ML20150A934

Suffolk County Answers to Lilco First Set of Interrogatories & Requests for Production of Documents Re Lilco Emergency Broadcast Sys.* Certificate of Svc Encl

ML20150A934
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/09/1988
From:	Mark Miller KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:	Atomic Safety and Licensing Board Panel
References
CON-#188-5846 OL-3, NUDOCS 8803160092
Download: ML20150A934 (21)

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4 00CKETED USNRC March 9, 1988 16 NM 11 P2 51 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE 0F SECRr:TAhY 00CMEilNG A $[4yjC[

Before the Atomic Safety and Licensino Board BRANCH

)

In the Matter of )

) Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY, ) (Emergency Planning)

)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

SUFFOLK COUNTY'S ANSWERS TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REGARDING LILCO'S EMERGENCY BROADCAST SYSTEM l

On February 24, 1988, LILCO filed its "First Set of Interrogatories and Requests for Production of Documents Regarding LILCO's Emergency Broadcast System ("EBS") to Suffolk County and New York State" ("First Request"). Pursuant to 10 CFR S 2.740b, Suffolk County (the "County") hereby responds to LILCO's First Request.

I. GENERAL RESPONSE A. All documents identified in these Answers will be provided within the time allotted by the NRC's Rules of Practice, to the extent the County does not object to their production.

B. The County hereby objects to LILCO's interrogatories and document requests to the extent they seek information or 8803160092 880309 a PDR G

ADOCK 05000322 PDR f9

documents outside of the possession, custody or control of the County.

C. The County objects to all interrogatories and document requests insofar as they require the disclosure of any information protected by the. attorney-client privilege or work product doctrine.

II. ANSWERS TO INTER?OGATORIES AND DOCUMENT REQUESTS Identification of Witnesses LILCO Interrocatory No. 1

1. Please identify each witness Intervenors expect to call to testify on any factors concerning EBS contentions 1.A, l.B, l.C, and 2.A, admitted by i

the Board in its February 22, 1988 Order. For each witness, other than experts, that

Intervenors expect to call, state the subject matter on which he is expected to testify and the substance of the facts to which he is expected to testify. For each witness that Intervenors expect to call as an expert witness, i

state the subject matter on which he is expected i to testify, the substance of the facts and opinions to which he is expected to testify, and the summary of the grounds for each such opinion.

Answer. On March 4, 1988, the County identified Gregory Minor as a potential witness, who may testify on the County's behalf at the hearing regarding LILCO's EBS. The County is

currently in the process of interviewing other individuals who

! may be called to testify at the hearing. When and if it is

decided to retain any of these individuals to testify on the County's behalf, they will be promptly identified, and the i

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t County's Answers to this and other interrogatories set forth in LILCO's First Request will be supplemented accordingly.

Mr. Minor has testified on numerous other issues in the Shoreham proceedings, and thus is well known to LILCO. At this time, it is expected that Mr. Minor may offer testimony regarding inadequacies in LILCO's new provisions for transmitting emergency messages and activating tone alert radios. More particularly, Mr. Minor may testify concerning weaknesses in WPLR's broadcast signal and the inability of LILCO's proposed EBS network to broadcast emergency messages to the full 10-mile EPZ on a 24-hour basis, thereby resulting in a failure to comply with regulatory i

requirements. If offered as a witness on Suffolk County's behalf, Mr. Minor's testimony would be based upon his general knowledge and experience in the field. Further research, i

analysis and investigation by Mr. Minor may lead to further bases I for any testimony that may be proffered.

LILCO Interroaatory No. 2

2. For each witness, please provide a copy of his most current curriculum vitae, resume, or statement of professional qualifications.

Answer. A copy of Mr. Minor's resume was produced to LILCO in connection with the 1987 litigation regarding the results of the February 13, 1986 Exercise for Shoreham. An updated resume I is attached to these Answers to LILCO's First Request.

