the NRC Staff's l

review of the Indian Point PRA required approximately one year to complete (and this review had the full cooperation of the utility and its consultants). It should be further noted that attempting to perform such a review on a shorter schedule by adding addi-tional analysts causes inefficiencies in the review process that l

1 require greater expenditures of resources than indicated here.

9. In order to perform a technically-adequate review of the LILCO 25% power Request, Suffolk County's consultants will require access to a large variety of documentation from LILCO and its consultants. Among the documents and data necessary for the review are the following:

(a) All of the reports and documents cited in Item 6, [

above.

(b) Access to the data base (s) upon which the accident sequence frequency calculations are based, or access to an equivalent data base (compilation of our own data  ;

base from available generic data will require much more time and effort).

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e (c) Access to documentation describing the analytical assumptions used in the various analyses and justifica-tion for the parameter values employed in the computer analyses.

(d) Access to the plant for one or more extended site inspections for the purpose of walking down plant systers, taking necessary measurements, and photo-graphing the plant as required.

(e) Access to all current plant operating procedures and emergency procedures and revisions thereto as they are issued.

(f) Access to and permission to utilize proprietary computer codes (MAAP-3.0 and MCT/SWNAUA) or use of arguably comparable codes (the latter will require considerable effort to assure that code inputs and code capabilities of the proprietary codes are well under-stood).

(g) Access to plant systems manuals, electrical diagrams, plant drawings, and containment structural materials reports.

(h) Technical specifications and license conditions intended to be used during operations at 25% power.

(1) Test and maintenance practices and procedures.

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  • Access to LILCO and LILCO consultant personnel to discuss their findings, assumptions, and other similar matters. (It is not possible to condact a careful review of a PRA without extensive personal interaction with the persons who performed the studies, since the studies and raw data necessarily need extensive expla-nation during the course of the review).
10. In order to perform the necessary review of the technical aspects of the Request, the County will require the services of a number of consultants. Among the consultants required are consultants with expertise in containment structural analysis, seismic design, PRA quantitative methods (data analysis), seismologists and other geo-specialists for the purpose of reviewing the seismic risk assessment, meteorologists (to review the consequence assessment and the severe winds risk assessment), severe accident phenomena specialists (physical chemist, physicists, etc.), human reliability professionals (to examine the human error contribution to risk), and professionals r

e to serve in QA and technical review roles. Thus, many consultants will need to be identified and retained -- a task which will require some time.

11. A four-step review process will be necessary in order to perform a technically adequate review of the LILCO 25% power Request PRA.2 Due to the interactive nature of the review work and LILCO's analyses, only limited parallel work for these tasks can be accomplished and thus considerable time will be required in order to complete the review. The four necessary steps ares (a) Front End Analysis of Data and Assumntions -- This step is a painstaking, detailed review of the accident sequence definition, PRA data analysis, fault tree and event tree analysis, and external events sequence analyses, including system analysis, system walkdowns, and human reliability analysis. By doing this, we verify or correct the initial data and assumptions in the analysis. The end product of this Phase will be a set of quantified accident sequence likelihoods and recommended accident sequence binning for review and refinement in the next Phase. The steps involved in this front-end analysis include the following:

2 The steps described herein are our preliminary view. Once all the LILCo data have been obtained, we would expect to refine and modify the work plan. It is unlikely that the refinement /

modificat;,ons would materially alter the schedule we have estimated for a careful review.

(1) Review Data Analysis - Compare the LILCO assumptions and data with operational data for the first two years of operation of other BWR's to see if LILCO adequately addressed not only " burn-in" period hardware failures but also well-recognized high human error rates during initial power operations.3 (2) Review Event and Fault Trees - Compare Brookhaven National Laboratory review of the original LILCO PRA to see if errors were corrected; review technical specifications for 25% power to see if Allowable Outage Times ("AOTs") and Limiting Conditions for Operation ("LCOs") permit systems to be out of service to a greater extent than for 100%

power (and, if so, quantify the impact on system availability).

(3) Review Human Reliability Analysis - Assure that seismic sequences appropriately reflect the higher level of stress on operations' personnel; assure that longer times asserted 3 There is an inherent unreliability in power production from nuclear power plants entering operation, conducting low power tests, and experiencing equipment break-in or infant failures.

This fact contradicts LILCO's argument that the use of Shoreham will relieve summer peaks in 1987.

to be available for mitigating actions are not in fact partially or wholly used up by confusion in sequence diagnosis, a more relaxed response, etc.

(4) Review external events secuence analysis, hazard curves, and fracility curves (includina all asoects above as they are affected by seismic events).

(5) Recuantification based on our analysis --

1 reflecting changes in the accident sequence frequencies based on our review above.

(6) Binnina based on our analysis -- recommended grouping of accident sequences into classes of accidents which should cause similar impacts on the plant.

l j (b) Severe Accident Phenomenoloav, Containment Event, and Source Term Assessments - This is a detailed assessment of the progression of severe accidents, including an I

analysis of sources and magnitudes of containment loads, modes, and likelihoods of containment failure, evaluation of source terms, and performance of an

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accident consequence analysis. At this point, the basic numerical data are reviewed and their validity verified or challenged. The steps involved include the following:

(1) Review methods, assumotions, inout carameters, and user-soecified values for code calculations - Are the assumptions and code inputs justified? Are other reasonable assumptions equally plausible?

(2) Review chenomena assessment - Did the PRA 9

treat hydrogen burns (both in primary containment if de-inerted and in secondary containment), steam explosions (in-vessel and ex-vessel), high pressure melt ejection, re-evolution of deposited fission products, suppression pool flashing upon containment failure, etc.

