APPLICANTS' SUBMITTAL ONwhose resume was submitted with Applicants' Motion for Summary Disposition...

23
cu M U go ', ' . August 25, 1981 or > UNITED STATES OF AMERICA @ h NUCLEAR REGULATORY COMMISSION 2 ,q BEFORE THE ATOMIC SAFETY AND LICENSING BOAitDb .Uc 271981 > :7 4 1 C" :- -f t' 3 : y.j Jj u. . ; c e~a E;l:2 , ~~] In the Matter of gg PENNSYLVANIA POWER & LIGHT COMPANY ) and ) Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC. ) 50-388 ) (Susquehanna Steam Electric Station, ) Units 1 and 2) ) APPLICANTS' SUBMITTAL ON TESTIMONY OF EXPER? WITNESSES The Licensing Board's August 24, 1981 Memorandum and Order on Prehearing Conference required the parties to file by August 25, 1981 the qualification.,, identities, subject matter and substance of testimony of expert witnesses for Contention 2 (other than chlorine), 17, 1, 5, 7, 4 and 8. Applicants respond as follows: I 1. Contention 2: Applicants' presentation on this issue is divided in three parts: Source term, dose j calculations and health effects. As to the source term ( i.e . , the magnitude of releases from the facility), see Applicants' Motion for Partial Summary Disposition of Contention 2 (Source Term), dated ty503 August 13, 1981. As to the dose calculations based 5 ||| . 010:310409 810825 PDR ADOCK 05000387 O PDR _ __ _ _ _ __ __. . _ _ - - . _ _ _ _ _ . - - _ _

Transcript of APPLICANTS' SUBMITTAL ONwhose resume was submitted with Applicants' Motion for Summary Disposition...

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August 25, 1981

or >UNITED STATES OF AMERICA @ h

NUCLEAR REGULATORY COMMISSION 2 ,q

BEFORE THE ATOMIC SAFETY AND LICENSING BOAitDb .Uc 271981 > :74

1 C" :- -f t' 3 : y.j Jju. . ; c e~a

E;l:2,

~~]In the Matter of gg

PENNSYLVANIA POWER & LIGHT COMPANY )and ) Docket Nos. 50-387

ALLEGHENY ELECTRIC COOPERATIVE, INC. ) 50-388)

(Susquehanna Steam Electric Station, )Units 1 and 2) )

APPLICANTS' SUBMITTAL ONTESTIMONY OF EXPER? WITNESSES

The Licensing Board's August 24, 1981 Memorandum and Order

on Prehearing Conference required the parties to file by August

25, 1981 the qualification.,, identities, subject matter and

substance of testimony of expert witnesses for Contention 2

(other than chlorine), 17, 1, 5, 7, 4 and 8. Applicants

respond as follows:

I 1. Contention 2: Applicants' presentation on this issue

is divided in three parts: Source term, dose

j calculations and health effects. As to the source

term ( i.e . , the magnitude of releases from the

facility), see Applicants' Motion for Partial Summary

Disposition of Contention 2 (Source Term), datedty503

August 13, 1981. As to the dose calculations based 5

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010:310409 810825PDR ADOCK 05000387O PDR

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on that source term, see Applicants' Motion for-

Partial Summary Disposition of Contention 2

(Radioactive Doses), dated August 25, 1981. The

third aspect of the testimony will be presented by

Dr. Roger Linnemann, a copy of whose resume is

attached hereto. Dr. Linnemann will describe the

health effects resulting from the calculated doses,

based upon such internationally recognized studies as

the BEIR-III Report and the 1977 UNSCEAR Report.

2. Contention 17: See Applicants' Renewed Motion for

Summary Disposition of Contention 17, dated August

18, 1981.

3. Contention 1: This contentien 4.s divided into three

major issues: radon, technetium, and other fuel cycle

releases. As to radon, see Applicants' Motion for

Summary Disposition of Cor,tention 1 (Radon), dated

August 7, 1981.1 As to technetium, Applicants'

testimony will be presented by Dr. Richard Englehart,

a copy of whose resume is attached hereto. Dr.

