ML19332F970

Joint Affidavit of Gc Minor & Sc Sholly.* Opposes Issuance of Full Power OL Until Problems Noted Resolved,Consistent W/ NRC Finding in Confirmatory Action Ltr CAL-RI/89-11.Addl Info & Certificate of Svc Encl

ML19332F970
Person / Time
Site:	Seabrook
Issue date:	11/30/1989
From:	George Minor, Sholly S MASSACHUSETTS, COMMONWEALTH OF, MHB TECHNICAL ASSOCIATES
To:
Shared Package
ML19332F965	List: ML19332F964 ML19332F970
References
CAL-89-11, CAL-RI-89-11, OL, NUDOCS 8912190402
Download: ML19332F970 (47)

Text

o j Ww ,

iI '

e 1

( '

< UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE COMMISSION l j

i

) i s in the Matter of -). j

, )

PUBLIC SERVICE COMPANY OF .) . Docket No. 50-443 0L i

NEW HAMPSHIRE, ET AL. - ')  !

) November 30,1989 i

-(Seabrook Station Unit 1) ) 4

)

i

' JOINT AFFIDAVIT GREGORY C. MINOR AND STEVEN C. SHOLLY .)

I, Gregory C. Minor,'do make oath and say: ,l P j j

1. My name is Gregory C. Minor. I am a' Vice President of- MHB Technical- l Associates..- My business address is 1723 Hamilton Avenue, Suite K, San Jose, California 95125. I l received a B.S. in Electrical Engineering from the University of California, Berkeley, in 1960 and h a M.S. in Electrical Engineering' from Stanford University in 1966. i l

2. I have over twenty-five years experience in the design, development, research, start-up testing, and management of nuclear reactor systems. From 1960 1076, I worked for General q Electric Company in the design, development, and testing of safety and control systems for nuclear f power plants. My responsibilities included equipment and systems design, as well as management of a large engineering group responsible for new control room design.

^

8912190402 891201 PDR G ADOCK 05000443

,, PDR

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

. 3. For the past thirteen years, I have been an independent technical consultant. In that u

capacity, I have participated in a variety of studies addressing nuclear facility economic, management, and safety issues for various organizations, including the Department of l

Energy /Sandia National Laboratories, the Swedish Government, and the offices of several states' Attorneys General. I am currently a consultant on several nuclear plant cases in which design, management, and compliance with existing regulations are being investigated.

4. I am a member of the Nuclear Power Plant Standards Committee for the

Instrument Society of America. Also, I participated in a Peer Review Group of the Nuclear Regulatory Commission's Three Mile Island Special Inquiry Group. Further details' of my

. qualifications "".d professional experience are summarized in my Statement of Professional Ounlifications which is appended to this affidavit at Attachment 1.

I, Steven C. Sholly, do make oath and say:

5. My name is Steven C. Sholly.. Since September 1985, I have been employed as an Associate Consultant by MHB Technical Associates. My business address is 1723 Hamilton Avenue, Suite K, San Jose, California 95125.

i 6. I have been previously employed by the Union of Concerned Scientists as a Technical Research Associate and Risk Analyst from February 1981 to September 1985, and by ll the Three Mile Island Public Interest Resource Center as Research Coordinator and Project L Director from January 1980 to January 1981. I also have non nuclear experience in the

?

L wastewater treatment and science education fields from September 1975 to January 1980. I received a B.S. in Education, with a major in Earth and Space Science and a minor in Environmental Education, from Shippensburg State College (now Shippensburg University),

Shippensburg, Pennsylvania, in 1975.

2-

L l i

0 l

7, For the last nine and a half years, I have been engaged in analyzing technical nuclear safety, management, design, construction, and regulatory issues and providing technical advice to state and local governments (including the States of California, New York, Illinois, Pennsylvania, hiaryland, hiaine, Connecticut, and biassachusetts, and Suffolk County, New York) )

and independent organizations on these issues. I have presented testimony concerning these j L issues before the Connecticut Department of Public Utility Control on behalf of the Prosecutorial Division and Division of Consumer Counsel, before the California Public Utility Commission on behalf of the Division of Ratepayer Advocates, before the Pennsylvania Public Utility Commission j on behalf of the Office of Consumer Advocate, and before the hiassachusetts Department of  ;

Public Utilities on behalf of the Office of the Attorney General, Comrnonwealth of hiassachusetts.

I.have also participated as an expert witness in proceedings before the Atomic Safety and Licer: sing Board in the Indian Point Special Investigation and the operating license review of the Catawba nuclear plant, and have presented testimony before the United States Congress and the I

Sizewell Inquiry (U.K.) on nuclear safety issues. Further details of my experience and qualifications are contcined in my Statement of Professional Oualifications which is appended to this affidavit as Attachment 2.

DISCUSSION

8. On hiay 26,1989, New Hampshire Yankee received a license from the U.S. Nuclear Regulatory Commission permitting low power operation (not to exceed 5% of full power, with certain other restrictions) of Seabrook Unit 1 (License No. NPF 67).

9. NRC regulations at 10 CFR 50, Appendix E, require the conduct of an exercise to test the operation license applicant's ability to respond to a radiological emergency. During such an exercise, an accident is simulated, and the applicant's ability to achieve certain objectives is 3

l 1

evaluand by the NRC and the Federal Emergency Management Agency (FEMA). In June 1988, l l

a FEMA /NRC graded exercise was conducted at Seabrook Unit 1. Among the established J l

objectives ior the exercise was to *(d)emonstrate the ability to analpe station conditions, parameter trends and develop potential solutions for placing the unit in a safe, stabic condition. y The l scenario for that exercise included a large break thCA which occurred during efforts to restore q an emetgency feedwater pump. Notwithstanding the occurrence of the large break LOCA, plant personnel were directed to continue efforts to restore an emergency feedwater pump. This action was illogical since the emergency feedwater system cannot help achieve safe shutdown in the event of a large break I.OCA, and the action would have accomplished nothing in a real large break  :

LOCA event toward

• develop [ing] potentialsolutions forplacing the unit in a safe, stable condition.

Indeed, New Hampshire Yankee's own Seabrook Unit 1 probabilistic risk assessment 1/ studies do not include the emergency feedwater system in the system event tree for large break LOCAs for that very reason. Continuation of efforts to recover an emergency feedwater pump following a large break LOCA represented a very poor judgment on the part of plant management. V ,

1/ Report of the 1988 FEMA /NRC Graded Exercise, at 2.2 2.

2/ A probabilistic risk assessment (FRA)is an analysis of the likelihood and conseguences of l postulated severs accidents. The objective of a PRA is to " identify and delmeate the L combinations of events that, if they occurred, could lead to undesirable public conscQences and to estimate the magnitude of those consequences and their respective probabilities . Sgt, Office of Nuclear Regulatory Research, U.S. Nuclear Re allatory Commission, Probabilistic Risk Assessment (15 RA) Reference Document, Final Report, NUREG-1050, September 1984, at 10. The NRC has published a procedures guide for the conduct of PRAs. Ses, U.S. Nuclear Regulatory Commission, PRA Procedures Guide A Guide for

! . -the Performance of Probabilistic Risk Assessments for Nuclear 'ower Plants.

NUREG/CR 2300, Vols.12, January 1983.

3/ New Hampshire Yankee has stated, and the NRC staff has agreed, that the EFW pump would be required to operate to support steam encrator cooldown in the recovery nhase ,

and that continued repair actions were arudent RC Inspection Report 8810, Octo >er 6, 1988). This is not correct. Following a t.rge bre k LOCA, the only heat transfer surface in the steam generators is that of containment atmosphere on the prirnary side (admittedly containing some steam) and, if EFW is available, water from the condensate storage tank on the secondary side. This is a vsIy inefficient heat transfer configuration, and one which would have no measurable effect on removing decay heat from the core or heat in general from the containment. Following a large break LOCA at Seabrook, the residual heat removal system would be relied upon to remove heat from the core and the containment spray system would be relied upon to remove heat from the containment. The EFW system

1

10. On May 3,1989, the Regional Administrator wrote a memorandum to the Director of the Office of Nuclear Reactor Regulation in which he noted a *possible declining trend infacility .

performance", and observed that two events which constituted part of this trend involved " violations of the special zero power license conditions associated with locked valves". Notwithstanding these concerns, however, the Regional Administrator recommended issuance of a low power license, which was granted less than three weeks later.

11. Operational performance has continued to decline. On June 23,1989, following an incident during the conduct of a natural circulation test (1 ST 22) at low power (described below),

the NRC Region I Administrator issued a Confirmatory Action l2tter (CAL 8911) which, among other things, prohibits New llampshire Yankee from operating Seabrook Unit 1 until the Regional Administrator grams his consent. The terms of CAL 8911 prohibiting operation until the Regional Administrator grants his consent remain in effect (CAL 8911 is provided as Anachment 3).

12. During low power testing on June 22,1989, involving a natural circulation test, plant personnel failed to manually trip (i.e., shut down) the rer.ctor in a timely fashion despite exceeding l

l the manual trip criterion. The reactor was later tripped manually only when it became clear that an automatic scram was inevitable (due to factors other than the one which caused the manual trip simply cannot accomplish either of these safety functions (or any other safety f_ unction, for l that matter) following a large break LOCA. In th< event of a large LOCA, EFW l availabilit defueled,y afRIwould be material the large break LOCA onhbreak afat safe locative shutdow !s reached, is repaired, afgr theis reactor afRI the reactor refueled, and afMI the reactor is restarted and some level of c ecay heat is accumulated in the core. These actions would almost certainly have required weeks, if not months, to complete, and would have been taken well after the accident was terminated and the Technical Support Center destaffed. Accordingly, EFW availability would have had no impact whatsoever on " steam generator cooldown m the recovery phase". New liampshire Yankee and NRC staff statements to the contrary demonstrate n remarkable level of ignorance about the capabilities of the emergency feedwater system and its role in recovering from a large break LOCA.

5-

c .

I f

criterion to be exceeded). The plant personnel in the control room who observed this condition included the entire five person licensed operator crew (including the Unit Shift Supervisor), all of whom had the authority to manually trip the reactor, as well as Startup Manager, the Test Director, the Assistant Operations Manager, and a host of additional management and operations ,

personnel. Following this event, the Vice President Nuclear Production of New Hampshire Yankee *made a decision to resume testing without completing a detailed and thorough analysis of the underlying causes of the event and without correcting the related human performance deficiencies" (NRC Notice of Violation, October 25,1989). The next day, as noted above, the NRC Regional Administrator issued a Confirmatory Action letter precluding further operation without his consent, and the terms of the CAL remain in effect. Moreover, subsequently (October 25,1989) the NRC staff issued a Notice of Violation and imposed a $50,000 civil penalty related to these events. #

13. On September 15, 1989, the NRC staff informed New Hampshire Yankee that during the week of December 11,1989,it plans to evaluate the proficiency of all Seabrook shift crews under simulated accident conditions. This is an extraordinary measure that is, to our knowledge, unprecedented. Once nuclear power plant operators have passed their NRC-administered operators' license examinations, as Seabrook's operators have, the NRC does not generally subject them to additional testing under simulated accident conditions. Moreover, this proposed test is unusual in that it will evaluate all of the Seabrook shift operating crews, not just the one crew on duty at the time of the June 1989 natural circulation test. In our view, the NRC's intention to require proficiency evaluations of all of the Seabrook operators under simulated accident conditions accurately reflects the extremely serious ncture of the problems evidenced during the failed natural circulation test on June 22,1989. (The NRC staff letter informing New Hampshire Yankee of the operator proficiency evaluations is provided as Attachment 5.)

y The NRC's Notice of Violation and proposed imposition of civil penalties is provided as Attachment 4.