(3) Review containment loads - Does the PRA adequately justify the loads and sources?

Are there sources of loads that have been missed?

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l (4) Review structural analysis of containment site resocnse to loads - What type of analysis was done? Were penetrations considered? Were seismic aftershocks I

considered in conjunction with loads from an accident in progress?

l (5) Review source term analysis - data, methods, assumotions - How does the analysis compare with IDCOR and NUREG 1150 methods?

(6) Recuantify containment event tree and calculate source term nrobabilities, '

(7) Re-Bin - Based on similar effects on plant and/or similar release characteristics.

I (c) Uncertainty Analysis and Comoarison of Risks of 25%

Power Ooeration of Shoreham with risks from other olants and Shoreham at Full Power -- This Phase will require perhaps the bulk of the study, requiring detailed uncertainty and sensitivity analyses to analyze the conclusions drawn in the study as a whole.

This is the most important analysis in that it l

assembles all the other results and produces an integrated view of the impact of changes or revisions l

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found necessary in the earlier reviews. At this point, it would be necessary to compare our findings to those of the LILCO Review Group. The steps involved include the following:

(1) Safety coal comoarison.

(2) Inter-olant comoarison - How does Shoreham at 25% power compare with other plants?

(3) Comoarison with 5% cower and 100% oower - How do 25% power risks compare with previous risk estimates at 5% power and 100% power?

(4) Comoarison with NUREG 0396 (5) Uncertainties and sensitivities.

(a) Frecuency - How large are the uncertain-ties on accident sequence frequencies, containment event tree split fractions, and source term frequencies?

I (b) Loads - How large are containment loads uncertainties? Could they affect binning or source term calculations?

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(c) Containment response - What is the uncertainty in containment failure pressure? Have possible design and construction errors been accounted for?

(d) Cgntainment failure mode and timino.

(e) Phenomena - What uncertainties exist in modeling events such as steam explcsions, high pressure melt ejection, etc.? Are these phenomena affected by 25% power operation?

(f) Source terms - What are the uncertain-ties in source term estimates (including release magnitudes, warning time, release elevation, release energey, etc.)?

l (g) Modelino l

(h) Consecuences - Do the analyses account for new health effects models in the MACCS code? Are the effects of external events (e.a., seismic) properly reflected in emergency response 6

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I modeling? Do the conclusions expressed in the text accurately reflect the technical data derived in the ccmputer printouts. Are the various reports consistent.

(d) Report writina.

12. The above steps are essential if the review is to be useful and technically well founded. The various computer codes are opaque to full understanding without such detailed review, including an understanding of the sources and magnitudes of the uncertainties. Unless the details and assumptions are reviewed, the LILCO conclusions cannot be viewed as meaningful or verified.
13. We estimate that the minimum schedule for the above-described analysis would require at least one year, and may require as long as 18 months, i.e., at least as long as it took LILCO to prepare the Request. Considering the possible lack of cooperation with the County by LILCO and LILCO's consultants, even this schedule may be optimistic.

Certainly, no meaningful review whatever of the technical aspects of LILCO's Request could be completed this summer to permit Shoreham operation during the Long Island peak load period. In view of the fact that LILCO has acknowledged that it

has been working on the Request for 18 months, no one can seriously contend that any kind of meaningful review can be undertaken prior to this summer.

14. Even in advance of performing the detailed review described above, we believe there are significant technical issues which are identifiable which should make the NRC extremely wary of the LILCO Request. Egg paragraph 4(c) above. And we similarly conclude that at 25% power, the potential exists for accidents with far more severe radiological consequences to distances greater than the one-mile circumference discussed in the Request. Egg paragraph 4(d) above.

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Subscribed to before me this ~ day of April 1987.

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Attachment A s

PROFESSIONAL QUALIFICATIONS OF GREGORY C. MINOR GREGORY C. MINOR MHB Technical Associates 1723 Hamilton 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 organi-zations and individuals. 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 Reactor Safety Study (WASH-1400) for the Union of Con-cerned 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 in-volved in the Nuclear Power Plant Standards Committee work for the In-strument Society of America (ISA).

1972 - 1976 Manager, Advanced Control and Instrumentation Enoineering, General Elec-tric Company, Nuclear Energy Division, San Jose, California Managed a design and development group of thirty-four engineers and sup-port 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 con-trol / programming, and equipment qualification.

1970 - 1972 Manager, Reactor Control Systems Design, General Electric Company, Nu-clear Energy Division, San Jose, California Managed a group of seven engineers and two support personnel in the de-sign and preparation of the detailed system drawings and control docu-r .

ments relating to safety and eraergency systems for nuclear reactors.

Responsibility required coordination with other design organizations and interaction with the customer's engineering personnel, as well as regu-latory personnel.

1963 - 1970 Design Engineer, General Electric Company, Nuclear Energy Division, San Jose, California Responsible for the design of specific control and instrumentation sys-tems for nuclear reactors. Lead design responsibility for various sub-systems of instrumentation used to 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 nuclear reactors. Other responsibilities included on-site checkout and testing of a complete reactor control system at an experi-mental reactor in the Southwest. Received patent for Nuclear Power Mon-itoring System.

1960 - 1963 Advanced Engineering Program, General Electric Company, Assignments in Washington, California, and Arizona Rotating assignments in a variety of disciplines:

Engineer, reactor maintenance and instrument design, KE and D re-actors, Hanford, Washington, circuit design and equipment mainte-nance coordination.