Englehart will describe the quantities of technetium

involved in the nuclear fuel cycle for the

Susquehanna facility and provide calculated doses

1 Applicants' continued reference to the radon contentiondoes not indicate a rejection of Environmental Coalition onNuclear Power's proposed stipulation. Tr. 927-33. Applicantshave submitted a proposed stipulation on this matter to ECNPand the Staff.

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from technetium releases. Other fuel cycle releases-

will first be analyzed in terms of the doses from

such releases in testimony by Dr. Morton Goldman,

whose resume was submitted with Applicants' Motion

for Summary Disposition of Contention 1 (Radon). The

health effects for technetium and other aspects of

the fuel cycle will be covered by the testimony of

Dr. Linnemann.

4. Contention 5: See Applicants' Motion for Summary

Disposition of Contention 5, dated June 25, 1981.

5. Contention 7(a): See Applicants' Motion for Summary

Disposition of Contention 7(a), dated August 4, 1981.

6. Contention 7(b): Applicants' testimony on this

contention will be presented by Joseph C. Lemaire

and Walter J. Rhoades. A copy of Mr. Lemaire's

| resume is attached hereto. Mr. Rhoades' resume was

attached as Exhibit "A" to Affidavit of Walter J.!

Rhoades in Support of Summary Disposition of

Contention 16. See Applicants' Motion for Summary|

| Disposition of Contention 16, dated October 27, 1980.

Mr. Lemaire will discuss the experience of stainless

l steel BWR reactor piping with cracking, the mechan-

| isms causing such cracking, and the remedies to

reduce the incidence of such cracking. Mr. Rhoades

will describe the specific remedies used by

Applicants at Susquehanna.

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7. Contention 7(c): Applicants' testimony on this

contention will be presented by Mr. Lemaire and will

indicate the absence of core spray nozzle cracking

and the steps taken to avoid cracking in other

portions of the core spray system.

8. Contention 7(d): See Applicants' Motion for Summary

Disposition of Contention 7D, dated July 17, 1981.

9. Contention 4(a) and (b): Applicants' testimony will

be presented in two portions. Grayson E. McNair will

describe PP&L's load forecasting methodologies and

load forecasts, describing both the econometric and

judgemental techniques used by the Company. A copy

of his resume is attached hereto. William F. Hecht

will present a system cost analysis showing that

operation of the Susquehanna facilities will save

consumers of electricity billions of dollars, reduce

oil imports, and improve diversity of generating

sources. Mr. Hecht's resume is attached hereto.

10. Contention 4(c): Applicants' testimony will be

presented by Grayson E. McNair. Mr. McNair will

describe PP&L's conservation programs and explain why

the actual and potential savings from conservation do

not remove the need to operate Susquehanna.

11. Contention 4(d): Applicants' testimony will be

presented by Grayson E. McNair and Preston L.

Roberts. A copy of Mr. Roberts' resume is attached

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hereto. This testimony will describa PP&L's progrcms-

involving passive and active solar energy and

explain why solar energy al*arnative do not remove

the need to operate Susquehanna.

12. Contention 8: See Applicants' Motion for Summary

Disposition of Contention C, dated July 16, 1981.

Applicants' identification of witnesses for those conten-

tion" not yet the subject of motions for summary disposition is

not an indication that Applicants will forego the filing of

such motions in the future.

Respectfully submitted,

SHAW, PITTMAN, TTS & TROWBRIDGE

FJay /S. | lilbefg j

Mafi/sj?. Travieso-DialV

Counsel for Applicants

1800 M Street, N.W.Washington, D.C. 20036Telephone: (202) 822-1000

Dated: August 25, 1981

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ROGER E. LINNEMANN, M.D.President

Radiation Management Corporation3508 Market Street

University City Science CenterPhiladelphia, PA 19104

(215)243-2950

EDUCATION

University of Minnesota, Minneapolis, MN; B.A. (Cum Laude) 1952

University of Minnesota, Minneapolis, MN; B.S., M.D. 1956

Walter Reed Army Hospital, Washington, D.C. ; INTERNSHIP 1956-1957

Walter Reed Army Hospital, Washington, D.C. ; RESIDENCY (Radiology) 1962-1965

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Certified by American Board of Radiology 1964

