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'[ TNBEFORE THE ATOMIC SAFETY AND LICENSING BOARDc: 5',

In the Matter of: '( /. ,,

SOUTH CAROLINA ELECTRIC AND GAS ) Do 5N,50-39.5

COMPANY ) p. G ,

(Virgil C. Summer Nuclear Station, ) 0 +% ok (/ A,6;p

Unit 1) ) 3 ';r

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AFFIDAVIT OF DR. MICHIO KAKU /

-

My name is Dr. Michio Kaku. I am an associate professor of theoretical

physics at the City College of New York. I have read the "NRC staff

brief and statement of position concerning proferred testimony of Dr.

Michio Kaku en Contention 8" and " Applicants' motion to exclude testimony

of Dr. Kaku on Contention 8."

I would like in this affidavit to answer the criticisms mentioned above

and to point out the weaknesses in their arguments.

I will fi.st address the points made by Dr. Lawrence E. Hochreiter.

It is clear from the testimony submitted by Dr. Hochreiter that he largel,y

missed the point of my remarks. It is clear that he did not understand the

thrust of my arguments and instead concerned himself with largely irrelevant

points. Every scientist must attempt to grasp the basic laws of nature

within a certain set of assumptions and physical boundaries. And Dr.

Hochreiter quotes from standard, text-book arguments. But that misses the

point entirely: a matt.re scientist must always understand the limitations

to that knowledge and have a profound appreciation for the fact that there

are boundaries beyond which the known technology breakr down. There are D503g

large gaps in our understanding of nuclear accidents, and any nuclear

physicist or engineer must have a deep respect for the limitations of our

knowledge. Instead of being mesmerized by text book knowledge and computer

codes, we should instead realize that full scale testing of the ECCS has__

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never been done and that multiple failures can easily exhaust the capacity

of any computer on earth. Dr. Hochreiter, instead of possessing the spirit

of a scientist willing to explore the limits of his understanding and

knowledge, is content to bureaucertically quote from codes and regulations.

Unfortunately, the reactor at TMI jid not understand these codes and

regulations when it exceeded them by a considerable margin on March 28, 1979.

There is much thht is not known about reactor physics, and a nuclear

physicist should be the first one to admit this. For o.xample, apparently

Dr. Hochreiter does not understand the content of the American Physical

Society report on reactor safety (summer edition,1975) when it stated

flatly that two dimensional cen;puter codes modelling the interaction of

steam with ECCS water are a poor representation of the three dimensional,

i

problem, compounded with the vast uncertainties in steam binding.

The APS (which represents the largest organization of physicsts in the

United States, and probably the world) was very cautious in its verdict on

the ECCS, careful to mention that a three dimensional modelling of the

thermal hydraulics of reactors is an incredibly difficult problem and

. the reliability of two- dimensional computer codes must be questioned.|

It is perhaps self-serving that Westinghouse does not share the attittude

of the APS panel when it states that their computer codes are sufficient|

to handle a large break ' 0CA.

As a result, most of Dr. Hochreiter's comments are largely irrelevant,

rehashing well-known aspects cf reactor physics while missing the entire

point of my testimony. Specifically:

Sec.1, para 2.

Dr. Hochreiter correctly mentions that the NRC permits the corc of

a reactor to rise up to 2200 F in case of a large break LOCA (peak clad

temperature) and that there are margins of safety built into Appendix K

of ICCFR50. All this is ture. But all this .nisses the point and is irrelevant.

- - - - -- . . . - _ - _ . - .__

. . - _.

. o,

.