Design engineer, Microwave Department, Palo Alto, California.

Work on design of cavity couplers for Microwave Traveling Wave Tubes (TWT).

Design engineer, Computer Department, Phoenix, Arizona. Design of core driving circuitry.

Design engineer, Atomic Power Equipment Department, San Jose, Cal-ifornia. Circuit design and analysis.

Design engineer, Space Systems Department, Santa Barbara, Califor-qia. Prepared control portion of satellite proposal.

Technical Staff - Technical Military Planning Operation. (TEMP 0),

Santa Barbara, Cal-ifornia. Prepare analyses of missile exchanges.

During this period, coupleted three-year General Electric program of extensive education in advanced engineering principles of higher mathematics, probability and analysis. Also completed courses in Kepner-Tregoe Effective Presentation, Management Training Program, and various technical seminars.

r EDUCATION University of California at Berkeley, BSEE, 1960.

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

I 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 l%nitoring System," February,1971.

Member: American Association for the Advancement of Science.

Member: Nuclear Power Plant Standards Committee, Instrument Soct-ety of America.

PERSONAL DATA Born: June 7, 1937 Married, three children Residence: San Jose, California PUBLICATIONS AND TESTIMONY

1. G. C. flinor, S. E. Moore, " Control Rod Signal Multiplexing," IEEE Trans-actions on Nuclear Science, Vol. NS-19, February 1972.
2. G. C. Minor, W. G. Milam, "An Integrated Control Room System for a Nu-clear Power Plant," NE00-10658, presented at International Nuclear In-dustries Fair and Technical Meetings, 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, Mas-sachusetts.
5. Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the California State Assembly Committee on Resources, Land Use, and En-ergy, 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.

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7. Testimony of G. C. Minor regarding the Grafenrheinfeld Nuclear Plant, March 16-17, 1977, Wurzbuerg, Germany.
8. Testimony of G. C. Minor before the Cluff Lake Board of Inquiry, Regina, Saskatchewan, Canada, September 21, 1977. -
9. The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Safety Study WASH-1400 (NUREG-75/0140), H. Kendall, et al, edited by G. C. Mi-nor and R. B. Hubbard for the Union of Concerned Scientists, August, 1977.
10. Swedish Reactor Safety Study: Barseback Risk Assessment, MHB Technical.

Associates, January, 1978. (Published by Swedish Department of Industry as Document Dsl 1978:1)

11. Testimony by G. C. Minor before the Wisconsin Public Service Commission, February 13, 1978, Loss of Coolant Accidents: Their Probability and Consequence.
12. Testimony by G. C. Minor before the California Legislature Assembly Com-mittee on Resources, Land Use, and Energy, AB 3108, April 26, 1978, Sacramento, California.
13. Presentation by G. C. Minor before the Federal Ministry for Research and Technology (BMFT), Meeting on Reactor Safety Research, Man / Machine In-terface in Nuclear Reactors, August 21, and September 1, 1978, Bonn, Germany.
14. Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard, before the Atomic Safety and Licensing Board, September 25, 1978, in the matter of Black Fox Nuclear Power Station Construction Permit Hearings, Tulsa, Oklahoma.
15. Testimony of G. C. Minor, ASLB Hearings Related to THI-2 Accident, Ran-cho Seco Power Plant, on behalf of Friends of the Earth, September 13, 1979.
16. Testimony of G. C. Minor before the Michigan State Legislature,'Special Joint Committee on Nuclear Energy, Implications of Three Mile Island Ac-cident for Nuclear Power Plants in Michigan, 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 Nuclear Reactor Safety, January 7,1980, San Francisco, California.
18. The Effects of Aging on Safety of Nuclear Power Plants, paper presented at Forum on Swedish Nuclear Referendum, Stockholm, Sweden, March 1, 1980.
19. Minnesota Nuclear Plants Gaseous Emissions Study, FMB Technical Associ- i ates, September 1980, prepared for the Minnesota Pollution Control Agency, Roseville, MN.

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20. Testimony of G. C. Minor and D. G. Bridenbaugh before the New York State Public Service Commission, Shoreham Nuclear Plant Construction Schedule, in the matter of Long Island Lighting Company Temporary Rate Case, September 22, 1980.
21. Systems Interaction and Single Failure Criterion MHB Technical Associ-ates, January,1981, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
22. Testimony of G. C. Minor and D. G. Bridenbaugh before the New Jersey Board of Public Utilities, Oyster Creek 1980 Refueling Outage Investiga-tion, in the matter of Jersey Central Power and Light Rate Case Febru-ary 19, 1981.
23. Testimony of G. C. Minor and D. G. Bridenbaugh on PORV's and Pressurizer Heaters, Diablo Canyon Operating License hearing before ASLB, January ll, 1982.
24. Testimony of G. C. Minor and R. B. Hubbard on Emergency Response Plan-

, Diablo Canyon Operating License hearing before ASLB, January 10,

25. Systems Interaction and Single Failure Criterion: Phase II Report, MHB Technical Associates, February 1982, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
26. Testimony of G. C. Minor, 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 78, Safety Classification and Systems Interaction, April 13, 1982.
27. Testimony nf 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 11, Passive Mechanical Valve Fail-ure, April 13, 1982.

28. Testimony of G. C. Minor and R. B. Hubbard on behalf of Suf folk County, before the Atomic Safety and Licensing Board, in the matter of Long Is-land Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 27 and SOC Contention 3, Post-Accident Moni-torina, 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 Program, May 25, 1982.
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 Suffolk County Contention 28(a)(vi) and S0C Contention 7A(6),

Reduction of SRV Challenges, June 14, 1982.

