ML20246H653

Affidavit of DG Bridenbaugh.* Discusses Technical Reasons Why Low Power Testing to 5% Power Has No Value If Subsequent Power Operation at or Near Full Power Not Authorized.W/ Supporting Documentation & Svc List

ML20246H653
Person / Time
Site:	Seabrook
Issue date:	05/08/1989
From:	Bridenbaugh D MHB TECHNICAL ASSOCIATES
To:
Shared Package
ML20246H567	List: ML20246H561 ML20246H653
References
OL-1, NUDOCS 8905160155
Download: ML20246H653 (58)

Text

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- EXHIBIT 3 .- j AFFIDAVIT OF DALE G. BRIDENBAUGH ,

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1. My name is Dale G. Bridenbaugh. I am President 3

of MHB Technical Associates ("MHB"), a technical consulting 4

firm specializing in nuclear power plant safety, licensing, 5

nd regulatory matters, located at 1723 Hamilton Avenue, 6

. Suite K, San Jose, California 95125. I received a Bachelor i

f Science degree in mechanical engineering from South 8

Dakota School of Mines and Technology in 1953 and am a g

licensed professional' nuclear engineer. I have more than 30 years experience in the engineering field, primarily in power plant analysis, construction, maintenance, and operations. Since 1976, I have been employed by MHB and have acted as a consultant to domestic and foreign government agencies and other groups on nuclear power plant safety and licensing matters. Between 1966 and 1976, I was employed by the Nuclear Energy Division of General Electric i,s Company ("GE") in various managerial capacities relating to the sale, service, and product improvement of nuclear power reactors manufactured by that company. Between 1955 and 1966, I was employed in various engineering capacities working with gas and steam turbines for GE. Included in my duties at GE was supervision of startup testing of equipment in fifteen to twenty fossil and nuclear power plants. I also was responsible for various nuclear fuel projects ranging from the remote disassembly of irradiated 27 gg 8905160155 890508 PDR ADOCK 05000443 o PDR

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y ' fuel to the supply of reload fuel for operating nuclear 2 plants. I have authored technical papers and articles on the subject of nuclear power equipment and nuclear power 3

plant safety and have given testimony on those subjects.

4 other details of my experience and qualifications are 5

c ntained in Attachment al.

6 7 My direct experience with the Seabrook plant 2.

8 began in September 1983 when my firm was retained by the b Massachusetts Attorney General to evaluate the prudence of 10 expenditures by Fitchburg Gas and Electric Company on II Including that initial assignment, I have Seabrook Unit 2.

I2 evaluated various phases of the Seabrook project in six 13 different engagements. In my work as consultant on the N Seabrook plar.t, I have performed diverse assignments, 15 focusing primarily on technical reviews and analysis of 16 safety and cost issues. I have visited the plant on II several occasions and have participated in a number of Ib interviews and/or depositions of key Seabrook management 19 personnel.

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3. The purpose of this Affidavit is to explain the technical reasons why low power testing to 5 percent power at Seabrook is of no value if subsequent power operation at or near full power is not authorized. It will further explain that there are, in fact, several irreversible changes which would result from testing at the 5% level 27 28 1

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y while no significant electrical power would be produced.

I These changes would limit the options available for the 2

plant and plant site in the event that full power operation 3

is not subsequently authorized, and would cause additional 4

financial st with no apparent off-setting benefit.

5 6

I SEOUENCE OF TESTING AND POWER OPERATION 8

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4. Every nuclear plant needs to have fuel loaded and

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10 1.evels sufficient to turn the turbine and generate electric g

g power. The typical test sequence is to perform non-nuclear zero-power tests first, then proceed to "zero-power" nuclear tests and subsequently to low-power nuclear

, operation with no electrical production. Ilectrical 10 production is usually deferred until the test program achieves a power level of 10-15%. Permission to proceed to l,e a higher power level is in general predicated on fulfillment of the test objectives at the lower levels.

When the testing is completed satisfactorily at the lower levels and other requirements are satisfied, the plant is then permitted to operate at a power level at which 1 22 I sufficient steam is generated to allow production of 23 electricity. Power levels are increased in steps and tests are conducted at the steps until full power operation has been achieved. Most power ascension programs include a 27

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l demonstration run at full power for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after which 7

the unit is declared to be in commercial operation. The 2

minimum length of time in which this process can be 3

completed is about three months. At Seabrook, the test 4

program as specified in the Final Safety Analysis Report 5

was scheduled for four months. A more recent and detailed

. Power Ascension flow chart dated 1/20/86 shows a 90 day i

chedule for Seabrook (furnished by PSNH in response to 8

NHPUC Staff Set #1, Request 48, Docket DR 87-151).

10 5. All other factors being equal, the initial II operating phase at a new nuclear unit can be most 12 efficiently performed if a smooth transition is made from 13 fuel loading to low power operation and on to the power 34 testing above 5%. If a significant delay between the 15 testing steps occurs, it is most burdensome for that delay 16 to take place after power operation has begun. The reason 17 for this is because the power test program is designed so 18 as to be able to proceed from the completed tests at a 19 lower authorized power level to tests at the next power 20 step. If lengthy delays are introduced, it then becomes 21 necessary to repeat certain activities such as instrument 22 calibrations, water chemistry adjustments, thermal 23 expansion measurements, radiation surveys, control system 24 realignments and heat balance calculations to assure safe 25 and smooth transition to the next authorized level. An 26 additional complicating factor can be the need to conduct 27 28

y surveillance tests that are required at certain frequencies specified by the plant Technical Specifications. If the 2

s hedule is known ahead of time, such required activities 3

j can be programmed into the Power Ascension program. A 4 ,

delay prior to initial nuclear operation minimizes the need f 5

for dup iCation of such operations.

I 6. In the case of Seabrook Unit 1, the loading of 8 fuel into the reactor has now been completed and the 9 Company has completed the tests intended to be performed 10 prior to nuclear operation of the unit. This work was II authorized by the granting of a "zero" power license by the I2 Nuclear Regulatory Commission ("NRC") on October 17, 1986, 13 and fuel loading was begun on october 22, 1986. William B.

II Derrickson's L/ September 26, 1986 presentation to the 15 NRC's Advisory Committee of Reactor Safeguards ("ACRS")

16 indicated that the scheduled time for completion of the II non-nuclear tests following fuel loading was 4 to 6 weeks:

18 Our request is to be able to load fuel and 19 do the hot testing with the coolant system at operating temperature and pressure.

We have several tests to run, from tests 21 from the original hot function tests. This whole effort from the day we receive the 22 license to completion of the hot functional tests will take about a month or six weeks.

23 (ACRs Transcript, pp. 14-15) 24 25 1/ Mr. Derrickson is a Senior Vice-President of Public Service of New Hampshire and has primary 26 responsibility for the Seabrook project.

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y This estimate is in general agreement with the 1/20/86 g Power Ascension cchedule which shows a 34 day period of time between fuel load and initial criticality, which is 3

the first time that nuclear operation begins.

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5 7. In the case of Seabrook, the operating license l

6 has now been requested in not one, but three separate I phases. The first phace which consists of fuel loading and 8 hot functional tests (but no criticality and no irradiation 9 of the fuel) has now been completed. The second phase, now 10 under review, would permit low power testing and subsequent II heatups involving operation at up to 5% of full power. The 12 third phase, if authori::ed, will permit operation between 13 5% and 100% power.

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8. The NRC action to permit low power operation at Seabrook, if granted at this time is a deviation from common past practice. The traditional licensing practice I,t was in the past to grant an operating license as a result of a single licensing action. In those cases, fuel loading and low power test activities were then performed and integrated with ascension to full power. Shortly after the Three Mile Island accident, the NRC began to issue licenses in a two-step (low power-full power) process. This two-step process was implemented to help ease the licensing review backlog which resulted from the licensing hiatus following the 1979 accident. Initially, this two-step 26 .

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I process worked reasonably well. Plants that were granted a 2 low power license generally completed the fuel loading and 3 low power testing by the time the full power license was 4

issued, with the low power testing and the full power 5 licensing relatively close together in time. 2/ Since 6

1984, however, there have been several cases of lengthy 7

delay between the low power license and the approval for 8 peration above 5%. Examples of these delayed cases g include:

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1) Diablo Canyon 1, where a three year delay was yy experienced between the initial low power license (September 1981) and full power approval 12 (November 1984).

2) Shoreham, where a low power license was awarded 13 in July 1985 and full power authorization is yet to be issued.

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3) Perry, which received low power authorization in 15 March 1986, did not receive full power approval until De ember 1986.

16 I These delays illustrate clearly that NRC approval of low 18 power operation-gives no assurance that timely 10 authorization of power operation is forthcoming. This 20 21 Of the 15 plants licensed for low power operation 2/

j 22 between March 1979 and June 1984 which also received a full power license during that period, the average l time between the low power and full power licenses was 23 The average time from initial less than 5 months.

24 criticality to award of the full power license was only 1/2 month (excluding Grand Gulf which was delayed 25 f r approximately two years because of improperly drafted Technical Specifications). See Attachment *2, l

26 p rtions of letter from NRC Chairman Palladino to Congressman Edward Markey, June 15, 1984.

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w uld appear to be particularly relevant for Seabrook which 2

is now heavily engaged in the resolution of complex emergency planning issues.

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5 IRREVERSIBLE CHANGES IN STATUS OUO RESULTING FROM LOW POWER OPERATION 6

9. Before a reactor "goes critical" as it does for the first time during low power testing, neither the O nuclear fuel nor the reactor or its components, are 10 irradiated or contaminated by radiation. (The uranium II contained in the fuel is of course naturally radioactive, I2 but this material is at a very low level and is, fully 13 contained within the fuel rods.) Low power testing, 14 however, necessarily causes irreversible changes to the 15 nuclear fuel and to portions of the nuclear reactor.

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10. There is necessarily irradiation of the nuclear l.e fuel as a result of low power testing. This irradiation 8

results in the build-up of quantities of fission products g

within the fuel which requires that the fuel subsequently be handled, transported, and treated as irradiated fuel.

Once these fission products have been produced, they cannot be removed from the fuel by any usual means. Thus, the irradiation from low power testing is irreversible. In addition to this, low power testing would result in some Components of the Seabrook plant becoming irreversibly 27 28 -a-

irradiated while other components will become contaminated 7

with activated corrosion products and fission products if 2

fuel r d leaks or perforations are present. The level of 3

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irradiation and/or contamination would depend both on the 4

length of time and the power level of operation, on the 5

p rformance of the fuel, and on the purity and chemical 6

. conditions of the reactor coolant. Potentially affected i

mponents include portions of the reactor pressure vessel 8

and internals, the steam generators, the control rods, g

incere nuclear instrumentation, and reactor._ auxiliary g

system components, equipment, and piping. If contaminated by substantial quantities of radioactive fission products, special care would be required in handling these items.