UThe point is that 2200 F is already beyond the oxidation point of zirconium

and is dangerously close to the autocatalytic point of zirconium. It is

Ulargely irrelevant when Dr. Hochreiter points out that 2200 F is a maximum

peak clad temperature for maximum power rating. Those temperature limits

are simply too high, because they already allow for the generation of

the hydorgen gas bubble (for which the physics and chemistry was cumpletely

misunde stood during the accident at TMI, especially by the NRC Chairman)

and because the metal-water reaction is close to feeding on itself when

it reaches the autocatalytic point. The slightest failure in a crucial

component of the reactor may compound the sequence of failures to push

the temperatures slightly higher, past the autocatalytic point, at which

stage the reaction will go out of control.

Furthemore, the " margins of safety" built-into the Appendix K

calculations are no reason to be confident of the reactor's perfomance

under large break LOCA conditions. Three Mile Island and Brown's Ferry

exceeded by a considerable amount the safety margins supposedly built-into

our reactors. Arguing at length about the safety inherent in " margins of

safety" is futile when we realize that many previous accidents have

exceeded byconsiderable amounts the government's margins of safety.

Next, Dr. Hochreiter again misses the point when he says that a

; leaking FORY will only contribute a miniscule amount to a large break LOCA.

Of covese. That goes without saying. No one ever said othe: vise.

The point that Dr. Mcchreiter misses is that multiple failures can

push a Class 8 design basis accident into a Class 9 accident, even when

the multiple failures, taken separately, are of no safety consequence.

Reactors are highly non-linear mechanisms whose possible couplings easily

exhaust the capabilities of any computer on earth. Failures in one system

can trigger failures in other systems in a non-trivial way, beyond the

foresight of any computer programmer. Class 8 accidents can conceivably

- -- . - . .

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be pushed into a Class 9 accident for entirely trivial reasons which,

taken separately, are negligible. We know this to be true because it

actually happened at Three Mile Island.

Dr. Hochreiter duagrees with my statement that many of the

results of Chapttr 15 of the FSAR are based on speculation. I disagree.

Since no one has ever conducted a genuine large break full-scale LOCA

analysis of the ECCS, by definition all computer codes in Chapter 15

are a matter of speculation. Some computer ccdes are better than others.

But all are matters of speculation. We can speculate by computers or we

can speculate by tracing out various imaginary failure sequences. But

they are all matters of speculation until the acid tests are performed.

Unfortunately, we have never conducted such tests, even though

scores of physicists in the past have faulted tne AEC on this point.

For example, Dr. Carroll L. Wilson, first general manager of the AEC,

has said, "One of the grievous errors of the AEC in the 1960's was

the failure to carry out the repeatedly recceended experiment of runninge

a reactor to destruction (LOCA) to find out what would really happen

instead of depending on studies based on computer modesl for such vital

infonnation." (Bulletin of Atomic Scientists, June 1979, p.16).

Unfortunately, this defect of the 1960's remains the defect of the

70's and 80's. Some computer codes show that the ECCS system will work.

Other computer codes, as it was revealed during the acrimonious and ofter.

bitter ECCS hearings of the early 1970's, failed. But the point is that

both are matters of sheer speculation.

para Se

Dr. Hochceiter apparently does not understand the severe limitations

of the LOFT tests. Critics have said that the LOFT tests, historically,

have always been the retarded child of the AEC and the NRC, always an

embarrassment to the nuclear reactor safety program, always lagging behind schedule.

,

. .

.

It has taken over a decade to get this ill-conceived program to work.

Underfunded, constantly downgraded in scope and size, poorly managed,

and largely forgotten by AEC public relations people, the LOFT program

only shows that a LOFT-sized reactor can probably handle a well-orchestrated

LOCA. Unfortunately, the laws of physics (excluding conformal transformations)

are not scale invariant. In fact, many crucial parameters do not transform

linearly under scale transformations. Of the hundreds of parameters to be

measured in such a test, many of them vary at different rates and in

inherently non-linear fashion. LOFT has not put to rest the uneasiness

that some scientists have over the ECCS's reliability; indeed, the modest

scale and woefully delayed timetable of the LOFT tests only call attention

to its irrelevance to the controversy: too little too late.

para Sh .