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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 Com-pany, Shoreham Nuclear Power Station Unit 1, regarding Environmental Qualification, 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, Regarding the Cost of Constructing the Susquehanna Steam Electric Sta-tion, Unit I, Re: Pennsylvania Power and Light, March 18, 1983.
33. Supplemental testimony of G. C. Minor, R. B. Hubbard, and M. W. Gold-smith on behalf of Suffolk County, before the Atomic Safety and Licens-ing Board, in the matter of Long Island Lighting Company, Shoreham Nu-clear Power Station, Unit 1, regarding Suffolk County Contention 7B, Safety Classification and Systems Interaction, March 23, 1983.
34. Testimony before the District Court Judge in the case of Sierra Club et.

al. vs. DOE regarding the Clean-up of Uranium Mill Tailings. June 20, 1983.

35. Systems Interaction and Single Failure Criterion: Phase 3 Report, MHB Technical Associatas, June,1983, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.
36. Systematic Evt luation Program: Status Report and Initial Evaluation, MHB Technical' Associates, June, 1983, prepared for and available from the Swedish Nuclear 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 Nuclear Power Station, Unit 1, regarding Emergency Planning Contentions 65, 23.D and 23.H, November 18, 1983.
38. Testimony of G. C. Minor, Sizewell 'B' Power Station Public Inquiry, Proof of Evidence Regarding 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 tio. 27563, in the matter of Long Island Lighting Company Proceeding to Investigate the Cost of the Shoreham Nuclear Generating Facility --

Phase II, on behalf of 0 .ity 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 Is-land Lighting Company, Shoreham Nuclear Power Station, Unit 1, on behalf of Suffolk County Regarding Emergency Planning Contention 61 (Sheltering), March 21, 1984.
41. 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 company, SSoreham Nuclear Power Station Unit 1, regarding EMD Diesel Generators and 20 MW Gas Turbine, March 21, 1984.

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42. Revised Testimony of Gregory C. Minor before the Atomic Safety and Li-censing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County regarding Emergency Planning Contentions 85 and 88 (Recovery and Reentry), 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 Is-land Lighting Company, Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County, regarding Low Power Hearings (Seismic Capabilities of AC Power Sources), July 1984.
44. Affidavit 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 Gregory C. Minor, Before the New York State Public Ser-vice Commission, PSC Case No. 27563, Shoreham Nuclear Station, Long Is-land Lighting Company, on behalf of Suffolk County and New York State Consumer Protection Board, regarding prudency of LILCO, 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 the prudency of expenditures by Fitchburg Gas and Electric Light Company on 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 Seabrook Unit 2, Docket No.84-113 December 21, 1984.
48. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor regarding Suffolk County's Emergency Diesel Generator Load Contention, 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 Department of Public Service, State of Vermont Public Service Board Docket No. 5030, Central Vermont Public Service Corporation, November 11, 1985.
50. 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 Division and Division of Con-sumer Counsel regarding the prudence of expenditures on Millstone Unit 3, February 18, 1986.

51. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding the prudence of expenditures by New England Power Co. on Seabrook Unit 2, February 21, 1986.
52. Direct Testimony of Gregory C. Minor on behalf of the Prosecutorial Di-vision of CDPUC regarding CL&P Construction Prudence for Millstone Unit 3, March 19, 1986.

F~

53. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding WMEco Construction Prudence for Millstone Unit 3, March 19, 1986.
54. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding WMECo's Commercial Operating Dates and Deferred Capital Additions on Millstone Unit 3. March 19, 1986.
55. Rebuttal Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding New England Power Company's Seabrook 2 Rebuttal, April 2,1986.
56. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of State of Maine Staff of Public Utilities Commission regarding Con-struction Prudence of Millstone Unit 3, April 21, 1986.
57. Implications of the Chernobyl-4 Accident for Nuclear Emergency Planning fcr the State of New York, prepared for the State of New York Consumer Protection Board, by MHB Technical Associates, June 1986.
58. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of the Vermont Department of Public Service, regarding Tariff Filing of Central Vermont Public Service Corporation Requesting a 12% Increase in Rates, Docket No. 5132, August 25, 1986.
59. Surrebuttal Testimony of Gregory C. Minor in the matter of Jersey Cen-tral Power and Light Company, regarding TMI Restart and Performance In-centives, OAL Docket No. PUC 7939-85, BPU Docket No. ER851116 September 11, 1986.
60. Surrebuttal Testimony of Gregory C. Minor on behalf of State of Vermont Ocpartment of Public Service, regarding CVPS/PSNH Construction Prudence of Millstone Unit 3 Docket No. 5132, November 6, 1986.
61. Direct Testimony of Gregory C. Minor and Lynn K. Price on behalf of State of Vermont Department of Public Service, regarding Seabrook 1 Costs, Docket No. 5132, December 31, 1986.
62. Direct Testimony of Gregory C. Minor on behalf of Suffolk County, before the Atomic Safety and Licensing Board, concerning Contention EX 36 --

Protective Action Recommendations, Docket No. 50-322-OL-5, February 27, 1987.

! 63. 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 l Board, concerning Contentions EX 15 and 16 -- the Scope of the Exercise, Docket No. 50-322-0L-5, April 6, 1987.

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&* , Attachment B s

PROFESSIONAL QUALIFICATIONS 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 discovery process in regulatory proceedings, develop testimony and other documents for regulatory proceedings, and respond to client inquiries.

