ML021340293

Amended Petition for Leave to Intervene and Request a Hearing

ML021340293
Person / Time
Site:	Indian Point
Issue date:	04/30/2002
From:	Coplan K Pace Environmental Litigation Clinic, Riverkeeper
To:	Bollwerk G Atomic Safety and Licensing Board Panel
Byrdsong A
References
+adjud/rulemjr200506, 50-247-OLA, ASLBP 02-798-01-OLA, RAS 4415
Download: ML021340293 (41)

Text

PACE ENVIRONMENTAL LITIGATION CLINIC, INC.

PACE UNIVERSITY SCHOOL OF LAW SUPERVISING ATTORNEYS 78 NORTH BROADWAY ADN4STRATOR KARL S. COPLAN WHT PLAINS, N.Y. 10603 MARY BETH POSTMAN ROBERT F KENNEDY, JR.

914-422-4343 FAX: 914-422-4437 DOCKETED USNRC May 10, 2002 (3:31PM)

OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF April 30, 2002 G. Paul Bollwerk, III Chief Administrative Judge Atomic Licensing and Safety Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Re:

In the Matter of ENTERGY COPORATION (Indian Point Nuclear Generating Unit No. 2; Facility Operating License DPR-26) Docket No. 50-247

Dear Judge Bollwerk:

Riverkeeper, Inc. submitted its Section 2.714 Petition For Leave to Intervene and Request a Hearing on March 18, 2002. Under the Nuclear Regulatory Commission's regulations in 10 C.F.R. § 2.714, any person who has filed an intervention petition has the right to amend such petition at any time up to fifteen days prior to the holding of a special prehearing or initial prehearing conference. See 10 C.F.R. § 2.714(a)(3). Pursuant to this provision Riverkeeper hereby submits its amended petition accompanied by attachments A-D and a certificate of service.

Enclosures

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All parties

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

) )

ENTERGY CORPORATION

)

(Indian Point Nuclear Generating

)

Docket No. 50-247 Unit No. 2; Facility Operating License

)

0 DPR-26)

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RIVERKEEPER, INC.

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DOCKETED USNRC May 10, 2002 (3:31PM)

FFICE OF SECRETARY RULEMAKINGS AND LDJUDICATIONS STAFF AMENDED PETITION FOR LEAVE TO INTERVENE AND REQUEST A HEARING I.

INTRODUCTION Pursuant to 10 C.F.R. § 2.714(a)(3), Riverkeeper, Inc. (hereinafter "Petitioner")

hereby amends its petition for leave to intervene and request a hearing. For the reasons set forth below, Petitioner's petition for intervention and request for a hearing should be granted.

IL BACKGROUND On July 13, 2001, the Consolidated Edison Company of New York, Inc.

("ConEd"), the former licensee of Indian Point Nuclear Generating Facility, Unit No. 2

("IP2"), sought leave for a one-time, five-year extension of the containment leak integrate rate test. 66 Fed. Reg. 44,161 (2002). The requested one-time revision to Technical Specification Surveillance Requirement 4.4.A.3 would extend the mandatory ten-year frequency for the containment integrate leak rate test, allowing five more years to pass until the next leak rate test on the containment dome at IP2 must be performed.

In

response to this request, NRC, on August 22, 2001, issued a proposed "no significant hazards consideration" finding.

On March 18, 2002, Petitioner filed a petition for leave to intervene and request a hearing.

In its initial petition, Petitioner challenged the adequacy of Consolidated Edison's application and its failure to provide an adequate basis to determine no significant hazards exist.

Responses to this petition were filed by Entergy Nuclear Operations, Inc. on April 4, 2002 and the by NRC staff on April 16, 2002. Pursuant to 2.714(a)(3) and in view of the responses, Petitioner hereby amends its March 18, 2002 Petition For Leave to Intervene and Request For a Hearing.

III.