Again, Dr. Hochreiter misses the point. He states correctly that

Appendix X requires that water be dumped onto the core faster than water

can be swept out of a lar;e break during blowdown. But intentions and.

reality are two different things. Since no one has ever tested the ECCS,

it is a matter of speculation whether or not Appendix K can be met.

The point was not to cnallenge Appendix X on this point. The point was

to show that perhaps nuclear reactors are in violation'of Appendix K,

but we probably will never know until a Class 9 accident happens aoain.

page 8, item b

Dr. Hochreiter is aware that the British questioned the integrity,

of reactor vessels t3 the point that they would not buy Westinghouse

reactors. And I am aware of the fact that the British Nuclear Installation

Inspectorate later fcund the Westinghouse PWR vessels to be licensable in

England. But these are largely irrelevant points.|

The main point was 'o show that the integrity of vessels has never

been fully analyzed and areas of doubt exist as to whether or i.ot spontaneous

Ir

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vessel rupture is credible or not. Since the ECCS system cannot contain

a meltdown in the event of a spontaneous vessel rupture accident, this

is not an academic point. Unfortunately, the theory of cracks, of " creep"

in carbon steel vessels, of the effects of neutron irradiation, the stresses

caused by rapid cold / hot temperature changes, etc. are not understood very

well. This point is unde-scored by the NRC's own recent statements concerning

th e integrity of reactor vessels around the country issued in the last

month. The recent accidar+ (Oct. 1980) at Indian Point 2, where there was

a 550 F temperature differential on the reactor vessel, pcints to plausible

scenarios where stresses can be placed on reactor vessels which may

undergo " brittle fracture." This is not a settled question, since the

state of our understanding of the growth of cracks in irradiated steen,

under large temperature differentials during accidents, is not well

developed.

para 7

Dr. Hochreiter correctly points out that post-mortem analyses of

the TMI accident show that, under many varying circumstances, the maximum

temperatures wdUld not have exceeded the melting point of uranium dioxide.

But this is beside the point. Major computer calculations (e.g. TMIBOIL,

BOIL) show that within 30-60 minutes, a substantial portion ef the fuel

in the core certainly would have melted if the PORV was left open after

6:00 am on March 28, 1979. Once again, computer codes can be conflicting,

depending on the initial conditions and the validity of the ansatz used.

But the point was never to debate the finer points of computer codes.

The point is that most scientists believe the NRC's own verdict that

we came perilously close to fuel melting at TMI if the PORV were left open

for 30-60 minutes more. Since it only takes roughly ar. hour for an exposed

core to reach the melting point of uranium dioxide, the main point is clear;

TMI was a close call.

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. .

.

The point is that, even with the PORV closed on time, 90% of the fuel

rods suffered some cladding failure and, as one engineer pointed out, the

core at TMI resembles "a bowl of granola." About 50% of the zirconium

oxidized, violating Appendix K by a considerable margin, and enough

hydrogen gas was generated to create a 28 psi pressure peak inside the

containment. So even with the PORV closed, the TMI accident exceeded the

expectations of all computer codes and CFR regulations.

para 8 and 9

Dr. Hochreiter feels that after TMI we learned many valuable safety

lessons. That is undeniable. But is that eaough? Nature has its own codes

and laws independent of NRC's NUREG's. I would like to believe that TMI

was the first and last major Class 9 accident in the history of commercial

nuclear power. , UnfortunFely, the accidents at Oyster Creek, Crystal

River, and Indian Point 2 after TMI are noi. encouraging for the industry.

I agree with Dr. Hochreiter that " industry has responded" after TMI.

My only question is that that may not be enough.

para 11

Dr. Hochreiter correctly poid s out that NRC regulations changed

! after the bitter ECCS hearings (which were supposed to last 2 weeks, but

wound up lasting an incredible 2 years). But that is one-sided.

He misses the point of the ECCS hearings, which showed deception

and embarrassing scientific gaps in our understanding of ECCS performance.