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LILCO Interrocatorv No. 3

3. Please list any NRC, legislative, or other legal proceeding in which each witness has testified on any matter concerning the adequacy and coverage capabilities of radio stations and, more specifically, the adequacy under NRC regulations of any EBS station or network intended to be used in the event of any nuclear or non-nuclear emergency to communicate emergency information to the public.

Answer. Mr. Minor has not appeared as a witness in any other proceeding on the subject topics.

LILCO Interrocatory No. 4

4. Please provide a copy of any prefiled testimony listed in response to Interrogatory 3 above.

Answer. Egg Answer to Interrogatory No. 3 above.

LILCO Interrocatory No. 5

5. Please identify all articles, papers, and other documents authored or coauthored by each witness on the subject of the adequacy and coverage capabilities of radio stations and, more specifically, the adequacy under NRC regulations of any EBS station or network intended to be used in the event of any nuclear or non-nuclear emergency to communicate emergency information to the public.

Answer. Mr. Minor has authored no articles, papers or other documents on the subject topics.

l LILCO Interroaatory No. 6

6. Please state whether each witness has prepared, I

or has had prepared, any written studies, reports, analyses, or other documents with respect to any of the following:

(a) The broadcast coverage area of any radio I station (s);

(b) The effect of geography, transmitter l

location, and reception antenna location on

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0 the broadcast signal and coverage capability of any radio station (s); and (c) The broadcast coverage capabilities required of any EBS radio station or system under NRC or FCC regulations.

Answer. Mr. Minor has not prepared or had prepared any studies, reports, analyses or other documents on the subject topics.

LILCO Interrocatory No. 7

7. Unless the answer to Interrogatory 6 above is a simple negative, please identify and provide a copy of each document.

Answer. Egg Answer to Interrogatory No. 6 above.

Identification of Information LILCO Interrocatory No. 8

8. Please list each and every factor, basis, or reason that Intervenors claim supports their statement in Contention 1.A that "WPLR's broadcast signal is too weak to convey a strong and clear broadcast message throughout the EPZ."

Please identify and produce a copy of every document concerning any such factors, bases, or reasons.

Answer. At this time, the County is relying on documents on file at the Federal Communications Commission ("FCC") to support the statement in Contention 1.A that "WFLR's broadcast signal is too weak to convey a strong and clear broadcast message throughout the EPZ." In part'.cular, a "Proposed service Contours Map" prepared for WPLR in October 1980 indicates that WPLR may not provide full coverage to the entire 10-mile EPZ. Suffolk County notes that discovery has just begun in this proceeding.

When and if the County obtains additional information to respond 5-

to this interrogatory, it will supplement this Answer in a timely manner.

LILCO Interrocatory No. 9

9. Please list each and every factor, basis, or reason that Intervenors claim supports their t statement in contention 1.B that "The geography of Long Island, combined with the location of WPLR's transmitters, exacerbates the weakness of WPLR's broadcast signal with respect to the public in . . . the Shoreham EPZ." Please identify and produce a copy of every document concerning any such factors, bases, or reasons. ,

Answer. At this time, the County i.s relying on documents on file at the FCC to support the statement in Contention 1.B that "The geography of Long Island, combined with the location of i

WPLR's transmitters, exacerbates the weakness of WPLR's broadcast signal with respect to the public in . . . the Shoreham EPZ." In addition to the proposed service contours map identified in response to Interrogatory No. 8 above, the County relies upon otter proposed contour maps maintained in the FCC's public files, which indicate that WPLR's signal may be impaired by interference fron other radio stations broadcasting on channels in close proximity to WPLR's channel (99.1 FM). Moreover, WPLR's l

transmitters are located in the New Haven, Connecticut area, f which is to the north of the Shoreham EPZ. Based upon  ;

i preliminary information, it appears that, most often, rooftop  :

l antennas used for TV and FM radio reception on Long Island are directional antennas oriented in a different direction than i toward New Haven. This could impair WPLR's reception in the Shoreham EPZ. (Egg response to Interrogatory No. 10 below). In l

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t addition, the geography of Long Island, including the hilly terrain on the north shore, could prevent or impair WPLR's  ;

reception in some areas. Suffolk County notes that discovery has ,

just begun in this proceeding. When and if the County obtains additional information to respond to this interrogatory, it will supplement this Answer in a timely manner.

l LILCO Interrocatory No. lq

10. Please state the basis for Intervenors' I statement in contention 1.B that "Long Island ,

radio antennas are typically oriented in a nominal east-west direction, in order to facilitate reception of radio signals from the New York City area." Please identify and produce any documents that Intervenors believe ,

! support this statement.