14 11. The irreversible changes to the plant resulting 15 from power operation as described above makes a significant 16 change in the way in which the Seabrook plant must be II considered. Prior to power operation, the plant equipment 18 and components are radiation free (with the exception of 19 readily removable nuclear fuel and some sensors), and there 20 is no limitation as to what future option for the plant and (

21 the plant site may be selected. It is possible in this 22 condition that the plant could be abandoned, :onverted to 23 non-nuclear use, or ultimately operated as a nuclear unit 24 as planned. once radioactive, the options are reduced.

25 Both the plant and plant site become nearly irreversibly 26 committed to a nuclear facility. This is because some of 27

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y the plant equipment will be made radioactive and because l 2 the site itself becomes (de-facto) a long-term radioative waste st rage fa ility since there is no approved storage 3

l facility available to receive the irradiated nuclear fuel.

4 5 12. Because of the unavoidable irradiation and 6 contamination described above, the conduct of' low power 7 testing of necessity requires some worker exposure to 8 potentially harmful radiation during the course of the 9 testing as well as after the testing is completed. The 10 amount of exposure may not be large and unless errors are Il made, probably would not exceed allowable limits. However, I2 it is an additional unavoidable impact which results from 13 low power testing. The necessity of performing the 14 associated health physics protection requirements further 15 complicates maintenance and operation steps and makes plant 16 security a more critical and time consuming function.

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13. In its non-irradiated condition, the fuel loaded into the Seabrook core probably has a recovery (or salvage) value that is likely equal to or a major fraction of the original purchase value of that fuel. This fuel, if not irradiated, likely could be sold to other nuclear plants to use as is, or, if necessary, to be reconfigure for a different reactor. (For example, some bundles might require manual disassembly and rod rearrangement or reconfiguration of the pellets for the necessary pattern of 27 28 - - _ _ _ _ - _ _ _ - - __ . _ _ _ _

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y enrichment.) Once the fuel is irradiated and there is a 2

build-up of fission products as would occur'during the pr p sed 5% p wer peration, it makes fuel shipment and 3

reconfiguration, and therefore most opportunities for reuse 4

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1. * #"*1' m re C mplicated and costly and therefore far less likely to be implemented. Based on present day

. nuclear fuel costs, the value of the Seabrook fuel is t

approximately $50-80 million. 2/ Salvage value 8

approximately equal to this amount could be realized from g

efe s presen n n. le s e hnically 10 possible that irradiated fuel could be transferred to a different reactor of the same design and subsequently used, there would be significant penalties associated with such an action. It would be necessary to ship the fuel in shielded casks which may or may not be readily available.

The fuel itself would not be of optimum design for equilibrium operation. Such a transfer has, to my l,e, knowledge, never been done in U.S. power reactors and would probably require lengthy review by the NRC and/or other regulatory bodies. Consequently, I conclude that the fuel has little or no value if used for testing up to 5% power.

My conclusion is supported by recent letter from Mr.

Harrison, president and CEO of PSNH to the NRC (NYN-87104 dated September 3, 1987) transmitting the following statement:

25 26 2/ See Attachment 3 for derivation cf the fuel value.

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. , l y In order to determine the actual salvage value of the fuel after the low power 2 testing program, a market analysis would have to be undertaken at that time together 3

with a study of special costs for handling l and shipping the fuel. Although the Joint -

owners have not performed a rigorous study 4 ,

of these costs, a review was performed in late 1986 which indicated that the salvage 5

value of the fuel would approximately offset the costs of handling and transportation of j 6

the fuel to a third party resulting in no a net cost to the Joint Owners for the disposal of the fuel. l 8

g 14. The proposed 5% power operation would also result in the loss of potential salvage value fo'r other plant 10 components that would be substantially irradiated or 73 yg contaminated (i.e., steam generators, reactor components su h as control rods and other internals, coolant pumps and 13 g seals, valves, piping and instrumentation sensors). I g estimate the salvage value of these components to be at least $20-30 million. These components are virtually yg identical in all Westinghouse Pressurized Water Reactors, g

many are peri dically replaced, and others are useful for 18 yg replacement in the event of component failures. A resale market for them should exist but it would be severely 20 .

limited or negated if they are irradiated. In an interview 21 g conducted in conjunction with a Vermont proceeding (Vermont Public Service Board, Docket 5132), William B. Derrickson, l g Vice-President of PSNH stated his estimate of the salvage g4 value of the cancelled Seabrook Unit 2 to be approximately i g

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$25 million. (See November 12, 1986 Interview, William B.

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l y Derrickson, p. 74.) It is likely, however, that if these same components were irradiated and/or contaminated by 2

power operation, they would have little or no or perhaps 3 .

negative salvage value.

4 5 15. Additional costs resulting from a decision to 6 perform low power testing are the costs of decontaminating, I decommissioning, and disposal of the fuel and portions of 8 the reactor system following a low power testing period in 9 the event that a full power license is not obtained. The 10 cost of necessary removal / disposal / decontamination efforts 11 could be tens of millions of dollars, depending on the 12 specific disposal requirements. Mr. Harrison's September 13 3, 1987 letter states the belief that the decontamination 14 following low power operation could be accomplished within 15 the " normal budget" of $10-11 million per month. He does 16 not speculate on the number of months that might be 17 required nor whether the " normal" budget could be reduced 18 quickly if that effort were not necessary. Such efforts 19 also carry with them the potential for additional worker 20 radiation exposure. If PSNH is not successful in selling 2I the irradiated fuel to another user, it will also need to 22 be treated as high level radioactive material and would l

23 likely ultimately be disposed of as spent fuel. Because of 24 the lengthy time periods during which spent fuel must be 25 isolated from the environment, Federal law has assigned the 26 responsibility for its ultimate disposition to the U.S.

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y Department of Energy (DOE). _4/ DOE will perform the 2

ultimate disposal of high level waste, but is also required to recover the full cost of disposal from the utility. DOE 3

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has published exp,ected costs for the receipt and ultimate 4 ,

disposal of irradiated fuel. These expected costs are 5

currently being collected at a rate of $.001/ kwhr of 6

. generation for fuel exposed now to be disposed of by DOE in i

the future. Fuel typically operates at a design exposure 8

9 y cuidelines for the. recommendation'of nuclear waste 10 sites were enacted in 10 CFR Chapter III, Part 960 on November 30, 1984. These guidelines do not specify g precisely the length of time that high level waste must be safeguarded from the environment. The 12 guidelines do, however, give an indication of the time periods required by including numerous statements of 13 .' Qualifying" and " Favorable" Conditions such as:

14 (1) Site conditions (b) Favorable Conditions.

such that the pre-waste-emplacement ground-water 15 travel time along any path of likely radionuclides travel from the disturbed zone to the accessible 16 environment would be more than 10,000 years.

II (2) The nature and rates of hydrologic processes operating within the geologic setting ~during the 18 Quaternary Period would, if continued into the future, not affect or would favorably affect the 19 ability of the geologic repository to isolate the vaste during the next 100,000 years.

2I (Part 960 - General Guidelines For the Recommendation of Sites for Nuclear Waste Repositories, 10 CFR, Chapter III)

Citation of the above guideline is not intended to 23 imply that the Seabrook Site will be required to store the irradiated fuel for the next 10,000 to 100,000 24 years. It does however, give an indication of the irreversible effects involved in the decision being 25 considered.

l 26 27 gg l

I y of 20,000 MWD'(t)/ ton. For such fuel, this collection rate g is equivalent to approximately $150,000 per ton. DOE has n t established a rate for fuel exposed to the lower level 3

associated with the 5% power test operation, but there is 4

n reason to expect that the cost per ton could be 5

neg tiated t mu h below DOE's published rates as DOE is 6

. . required by law to obtain full cost recovery and the same 1

disposal care would likely be required. Accordingly, the 8

g potential cost for disposal by DOE of the 90 tons at Seabrook could be as much as $13,000,000, not counting g

transportation or possible cost increases. In addition, no g

disposal facility is planned or-expected until after the g

year 2000, at least 15 years in the future. It would

-3 therefore be necessary to store and safeguard the spent g

fuel on site until that time. Mr. Harrison's September 3, 1987 letter gives an estimate for the onsite storage of the fuel of approximately $700,000 per month. If this estimate le is correct, the cost of spent fuel storage and disposal becomes nearly a $140 million obligation. Reactor 1

19 components removal, handling and disposal would be additionally required. I do not believe the costs would actually be that high, but it is clear they could total tens of millions of dollars.

24 THERE IS NO PURPOSE SERVED, AND THE BENEFITS N PRODUCED BY LOW POWER TESTING ARE OUTWEIGHED BY THE l ADVERSE AND IRREVERSIBLE CHANGES IN THE STATUS OUO 27 28 _____ _

16. The essential purpose of a low power license is 7

to test reactor systems which cannot be effectively tested 2

in n neritical conditions. It is necessary to conduct such 3

testing prior to operating the plant at higher power levels 4

(i.e., greater than 5% power) . At 5% power, the reactor 5

w uld barely pr du e en ugh steam to spin the turbine and 6

- synchronize the generator. Taking into account the station i

g auxiliary power needs, it is not likely that net electric g power would be supplied to the gr!.d as a result of the testing, and there would be no displaced oil or fuel cost O

savings. Instead, power from the grid would be required to g

run the plant during the tests. Mr. Harrison's September g

3, 1987 letter contains as an enclosure Table 1, showing PSNH's estimated incremental costs for low power operation.

This Table shows a total cost for electric power for the low power testing of $1.144 million. This seems to verify f that no positive electrical power will be produced. Thus, 1,e,,

l l none of the benefits assumed in the NRC's Environmental Impact Statement for Seabrook would be achieved by low power testing; however, as noted, low power operation would 20 result in environmental impacts, such as plant contamination with radioactive material, the likely loss of the resale value of the fuel and other components once they become irradiated, the cost of decontamination, decommissioning and disposal, worker exposure, and last but

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} not least, the potential commitment of the site to lengthy 2 radioactive waste storage use.

3 17.. Because low power testing standing a-lone produces 4 -

no net benefits but does have potential adverse effects, it 5

is my opinion that there is no reason to conduct low power 6

testing just for its sake alone. Rather, low power testing can be rationally justified only in circumstances where 8

there is no substantial doubt that the plant subsequently 9

will operate at higher power levels so that its benefits 10 (i.e., generation of electricity) will be available to 11 offset the adverse effects (fuel irradiation, radioactive 12 contamination, potential worker exposure) which cannot be avoided. In my technical opinion, the optimum time for I4 performing low-power testing of any nuclear reactor is 15 shortly before full-power operational' approval is re.liably 16 anticipated to be obtained.