Moreover, the point is that there are many areas which are g;11 not

reflected in Appendix K as a result of the ECCS hearings (e.g. full-scale

testing, steam binding effects in blowdowns, three dimensional two phase

flow analysis). The hearings are important not for what reforms were made

on safety systems, but for what reforms were neglected or overlooked.

|

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para 12

Dr. Hochreiter tries to make a vice into a virtue. I pointed out that,

25 years irito the nuclear age, we still have " unresolved safety problems"

(e.g. ATWS, water hammers, missiles, etc.), which does not reflect well

on the nuclear safety program. But Dr. Hcchreiter states that the very

existence of these unresolved safety problems means that the NRC is

fulfilling its " role as the industry regulator." I don't think the FAA

would pride itself as "fulfiling the role of industry regulator" if they

classified defective pylons on the wings of DC-10's as simply " unresolved

safety problems." Having your engines fall off your wings when in flight

' not be taken lightly by simply brushing it under the rug-by callings.

it an " unresolved safety problem."

Dr. Hochreiter confuses the train point concerning LOFTRAN codes

and FLECHT. The point was never that one is part of Appendix K and the

other is not. The point is that Appendix K requires the ECCS of reactors

to take intos consideration stearii interactions with ECCS water, but the

WCAP programs of Westinghouse do not adequately analyze these interactions.

Th e American Physical Society report (sumer 1975) on reactor safety

clearly points out two main deficiency in all computer codes for blowdowns;

st eam binding and two dimensional analyses.

The WCAP programs apparently have not taken the warning of the'

APS seriously. Steam binding may seriously impair the transport of

cooling water to the vessel and cause temper 0tures to rise dangerously.

But the theory of steam binding is rot well-understood. Westinghouse is

( being self-serving when it says that "with regard to steam binding, we

ao not regard it as a uncharted area of tnermal hydraulics since it only

concerns calculations of heat transfer .in the steam generator and pressure

drops in the reactor coolant loop." The APS canel on reactor safety

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thought otherwise and gave a clear warning to the industry that steam

binding may invalidate much of the confidence we have in the ECCS.

Furthermore, two dimensional analyses of ECCS modelling was also criticized

for being inadequate. Solving differential equations in multi-variables

with complex boundary conditions is crucially dependent on the number of spatial

dimensions. If this were not true, then all physics would be trivial.

NUREG-0717 (SER) :tates that "We will require that the applicant comply

with any changes to WCAP Reports 7907 and 9230 that result from completion

of the staff review of these reports."(p. 15-10) "If the final approval

of the methods indicates revisions to the analyses are required, the

applicant will be required to implement the results of such changes."

(p.15-5). Because the Virgil C. Summer plant depends crucially on

the WCAP programs, and because Appendix K requires that the analyses of

the ECCS must take into account the interaction of s team with

ECCS water, a strong case can be made that the plant is in violation

of Appendix K and that approval of these codes be withdrawn.

The rest of Dr. Hochreiter's affidavit dwells on interesting but again

largely irrelevant points. Small, largely irrelevant issues are cons tantly

confused with the large question of understanding the limits of reactor

physics. For example:

Dr. Hochreiter tries to make, once again, a vice into a virtue by

saying that full-scale ECCS tests are not necessary because individuali

components can always be tested to much greater endurances separately.

This is true, but also irrelevant. When testing cars, autcmotive engineers

do not take a lemon and decide that it is safe after pushing the seat belts,

to their maximum endurance. And neither should physicists have confidence in

nuclear reactors if only isolated components are tested under well-orchestrated

conditions. Scientists must take the untire systra to test how subsystems

are integrated and car affect one another. Boasting about the successes

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of individual, isolated subsystems is like saying that the operation was

a success but the patient died.

Quite frankly, what is the industry afraid of? If reactors are so

safe, then why the tremendous hesitation in conducting full-scale ECCS

tests?