Certified b;' American Board of Nuclear Medicine 1972

Licensed to practice Medicine in 1) Commonwealth of Pennsylvania; 2) Illinois;and 3) Minnesota

********

Sandia Base, New Mexico; Nuclear Weapons Orientation Course 1961

Walter Reed Army Institute of Research, Washington, D.C.; Medical Aspects ofNuclear Warfare 1962

US Department of Agriculture Graduate School (Evening) , Washington, D.C.Russian Language 1963-1935

******(*

PROFESSIONAL EXPERIENCE

1969-present President / Chief Executive Officer, Radiation Management Corporation

1974-present Clinical Associate Professor of Radiology, University ofPennsylvania School of Medicine

1977-present Visiting Associate Professor, Clinical Radiology, NorthwesternUniversity Medical School

1969-1974 Assistant Professor, Clinical Radiology, University ofPennsylvania School of Medicine

1968-1969 Nuclear Medicine Consultant, Philadelphia Electric Company-

%

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PROFESSIONAL EXPERIENCE (Continutd),

Jan-Aug 1368 Assistant Professor, Radiology, University of MinnesotaSchool of Medicine (investigated use of isotopes in kidneyfunction evaluation)

1957-1968 Employed by United States Army ....

1965:1968: Commanding Officer, Nuclear Medicine Research Detachment,Europe; Radiological Health Consultant, US Army-Europe.(responsible for plans, procedures and training of militaryhospitals and personnel in the evaluation, evacuation andtreatment of radiation casualties. In January, 1966 sentto Palomaris, Spain for evaluation of medical and environmentalaspects of the mid-air collision involving nuclear weapons)

1961-1962: Research Associate, Department of Radiobiology, Walter ReedArmy Institute of Research, Washington, D.C. (investigateduse of anti-radiation drugs in treatment of cancer)

1957-1961: General Medical Officers Europe

Languages: German, Russian

********

PROFESSIONAL APPOINTMENTS

1979-present Health Physics Society Standards Committee

1978-present General Dynamics Electric Boat Division Radiological HealthConsultant

-.. . - . - . - - . - . . . . - . - -

1978-present Edison Electric Institute Utility Radiation Standards Group

1973-present University cj[ Pennsylvania Radiation Safety Commi.tec

1973-present The Atomic Industrial Forum, Inc. Public Affairs & InformationCommittee

1970-present The American Nuclear Society Subcommittee for Writing EmergencyProcedures Standards

ll 1969 & 1975 Atomic Energy Commission ad hoc Committee on Medical Aspects

of Radiation Accidents

1956-present American College cj[ Radiolcgy ....

1969-present Commission on Radiologic Units, Standards and Protection1969-present Committee on Radiation Exposure of Women

| 1969-present Committee on Radiological Aspects of Disaster Planning1967-1978 International Affairs Committee

1965-1958 U.S. Delegate to, NATO Radiation Protection Committee & Medicall Aspects of Nuclear Warfare Committee

,

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PROFESSIONAL APPOINTMENTS (Continued)

1971-present Department of Defense & Environmental Protection AgencyMedical Liaison Officer's Network (MLON)-State ofPennsylvania Representative

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PROFESSIONAL MEMBERSHIPS

?.merican College of RadiologyAmerican Public Health AssociationAmerican Medical AssociationSociety o3 Nuclear MedicinePhiladelphia Roentgen Ray SocietyPennsylvania Medical SocietyCollege of Physicians of PhiladelphiaRadiological Society of North America, Inc.American Institute of Physicists /Agerican

Association of Physicists in MedicineAmerican College of Nuclear PhysiciansAmerican Council on GennanyUnion League of Philadelphia

************.

AWARDS & HONORS

1978 Association of Medicine & Security, Madrid, Spain -

(Honorary Member)

1968 University cd[ Minnesota Radiological Research Scholar(National Research Council)

1968 United States Army Legion of Merit

************

PRESENTATIONS

1980 Korea Women's Association (Seoul, Korea)presented paper, " Energy: The Basis for Health in Developingand Developed Countries", at International Symposium on theExpulsion of Environmental Pollution

