ML20053D742

Request to Institute Show Cause Proceeding & for Other Relief to Immediately Suspend Consideration of Util Request for Fuel Loading & Low Power Testing in Light of Newly Discovered Safety Issues

ML20053D742
Person / Time
Site:	LaSalle
Issue date:	03/24/1982
From:	Fahner T ILLINOIS, STATE OF
To:	NRC COMMISSION (OCM)
Shared Package
ML20049J771	List: ML20049J770 ML20053D734 ML20053D739 ML20053D742
References
FOIA-82-168 NUDOCS 8206070275
Download: ML20053D742 (28)

Text

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l UNITED STATE OF' AMERICA '

NUCLEAR REGULATORY COMMISSION

)

In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-373

) and LaSalle County Nuclear ) 50-374 Generating Station, Unit 1 )

and Uni,t 2 )

REQUEST TO INSTITUTE A SHOW CAUSE PROCEEDING AND FOR OTHER RELIEF The People of the State of Illinois (Illinois), by TYRONE C, FAHNER, Attorney General of the State of Illinois, pursuant to the Atomic Energy Act and 10 C.F.R. 52.206, hereby requests the United States Nuclear Regulatory Commission (Com-mission), or the Director of Nuclear Reactor Regulation, to institute a proceeding pursuant to 10 C.F.R. 52.202, to suspend operating license proceedings and for other appropriate relief, in light of newly discovered safety issues...

I. PROCEDURAL BACKGROUND ,

Commonwealth Edison Company (Edison) has been authorized by Construction Permit Nos. CPPR-99 and CPPR-100 to build the LaSalle B206070275 B205'11 .

"' PDR FOIA KODNER82-166 PDR

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County, Illinois Nuclear Station consisting of two generating units, Unit 1 and Unit 2. Construction has been ongoing since 1974 or earlier. The construction of Unit 1 is sub.atantially complete. Uhit 1 is' scheduled for commercial servi ~ce in September, 1982. Unit 2 is scheduled for completion in October, 1983. Operating license proceedings for Unit 1, Docket No. 50-573; and Unit 2, Docket No. 50-374, are pending before the Commission. Illinois in informed that no hearing has been requested or noticed in said operating license proceedings.

Illinois is also informed that Edison has advised the Office of Nuclear Reactor Regulation that it is ready to obtain an oper-ating license for fuel loading and low power testing of Unit 1, pursuant to 10 C.F.R. S2.764 (b) , (f) .

• II. STATEMENT OF FACTS

1. Several of the-buildings which comprisa LaSalle Station ,

Units 1 and 2, including the reactor buildings, are physically connected to each other. In some instances a single building houses equipment which serves both units. Therefore the con-struction practices which are the subject of this Request to Institute a Proceeding (Request), and which are more fully des-cribed below, relate to Unit 1 and to Unit 2.

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• On March 2, 1982 Robert J. Schultz, a vice president of Edison, f stated that Edison expected to load nuclear fuel and to begin

! low power testing within 30 to 40 days. Ill. Commerce Commission Docket No. 82-0026, report of proceedings, p.370.

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2. During the installation of electrical conduit and other equipment in Units 1 and 2, as in nuclear power plants in general, thousands of holes were drilled into the reinforced concretc structures of the plant. Reinforced concrete contains numerous reinforcing steel bars which add strength to the con-crete structura. The steel is commonly called "rebar." The holes have two general functions. Large holes, up to 8 inches in diameter, and ranging from 1 to 7 feet in depth, were drilled through walls and floors to carry conduit from one room or building to another. Small holes, up to 3/4 inch in diameter and up to 6 inches deep, are used to mount the hardware from which conduit, cable trays and other equipment are suspended on .

walls and ceilings in the plant. Anchor bolts are inserted into the small holes to support brackets which hold the equipment.

3. In February, 1982, it came to the attention of the Office of the Attorney General of Illinois that during the construction of Units 1 and 2, certain. practices related to the drilling of 7

holes in the concrete walls, floors and ceilings of the Unit 1 and 2 buildings have created a potentially hazardous condition

.which, upon the operation of either unit at full power, may be injurious to the public health and safety.

A. These practices are generally described as follows. From the beginning of the construction work associated with the installation of electrical

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equipment, at least as early as 1978, until the end of 1979, holes in the reinforced concrete walls, floors, and ceilings of the reactor buildings and other build-ings were, as a matter of course, drilled through the reinforcing steel or rebar. Depending upon the size of the hole and the thickness of the rebar, this drilling practice may damage or completely sever one or more lengths of rebar, or cut chunks out of the rebar.

B. The affidavit of Earnest Garrison, a driller who worked at the LaSalle County construction site during the years 1978, 79, and 80, is attached to this Request as Exhibit 1 and is incorporated herein by reference. Mr. Garrison's affidavit explains in greater detail the drilling practices alleged herein.