Other issues that Dr. Hochreiter/ggsMso largely tangential:

knowing the exact melting paint of metallic uranium is not important.

What is important is realizing that metallic fuel has safety problems

(e.g. metal-water and metal-air reactions) which make it less suitable

for comercial use, in addition to melting. points.

Specific measures used for reactivity control (e.g. burnable poisons)

are only minor details; the important issue involved is how poisons can

regulate variations in the neutron population over time because of their

larger neutron capture cross-sections.

In my testimony, I said that I was not an expert on themal hydraulics.

However, the specific details of the transition in a blowdown

from nucleate boiling to film boiling, though interesting, is not necessarily essential

for a discussion of meltdowns. For example, the intricacies of DNBi

ratios are largely irrelevant in a situation, like at TMI, where the main .

HPI was shut off for long periods of time and the ECCS played no major role

in the first few hours of the accident.

The bulk of my testimony concerns not the thermodynamic considerations

in keeping the core cooled, but in scenarios in which cooling has not occurred.,

,

i The dispersion of radionuclides in the atmosphere and the subsequent

health and safety considerations form the heart of my testimony. Mention of

,

the Three Mile Island &ccident,and the controversy surrounding the ECCS|

were added to show that a plausible, reasonable case can be mace for'

initiating events which precipitate a Class 9 accident.

The scenario I gave in my testimony is not an unsubstantiated,

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a priori sequence of events, but in fact a PWR3, which falls well within the

definitions accepted by the NRC itself.

Notice that Dr. Hochreiter says not one word about the effects of

the dispersion of radionuclides into the atmosphere after a breachment

of containment. We may disrute at length the finer points of steam binding,I

but once the radionuclides escape from the containment (e.g. in a PWR3),

all the atmospheric modelling required to calculate the dispersion of

cesium-137, iodine-131, and strontium-90 in the atmosphere are in rough

agreement.

Unfortunately, the issue of thermal hydraulics is a minor issue

compared to Contention 8. The testimony given by the men and women in

charge r5 the evacuation program within the 10 mile limit certainly

does not inspire confidence. I must admit that I was taken aback when,

time and again, people with barely high school education would hetray

enormous ignorance about the simplest basics of a meltdown. It is

ironic that while we may debate the finer points of the state-of-the-srt

o accidents,technology with regard to computer simulations of Class

not one person could give a description, even the most rudimentary,

of a meltdcwn. In perhaps the greatest euphemism of the trial, Mr.

Steven C. Goldberg refers to these glaring lapses in basic understanding

by sayidg" Key state and local emergency planning officials displaed

varying degrees of familiarity with risk of accidents." It is matter

of record that one of the chief men in charge of evacuation was totally

unfamiliar with the PWR classification of Class 9 accidents, had never even

seen the chart before explaining fission product inventory release, and

admitted under oath that, in case of a PWR1 meltdown, there was nothing

left to do but " sit back and pray."

Given this state of ignorance and complacency, we must seriously

question whether or not local and state officials will be able to recognize

a meltdown when it actually happens.___ _ __ _ .__ _ _

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.

Furthermore, testimony concerning the inspection of welds was very

revealing during the proceedings. Once a gain, under oath officials admitted

that only 1% of the welds in question were actually inspected. The Nielsen

ratings are often criticized formaking all-powerful judgements on the

ttsis of deficient sampling techniques. Apparently, the inspection of

welds in nuclear power plants have the reliability of the Nielsen ratings.

Such poor methodology should not go unnoticed.

In closing, I would like to make a few specific comments to

answer the criticisms mentioned by Mr. Goldberg and Mr. Knctts.