6-

14. The events discussed above give rise to serious questions about the judgment of New Hampshire Yankee personnel in operating Seabrook Unit I at power levels above 5% of full power. Human performance is well recognized as an important contributor to the risk of nuclear power plant operation even when operational performance is otherwise nominal. For instance, the NRC's "PRA Reference Document" (NUREG 1050), which summarized insights from dozens of PRA studies, indicated that human interactions with plant safety systems *are extremely 9

important contributors to safety and reliability" of nuclear power plants, that the reliability of human actions important to safety (as well as systems and components important to safety) must be maintained during operation, and that degradation in their reliability can " sharply increase the risk or likelihood of core melt". f/ Human reliability is also important specifically at Seabrook.

Among the twenty most likely accidents at Seabrook, New Hampshire Yankee's 1983 PRA study of Seabrook identified several accident scenarios where human actions are an important factor (i.e., actions such as recovering failed systems, failure to establish long term decay heat removal, ,

failure to establish feed and bleed cooling, failure to perform emergency boration, etc.). 6/

15. In addition, it is well recognized in the PRA field that the likelihood of core damage frequency may be higher in the first year or two of full power operation. This is in part due to the well recognized fact that transient events which can initiate accidents are much more likely in the 5/ Office of Nuclear Regulatory Research, Probabilistic Risk Assessment (PRA) Reference Document, Final Report, NOREG 1050, September 1984, at 6 and 64.

6/ Pickard, I. owe and Garrick, Inc., Seabrook Station Probabilistic Safety Assessment, PLG-0300, December 1983, at 2.310 and 2.311. It should be noted moreover, that Seabrook's 4

core damage frequency is estimated by that study to be 2.3 x 10 per reactor year, or about one chance in 4,300 per reactor year for n mature olant assumine nominal human oerformance, lhid, Given declining human performance, one would generally expect the

' core damage frequency to increase due to increasing human error rates. This expectation is confirmed in a recent Brookhaven National Laboratory study for the NRC staff (using the Oconee plant as a case study) which concluded that small changes in human error rates could have significant impacts on risk. Sn, P. Samanta, et al., Risk Sensitivity to Human Error, Brookhaven National laboratory, prepared for the Office of Nuclear Reactor Regulation, NUREG/CR 5319, April 1989, at ES 3.

. 7 s,,re- ---.-- -

first two years of operation. For example, data for the period of 19841988 compiled by the NRC's Office for Analysis and Evaluation of Operational Data indicate that mature Westinghouse plants have a frequency of transients resulting in reactor trip of 0.61 trips /1,000 critical hours, whereas new plants had a frequency of 1.95 trips /1,000 critical hours - a difference of a factor of more than three (on average). Similarly, personnel errors are a more frequent contributor to reactor trips for new plants than for mature plants - a rate of 0.17 trips /1,000 critical hours for new plants compared with a rate of 0.53 trips /1,000 critical hours caused by personnel errors, again a factor of more than three difference (on average). 2/

16, Given these circumstances, declining operational performance in the year preceding the full power operation is a very serious matter. To allow Seabrook to initiate operations at full power before resolving the problems identified above would pose an unacceptable and unnecessary added risk to public health and safety.

17. In cases of declining performance invoh'ing operating plants, the NRC has not hesitated to step in and cause a cessation of operations (whether by Confirmatory Action letter or by Order) until the performance problems are corrected and a period of improved performance is seen. 8/ In the case of Seabrook Unit 1,which is licensed for low power testing, there is no basis for more lenient treatment, in our opinion, the NRC should not consider issuance of a full power license until the performance problems identified above are resolved, and until New Hampshire Yankee demonstrates by a period of troublefree activities that it is fully and adequately prepared to undertake power operations. The NRC should assure itself of New Hampshire Yankee's 2/ Office for Analysis and Evaluation of Operational Data,1988 Annual Report, NUREG.

~

1272, Vol. 3, No.1, June 1989, at A 59, A 63, A 88, and A 92.

B/ For example, this was the staff ractice in the case of Pilgrim (shutdown under Confirmatory Action letter from til 1986 until December 1988) and Peach Bottom Units 2 and 3 (shutdown under Orde from March 1987 until April 1989). Other examples exist as well (Calvert Cliffs Units 1 and 2, Rancho Seco, Davis Besse, Browns Ferry Units 1, 2, and 3, and Sequoyah Units 1 and 2.

l 8 j

o~

readiness to safely conduct power operations by completion of the planned operator proficiency I evaluation, and by conduct of a detailed operational readiness inspection by an inspection team l consisting of experts in the various relevant operational disciplines (licensed operators, ,

nonlicensed operators, training, radiological chemistry, health physics, maintenance, management, r I

and so on). (Such inspections have been performed at other plants which have been shut down due to perfumance problems.)

18. Accordingly, we conclude that it is premature to issue a full power operating license until the problems identified above have been resolved. Indeed, the NRC has tacitly acknowledged as much by requiring a halt in low power operation (CAL 8911) and by requiring an unprecedented operator proficiency evaluation of all licensed operators at Seabrook.

Signed under the pains and penalties of perjuiy this 30th day of November 1989.

?-

_  % C. '

t Steven C. Sbolly y f' Stat f . On this the ay of M._ OO M b R 19M, bef ore me.  ;

County of ___ N J M b .

the undersigned Notar Public, personally appeared j

t STudes c. SLt L1, .

( u**^^^^-^^^- ^a _ personally known to me

{. 7 ,

roved to me on the basis of satisf actory evidence to be the person (s) whose name(s) subscribed to the N01ARY PJBUC.CAtt0RNA

{ SANTA CW C0JNTY  : within instrument,and acknowledged that _ executed it, j

-x y v v v - vv v,?

MtComm.Esoressect 30.1993 w;7 N ESS my hand and of ficial seal.

l -.

01%n 0 Notar)'s Signature

^

i

[

W '

... ..J cinian acawows:powtut e owu neeu =atio~a .woiaso Associatio= . rma. ave e..e . wao..a n o, ca eou

-- .~

h 9

1 a

1 j

Signed under the pains and penalties of perjury this 1st day of December 1989. I l

1 i

- Gregory C. Minor i 3

1 t

e b

V s

e e

e i

10-

o .  :

i i

l I

!. I i

a I

h' l i

+

ATTACHMENT 1 Statement of Professional Qualifications t Gregory C. Minor L

f s

i 1

y h

+

i

,  ?

e ,. ..

14 PROFF_CCIONAL QUALIFICATIONS OF GREGORY C. MINOR GREGORY C. MINOR MHB Tachniemi Anociates 1723 Hamilton Avenue Suite K San Jose, California 95125 (408) 266-2716 EXPERIENCE:

1976 to PRESENT Vice.Prsident . MHB Teekalcal Auneintet Can Jnse Onlifornia Engineering and energy consultant to state, fedeial, and private organizations and individuals. Major activities include studies of safety and risk levolved in energy generation, providing technical consulting to legislative, regulatory, public and private groups and expert witness in behalf of state organizations and citizens' groups. Was co. editor of a critique of the Reactor Safety Study (WASH 1400) for the Union of Concerned Scientists and co. author of a risk analysis of Swedkh reactors for the Swedkh Energy Commiulon. Served on the Peer Review Group of the NRC/I'MI Special Inquiry Group (Rogovia Committee). Actively involved in the Nuclear Power Plant Standards Committee work for the Instrument Society of America (ISA).

1972 1976 Maamaer. Advanced Control and Instrumentation Fnaineerina General Electric Camnanv. Nuclear Fnerry Divkion. San Jnte. California Managed a design and development group of thirty four enginects and support personnel designing systems for use in the measurement, control and operation of nuclear reactors, involved coordination with other reactor design organizations, the Nuclear Regulatory Commluion, and customers, both overseas and domestic. Responsibilities included coordinating and managing and design and development of control systems, safety systemt, and new control concepts for use on the next generation of reactors. The position included responsibility for standards applicable to control and instrumentation, as well as the design of short term solutions to field problems. The disciplines involved included electrical and mechanical engineering, seismic design and procca computer con-trol / programming, and equipment qualification.

1970 1972 Mannocr. Reactor Control Systems Declan General Electric Comnanv. Nuclear Fnerav Divkion Kan Jose. California Managed a group of seven engineers and two support personnel in the design and preparation of the detailed system drawmgs and control documents relating to safety and emergency systems for nuclear reactors. Responsibility required coordination with other design organizations and interaction with the customer's er.gineering personnel, as well as regulatory personnel.

1

t s .

1 % 3 1970 t rwt Fnes..,, General whee,1c camnanv. Nurbar Faarev Divitian Ran Jnae. california Responsible for the design of specific control and instrumentation systems for nuclear reactors. Lud .

design respons*bility for various subsystems of instrumentation used to measure neutron flux in the  :

reactor during startup and intermediate power operation. Performed lead system design function in the design of a major system for measuring the power generated in nuclear reactors. Other responsibilities included on-site ebeckout and testing of a complete reactor control system at an experi-mental reactor in the Southwest. Received patent for Nuclear Power Monitoring System.

1960 1 % 3 Advanced Fnnineerine Proaram General Flectric Comnany' Attienments in Watkinaton. California.

and Amana Rotating assignments in a variety of disciplines:

- Engineer, reactor maintenance and instrument design, KE and D reactors, Hanford, Washington, circuit design and equipment maintenance coordination.

- Design engineer, Microwave Department, Palo Alto, California. Work on design of cavity couplers for Microwave Traveling Wave Tubes (TWT). ,

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

- Design engineer, Atomic Power Equipment Department, San Jose, California. Circuit design

and analysis.

- Design engineer, Space Systems Department, Santa Barbara, California. Prepared control l l

portion of satellite proposal.

l L - Technical Staff . Technical Military Planning Operation. (TEMPO), Santa Barbara, California. Prepare analyses of missile exchanges.

During this period, completed three year General Electric program of extensive education in advanced ,

engineering principles of higher mathematics, probability and analysis. Also completed courses in Kepner.Tregoe, Effective Presentation, Management Training Program, and various technical seminars.

EDUCATION University of California at Berkeley, BSEE,19(4.

(

Advanced Course in Engineering . three year curriculum, General Electric Company,1%3.

Stanford University, MSEE,1966.

l' 2

L - . . - -

t 6

HONOR.C AND ASSOCIATIONS

- Tau Beta Pi Engineering Honorary Society

. Co bolder of U.S. Patent No. 3,565 760, ' Nuclear Reactor Power Monitoring System,'

February,1971.

. Member: American Association for the Advancement of Science.

. Member: Nuclear Power Plant Standards Committee,lastrument Society of America.

PUBLICATIONS AND TESTIMONY

1. G. C. Minor, S. E. Moore, ' Control Rod Signal Multiplexing,' IEEE Transactions on Nuclear Science, Vol. NS 19, February 1972.