7 4. An unknown number of dri1Ied holes, ranging in the ordar cf thousands, are likely to have been cut through steel reinforce-ment in the concrete walls of safety related buildings, including the reactor buildings. Although Illinois does not have access to Edison's records which document these drilling practices, it-understands from the affidavit of Earnest Garrison that such records were made at the time the alleged practices occurred.

. These records, or drill sheets, are essential to the commission's

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- s determination of the extent to which steel reinforcement was damaged or severed in the concrete structure of Units 1 and 2 during construction. The records are believed to be presently in Edison's possession or control. The Commission has access to drill sheets, engineering plans, and other construction records, pursuant to 10 C.F.R. 550. 70 (a) and 42 U.S.C. S2232 (a) .

5. According to Earnest Garrison's affidavit, the practice of drilling through rebar was discontinued, or subjected to the case by case approval of an engineer, some time in late 1979 or early 1980. Illinois has no information which suggests that any engineering approval was ever obtained from Edison's engineering consultants for the rebar cutting which occurred prior to 1980.

6. Tne removal, damaging, or severance of unknown amounts of reinforcing eteel in the walls of the reactor buildings and other related structures presents; a substantial health and safety issue which requires the immediate attention of the Commission. Attached to this Request as Exhibit 2 is the affi-davit of Dale Bridenbau'gh, an expert in the field of nuclear plant construction. According to Mr. Bridenbaugh, the practice of cutting through reinforcing steel should be thoroughly

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i investigated prior to plant operation. He states that if the rebar was damaged or severed without appropriate structural analysis, and if the drilling practice was widespread, "it seems nearly certain that some safety-related structures . . .

would have been affected." (Exhibit 2, at 3-4) Mr. Bridenbaugh explains that the potential consequence of degradation in structural quality is the " failure of the structures and/or systems to perform their safety related functions under accident or seismic conditions." (Exhibit 2 at 5) He recommends that any repairs which may be required to remedy structural degra-dation be mado before the safety systems are called upon to prevent or mitigate the consequences of an accident.

7. A second type of structural deficiency at LaSalle Station has come to the attention of Illinois. The off-gas building is 1

a structure which serves Units 1 and 2. A former construction foreman, whose identi.ty is being kept confidential by the

~i Region'III staff, had told Region III that the concrete ceiling i or roof of the off-gas building was actually only 8 inches thick even though the specifications called for this roof to be 12 inches thick. Illinois is also informed that a transformer sits atop this roof, and that the concrete has cracked substantiaily due to the number of anchor bolt holes drilled in it. The

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affidavit of Dale Bridenbaugh states that the off-gas building houses equipment containing radioactive gases. (Exhibit 2 at 4)

The off-gas building also contains monitoring equipment for measuring radiation levels in the building. The inadequate thick-ness and cracked concrete of the roof on the off-gas building, the presence of anchor bolt holes which may have been drilled through rebar in the concrete roof, and the presence of a heavy transformer on top of this roof, raise a question of possible damage to the equipment housed in the off-gas building in the event the roof or ceiling should fail.

8. In view of the substantial health and safety issues presented in this Request and in the affidavits attached hereto, the loading of nuclear fuel into the reactor building of Unit 1 is inadvisable at this time. The affidavit of Dale Bridenbaugh .

attests to the reasons why fuel loading should be postponed.

(Exhibit 2 at 5) The presence of nuclear fuel severely. limits the ability of investigating personnel to perform the necessary 7

investigation, by making access to some portions of the plant either extremely difficult or impossible. Until the Commission fully examines the potential safety hazard presented by the cut-ting of reinforcing steel as alleged herein, it will not be known whether corrective measures will be needed to ensure the struc-tural integrity and safety of Units 1 and 2. The presence of

. nuclear fuel within the structure of Unit 1 will make more diffi-cult not only the investigation itself, but also the performance

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of any corrective measures which may be ordered by the Commission for Units 1 and 2.

9. Illinois has not previously been a party to any proceeding concerning the licensing of the LaSalle County Nuclear Station.

The facts alleged in this Request which create a substantial -

issue of health and safety were not known to the Requestor Illinois until February, 1982. Thus it is only now that the Attorney General of Illinois finds it necessary to seek t.he relief requested herein. The continued protection of the health and safety of the People of Illinois requires that the questions raised by this Request be fully resolved before the Commission authorizes the operation, at low power or at full power, of Units 1 and 2.

III. REQUESTED RELIEF 7 .For the reasons set forth*above, Illinois requests that the Commission institute a proceeding pursuant to 10 C.F.R.

S2.202 and:

1. Immediately suspend consideration of Edison's.

request for a fuel loading and low power testing license at Unit i until the Commission investigates the alle-gations contained in this Request and decides whether to institute a show cause proceeding.