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DAu . sa m nsAcca t 20 l

EI Subscribed and sworn lo before me g on this .J f

• day of (.fcf , 1987.

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OFFICIAL SEAL s4y-> ">'-- ,

MYRNA L BARRY 24 fJ07ARY PUBLic . cAliggggg4 W NoTAay pusLIc i SWTA CLARA COUNTY w cmm. tem m u.19si E

{ 26 My Commission expires: /M/M ~ ~ ~ ~ ~ ~

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ATTACHMENT 1 PROFESSIONAL QUALIFICATIONS OF' DALE'G. BRIDENBAUGH l

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PROFESSIONAL QUALIFICATIONS OF DALE G. BAIDENBAUGH DALE G. BRIDENBAUGH MHB Technical Associates

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1723 Hamilton Avenue.

Suite K San Jose, California 95125 (408) 266-2716 EXPERIENCE:

1976 - PRESENT President - MHB Technical Associates. San Jose. Califomia Co-founder and partner of technical consulting firm. Specialists in energy consulting to governmental and other groups interested in evaluation of nuclear plant safety and licensing.

Consultant in this capacity to state agencies in California, New York, Illinois, New Jersey, Pennsylvania Oklahoma and Minnesota and to the Norwegian Nuclear Power Committee, Swedish Nuclear inspectorate, and various other organizations and environmental groups.

Performed extensive safety analysis for Swedish Energy Commission and contributed to the Union of Concerned Scientists's Review of WASH 1400. Consultant to the U.S. NRC - LWR Safety Improvement Program, performed Cost Analysis of Spent Fuel Disposal for the Natural Resources Defense Council, and contributed to the Department of Energy LWR Safety improvement Program for Sandia Laboratories. Served as expert wrtness in NRC and state utility commission hearings.

1976 - (FESRUARY - AUGUST)

Consultant. Project Survival. Palo Alto. Califomia Volunteer work on Nuclear Safeguards initiative campaigns in California Oregon, Washington, Arizona, and Colorado. Numerous presentations on nuclear power and alternative energy options to civic, govemment, and college groups. Also resource person for public service presentations on radio and television.

1973 -1976 Manacer. Performance Evaluation and improvement. General E!ectric Comcany Nuclear Enercy Division. San Jose. California Managed seventeen technical and seven clerical personnel with responsibility for establishment and management of systems to monitor and measure Boiling Water Reactor equipment and >

system operational performance. Integrated General Electric roscurces in customer plant modifications, coordinated correction of causes of forced outages and of efforts to improve reliability and performance of BWR systems. Also responsible for development of Division Master Performance Improvement Plan as well as for numerous Staff special assignments on long range studies. Was on special assigr, ment for the management of two d:fferent ad hoc projects formed to resolve unique technical problems.

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1972 -1973 Manacer. Product Service General Electric Comoany - Nuclear Enercy Division San Jose.

Canfomia Managed grou'p of twenty-one technical and four clerical personnel. Prime responsibility was to direct interface and liaison personnel involved in corrective actions required under contract warranties. Also in charge of refueling and service planning, performance analysis, and service communication functions supporting all completed commercial nuclear power reactors supplied by General Electric, both domestic and overseas (Spain, Germany, Italy, Japan, India, and Switzerland).

1968 1972 Manacer. Product Service General E!ectric Comoanv - Nuclear Enercy Division. San Jose.

California .

Managed sixteen technical and six clerical personnel with the responsibility for all customer contact, planning and execution of work required after the customer acceptance of department-supplied plants and/or equipment. This included quotation, sale and delivery of spare and renewal parts. Sales volume of parts increard from $1,000.000 in 1968 to over $3,000.000 in 1972.

1966 -1968 i

Manaaer Comolaint and Warrantv Service General E!ectric Comoany - Nuc! ear Enerav Division San Jose Califomia Managed group of six persons with the responsibility for customer contacts, planning and execution of work required after customer acceptance of department supplied plants and/or equipment-both domestic and overseas.

1963 -1966 Field Encineerine Suoervisor General E!ectric Comoanv. Installation and Service Encineerino Decartment. Los Anceles. Califomia Supervised approximately eight field representatives with responsibility for General Electric steam i

and gas turbine installation and maintenance work in Southem California, Arizona, and Southern Nevada. During this period was responsible for the installation of eight different central station steam turbinesenerator units, plus much maintenance activity. Work included customer contact.

l preparation of quotations, and contract negotiations.

l 1956 -1963 Field Encineer. General Efectric Comoanv. Installation and Service Encineerino Decartment.

Chicaao. Illinois .

Supervised installation and maintenance of steam turbines of all sizes. Supervised crews of from ten to more than one hundred men, depending on the job. Worked primarily with large utilities but had significant work with steel, petroleum and other process industries. Had four years of 1

2-

experience at construction, startup, trouble-shooting and refueling of the first large-scale commercial nuclear power unit.

1955 -1956 Enaineerina Trainino Procram General Electric Comoanv. Erie Pennsvivania. and Schenectadv.

New York Training assignments in plant facilities design and in steam turbine testing at two General Electric factory locations.

1953 -1955 United States Armv-Ordnance School Aberdeen Marviand instructor - Heavy Artillery Repair. Taught classroom and shop disassembly of artillery pieces.

1953 Encineerino Trainina Precram General Electric Comeanv. Evenda!e Ohio Training assignment with Aircraft Gas Turbine Department.

EDUCATION & A41LfATIONS:

BSME - 1953, South Dakota School of Mines and Technology, Rapid City, South Dakota. Upper 1/4 of class.

Professional Nuclear Engineer - Califomia. Certificate No. 0973.

Member- American N*Jelear Society Various Company Training Courses .during career including Professional Business Management.

Kepner Tregoe Decision Making, Effective Presentation, and numerous tecnnical seminars.

HONOAS & AWAADS:

Sigma Tau - Honorary Engineering Fraternity.

General Managers Award, General Electric Company.

PE=SONAL DATA:

Born November 20,1931, Miller, South Cakota .

Married, three children '

6T,190 lbs., nealth . excellent HonoraHe discharge from United States Army . -

Hobbias: Skiing, hiking.

l PUBLICATIONS & TESTIMONY OF DALE G. BRIDENBAUGH:

1.

Ooeratino and Maintenance Exoerience. presented at Twelfth Annual Seminar for Electric Utility

• Executives, Pebble Beach, California, October 1972, published in General E!ectric NEDC-10697,  !,

December 1972. '

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2. Maintenance and In-Service insoection. presented at lAEA Symposium on Experience From Operating and Fueling of Nuclear Power Plants, Bridenbaugh, Uoyd & Turner, Vienna, Austria, October,1973. {

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3.  !

Oceratina and Maintenance Excerience. presented at Thirteenth Annual Seminar for Electric Utility j Executives, Pebble Beach, California, November 1973, published in General Electric NEDO-20222, '

January 1974.

4 Imorovino Plant Availability. presented at Thirteenth Annual Seminar for Electric Utility Executives, j Pebble Beach, Califamia. November 1973, published in General Electric NEDO-20222, January, 1974  ;

5.

Aeolic:stion of Plant Outace Exoerience to imorove Plant Performance. Bridenbaugh and Burdsall, American Power Conference, Chicago, Illinois April 14,1974.

6. Nuclear Valve Testina Cuts Cost. Time. Electrica! Worid. October 15,1974.

7.

Testimony of D. G. Bridenbaugh, R. B. Hubbard, and G. C. Minor before the United States Congress. Joint Committee on Atomic Energy, February 18,1976, Washington, D.C. (Published by the Union of Concerned Scientists, Camoridge, Massachusetts.)

8.

Testimony of D. G. Bridenbaugh, R. B. Hubbard, and G. C. Minor to the California State Assemcly Committee on Resources, Land Use, and Energy, March 8,1976.

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9. Testimony by D. G. Bridenbaugh before the California Energy commiscion, entitled, initiation of j Catastroonic Accicents at Diablo Canyon. Hearings on Emerge'ncy Planning, Avila Beacn, j Califomia November 4,1976.

10.

Testimony by D. G. Bridenbaugh before the U. S. Nuclear Regulatory Commission, subject: Diab!o Canven Nuclear Plant Performance. Atomic Safety and Licensing Board Hearings, in the matter of Pac:fic Gas and Electne Company, (Diablo Canyon Nuclear Power Plant, Units 1 and 2 ), Docket Nos. 50-275-01., 50-323-OL, December,1976.

11 Testimony by D. G. Bridenbaugh before the California Energy Commission, subject: Interim Scent Fuel Storace Considerations. March 10,1977, {

i 12.

Testimony of D. G. Bridenbaugh before the New York State Public Service Commission Siting Board Hearings conceming the Jamesport Nuclear Power Station, subject: Effect of Technical and Safety Deficiencies on Nuclear Plant Cost and Reliabi!ity. in the matter of Long Island Lignting )

Company (Jamesport Nuclear Power Station, Units 1 and 2), Case No. 80003, April,1977.

i

13. Testimony by D. G. Bridenbaugh before the Califomia State Energy Com,rptssion, subject:

Decommissioning of Pressor: zed W ster Reactors. Sundesert Nuclear Plant Hearings, in the matter of San Diego Gas and FJectric Company (Notice of intention to File Application for Certification of Site and Related Facilities), Docket No. 76-NOI 2, June 9,1977.

1 l

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14. Testimony by D. G. Bridenbaugh before the California State Energy Commission, subject:

Economic Relationships of Decommissioning. Sundesert Nuclear Plant, for the Natural Resources i

Defense Council, in the matter of San Diego Gas and Electric Company; Notice of Intention to File .

Application for Certification of Site and Related Facilities, Docket No. 76-NOl 2. July 15,1977.

15. The Pisks of Nuclear Powe'r Reactors: A Review of the NRC Reactor Safety Studv N/ ASH-1400.

Kendall, Hubbard, Minor & Bridenbaugh, et. al., for the Unicn of Concerned Scientists, August, 1977.

16. Testimony by D. G. Bridenbaugh before the Vermont State Board of Health, subject: Ooeration of Vermont Yankee Nuclear Plant and its Imoact on Public Health and Saferv. October 6,1977.