2. G. C. Minor, W. G. Milam,'An Integrated Control Room System for a Nuclear Power Plant,' NEDO-10658, presented at International Nuclear Industries Fair and Technical Meetings, October,1972, Basle, Switzerland.

3. The above article was also published in the German Technical Magazine, NT, March,1973,

4. Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the Joint Committee on Atomic Energy, Hearing held February 18,1976, and published by the Union of Concerned Scientists, Cambridge, Massachusetts.

5. Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the California State Assembly  ;

Committee on Resources, Land Use, and Energy, March 8,1976.

6. Testimony of G. C. Minor and R. B. Hubbard before the California State Senate Committee on Public Utilities, Transit, and Energy, March 23,1976.

7. Testimony of G. C. Minor regarding the Grafearbeinfeld Nuclear Plant, March 1617,1977, Wurzbuerg, Germany,

8. Testimony of G. C. Minor before the Cluff Lake Board of Inquiry, Regina, Saskatchewan, Canada, September 21,1977.

9.. The Risks of Nuclear Power Reactors

• A Review of the NRC Reactor Safety Study WASH 1400

. (NUREG.75/014), H. Kendall, et al, edited by G. C. Minor and R. B. Hubbard for the Union of Concerned Scientists, August,1977.

10. Swedish Reactor Safety Stude Barseback Risk Assessment, MHB Technical Associates, January,1978.

(Published by Swedish Department of Industry as Document Dsl 1978:1)

11. Testimony by G. C. Minor before the Wisconsin Public Service Commission, February 13,1978, LossA Coolant Accidents Their Probability and Consecuence.

12. Testimony by G. C. Minor before the California legislature Assembly Committee on Resources, land Use, and Energy AB 3108, April 26,1978, Sacramento, California.

3

.___-_______-_s

I s l l

l

13. Presentation by G. C. Minor before the Federal Ministry for Research and Technology (BMFT), j Meeting on Reactor Safety Research, Man / Machine Interface in Nuclear Reactors. August 21, and  :

September 1,1978, Bonn, Germany. I 1

14. Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard, before the Atomic Safety and I Ucensing Board, September 25,1978, in the matter of Black Fox Nuclear Power Station Construction l Permit Hearings, Tulsa, Oklahoma. l 1

15. Teatimony of G. C. Minor, ASLB Hearings Related to TMI.2 Accident, Rancho Seco Power Plant, on l behalf of Friends of the Earth, September 13,1979. j 16.' Testimony of G. C. Minor before the Michigan State legislature, Special Joint Committee on Nuclear Energy,1mnl cations of Three Mile Island Accident for Nuclear Power Plants in Michiaan October 15, 1979. l

17. A Critical View of Reactor Safety. by G. C. Minor, paper presented to the American Association for the Advancement of Science, Symposium on Nuclear Reactor Safety, January 7,1980, San Francino, California.

18. The Effects of Acine on Safety of Nuclear Power Plants. paper presented at Forum on Swedish Nuclear Referendum, Stockholm, Sweden, March 1,1980.

19, Mii nesota Nuclear Plants Gaseous Emissions Study, MHB Technical Associates, September 1980, prepared for the Minnesota Pollution Control Agency, Roseville, MN.

20. Testimony of G. C. Minor and D. G. Bridenbaugh before the New York State Public Semce Commission, Shoreham Nuclear Plant Construction Schedule. in the matter of long Island Lighting Company Temporary Rate Case, case # 27774 September 22,1980.

21. Direct testimony of Dale G. Bridenbaugh and Gregory C. Minor before the New York State Public Service Commission, Kaiser Engineers Power Corporation Review, t Shoreham Nuclear Power Station Costs and Schedule. in the matter of long Island Lighting Company Temporary Rate Case, Case Number 27774, September 29,1980.

22. Systems Interaction and Sincie Failure Criterion. MHB Technical Associates, January,1981, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.

l 23. Testimony of G. C. Minor and D. G. Bridenbaugh before the New Jersey Board of Public Utilities, Ovster Creek 1080 Refuelinc Outace Investication. in the matter of the Petition of Jersey Central Power I and Light Company for approval of an increase in the rates for electrical service and adjustment clause and factor for such service, OAL Docket No. PUC 3518-80, BPU Docket Nos. 804 285, 807-488, February 19,1981.

24. Testimony ol G. C. Minor and D. G. Bridenbaugh on PORV's and Pressuri7er Henters, Diablo Canyon Operating Lic-nse hearing before ASLB,in the matter of Pacific Gas and Electric Company (Diablo Canyon Nucleat Power Plant, Units 1 and 2), Docket Nos. 50-275-OL,50 32.tOL, January 11,1982.

25. Testimony of G. C. Minor and R. B. Hubbard on Emercency Resnonse Planninc. Diablo Canyon Operating License hearing before ASLB, Docket Nos. 50 275 OL,50-32.kOL, January 11,1982.

26. Systems Interaction and Sincie Failure Criterion: Phase il Renoll, MHB Technical Associates, February 1982, prepared for t.nd available from the Swedish Nuclear Power inspectorate, Stockholm, Sweden.

4-

27. Teatimony of G. C. Minor, R. B. Hubbard, M. W. Goldsmith, S. J. Harwood on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of long Island Ughting Company, l Shoreham Nuclear Power Station, Unit 1, regarding Contention 7B, saferv O- :'ientian and Svate=a LalstaniGB. Docket No. S322 Oi, April 13,1982.

28. Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety l and Licensing Board, in the matter of long Island Lighting Company, Shoreham Nuclear Power Station, 4 Unit 1, regarding Suffolk County Cantentian 11. Pat =ive Meekmatent Valve Falhwe. Docket no. 50 322- I i

OL, April 13,1982,

29. Teatimony of G. C. Minor and R. B. Hubbard on behalf of Suffolk County, before the Atomic Safety and Ucensing Board, in the matter of long Island Lighting Company, Shoreham Nuclear Power Station, i Unit 1, regarding Suffolk County Contention 27 anni SOC Cantention 1 Post.Aerident Moniinrino 1 Docket No.50 322 OL, May 25,1982.

30. Testimony of G. C. hiinor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety l and Licensing Board,in the matter of long Island Lighting Company, Shoreham Nuclear Power Station,  !

Unit 1, regarding Suffolk County Contention 22. SRV Test Pronram. Docket No. 50 322-OL, May 25, ]

1982.

Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety l 31.

and Ucensing Board,in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, )

Unit 1, regarding Reduction of SRV Challences. Docket No. 50-322 OL, June 14,1982. j

32. Testimony of G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Ucensing Board,in the mmer of long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, regarding Enviran= ental Oumlification. Docket No. 50 322-OL, January 18,1983.

l 33. Teatimony of G. C. Minor and D. G. Bridenbaugh before the Pennsylvania Public Utility Commission, I on behalf of the Office of Consumer Advocate, Renardino the Cost of Constructine the Susouch==nm Steam Electric Statinn. Unit 1. Re: Pennsylvania Power and Light, Docket No. R 822189, March 18, 1983.

l 34 Supplemental testimony of G. C. Minor, R. B. Hubbard, and M. W. Goldsmith on behalf of Suffolk l

County,before the Atomic Safety and Licensing Board,in the matter of LongIsland Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Safety Cimification and Svstems Interaction fContention 7B). Docket No. 50-322, March 23,1983.

35. Verbal testimony before the District Court Judge in the case of Sierra Club et. al. vs. DOE regarding the Clean.up of Uranium Mill Tailings. June 20,1983. 3

36. Systems Interaction and Sincle Failure Criterion: Phase 3 Report. MHB Technical Associates, June, 1983, prepared for and available from the Swedish Nuclear Power laspectorate, Stockholm, Sweden.

1

37. Systematie Evaluation Program: Status Report and initial Evaluation. MHB Technical Associates, June, 1983, prepared for and available from the Swedish Nuclear Power laspectorate, Stockholm, Sweden.

38. Testimony of G. C. Minor, F. C. Finlayson, and E. P. Radford before the Atomic Safety and Licensing Board, in the Matter of long Island Ughting Company, Shoreham Nuclear Power Station, Unit 1, regarding Emercenev Plannine Evacuation Times and Doses (Contentions 65. 23.D and 21H). Docket No. 50 322 OL 3, November 18,1983.

39. Testimony of G. C. Minor, Sinwell 'B' Power Station Public inquiry, Proof of Evidence Recardinc Safety Issues, December,1983.

l l

5

40. Teatimony of D. G. Bridenbaugh, L. M. Danielson, R. B. Hubbard and G. C. Minor before the State of New York Public Service Commission, PSC Case No. 27%3, in the matter of Long Island Ughting  !

Company Proceeding to inveatiente the Coat of the Shar*kam Nacione Generatina Faettiev - Phagj, I

on behalf of County of Suffolk, February 10,1984.

41. Teatimony of Fred C. Finlayson, Gregory C. Minor and Edward P. Radford before the Atomic Safety and ucensing Board,in the Matter of Long Island Lighting Company, Shoreham Nuclear Power Station, ,

Unit 1, on behalf of Sufic,lk County Regarding ha*aenev PI---" Ekeherian Tanimatian 61L Docket No. 50 322-OL, March 21,1984. .

42. Testimony of G. Dennis Eley, C. John Smith, Gregory C. Minor and Dale G. Bridenbaugh before the Atomic Safety and Licensing Board,in the matter of long Island Lighting company, Shoreham Nuclear Power Station Unit 1, regarding EMD Diesel Generators and 20 MW Gas Turbine. Docket No. 50 322 OL, March 21,1984.

43. Revised Testimony of Gregory C. Minor before the Atomic Safety and Ucensing Board,in the matter of ihng Island Lighting Company, Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County regarding Fenernenev Plannine - Recoig; and Reentry (Contentinns R$ anti Rat Docket No. 50-322-OL, July 30,1984.

44. Testimony of Dr. Christian Meyer, Dr. Jose Roesset, and Gregory C. Minor before the Atomic Safety and Licensing Board,in the matter of Long Island Ughting Company,Shoreham Nuclear Power Station i

Unit 1, on behalf of Suffolk County,regarding Low Power Hearinns Seismic Canabilities of AC Power

• Sources, Docket No. 50 322 OL, July 1984

45. Surrebuttal Testimony of Dale G. Bridenbaugh, Lynn M. Danielson, Richard B. Hubbard, and Gregory C. Minor, Before the New York State Public Senice Commission, PSC Case No,27563, Shoreham Nuclear Station, long Island Ughting Company, on behalf of Suffolk County and New York State Consumer Protection Board, regarding Investiention of the Cost of the Shoreharn Nuclear Generatino Eanigy, October 4,1984.

46. Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C. Minor on behalf of Massachusetts Attorney General, DPU 84-145, before the Massachusetts Department of Public Utilities, regarding Prudence of Emenditures by Fitchburc Gas and Electric Licht Comnany for Seabrook Unit 2.

November 23,1984, S4 pgs.

47, Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C. Minor on tchalf of Maine Public Utilities Commission Staff regarding Prudence of Costs of Seabrook Unit 2. Docket No.84-113, December 21,1984.

l 48. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Suffolk County regarding Shoreham Emercency Diesel Generator Lands. Docket No. 50-322 OL, January 25,1985.

49. Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson, and Gregory C. Minor on behalf of the Vermont Department of Public Senice, PSB Docket No. 5030, regarding Prudence of Central Vermont <

Public Senice Corporations Costs for Seabrook 2, November 11,1985.

50. Surrebuttal testimony of Gregory C. Minor on behalf of the Vermont Department of Public Senice, PSB Docket No. 5030, Prudence of Central Vermont Public Senice Corporations Costs for Seabrook 2, December 13,1985.

3. _ 7 w  !

l

$1. Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price, and Stewn C. Sholly on behalf of State of Connecticut Department of Public Utility Control Prosecutorial Division and Division of Consumer Counsel regarding the Prudence of F*aanditures on Millstone Unit 3. Docket No. 83 07 03 February 18,1966, i

52. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney )

General regarding the Pradaara of Fraend'tures by New Fant ad Power Co. for (*=hrank Unit 2.

Docket Nos. ER 85-646-000, ER 85-647 000, February 21,1966. l

$3. Direct Testimony of Gregory C. Minor on behalf of the Prosecutorial Division of CDPUC regarding .

rt AP Canttructinn Prudence for Millstone Unit 3. Docket No. ER 85 720-001 March 19,1966. ]

$4. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding WMECo Canttruction Prudence for Millstone Unit 3. Docket No. 85 270, March 19, 1986.

55. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney j General regarding WMECo's Commercial Oncratine Dates and Deferred ranital Additions on Milltrone Unit 3. Docket No. 85 270, March 19,1986. ,

l

56. Rebuttal Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding Rebuttal to New Enoland Power Comnany's Seabrood, Docket Nos. ER 85-646-001, ER-85-647 001, April 2,1986.

57. 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 i l

Minine Power Company Proposed increase in Rates, Docket No. 85 212, April 21,1986.

i' ' 58. Imnlientiant of the Chernobyl-4 Accident for Nuclear Emernency Planninc for the State of New York. i

! prepared for the State of New York Consumer Protection Board, by MHB Technical Associates, June l 1986.

Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behdf of the Vermont Department

(. 59.

of Public Service, regarding Prudence of Costs by Central Vermont Public Service Cornoration for i

Millstone 3. Docket No. 5132, August 25,1986. j

60. Surrebuttal Testimony of Gregory C. Minor in the matter of Jersey Central Power and Light Company, I

I regarding TM1 Restart and Performance incentives. (Oral testimony), OAL Docket No. PUC 7939 85, BPU Docket No. ER851116, September 11,1986.

. 61. Surrebuttal Testimony of Gregory C. Minor on behalf of State of Vermont Department of Public Service, regarding CVPS/NU Construction Prudence related to Millstone Unit 3. DocLet No. 5132, Novemher 6,1986. )

l 62. Direct Testimony of Gregory C. Minor and Lynn K. Price on behalf of State of Vermont Department of Public Service, regarding Prudence of Exnenditures for Seabrook 1. Docket No. 5132, December 31, 1986.

63. Direct Testimony of Gregory C. Minor on behalf of Suffolk County, before the Atomic Safety and Licensing Board, concerning Shoreham - Protective Action Recommendations (Contention EX 361, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, Docket No. 5(k 322 OL 5, February 27,1987, i

7

i

• i i

1

64. L+irect Testimony of Gregory C. Minor et. al. on behalf of the State of New York and Suffolk County, i before the Atomic Safety and Licensing Board, regarding The bane of the F=armenev P'a:aa j Fuercise fenntentiana EX 15 and 161 in the matter of long Island Lighting Company, Shoreham )

Nuclea: Power Station, Unit 1, Docket No. 50 322-Ob5, April 6,1987. J

65. Direct Testimony of Gregory C. Minor regarding F=araanev Planaia Recentian centers Mantencian  !

and Decontaminatiop. Shortham Docket 50 322 Ob3 (Emergeney Planning), April 13,1987. l l

\

66. - Teatimony of Gregory C. Minor, Steven C. Sholly et. al. on behalf of Suffoll County, regarding LILCCh ,

n.,.neinn r,nters . Plaaataa hile before the Atomic Safety and Licensing Board, in the matter of I long Islead Lighting Company, Shoreham Nuclear Power Station Unit 1, Docket No. 50-322 Ob3, April 13,1987.

67. Rebuttal Testimony of Gregory C. Minor and Steven C. Sholly on behalf of Suffolk County regarding ,

LILCO's Recentinn renters (Rebuttal to Testimnnv of 12wis G. Hulmant in the matter of long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, Docket No. 50 322-Ob3, May 27,1987. I

68. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General, before the Federal Energy Regulatory Commission, regarding canal Electric Cnmnany Prudence Related to Seabrook Unit 2 Constructinn Frnenditurn, Docket No. ER86 704-001, July 31, 1987.

69. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor before the Pennsylvania Public Utility l Commission, Regarding Beaver Vallev Unit 1 1970 Outanc. Docket No.179070318, OCA Statement No.

2, August 31,1987.

70. Oral testimony of Gregory C. Minor Before the Illinois Pollution Control Board on behalf of Reed-Custer Community Unit School District No. 255-U, re: Braidwood Cooline Por.d September 8,1989, Case PCB 87 209. .

71. Testimony of Gregory C. Minor in the U. S. District Court, Brooklyn, New York, September 31,1988, re: County of Suffolk vs. Lil CO et. al Case CV 87 646.

72. GE Reed Reoort Safety tune Reviews, Issues 5,10, and 24, prepared by MHB Technical Associates for The Ohio State University Nuclear Engineering Program Expert Review Panel, Public Utility Commission of Ohio, October 198S.

73. Direct Testimony and Exhibits of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station, Invectientinn of Pilcrim Outane. DPU 88 28, November 30,1988, PROTECTED INFORMATION.

i 74. Supplemental Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station, investication.cf l

Pilarim Outace. DPU 88-28, January 20,1989, Exhibit AG.2.

75. Testimony of Gregory C. Minor, U. S. District Court, Brooklyn, New York, February 3,1989, re: County of Suffolk vt LILCO et. al Case 87 CIV. 646 (JBW).

76. Surrebuttal Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Uchalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station,investiention of Pilarim Ontace. DPU 88 28, Februaiy 13,1989, Exhibit AG 74.

L l

l

.g.

,.  ?

'I O -- )

a

'i

77. Surrobuttal Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station,invaatisation of Pilgrim Outape. DPU 88 28, February 17,1989, Exhibit AG 93. i

78. Waev --A Perfor === of Ww Parearn MEIVt la kn:8 -- Water Remreats. report prepared for Paul, ,

Weiss, Rifkind, Wharton & Garrison by MHB Technical Associates, October 1989.

0 F

i b

i b

b I

l-

![ .

i I e 1

9

. i i

l 1

I t

ATTACHMENT 2 i Statement of Professional Qualifications Steven C. Sholly i t

\

I 1

F l

[

- - - - - - -- e--------- . ---- -- n . - . . - - . , ,. --,.--.,,a . ,, ~ . . . . , n . ,. - -w-

m -,

I:-

4-PROFFttlONAL QUAL f rlCATIONS OF ETEVEN C. EHO11Y STEVEN C. SHOI.LY MHB Techatcal Auociates 1723 Hamilton Avenue Suite K .

SanJose, California 95125 (408) 2t 6 2716 EXPERIENCE:

September 1985 PRESENT Annelmer . MHB Technient Aunciatet. Can Jose Onlifornia Associate in energy consulting firm that sjecialires in technical and economic auessmeats of energy production facilities, especially nudcar, for local, state, and federal governments and private organizations. MHB h extensively involved in regulatory p+oceedags and the preparation of studies and reports. Conduct research, write reports, participate in discovery proccu in regulatory proceedings, develop testimony and other documents for regulatory proceedi*p, and respond to client inquiries.

Clients have included: State of California, State of New York, bate of Illinois, Commonwealth of Massachusetts, and Commonwealth of Pennsylvania.

February 1981. September 1985 Techairal Research Aunciate and Risk Analvst . Uninn of Onneerned Selentiate W=thinnenn D.C.

Research anociate and risk analyst for public interest group based in Cambridge, Maunchusetts, that specialires in examining the impact of advanced technologies on society, principally in the areas of arms control and energy, Technical work focused on nuclear power plant safety, with emphasis on L probabilistic risk auessment, radiological emergency planning and preparedneu, and generic safety L hsues. Conducted research, prepared reports and studies, participated in administrative proceedings I

before the U.S. Nuclear Regulator) Comminion, developed testimony, analyred NRC rule making s proposals and draft reports and prepared comments thereon, and responded to inquiries from sponsors, the general public, and the media. Participated as a member of the Panel on ACRS Effectiveneu (1985), the Panel on Regulatory Uses of Probabilistic Risk Asseument (Peer Review of NUREG 1050;

!. 1984), Invited Observer to NRC Peer Review meetings on the source term reaucument (BMI.2104;

- 19831984), and the Independent Advisory Committee on Nuclear Risk for the Nuclear Risk Task Force of the National Auociation of Insurance Commissioners (1984).

January 1980. January 1981 Proicet Director and Research Coordinator . Three Mile Island Public Interest Resource Center.

Harrisburc. Pennsylvania Provided administrative direction and coordinated research projects for a public interest group based in

' Harrisburg Pennsylvania, centered around issues related to the Three Mile Island Nuclear Power Plant.

Prepared fundraising proposals, tracked progress of U.S. Nuclear Regulatory Commiulon, U.S.

Department of Energy, and General Public Utilities acthities concerning cleanup of Three Mile Island 3 Unit 2 and preparation for restart of Three Mile Island Unit 1, and monitored developments related to

( e emergency planning, the financial health of General Public Utilitics, and NRC rulemaking utions related to 7kee Mile lsland.

July 1978. January 1980 Chief Binkykal Practu oneratnr . Wauewater Treat =*=e Pi -' Derry Towmua lha l aAwharhv.

ggghev. Pennav!v--I-Chief Biological Process Operator at a 2.5 million gallon per day tertiary, utivated sludge, wastewater treatment plant. . Responsible for biokgical proceu snonitoring and control, including analysis of

, physical, chemical, and bioksical test results, proccu fluid and mau flow management, microhkgial analysis of activated sludge, and maintenance of detailed procca kys for input into state and federal reports on treatment proceu and effluent quality, Received certification from the Commonwealth of Pennsylvania as a wastewater treatment plant operator, Member of Water Pollution Control Amociation of Pennsylvania, Central Section,1980.

Iuly 1977. July 1978 Wantewater Treatment Plant Oncrator . Borouch of Limovne. Irmovne. Pensavivag[3 Wastewater treatment plant operator at 2.0 million gallon per day secondary, activated sludge, wastewater treatment plant, Performed tasks as auigned by supervisors, including simple physical and chemical tests on wastewater streams, maintenance and operation of plant equipment, and maintenance , ~

of the collection system.

September 1976. June 1977 Science Temeher West Shore School District. Camn Itill pennwivant.

l Taught Earth and Space Science at ninth grade level. Developed and impicmented new course materials on plate tectonics, environmental geology, and space science. Served as Auktant Coach of the districi gymnastics team.