Clients have included: State of California, State of New York, State of Illinois.

February 1981 - September 1985 Technical Research Associate and Risk Analyst - Union of Concerned Scien-tists, Washington, D.C.

Research associate and risk analyst for public interest group based in Cambridge, Massachusetts, that specializes in examining the impact of ad-vanced technologies on society, principally in the areas of arms control and energy. Technical work focused on nuclear power plant safety, with emphasis on probabilistic risk assessment, radiological emergency planning and preparedness, and generic safety issues. Conducted research, prepared reports and studies, participated in administrative proceedings before the U.S. Nuclear Regulatory Commission, developed testimony, anlayzed 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 (1985), the Panel on Regulatory Uses of Probabilistic Risk Assessment (Peer Review of NUREG-1050; 1984), Invited Observer to NRC Peer Review meetings on the source term reassessment (BMI-2104; 1983-1934), and the Independent Advi-sory Committee on Nuclear Risk for the Nuclear Risk Task Force of the National Association of Insurance Commissioners (1984).

January 1980 - January 1981 Project Director and Research Coordinator - Three Mile Island Public Interest Resource Center, Harrisburg, Pennsylvania Provided administrative direction and coordinated research projects for a public interest group 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 Com-mission, U.S. Department of Energy, and General Public Utilitics activi-ties 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 financial health of General Public Utilities, and NRC rulemaking actions related to Three Mile Island.

July 1978 - January 1980 Chief Biological Process Operator - Wastewater Treatment Plant, Derry Tcwnship Municipal Authority, Hershey, Pennsylvania Chief Biological Process Operator at a 2.5 million gallon per day ter-tiary, activated sludge, wastewater treatment plant. Responsible for bi-ological process monitoring and control, including analysis of physical, chemical, and biological test results, procees fluid and mass flow man-agement, micro-biological analysis of activiated sludge, and maintenance of detailed process logs for input into state and federal reports on treatment process and effluent quality. Received certification from the Commonwealth of Pennsylvania as a wastewater treatment plant operator.

Member of Water Pollution Control Association of Pennsylvania, Central Section, 1980.

July 1977 - July 1978 Wastewater Treatment Plant Operator - Borough of Lemoyne, Lemoyne, Penn-sylvania Wastewater treatment plant operator at 2.0 million gallon per day sec-ondary, activated sludge, wastewater treatment plant. Performed tasks as assigned by supervisors, including simple physical and chemical tests on wastewater streams, maintenance and operation of plant equipment, and maintenance of the collection system.

September 1976 - June 1977 Science Teacher - West Shore School District, Camp Hill, Pennsylvania Taught Earth and Space Science at ninth grade level. Developed and im-plemented new course materials on plate tectonics, environmental geology, and space science. Served as Assistant Coach of the district gymnastics team.

O September 1975 - June 1976 Science Teacher - Carlisle Area School District, Carlisle, Pennsylvania Taught Earth and Space Science and Environmental Science at ninth grade level. Developed and implemented new course materials on plate tecton-ics, environmental geology, noise pollution, water pollution, and energy.

Served as Advisor to the Science Projects Club.

EDUCATION:

B.S., Education, majors in Earth and Space Science and General Science, minor in Environmental Education Shippensburg State College, Shippens-burg, Pennsylvania, 1975.

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

PUBLICATIONS:

1. " Determining Mercalli Intensities from Newspaper Reports," Journal of Geological Education, Vol. 25, 1977.
2. A Critique of: An Independent Assessment of Evacuation Times for Three liile Island Nuclear Power Plant. Three Mile Island Public Intere st Resource Center, Harrisburg, Pennsylvania, January 1981.
3. A Brief Review and Critique of the Rockland County Radiological Emergency Preparedness Plan, Union of Concerned Scientists, prepared for Rockland County Emergency Planning Personnel and the Chairman of the County Legis-lature. Washington, D.C., August 17, 1981.
4. The Necessity for a Prompt Public Alerting Capability in the Plume Expo-sure Pathway EPZ at Nuclear Power Plant Sites, Union of Concerned Scien-tists, Critical Mass Energy Project. Nuclear Information and Resource Service, Environmental Action, and New York Public Interest Resea rch 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 Briefing on the Safety Investigation 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), 1932.
7. " Union of Concerned Scientists Comments, Proposed Rule,10 CFR Part 50, Emergency Planning and Preparedness: Exercises, Clarification of Regula-tions, 46 F.R. 61134," Union of Concerned Scientists, Washington, D.C.,

January 15, 1982.