17. Testimony by D. G. Bridenbaugh before the U.S. Nuclear Regulatory Commission, Atomic Safety and Licensing Board, subject: Deficiencies in Safetv Evaluation of Non-Seismic Issues Lack of a Definitive Findino of Safety. Diablo Canyon Nuclear Units, October 18, 1977, Avila Beacn, Cal.

ifornia.

18. Testimony by D. G. Bridenbaugh before the Norwegian Commission on Nuclear Power, subject:

Reactor Safetv/ Risk. October 26,1977.

19. Swedish Aeactor Saferv Studv Barseback Risk Assessment. MHB Technical Associates January, 1978. (Published by the Swedish Department of industry as Document Dsl 1978:1)

20. Testimony by D. G. Bridenbaugh before the Louisiana State Legislature Committee on Natural Resources, subject: Nuclear Power Plant Deficiencies Imoactino on Safetv & Reliability. Baton Rouge, Louisiana February 13,1978.

21. Soent Fuel Discosal Costs. report prepa d by D. G. Bridenbaugh for the Natural Resources Defense Council (NRDC), August 31,1978.

22. Testimony of D. G. Bridenbaugh, G. C. Minor, and R. B. Hubbard before the Atomic Safety and Ucensing Board, in the matter of the Black Fox Nuclear Power Station Construction Permit Heanngs, September 25,1978, Tulsa, Oklahoma.

23. Testimony of D. G. Bridenbaugh and R. B. Hubbard before the Louisiana Public Service Commission, Nuclear Plant and Power Generation Costs. November 16, 1978, Baton Rouge, Louisiana.

24. Testimony by D. G. Bridenbaugh before the City Council and Electric Utility Commission.of Austin, Texas, Desion Construction. and Coeratino Exoerience of Nuclear Generatino Facilities.

December 5,1978, Austin, Texas.

25. Testimony by D. G. Bridenbargh for the Commonwealth of Massachusetts, Deprtment of Public Utilities, Imoact of Unr.g.sg!Pd Saferv Issues. General Deficiencies and Three Mile Irland-initiated M_.2@ pat'ons on Pcwcr Generation Cort at the._P_poosed Pilorim-2 Nyplegn.1, June 8,1979.

26. Imorovino the SafetV cf LWR Power Plants. MHB Techn; cal Associateji, prepare (for U.S. Dept. of Energy, Sandia Labort. tories, September 28,1979.

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27. BWR Pice and Nozzle Cracks. MHB Technical Associates, for the Swedish Nuclear Power inspectorate (SKl), October,1979.

28. Uncertainty in Nuclear Risk Assessment Methodolocv. MHB Technical Associates, for the Swedish Nuclear Power inspectorate (SKI), January 1980.

29. Testir'nony of D. G. Bridenbaugh and G. C. Minor before the Atomic Safety and Ucensing Board, in the matter of Sacramento Municipal Utility District, Rancho Seco Nuclear Generating Station following TMI-2 accident, subject: Ooerator Trainino and Human Factors Encineerina. for the Cali-famia Energy Commission, Docket No. 50-312-SP, February 11,1980.

30. [*9n Reactor Safety Studv Caorso Aisk Assessment. MHB Technical Associates, for Friends of tr.e Earth, Italy, March,1980.

31. Decontamination of Krvaton 85 from Three Mile Island Nuclear Plant. H. Kendall, R. Pollard, and D.

G. Bridenbaugh, et al, The Union of Concerned Scientists, delivered to the Governor of Pennsylvania, May 15,1980.

32. Testimony by D. G. Bridenbaugh before the New Jersey Board of Public Utilities, on behalf of New Jersey Public Advocate's Office, Division of Rate Counsel, Analvsis of 1979 Salem-1 Refueina r Outace. in the matter of the Petition of Public Service Electric and Gas Company for approval of an increase in Electric and Gas rates and for changes in the tariffs for Electric and Gas service., P.U.C.

N.J. No. 7 Electric, and P.U.C. N.J. No. 5, Gas, Pursuaut to R S. 48:2-21, August 1980.

33. Minnesota Nuclear Plants Gaseous Emissions Studv. MHB Technical Associates, for Minnesota Pellution Control Agency, September,1980.

34. Position Statement, Procosed Rufemakinc on the Storace and Discosal of Nuclear Waste. Joint Cross-Statement of Position of the New England Coalition on Nuclear Poilution and the Natural Resources Defense Council, September,1980.

35. Testimeny by D. G. Bridenbaugh and G. C. Minor, before the New York State Public Service Commission, in the matter of Long Island Light Company Temporary Rate Case, prepared for the Shoreham Opponents Coalition, September 22,1980, Case No. 27774, Shoreham Nuclear Plant Construction Schedofe.

36. Supplemental Testimony by D. G. Bridenbaugh before the New Jersey Board of Public Utilities, on ,

benalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, Analysis of i 1979 Salem-1 Refuelino Outace. In the matter of the Petition of Public Service Electric and Gas Company for approval of an increase in Electric and Gas rates and for changes in the tariffs for Electric and Gas Service, P.U.C. N.J. No. 7, Electric, and P.U.C. N.J. No. 5, Gas, Pursuant to A S.

48:2-21, Docket No. 794-310, OAL Docket No. PUL-877 79, December,1980.

37. Testimony by D. G. Bridenbaagh and G. C. Minor, before the New Jersey Board of Public Ut'lities, on behalf of New Jersey Department of the Public Advocata. Division cf Rate Counsel, Qyster Creek 1980 Refueling _Outace Investicstfo.n., in the matter of the Petition of Jersey Centnl Power )

ano Light Company for approval of an increase in tne rates for electrical service and adji.utmer.1 clause and facters for such servic;, OAL Docket No. PUC41518-80, BPU Dockat Net. SO4 2SS, 007 488, February 1981, I

-s-

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38.

Economic Assessment: Ownershio interest in Palo Verde Nuclear Station. MHB Technical Associates, for the City of Riverside, September 11,1981.

39. Tes:imony of D. G. Bridenbaugh before the Public Utilities Commission of Ohio, in the Matter-of the Regu:ation of the Electric Fuel Component Contained Within the Rate Schedules of the Toledo Edison Company and Related Matters, subject: Davis Besse Nue' ear Power Station 1980-81 Outace Peview. Case No. 81306-EL-EFL, November,1981.

40. Supplemental Testimony of D. G. Bridenbaugh before the Public Utilities Commission of Ohio, in the matter of the Regulation of the Electric Fuel Component Contained within the Rate Schedules of the Toledo Edison Company and Related Matters, subject: Davis.Besse Nuclear Power Station 1980 81 Outace Review. Case No. 81-306-EL-EFL, November 1981.

41. Systems Interaction and Sinole Failure Criterion. Phase 2 Pecort. MHB Technical Associates for the Sweoisn Nuclear Power inspectorate (SKl), January,1982.

42. Testimony of D. G. Bridenbaugh and G. C. Minor on behalf of Govemor Edmund G. Brown Jr.,

before the Atomic Safety and Ucensing Boaru, regarding Contention 10. Pressurizer Heaters. 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-OL, January 11,1982.

43. Testimony of D. G. Bridenbaugh and G. C. Minor on behalf of Governor Edmund G. Brown Jr.,

before the Atomic Safety and Ucensing Board, regarding Contention 12. Block and Pilot Ooerated Pelief Valves. 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-OL January 11,1982.

44. Testimony of D. G. Bridenbaugh before the Commonwealth of Massachusetts, Department :

Public Utilities, on behalf of the Massachusetts Attorney General, Pilorim Nuclear Power Station.

1991-82 Ou' ace investigation. in the matter of Boston Edison Company, DPU Docket No.1009-P, March 11,1982.

45. Testimony of D. G. Bridenbaugh before the Pennsylvania Public Utility Commission, on behalf of the Pennsylvania Office of Consumer Advocate, Beaver Vallev Outace. March,1982.

46. Interim testimony of D. G. Briden$augh and G. C. Minor before the Atomic Safety and Ucensing Board, on behalf of Suffolk County, in the matter of Long Island Ughting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 11 Passive Mechanical Vawe Failures. Docket No. 50-322-OL April 13,1982.

47. Testimony of D. G. Bridenbaugh and G. C. Minor before the Atomic Safety and Ucensing Board, on behalf of Suffolk County, in the matter of Long Island Ughting Company, Shoreham Nuclear Power Sta; ion Unit 1, rega ding S#clk Ccunty Contention 11. Passive Mechanical Valve Failures, Docket No. SCL322-OL April 13.1982.

48. Testmony of D. G. Brioenbaugh and R. S. Hubbard, in the Matter of Jersey Central Power and Ught Compar y For an fricrease in Rates for Electrical Service, on behalf of New Jersey

. Department of the Public Advocate. Division of Rate Counsel, Three Mile Island Units 142  ;

C!eanuo and Modificgt,yj, Precram1, DPU Docker Nos. 818-726. S18-736, May,1982.

49. Tesu.nony et D. G. Bridenbaugh ard G. C. Minor on behalf of Suffolk Ccunty, before the Atomic Safety r.nd Ucensing Ecard, in the mattar of Long Island Ughting Company, Shoreham Nuclear 7

l

. . l l

l Power Station, Unit 1, regarding Su* folk County Contention 22 SRV Test Procram. Docket No. 50-322-OL May 25,1982.

50. Testimony of D. G. Bridenbaugh and G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting Company, Shoreham Nuclear Power Station, Unit 1, regarding suffolk County Contention 28(aHvii and SOC Contention 7A(6).

Redu~ction of SRV Challences. Docket No. 50 322-OL, June 14,1982.

51. Testimony of D. G. Bridenbaugh before the Illinois Commerce Commission, on behalf of the Illinois Attomey General's Office, Excected Ufetimes and Performance of Nuc! ear Power Plants, in the matter of Commonwealth Edison (Proposed general increase in electric rates), ICC Docket No. 82-0026, June 18,1982.

52. Testimony of D. G. Bridenbaugh and R. B. Hubbard on behalf of the Ohio Consumers Counsel, before the Public Utilities Commission of Ohio, regarding Construction of Perry Nuclear Generatina Unit No.1. in the matter of the, application of the Cleveland Electric illuminating Company for )

authority to amend and increase certain of its filed schedules fixing rates and charges for electric !

service, Case No. 81-1378-EL-AIR, October 7,1982.

53. Issues Affectina the Viability and Acceptability of Nuclear Power Usace in the United States.

prepared by MHS Technical Associates for Congress of the United States. Office of Technology 1 Assessment for use in conjunction with Workshop on Technological and Regu!ratory Changes in Nuclear Power, December 8 & 9,1982.