September 197$ . June 1976 1

! Science Teacher Carlisle Area School District. Carlisle. pennsylvnala i'

Taught Earth and Space Science and Emironmental Science at ninth .:rade level. Developed and implemented new course materials on plate tectonics, emironmental geok>gy, noise polluGon, water i

pollution, and energy, Served as Advisor to the Science Projects Club.

l EDUCATION:

l H.S., Education, majors in Earth and Space Science and General Scier.cc, minor in Emironmental Education, Shippensburg State College, Shippensburg, Pennsylvania,1973. .

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

Short Course on Individual Plant Ex.aminstions, Manachusetts Institute of Technokgy, Cambridge, Manachuseits,1989,

w PUB 13 CATIONS:

1. ' Determining Mercalli Intemities from Newspaper Reports,' Journal of Gaala temi FAar*>laa Vol. 25, 1977.

2. A Critiane of: An InhnA*at Aneu=*a' of h=netaa Ti=*= for Three Mile bi--A Nae 1**e Power l'jant, Three Miie Island Public Interest Resource Center, Hamsburg, Pennsylvania, January 1981.

3. A Brief R2h mad Critinue of the Ra41==A raantv B =A!nlanieml F=*emmer Pranneg

• Union of Concerned Scientists, prepared for Rockland County Emergency Planang Personnel and the Chairman of the County legislature, Washington, D.C., August 17,1961.

4 Li'he N*eaulty for a Penmnt Public Alereine r===hility in the Pla== Funature Pathway EPZ mt Naria=*

Power Plaat Kitet Union of Concerned Scientists, Critical Mass Energy Project, Nuclear Information and Resource Service, Environmental Action, and New York Public laterest Research Group,  :

Washington, D.C., August 27,1981. ' ,

5. ' Union of Concerned Scientists,Inc., Comments on Notice of Proposed Rulemaking, Amendment to 10 CFR 50, Apper. dix E,Section IV.D.3,' Union of Concerned Scientists, Wuhington, D.C., October 21, 1981.*

6. 'The Evdution of Emergency Planning Rules,' in The lad;ma Pniht Book' A Briefine on the Rafety lanatiga ion of the ladian Paint Nuclear Power P!an't Anne Witte, editor, Union of Concerned Scien-tists (Wuhington, D C.) and New York Public laterest Research Group (New York, NY),1982.

7 ' Union of Coincerned Scientists Comments, Proposed Rule,10 CFR Part 50, Emergency Planning and i

Preparedness: Exercises, Clarification of Regulations,46 F.R. 61134,* Union of Concerned Scientists, Washington, D.C., January 15,1982. *

8. Testimony of Robert D. Pollard and Steven C. Sholly before the Subcommittee on Energy and the t

Environment, Committee on Interior and insular Affairs, U.S. House of Representatives, Middletown, l Pecasyhania, March 29,1982, available from the Union of Concerned Scientists.

9. " Union of Concerned Scientists Detailed Comments on Petition for Rulemaking by Citiren's Tuk Force, Emerpacy Planning.10 CFR Parts 50 and 70, Docket No. PRM.50 31, 47 F.R.12639,' Union of Concerned Scientists, Washington, D.C., Msy 24,1982.

10. Supplements to the Testimony of Ellyn R. Weiss, Esq., General Counsel, Union of Concerned Scientists, before the Subcommittee on Energy Couervation and Power, Committee on Energy and Commerec, U.S. House of Representatives, Union of Concerned Scientists, Wuhington, D.C., August 16,1982.

11. Testimony of Steven C. Sholly, Union of Concerned Scientists Washington, D.C., on behalf of the New York Public Interest Research Group,Inc., before the hpecial Committee on Nuclear Power Safety of I

the Asse: ably of the State of New York, hearings on Legisladve Oversight of the Emergency Radiologie Preparedness Act, Chapter 708, Laws of 1981, September 2,1982. .

12. ' Comments on ' Draft Supplement to Final Environmental Statement Related to Construction and Operation of Clinch River Breeder Reactor Plant',' Docket No. 50 537, Union of Concerned Scientists, Washington, D.C., September 13,1982. '

13. ' Union of Concerned Scientists Comments on ' Report to the County Commissioners', by the Advisory Committee on Radiological Emergency Plan for Columbia County, Pennsylvania.' Union of Concerned Scientists, Washington, D.C., September 15,1982.

~

e ,

o i

14. ' Radiological Emergency Planning for Nuclear Reactor Accidents,* presented to Kernenergic Ontmanteld Congren, Rotterdam, The Netherlands, Union of Concerned Scientists, Wuhington, D.C.,

October 8,1982.

15. ' Nuclear Reactor Accident Consequences: Implications for Radiological Emergency Planning,'

presented to the Cittren's Advisory Committee to Review Rockland County's Own Nuclear Evacuation and Preparedneu Plan and General Dkuter Preparedness Plan, Union of Concerned Scientists, Wub.

ington, D.C., Novemler 19,1982.

16. Teatimony of Steven C. Sholly tefore the Subcommittee on Oversight and Investigations, Committee on i laterior and lasular Affairs, U.S. House of Representatives, Washington, D.C., Union of Concerned Sci.

entists, December 13,1982,

17. Testimony of Gordon R. Thompson and Steven C. Sholly on Comminion Oucation Two, Contentions 2.1(a) and 2.1(d), Union of Concerud Scientists and New York Public Interest Research Group, before the U.S. Nuclear Regulatory Commiulon Atomic Safety end Licensing Board, in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) and the Pont Authority of the State of New Yotk (Indian Point Unit 3), Docket Nos. S247 SP and S2 ESP, December 28,1982. '

18. Testimony of Steven C. Sholly on the Consequences of Accidents at Indian Point (Comminion Oucation One and Board Question 1.1, Union of Concerned Scientists and New York Public Interest Research Group, before the U.S. Nuclear Regulatory Comminion Atomic Safety and Licensing Board, in the Matter of Comolidated Edison Company of New York (Indian Point Unit 2) and the Power Authority of the Stste of New York (Indian Point Unit 3), Docket Nos. S247.SP and $2 ESP, February 7,1933, as cortceted February 16,1983. *

19. Testimony of Steven C. Sholly on Commission Question Five, Union of Concerned Scientists and New York Public Interest Research Group, before the U.S. Nuclear Regulatory Commlulon Atomic Safety and 1.icensing Board,in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) t and the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos. S247 SP and S 2 ESP, March 22,1983. '

20. ' Nuclear Resetor Accidents and Accident Consequences: Planning for the Worst,' Union of Concerned ScientiMs, Washington, D.C., presented at Critical Mau '83, March 26,1983.

l l

21. Testimony of Steven C. Sholly on Emergency Planning and Preparedneu at Commercial Nuclear Power Plants, Union of Conectned Scientists, Washington, D.C., before the Subcommittee on Nuclear Regulation, Committee on Environrwent and Public Works, U.S. Senate, April 15,1983, (with ' Union of Concerned Scientists' Response to Ouutions for the Record from Senator Alan K. Simpson,' Steven C.

Sholly and Michael E. Faden).

l

22. 'PRA: What Can it Really Tell Us Aleut Public Risk from Nuclear Accidents?,' Union of Concerned Scientists, Washington, D.C., presentation to the 14th Annual Meeting, Seacoast Anti Pollution league, May 4,1983.

23. 'Probabilistic Risk Auessment: The impact of Uncertainties on Radiological Emergency Planning and Preparedness Considerations,' Union of Concerned Scientists, Washington, D.C., June 28,1P83,

24. ' Response to GAO Questions on NRC's Use of PRA,' Union of Concerned Scientists, Washington, D.C. October 6,1983, attachment to letter dated October 6,1983, from Steven C. Sholly to John E.

Bagnolo (G AO, Washington, D.C.).

f I

1 l

1 i

25. ne I=aar* of 'F=ternal Events' on R.,ualneiexl Emereanev Ratnante Planning Considerations. Union of Concerned Scientkts, Washington, D.C., December 22,1983, attachment to letter dated December 22, 1983, from Steven C. Shouy to NRC Commiuioner James K. Auelstine. j 1

26. Sisewell 'B' Public inquiry, Proof of Evidence on: Rafetv - A W at** M----*=ent t=aHeitlane of the '

Eigg3stil PWR. Gordon Thompson, with supporting evidence by Steven Sholly, on behalf of the Town and Country Planning Association, February 1964, including Annex G, 'A review of Probabilistic Risk Analysis and its Application to the Sizewell PWR,' Steven ShoUy and Gordon Thompson, (August 11, 1983), and Annex 0, ' Emergency Plaening in the UK and the US: A Comparison,' Steven Shouy and .

Gordon Thompson (October 24,1983).

27. Testimony of Steven C. Sholly on Emergency Planning Contention Number Eleven, Union of Concerned Scientists, Washington, D.C., on behalf of the Palmetto Alhance and the Carolina Environmental Study Group, before the U.S. Nuclear Regulatory Comminion Atomic Safety and Licensing Board, in the Matter of Duke Power Company, et al. (Catawba Nuclear Station, Units 1 and 2), Docket Nos. 50 413 and 50 414, April 16,1964. *

28. ' Risk Indicators Relevant to Auessing Nuclear Accident Liability Premiums,* in Preliminary Renort to the Indenendent Advisory Committee to the NAlc Nuclear Risk Task Fatst, December 11,1964, Steven ,

C. Sholly, Union of Concerned Scientists, Washington, D.C.

29. ' Union of Concerned Scientists' and Nuclear Information and Resource Service's Joint Comments on NRC's Proposal to Bar from Licensing Proceedings the Consideration of Earthquake Effects on Emergency Planning,' Union of Concerned Scientists and Nuclear Information and Resource Senice, Washinson, D.C., Diane Curran and Ellyn R. Wein (with input from Steven C. Shouy), February 28,  ;

1985.*

30. ' Severe Accident Source Terms: A Presentation to the Commissioners on the Status of a Review of the i NRC's Source Term Reaucument Study by the Union of Concerned Scientists,' Union of Concerned Scientists, Washington, D.C., April 3,1985. *

31.

• Severe Accident Source Terms for Light Water Nuclear Power Plants: A Presentation to the Illinois Department of Nuclear Safety on the Status of a Review of the NRC's Source Term Reasseument Study (STRS) by the Union of Concerned Scientists,' Union of Concerned Scientists, Washington, D.C., May 13,1985.

32. The Source Term Debate A Review of the Current Basis for Predictine Severe Accident Source Terms with Snecial Emnhatit on the NRC Source Term Reaucument Procram (NUREG 00561 Union of Concerned Scientists, Cambridge, Massachusetts, Steven C. Sholly and Gordon Thompson, January 1986.

33. Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price, and Steven C. Sholly on behalf of State of Connecticut Department of Public Utility Control, Prosecutorial Division and Division I of Consumer Counsel, regarding the prudence of expenditures on Millstone Unit Ill, February 18,1986.