  • r
8. Testimony of Robert D. Pollard and steven C. Sholly before the Sub-committee on Energy and the Environment, Committee on Interior and Insular Affairs, U.S. House of Representatives, Middletown, Pennsylvania, Pirch 29, 1982, available from the Union of Concerned Scientists.
9. "Jnion of Concerned Scientists Detailed Comments on Petition for Rulemak-ing by Citizen's Task Force, Emergency Planning,10 CFR Parts 50 and 70, Docket No. PRM-50-31, 47 F.R. 12639," Union of Concerned Scientists, Washington, D.C., May 24, 1982.
10. Supplements to the Testimony of Ellyn R. Weiss, Esq., General Counsel, Union of Concerned Scientists, before the Subcommittee on Energy Conservati3n and Power, Committee on Energy and Commerce, U.S. House of Representatives, Union of Concerned Scientists, Washington, D.C., August 16, 1982.
11. Testimony of Steven C. Sholly, Union of Concerned Scientists, Washington, D.C., on be'1alf of the New York Public Interest Research Group, Inc., be-fore the Special Committee on Nuclear Power Safety of the Assembly of the State of New York, hearings on Legislative Oversight of the Emergency Ra-diologic 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 Commis-stoners', by the Advisory Committee on Radiological Emergency Plan for Columbia Cour ty, Pennsylvania," Union of Concerned Scientists, Washing-ton, D.C., Seotember 15, 1982.
14. " Radiological Emergency Planning for Nuclear Reactor Accidents," pre-sented to Kernenergie Ontmanteld Congress, Rotterdam, The Netherlands, Union of Concerned Scientists, Washington, D.C., October 8,1982.
15. " Nuclear Reactor Accident Consequences: Implications for Radiological Emergency Plenring," presented to the Citizen's Advisory Committee to Re-view Rockland Jounty's Own Nuclear Evacuation and Preparedness Plan and General Disaster Preparedness Plan, Union of Concerned Scientists, Wash-ington, D.C., Enember 19, 1982.
16. Testimony of Steven C. Sholly before the Subcomittee on Oversight and Investigations, Committee on Interior and Insular Affairs, U.S. House of Representatives, Washington, D.C., Union of Concerned Scientists, Decem-ber 13, 1982.
17. Testimony of Gordon R. Thompson and Steven C. Sholly on Commission Ques-tion Two, Contentions 2.1(a) and 2.1(d), Union of Concerned Scientists and New York Public Interest Research Group, before the U.S. Nuclear Reg-ulatory 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 50-236-SP, December 28, 1982.
  • 7
18. Testimony of Steven C. Sholly on the Consequences of Accidents at Indian Point (Comission Question One and Board Question 1.1, Union of Concerned Scientists and New York Public Interest Research Group, before the U.S.

Nuclear Regulatory Comission 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, 1982, as corrected February 16, 1983. *

19. Testimony of Steven C. Sholly on Commission Question Five, Union of Con-cerned 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, 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 26,1983.
21. Testimony of Steven C. Sholly on Emergency Planning and Preparedness at Commercial Nuclear Power Plants, Union of Concerned Scientists, Washing-ton, D.C., before the Subcomittee on Nuclear Regulation, Comittee on Environment and Public Works, U.S. Senate, April 15, 1983, (with " Union of Concerned Scientists' Response to Questions for the Record from Sena-tor Alan K. Simpson," Steven C. Sholly and Michael E. Faden).
22. "PRA: What Can it Really Tell Us About Public Risk from Nuclear Ac-cidents?," 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 Radi-ological Emergency Planning and Preparedness Considerations," Union of Concerned Scientists, Washington, D.C., June 28, 1983.
24. " Response to GA0 Questions on NRC's Use of PRA," Union of Concerned Sci-entists, Washington, D.C., October 6,1983, attachment to letter dated October 6, 1983, from Steven C. Sholly to John E. Bagnulo (GAO, Washing-ton,D.C.).
25. The Impact of " External Events" on Radiological Emergency Response Plan-ning Considerations, Union of Concerned Scientists, Washington, D.C., De-cember 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 Evidence on: Safety and Waste Man-agement Imolications of the Sizewell PWR, Gordon Thompson, with supporting evidence by Steven Sholly, on behalf of the Town and Country Planning Association, February 1984, including Annex G, "A review of Probabilistic Risk Analysis and its Application to the Sizewell PWR,"

Steven Sholly and Gordon Thompson, (August 11, 1983), and Annex 0,

" Emergency Planning in the UK and the US: A Comparison," Steven Sholly and Gordon Thompson (October 24,1983).

. . ~ . - - - - - . - - _ - - _ _ _ - _ - . - - . - .

a

27. Testimony of Steven C. Sholly on Emergency Planning Contention Number l Eleven, Union of Concerned Scientists. Washington, D.C., on behalf of the Palmetto Alliance and the Carolina Environmental Study Group, before the U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in

] the Matter of Duke Power Company, et. al. . (Catawba Nuclear Station, Units j 1 and 2), Docket Nos. 50-413 and 50-414, April 16, 1984. *

28. " Risk -Indicators Relevant to Assessing Nuclear Accident Liability Premi-ums," in Preliminary Report to the Independent Advisory Committee to the NAIC Nuclear Risk Task Force, December 11, 1984, Steven C. Sholly. Union of Concerned Scientists, Washington, D.C.
29. " Union of Concerned Scientists' and Nuclear Information and Resource Ser-i vice's Joint Comments on NRC's Proposal to Bar from Licensing Proceedings the Consideration of Earthquake Effects on Emergency Planning," Union of 1 Concerned Scientists and Nuclear Information and Resource Service, Wash-I ington, D.C., Diane Curran and Ellyn R. Weiss (with input from Steven C.

Sholly), February 28, 1985.

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 Review of the NRC's Source Term Reassessment Study (STRS) by the
Union of Concerned Scientists," Union of Concerned Scientists, Washington, D.C., May 13, 1985.

4

32. The Source Term Debate: A Review of the Current Basis for Predicting Se-vere Accident Source Terms with Special Emphasis on the NRC Source Term i Reassessment Program (NUREG-0956), Union of Concerned Scientists, Cam-

} bridge, Massachusetts, Steven C. Sholly and Gordon Thompson, January i

1986.

9

33. Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price, I

and Steven C. Sholly on behalf of State of Connecticut Department of Pub-j lic Utility Control, Prosecutorial Division and Division of Consumer Counsel, regarding the prudence of expenditures on Millstone Unit III,

! February 18, 1986.