54. Testimony of D. G. Bridenbaugh on behalf of Rockford League of Women Voters, before the Atomic Safety and Ucensing Board, in the matter of Commonwealth Edison Company, Byron Station, Units 1 and 2, regarding Contention 22. Steam Generators. Docket Nos. 50-454, 50-455.

March 1,1983.

55. Testimony of G. C. Minor and D. G. Bridenbaugh before the Pennsylvania Public Utility Commission, on behalf of the Office of Consumer Advocate, Pecardino the Cost of Censtructina the Suscuehanna Steam Efectric Station. Unit f. Re: Pennsylvania Power and Light, Docket No. R-822169, March 18,1983.

56. Surrebuttal Testimony of D. G. Bridenbaugh before the Pennsylvania Public Utility Commission, on behalf of the Office of Consumer Advocate, Recardina the Cost of Constructing the Suscuehanna Steam Electric Station. Unit I. Re: Pennsylvania Power and Ught, Docket No. R-822169, April 20, 1983.

57. Testimony of D. G. Bridenbaugh in the Matter of Public Service Gas & Cectric, Base Rate Cas=,

Nuclear Construction Expenditures. on behalf of New Jersey Department of the Public Advocate.

Division of Rate Counsel, Docket No. 836-620, OAL Docket No. PUC-04930-83. October 13,1983.

58. Affidad cf C. G. 3rldenbaugh,in the Mitter of Jersey Central Power and Ught, on behalf of New Jarse/ Cepartment of the Public Advocate, Ohision of Rate Counsei, TMI Fautt investigation. DPU Docket No. 836-500, November 23,1983.

59. Testimony of D. G. Bridenbaugh, in the Matter of Public Service Electric & Gas, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, LEAC Investigation Sgem-1 Outaces., DPU Docket No. 831-25, December 1,1983.

60. Rebuttal Testimony of D. G. Bridenbaugh, in the Matter of Public Service Electric & Gas, on behalf I of New Jersey Department of the Public Advocate, Division of Rate Counsel, LEAC Investicat'on. f Safem-1 Outaces. DPU Docket No. 83125, January 18,1984. I

61. Testimony of D. G. Bridenbaugh, L M. Danielson, R. B. Hubbard and G. C. Minor before the State

. of New York Public Servics' Commission, PSC Case No. 27563, in the matter of Long Island Ughting Company Proceeding to investigate the Cost of the Shoreham Nuclear Generating Facility

- Phase 11, on behalf of County of Suffolk, February 10,1984.

62. Testimony of D. G. Bridenbaugh, in the Matter of Jersey Central Power & Ught Company, on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, Base Rate Case.

Ovster Creek 1983-84 Outace and O&M and Caoital Expenditures. OAL Docket No. PUL-00797-34,.

BPU Docket No. 841-55, May 23,1984.

63. Direct Testimony of Dale G. Bridenbaugh and Richard B. Hubbard, Before the Illinois Commerce Commission, Illinois Power Company, Clinton Nuclear Station, on its own motion, an investigation to consider a plan for moderating the initial rate increase associated with placing Illinois Power Company's Clinton Unit No.1 generating station in service, Docket No. 84 0055, available from lilinois Govemor's Office of Consumer Services July 30,1984.

64. Joint Direct Testimony of Dr. Robert N. Anderson, Professor Stanley G. Christensen, G. Dennis Einy, Dale G. Bridenbaugh and Richard B. Hubbard Regarding Suffolk County's Emergency Diesel Generator Contentions, Before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting Company, Shoreham Nuclear Plant Unit 1, NRC Docket No. 50-322-OL July 31,1984.

65. Surrebuttal Testimony of Dale G. Bridenbaugh, Lynn M. Danielson, Richard B. Hubbard, and Gregory C. Minor, Before the New York State Public Service Commission, PSC Case No. 27563.

Shoreham Nuclear Station Long Island Ughting Company, on behalf of Suffolk County and New York State Consumer Protection Board, in the matter of Long Island Ughting Company Proceding to Investigate the cost of the Shoreham Nuclear Generating Facility - Phase 11, October 4,1984.

66. Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C. Minor on Behalf of Massachusetts Attomey General DPU 84-145, Before the Massachusetts Department of Public Utilities, regarding the prudency of expenditures by Fitchburg Gas and Electric Ught Company on Seabrook Unit 2, November 23,1984,84 pgs.

67. Direct Testimony of Dale G. Bridenbaugh, Richard B. Hubbard and Lynn K. Price on Behalf of l

Massachusetts Attomey General, DPU 84-152, Before the Massachusetts Department of Public Utilities, regarding the investigat;on by the Department of the Cost and Schedute of Seaborok Unit

1. Decnmber 12,1984 L 68. Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C. Minor on Behalf of Maine Public Utililes Commission Staff regarding Seabrook Unit 2, Docket No.84-113, December 21,1984.

69. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor Regarding Su4clk Courry's Emergency Diesel Ger erator Load Contention, Docket No 50-322-OL, January 25,1985.

70. Direct Testimony of Dale G. Bridenbaugh, in the Matter of the Motion of Public Service Electric &

Gas, on behalf of New Jersey Depanment of the Public Advocate, Divisionof Rate Counsel, McHeq l;: n

.J___--_--_=_-----__-_=-- - - - - -

To increase The Level of the Levelized Enercy Adlustment Cfause.' Docket No. ER 8501166 and Docket No. 837-620, April 24,1985.

71.

Direct Testimony of Dale G. Bridenbaugh on behalf of the Attorney General of the Commonwealth of Massachusetts, in the Matter of Boston Edison Company DPU 8518, A Hearing to Determine Whether Fuel and Purchased Power Costs Associated with the Outage at Pilgrim Nuc! ear Power Station Which Began on December 10,1983 and Ended on December 30,1984 Were Reasonably and Prudently incurred. May 13,1985.

72. Direct Testimony of Dale G. Bridenbaugh on behalf of the Residential Ratepayer Consortium, in the  !

Matter of the Application of Consumers Power Company for a Power Supply Cost Reconciliation proceeding for the 12-month period ended December 13,1984, regarding Palisades Outage Re-view, Case No. U 7785-R, August 28,1985.

73. 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. *

74. Direct Testimony of Dale G. Bridenbaugh on behalf of New Jersey Department of the Public Advocate, in the matter of JCP&L for an increase in rates, Base Rate Case, Oyster Creek O&M and Capital Expenditures, CAL Docket No. 4929-85, BPU Docket No. 8507-698, November 25,1985.

75. Direct Testimony of Dale G. Bridenbaugh on behalf of New Jersey Department of the Public Advocate, in the matter of JCP&L TMl Restart . LEAC, Re: TMl-Restart Commercial Operation Standards & Reliability of Service, January 31,1986.

76.

Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price, and Stever: C. Shelly on behalf of State of Connecticut Department of the Public Utility Control Prosecutorial Division and Division of Consumer Counsel in the matter of Connecticut Ught and Power Company Retrospective Audit of the Prudence of the Management and Financing of the Construction of Millstone Unit 3, February 18,1986.

77. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attomey General regarding the prudence of expenditures by New England Power Co. on Seabrook Unit 2. Docket Nos. ER 85-646-000, ER 85-647-000, February 21,1986.

78. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attomey General regarding WMECo Construction Prudence for Millstone Unit 3, in the matter of investigation by the department on it own motion as to the priority of the rates and charges set forth in schedules filed with the department Dec. 17,1985 by Western Massachusetts E!ectric Co.

to become e fectr/e Jcn.1,1986. Docket No.85-270, March 19,1986.

79. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attemey General regarding WMECo's Commercial Operating Dalus and Deferred Capitel Additierts on Mristona Unit 3, Docket No.85-270 Mart,tt 19, t986.

80. Rebuttal Testimony of Da!e G. Bridenbaugh and Gregory C. Minor om beha;f of Massachusetts l Attomey Generaf ragarding New Englar:d Power Company's Seabrook 2 Rebuttal. Docket Nea. ER l 85-646 001, ER 85-647 001, April 2,1966.

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81. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of State of Maine Staff of Public Utilities Commission regarding Construction Prudence of Millstone Unit 3, in the matter of Maine Power Company Proposed increase in Rates, Docket No.85-212. April 21,1986.

82. Direct Testimony. of Dale G. Bridenbaugh and Peter M. Scauss on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, 'egarding Base Rate Case: In-Service Criteria for Hope Creek, Hope Creek O&M and Decommissioning Costs, and Operating Plant O&M Costs, OAL Docket No. PUL 0231-86, BPU Docket No. ER 85121163, May 19,1986, 107 pp.

83. Direct Testimony of Dale G. Bridenbaugh on behalf of New Jersey Department of the Public Advocate, Division of Rate Counsel, regarding Base Rate Case: Hope Creek Commercial Operating Date and Criteria, Hope Creek O&M Costs, Operating Life, Capital Additions, and Decommissioning Costs, in the matter of Atlantic City Electric Company increasing its rates for electric service - Phase !!, CAL Docket No. PUL 3290-85, BPU Docket No. ER 8504-434, May 27, 1986,85 pp.

84. Direct Testimony of Dale G. Bridenbaugh, Richard B. Hubbard, and Lynn K. Price on behalf of State of Illinois Office of the Attomey General and Office of Public Counsel, in the matter of Illinois Commerce Commision on its own motion, an investigation to consider a plan for moderating the initial rate increase associated with placing Illinois Power Company's Clinton Unit 1 generating station in service, Docket No. 84-0055, July 9,1986.

85. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of the Vermont Decartment of Public Service, regarding Tariff Filing of Central Vermont Public Service Corporation Requesting a 12% increase in Rates, Docket No. 5132, August 25,1986.

86. Direct Testimony of Dale G. Bridenbaugh and Richard B. Hubbard on behalf of the Pennsylvania Office of Consumer Advocate, regarding Pennsylvania Public Utility Commission vs. Duquesne Ught Company and Pennsylvania Power Company, Docket Nos. R-860378 and R-850267 September 22,1986.

87. Direct Testimony of Dale G. Bridenbaugh and Richard B. Hubbard on behalf of The Public Parties Committee, Public Utility Commission of Texas, regarding the Evaluation of Costs of River Bend Nuclear Generating Station, in the matter of application of Gulf States Utilities for authority to change rates, Docket Nos. 7195 and 6755, February 23,1987.

88. Direct Testimony of Dale G. Bridenbaugh on behalf of Maryland People's Counsel, in the matter of the Application of the Baltimore Gas and Electric Company to Adjust its Electric Fuel Rate Charges, ,

Pursuant to Section 54F of Article 78 of the Annotated Code of Maryland, Case No. 3520-D. April 29, {

1987, I

89. Direct Testimony of Dale G. Bridenbaugh on behalf of Florida Office of Public Counsel, in regard to '

Fual and Purchased Power Cost Recovery C!ause with Generating Performance incentive Factor (Florida Power Corporation - Crystal River 3) Doce: No. 860001-El-8, June 12,1997.