LEGAL STANDARDS FOR FILING AN AMENDED PETITION Under the Commission's regulations in 10 C.F.R. § 2.714(a)(3), Petitioner has the right to amend its intervention petition any time up to fifteen days prior to the holding of the special prehearing conference, or where no special prehearing conference is held, fifteen days prior to the holding of the first prehearing conference.

10 C.F.R. § 2.714(a)(3). Because the Atomic Safety and Licensing Board has not yet decided to hold either a special prehearing or initial prehearing conference, "[p1etitioner may amend its intervention petition to address any shortcomings, or other matters, in its initial petition."

Tennessee Valley Authority (Sequoyah Nuclear Plant, Units 1 & 2; Watts Bar Nuclear Plant, Unit 1), 2002 NRC Lexis 27 (February 7, 2002).

IV.

PETITIONER SATISFIES LATE-FILING STANDARDS Petitioner satisfies the requisite factors for non-timely filings, set forth in 10 C.F.R. § 2.714(a)(1). The five factors to be balanced are:

(i) Good cause, if any, for failure to file on time; 2

(ii) The availability of other means whereby the petitioner's interest will be protected; (iii) The extent to which the petitioner's participation may reasonably be expected to assist in developing a sound record; (iv) The extent to which the petitioner's interest will be represented by existing parties; (v) The extent to which the petitioner's participation will broaden the issues or delay the proceeding.

10 C.F.R. § 21714(a)(1)(i)-(v). Petitioner fully addresses each of the five lateness factors and demonstrates that based upon a balancing of the factors its amended petition for leave to intervene and request for a hearing should be granted.

A.

Petitioner Has Good Cause for Failure to File on Time Petitioner has good cause for filing a petition for leave to intervene and request a hearing. At the time NRC issued its proposed determination of Consolidated Edison's application, the Federal Register Notice did not disclose the rusted areas in the steel lining of the dome. In fact, the presence of rust in the dome did not become public knowledge until February 2002. A search on the NRC website does not disclose the pertinent information. As documented in Attachment A, this search did not reveal the relevant documents NRC claims to have become public knowledge before the request for amendment in July, 2001.1 It was only when Petitioner received NRC staff's response to the intervention petition that Petitioner was provided with ADAMS accession numbers. 2 These accession numbers allow the public to readily acquire the information. Without

'The search was performed on the ADAMS database and included terms such as "Indian point,"

"corrosion," rust" and "Entergy." There were date restrictions placed on some searches.

2 See NRC Staffs Response at Footnote 8.

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these numbers the information remains virtually hidden, especially to a lay person not familiar with the intricacies of the ADAMS database.

Furthermore, in its published application to the NRC, ConEd failed to mention areas "in the [IP2] containment building, and areas under the insulation on the walls that

",3 have rust.

Instead ConEd cited past IP2 leakage tests and stated that such tests indicated a "very leak-tight containment." 66 Fed. Reg. 44161 (2002). ConEd assured the NRC that "[p]erformance of the testing on the revised schedule [would] not have an adverse affect on the ability of the containment to perform its intended function." Id. at 44165 Because ConEd did not even discuss the rust in the dome in its application as published in the Federal Register, neither Petitioner nor NRC were aware of the problem until February 2002. Given the omission of this significant fact in the Federal Register coupled with the difficulties in finding the relevant information, Petitioner has good cause for failure to file on time.

B.

There Are No Other Available Means to Protect Petitioner's Interests There are no other means for Petitioner to protect its interest because there is no other party in the proceeding that seeks to require licensee to immediately conduct leakage tests in the containment dome at IP2. Furthermore, a hearing is the only forum in which Petitioner can request NRC to order licensee to immediately conduct containment leakage pressure testing at IP2 as required by its original license.

C.

Petitioner's Participation Will Reasonably Be Expected to Assist in the Development of a Sound Record 3 Roger Witherspoon, Indian Point 2"s Rusted Lining Causes Concern, JOURNAL NEWS, February 15, 2002 (quoting Entergy Vice President Fred Dacimo) (Attachment B).