• Answer. Preliminary information available to Suffolk County indicates that, most often, rooftop antennas used for TV and FM radio reception on Long Island are directional antennas oriented

] in a different direction than toward New Haven, Connecticut, where WPLR is located. Suffolk County notes, however, that discovery has just begun in this proceeding. When and if the r

County obtains additional information to respond to this ,

interrogatory, it will supplement this Answer in a timely manner.

LILCO Interrocatory No. 11

11. Please identify and produce a copy of any  !

documents that Intervenors believe support their statement in contention 2.A that "the new EBS network has significant gaps in its AM coverage l of the EPZ at night."

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Answer. LILCO's Motion for Summary Disposition of the WALK ,

I Radio Issue, dated November 6, 1987, and in particular the l

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engineering reports attached to LILCO's Motion, indicate that there may be significant portions of the EPZ that are not provided AM coverage at night. Suffolk County notes, however, that discovery has just begun in this proceeding. When and if the County obtains additional information to respond to this interrogatory, it will supplement this Answer in a timely manner.

Identification of Other Documents LILCO Interrocatory No. 12

12. Please identify and provide a copy of any document not already identified in response to Interrogatories 1-11 above on which Intervenors intend to rely in support of their position on contentions 1.A, l.B, l.C, and 2.A.

Answer. At this time, the County has not identified any documents on which it intends to rely, other than those documents referenced above. Suffolk County notes, however, that discovery has just begun in this proceeding. To the extent that additional, non-privileged documents responsive to this interrogatory are identified, they will be produced on a timely basis by the County. Similarly, to the extent that any documents responsive to this interrogatory are identified but not produced by the County because of privilege, such documents and the nature of the privilege claimed will be sufficiently described to permit

the Licensing Board to determine the validity of the claim of privilege.

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OBJECTIONS STATED BY COUNSEL All objections and assertions of privilege, or reference thereto, were stated by counsel.

E. Thomas Boyle Suffolk County Attorney Building 158 North County Complex Hauppauge, New York 11788 Michael S. Miller Michael J. Missal KIRKPATRICK & LOCKHART 1800 M Street, N.W.

South Lobby - Ninth Floor Washington, D.C. 20036-5891 Attorneys for Suffolk County.

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l March 9, 1988 i

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i 000XETE0 USNRC March 9, 1988 UNITED STATES OF AMERICA ~58 MU 11 P2 5f

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NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina BoarhC E BRAhut h fk

)

In the Matter of )

)

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

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY'S ANSWERS TO LILCO'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION

OF DOCUMENTS REGARDING LILCO'S EMERGENCY BROADCAST SYSTEM have been served on the following this 9th day of March, 1988 by U.S.

mail, first class, except as otherwise noted.

James P. Gleason, Chairman Mr. Frederick J. Shon Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washingtcn, D.C. 20555 i

James P. Gleason, Chairman William R. Cumming, Esq.

513 Gilmoure Drive Spence W. Perry, Esq.

l Silver Spring, Maryland 20901 Office of General Counsel j Federal Emergency Management Agency

! Dr. Jerry R. Kline 500 C Street, S.W., Room 840

! Atomic Safety and Licensing Board Washington, D.C. 20472 i

U.S. Nuclear Regulatory Commission Wsshington, D.C. 20555 W. Taylor Reveley, III, Esq.

Hunton & Williams

Fabian G. Palomino, Esq. P.O. Box 1535 Richard J. Zahnleuter, Esq. 707 East Main Street Special Counsel to the Governor Richmond, Virginia 23212 l Executive Chamber, Rm. 229 State Capitol Albany, New York 12224

Joel Blau, Esq. Anthony F. Earley, Jr., Esq.