J

90. Direct Testimony of Ot!e G. Bridenbaugh en behalf of tne Residential Ratepayer Consortium, before the Michigan Public Service Commission, in the matter of the Application of Consumers Power j Company for a Reconci!!atlon of Power Supply Cost Recovery Costs and Revenues for Caf6ndar j Year 1986 Palisades . Nuclear Power Plant, Case No. U<1286-R, July 13,1967. ,

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J 91. Direct Testimony of Dale G. Bridenbaugh on behalf of the City of El Paso, before the Public Utility Board, in the matter of the Application of the El Paso Electric Company for a Rate increase in the City of El Paso Evaluation of Costs of Palo Verde Units 1 and 2, July 15,1987.

ll 92. Direct Testimony of Dale G. Bridenbaugh on behalf of the City of El Paso, before the Public Utility l

. Commission of Texas,in the matter of the Application of the El Paso Electric Company for Authonty to increase Electric Rates. Evaluation of Operational and Decommissioning Costs of Palo Verde Units 1 and 2. Docket No. 7460, July 29,1987.

93. 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 Company

. Prudence Related to Seabrook Unit 2 Construction Expenditures Docket No. ER86 704-001, July 31, 1987.

94. Direct Testimony of Dale G. Bridenbaugh on behalf of Maryland People's Counsel, before the Public Service Commission of Maryland, in the matter of the Application of Delmarva Power & Ught Company for Electric Fuel Rate Adjustment, Pursuant to Section 54F of Ariticle 78, of the Annotated Code of Maryland, Case No 8521, Phase 11, August 10,1987, PROPRIETARY.

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ATTACHMENT 2 s;n LETTER. NUNZIO J. PALLADINO. NRC. TO THE HONORABLE EDWARD J. MARKEY DATED JUNE 15. 1984 r . g ,l.

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5 The Hencrable Edward J. Mar. key, Chair .an Sube==ittee on Oversight and Investigations <

C:mittee on Interior and Insular Affairs United States House of Representatives Washington, D.C., 20515

Dear Congressman Markey:

Your 'lettee of Har:h 30, le84 re uested an explanation of the risks associated with lew power operation at cocrarcial nu: lear power react:rs.

In addition, you raised five specific questions whien we have responded to i n A tta chne nt 1 to .t.h_i s.. l ett e r.

With regard to the risks associated with low power creratien, Attachment 2 is a Cemission pacer developed by the staff addressing this issue. As indicated by this pacer, the overall conclusion.that the staff must rea:h fer fuel leading and low powei testing up to 5 percer.t power, is that there is no undue risk to the health and safety of the public for the limited coerations autWorized. In' practice, the staff has developed analyses that indicate that the risks of 5 percent power cperatien can be expected to be a;oreciably less 'than the risks of 100 percent power operation.

C:missioner Gilinsky did n : par'ticipate in the p n;aration of.this reply.

We trust that this infor:.ation is responsive to ycur concerns.

, Since rely ,

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e .- il b Hun:io J. Pc11adino AttacF*nents:

Af Stated L cc: Rep. Ron Marlenee

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CUESTION E: l'or . .T'; esctors li:ensed since the ac:ident at Three F.ile Islan'd, please provide the foilowing ( A) the dzi.e of issuance of 'the low power license; (B) the date cf initia) criticality; (C) the date of 5 percent p:wer operation; (D) the date of issuance of the full pcwcr licer.se; (E) tne date that power levels of 25 cercent or higner were first attained; (F) the cite that oewer levels cf 90 :ercent or higher were first attained; (G) exem:.ic :s granted by the N:C to the low pow ~er licensce and, (H) exe. ptiens granted by the f(P.C to tne full power licensee.

a p';5MER .

The data re uested is provided in the attached Table 5.1. We interpreted t .e cate of 5 percent c:wcr c eration to be the date it.at this power level was execeted. Where the plant has not achie.ed the event listed the syT.hol fi/Ahasbeenused.g. -

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l STATE OF. VERMONT -

i- F.UELIC SERVICE BOARD t.

I__ .

, _ . , . _ _____._____ __x .

t IN RE: Tariff Filing Of  :

Central Verr.cnt Public Service  :

Corporation Requesting A  : Cocket No. 5132:

l'12 Percent Increase In Rates I  :

.To Take Effec: Ju .e 2, 1986.  :

l  :

+ ._ _ _ _

____________x .

j .,

INTERVI_"4 WITE: WILLIAM B . DERRICESCM

. I

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Seabrook Statica New Har.pshire Yankee General Cf fice Building Seabrook, New Ear.pshire Wedn e s day, Nev er.b er 12, 1955 10 :07 a.m.

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CEP.TI FIED SHORTHAND REPOP.TER i

REGISTERED PROFESSICN14 REPORTER l-L P.O.' Box 571 (603) 77 8-7.;7 0 cr Exeter, N.H. 03E33 1-800-527-3311 e

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• l' c_&__ __ ___:-- . - - .

( 1

,PRESENT:

2 1

2 !M.H.B. Technical Associates Gregory C. Mincr, Vice President and -

3 Judith R. 'Liebec.an, Associate Consultant

~

, . 17 23 Hamilten Avenue, Suite K -

4 i San Jose, Califc=ia 95125 l

\

5 i Cahill, Garden & Reindel l (by Thc=as R. Jcn es , Esquire) 6 8 I

8 0 Pin e S treet.

New York, New Ycrk 10005; 7 f or Public Service Cc=pany of New Ha .pshire.

8 D e r.s , Rachlin & Martin (by Elizabeth B . Mullikin, Esquire) 9 100 Dorset Street, Suite 1 P.O. Scx 190 10 Burlin gten, Ver=cn t 05402-0190; f or Central Ver=cnt Public Service Corporation.

Department cf Public Service s 12 j (by Christopher Micciche, Special Ccunsel) l 120 State Street 13  ! Mcntpelier, Ver.cnt 05602 14 Swidler & Berlin (by Andrew Weissman, Esquire) 1000 Themas Jeff ersen Street, NW 15 Washin gten , D.C. 20007 ;

fcr C.V.P.S.C.

16 a

17 IS INDEX 19 Interview with: Direct 20 Derrickt;cn 3 21 l William B.

l(by Mr. Minor) 1 5

22 23 i

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- -_.__n__.----_ _ _ _ - - - _ _ - - - _ _ _ - - _ - - . - _ _ _ _ _ _ _ _ _ _ _ __ _._J

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t PROCEEDINGS i

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EXA*C NATI ON g ~. _.~ .

4 i EY MR. MIbOR: ~

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5 Q' This is not a depositicn.

I guess I should start 6  : by saying that.

Just for the usual pattern of l -

7 '

these type of things, I will intreduce myself. I 8 am Greg Minor of M.E.'E. To my righ: is 9

Judy Lieberman, also of M.E.E.; Chris Micciche cf 10 the Department of Public Services in Ver=cnt .

11 And we are here, Mr. Derrickscn, to ask you 12 sc=e questicns about the proj ect; and I t=derstand

you have schedule restraints; an d I appreciate ycur 14 being here today.

I 15 l i

I would like to' just go, back and start, if ycu 16  :

wculd, by telling me your first associatica with 17 this proj ect and whether the.t was as a ec=sultant 13 to Florida Power and Light or direct i nvcivemen t 19 l with the pcsition at New Es=pshire Ya.5kee.

20 A Okay. We did have an involvement at Ficyida Pcwer 21 Ecd Light Company with respect to Public SecVice ~O C

22 sand seme pecple up here to provide some assistance 23 ,

to Public Service in 1983, I believe, and we did

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. 73 L...

1 unique?.y cut and ben t fer this plant. Struc' ural i

2 steel is the satae way, uniquely cut, specific' 3

cennec:icns out here.

You would have to design a 4 building arcund that structural steel. I dca't 5

think we are going to find too many pecple excited 6 to do that.

I think coisture separators, 7-reheaters, si= ply because not that many plan ts are S

being buil t. , They have cepper nickel tubes', and I 9

d on ' t think there is much of a market for those.

10 C:her compenents we are going to have to look 11- . at en-a chse-by-case' basis. Original large motors a

1 12 f or replace =en t , and we will go to and make an 4

13 atte=p: to see wha: we can do in those areas.

13 14 Other than that, I d:n ' t know. We haven 't looked 15 at that. We have to get a team tcgether to really l'

15 go cut and ca:alcg model, make and see if we can 17 find a match up around the country sc=eplace.

1B Q' Is it viable to sell the Medel F s: sam generators 19 as a replacemen t par: cnit?

23 A There are two uses for them. Cne wculd be a 21- cc=plete steam generator change cut in ancther 22 facility that could use them. Ano:her would be a 23 lot cf utilities are putting training f acilities in f-

]

74 1 where they are taking the t6e sectica, the tube r

2 sheet sectica and using it to practice any current 3 testing and tube plugging. We may be able t6 do 4 scesthing like that. I den ' t 10: cw . We will work 5 en it. If tha: is the marching crders, that is 6 what we will dc.

7 Q Eave you made any esti. ate cf salva e values?

1 8 A I think the g,dys did. I think they are iceking at '

9 S26 millica. I say 25 plus er minus. That is for 3g

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.'t a .U. # i l ' s 13 exact nuclear steam system, so we are cc=peting

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• 5. cou.try, E .d I f cund Marble Hill all over the 1 o- c....-..,,.

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0 (Whercupen, a: 11: 50 a.m. , the 21 interview was adj curned. ) ,

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CERTI FI CATE -

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I, MP.[ia.ne Kusa-Ryll, Registered PrOfessic.r1  !

4 Re.ccr:er, do hereby certify the f oregoing to be 5

e a true ccpy o f the i..t er ri ew of WI * . Ali = . c E .7 CF.50:;, .

held at the 5ew Ha .pshire Yankee Gs .eral office 7

S Building, Seabr0ck, New Ear.pshire, ca Wed: es:iay, .

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ATTACHMENT 1 SEABROOK FUEL VALUE DERIVATION J

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ATTACRMENT 3 SEABROOK FUEL VALUE DERIVATION Assumptions:

Uranium content of core: 90 metric tonnes Average thermal output of initial core: 12,000 MWt-days / tonne Thermal efficiency of plant: 31%

Fuel cycle cost increment: $10/MW hr Fuel disposal cost included in fuel cycle cost: $1/MW hr 12,000 MWtD X 90 T X 24 Hr X 0.31 MWe = 8.035 X 10 6 MW hrs T D MWt 8.035 X 10 6 MW hrs X $9.00/MW hr = $72.3 million 12,000 MWt days / Tonne could vary substantially up or down.