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2. Suspend or stay all proceedings concerning Edison's applications for operating licenses for the LaSalle County Nuclear Station Units 1 and 2, includ-ing in particular consideration of the granting of authority to begin fuel loading and low power testing, until the Commission investigates the structural inte-grity of the LaSalle Station and determines the extent to which. corrective measures will be required to' eliminate any potentially hazardous condition.

3. Upon a determination by the Commission in the requested proceeding that corrective measures will be required to eliminate such hazardous condition as may be found, modify the construction permits for Units 1 and 2 accordingly.

4. Grant a hearing in the requested proceeding

'e 'and admit Illinois

• as a party thereto.

5. Order such additional relief as may be appro-priate under the circumstances.

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In the alternative, if the Commission chooses to consider this Request within the framework of the pending operating license proceedings, the Commission is requested to admit 1Alinois as a party to such proceedings (Docket Nos. 50-373 and 50-374) and grant a hearing therein limited to the matters raised in this request.

Respectfully submitted, PEOPLE OF THE STATE OF ILLINOIS 1t , J DQ ri:- _ _ -

ONE C. FARMER orney General of Illinois of Counsel .

. PHILIP C. PARENTI Chief, Environmental Control Division JUDITH S. GOODIE Assistant Attorneys General .

Environmental Control Division .

188 West Randolph Street Suite 2315 Chicago, Illinois 60601 .

(312) 793-2491 .

Dated: March 24, 1982 ,

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STATE OF ILLINOIS )

) SS.

COUNTY OF LASALLE )

AFFIDAVIT I, ERNEST GARRISON, being fully sworn and under oath do state:

I reside at Carriage Lane Estates, 3treator, Illinois. I was employed as a core driller at the Commonwealth Edison LaSalle County nuclear plant construction site from approximately June, 1978 until July, 1980.

From about June, 1978 until about February 1980 my employer was Commercial Concrete Sawing and Drilling Company. My duties were the drilling of holes in concrete. I drilled holas ranging in diameter from 1/4" to 3/4" with a small hand drilling machine. I also drilled larger holes, ranging in diameter from 1-1/2" to 8", with a large boring machine. Anchor bolts for the small holes were used for f hanging conduit, cable trays, and other electrical equipment. The large holes were used to carry conduit through walls and floors.

I performed core drilling in all buildings, at all elevations, l thrcughout the plant site, including the reactor buildings for Units ,

1 l and 2. During nost of the year 1979, my partner and I were assigned primarily to the two reactor buildings. We drilled at all elevations in the rcactor buildings. During the time of my employ-ment with Commercial Concrete Sawing and Drilling, I. received my 1

Exhibit 1. .

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drilling instructions orally from my foremen, Stanley Wollek, a Commercial -Concrete cmployee. My work was_ observed; by Tom McGarty, a superintendent employed by the general contractor, Foley Electri-cal Co.

From the time I began drilling at LaSalle in June, 1978 until about February, 1980, it was the usual practice, upon contacting metal reinforcement or rebar during core drilling, to drill through the metal rebar. I was instructed to follow this practice, and to the best of my knowledge, it was the general practice among the other core drillers. Occasionally we were instructed to stop and relocate the holes when metal was contacted. But during most of the time period, we cut through the metal.

Small holes were of the following sizes:

Diameter (inches) Depth (inches) 1/4 1-1/4 3/8 4 1/2 4-1/2 5/8

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't 3/4 6 When rebar was contacted in drilling small holes with diameters of 1/2 to 3/4 inches, we changed to the larger " wet drill", which was a boring drill with a carbon bit and a water spray. The wet drill was too large for 1/4 and 3/8 inch holes. When rebar was contacted

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in drilling these smallest holes, we relocated the holes. My partner and I drilled hundreds of small hcles per week. We contacted and I

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cut through rebar in less than 1/4 of those holes. During the latter part of 1979,-each small hole cut through rebar was marked with paint or a felt pen. I am unable to estimate the number of rebar cuts more precisely.

Large holes, ranging in diameter from 1-1/2 inch to 8 inches, were all cut with the large boring machine. The depths of the large holes equalled the thickness of the walls, floors, or ceilings through which the holes were cut, and ranged from about 1 foot to 6 feet. For the largest diameters, the bits were carbon with dia-mond chips. During my employment in 1978-79, core drillers were instructed to cut through rebar when it was contacted during the drilling of large holes. We seldom failed to contact rebar with the large boring machine. My partner and I followed this practice; and to the best of my knowledge the other. drillers did also. Until the end of 1979, I believe that all of the large holes were drilled by Commercial Concrete employees.