Director, Utility Intervention General Counsel N.Y. Consumer Protection Board Long Island Lighting Company Suite 1020 175 East Old Country Road Albany, New York 12210 Hicksville, New York 11801 E. Thomas Boyle, Esq. Ms. Elisabeth Taibbi, Clerk Suffolk County Attorney Suffolk County Legislature Bldg. 158 North County Complex Suffolk County Legislature Veterans Memorial Highway Office Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 Mr. L. F. Britt Stephen B. Latham, Esq.

Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.

195 East Main Street 1717 H Street, N.W.

Smithtown, New York 11787 Washington, D.C. 20555 Alfred L. Nardelli, Esq. Hon. Patrick G. Halpin New York State Department of Law Suffolk County Executive 120 Btoadway, 3rd Floor H. Lee Dennison Building Room 3-118 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792 Mr. Jay Dunkleburger George E. Johnson, Esq.

New York State Energy Office Edwin J. Reis, Esq.

Agency Building 2 office of the General Counsel Empire State Plaza U.S. Nuclear Regulatory Comm.

Albany, New York 12223 Washington, D.C. 20555 l David A. Brownlee, Esq. Mr. Stuart Diamond l Kirkpatrick & Lockhart Business / Financial

1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W. 43rd Street New York, New York 10036 I

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vQ Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 k fk 22 Michael J.fissal KIRKPATRICK & LOCKHART 1800 M Street, N.W.

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

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EROFESSIONAl OUAUFICATIONS OF GREGORY C. MINOR GREGORY C, MINOR MHB Technical Associates 1723 Hamkon Avenue Suite K San Jose, California 95125 (408) 266-2716 EXPERtENCE:

1976 to PRESENT Vice President MHB Technical Associates. San Jose. California Engineering and energy consultant to state, federal, and private organizations and IndMduals.

Major activities include studies of safety and risk involved in energy generation, providing technical consulting to legislative, regulatory, public and private groups and expert witness in behalf of state organizations and citizens' groups. Was co-editor of a critique of the Reactor Safety Study (WASH 1400) for the Union of Concerned Scientists and co-author of a risk analysis of Swedish reactors for the Swedish Energy Commission. Served on the Peer Review Group of the NRC/TMI Specialinquiry Group (Rogovin Committee), ActNely involved in the Nuclear Power Plant Standards Committee work for the Instrument Society of America (ISA).

1972 -1976 Manaaer. Advanced Control and Instrumentation Enoineerino. General Electric Comoany.

Nuclear Enerov DMslon San Jose. California Managed a design and development group of thirty-four engineers and support perconnel designing systems for use in the measurement, control and operation of nuclear reactors.

Involved coordination with other reactor design o ganizations, the Nuclear Regulatory Commission, and customers, both overseas and domestic. Responsibilities !ncluded coordinating and managing and design and development of control systems, safety systems, and new control concepts for use on the next generation of reactors. The position included responsibility for standards applicable to control and instrumentauon, as well as the design of short term solutions to field problems. The disciplines uwolved included electrical and mechanical engineering, seismic design and process computer control / programming, and equipment qualifcation.

1970 1972 Manaaer. Reactor Control Systems Deslan. General Electric Comoany. Nuclear Enerov DMslon. San Jose. Cafifornia Managed a group of seven engineers and two support personnel in the design and preparation of the detailed system drawings and control documents relating to safety and emergency systems for nuclear reactors. Responsibility required coordination with other

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design organizations and Interaction with the customer's engineering personnel, as well as regulatory personnel.

1963 1970 Deslan Enaineer. General Electric Comoany. Nuclear Enerav DMslon. San Jose Califomia Responsible for the design of specific control and instrumentation systems for nuclear reactors. Lead design responsibility 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 responsibaitles included on site checkout and testing of a complete reactor control system at an experimental reactor in the Southwest.

