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Reply Declaration of Arnold Gundersen in Support Of 1 MICHAEL J. STRUMWASSER (SBN 58413) BEVERLY GROSSMAN PALMER (SBN 234004) 2 RACHEL A. DEUTSCH (SBN 275826) STRUMWASSER & WOOCHER LLP 3 10940 Wilshire Boulevard, Suite 2000 Los Angeles, California 90024 4 Telephone: (310) 576-1233 Facsimile: (310) 319-0156 5 E-mail: [email protected] 6 HARVEY ROSENFIELD (SBN 123082) PAMELA PRESSLEY (SBN 180362) 7 LAURA ANTONINI (SBN 271658) CONSUMER WATCHDOG 8 2701 Ocean Park Boulevard, Suite 112 Santa Monica, California 90405 9 Telephone: (310) 392-0522 Facsimile; (310) 392-8874 10 E-mail: [email protected] 11 Attorneys for Physicians for Social Responsibility-Los Angeles, Southern California Federation of 12 Scientists, Committee to Bridge the Gap, and Consumer Watchdog 13 14 SUPERIOR COURT OF CALIFORNIA 15 COUNTY OF SACRAMENTO 16 ) Case No.: 34-2013-80001589 PHYSICIANS FOR SOCIAL ) 17 RESPONSIBILITY-LOS ANGELES, a non- ) REPLY DECLARATION OF ARNOLD profit corporation; SOUTHERN CALIFORNIA ) 18 FEDERATION OF SCIENTISTS, a non-profit ) GUNDERSEN IN SUPPORT OF corporation; COMMITTEE TO BRIDGE THE ) PETITIONER’S MOTION FOR 19 GAP, a non-profit corporation; and CONSUMER ) PRELIMINARY INJUNCTION WATCHDOG, a non-profit corporation ) 20 ) Petitioners, ) 21 v. ) ) 22 DEPARTMENT OF TOXIC SUBSTANCES ) CONTROL; DEPARTMENT OF PUBLIC ) 23 HEALTH; and DOES 1 to 100 ) ) 24 Respondents. ) ) 25 ) THE BOEING COMPANY, a corporation; ROES ) 26 1 to 100 ) ) 27 ) Real Party In Interest. ) 28 PRINTED ON RECYCLED PAPER REPLY DECLARATION OF GUNDERSEN ISO MOTION FOR PRELIMINARY INJUNCTION 1 I, Arnold Gundersen, declare and state as follows: 2 1. I make this Reply Declaration In Support of Petitioners: Physicians for Social 3 Responsibility – Los Angeles, Southern California Federation of Scientists, Committee to Bridge the 4 Gap, and Consumer Watchdog’s Motion for Preliminary Injunction. I have personal knowledge of the statements herein, and if called upon to do so, could and would testify competently thereto. My 5 Curriculum Vitae is attached as Exhibit A to my prior Declaration submitted in this matter. 6 2. I submit this Reply Declaration in part to respond to the attacks by Real Party in Interest 7 the Boeing Company (“Boeing”) on my qualifications to testify regarding the topics addressed in my 8 prior declaration and on the foundation for the opinions I expressed in that declaration. Boeing 9 misrepresents my educational and professional background as well as my qualifications to testify as 10 expert on matters related to decommissioning of nuclear sites and facilities. I also identify and discuss 11 the substantive errors in the testimony submitted by Boeing and by the Respondent Department of 12 Public Health (“DPH”). 13 3. As stated in my prior Declaration, I have more than forty years of professional 14 experience in the field of nuclear engineering and the decommissioning of nuclear sites. Throughout 15 that period, I have been professionally employed on matters related to the nuclear industry with a focus 16 on the regulatory and scientific framework governing safety at operating and decommissioned nuclear 17 facilities. I have a Master of Engineering degree in Nuclear Engineering (ME NE) from the Rensselaer 18 Polytechnic Institute. I was also licensed to serve as a Licensed Reactor Operator by the US Atomic 19 Energy Commission. During the past forty years, I have provided expert consulting services to private, state, and federal entities, testified before the Nuclear Regulatory Commission (NRC) and other state 20 and federal agencies, and served on state Commissions and Panels charged with the oversight or review 21 of nuclear decommissioning projects. 22 4. I worked for more than 10 years for Nuclear Energy Services, as a Senior Vice President 23 and as a member of the Radiation Safety Committee. The NRC licensed Nuclear Energy Services to 24 perform decommissioning services, and the NRC required that the Radiation Safety Committee oversee 25 all licensed activities. In the course of my work for Nuclear Energy Services, I oversaw teams of 26 workers conducting decommissioning of major nuclear sites, including the Shippingport nuclear power 27 plant in Pennsylvania. In this capacity, I was responsible for developing decommissioning plans, 28 writing and presenting decommissioning cost estimate testimony to various Public Service Commissions 1 REPLY DECLARATION OF GUNDERSEN ISO MOTION FOR PRELIMINARY INJUNCTION 1 and ensuring that all corporate decommissioning activities would protect public health and safety. I 2 regularly oversaw radiation monitoring and thus understand what methods and techniques are required 3 to accurately calculate the radioactivity in the context of a widely contaminated site. Also in this 4 capacity, I was an invited chapter author of the very first DOE Decommissioning Handbook, written in 1982. 