7 When I werked in the reactor buildings for Units 1 and 2 during 1979, I drilled large holes through the walls between the twv re-act6r buildings, b,etween the reactor and the off-gas building, and between the reactor and the auxilliary building. Large holes were cut at a rate of about 1 foot per hour through concre'e. t When rebar was contacted and cut, it took longer.

The locations for the holes to be drilled were laid out by ,

i employees of Foley Electric. To the best of my knowledge metal g

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detectors were not used during the first 7-8 months of my employ-1 ment for locating the holes. A Quality Ascurance inspector in-spected my work beginning several months after I started working.

I can recall two specific incidents concerning the drilling of large holes through metal rebar. On one occasion I' drilled a 6" diameter hole through rebar in the reactor building of Unit 1, at an elevation below 710'. It was at a place where all the steel tied together, and I removed about 25-40 pounds of steel. It took me 2 or 3 days to drill this hole. Tom McGarty instructed me to keep drilling this hole, and he added, "If you can't do it, we'll get someone who can."

On a second occasion I drilled a 7" diameter hole in the re-actor building of Unit 1 at elevation 735. I hit the 2" rebar, and as I continued to drill the rebar was splitting. I asked McGarty and Wollek if I could relocate the hole. McGarty said, "No." That hole was drilled to a depth of 6 to 7 feet, where we hit a beam in 7

the floor of a room where steam pipes were located. .This hole was later grouted in, because it was improperly located.

We filled out'a written report, or drill sheet, _on each hole we drilled for both small and large holes. The reports showed the location, depth, and diameter of each hole. They also showed I whether rebar was contacted or cut.

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'. s From November 1979 to February 1980 I was out on sick leave.

When I returned to the site in February 1980 I worked as a core driller for Foley Electrical Co. until July 1980. During this time period the procedures for contacting rebar were changed. We were instructed to relocate small holes when rebar was contacted, and we were only allowed to cut through the rebar if approval was given by an engineer. Written reports were also made of each hole drilled during this time period. I stopped working at the LaSalle plant as of July 31, 1980, because of an injury.

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. ERNEST' GARRISON SUBSCRIBED AND SWORN TO BEFORE ME THIS //N DAY OF $7)otp}v 1982.

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. . l 1 AFFIDAVIT OF DALE G. BRIDENBAUGH

. 2 3 STATE OF CALIFORNIA )

) ss.

4 COUNTY OF SANTA CLARA )

5 6 DALE G. BRIDENBAUGH, being duly sworn, deposes and says 7 as follows:

8 1. I am a Professional Nuclear Engineer, technical 9 consultant, and' a founder and president of MHB Technical 10 Associates, technical ~ consultants on energy and environment, 11 with offices at 1723 Hamilton Avenue, Suite K, San Jose,-

12 California. I have participated as an expert witness in 13 licensing proceedings before the U.S. Nuclear Regulatory 14 Commission (NRC); have served as a consultant to the NRC; 15 have testified at the request of the Advisory Committee on 16 Reactor Safeguards; have appeared before various committees 37 of the U.S. Congress and testified in various state. licensing 33 and regulatory proceedings. ,

2. I cun a graduate engineer th'oroughlyJ familia [ with . .

39 20 the design, construction, and o'peration of nuclear generating 21 Pl ants , inclu' ding operational errors , equipment andf system 22 failures, and other problems that could lead to adverse safety and reliability consequences. I received a B.S. in Mechanical 23 Engineering from the South Dakota School of Mines and Technology 24 in 1953, and have since been registered in the state of Cali-25 f rnia as a Professional Nuclear Engineer. Further details 26 Exhibit 2. -

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j 1 of my experience and qualifications are contained in my resume, 2 Attachment 1.

3 3. The purpose of this Affidavit is to identify my 4 concerns regarding the adequacy and quality of construction 5 of certain structures which make up an essential portion of 6 Commonwealth Edison Company's LaSalle Nuclear Plant. I have 7 reviewed the Affidavit of Ernest Garrison, which describes

, 8 numerous cases of anchor bolt hole drilling and conduit 9 passageway core drilling in the LaSalle Units 1 and 2 reactor 10 buildings during the period of June, 1978 through July, 1980.

11 If, as is reported in Mr. Garrison's Affidavit, such drilling 12 was conducted so that reinforcing steel in concrete walls was

! 13 damaged and/or completely severed without the benefit of 14 appropriate structural analysis, this trould appear to me to 15 be a c nditi n with potential. safety significance and one that yg should be thoroughly investigated at LaSalle prior to plant operation.

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7 18 4. I have no way of knowing whether the reported practice

! 19 has in fact. jeopardized safety-related structures as I do not i

20 have access ,to the exact locations of the holes that were drilled.

,21 Mr. Garrison's Affidavit, however, indicates that such drilling  !

22 practices were " usual" with the associated imp 1'ication that the~  !

