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UNITED STATES OF AMERICA 9- SMR' ~~

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c'f IgNUCLEAR REGULATORY COMMISS'10N D

Bar. 5 /ATOMIC SAFETY AND LICENSING BOARD da.4 ,

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in the matter of: ) .'

)DUKE POWER COMPANY ) DOCKET NUMBERS

).(William B. McGuire Nuclear Station ) 50-369-OLUnits I and 2: - - reope'ned ) 50-370-OLoperating license proceeding) )-

))

INTERVENOR, CAROLINA ENVIRONMENTAL STUDY GROUP, HEREBY MAKES APPLICATION

FbRSUBPOENAS,PURSUANTTO10CFR52.720,andsays:.

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On February 24, 1981, in the course of tie opening day of hearingC

in this matter, Intervenor gave oral notice that it desired to have

subpoenas issued for witnesses necessary for the proper presentation of

its case. The Chairman of the Board sitting in said hearing has

required a showing, pursuant to 10 CFR 22 720(a) of the general"

' relevance of the testimony sought.

| TIntervenor appends hereto a list of proposed witnesses and

questions to be asked of them. Further, for those from which one.

'could be obtained, we append a curriculum vita. In so far as the|

|questions to be asked are not sufficiently revealing of the testimony

proffered,'a summary of the answers believed likely is attached,

in relation'to the Contentions admitted in this hearing. Intervenor

| believes that the testimony of the five academic psychologists, Messers

Cook, Palmer, Kello, Brockway and Long, is relevant to Contentions

1 and 2 concerning the ootential for hydrogen generation, in that .

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elements of the Job content of reactor operators, of all grades, are

likely to lead to poor performance under accident conditions. This

testimony will be in direct contradiction, we believe, to the testimonyi

given by the Appilcant's panel on operator training and work. Further,

this testimony will be relevant'to Contention 3 relating to emergency'

planning in that it make,s Applicant's reluctance to do proper planning

understandable.

The testimony of Louis Charles Barbe is relevant to Contentions

1 and 2 in that he can also testify about the human factors involved

in reactor operation and to safety factors. He is an engineer and.

has worked for Westinghouse in the nuclear division.

Joe Lanford is also an engsteer and is a former Duke Power employee

who worked at McGuire. He can testify on issues involved in ContentionsP

~

1 and 2 with regard to deficiencies in welding techniques on the

McGuire containment and Duke's reaction to his reporting these deficiencies.

Doctors Easton and Baker work at Charlotte Memorial Hospital, -,

the prime emergency facIIIty in the area. The former is head of radio-,

Llogy and the'1atter head of the emergency room. They can testify about

the ability to care for victims of a radioactive release from McGuire,

a matter raised in Contentions 3 and 4.

Intervenor reluctantly applies for a subpoena for Jan Beyea. Dr.

Beyea was identified as a potential witness in the cover letter to

the testimony of Jesse Riley, dated 2/17/81. "We anticipate having . . .

Dr. Jan Beyea regarding the.use of potassium iodide in a radiological

. emergency ." His testimony will be relevant to Contentions 3 and 4.. .

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Beyea had indicated a willingness to testify, but has since become |

reluctant to do so. A pubilcation is attached indicating his area,

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of expertise, he consequences of a radioactive release on the population.

Intervenor still intends to call Mr. Riley and Dr. Sternglass,'

and has distributed their testimony. ,

Beyond the relevance of testimony Intervenor has commented in

the course of the hearing on the reasons for subpoenas, lateness of

ifthe request and other factors that amount to excusable neglect,

neglect it be. Mr. Barbe came to the attention of Intervenor when he

answered an advertisement in Human Factors Magazine. A member of CESG

telephoned him after receiving his letter on 2/20/81. Thereafter,

Hr. Riley telephoned him on 2/21/81. He was unknown to the Intervenor*

prior to that time and thus there was no way to notify the parties.

Mr. Lanford called Mr. Riley after he read an article on the

His case ispending hearing in the Charlotte Observer on 2/22/81. ,

s'imilar to that of Mr. Barbe.

Although Intervenor knew it wanted some human factors witnesses,

it had none as of January, 1981. Its search accounts for the advertise-

ment mentioned above. Conversations with local psychology professors-

.

brought forth persons who had knowledge of the area in early February,..

but CESG's investigator-member had to leave Charlotte on business and

was unable to confirm the testimony of thesepeople. Another member

The same is true ofgathered the information submitted herewith.

the two doctors.

Based on the importance of the issues involved, the public's ,

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right to have all points of view adequately presented and the minimal.

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Impact on the parties ability to present their cases and cross examine,

Intervenor requests subpoenas for these witnesses. / Intervenor believes

that without subpoenas, they will not attend and testify.

.

Dated: 2/26/81. -

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Shelle/41um, atto y for Intervenor CESG854 Henley PlaceCharlotte NC 282C-

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Proposed witnesses for whom subpoena is requested'!

Janes Cook: Prof.of psychology at UNC-Charlotte ?

Edward L. Palmer: Prof. of psychology at Davidson.

John Edward Kello: Prof. of psychology at Davidson ,-

Prof, of psychology at UNC-CharlotteGar; Thomas Long: Prof. of psychology at Davidson'

John Philip Brockway:

Chief of Department of Radiology at Charlotte MemorialDr. Edward Easton:

Hospital '

Head of Emergency Treatment Department at CharlotteDr. John W. Baker: Memorial HospitalI

former Westinghouse nuclear division engineer' Louis Charles Barbe:

former Duke Power engineer at McGuire Nuclear StationJoe Lanford:scienti'ic advisor of National Audubon Society'Jan Beyea:

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LEWIS CHARLES BARBE {**

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6321 Limerick Lane (612) 941-6319 .