Received patent for Nuclear Power Monitoring System.

1960 1963 Advanced Encineerina Proaram. General Efectric Comoany: Assianments in Washincton.

California. and Arizona 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, Califomia. Work on design of j cavity couplers for Microwave Traveling Wave Tubes (TWT)

Design engineer, Computer Department, Phoenbr, Arizona. Design of core drMng circultry.

Design engineer, Atomic Power Equipment Department, San Jose, California.

Circuit design and analysis.

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Design engineer, Space Systems Department, Santa Barbara, California.

Prepared control portion of satellite proposal.

Technical Staff Technical Military Planning Operation. (TEMPO), Santa Barbara, i

Califomia. 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.

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EDUCATION University d Califomia at Berkeley, BSEE,1960.

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

Stanford University, MSEE,1966.  !

HONORS AND ASSOCIATIONS Tau Beta Pi Engineering Honorary Society Co-holder d U.S. Patent No. 3,565 760,

• Nuclear Reactor Power Mor/toring System,' February,1971.

l Member: American Association for the Advancement of Science. -

Member: Nuclear Power Plant Standards Commhtee, instrument Society of America. .

PERSONAL DATA Bom June 7,1937 Married, three children k Residence: San Jose, Califomia f'

t PUBLICATIONS AND TESTIMONY 1.

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

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G. C. Minor, W. G. MHam, 'An integrated Control Room System for a Nuclear Power Plant,'

NEDO 10658, presented at International Nuclear Industries Fa r and Technical Meetings, j October,1972, Basie, Switzeriand.

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The above article was also published in the German Technical Magazine, NT, M&rch,1973.

4 Testirnony d G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the Joint Committee f.m Atomic Energy, Hearing held February 18,1976, and published by the Union i, d Concemed Scientists, Cambridge, Massachusetts. ,

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5. Testimony d G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the Calrfornia State l Assembly Committee on Resources, Land Use, and Energy, March P,1976.

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

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7. Testimony of G. C. Minor regarding the Grafentheinfeld Nuclear Plant, March 16 17, 1977,  !

Wurzbuerg, Germany. .

8. Testimony of G. C Minor before the Cluff Lake Board of inquiry, Regina, Saskatchewan,  :

Canada, September 21,1977, r

9. i The Risks of Nuclear Power Reactors A Rev_lts.pf 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 Concemed Scientists, August,1977. ,

10. Swedish Reactor Safety Studv Barseback Risk Assessment. MHS Technical Associates,  ;

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

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11. Testimony by G. C. Minor before the Wisconsin Public Service Commission, February 13, ,

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1978, Loss of Codant Accidents Their Probability and Consecuence.

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

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

August 21 and September 1,1978, Bonn, Germany.  :

14. Testimony of G. C. Minor. D. G. Bridenbaugh, and R. B. Hubbard, before the Atomic Safety i

and Licensing Board, September 25,1978,in the matter of Black Fox Nuclear Power Station l Corxtruction Permit Hearings, Tulsa, Oklahoma.

15. Testimony of G. C. Minor, ASLB Hearings Related to TMI.2 Accident, Rancho Seco Power ,

i Plant, on behalf of Friends of the Earth, September 13,1979.

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[t Testimony of G. C. Minor before the Michigan State Legislature, Special Joint Committee on l

Nuclear Energy, Imolications of Three Mlle Island Accident for Nuclear Power Plants in Michican. October 15,1979. t

. 17. A Critical View of Reactor Saferv by G. C. Minor, paper presented to the American Association for the Advancement of Science, Symposium on Nuclear Reactor Safety.

• January 7,1980, San Francisco, Californla. *

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

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19. Minnesota Nuclear Planto Gaseous Emissions Study. MHB Technical Associates, j September 1980, prepared for the Minnesota Pollution Control Agency, Rosevi!!e, MN. l 3 20. Testimony of G. C. Minor and D. G. Bridenbaugh before the New York State Public Service t

Commission, Shoreham Nuclear Plant Construction Schedute, in the matter of Long Island '

{ Ughting Company Temporary Rate Case, case # 27774 September 22,1980.  ;

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21. i l Syster-s interaction and Sinde Falture Criterion. MHB Technical Associates, January,1981, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, j Sweden.