I 34, implications of the Chernobyl 4 Accident for Nuclear Emergency Planning for the State of New York, prepared for the State of New York Consumer Protection Board, by MHB Technical Associates, June 1986,

35. Review of Vermont Yankee Containment Safe'v Study and Anah' sis of Containment Ventinc issues for the Vermont Yankee Nuclear Power Plant, prepared for New England Coalition on Nuclear Pollution, Inc., December 16,1986.

o l

l

36. Affidavit of Steven C. Sholly before the Atomic Safety and Ucensing Board,in the matter of Public I Service Company of New Hampshire, et al., regarding Seabrook Station Units 1 and 2 Off-site Emergency Planning issues, Docket Nos. 50-443-OL & $0-444-OL, January 23,1987.

37. Direct Testimony of Richard B. Hubbard and Steven C. Sholly on behalf of California Public Utilities Commission, regarding Diablo Canyca Rate Case, PG&E's Failure to Establish its Committed Design  ;

OA Program, Application Nos. 84-06014 and 85 08-025, Exhibit No.10,935, March,1987.

38. Testimony of Gregory C. Minor, Steven C. Sholly et. al. on behalf of Suffolk County, regarding ULCO's 4 Reception Centers (Planning Basis), before the Atomic Safety and Licensing Board, in the matter of )

long Island ughting Company, Shoreham Nuclear Power Station Unit 1, Docket No. $0-322 013, J April 13,1987.

l

39. Rebuttal Testimony of Gregory C. Minor and Steven C. Sholly on behalf of Suffolk County regarding LILCO's Reception Centers (Addressing Testimony of Lewis G. Hulman), Docket No. 50 322 OL-3, -

May 27,1987. ,

40. *Scismic Events,' Presentation at Severe Accident Policy implementation External Events Workshop, Sponsored by U.S. Nuclear Regulatuy Commission, August 4-5,1987, Annapolis, Maryland.

41. Review of Selected Asnects of NUREG-1150. Reactor Risk Reference Document. prepared for the Illinois Department of Nuclear Safety by MHB Technical Associates, September 1987,

42. Direct Testimony of Richard B. Hubbard and Steven C. Sholly on lehalf of the Pennsylvania Office of Consumer Advocate, before the Pennsylvania Public Utility Commission, Evaluation of Beaver Valley Unit 2 Plant Costs, OCA Statement 6, Docket No. R 870651, October 23,1987.

43. Final Renort* Sinnificant Factors Affectine th-fost of Beaver Vallev Power Station. Unit 2- prepared for Pennsylvania Office of Consumer Advocate, by MHB Technical Associates, OCA Eahibit 6A, Octo'oct 1987. .

44. Surrebuttal Testimony of Richard B. Hubbard and Steven C. Sholly before the Pennsylvania Public Utility Commission, on behalf of the Pennsylvania Office of Consumer Advocate, regarding Evaluation of Beaver Valley Unit 2 Plant Costs, OCA Statement 61, Docket No, R 870651, December 7,1987.

45. Testimony on Diablo Canyon Rate Case, Desien Quality Assurance. SupplementrJ and Rebuttal Testimony of Richard B. Hubbard and Steven C. Sholly, on behalf of the California Public Utilities Commission, Division of Ratepayer Advocates, Application Nos. 84-06 014 and 85 08 025, Exhibit No.

16,690, September 1988.

. 46. Testimony on Diablo Canyon Rate Case, Evolution of OA Reauirernents And Their Understandina By The Nuclear Industry- Quality Assurance As A Manacement Tool, Volumes I and II, Supplemental and Rebuttal Testimony of Richard B. Hubbard and Steven C. Sholly on behalf of the California Puolic Utilities Comraission, Division of Ratept,yer Advocate, Application Nos. 84-06-014 and 85-08-025, Exhibit No.16,650, September 1988.

I- 47. GE Reed Report Safety issue Reviews, lisucs 1,6, and 14, prepared by MHB Technical Associates for The Ohio State University Nuclev Engineering Program Expert Review Panel, Public Utility Commission of Ohio, October 1988.

48. Direct Testimony and Exhibits of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station, lovestigation of Pilgrim Outage, DPU 88 28, November 30,1988, PROTECTED INFORMATION.

i

)

4 1

l

49. Supplemental Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station, lanstigation of Pilgrim Outage, DPU 88 28, January 20,1989, Exhibit AG 2, 1

50. Surrebuttal Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of j Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear Pour Station,lavestigation of l Pilgrim Outage, DPU 88-28, February 13,1989, Exhibit AG 74. j

. 1

51. Surrebuttal Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of l

~

Massachusetts Department of Attorney General, Re: Pilgrim Nuclear Power Station, investigation of Pilgrim Outage, DPU 88 28, February 17,1989, Exhibit AG 93.

52. F==1 Renart Severe Ace:A.nea at 'Ihree Mile ta A Unit 1: Severe Accidrat r%r.ceertarie, for Radialqgical Emergency Response Plan Development. prepared for Irdtitute for Resource and Security i Studies, February 1989.

53. A 1 imised Renae Review of the Sected Draft of NUREG 1150. prepared for the Illinois Department of Nuclear Safety, November 1989.

Available from the U.S. Nuclear Regulatory Commission, Public Document Room, Lobby,1717 H Street, N.W., Washington, D.C.

l t

.,---r-- * -- --- s

m .

q:_ i c.

j f

1 ATTACHMENT 3  :

NRC Confirmation Action Letter CAL 8911  ;

V k

d e

i h--'-

y._._ _ _ _ _ - _ _ _ . _ _ _ _ . . _ . _ _ _ _ _ _ _ _ .

r fg weree states NWOL&AA ARGWhAT98tv tesmesteN acesses a

% e4eumstaM Reat sales to penweem. steessevhvaasu teens 4

Osthets No.: 60-443 M

CAL No.: 49*11 ,

twbits~Mr.

Aith: le*v':e of New Wassshire (PlNN)

Levere A. Brown, saesteent ,

and Chief taecuttve Cfficer  !

post Office to: 300 Yankee Divisten

% maneshire i Seeeeeek, how Maapshire 03874 '

lentlemen:

Subject:

CONF 244&t0RY Actf0N LITTER (CAL) $$*11 This letter conf tms our unterstanatag of these acttens yev intene to take in performente of the natural tiet 'etion sta**up distwased evetag e June 43, 1949 test. response to the These actions were

ra

1. a. nin, no,vt, no,te i A.inistrater, a C i.fien 2. phone eenversetten 1 Specif1:a11y. We sneerstsee snat, prior te startup of the unit, plNH willt (1) Ceeplete one document the results of the post trip review protets elletieted with the June it,1989 event; -

(t) Estatitth these thert*ters terrettive ottient to be toepleted Drter to retta*t of ne vndt to eteress the specif te defittenttet identified dweing year post trip rev*ewt 1 (3)- Determine these langer tore terrective actions and their respective scheavies, to ederess any potenstally besador tap 1ttations associated with the 6pectf te esficiencies teentified as a retvit of reve review; and, (4) Review the rescits of 16006 (1), (t) and (3), above, with the NRC staff.

we fvether .menun not we .ePeement er the aseien) Admintitrttee, nesten 1, vests a nuinw orter to resurt of the unit. .

1 1

.R$64f<>o4 5 Aff.

. , . , ,. ,~~-,,.7 4 ...,.._...,,,,~..-,..y.m, -.__,_,.,~.w,......,. _ . - . . - _ . _ _ _ _ . _ _ _ _ _ _ _ _ -

4 Public.lervice of New Hampshire  ! #

4

. If your unterstanding difftet f rom that ut, forth above, please c temee tately.

linteral ,

William 7. Austell.

tagional Aeministrater ec: .

.l.

C. Dwf fett, Presidevil, and Chief J. M. #eschel, Regulatory Ser .tcenst:y & Q alit boeutive Of ficer, F$N D. E. Needy, Statten Marager. vices u y Program, WY P. W. Agne6 N4Y Manager, WY Cnemanw,e41th Jr., Assistant Setretary of Pubitt Safety of Massachusetts ,

L Public.Decument Ases.(PDR)

Local Putile Document Room (LPOR) l l WRC Resteent inspector #welear Safety Infomation Center (N$!C) l $ tate of New Maasshire -

Commonwealth of mastechusetts lostreek Hearing Service 1. int D

e b .

JcL r ,

e

)/

i:[

i

(

L ATTACHMENT 4 NRC Notice of Violation Related to June 22,1989 Natural Circulation Test Failure i

e

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

( e tee g k

UNffee sf ATEs s q NUCLEAll ftt0VLATORY COMMISSION t 5 Ae0 ION 1 876 ALLENDALe ROAD

'ee** KING OF PAU$slA. PtNNSYLVANIA 1s404 October 25, 1989 Docket.No. 50 443 License No. NPF-67 -

EA 89-158 l- Public Service Company of New Hampshire ATTN: Mr. Edward A. Brown L president and Chief Erecutive Officer l New Hampshire Yanket . Division-Post Office Box 300 Seabrook. New Hampshire 03834 Gentlemen:

Subject:

NOTICE OF VIOLATI0h AND PROPOSED IMPOSITION OF CIVIL PENALTY - $50,000 (NRC Inspection Report No. 50433/89-82)

This letter refers to the NRC Augmented Inspection Team (Ali) inspection

! conducted on June 28-30, 1989'ssociated with an event which occurred at theat to review the circumstances s facility on June 22, 1989. Tpeeventinvolvedthefailurebytheoperations staff to promptly trip the re a test procedure was exceeded,petor during a startupwhen test. aThe reactor reporttrip criterion of this AIT set forth inspection was sent to you on August 37, 1989. -As a result of the inspection, iviolations of NRC requirement 6 were identified. On September 7, 1989, an I enforcement conference was co 1 ducted with you and members of your staff to

[ discuss the event, the associated violations, causes and your corrective actions. The conference was also attended, at your request, by Mr. J. Eichorn and Mr. G. Edwards, Chairman uno Vice Chairman, respectively, of the Seabrook Joint'0wners Group Executive committee.

The event occurred while the reactor was at 2% power during a natural circula-tion test. Duringthetest,Oneofthecondensersteamdumpvalvesfailedin the full open position (shortl accordancewiththestartupt(yafterthereactorcoolantpumpsweretrippedin stprocedure). The valve failure was caused by the position feedback linkage,becoming disconnected from the positioner. The failure of the dump valve to ghe full open position resulted in an unplanned reactor cooldowr which caused the pressurizer level to decrease below the 17%

manual trip criterion speciffe'd in the startup test procedure. Notwithstanding thisoccurrence,thereactordasnottrippeduntilapproximatelyfiveminutes later when, after the cooldown'was terminated by closure of the dump valve, pressurizer pressure rapidly increased and the reactor was manually tripped.

L

' The NRC recognizes that the tephnical safety significance of this event was low in that the reactor did no

! specification or design limits,,t wereexceed its initial exceeded. power level Nonetheless, theand no technical failure te L trip the reactor when required by the test. procedure is a significant regulatory

i. Concern.

~

W 000h- p.

t .S Pubite Service Company of 2

, New Hampshire Furthermore, the NRC found that performance deficiencies were enhibited by individuals at multiple levels within the organization either prior to, during, or after the event.