23 Practice was in common use by a large number of electrical crews' 24 working throughout the plant. If the practice was widespread 25 and used by all drillers during this time period, it seems nearly i pg certain that some safety-related structures (those associated 6

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I with systems or components assuring the integrity of the 2 reactor coolant pressure boundary or those necessary to 3 maintain the capability to shut down the reactor cnd maintain 4 it in a safe shutdown condition, or those needed to prevent 5 or mitigate the consequences of accidents which could result 6 in potential off-site exposures) would have been affected.

7 If so, the associated damage or degradation of safety margins

.8 of safety-related structures would appear to have violated 9 the quality requirements imposed by the U.S. Code of Federal 10 Regulation, 10 CFR Par't 50, Appendix A, General Design Criteria 11 for Nuclear Power Plants and Appendix B, Quality Assurance 12 Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.

13 It is also possible, if the practice was widespread to the j 14 extent that it also was used in the attachment of components 15 and equipment to the primary containment structure, that the 13 integrity of that structure could be affected. The LaSalle

. 17 Nuclear Plant configuration includes a Mark II concrete containment structure designed to contain and mitigate the 18 yg consequences of design-basis accidents that could occur during 20 the operatio.n of the plant. The U.S. NRC reviews the 21 adequacy of this containment to assure its compliance with ,

federal regulations. Standard Review Plan 3.8.1, Concrete 22 23 Containment, discusses the points normally covered by the 24 NRC in such review. The impact of the drilling operations

. 25 described in Mr. Garrison's Affidavit would be relevant to the review conducted in accordance with Part II.6, 20 d .

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1 Page 3.8.1-14, which covers materials, quality control, and 2 special construction techniques of concrete containment.

3 The concepts expressed in this Review Plan applying to concrete 4 containment would also apply to the structural integrity of 5 other concrete safety-related walls and structures.

6 5. I have been informed that some of the facts contained 7 in Mr. Garrison's Affidavit have been verbally communicated 8 to the U.S. Nuclear Regulatory Commission as called for in 9 10 CFR Part 21 (U.S. Code of Federal Regulations), but that no 10 investigation has-yet been reported. I have also been informed 11 that the U.S. NRC has been verbally informed (by an unidentified 12 employee) that the concrete roof slab making up the ceiling of

'13 the LaSalle off gas building is below specified thickness and 14 contains numerous holes and cracks. I have further been 15 informed that the NRC's response to the report of this condition was that no investigation of this condition was 19 17 warranted. While it is not likely that failure of the off 18 gas building roof would result in a " calamitous" accident, 19 it does contain equipment and components handling radioactive 20 gases'. The primary significance, however, of the reported 21 failure to in'vestigate this condition by the NRC is the .

22 question that it raises as to the efficacy of the entire I

23 quality oversight function conducted by the NRC on the 24 verall construction of the LaSalle Plant. This question 25 makes more urgent the necessity to resolve the, reported 1 20 ///// .

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_#a 1 deficiencies that may exist in the reactor building (and 2 other structures).

3 6. Prompt action to investigate these concerns is .

4 important. It is my understanding that the LaSalle Unit 1 i

5 Operating License is about to be issued which would permit 6 the loading of fuel into the reactor and initial operations 7 to begin.

While fuel loading in itself is not likely to change h I.

8 the loading conditions of the potentially affected structures 9 so that a failure would be expected, fuel loading does 10 represent a point in t'ime that is of significance in the [

11 Proper conduct of the investigation that may be required.

12 When fuel loading occurs and low power operation is possible, 13 access to certain areas of the plant, including portions of 14 primary containment and reactor building must be controlled 15 and/ r minimized and the free movement from compartment to 16 compartment by investigatory personnel could be restricted. .

, 17 Subsequent power' operation of the reactor could make physical ccess to some portions of the facility impossible or at least 18 yg extremely limited.

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7. The, consequences of the degradation of the structural j quality potentially represented by the severance of. reinfor'cing 21 steel in the concrete walls is the potential failure of the 22 structures and/or systems to perform their safety related -

23 functions under accident or seismic conditions. In my opinion, 24 it is essential that a thorough investigation be made by the

, 25 appropriate authorities of the allegations raised. This would 20

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1 assure that damage to the essential structures, if it in fact 2 exists, has been properly analyzed by appropriate technical 3 experts and repairs or modifications are made if needed before 4 these safety systems are called upon to prevent or mitigate 5 the consequences of an accident.