Round to $50-80 million.

Note: Eastern Utilities Associates letter of February 18, 1987 to the Honorable Lawrence R. Alexander estimated the (market) value of the core at $5-23 million. The letter contained no

basis for this number. It would appear to be an estimate of l

resale rather than replacement value.

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o *** June 15, 1984 -

CH A IR M A N

~he Henerable Edward J. Mar. key, Chairr.an Sube =tittee en Oversight and Investigations C:mittee on Interior and Insular Affairs Crited States House of Representatives Washington, D.C. 20515

Dear Congrass.an Markey:

Y:ur letter of March 30, 1984 recuested an ex:lanation of the risks asse:iated with icw power c:eration at correr:ial nu: lear p:wer rea:::-s.

.n actitten, y:u raised five s:e:ift: questions whicn we have rese:n=ed t:

> in Atta:n=ent I to this letter. .

W1th regard to tne risks a:se:iated with is ::wer ::eratien, Atta:r ect 2 is a C: mis:icn >a:er ceveic ed by the staff at:ressing tnis issue. As indi:sted by this :a:er, the overall conclusien that tne staff =ust rea:5 f:r fuel leadin; and 1:w : we, testing c: t: 5 :e-:ea.: ;;we , is tra: tre e is n u:leve risk to tne healt." and safety of the :v:li: f:r tne lini*e:

C erations autMrized. In pra:tice, the staff has cevei::ed analyses tnat in:icate tnat tre rists of 5 per:ent p:wer c; ratien can be eue:te: to be '

a::re:1 ably less tnan the risks of 100 per:ent ;::wer c eration.

0: .issiener Gilinsky did ne: partici: ate in the pre:aration f this reply.

'ne trust that this info--.ation is res;:ensive to ycur c ncerrs.

Sincerely ,

' ~ ~ ~

<.n m  % '0}0 //gl *b w O

Nun:io J. Pc11adino l Attach nents: '

L As stated i

l Rep. Ren Marlemee

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ENCLOSURE f.

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OUESTION 1: What studies, reports or "NUREG" docunent has the Commission published concerning the risk of low power operation.

ANSWER NRC staff estimates of the relative risks of low power versus 100% power operation have been made in recent operating license cases based on consideration of important accident sequences from the Reactor Safety Study (WASH-1400).

These risk estimates are discussed in supplements to the NRC staff safety evaluation reports for several plants including the following:

(A) Diablo Canyon Units 1 and 2 (NUREG-0675, Supplement No.10, August 1980)

(B) San Onofre Units 2 and 3 (NUREG-0712, Supplement No. 4, January 1982)

(C) Summer Nuclear Station Unit 1 (NUREG-0717, Supplement No. 4, January 1982)

(D) LaSalle County Station, Units 1 and 2 (NUREG-0519, Supplement No. 3, April 1982)

(E) Grand Gulf Nuclear Station, Unit 1 (NUREG-0831, Supplement No. 2, June 1982)

(F) Susquehanna Station, Units 1 and 2 (NUREG-0776, Supplement No. 2, June 1982).

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, QUESTION 2: What would be the accumulation of radioactive fission l products after 30, 60 and 120 days of 5 percent operation at a' typical BWR.and at a typical PWR7 l

ANSWER.

Low power testing of a new power reactor would not typically result in as much radioactive fission products as 30 days of continuous operation at the maximum pemitted power. Low power testing could be described as a period of final adjustment of many plant systems, punctuated by ascensions to the minimum power needed to perfonn each series of tests. The assumption of continuous operation at constant power, however, is usually made in computing radioactive inventories in order to simplify the equations of growth and decay and to provide an upper bound analysis of risks.

The distributions of fission products differ somewhat between BWR and PWR cores mainly due to differences in the relative amounts of fissions occurring iE3getinides(theseriesofelementsbeginningwithactinium) other than U. These other actinides are not present in new fuel, but they build up slowly over time through a series of reactions. These other actinidesaccumulateatdifferentratesinthetwg3gypesofcores,andhave fission product years which' differ from those of U. During low power testing with new fuel, very little generation of other fissile actinides .

would occur, and the early accumpgtion of fission products in both BWR' and.

PWR cores would be dominated by U fissions. A single estimate of accumulation of fission products, therefore,1s considered applicable to

. both reactor types. ,

While sufficient infomation is available for the estimation of 937 isotopes "

that may be generated in a reactor core, the' bulk of these have very short half-lives, are stable isotopes, or are made in very small amounts. The Reactor Safety Study (WASH-1400), identified 43 fission products and 11 actinides and other activation products which were judged responsible for virtually all radiological risk, and the staff uses only these radio-isotopes as a simplification in computing accident consequences. No detailed computer calculations of a core inventory at any of the durations of operation are available, and such calculations require lengthy preparations and significant expense. The requested accumulations,  !

therefore, have been calculated from an existing computer-generated inventory using the equations of radioactive growth and decay to correct that inventory to approximate the requested conditions. The inventory silected was the new fuel region at 91 days of operation in case IIA 2, described in the report " Extended Burnup Calculations for Operating Reactor Reload' Reviews", NUREG/CR-3108, February 1983. Only the 43 risk-dominant fission products were corrected to the requested conditions.

_- ---__--___._--___..-__x-_.-_-_--. _ _ . _ - - _ _ _

m 3

. , e Of the 43 risk-dominant fission products, 25 have half-lives sufficiently short that they would closely approach secular equilibrium with a continuous source in 30 days or less. At equilibrium, the decay rate of a radioisotope equals its rate of production, and no further accumulation occurs. Four of these shorter-lived fission products however, have at least fractional parentage from longer-lived isomers or isotopes with which they are in transient equilibrium. At transient equilibrium, the decay rate of a daughter isotope equals the rate at which its parent decays. In Table 2.1, the megacuries of 21 shorter-lived fission products at secular equilibrium with a continuous source of 150 megawatts of fission have been listed,giong with the half-life of each isotope. A megacurie is a rate of 3.7 x 10 nuclear disintegrations per second. For comparison,150 megawatts (which is close to 5% of current generation reactor core power levels) is the power generated by 126 megacuries of fission. During low power testing of a new I core, the 21 fission products would 3e removed from secular equilibrium by {

variations in power level or periods of shut-down, but would approach  !

secular equilibrium at any power level within several da depending upon i half-life. For example, the longest-lived Table entry, 'g, would I be at 50%

of its equilibrium value at 8.1 days of continuous operation, and at 98% at 30 days. -

The remaining 22 risk-dominant fission products accumulated after 30, 60,  !

and 120 days in a continuous source of 150 megawatts of fission have been The entries listginTable Rb, and '35 2, alogg with the half-life of each isotope. j for Cs and ~Zr include estimated contributions from activation as well as fission yield, ang3jheir estimates' are correspondingly less I accurate. The radioisotope Cs is not included, since it i f33tafission j

' product, but an activation product of stable fission product Cs. It is l j

gimated that a 150 megawatt core would accumulate about 1000 curies of Cs in 30 days, with further accumulation to about 6000 curies at 120 days.

In addition to the 43 risk-dominant fission products listed, there are '

several hundred short-lived fission products accounting for several hundred megacuries in a 150 megawatt core. These are in approximate secular equi-librium within minutes of operation at any power level, but are too short-lived to be transported off-site in any accident.

Again, the actual amounts of the isotopes identified in Table 2.2 would vary in an extremely complex manner during variations of core power.

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TABLE 2.1 Megacuries In Secular Equilibrium With 150 Megawetts Of Fission-At A Typical Light Water Reactor Fission Product .Megacuries Halffife(Days) 85m Xr 1.5 0.18 87 , 3.0 Kr 0.053 L 88 Kr 4.1 -0.12 133 5.3 Xe 8.4-135 0.38 Xe 2.7 131 8.1 I 3.7 132 0.096 I 5.5 133 0.88 1 8.4 134 7 . 9.6

~

0.037

.135 7.9 0.28 1

131m 1.3 Te 0.52.

132 3.3 Te 5.5 127 3.9 5b 0.18 129 0.18 5b 1.0 91 0.40 Sr 7.0 99 7.6 2.8 Mo 99m 6.7 0.25 Tc 105 0.19 Ru 1.8 105 1.5 Rh 1.7 97 7.3 0.71 Zr 143 1.4 Ce 7.2 p 9

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" TABLE 2.2 Megacuries At Various Durations In a Typical LWR At 150 Megawatts ik I

Fission Product 30 Days 60 Days 120 Days 1/2 Life (Days) f

.. 85 3950.

Kr .0016 .0033 .0066 86 .00035 18.7 Rb .00024 .00031 136 ,018 .019 13.0 Cs .015 137 .055 11000.

Cs .014 .027 127 .13 .13 .391 Te .12 1275e .0028- .0051 .0084 109.

129 .88 .048 Te .83 .86 129%e .075 f.115 . .15 34.

89 3.0 4.4 52.1 5r l' . 9 90 .026 .051 11030.

Sr .013 140 12.8 Ba 6.2 - 7.4 7.7 103 2.6 3.6 39.5 Ru 1.7 106 .083 .16 366.

Ru .042 90 .026 .051 2.67 Y .013 91 5.1 59.0 Y 2.0 3.4 95 3.6 5.5 65.2 Zr 2.1 .

95 2.3 3.0 35.0 Nb 1.5

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140 7.4 7.7 1.67

. La 6.2 141 5.0 ' 6.3 32.3 Ce 3.3 144 .85 1.6 284.

Ce .44 143 6.7 7.1 13.7 Pr 5.5 147 2.7 2.8 11.1 Nb 2.4 9

l

. +

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l As noted in the response to Question 2, the core inventory during low power .

testing would be expected to vary greatly due to fluctugj{ons in power level. The thyroid dose calculations are dominated by I, due to the  !

nature of }gg radiation emitted by its decay, such that a similar number of

. curies of I pose more risk than a larger number of curies of the other i {cginefissionproductscombined. For a typical low power testing period, I would not be expected to accumulate to more than a fraction of its equilibrium value.

Under a Commission policy statement of June 1980, the staff and utilities have also assessed accident consequences and probabilities of very low probability accidents from an environmental as well as a safety point of view. These accidents are sometimes referred to as beyond design basis or Class 9 accidents. The staff has published Environmental Impact Statements covering such events for all license applications submitted after July 1, 1980. In addition, the staff has also assessed the risks (probability times consequences) from such accidents for such purposes as siting criteria studies, probabilistic risk assessment reviews of specific reactors and for generic studies. All of these assessments have been made for reactors coerating at full power. No specific offsite consequences have been assessed for reactors operating at low powdr levels.