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Petitioner's participation in this proceeding can reasonably be expected to assist in the development of a sound record.

Petitioner will provide the independent engineering analysis of Dr. Christian Meyer, Professor of Civil Engineering at Columbia University, New York. His qualitative assessment will show the significance of the rust in the containment dome and the importance of immediately performing the containment integrate leak rate test to determine whether the containment structure has been compromised. Dr. Meyer opines that the significance of corrosion damage, even

'if only of limited extent, can impair the integrity of the liner. See Attachment C.

It may create stress concentrations in the surrounding steel, and has the potential to cause embrittlement of the surrounding steel. See Attachment C.

Petitioner expects that expert testimony will provide further detail with respect to the specifics of the risk of rust in the containment dome and the importance of the ten-year integrate leak rate tests in an aging facility such as IP2.

D.

Petitioner Interests Will Not Be Represented by Existing Parties There are no other intervenors in this case, and therefore there are no other parties who can or will represent Petitioner's interests.

E.

Petitioner's Participation Will Not Broaden the Issues and Not Unduly Delay the Proceeding Petitioner's proposed independent engineering reports will not broaden the issues to be considered and not unduly delay this proceeding beyond the current timetable. The concise issue on this application is whether deferral of the required pressure testing might increase the consequences of an accident or other malfunction at IP2.

Petitioner proposes, through the testimony of Dr. Meyer, to present additional evidence on the dome 5

issue to further define the hazards of not performing a pressure test and the consequences this will have on public health and safety.

ConEd filed its proposed amendment application and chose not to include information regarding the presence of rust in the containment dome.

Had ConEd provided such information in its analysis in the first place, an appropriate analysis would already have been performed. Petitioner's proposal for immediate testing addresses this issue, which is already before the NRC.

V.

PETITIONER SATISFIES THE ADDITIONAL STANDARDS FOR INTERVENTION Petitioner satisfies additional standards set forth in 10 C.F.R. § 2.714(d)(1) thereby demonstrating it has a substantial interest in the outcome of the proceeding.

A.

Petitioner Interest in the Proceeding Petitioner is a not-for-profit organization with 6,500 members dedicated to the protection and conservation of the Hudson River and its watershed. "The idea behind the Riverkeeper organization is not only about the Hudson River. It's about people defending the place in which they live.'4 Many of Petitioner's members who live, work and recreate sufficiently close to IP2 are concerned with the substantially higher probability and consequences of a potential radiation leak. Through its members, Petitioner has the requisite personal interests to establish standing.

1.

Standing as of Right Petitioner has standing as of right to intervene. To demonstrate standing as of right Petitioner must satisfy that: (1) it has suffered or will suffer a distinct and palpable injury that constitutes injury in fact within the zone of interests arguably protected by the 4 "The Riverkeeper Story," available at http://www.riverkeeper.org/story/background.htmr.

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governing statute; (2) the injury is fairly traceable to the challenged action; and (3) the injury is likely to be redressed by a favorable decision. General Public Utilities Nuclear Corp. (Oyster Creek Nuclear Generating Station), 44 N.R.C. 143, 30-31 (1996)

(emphasis added).

Petitioner's members who live, work and engage in recreational activities near IP2 fulfill the necessary criteria for standing as of right and have authorized Petitioner to represent their interests in this matter.

"* Lisa Mechaley, of 758 Old Albany Post Road, Garrison, NY, is a member of "Petitioner's organization and has authorized it to represent her interests in this matter. Ms. Mechaley lives nine miles from IP2. Her young son, Jack, attends the Flying Goose day-care center located less than five-miles from IP2. Ms. Mechaley is concerned with the health and safety consequences of a potential release of radiation from P2.