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Dale G. BridenbauglI#

10 March 17, 1982 o

11 Subscribed and sworn to before 12 me this /7 day of[/8MC/,1982.

13 14 M " E l

15 . NOTARY PU d j r ,

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• SANTA CLARA COUNTY 16  !. > commission expires: 7 4/

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P RO FES SION AL O UALI FI C A!!ONS OF DALE G. 3 RI DEN 3 AUGH DALE G. 3 RI DEN 3 AUGH 172 3 Hamilton Avenue Suite R S an Jo se, CA 95125 (408) 266-2716 EX?E R'ENCE :

19 7 6 - P RESENT President - MH 3 Technical Associates, S an Jose, California.

Co-founder and partner of :echnical consulting firm. Specialists

' in energy consulting to governmental and other groups interested in evaluation of nuclear plan: safety and licensing. ' Consultant in this capacity to state agencies in California, New York, Illi-nois, New J2:sey, P en n s y lv an ia , Oklahoma and Minnesota and to the Norwegian Nuclear Power Committee, Swedish Nuclear Inspectorate, and various other organizaticas and environmental groups. Per-formed extens ive saf ety analysis f or Swedish Energy Commission and contributed to the Union of Concerned S cientis t's Review of W AS H-14 00. Consultant to the U.S. NRC - LWR S af ety Improvement Program, performed Cost Analysis of Spen: Fuel Disposal for the Natural Resources Defense Council, and contributed to the Depart-ment of Energy LWR S af e ty Improvement Program f or S andia Labora-cortes. Served as expert witness in N RC and state utility c ommis sion hearings.

.r76 - (FI3RUARY -

AUGUS T) i Consultant, Project Survival, Palo Alto, California.

Volunteer work on Nuclear S af eguards Initiative campaigns in California, Oregon, W as h in g t on , Arizona, and Colorado. Numerous presentations on nuclear power and alternativ,e energy options to civic, government, and college groups. Also resource person for public service presentations on radio and television.

1973 - 1976 Manager, P e rf orman ce Evaluation and Improvement, General Electric

' Company - Nuclear Energy Division, San Jose, Calif ornia.

Managed seventeen technical and seven clerical personnel with responsibility for establish =en: and management of systems to monitor and measure 3 oiling Water Reactor equipment and system operational perf ormance. Integrated General Electric resources in cus tomer plan t modifications , coord in a ted correc tion o f causes of forced outages and of efforts :o improve reliability and per-formance of BWR systems.

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1973 - 1976 ( C on t d)

Responsible for development of Division Mas ter P erf ormance Improvement Plan as well as for numerous Staff special assign-ments on long-range studies. Was on special assignment for the management of two different ad hoc proj ec ts formed to resolve unique technical problems.

1972 -

1973 Manager, Product Service, General Electric Company - Nuclear Energy Division, San Jose, California.

Managed group of twenty-one technical and four clerical personnel.

Prime responsibility was to direct interface and liaison personnel involved in corrective actions required under contract warranties.

Also in charge of refueling and service planning, performance analysis, and service communication functions supporting all com-pleted commercial nuclear power reactors supplied by General Electric, both domestic and overseas (Spain, Germany, Italy, Japan, India, and Switzerland) .

1968 - 1972 Manager, Product Service, General Electric Company - Nuclear "nergy Division, San Jose, California.

Managed sixteen technical and six clerical personnel with the r e s p on s ib ility for all customer contact, plann in g and execution of work required after the customer accep tance of department-supplied plants and/or equipmen t. This included quotation, sale and delivery of spare and renewal parts. Sales volume of parts increased from $1,000,000 in 1968 en over $3,000,000 in 1972.

.966 - 1968 Manager, Complaint and Warranty S ervic e , Gener al Electric Company -

Nuclear Energv Division, S an J o s e , California.

Managed group of six persons with the responsibility for customer contacts, planning and execution of work required after customer acceptance of depar tment-supplied plan ts and/or equipment--both domestic and overseas.

1963 - 1966 Fie ld En g inee rin g Suoervisor, General Electric Company, Installation and S ervice Enginee ring Department, Los Angeles, California.

Supervised approximately eight field representatives with responsi-bility f or General Electric steam and gas turbine installation and main tenance work in S outhern Calif ornia, Arizona, and Southern Nevada. During this period was re s p on s ib le for the installation of eight different central station steam turb ine generator units , plus much maintenance activity. Work included customer contact, prepa-ration of quotations, and contract negotiations.

s 1956 - 1963 Field Engineer, General Electric Company, Installation and Service Engineering Department, Chicago, Illinois.

Supervised installation and maintenance of steam turbines of all sizes. Supervised crews of from ten to more than one hundred men, depending on the j ob. Worked primarily with large utilities but had significant work with steel, petrole2m and other process industries. Had four years of experience at construction, startup, I trouble-shooting and refueling of the first large-scale commercial nuclear power unit.

1955 - 1956 Engineering Training Program, General Electric Company, Erie, Pennsylvania, and Schenectady, New York. ,

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

1953 - 1955 United S tates Army - Ordnance School, Aberdeen, Maryland.