1980 Korean Association for Radiation Protection (Seoul, Korea),

presented seminar on emergency management of radiation injuries|

1980 Ministry cj[ Health (Madrid, Spain)|

presented paper, " Definitive Treatment of Radiation Injuries",at First Seminar on Assistance to Those Wounded by RadioactiveElements and Ionizing Radiations

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PRESENTATIONS (Continu1d)*

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1979 Reinisch-Westfalisches Elekrizitatswerk (Essen, Germany)presented paper, " Energy: The Basis for Health in Developingand Developed Countries", at The Seventh Energy Workshop

1978 The Swedish State Power Board (Vallingby, Sweden)presented seminar, " Management and Treatment of RadiationInjuries", and conduwted radiation emergency medicalexercise at the Ringhauls Nuclear Power Plant

1978 Deutsche Gesellschaft fur Wiederaufarbeitung (Hannover, Germany)appeared before the Prime Minister and ParJ.iament ofLower Saxony as an International expert to testify on thesafety of a repcocessing plant at Gorleben, Germany

1978 International Atomic Energy Acency (Vienna, Austria)

presentation at Symposium on Late Effects of IonizingRadiation

1978 Associacion Ict Medicina y Seguridad en el Trabajo deUnesa para laL Industria Electrica (Madrid, Spain)presented one-day seminar entitled, " Primary Managementof Radiation Injury"

;

1977 International Atomic Energy Agency (Vienna, Austria)

presented paper, " Emergency Medical Assistance Programsfor Nuclear Power Reactors", at Symposium on Handling ofRadiation Accidents

1967 University of,Freiburg Institute of Radiobiology (Freiburg,Gemmany); presented seminar on diagnosis and treatment ofradiation injuries

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v - - - - - - ~ - , -- ~n < , . - - - - ,------,,,a _ 7, , ,_, , y_ , _ , , _ , . , ,

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SELECTED PUBLICATIONS- -.

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ROGER E. LINNEMANN

Linnemnn, Roger E. "The Acute Radiation Syndm:e and its Impact on theChain of Evacuation". hidcal Bulletin, U.S. AnTrf Euroce:22, No.12(Deceraber 1965)

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Linne: ann, Ibger E. and Riert T. Wangemnn. "Fbdical Support of NuclearWeapcns Accidents". Medical Bulletin, U.S. Amf Europe (Nove2er 1967)

Linnemnn, Roger E. and O. Messerschmidt. "Erhol:mpsvorgcenge beiGrosstieren nach Gan::koerperbestrahlung", :dem 6_, Jahrbuch von dervereinigung Daetscher Strahlenschutzaerzte (1968)

Linnemnn, Roger E. "Ctrmand Radiation Guidance". Military bbdicine:pp. 771-716 (Septe2er 1968)

-33,

Icken, Merle K. , Linnemnn, Roger E. and George S. Kush. " Evaluation ofRenal Function Using a Scintillation Camara and Caguter". Padiolocy: 9 3,,No.1, pp. 85-94 (July 1969)

Linnemnn, Roger E. , Icken, bhrle K. and Colin 11arkland. "CaputerizedCagartrental Renograms to Study Kidney Function". Journal of_ Urology: 103,pp. 533-537 (May 1970)

Linnemnn, Ibger E. and J.W. 'Ihiessen. "Pegional Approach to the Managementof Radiation Accidents". Journal of the Arerican Public Health Association:6_1_, No. 6, pp.1229-1235 (Jtm 1971)

Linnemnn, Roger E. and Robert H. Hobies. " Nuclear Accidents and TheirManage: Tent". Diergency Fbdical Care, pp. 281-292, Spitzer, Stanley andWilbur W. Oaks (eds.) New York: Brune and Stratton, Inc. (1971)

Linnemnn, Foger E. , Ras =tussen, N.C. and F.K. Pittman. Nuclear Enercy:Issues and Answers. Atcric Industrial Forum, Inc. in cooperation withPennsylvania Power & Light Cmpany (April 1973)

Linnemnn, Roger E. Nucleg Fadiation and Health. Springville, NYNuclear Fuel Services, Inc. (Septe:1ber 23, 1974)