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22. Testimony of G. C, Minor and D. G. Bridenbaugh before the New Jersey Board of Public Utilities, Oyster Creek 1980 Refuelino Outaae Investication. In the rnatter of the Petition of Jersey Central Power and Light Company for approval of an increase in the rates for electrical service and adjustment clause and factor for such service, CAL Docket No. PUC 3518-80, BPU Docket Nos. 804 285,807 488, February 19,1981.

23. Testimony of G. C. Minor and D. G. Bridenbaugh on PORV's and Pressurizer Heaters. Diablo Canyon Operating Ucense hearing before ASLB, in the matter of Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), Docket Nos. 50 2754L 50-3234L, January 11,1982.

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Testimony of G. C. Minor and R. B. Hubbard on Emergenev Response Planning. Diablo Canyon Operating Ucense hearing before ASLB, Docket Nos. 50 275 OL 50 323 OL, January 11,1982.

25. Systems Interaction and Sinde Failure Criterion Phase 11 Reoort, MHB Technical Associates, February 1982, prepared for and availade from the Swedish Nuclear Power inspectorate, Stockholm, Sweden.

26. Testimony of G. C. Minor, R. B. Hubbard, M. W. Gdasmith, S. J. Harwood on behalf of Suffolk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughtlng Company, Shoreham Nuclear Power Station, Unit 1, regarding Contention 78, Safety Classification and Systems interaction. Docket No. 50 3224L April 13,1982,

27. Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffdk County Contention 11. Passive Mechanica1 Vatve Failure, Docket no. 50 322-OL April 13,1983.

28. Testimony of G. C. Minor and R. B. Hubbard on behalf of Suffdk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting Company, Shoreham Nuclear Power Station, Un!t 1, regarding Suffolk County Contention 27 and SOC Contention

3. Post Accident Monnoring, Docket No. 50-322 OL, May 25,1982.

29. Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Sua dk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffdk County Contention 22. SRV Test Proaram. Docket No. 50 322-OL, May 25,1982.

30. Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Su"dk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Reduction of SRV Cha'!enge$, Docket No. 50-3224L, June 14,1982.

31. Testimony of G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Un?t 1, regarding Environmental Qual f; cation. Docket No 50 322 OL January 18, 1983.

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Testimony of G. C. Minor and D. G. Bridenbaugh before the Pennsylvania Public Utility L Commission, on behalf of the Office of Consumer Advocate, Recardino the Cost of  !

Constructino the Susouehanna Steam Electric Station. Unit 1. Re: Pennspvania Power and l

Ught, Docket No. R 822189, March 18,1983.

33. Supplemental testimony of G. C. Minor, R. B. Hubbard, and M. W. Goldsmith on behalf of 3

Suffolk County, before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting Company, Shoreham Nuclear Power Station, Unit 1, regarding Safety Classification '

and Systems interaction (Contention 78). Docket No. 50-322, March 23,1983.

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34. Verbal testimony before the District Court Judge in the case of Sierra Club et. al. vs. DOE regardhg the Clean up of Uranium Mill Tailings. Ju ie 20,1983.

35. Systems Interaction and Sinate Failure Criterion: Phase 3 Reoort. MHB Technical Associates, June,1983, prepared for and available from the Swedish Nuclear Power inspectorate, Stockholm, Sweden.

i 36. Systematic Evaluation Procram: Status Reoort and initial Evaluation. MHB Technical Associates, June,1983, prepared for and available from the Swedish Nuclear Power inspectorate Stockholm, Sweden.

37. Testimony of G. C. Minor, F. C. Finlayson, and E. P, Radford before the Atomic Safety and Ucensing Board, in the Matter of Long Island Ughting Company, Shoreham Nuclear Power

' Station, Unit 1, regarding Emeroency Plannino Evacuation Times and Doses (Contentions -

65. 23 D and 23 H). Docket No. 50 322 OL-3, November 18,1983.  !