. Ins tructor - Heavy Artillery Repair. Taught classroom and shop disassembly of artillery pieces.

1953 En g in e e rin g Training Program, General Electric Company, Evandale, Ohio.

Training assignment with Aircraft Gas Turbine Department.

T EDUCATION & AFFILIATIONS:

BSME - 1953, . South Dakota S chool of Mines and Technology, 1 . Rapid City, South Dakota, Upper % of class.

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P ro f es sional' Nuclear Engineer - Calif ornic. Certificate No. 0973.

Member - American Nuclear Society.

Various Company Training Courses during career including Prof es- ,

sional Busines s Management , Kepner Tregoe Decision Making, Effective !

Presentation, and numerous technical seminars. l 4

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Swedish Reactor Saf ety Study: BarsebWck Risk As sessment, 8.

KHB Technical As sociates , January , 1978. (Published by the Swedish Department of Industry as Document Dsl 1978:1)

Testimony of D.G. Bridenbaugh, R.B. Hubbard, G.C. Minor to

9. on Resources, Land the Calif ornia S tate Assembly Committee Use, and Energy, March 8, 1976.

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10. Testimony of D.G. Bridenbaugh, R.B. Hubbard, and G.C.

before the United S tates Congress, Joint Committee on Atomic Energy, February 18, 19 7 6, Washing ton , DC (Published by the Union of Concerned S cientis ts , Cambridge, Ma s s cchu s e t t s . )

11. Testimony by D.G. Bridenbaugh before the California Energy Commission, entitled, Initiation of Catastrophic Accidents at Diablo Canyon, Hearings on Emergency Planning, Avila Beach, California, November 4, 1976.

12. Testimony by D.G. Bridenbaugh before the U.S. Nuclear Regula-tory Commission, subject: Diablo Canyon Nuclear Plant Perfor-mance, Atomic S af ety and Licens ing B oard Hearings , December,.

1976.

13. Tes timony by D.G. Bridenbaugh bef ore the California Energy Commission, subject: Interim Spent Fuel S torage Considerations, March 10, 1977.

14. Testimony by D.C. Bridenbaugh before the New York S tate Public Service Consission Siting Board Hearings concerning the James-port Nuclear Power S tation , subject: Effect of Technical and Safety Deficiencies on Nuclear Plant Cost and Reliability, April, 1977.

15. Testimony by D.G. Bridenbaugh before the California State Energy Commission, subject: Decommis sioning _ of Pres surized Water Reactors, Sundesert Nuclear Plant Hearings, June 9, 7

1977. -

16. Testimony by D.G. Bridenbaugh before the Calif ornia S tate Energy Commission, subject: Economic Relationships of Decommissioning, Sundesert Nuclear Plant, for the Natural

" Resources Defense Council, July'15, 1977.

Testimony by'D.G. Bridenbaugh before the Vermont State Board 17.

l of Health, subject: Operation of Vermont Yankee Nuclear1977. Plant i

and Its Impact on Public Health and Safety, October 6, l

Testimony by D.G. Bridenbaugh bef ore the U.S. Nuclear Regula-i l 18.

tory Commission, Atomic Safety and Licensing Board, subject:

Deficiencies in S af ety Evaluation o f Non-S eismic I s sues . Lack l of a Definitive Finding of S af ety , Diablo Canyon Nuclear Units October 18, 1977, Avila Beach, California.

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19. Testimony by D.G. Bridenbaugh before the Norwegian Commission on Nuclear Power, subject: Reactor S af etv /Ris k. October 26, j 1977.

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20. Testimony by D.G. B ridenbaugh bef ore the Louisiana S tate Legis1sture Committee on Natural Resources, subject: Nucicar Power Plant Deficiencies Impacting on Safety & Reliability, Baton Rouge, Louisiana, February 13, 1978.

21. Spent Fuel Disposal Costs, report prepared by D.G. Bridenbaugh for the Natural Resources Defense Council ( NRDC) , August 31, 1978.

22. Testimony by D.G. Bridenbaugh, G.C. Minor, and R.B . Hubbard before the Atomic Safety and Licensing Board, in the matter of the Black Fox Nuclear Power S tation Construction Permit Hearings, September 25, 1978, Tulsa, Oklahoma. i

23. Testimony of D.G. B ridenbaugh and R.B . Hubbard before the Louisiana Public Service Commission, Nuclear Plant and P ower Generation Costs, November 19, 1978, Baton Rouge, Louisiana.

24 Testimony by D.G. Bridenbaugh before the City Council and Electric' Utility Commission of Austin, Texas, Design, Con-struction, and Operating Experience of Nuclear Generating Facilities, December 5, 1978, Austin, Texas.