"* Eric and Christine Puente, of 31 Battery Place Crugers, NY, are members of Petitioner's organization and have authorized it to represent their interests in this matter. Mr. and Mrs. Puente live a mere two-miles from 1P2. They live near the Hudson River waterfront and regularly boat on the River near Indian Point. The Puentes are newlyweds who would like to start a family, but the recent report of a new study linking infant death rates to nuclear power plants alarms them.5 Therefore, the Puentes are concerned about any offsite release.

Petitioner has demonstrated and can provide affidavits of individual members that have a significant health and safety interest in the matter. Through individual member concerns 5 The recent study is mentioned in the article by Andrew C. Revkin, Nuclear Power Opponents Cute Lint to Infant Death Rates, NEW YoRK TIMES, April 30, 2002 (the report indicates that infant death rates downwind of eight American nuclear power plants have dropped since the plants were shut down.)

(Attachment D).

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regarding the health, safety and property damage consequences of an accidental radiological release, Petitioner has established the requisite injury in fact. This injury can be traced to the challenged action because a pressure test would assure the integrity of IP2's dome.

Admittedly, a decision to order Entergy to immediately conduct pressure testing at IP2 would redress any injury asserted by Petitioner as it represents its individual members in this matter. Because Petitioner's members reside and engage in regular activities near IP2 and are concerned about the possibility of offsite consequences from a radiological leak, these interests provide the individual members, and thus Petitioner, with standing as of right. One of the purposes of the Atomic Energy Act is to protect the public health and safety with respect to nuclear power plants. See 42 U.S.C.S. § 2013(d)

(2002). Therefore, Petitioners should be made a party to the proceeding because the Act directly speaks to the nature of Petitioner's right to be afforded such protection.

2.

Proximity Presumption Standing for Petitioner can also be found based upon "proximity presumption."

NRC case law establishes that, "in certain types of proceedings, the agency has recognized a proximity or geographical presumption that presumes a petitioner has standing to intervene without the need specifically to plead injury, causation, and redressability if the petitioner lives within, or otherwise has frequent contacts with, the zone of possible harm from the nuclear reactor or other source of radioactivity." Florida Power & Light Co. (Turkey Point Nuclear), 53 NRC 138, 18 (2001) (in this case NRC found that petitioner, who lived 15 miles downwind of the plant, had standing to 8

intervene under the proximity presumption).6 The presumption, which is based upon geographical proximity, "may be applied where there is a determination that the proposed action involves a significant source of radioactivity producing an obvious potential for offsite consequences." Florida Power & Light Co. (Turkey Point Nuclear), 53 NRC 138, 23 (2001).

Several of Petitioner's members live, work, or recreate within close proximity of IP2. In fact, two of its members, Mr. and Mrs. Puente, live only two miles from IP2. It is precisely this close geographical proximity which establishes that the Petitioner has standing in this matter. The proximity presumption is applicable in this matter because there is an obvious potential that Petitioner's individual members would be affected by any offsite consequences of a radiological release stemming from the degraded containment area.

Therefore, standing for Petitioner can be established based on proximity presumption.

3.

Discretionary Standing In addition to establishing that Petitioner has both standing as of right and standing based on proximity presumption, Petitioner also demonstrates it meets the requirements for discretionary standing. The governing factors for discretionary standing are:

a)

Weighing in favor of allowing intervention:

1) The extent to which the petitioner's participation may reasonably be expected to assist in developing a sound record.

2) The nature and extent of the petitioner's property, financial, or other interest in the proceeding.

6 Duke Energy Corp. (Oconce Nuclear Station, Units 1, 2, and 3), CLI-99-11, 49 NRC 328, 333 n.2 (1999)(noted that although unnecessary to determine standing in this case, the 50-mile proximity presumption would have applied); Northern States Power Co. (Prairie Island Nuclear Generating Plant, Units 1 and 2), ALAB-107, 6 AEC 188, 190 (1973)(where the appeal board found that the proximity of petitioners living 30 to 40 miles from the reactor established their standing to intervene).

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3) The possible effect of any order which may be entered in the proceeding on the petitioner's interest b)

Weighing against allowing intervention:

4) The availability of other means whereby petitioner's interest will be protected.