5 5. I have had my testimony on nuclear safety issues accepted in both adjudicatory and 6 judicial proceedings. The following matters drawn from my curriculum vitae represent instances in 7 which I presented expert testimony in adversarial and administrative settings regarding nuclear 8 engineering, safety, and radiological contamination issues: 9 Blue Castle Holdings, State of Utah 7th District Court (September 2013) as an expert witness 10 on a proposed new nuclear power plant 11 12 Fermi 3 Nuclear Power Plant, Atomic Safety and Licensing Board (ASLB), U.S. Nuclear 13 Regulatory Commission (May 30, 2013) expert reports admitted 14 15 Canadian Nuclear Safety Commission Pickering Hearings (April 30, 2013) – written report 16 and oral testimony as an expert witness 17 18 San Onofre Nuclear Generating Station, Atomic Safety and Licensing Board, U.S. Nuclear 19 Regulatory Commission (January 2013) – written testimony as an expert witness 20 Indian Point Nuclear Power Plant, New York State Department of Environmental 21 Conservation (November 2011) – written and oral testimony as an expert witness 22 23 North Anna 3 Nuclear Power Plant, Atomic Safety and Licensing Board, U.S. Nuclear 24 Regulatory Commission (October 2010) – written testimony as an expert witness 25 26 Vogtle 3 and 4 Nuclear Power Plant, Atomic Safety and Licensing Board, U.S. Nuclear 27 Regulatory Commission (August 2010) – written testimony as an expert witness 28 2 REPLY DECLARATION OF GUNDERSEN ISO MOTION FOR PRELIMINARY INJUNCTION 1 Bellefonte Nuclear Power Plant, Atomic Safety and Licensing Board, U.S. Nuclear 2 Regulatory Commission (2009) written testimony as an expert witness 3 4 Pilgrim Nuclear Power Plant, Atomic Safety and Licensing Board, U.S. Nuclear Regulatory Commission, (April 2008) –written testimony and oral testimony as an expert witness 5 6 Vermont Yankee Nuclear Power Plant, State of Vermont Supreme Court, (March 2006) 7 written testimony as an expert witness 8 9 Vermont Yankee Nuclear Power Plant, State of Vermont Environmental Court, (April 2007) 10 written testimony and deposition as an expert witness 11 12 Indian Point Nuclear Power Plant, New York State Department of Environmental 13 Conservation (November 2011) – written and oral testimony as an expert witness subjected 14 to cross examination 15 16 Levy County 1 and 2 Nuclear Power Plant, Florida Public Service Commission, (September 17 2009) (Progress Energy questioned credentials under cross examination and in deposition, 18 testimony accepted by FL Public Service Commission) – written and oral testimony as an 19 expert witness 20 Vermont Yankee Nuclear Power Plant, State of Vermont Public Service Board, (2003-2004) 21 written and oral testimony as an expert witness; testimony admitted into evidence, twice 22 resulting in sanctions against the Defendant Entergy (parent corporation to Vermont Yankee) 23 24 Penn Central (NRC licensee Nuclear Energy Services), United States Nuclear Regulatory 25 Commission Inspector General 26 o Testimony led to two NRC Inspector General reports and two Congressional 27 Hearings about corruption within the Nuclear Regulatory Commission. 28 3 REPLY DECLARATION OF GUNDERSEN ISO MOTION FOR PRELIMINARY INJUNCTION 1 o Publicly recognized by NRC Chairman Ivan Selin, in May 1993, before U.S. Senate 2 Government Oversight Committee chaired by Senator John Glenn. 3 4 Three Mile Island Litigation (TMI) (1994-1997) – written and deposition testimony as an expert witness. 5 6 6. My expert testimony was accepted in every proceeding noted in my curriculum vitae, 7 except in the Finestone matter referenced by Boeing. In the Finestone personal injury tort litigation, I 8 was asked to perform a forensic analysis identifying the likely source of a specific release of radiation 9 that was alleged to have caused specific illnesses in two children. By contrast, the Boeing matter 10 involves questions whether a nuclear site is being decommissioned, and its nuclear wastes disposed, in 11 an appropriate manner. My testimony in the Finestone matter was thus categorically different from the 12 nature of testimony I now offer in the Boeing matter. 13 7. Boeing’s assertion that I have not been employed in the nuclear industry since 1990 is 14 factually incorrect. From 1990 to 2005, I provided nuclear safety consultation services to private, state, 15 and federal agencies under the auspices of my own company, Gundersen Management Analysts and 16 later Fairewinds. Since 2005, I have served as the Chief Engineer at Fairewinds Associates, Inc., a 17 company that provides expert nuclear consulting services to private, state, and federal entities regarding 18 the decommissioning of nuclear sites, among other
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