1

34. Implications of the Chernobyl-4 Accident for Nuclear Emergency Planning for the State of New York, prepared for the State of New York Consumer

! Protection Board, by MHB Technical Associates, June 1986.

35. Review of Vermont Yankee Containment Safety Study and Analysis of Containment Venting Issues for the Vermont Yankee Nuclear Power Plant, i

prepared for New England Coalition on Nuclear Pollution, Inc., December i 16, 1986.

'I i

1 j  !

_ . . _ _ _ _ _ _ _ - . _ . _ . _ _ _ _ - _ ~ . . - . _ _ _ _ _ _ _ _ _ . - _ --

36. Affidavit of Steven C. Sholly before the Atomic Safety and Licensing I Board, in the matter of Public Service Company of New Hampshire, et al.,

regarding Seabrook Station Units 1-and 2 Off-site Emergency Planning Issues, Docket Nos. 50-443-OL & 50-444-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 QA Program, Application Nos. 84-06-014 and 85-08-025, Exhibit No. 10,935 March, 1987.
  • Available from the U.S. Nuclear Regulatory Commission, Public Document Room, Lobby, 1717 H Street, N.W., Washington 0.C.

~

/f*M..fi,g(,\, Attachment 3

.. 5.

Orrect or THE Suptavsson Toww or Nontw Ntupsttao Town Matt,Manpasstv,N Y ssO3o JOMM S M0(RNAM SwM ovioom January 16, 1987 Mr. William J. Catacosinos, Chairman Long and Chief Island Lighting Executive Officer Company 175 East Old Country Road Hicksville, New York 11801

Dear Mr. Catacosinos:

LILCORoslyn Avenue, is representing Heights, its property located at 250 WillisTh LILCO's station. emergency plan for the Shoreham nuclear powerto be a "

prevent any property. As ofmisunderstanding today, as to the use of the subje Avenue, Roslyn Heights is zoned Business A.the subject property at 250 W tion permitscenter.

operations the property to be used as it has beensThis classifica- an The present zoning does not permit the property center." toAccordingly, be used in a any newre and expanded way as a " reception

' subject property as being a " presentation by LILCO of the

, ting the new and expanded use described in LILCO's recentreception cen Revision 8 of its emergency plan is contrary to the present zoning classification.

Any attempt by LILCO to use the l

Roslyn zoning laws.Heights facility in this manner would violate local i

As you probably know, we have previously' outlined i our position on this matter with the Nuclear Regulatory Commission, was sent to Mr.and a copy'of our letter of December 11, 1986 -

Ira Frielicher of your company.

appears that despite prior notification of the Town'sHowever,,it

! position, LILCO has continued to represent to the Nuclear Regulatory Commission that the operations . center could be -

l used as part of the evacuation plan. .

of myself and the other members of the Board, CouncilmanTherefore, on beh

( .

t l

t

. , 4 Mr. William J. Catacosinos January 16, 1987 Page Two Weinstein, Councilman Cunningham, Councilman Fuschillo and Councilman Guarino, you are hereby requested to refrain from any further representation that this site can legally be used as a reception center and to further ref rain f rom any further representation that it is available as a reception and evacuation center.

V , uly ours,

[ ,

/ John B. Kiernan Supervisor JBK:lg cc: Nuclear Regulatory Commission Hon. Jerome J. Weinstein Hon. Gerard W. Cunningham Hon. Charles J. Fuschillo Hon. Joseph A. Guarino Robert F. Dolan, Esq.

Mr. Bert J. Cunningham t

h - _

1 was k cutoTve. Attachmenti,,4 R,.u. . s . - ~.- cu cNc t. .l..o,.

  1. OSEM A J Auss o. oENNCTT

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'a"c'A"3:t'o","#tJ" '

RICH A R D V. .U AR QlNO, J R.

TOWN HALL PLAZA H E MPST E A D, N.Y.11550 rc..a.a.. .es-s ooo January 6, 1987 Mr. William Catacosinos, Chairman Long Island Lighting Company 175 East Old Country Road Hicksville, New York 11801

Dear Mr. Catacosinos,

The Town Board of Hempstead has learned from press reports, statements of members of the public before the ,.

Board, and a review of pertinent portions of Revision 8 t of LILCO'S emergency plan for the Shoreham nuclear power plant that LILCO is representing its property located at 2400 Sunrise Highway, Bellmore, to be a " reception center."

We understand that this " reception center" includes structures, f acilities and services necessary to process tens of thousands of evacuees arriving in vehicles for monitoring for radiation and possibly for decontamination, as well as ancillary facilities and services for these persons. To date, the subject property has been used by LILCO as an operations center in support of its supply of electrical power to Long Island residents and businesses. It is our understr.nding that LILCO is continuing to use the property as an operations center, but that, in addition, LILCO claims the property for a new and expanded use as a " reception conter."

We are taking this initiative to write in order to prevent any misunderstanding as to the use of the subject property. As of today, the subject property located at 2400 Sunrise Highway, Bellmore, is zoned Part Business /Part Residence B. This classification permits the property to be used as it has been, as an operations center.

l l

.h ..

POg3 2

. 2400 Sunrise Highway Bellmore, New York 11710 The present zoning does not permit the property to be used in a new and expanded way as a " reception center."

Accordingly, any representation by LILCO of the subject property as being a " reception center" or as permitting the new and expanded use described in LILCO'S Revision 8 of its emergency plan is contrary to the present zoning classification. Any attempt by LILCO to use the Bellmare facility in this manner would violate local zoning laws.