25. Testimony by D.G. Bridenbaugh for the Commonwealth of Massachusetts, Department of Public Utilities, Impact of Unre solved S sf e ty Issues, Generic Deficiencies, and Three Mile Island-Initiated Modifications en Power Generation Cost, at the Proposed Pilgrim-2 Nuclear Plant, June 8, 1979.

26. I mp r o v in g the Safety of LWR P ower Plants, MHB Technical Associates, prepared for U.S. Dept. of Energy, Sandia Lab. oratories, September 28, L979.

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27. BWR Pipe and Nozzle Cracks, MHB Technical Associates , for the Swedish Nuclear Power Inspectorate (SKI), October, 1979.

2 8.. Testim-ony of.D.G. B ridenbaugh and G. C. Minor before the Atomic S af ety and Licensing B oard, in the matter of Sacramento Mudicipal Utility Dis trict, Rancho Seco Nuclear Generating Station f ollowin g TMI-2 accident, subject:

Operator Training and Human Factors En g in e e rin g , for the, i California Energy Commission, February 11, 1980.

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29. Italian Reactor Safety Study: Caorso Risk Assessment, MHB 1 Technical Associates, for Friends of the Earth, Italy,

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March, 1980.

30. Decontamination of Kryp ton-85 from Three Mile Island Nuclear Plant, H. Kendall, R. Pollard, & D.G. B r id enb aug h , et al, The Union of Concerned S cientis ts, delivered to the Governor of Pennsylvania, May 15, 1980.

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31. Decontamination of Krypton-85 from Three Mile Island Nuclear Plant, H. Kendall, R. Pollard, & D.G. Bridenbaugh, et al, The Union of Concerned Scientists, d eliv ered to the Governor-of Penns ylvania, May 15, 1980.

32. Testimony by D.G. Bridenbaugh before the New Jersey Board of Public Utilities, on behalf of New Jersey Public Advocate's Office, Division of Rate Counsel, Analysis of 1979 Salem-1

- Refueling Outage, August, 1980.

33. Minnesota Nuclear Plants Gaseous Emissions Study, MHB Technical ,

Associates, for Minnesota Pollution Control Agency, September, 1980.

[. 34. Position Statement, Proposed Rulemaking on the Storage and Disposal of Nuclear Waste,. Joint Cross-Statement of Position of the New England Coalition on Nuclear Pollution and the Natural Resources Defense Council, September, 1980.

35. Testimony by D.G. Bridenbaugh and Gregory C. Minor, before the New York State Public Service Commission, In the Matter of Long Island Lighting Company Temporary Rate Case, prepared for the Shoreham Opponents Coalition, September 22, 1980, Shoreham Nuclear Plant Construction Schedule.

36. Supplemental Testimony by D.G. Bridenbaugh before the New Jersey Board of Public Utilities, on behalf of New Jersey Public Advocate's Office, Division of Rate Counsel, Analysis of 1979 Salem-1 Refueling Outage, ecember, 1980.

37. Te,stimony by D.G. Bridenbaugh and Gregory C. Minor, before, the New Jersey Board of Public Utilities, on behalf of New Jersey Department of.the Public Advocate, Division of Rate Counsel, Oyster Creek 1980 Refueling Outage Investigation, February, 1981.

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38. Economic Assessment: Owner' ship Interest in Palo Verde Nuclear Station, MHB Technical Associates, for The City of Riverside,

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September 11, 1981.

39. Testimony of D.G. Bridenbaugh,before the Public Utilities Commission,of Ohio, in the matter of the Regulation of the Electric Fuel Component Con tained Within the Rate Sch adules of the Toledo Edison Company and Related Matters,. subject:

Davis-Besse Nuclear Power Station 1980-81 Outage Reviek, October, 1981.

40. Supplemental Testimony of D.G. Bridenbaugh before.the Public Utilities Commission of Ohio, in the matter of the Regulation of the Electric Fuel Component Contained'within the Rate Schedules of the Toledo

• Edison Company and Related Matters, subj ec t : Davis-Besse Nuclear Power Station 1980-81 Outage Review, November, 1981.

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41. Systems Interaction and Single Failure Criterion. Phase 2  !

Report, MHB Technical Associates for the Swedish Nuclear l Power Inspectorate (SKI), January, 1982. j

42. Testimony of D.G. Bridenbaugh and Gregory C. Minor on behalf of Governor Edmund G. Brown Jr., before the Atomic Safety and Licensing Board, regarding-Contention 10 1 Pressurizer Heaters, January 11, 1982.

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43. Testimony of D.G. Bridenbaugh and Gregory C. Minor on behalf  !

of Governor Edmund G. Brown, Jr. before the Atomic Safety ,

I and Licensing Board, regarding Contention-12, Block and l Pilot Operated Relief Valves. January 11, 1982. l k.

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