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QUESTION 3: What could be the off-site consequences of an accident at low power assuming the accumulation of fission products after 30, 60, and 120 days of 5 percent operation at a typical BWR and at a typical PWR7 Specifically, what, if any, source term assumptions does the NRC use for judging the risk of low power operation?

ANSWER

' The staff's Safety Evaluation Reports for proposed operating licenses consider a variety of postulated reactor accidents, all of which assume the reactor to have been at 105% of design power. The off-site consequences estimated in these reports are doses to hypothetical individuals at specific locations downwind from the plant, which are compared to the dose guidelines in 10 CFR Part 100. Analyses to estimate off-site consequences for power less than 105% of design are not performed since such consequence estimates would necessarily be lower.

The purpose of the postulated accident analyses in Safety Analysis Reports (SARs) is to assess the performance of the plant during postulated accidents and to demonstrate that the radiological consequences of the postulated accidents, when evaluated using conservative assumptions, remain below the guideline dose values of 10 CFR 100.

For the large break loss of coolant accident, (LOCA) the most severe reactor accident considered in the Safety Evaluation Reports, it is assumed that 100% of the noble gases, krypton and zenon, and 25% of the iodine in the core are dispersed into the containment, while 50% of the iodine is dis-solved in the emergency cooling water. The source term, i.e. , the amounts of these fission products escaping into the environment, is conservatively computed by modeling the containment leakage paths, leakage and dispersal of cooling water from the emergency cooling system, and operation of additional engineered safety features, all of which vary from plant to plant.

As shown in the response to the second question, the noble gas and iodine fission products are predominantly at secular equilibrium after 30 days of operation. Were the release assumed in Safety Evaluation Reports for the large break LOCA to occur during 5% power operation, the dose consequences estimated would be 4.8% of those reported for 105% power operation. Since these doses are estimated conservatively, no diminution by radioactive decay of the source term is accounted for, and the worst possible dose would be somewhat less. For typical BWR and PWR plants, this would result in dose 1 estimates of several REM to the thyroid and a few hundred millirem whole body to an individual spending the first two hours of the source tenn emission directly downwind at the exclusion area boundary during a period of l

~ extremely unfavorable weather, while breathing heavily. It should be noted j that the staff's methods of computing thyroid dose also assume that iodine l remains as elemental iodine during its transport. l l

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l OUESTION 4: What does the NRC believe to be the probability of accidents at a typical BWR and at a typical PWR during low power operation? Identify the dominant accident sequences that could lead to core damage, core melting, or offsite releases.

Additionally, please indicate whether the Comission believes that the probability of mishaps and accidents is higher or lower for plants with a low power license than for plants with a full power license. Please also indicate what has

! been the history of operating experience for plants with low power license and provide any studies or memoranda concerning this subject.

ANSWER.

Estimates of risk reduction were made in recent operating license cases (See Question 1) based on dominant sequences from the Reactor Safety Study (WASH-1400). For PWRS and BWRS, the important sequences are small Loss-of-Coolant accidents and transients, with the addition of the Anticipated Transients Without SCRAM sequence for BWRS. The following major s factors contribute to a substantial reduction in risk at low power operation compared to equilibrium full power operation: ,

A. The reduced decay heat from low power operation results in a significant reduction in the response required to mitigate potential severe accidents and therefore a reduction in the likelihood of core damage. For example, passive heat sinks within the system may be sufficient to delay the need for operator remedial action for several hours before core damage would be a threat, similarly, the cooling water flow rates required to dissipate the low decay heat are reduced by a factor of 20 or more so that numerous small pumps available at a plant may be sufficient to provide adequate cooling in the event that the primary safety systems failed to function.  !

B. The fission product inventory from operation at low power is significantly reduced and therefore the potential risk to the public is also reduced.

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I Regarding minor malfunctions of normally operating systems, there may or may not be a greater number during this initial shakedown period. In any case, .

because of the factors discussed above, it is less likely that a " mishap" at low power operation would lead to a sequence resulting in core damage. With respect to the history of operating experience with low power licenses, attached please find SALP reports covering the first year. operating experience fcr the following plants licensed since the three Mile Island incident:

1. North Anna Nuclear Plant Units 1 and 2, dated November 3,1982

2. Sequoyah Nuclear Plant Units 1 and 2, dated April 13, 1983

3. . Farley Nuclear Plant Units 1 and 2, dated December 6,1982

4. Salem Nuclear Generating Station Units 1 and 2, dated January 11, 1983 f

5. McGuire Nuclear Station Units 1 and 2, dated December 9,1982

6. Diablo Canyon Nuclear. Power Plant Units 1 and 2, dated March 18,.1983

7. San Onofre Nuclear Generatin5 Station Units 2 and 3, dated July 15, 1983 .  !

8. LaSalle County Station Units 1 and 2, dated July 26, 1983

9. Grand Gulf Nuclear Station Unit 1, dtaed January 11, 1984

10. Susquehanna Steam Electric Station Units 1 and 2, dated May 9, 1983

11. V. C. Sunener Nuclear Station Unit 1, dated July 12, 1983

'. 12. St. Lucie Plant Units 1 and 2, dated December 15, 1983 G

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OUESTION 5: For all reactors licensed since the accident at Three Mile j Island, please provide the following (A) the date of issuance  ;

of the low power license; (B) the date of initial '

criticality; (C) the date of 5 percent power operation; (D) the date of issuance of the full power license; (E) the date that power levels of 25 percent or. higher were first attained; (F) the date that power levels of 90 percent or 1 1

higher were to the low firstlicensee power attained; and,(G)(H) exemptions granted by theexemptio NRC to the full power licensee.

ANSWER.

The data requested is provided in the attached Table 5.1. We interpreted tne date of 5 percent power operation to be the date that this power level was exceeded. Where the plant has not achieved the event listed the symbol N/A has been used.

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i CERTIFICATE OF SERVICE, '89 MAY -9 P2 :38

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I certify that'on May 8, 1989, copies of ths0fdre, going ar.f.

. pleading were served by overnight mail or as otherwisC indicated on the attached service list. ^ i i

Diane Curran l

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SEABROOK SERVICE LIST

, Onsite Commission Docketing and Service Branch Sandra Gavutis Diana Sidebotham

(. US Nuclear Regulatory Commission RFD 1, Box 1154 RFD # 2 Box 1260

- **Iando W. Zech Chairman Washington,D.C 20555 East Kensington,NH 03827 Putney,VT 05M6 UA Nuclear Regulatory Commission

. Washington, D.C 20555 John Traficonte, Esquire Judith H. Mizner, Esq.

Assistant Attorney General Silverglate, Gertner, et at

" Thomas M. Roberts 1 Ashburton Place,19th Ploor 88 Broad Street

• By Overnight Delivery Commissioner Boston,MA 02108 -Boston,MA 02110 US Nuclear Regulatory Commission " Hand Delivery Washington, D.C 20555 Stanley W. Knowles "'Ihomas G. Dignan, Esq.

Board of Selectmen R.K. Gad II, Esq.

"J;mes R. Curtiss P.O. Box 710 Ropes & Gray Commissioner Northllampton,NH 03826 One International Place US Nuclear Regulatory Commission Boston, MA 02110 2624 Washington, D.C 20555 J.P. Nadeau Town of Rye Robert A. Backus, Esq.

• • Kenneth M. Carr 155 Washington Road Backus, Meyer & Solomon Commissioner Rye, New Hampshire 03870 111 lowell Street US Nuclear Regulatory Commission Manchester,NH 03105 Washington, D.C 20555 Senator Gordon J. Humphrey US Senate George Dana Bisbee, Esq.

"Kenneth C Rogers Washington,D.C 20510 Geoffrey M. Huntington, Esq.

Commissioner (Atta. Tom Burack) Office of the Attorney General US Nuclear Regulatory Commission State liouse Annex Washington, D.C 20555 Senator Gordon J.Ilumphrey Concord. N1103301 1 Eagle Square, Ste 507 Ahn S. Rosenthal, Chairman Concord,NH 03101 Richard A. Ilampe, Esq.

Atomic Safety and Licensing Hampe and McNicholas Appeal Board Michael Santosuosso, Chairman 35 Pleasant Street U.S. NRC Board of Selectmen Concord, Nil 03301 Washington,D.C 20555 Jewell Street, RFD # 2 South Hampton, NH 03842 Gary W. IIolmes, Esq.

Iloward A.Wilber Holmes & Ellis Atomic Safety and Licensing Charles P. Graham, Esq. 47 Winnacunnent Road

' Appeal Board McKay, Murphy and Graham flampton, N1103842 US NRC 100 Main Street Washington, D.C 20555 Amesbury,MA 01913 William Armstrong Civil Defense Director Petir B. Bloch, Chairman Alfred V. Sargent, Chairman 10 Front Street Atomic Safety and Licensing Board Board of Selectmen Exeter,NH 03833 US Nuclear Regulatory Commission Town of Salisbury, MA 01950 Washington, D.C 20555 Calvin A.Canney Rep. Suzanne Breiseth City Manager Dr. Emmeth A. Luebke Town of Hampton Falls City Hall Atomic Safety and Licensing Board Drinkwater Road 126 Daniel Street 5500 Friendship Boulevard flampton Falls,NII 03844 Portsmouth, Nil 03801 Apartment 1923N Chevy Chase, MD 20815 Phillip Ahrens, Esq. Mrs. Anne E. Goodman Assistant Attorney General Board of Selectmen Richtrd F. Cole State House, Station #6 13-15 New Market Road Atomic Safety and Licensing Board Augusta,ME 01333 Durham,NII 03M2 U.S. Nuclear Regulatory Commission Washington, D.C 20555 " Gregory A. Derry, Esq. Jane Doughty Office of General Counsel SAPL Atomic Safety and Licensing US Nuclear Regulatory Commission 5 Market Street Appeal Board Panel Washington, D.C 20555 Portsmouth,NH 03801 US Nuclear Regulatory Commission Washington,D.C 20555 Allen Lampert R. Scott Hill Whliton Civil Defense Director lagoulis, Clark, Hill-Whilton Atomic Safety and Licensing Town of Brentowood and McGuire Board Panet Exeter, Nil 03833 79 State Street UX Nuclear Regulatory Commission Newburyport,MA 01950 Washington,D.C 20555 Paul McExtern, Esq.

Shaines & McEachern P.O. Box 360 Maplewood Avenue Portsmouth,NII 03801

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