38. Testimony of G. C. Minor, Sizewell 'B' Power Station Public inquiry, Proof of Evidence Recardino Safetv lssues. December,1983.

j 39. Testimony of D. G. Bridenbaugh, L M. Danielson, R. B. Hubbard and G. C. Minor before the l

' State of N6w York Public Service Commission, PSC Case No. 27563,in the matter of Long

' Island Ughting Company Proceeding to Investlaste the Cost of the Shoreham Nuclear Generatino Facility - Phase ll. on behalf of County of Suffolk, February 10,1984. L

40. Testimony of Fred C. Finlayson, Gregory C. Minor and Edward P. Radford before the Atomic Safety and Ucensing Board in the Matter of Long Island Ughting Company, Shoreham

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Nuclear Power Station, Unit 1, on behalf of Suffolk County Regarding Emeroency Plannino - i Shetterino IContention 61). Docket No. 50-322 OL, March 21,1984.

41. Testimony of G. Dennis Eley, C. John Smith, Gregory C. Minor and Dale G. Bridenbaugh before the Atomic Safety and Ucensing Board, in the matter of Long Island Ughting '

company, Shoreham Nuclear Power Station Unit 1, regarding EMD Diesef Generators and 20 MW Gas Turbine. Docket No. 50 322-OL, March 21,1984.

42. Revised Testimony of Gregory C. Minor before the Atomic Safety and Ucensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, on  :

behalf of Suffolk County regarding Emeroency Plannino - Recovery and Reentry I (Contentions 85 and 88). Docket No 50-322 OL, July 30,1934.

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43. Testimony of Dr. Christian Meyer, Dr. Jose Roesset, and Gregory C. Minor before the Atomic Safety and Ucensing Board, in the rmtter of Long Island Ughting Company, 4

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Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County, regarding low Power Hearinos Seismic Cacabifitles of AC Power Sources. Docket No. 50-322 OL, July 1984.

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44. Affidavit of Gregory C. Minor, Emergency Planning Legal Authority Court Case, State Court i of New York, September 11,1984.

j 45. Surrebuttal Testimony of Dale G. Bridenbaugh, Lynn M. Danleison, Richard 8. Hubbard, and Gregory C. Minor, Before the New York State Public Service Commission, PSC Case No.

27563, Shoreham Nuclear Station, Long Island Ughting Company, on behalf of Suffolk i

County and New York State Consumer Protection Board, regarding Investlaation of the Cost

] ofjhe Shoreham Nuclear Generatino Facilltv, 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 Excend4ures by Fitchburo Gas and Electric Ucht Comoany for Seabrook Unit 2. November 23,1984,84 pgs.

47. Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C. Minor on i

1 behalf of Maine Public Utilities Commission Staff regarding Prudence of Costs of Seabrook Unit 2, Docket No. 84113, December 21,1984.

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

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49. Direct Testimony of Dale G. Brldenbaugh, Lynn M. Danielson and Gregory C. Minor on i

• behalf of the Vermont Department of Public Service, PSB Docket No. 5030, regarding Prudence of Central Vermont Public Servlee Coroorations Costs for Seabrook 2, November 11,1985. s

! 50. Surrebuttal testimony of Gregory C. Minor on behalf of the Vermont Department of Public Service, PSB Docket No. 5030, Prudence of Centrat Vermont Public Servlee Corocrations Costs for Seabrook 2, December 13, 1985.

I l 51. Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K Price, and Steven C.

1 Sholly on behalf of State of Connecticut Department of Public Utility Control Prosecutorial

, DMslon and DMslon of Consumer Counsel regarding the Prudence of Evoenditures on l Millstone Und 3. Docket No. 83 0743, February 18,1986.

52. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding the Prudence of Eroend4ures by New Enotand Power Co for Seabrook Un4 2. Docket Nos. ER 65-646400, ER-85447 000, February 21,1986.