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Linnerann, Poger E. and Wed A. Mettler, Jr. "D mrgency Medical AssistancePrograms for Nuclear Power Reactors". International Atomic Energy AgencySyntosiun on the Handling of Radiation Accidents, IAEA-SN1-215/22, ViennaAustria (1977)

Lin:ierann, Ibger E. "Why AIAPA?" Transactions of 1979 American NuclearSociety Conference, Atlanta, G7s (June 3-7,1979) , Vol. 32, TANS AO 32 1 832-

ISSN 0003-018x (1979)

Linne:rann, Roger E. , Hackbarth, C.J. and Ray Crandall. "Tne Contaminatedand Injured Patient". Proceedings of Twenty-fourth Annual Feeting of theHealth Physics Society, July 9-13, 1979 (Philadelphia, PA)

Linnemann, Poger E. "'Ihe Three Mile Island Incident in 1979: te Utility .

Pesponse". 'Ihe Medical Basis for Radiation Accident Precaredness, K.F. Hubnerand S.A. Fry (eds.) , Elsevier/ North-Holland, pp. 501-509 (1980) (

Linnerann, Roger E. " Initial Managemnt of Radiation Injuries". Tne KoreanAssociation for Radiatica Protection, Seoul, Korea (1980) - to be published -

LinnsTann, Roger E. "Fdcilities for Handling the Contaminated Patient".Radiation Accident Preparedness _: Fedical and Managerial Asoects, Science

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'Ihru-Media Company: New York (1980) -- to be published -

Linnemnn, Ibger E. "A Systems Approach to the Initial Management ofRadiation Injuries". gstems Approach to Emergency Medical Care, Appleton-Ccatury-Crofts: New York (1980) - to be published -

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TEDNICAL QUALIFICATIONS

RICHARD W. D GLEHARTSDiIOR DGLM DGINEER

DWIROtNDTIAL SERVICES DIVISICNFUS CORPORATION

My name is Richard W. Englehart. I am a Se.nior Executive Cbnsultant,Environmcntal Services Division, NUS Cbrporation at 4 Research Place, Rx:k-ville, Maryland 20850. I have held this title since October 1, 1980. Priorto this, at NUS I have held the titles:

Ececutive Engineer October 1, 1978Consulting Engineer October 1, 1976Principal Engineer October 1, 1974Staff Engincer January 1, 1974Senior Technical Engineer January 2, 1973

I am manager of the Radiological Programs Departnant at NUS, which in-cludes a professional staff of 15 and cn Environmental Radiological Laboratory.In addition to line manage'ent responsibilities, I have been principal investi-gator and manager of various projects including: environmental and safetylicensing services for a uranium mill; environmental and safety consultingfor the U.S. nuclear space program; and an Envisem sital Impact Statement forthe U.S. nuclear ship program. I have been responsible for the radiologicalaspects of several other projects including n update of the Nuclear Regula-tory (bmmission's " Table S-3", which quantifies the enviromntal effects ofthe nuclear fuel cycle, and several nuclear power plant licensing applica-tions. I have been responsible for individual consulting efforts for uraniumexploration, mining, and milling projects, rare earth metal processors, andothers.,

I gradlated frca the Carnegie Mellon University in 1960 with the degreeof Bachelor of Science in schnical Engineering. In 1963 I received a m sterof Science degrea in Nuclear Engineering; and in 1969 a Ibctor of Philosophydegree in Nuclear Engineering, both frcm the Pennsylvania State University.

Frcm 1960 to 1961 I was a Research Assistant at the Penn State NuclearResearch Reactor. In 1962 I obtained an Operator's License for the Reactor.

Frca 1961 to 1963 I held a National Science Ebundation Fellowship forgraduate study and continued on the staff of the reactor in the areas ofresearch and training.

Frcm 1964 to 1966 I served as a Cbanirsioned Officer in the UnitedStates Army, Corps of Engineers, assigned to the U.S. Atcmic Enextjy Otmnissionas a project engineer in support of the various military land based nuclearpower plants.