For example, although the op trations staff had received classroom training and simulator training regarding the test approximately one year and three years .

respectively, prior to the tast, there apparently was no refresher training provided for this test since that time. Furthermore, the Test Director, who was responsible for briefing the operations staff concerning conduct of the .

test and the $hif t Superinte dent, responsible for control and command of the shift, did not provide an adequate briefing prior to the test in that (1) one of the two control board cperators assigned to assist the shift crew was not briefed on the procedure's reactor trip criteria; (2) the briefings were not formally provided to the ope 'ations staff as a whole even though the staff on shift at the time had not to tinely worked together as a group; and (3) the briefings were not sufficien ly detailed. In addition, the Test Director signed off a test prerequist e for verifying steam dump system availability.

without properly considering the effects of an outstanding work order to stroke test the valve.

During the performance of th test, the knowledge of the operations staff, including the Unit Shift Sup rvisor, was deficient in that the staff apparently perceived a hierarchy betwee limits and criterte set forth in the Technical Specifications and operating rocedures, compared to those set forth in the L

test procedures, and apparent, y attached less importance to complying with -

-the test procedures. Deficie1cies were also identified in the performance of senior shift management, as will as senior plant and corporate management.

The Shift Superintendent on d Jty did not adequately implement his oversight function in that he did not maintain a sufficient level of awareness and involvement in the specific data 11s of this test. More significantly, the

' 5tartup Manager, the $hift Te Et Director, and the Test Director who became aware of the plant exceeding a manual trtp criterion did not recommend to the u

" operations staff that the reactor be tripped. Of similar concern was management's initial decision to resume tehting without completing a detailed and thorough

' analysis of the underlying causes of this event and the related human performance deficiencies.

This event, involving multipl( levels of the organization, represents a failure tocontrolanimportantactivityattheSeabrookStation. These failures demonstrate the need for, and,importance of, adequate planning, preparation, i

' implementation and evaluation f all activities at the facility to assure that those activities are conducte safely and in accordance with the terms of your license. The NRC recognizes t at, since the event, a root cause analysis was performed and management has ken corrective measures which have included disciplinary action against s eral individuals. Nonetheless, to emphasiza the importance of maintaining he necessary attention to, and control and oversight of, activities at yoJr facility, I have been authorized, after consultation with the Director of Enforcement and the Deputy Executive Director for Nuclear Materials Safety, afeguards and Operations Support, to issue the enclosed Notice of Violation al d Proposed Imposition of Civil Penalty in the amount of $50,000 for the violations set forth in the enclosed Notice. The

, - .~ . ,c- ~, --.,+o,,w .._,,n ,m. . . . . - - ,, -- m.., ,-..,,m.,--.,,. . . , . - - - , . - . , . _ , . , , , , . , . . . , . - - ,

y .. .

4 +

l Public Service Company of 3 New Hampshire l violations are classified i the aggregate at Severity level !!! 1n accordance with the " General Statement f Policy and Procedure for NRC Enforcement Actions " i 30 CFR Part 2, Appendix C ( 989) (Enforcement Policy).

The base civil penalty amoun L for a Severity Level 111 violation or problem is 550,000. The escalation-ind mitigation factors set forth in the Enforcement ,

Policy were considered. The base civil penalty has been escalated by 50 percent because-though your subseque st corrective actions were comprehensive, they were initially poor in that a ful human performance evaluation was not scheduled for l

completion prior to reactor Ltartup. Considering your good overall past perfor-mance including in the test area, 50 percent mitigation is warranted. ,

l You are required to respond to this letter and the enclosed Notice, and should follow the instructions in tije enclosed Notice when preparing your response.

In your response, you should document the specific actions taken and any l addttional actions you plan to take to prevent recurrence. In your response, you may make reference, as appropriate, to previous submittels to the NRC on this-matter. After reviewini your response to this Notice, including your proposed corrective actions a nd the results of future ins; ctions, the NRC .

will determine whether furths c' enforcement action is necessary to ensure compliance with regulatory requirements.

In accordance with Section 2 790 of the NRC's " Rules of practice,' Part 2, Title 10, code of Federal Rehulations, a copy of this letter and its enclosure will be:placed in the NRC Put:lic Document Room.

The responses' directed by thi letter and the enclosed Notice are not subject to the clearance procedures the Office of Management and Budget as required by the Paperwork Reduction Ac of 1980, PL No.96-511. ,

l Sincerely, ,

lJ,&::*k William T. Russell Regional Administrator

Enclosure:

Notice of Violation and proponed Imposition p of Civil Penalty l

I I

e 8" 4 85 W-9 vp e-T-*=$y-g g,er- ge-w- w. ,y

l-c, .

I NOTICE OF VIOLATION AND PROPOSED IMPOSITION .0F CIVIL PENALTY

{ -

\

Public Service Company of Nov Hampshire Docket No. 50 443 .

Seabrook Station License No. NPF 67  ;

EA 8g-158 a On June 28 - 30, 1989, an NRC AugmentedInspectionTeam(AIT)inspectionwas y

E ennducted at the Seabrook St(tion to establish and evaluate the facts associ-atedwithaneventwhichoccqrredatthefacilityonJune 22, 1989. Based on L an evaluation of the event a the findings of the AIT inspection, violations of i l NRC requirements were identi ed. In accordance with'the " General $tatement '

l of Policy and Procedure for RC Enforcement Actions," 10 CFR Part 2, Appendix C, (1989),theNuclearRegulato rCommission(NRC)proposestoimposeacivil-  !

penalty pursuant to Section 254 of the Atomic Energy Act of 1954, as amended  !

(Act),42U.S.C.2282,and10CFR2.205. The particular violations and associ-ated civil penalty are set fo i h t below:

A. 10 CFR Part 50, Appendix 8. Criterion V, requires, in part, that '

activities affecting qual ity shall be prescribed by documented instructions, procedures. or drawings,

, or drawings shall inc udo,appropriate appropriate acceptance to the circumstances. The criteria for procedures determining ,

E that important activitten have been satisfactorily accomplished.

10 CFR Part 50. Appendix 8, Criterion XI, requires, in part, that a test program shall be es ablished to assure that all testing required to demonstrate that stru tures, systems, and components will perform satisfactorily in service is identified and performed in accordance with i written test procedures ghich incorporate the requirements and acceptance limits contained in appli Test procedures stall include provisions for as, cable design documents.

have been met, and test q;suring ssults shall be that all prerequisites documented and evaluatedfortothe given test assure that test requirements have been satisfied.

t

. 1. Seabrook Startup Tes l Test, Attachment 9.3,t Procedure

, Section B.5,1-ST-22, sets forthentitled Natura'l the manuel tripCirculation criteria for the test, and requires that the test be terminated and the reactor tripped if pressurizar water level is less than 175.

Contrary to the abovo, during the performance of Startup Test Procedure 1-$T-22 on June 22, 1989, pressurizer level decreased below 17% and the retetor was not tripped by the operating shift as required.

2. Seabrook Startup Tes Procedure 2-ST-22, Section 3.0, Prerequisites, Step 3.6.7 requires sign-off confirming the availability of the steam dump, includin the atmospheric relief valves, as a prerequisite to the t'est.

n

^99H4Mp4 'ff'

7pp . .

1 4 l(

Notice of Violation 2

Contrary to the a nove, prior to the performance of Startup Test '

Procedure 1 $T-22 on June 22, 1989, Step 3.6.7 was signed off by the Test Director confirming the availability of the main steam dump-system includesi valvew(asnotreafy.tosupportthetestbecauseWorkOrderalve No. _

' No.WR7 WOO 5592(whichrequiresastroketestofthevalveatnormal .

operating temperature and pressure) was-still open.

3. Seabrook Startup T st Procedure 1-$T-22, Section 3.0, Prerequisites, Step 3.2 requires signoff confirming that personnel involved with the performance o the procedure have been briefed on the procedure '

content and inforud of the respective duties.

Contrary to the above, prior to-the performance of Startup Test Procedure 1-$T-22 sn June 22, 1989, Step 3.2 was signed off by .the Test Director conf,1rming .the adequacy of the pre-test briefing; however, the briefing was inadequate in that one of the two control board operators as ligned to assist the shift crew was not briefed on the procedure's reactor trip criteria.

4. Seabrook Operation L Management Manual, Section 1.8, requires that shift ~ evolution-br efings shall be conducted for individuals involved in the performance of an evolution. This section also states, in part, that complex evolutions requiring close coordination of individuals should include exaoinations of each' individual's specific involvement and responsibility, Contrary to the abc ve, prior to the performance of Startup Test

• Procedure 1-$T-22 (n June 22,1989, the shift briefings were inadequate in that jthe briefings were conducted in a fragmented manner and not for were not sufficient1ylthe operations detailed. crew as For example, a.briefings the group, and the briefings did not cover each operaton's specific involvement, responsibility,-and understanding of the required interfaces and communications.

B. 10 CFR Part 60, Appendix B, Criterton XVI, requires, in part that measures be established to assure,, that conditions adverse to quality are promptly W -

identified and corrected, Contrary to the above, m+asures were not adequately established to assure that a condition adverse to quality was promptly identified and corrected as evidenced by the follo, wing examples:

1. During the performance of Startup Test Procedure 1-Sf-22 on June 22, 1989, the btartup Manager, the $hift Test Director, and the Test Director became aware of a condition adverse to quality, but failed to ensure the t the condition was promptly corrected. The adverse condition consisted of the pressurizer level dropping below the trip criteria s oftheoperationss(ecifiedinthetestprocedureandthefailure taff to trip the reactor as required.

., _._ ___. _ _. ~ ._ ___._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

E  : 40

'}

y .

i

r:

Nottee of Violation 3 e ,

f

2. Subsequent to the June 22, 1989 failure to promptly effect a manual reactor trip as required by the criterion in Startup Test Procedure j 1-ST-22, licensee nanagement did not promptly identify and correct associated personnel performance failures in that management initially made a decision to resume testing without completing a detailed and.

thoroughanalysisbf the underlying causes of the event and without correcting the reli ted human performance deficiencies. ,

These. violations are classifi ed in the aggregate as a Severity Level III problem ($upplement1).

Civil Penalty $50,000 - tsiessed equally among the six violations L Pursuant to the provisions of 10 CFR 2.201, Public Service Company of New L

Hampshire is hereby required o submit a written statement or explanation to i

the Director, Office of Enfo ement, U.S. Nuclear Regulatory Commission, within .

30 days of the date of this ,tice. This reply should be clearly marked as a

" Reply to a Notice of Violat1 >n" and should include for each alleged violation:

(1) admission or dental of thi alleged violation, (2) the reasons for the viola-L tion if admitted, (3) the cor ective steps that'have been taken and the results 6teps that will' be taken to avoid further viola-achieved,(4))thecorrective tions,and-(5 the date when dull compliance will be achieved. If an adequate reply is not. received within she time specified in this Notice, an order may ,

p be-issueo to show cause why the license should not be modified, suspended..or l

revoked or why such other act on as may be proper should not be taken. Consid-L eretion may be given to exten ling the response time for good cause shown.

Under the authority of Sectio i 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation..

l .