Sincerely,

', ,I j A f f

~

2nts44 A.

Thomas S. Gu l'otti lhM r v11 me' s D.

B6rinett Presiding Supervisor S visor I

i

(

.W6 .,

Eug L. Weisbein Gergor P.f9eterson Cou ilman '

Counc 1rianN

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os h G. air r. Martin B. Bernstein C cilm Councilman m 1 Jose . Mond' ell'o Nichard V. Guardino, Jr. '

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Cou ilman Councilman

4,R4; Attachment 5 Q

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' .5 OFFIC E OF T H E SU PE RVISOR TOWN HALL OYSTER DAY.N Y 117 71 January 28, 1987 JIst; coter sie.. seco Mr. William J. Caticosinos Ch2irman and Chief Executive Officer Long Island Lighting Company 175 East Old Country Road Hicksville, New York 11801 Dacr Mr. Catacosinos:

We, the undersigned, representing a majority of the Oyster Bay Town Council, are writing in reference to LILCO's emergency evacuation plan for the Shoreham nuclear power plant.

The members of the Board have become aware that portions of Revision 8 of the LILCO plan designate its Hicksville facility on Old Country Road as o " reception center." We understand that the Hicksville facility would in-clude services and rtructures necessary to process 40,000 evacuees and thoir vehicles. Actions to be taken at the center would include the moni-toring of the evacuees and their vehicles for radiation and, if necessary, dccontamination measures would be taken on site.

To date, the Hicksville facility has been used by LILCO as an office the utility in its effort to supply Long and operaticn center to assist Icland with electrical power. LILCO's plan for a new and expanded use at Hicksville by designating it as a reception area was never discussed that any with Town of ficials, and we have been advised by our Town Attorney, representation by LILCO of the subject property as being used as a " reception canter" or as permitting the new and expanded use described by LILCO zoning in classifi-R3 vision 8 of its emergency plan is contrary to the present cction. Any attempt by LILCO to use the Hicksville facility in this nanner would violate local zoning laws. ,

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~ sugla~ J. Hines Council .,an Councilman cct U.S. Reco13ecry Commisblon

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DOLKErty April 27. 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission bYCEfk'y!

g gg"Mf "UlI'sY

)

In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY ) Docket Nos. 50-322-OL

) 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

) CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY, STATE OF NEW YORK, AND TOWN OF SOUTHAMPTON RESPONSE IN OPPOSITION TO LILCO'S MOTION FOR EXPEDITED COMMISSION CONSIDERATION have been served on the following this 27th day of April 1987 by U.S. mail, first class.

Lando W. Zech, Jr., Chairman Comm. James K. Asselstine U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Room 1113 Room 1136 1717 H Street, N.W. 1717 H Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20555 William C. Parler, Esq. Comm. Frederick M. Bernthal U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 10th Floor Room 1156 1717 H Street, N.W. 1717 H Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20555

t

, Comm. Thomas M. Roberts Alan S. Rosenthal, Chairman U.S. Nuclear Regulatory Commission Atomic Safety and Licensing

! Room 1103 Appeal Board 1717 H Street, N.W. U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555

- Mr. Howard A. Wilber Gary J. Edles, Esq.

Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 i

Morton B. Margulies, Esq. Comm. Kenneth M. Carr Atomic Safety and Licensing Board U.S. Nucidar Regulatory Commission U.S. Nuclear Regulatory Commission 1717 H Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry R. Kline William R. Cumming, Esq.

Atomic Safety and Licensing Board Spence W. Perry, Esq.

U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C. 20555 Federal Emergency Management Agency 500 C Street, S.W., Room 840 Washington, D.C. 20472 Mr. Frederick J. Shon Anthony F. Earley, Jr., Esq.

Atomic Safety and Licensing Board General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company Washington, D.C. 20555 175 East Old Country Road Hicksville, New York 11801 Ms. Elisabeth Taibbi, Clerk W. Taylor Reveley, III, Esq.

Suffolk County Legislature Hunton & Williams Suffolk County Legislature P.O. Box 1535 Office Building 707 East Main Street Veterans Memorial Highway Richmond, Virginia 23212 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

6 Q

Mary M. Gundrum, Esq. Hon. Michael A. LoGrande New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-116 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 Martin Bradley Ashare, Esq. Fabian G. Palomino, Esq.

Suffolk County Attorney Special Counsel to the Governor Bldg. 158 North County Complex Executive Chamber, Rm. 229 Veterans Memorial Highway State Capitol Hauppauge, New York 11788 Albany, New York 12224 Richard G. Bachmann, Esq. David A. Brownlee, Esq.

Oreste Russ Pirfo, Esq. Kirkpatrick & Lockhart George E. Johnson, Esq. 1500 Oliver Building U.S. Nuclear Regulatory Commission Pittsburgh, Pennsylvania 15222 Office of General Counsel Washington, D.C. 20555 Mr. Jay Dunkleburger Mr. Stuart Diamond New York State Energy Office Business / Financial Agency Building 2 NEW YORK TIMES Empire State Plaza 229 W. 43rd Street Albany, New York 12223 New York, New York 10036 Joel Blau, Esq. Mr. Philip McIntire Director, Utility Intervention Federal Emergency Management N.Y. Consumer Protection Board Agency Suite 1020 26 Federal Plaza Albany, New York 12210 New York, New York 10278 Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 I .x h Kerbert H. Brown ~

KIRKPATRICK & LOCKHART 1800 M Street, N.W.

South Lobby - 9th Floor Washington, D.C. 20036-5891

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