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Richard W. EnglehartPage ho

Frmt 1966 to 1968 I returned to the Pennsylvania State University toemplete work towards a PhD in Nuclear Engineering. During the time I helda U.S. AEC Fellowship.

From 1968 to 1972 I was an Assistant Professor in Nuclear Engineeringand Supervisor in charge of the University training and research reactor atthe University of Florida where I held a Senior Reactor Operator's License.I taught senior and graduate level courses in introductory reactor theory,radiation shielding, reactor engineering, heat and nass transfer in nuclearsystems, fast breeder reactor plant design, and reactor operations. Inaddition, the university reactor was disassembled and corqpletely rebuiltunder my direction.

During the period 1970-1972 I was a consultant to the Florida PowerCorporation dealing with the areas of environnental radiological nonitoring,nuclear system bid evaluations, nuclear system analyses and general environ-mental evaluations.

Ebr a one year period during 1971-72 I was on leave of absence from theUniversity as a recipient of an American Society for Engineering Education -Ebrd Ebundation Fellowship for Residency in Engineering Practice. I spentthis time at Gilbert Associates, Architect-Engineers in their Nuclear Engi-neering Department. 'Ihere, I was responsible for design and evaluation ofradiological effluent control systens for nuclear power plants, accidentanalyses, and site selection tasks.

Since 1973, I have been with NUS Corporation and involved in the activi-ties described earlier.

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I am the author and cc>-author of a number of papers on neutron physics,environmental radiological nonitoring, engineering education, and environ-mental aspects of the nuclear industry.

I am a member of the American Nuclear Society, the American Societ forEngineering Education, and Sigma Xi (Scientific Research Society). I am!

j currently serving on an Atomic L*x3ustrial Forum working group regarding radia-tion criteria.'

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BIOGRPPHICAL ' SKETCH - JOSEPH C. LEMAIRE

Joseph C. Lemaire is currently manager of Plant Component Behavior Analysis,

a materials research component within the Nuclear Engineering Division of

General Electric Company. He has been responsible for metallurgical failure

analysis and environmental qualification of plant structural materials, in-

cluding nuclear grade materials, at GE. Prior to joining General Electric in

1975, Mr. Lemaire was a nuclear propulsion metallurgist with the U.S. Energy

Research cnd Development Agency, where he supervised nuclear fuel development

activities. He holds a Bachelor of Science in Mechanical Engineering from

the University of Denver (1970), a Master of Science in Metallurgical Engineer-

ing from Massachusetts Institute of Technology (1971), and a Master of Business

Administration from Santa Clara University (1979). He is a member of the

American Society of Metals (ASM) and the American Nuclear Society (ANS),

and has published recent papers on the subject of corrosion technology at the

ASM Metals and Welding Conferences and in Corrosion.

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RESUME. .

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GRAYSON E. McNAIR

Q. Please state your full name and business address.

A. Grayson E. McNair, Two North Ninth Street, Allentown,

Pennsylvania 18101.

Q. By whom are you employed and in what capacity?

A. I am employed by pennsylvania Power & Light Company (PP&L).

as Vice President-Consumer and Community Services.

Q. What are your responsibilities as Vice President-Consumer

and Community Services?

A. I am responsible for the development and administration of

PP&L's conservation and load management programs, customer

services, rates, market resear ch, customer-relation

activities and economic and community development programs.

I am also responsible for research andd development of ways

the customer can more wisely use electric energy supple-I

mented by alternate energy sources.

Q. What is your educational background?

A. I received a BEE degree from the University of Virginia in

1962; completed the Power Systems Engineering course in .

Schenectady, New York in 1967; became a registered Pro-

fessional Engineer in the Commonwealth 'of Pennsylvania in.

1968; completed several post-graduate courses in electrical

engineering at Lehigh University; and was Visiting Lecturer

in Electrical Engineering for three years at Lehigh Univer-

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Q. How long have you been employed by PP&L and in what

capacities?

A. I joined PP&L in 1962 as Graduate Trainee followed by

assignment to Distribution Engineering in 1963 with

responsibilities for design of overhead and underground 12

kv facilities. In 1964 I was transferred to the Relay and-

Control Engineering group and became Project Engineer in

1966, representing PP&L on the Conemaugh Relay and Commun-

ications Task Force for designing protective relaying for

the 500 kv transmission lines. I was also Chairman of the.