, Within the same time as-provic ed for the response required under 10 CFR 2.201, p .the Licensee may pay the civit penalty by letter to the Director, Office of _

i Enforcement, U.S. Nuclear Regt 1 story Commission, with a check, draft, or money L order payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or a protest imposition of the civil penalty in whole or in part by a written answe addressed to the Director. Office of Enforcement, U.S. Nuclear Regulatory Commi ion. Should the Licenses fati to answer within the time specified, an order ipposing the civil penalty will be issued. ~Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the notice of violation and pr > posed imposition of civil penalty, in whole or in part, such answer should beiclearly marked as an " Answer to a Notice of Violation and Proposed Impositlen of Civil Penalty" and may: (1)denythe l' violations listed in this Notice in whole or in part; (2) demonstrate extenu-atingcircumstances;(3)showorror in this Notice; or (4) show other reasons why the penalty should not be "mposed. In addition to protesting the civil penalty, in whole or in part, huch answer may request remission or mitigation of the penalty.

f

. l

. i Notice of Violation. -4

~

In requesting mitigation of ;he proposed penalty, the factors addressed in --

Section V.8 of 10 CFR Part 2 Appendia C, should be addressed. Any written

-answer statementin or accordance explanation .inwith 10(CFR 2.205 should be set forth separately fro parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraphnumbers)toavoid(epetition. The attention of the licensee is

-directed to the other provisi ons of 10 CFR 2.205, regarding the procedure ,

for imposing a. civil pensity, Upon failure to pay any civi penalty due which subsequently has been determined i in accordance with the app 11 able provision of 10 CFR 2.205, this matter may be referred to the Attorney Gen ral, and the penalty, unless compromised, remitted. -

or mitigated, may be collect by civil action pursuant to Section 234c of the t

-Act. 42 U.S.C. 2282c.

The responses to the Directorp officeofEnforcement,notedabove(Replyto a Notice of Violation, letter with payment of civil penalty, and Answer to

a Notice of Violation and Pro >osed Imposition of Civil Penalty) should be addressed to: Director, Offi':e of Enforcement, U.S. Nuclear Regulatory-t Commission, ATTN: .DocumentCpntrolDesk, Washington,D.C.20555,withacopy -;

L to-the Regional Administrator Region I, U.S. Nuclear Regulatory Commission, 475 Allendale Road, King of Pr)ussia Pennsylvania 19406, and a copy to the NRC Senior Resident Inspector Seabrook Station.

FOR THE NUCLEAR REGULATORY COMMISSION d% ::8 L William T. Russell Regional Administrator Dated at King of Prussia, Pennsylvania this AS day of October 198g '

L

= - - - . , , = ~ - - - - .~.-n--.,-,c ., , , . - - - - -e,,.- ,-r-s ,- n cw , .rw v.,m m, w , ,-,rv

si r

P u

. I' ATT A C H M ENT 5 D NRC 1.etter of 15 September 1989 Concerning' Operator Proficiency Evaluations of Seabrook Operators I

1 1-I l

r u

I.j hi

. J.- .. . . . . . .

j y -

1

., c (f- ,_

I o,, . UNITED STATES

^P

[ O

{9 e

NUCLEAR REGULATORY COMMISSION REQlON l '

476 ALLENDALE ROAD

• • • • • ~ KING OF PRUSSIA. PENNSYLVANIA 194o6 ,

' Docket No. 50-443 SEP 151989 4

PublieLService Company.of.New Hampshire ATTN: Mr. Edward A.. Brown, President and Chief Executive Officer ,

New Hampshire Yankee Division i

. Post Office Box 300 9 ,

Seabrook, New Hampshire 03874'  :

Gentlemen: )

Subject:

NRC EVALUATION OF SEABROOK-STATION, UNIT 1, OPERATOR PROFICIENCY  ;

In a conversation on Septemoer 7,1989, between Mr. Joseph Grillo, Unit 1 Operations, and Mr. Peter Eselgroth, Chief, PWR Section, arrangements were made for' an NRC evaluation of operator proficiency.

.The NRC is planning to conduct the evaluation of all shift: operating crews on the Seabrook Unit 1 sim'ulator, using NRC-developed. scenarios during the week L of December 11, 1989. The-scenarios will cover various types of broad evolu-

!' tion / transients and will not be limited to the use of the E0Ps, In order for the NRC staff to adequately develop scenarios for the evaluation, L it will be necessary for you to furnish the reference material listed in Attach-ment I by October 11, 1989. Also, we.will need one simulator instructor and-

'one operations person to assist in the validation'of the simulator scenarios

• l l; . developed.by the NRC. The two individuals will be required to sign a security

'l agreement that they will not knowingly divulge the scenario contents to other y facility personnel and not be involved in further training of the operators E after validation of the scenario contents. Future communications will confirm y the schedule and finalize our needs.

Your cooperation with us in this matter is appreciated. If you have any ques-tions concerning this matter, please contact Mr. Peter Eselgroth, of my staff, at 215-337-5211.

. Sincerely.

1 Robert M. Gal o, Chief Operations Branch i

Division of Reactor Safety

i Public. Service' Company of New Hampshire 2 cc:

J. C. Duffett, President and Chief Executive Officer, PSNH T. C. Feigenbaum, Senior Vice President and Chief Operating Officer, NHY J. M. Peschel, Operational Programs Manager, NHY D. E. Moody, Station Manager, NHY T. Harpster, Director of Licensing Services J. Grillo, Operations Manager P. Richardson, Training Manager .

P. W. Agnes, Jr., Assistant Secretary of Public Safety, Commonwealth of Massachusett Public Document Room (PDR).

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Hampshire Commonwealth of Massachusetts

.Seabrook Hearing Service List 1

l .

1 1

1 .

q

[o:

r. s-

- REFERENCE MATERIAL REQUIREMENTS FOR J SEABROOK-STATION, UNIT 1 OPERATOR ASSESSMENTS

1. Operator training material on Seabrook Unit 1 plant systems.

2. All integrated plant procedures (normal or general operating procedures).

3. All emergency procedures (emergency instructions, abnormal or 'special procedures), including bases, if applicable. ,

4. Conduct of operations administrative procedures.

5. All annunciator / alarm procedures.

6. Energency plan implementing procedu-es.

7. Technical specifications.

8. System operating procecures.

-9. _ Piping and instrumentation diagrams and electrical single-line diagrams.

10. Simulator malfunction book.

-11. List of all preprogrammed initial conditions.

l 12. Copy of simulator scenarios used by the facility to train on the E0Ps.

l l

l-1 O

m

1:

I p UNITED STATES OF' AMERICA 14 NUCLEAR REGULATORY COMMISSION ,

Before the Commission:

Kenneth M.-Carr, Chairman

,, Thomas M. Roberts, commissioner Kenneth-C. Rogers, Commissioner James R. Curtiss, Commissioner l? )

In-the Matter of ) Docket Nos. 50-443-OL L ) 50-444-OL l PUBLIC SERVICE COMPANY ) '(Emergency Planning Issues)

I' OF NEW HAMPSHIRE, E.T AL. )

i

)

(Seabrook Station, Units 1 and 2) ) December 1, 1989

)

l l l L CERTIFICATE OF SERVICE l l

l I, Matthew T. Brock, hereby certify that on December 1, 1989, I made service of the within INTERVENORS' APPLICATION FOR A STAY l ,

'l l OF LBP-89-32 by Federal Express as indicated by [*] and by first

- class mail to the'following parties:

1 Ivan W. Smith, Chairman Kenneth A. McCollom L Atomic Safety & Licensing Board 1107 W. Knapp St.

l U.S. Nuclear Regulatory Commission Stillwater, OK 74075 l

' East West Towers Building l 4350 East' West Highway l Bethesda, MD 20814 Dr. Richard F.' Cole Robert R. Pierce, Esq. l l Atomic Safety & Licensing Board Atomic Safety & Licensing Board l-, U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway ,

Bethesda, MD 20814 Bethesda, MD 20814 l

• Docketing and Service

• Thomas G. Dignan, Jr. y U.S. Nuclear Regulatory Commission Ropes & Gray Washington, DC 20555 One International Place Boston, MA 02110 l

i.... ._ , . . . _. . . _ . . _ . _ . . __ __ ______________-

• T an' i

I

• Marjorie Nordlinger, Esq. Paul McEachern, Esq.

U.S. Nuclear Regulatory Commission Shaines & McEachern Office of the General Counsel 25 Maplewood Avenue 1 11555 Rockville Pike,_15th Floor P.O. Box 360 l Rockville, MD 20852 Portsmouth, NH 03801  !

l H. Joseph Flynn, Esq. -Atomic Safety & Licensing l Assistant General Counsel. Appeal Board

. Office of General Counsel U.S. Nuclear Regulatory Commission Federal Emergency Management Washington, DC 20555 Agency 500 C Street, S.W.

Washington, DC 20472 Robert A. Backus, Esq. Atomic Safety & Licensing Board Backus,-Meyer & Solomon U.S.-Nuclear Regulatory Commission 116 Lowell Street Washington, DC 20555 P.O. Box 516 Manchester, NH 03106 Jane Doughty Dianne Curran, Esq.

Seacoast Anti-Pollution League Harmon, Curran & Towsley Five Market Street Suite 430 Portsmouth, NH 03801 2001 S Street, N.W.

Washington, DC 20008 Barbara St. Andre, Esq. Judith Mizner, Esq.

Kopelman & Paige, P.C. 79 State Street 77 Franklin Street Second Floor l, Boston, MA 02110 Newburyport, MA 01950 l

! Charles P. Graham, Esq. R. Scott Hill-Whilton, Esq.

l Murphy & Graham Lagoulis, Hill-Whilton & Rotondi

- 33 Low Street 79 State Street L .Newburyport, MA 01950 Newburyport, MA 01950 l

Ashod N._Amirian, Esq. Senator Gordon J. Humphrey 145 South Main Street U.S. Senate l P.O. Box 38 Washington, DC 20510 1

Bradford, MA 01835 (Attn: Tom Burack)

Senator Gordon J. Humphrey John P. Arnold, Attorney General One Eagle Square, Suite 507 Office of the Attorney General Concord, NH 03301 25 Capitol Street 1

(Attn: Herb Boynton) Concord, NH 03301 i

l Phillip Ahrens, Esq. William S. Lord Assistant Attorney General Board of Selectmen Department of the Attorney General Town Hall - Friend Streat Augusta, ME 04333 Amesbury, MA 01913

, ll ,

• 0,

)

G. Paul Bo11werk, III, Chairman Alan S. Rosenthal Atomic Safety & Licensing Atomic Safety & Licensing

• Appeal Board. ~ Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 ,Bethesda, MD 20814 ,

Howard A. Wilber *Kenneth M. Carr Atomic Safety & Licensing Chairman Appeal Board U.S. Nuclear Regulatory Commission

'U.S. Nuclear Regulatory Commission 11555 Rockville Pike East West Towers Building Rockville, MD 20852 4350 East West Highway Bethesda, MD 20814

• Thomas M. Roberts, Commissioner *Kenneth C.-Rogers, Commissioner U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 11555 Rockville Pike 11555 Rockville Pike p Rockville, MD 20852 Rockville, MD 20852

• James R. Curtiss, Commissioner U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20952 Respectfully submitted, JAMES M. SHANNON ATTORNEY GENERAL

' ~

i John Traficonte

. Assistant Attorney General Chief, Nuclear Safety Unit Matthew T. Brock l Assistant Attorney General

! Department of the Attorney General One Ashburton Place Boston, MA 02108 (617) 727-2200 Dated: December 1, 1989 i

- _ -