Edina, Mn. 55435 (-

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7CERTIFICATIONS:

C.S.P. Registration Number 1853 ( A.S.S.E.)P.E. Registration Number 717 Safety Engineering(State of California)P.E. Registration Number 435 Fire Protection Engineering(State of California)C.S.R.P. Registration Number 76-047

f EDUCATION:

Illinois Institute of Technology, B.S.,1954 (Fire Protection.

and Safety Engineering)University of Iowa (Industrial Hygiene) .

Penn State (Basic Principles of Property Control)American Management Association (Risk Management)Massachusetts Institute of Technology (Safety)Factory Insurance Association (Fire) National Safety Council Courses (Safety, Loss Control)U.S. Department of Labor (Safety)'

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f. EXPERIENCE: ;Occupational Safety & Heal th Services , Inc. , -

. Managing Director - EngineeringAmerican Hoist & Derrick, Corp. Director - Loss ControlWestinghouse Electric Corp. , Manager of Accident Prevention

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Stanray Corporation, Safety Engineer|

Loss Control Services Ltd., Risk Service Engineer|

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SOCIETIES:

Veterans of Safety InternationalAmerican and Canadian Societies of Safety EngineersNational Fire Prevention Association.American Society of Testing MaterialsAmerican Industrial Hygiene AssociationNational Society of Professional EngineersBritish Safety CouncilSystem Safety Society

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FLOUIS CHARLES BARBE b

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Direct Examination !

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How would you go about evaluating the safety of a givenoperation in a nuclear generating plant?

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Who would be qualified to make such a deter inat".on?Q.

How would his credentials be attained?Q.What document or set of standards would guide the safety -

Q. .

evaluation?What level of risk 'is assumed in meeting these standards?

Q.

Is fire a hacard in a nuclear plant control room?Q.

Q. Explain why.What extinguisher systems are used?Q.

What position has the NRC taken with regard to extinguisher*

Q. system specification?Who would be qualified to make judgnents'in regt<.d to

Q. the risk of fire?In regard to means for fire protection?Q.

How are such. credentials attained?Q.

What are the effects on control room personnel of theoperation of a fire extinguishing system?Q. ,

these personnelWhat provisions must be made to protectfrom ill eiffects due to carbon dioxide or Halon?Q. ,

of human mistakes in relation to theQ. What is the incidence 'ed for equipment by fault tree analysis?safety standards r(s

.-ence that is instructive in regardQ.' Is there any NELIA e. to human error and equipment failure?to safety matters, bot

Have fau.lt tree analyses been made in regard to the hydrogenQ. generation question at McGuire?

Are redundant safety systems present in regard to variousignition, mitigation systems?Q.hydrogen generation,

Has the maximum forseeable. loss been determined?Q.

Q. Should it have been?.

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Q. Has there been a control room fire?

Q. Describe what happened?

Q. What would prevent a similar occurrence in a like eventat McGuire? ,

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Q. Could a control room fire contribute to a hydrogen generationevent?

Q. What would .be the consequences of installing ra" pipe in-place of 1" pipe in the McGuire spray system?

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Q. What is the fire protection significance of having wiringand ductwork underneath spray heads?

Q. What do you see as essential qualities in reactor operators?

Q. In senior reactor operators?'

Q. How does this relate to navy training, i.e. nuclear submarineservice, as part of a reactor operator's prior experience?

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Q. How are you presently employed?

Q. Wnat employment,have you previously had?

Q. What is your academic background?

Q. Are you a member of any professional societies? --

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Dr. Edward EastonQ. Where are you employed? .'

In what capacity?Have you received any special training in the treatment of radiologic fQ.

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exposure cases?Where and when?Q.Do any other medical doctors in Charlotte have similar or equivilentQ.training to the best of your knowledge? Would ,you know if there werea doctor so trained?

Dr. Easton is Chief of the Department of Radiology at Charlotte Memorial~

He has received a course in the treatment of persons exposedHospital.to radiation a't Oak Ridge National Laboratory. He is the only physicianin Charlotte to have received such training and one of the few inNorth Carolina.

Dr. John W. BakerQ. Where are you employed?

In what capaci ty?Q.Q. Have you recived special training in the treatment of radiation exposurecases?

Is Charlotte Memorial Hospital one of the hospitals scheduled to receiveQ.patients in the event of radiation exposure resulting from an accidentat McGuire nuciear, station?Q. How many beds do you have in the emergency ward?

How many seriously exposed patients could you treat?Q.*

What special facilities do you have for treating radiation victims?Q.Q. Could you adequately treat 100 to 200 radiation patients?

Dr. Baker heads the Emergency Treatment Department at Charlotte MemorialHospital. He has not received special training in handling radiation

Memorial is a key hospital in McGuire emergency planning. Thecases.emergency ward has about 20 beds. Showers are available for decontamination. %

So are chelating agent procedures. A load of 100 to 200 cases wouldfar exceed the physical capabilities of the Memorial emergency ward.

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Questions to Jan Beyea\.\

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Q. What is your present position? ) s

Q. Wh5t is your prior expereince and background?

Q. In studying possible exposure of a population to radio-iodine, what

mitigatory measure would you recommend? Why? -

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Q. Have you studied the benefit of increas}ng containment strength?

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Q. What are the consequences of containment rupture?

Dr. Beyea has studied the health effects of exposure to radio-

Iodine. He finds that a population subject to exposure will be most

effectively protected by taking potassium iodide before exposure.4

For the currect generation of containments, the release in,

a severe accident is such as to create the inhabitation of 4000 square

miles of land untenable, in that a dose of 10 rem or greater would be

delivered to inhabitants over a 30 year period.~

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