Transient Stability Committee. In 1968, I transferred to.

the Interconnection Planning Section of the System Planning

Department as a Project Engineer. After being a Senior

Project Engineer, I was named Transmission and Distribution

Planning Engineer in 1971 with responsibilities for long-

and short-term planning of all electrical facilities

operating at less than 230 kv. In 1975, I became Assistant

Manager-Rates & Market Research. I assumed the position of

Manager-Conservation Services in 1978. On January 1, 1980,

I was appointed to my present position.

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RESUME.

OFWILLIAM F. HECHT

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Q. Will you please state your full name, business address, educational

and professional background, and employment bachgrcund. '

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A. Willi.a F. Hecht, Two North Ninth Street, Allentown, Pennsylvania..

I am employed by Pennsylvania Power and Light Company (PP&L) as

Manager - System Planning. In this position I am responsible for.

the planning of the electric supply system. Among my responsibilities

is the costing aspects of new generation. This includes all economic *

analysis of total and marginal system costs for generation additions

and retirements. Also my responsibilities include support of

licensing, ratemaking and other regulatory matters associated with

the economic and reliability benefits of Susquehanna to PP&L and

the PJM Interconnection. Also, I am responsible for analytical

work concerning bulk power contracts between PP&L and other utilities

and the power system analysis of load management applications...

e

I graduated from Lehigh University in 1964, with a Bachelor of

Science Degree in Electrical Engineering. I received a Master of

Science. Degree in Electrical Engineering from Lehigh University in

1970. From 1973 through 1975, I was a adjunct Professor in the

Electrical Engineering Department at Lehigh University. I am a

Registered Professional Engineer in the Commonwealth of Pennsylvania.

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I was employed by PP&L in 1964 as an Engineer in the System Plan-

I progressed to Project Engineer and later toning Department.ISenior Project Engineer in the System Planning Department.

became Executive Direc, tor of the Corporate Energy Planning Council

in August 1976, and was appcinted Manager - System Planning in May,s

1978.

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BIOGRAPHICAL DATA-

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PRESTON L. ROBERTS

EDUCATION:

B. S. 1969 Pennsylvania State University

Major in Physics, Minor in Mathematics.Studied in Aerospace Engineering curriculum for three years.

M. S. 1976 Villanova University

Electrical Engineering Program, specializing in AutomaticControl.

Emphasis on Digital Control utilizing MicroprogrammableProcessora.

PROFESSIONAL DATA:

Registered Professional EngineerMember: American Section of the International Solar Energy

Society, Inc.; American Wind Energy Association(AWEA) ; American Society of Heating, Refrigeratingand Air Conditioning Engineers; Association ofEnergy Engineers; Advance Conversion and StorageTask Force (EPRI) ; Utility Interface StandardsCommittee of AWEA; EPRI Passive Solar UtilityImpact Assessment Project.

Board Member: Lehigh Valley Manpower Solar UtilizationEconomic Development and Employment Program;Lehigh County Community College Solar CurriculumAdvisory Committee

EXPERIENCE:

1978 to Present - Manager-Research and Technical Services,,

Pennsylvania Power and Light Company'

I am Manager, Research and Technical Services forPennsylvania Power and Light Company, and am responsiblefor overall Company applications research into alternative

i and conventional energy technologies on both a residentiali

and commercial / industrial level.The thirty research projects my group is involved with

range from a study to characterize the operating costs andefficiencies of commercially available electric residentialspace heating systems to a demonstration of solar repowering

|' of an industrial steam process using high temperature t: acking

solar concentrating collectors.

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EXPERIENCE: (con' t)

1976 to 1978 - Applications Consultant, Consumer & CommunityServices, PP&L

I specialized in experimental HVAC design bothresidentially and commercially, electronic equipmentdesign and applications, solar and photovoltaic applications.Accomplishments included design of supplemental energy storagesystems and the first base load ice builder design concept forcooling of commercial buildings.