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53. Direct Testimony of Gregory C. Minor on behalf of the Prosecutorial DMslon of CDPUC l

i regarding CL&P Construction Prudence for Mitistone Uni 3. Docket No. ER-85 720401 l March 19,1986.

l l 54. Direct Testimony of Date G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts i

Attorney General regarding WMECo Construction Prudence for Vilstone Unit 3 Docket No.85-270, March 19,1986.

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55. Ottoct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attomey General regarding WMECo's Commeretal Ooeratina Dates and Deferred CaoMal AddMions on Miffstone UnM 3. Docket No. 85 270, March 19,1986.

56. Rebuttal Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding Rebuttal to New Enofand Power Comoanv's Seabrook 2. Docket Nos. ER 85-646@1, ER-85-647@1, 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 Mittstone Unit 3,in the matter of Malne Power Company Proposed increase in Rates, Docket No. 85 212. April 21,1986.

58. Imolications of the ChemobM Accident for Nuclear Emeroency Pfannina for the State of New York. prepared for the State of New York Consumer Protection Board, by MHB Technical Associates, June 1986.

59. Direct Testimony of Date G. Bridenbaugh and Gregory C. Minor on behalf of the Vermont Department of Public Ser< ice, regarding Prudence of Costs by Central Vermont Public Servlee Corocration for Millstone 3. Docket No. 5132, August 25,1986.

60.

Surrebuttal Testimony of Gregory C. Minor in the matter of Jersey Central Power and Ught Company, regarding TMI Restart and Performance incentives, (Oral testimony). OAL Docket No. PUC 7939-85, BPU Docket No. ER851116. September 11,1986.

61.

Surrebuttal Testimony of Gregory C. Minor on behalf of State of Vermont Department of Public Service, regarding CVPS/NU Construction Prudence related to Miffstone UnM 3, Docket No. 5132 November 6,1986.

62.

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

l 63.

Direct Testimony of Gregory C. Minor on tehalf of Suffolk County, before the Atomic Safety and Ucensing Board, conceming Shoreham ProtectNe Action Recommendations (Contention EX 36). In the rnatter of Long Island Ughting Company, Shoreham Nuclear Power Station, Unit 1, Docket No. 50 322-OL 5, February 27,1987.

64. Direct Testimony of Gregory C. Minor et. al. on behalf of the State of New York and Suffolk County, before the Atomic Safety and Ucensing Board, regarding The Scoce of the l

Emeroency Plannino Exercise (Contentions EX 15 and 16), in the matter of Long Island Ughting Company, Shoreham Nuclear Power Station, Unit 1, Docket No. 50 322 OL 5, April 6,1987.

65. Direct Testimony of Gregory C. Minor regarding Emeroency Plannina Recention Centers -

Monitorina and Decontamination, Shoreham Docket 50 322 OL 3 (Emergency Planning).

Apri 13,1987, 65.

Testimony of Gregory C. Minor, Steven C. Shotly et. al. on behalf of Suffolk County, regarding ULCO's Receotion Centers Plannino Basis, before the Atomic Safety and

.s.

Ucensing Board, in the matter of Long Island Ughting Company, Shoreham Nuclear Power Station Unit 1, Docket No. 50422-OL4, Apri 13,1987, d

67.

Rebuttal Testimony of Gregory C. Minor and Steven C, Sholly on behalf of Suffolk County regarding ULCO's Receotion Centers (Rebuttal to Testimony of Lewis G. Hufman). In the matter of Long Island Ughtiry Company, Shoreham Nuclear Power Station, UnN 1. Docket No. 50422 OL4, May 27,1987.

66.

Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behaN of Massachusetts Attorney General, before the Federal Energy Regulatory Commission, regarding Canal Electric Comoany Prudence Related to Seabrook Unit 2 Construction Excenditures, Docket No. ER86 704401, July 31,1987.

69.

Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor before the Pennsylvania Public UtHity Commission, Regarding Beaver Va!!ey Unit 1, Docket No. 179070310, OCA Statement No. 2. August 31,1987. ,

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