1) Mr. Goldberg's main point is that my testimony challenges the 10

mile limit, which is not subject to debate in these hearings. On the

contrary, the PWR3 scenario that I have given in my testimony has been

amended to only include those factors and circumstances which apply

within the 10 mile limit. Of course, radionuclides may still be blown

considerably beyond the 10 mile limit, but for the ourpose of these

hearings it is a simple matter to amend ray testimony so that the

effects of a PWR3 on evacuation plans within the 10 mile limit is the

subject of main concern. Mr. Goldberg is incorrect when he says that

my testimony only challenges the 10 mile limit; the bulk of my testimony!

remains the same.;

l

2) Mr. Goldberg is surprised that my scenario does not declare a

general en.ergency until 50% of the core has melted. This is not beyond

reason, and only shows Mr. Goldber's lack of familiarity with meltdown

sequences. According to the APS report, WASH 1400, and every other major

study on meltdowns, the core can reach melting within an hour and a second

hour is required before the uranium dioxide begins to melt its way throughl

the 8 inch steel vessel. Given the fact that the core at TMI was within

30-60 minutes of a significant core melting incident, and given the lateness

. __. ..

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of the operators in calling for an emergency, it is entirely within precedent

to have a general emergency declared a few hours into the accident (at which

time considerable core degradation will have already begun).

3) Mr. Goldberg challenges the scenario and says that "there is just

no way that this " scenario" or anything like it could yield a meaningful

test of the emergency plans." Once again, this only shows Mr. Goldberg's

lack of familiarity with meltdown sequences, because the scenario given

in my testimony is a standard one, given in other references and other

studies. The point is not that this scenario is not applicable to the

question of emergency plans; the point is that Mr. Goldberg apparently

does not realize that scenarios like mine have been studied for the

last 25 years to yield information concerning the effectiveness of

ev,acuation plans._

4) Mr. Goldberg cites favorably from the results of the May 1,1981

ex ,ercise required under 10 CFR50.47(c). He claims that this exercise

shows that the evacuation plans are adequate. On the contrary, the

May 1,1981 exercise showed the opposite. The testimoniesof the

men and women responsible for emergency evacuation showed their glaring

lack of knowledge of a meltdown, whici. _.: owed up quite clearly in their

description of a meldown's effects on evacuation procedures. Specifically:

a) they refused to answer direct questions concerning the nature of

a major fission product release, always deferring to their superiors,

b) they showed lack of understanding of how a fission product release

would affect the health and safety of the people within the 10 mile limit.'

c) their education level was often just high school or junior college,

and slmost none of them had ever taken courses in how meltdowns occur and

how radiona:' ides are disper:ed-

d) they were unfamiliar with the PWRl-9 classification and with the

amount of fission product release in each category. Conducting an

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exercise without knowledge of the scope, extent, and effects of widespread

radionuclide contamination reflects poorly on the emergency evacuation

program and casts doubt on the effectiveness, if any , of the exercise,

e) they had an incorrect understanding of the comparison of the

fission product release from a nuclear weapon versus a nuclear meltdown

f) they were unfamiliar with the biological implications of contamination

by iodine-131, cesium-137, and strontium-9C

g) they were unfamiliar with the basic, rudimentary procedures in

decontaminating victims and recognizing the extent of their exposure

1) they were unprepared for a breakdown in the emergency plans.

As long as their evacuation plans work according to the text. book,

they felt confident. But when asked about breakdowns in these plans, their

responses were vague, evasive, and inccmplete.

5) Mr. Goldberg claims that my testimony only refers to nuclear power

plants generically, and not specifically to the V.C. Summer plant.

This it not correct.First, there have been specific allegations of

faulty welds at the site and other defects in tile construction of the

plant by workers. Mr. Goldberg responds by saying that the NRC looked into

the question of these welds add other allegations. But, like before,

it must be pointed out that only 1% cf the welds in question were actually

inspected, which is not a representative sample of the welds.

Second, the WCAP Westinghouse computer programs are subject to NRC approval,

according to~the SER, and the WCAP programs do not take into account

three dimetuional effects, nor do they adequately treat the question of

steam binding, as mentioned in the APS report of 1975.