1974 to 1976 - Building Systems Engineer, General OfficeBuilding Operations, PP&L

Responsible for proper operation and design modificatiensto the electrical, mechanical and control systems in the G':neralOffice complex. I had direct supervisory responsibility f)rnine employees and coordination of work by outside contractorsperforming work in the General Office. I specified, andcoordinated the installation of the computer based monitoringand control system for the General Office complex. I was alsoresponsible for all technical training of Building Departmentemployees.

1972 to 1973 - Sales Engineer, Powers Regulator Company,Phila., PA.

In this position I was responsible for control systemapplications and sales. My responsibilities includedspecification writing and application assistance to consult-ing engineering firms, coordination of system installationsand customer training.

1969 to 1973 - Regional Automation Engineer, Powers RegulatorCompany,_Phila., PA.

In this position I was responsible for the design andapplication engineering of all centralized digitai control

i

J systems. The territory included all of the East Coast. I| also developed training programs for in-house use and customer

training. I was responsible for field installation coordination,'

purchasing of materials and start-up of systems.

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UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

BEFOPE THE ATOMIC SAFETY AND LICENSING BOARD

In the Matter of ))

PENNSYLVANIA POWER & LIGHT COMPANY ))

and ) Docket Nos. 50-387) 50-388

ALLEGHENY ELECTRIC COOPERATIVE, INC. ))

(Susquehanna Steam Electric Station, )Units 1 and 2) )

CERTIFICATE OF SERVICE

,

This is to certify that copies of the foregoing

" Applicants' Submittal on Testimony of Expert Witnesses" were

served by deposit in the U.S. Mail, First Class, postage prepaid,

this 25th day of August, 1981, to all those on the attached

Service List.,

| O,

Jay $ S lberg'

Dated: August 25, 1981

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UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

.

In the Matter of ))

PENNSYLVANIA POWER & LIGHT COMPANY ))

AND ) Docket Nos. 50-387) 50-388

ALLEGHENY ELECTRIC COOPERATIVU, INC. ))

(Susquehanna Steam Electric Station, )Units 1 and 2) )

SERVICE LIST

Secretary of the Commission Dr. Judith H. JohnsrudU. S. Nuclear Regulatory Commission Co-DirectorWashington, D C. 20555 Environmental Coalition on

Nuclear PowerAdministrati'e Judge James P. Gleason 433 Orlando Avenue513 Gilmoure Drive State College, Pennsylvania 16801Silver Spring, Maryland 20901

Susquehanna Environmental AdvocatesMr. Glenn O. Bright c/o Gerald Schultz, EsquireAtomic Safety and Licensing Port Office Box 1560

Board Panel Wilkes-Barre, Pennsylvania 18703U. S. Nuclear Regulatory CommissionWashington, D. C. 20555 Mr. Thomas J. Halligan, Correspondent

The Citizens Against Nuclear DangersDr. Paul W. Purdom Post Office Box 5245 Gulph Hills Foad Scranton, Pennsylvania 18501Radnor, Pennsylvania 19087

Ms. Colleen MarshAtomic Safety and Licensing Box 558 A, R. D. #4

Board Panel Mt. Top, Pennsylvania 18707U. S. Nuclear Regulatory CommissionWashington, D. C. 20555 Jessica h. Laverty, Esquire

Office of the Executive LegalDirector

U. S. Nuclear Regulatory CommissionWashington, D. C. 20555

.

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Robert W.-Adler, Esquire Mr. Thomas M. Gerusky, DirectorDepartment of Environmental Resources Bureau of Radiation ProtectionCommonwealth of Pennsylvania Department of Environmental505 Executj'' a House ResourcesPost Office Box 2357 Commonwealth of PennsylvaniaHarrisburg, Pennsylvania 17120 Post Office Box 2063

'

Janes II. Cutchin, IV, EsquireOffice of the Executive Legal Atomic Safety and Licensing Appeal

Director Board PanelU. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory CommissionWashington, D. C. 20555 Washington, D. C. 20555

DeWitt C. SmithDirectorPennsylvani.a Emergency Management AgencyTransporta ion and Safety BuildingHarrisburg, Pennsylvania 17120

.

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