Third, the evacuation personnel are woefully inadquate, by their own admission,

to handle a Class 9. They would have difficulty understanding how to cope

with a Class 9 accident when, under oath, they had difficulty even identifyingI

_ _ _ _ _______ _ ______ _ _ _ _ _ _

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what a Class 9 accident is.

Fourth, a meltdown at the V.C. Summer site would have characteristics similar to

those studied in the past 25 years in WASH 740, WASH '400, the APS report,

etc. To the extent that the geography, meteorology, and topography of the

site are not qualitatively different from, typical sites studied in these

reports, we may with certain confidence use their analyses. Reading the

information in the~ ESAR ar.d SER concerning the site, it is apparent to me

that there are no particular reasons for invalidating the generic studies

that have been done in the past concerning meltdowns and dispersion of

radionuclides in the enviornment.

Mr. Goldberg takes issue with WASH-740 because this early document

does not take into account emergency evacuation. This is true, but beside

the point, because the purpose of mentioning WASH-740 is to get . background

information concerning the scope and magnitude of Class 9 accidents.

Mr. Goldberg dismisses WASH-1400 because it has no regulatory status.

Ho wever, WASH-1400 is the very foundation o which the FSAR and SER

are based. The FSAR and SER mention at length the calculations of

probabilities and sequences mentioned in WASH-1400 and use them as the

prircipal guide to formulating an analysis of Class 9 cccidents.

Similar statements apply to the motion subm.itted by the applicant,

represented by Mr. Knotts. Again, he cites the question of the challenge

to the 10 mile limit, which is now irrelevant, and the question of

whether or not my testimony app 1 Ls specifically to the V.C. Summer plant.,

1

Again, he repeatedly states that my testimony challenges re'julations rather

than staying vithin the confines of Contention 8. Mr. Knotts states thati

the scenario given in my testimony, based on a typical PWR3, "is not relevant

to the contention and may be a challenge to the regulations." On the contrary,

this does nct constitute a challenge to the regulations because we are

;

I

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.

staying within the 10 mile limit and because it was used to give a description

of how the emergency and evacuation personnel can cope with a Class 9

accident. The PWR3 scenario is crucially relevant because it serves as the

framework by which we can test the adequacy of emergency planning.

It is absurd to test a system designed to handle an emergency without

being able to describe the emergency itself.

In summary, I wish to emphasize that on June 1980 the NRC, in a

statement of interim policy regarding accident considerations under

NEPA, altered its previous policy of not consieering the effects of Class 9

accidents in NRC environmental impast statements prepared in connection

with construction permits and operating license applications. These

hearings have historic implications because this plant is the first to

be considered under this new ruling on Class 9 accidents. What happens

during these hearings will determine the precedent for later hearings,

or may be challenged on the basis of mistrial if they are not properly

conducted. The irony of these hearinas is that, even though Class 9

accidents are the very reason for our coming together in the first place,

no one fnometbe otility has been qualified to speak on Class 9 accidents,

and now the utility seeks to prevent someone from the intervenor's

case to testify on the nature of Class 9 accidents. This seems to form

j the basis of a mistrial if hearings on Class 9 accidents can take place

without people qualified to talk about them in the firLt place.

As a nuclear physicist, I feel that there are substantial scientific

criticisms that can be made concerning the adequacy of the FSAR and SER

to analyze Class 9 accidents and, as a result, whether or not the

emergency and evacuation personnel are qualified to carry out a massive

evacuation within the 10 mile limit in a Class 9 accident.

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I apologize for the lateness of this response, but I must say in

my defense that (a) I have never seen the court transcripts of my own

testimony and (b) I was only given one week to make a response, given the

lateness of my receiving the responses from Mr. Knotts and Mr. Goldberg.

Respectfully ubmitted,,

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Dr. Michio KakuAssociate Professor of Physics

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