5) The extent to which the petitioner's inteirest will be represented by existing parties.

6) The extent to which petitioner's participation will inappropriately broaden or delay the proceeding.

Portland General Electric Co. (Pebble Springs Nuclear Power Plant, Units 1 and 2), CLI-76-27, 4 NRC 610, 616 (1976).

Petitioner will assist in developing a sound record through the expert testimony of Dr. Christian Meyer. Dr. Meyer has special expertise in containment dome structures.

His testimony will bring to the record a thorough assessment of the corrosion damage and the necessity of pressure testing. As Petitioner made clear, it has substantial stake in preserving its health, safety and property interests. Furthermore, any order, which may be entered as a result of this proceeding, will directly effect Petitioner's interests.

Petitioner has previously established the factors weighing against allowing intervention. There are no other means available whereby Petitioner can request Entergy to immediately perform a leak rate test at IP2 and there is no other party to this proceeding that have the same interest as Petitioner. Finally, Petitioner's participation will appropriately provide useful information within the parameters of the issue at hand and will not unduly delay the proceeding.

C.

Petitioner Should Be Permitted to Intervene Because The Result of the Proceeding Affects the Petitioner's Interests If NRC denied the proposed amendment, licensee would be required to immediately conduct pressure tests in the containment area, thus addressing Petitioner's interest that there is currently no breach in the integrity of the dome. For the reason that 10

Petitioner's members' health, safety and property interests are at issue, Petitioner should be permitted to intervene to insure the effectiveness of the IP2 dome.

Petitioner's members' and their families live, work and attend schools near the IP2 Facility.

The presence of rust in the containment dome indicates there may be a leak in the dome's steel lining as well as other age-related deterioration. Failure to identify such a leak will defer required repair measures, greatly increasing the safety risks to Petitioner's members. Failure to pass its pressure test will demonstrate an increased likelihood of a radiological release into the human environment. Therefore, Petitioner seeks to intervene to compel NRC to deny the proposed amendment and require immediate integrate leak rate testing in the containment dome at IP2.

VI.

CONCLUSION For the foregoing reasons, Riverkeeper, Inc.'s petition for leave to intervene and request for a hearing should be granted.

Dated: White Plains, N.Y.

Respectfully submitted, April 30, 2002 RIVERKEEPER, INC.

Karl Coplan, Esq.

Pace Environmental Litigation Clinic, Inc.

78 North Broadway White Plains, New York 10603 Attorney for Riverkeeper, Inc.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

ENTERGY CORPORATION (Indian Point Nuclear Generating Unit No. 2; Facility Operating License DPR-26)

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Docket No. 50-247 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing AMENDED PETITION FOR LEAVE TO INTERVENE AND REQUEST A HEARING in the above captioned proceeding have been served upon the following persons this 3 0th day of April, 2002:

VIA FEDERAL EXPRESS G. Paul Bollwerk, III Chief Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Michael C. Farrar, Chair Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Dr. Richard F. Cole Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Dr. Charles N. Kelber Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 VIA U.S. MAIL, FIRST CLASS Office of the Secretary Attention Rulemaking and Adjudications U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sara E. Brock, Esq.

Catherine L. Marco, Esq.

Counsel for NRC Staff U.S. Nuclear Regulatory Commission Office of the General Counsel Washington, D.C. 20555 John M. Fulton, Esq.

Assistant General Counsel Entergy Nuclear Operations 440 Hamilton Avenue White Plains, NY 10601 J. Micheal McGarry IIl, Esq.

Kathryn M. Sutton, Esq.

Counsel.:for Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Operations, Inc.

Winston & Strawn 1400 L Street, N.W.

Washington, D.C. 20005 Aichtre eB.More Attorney for Riverkeeper, Inc.

ATTACHMENT A

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ATTACHMENT B

The Journal News 02/15/02 eJoun !INews.

Indian Point 2's rusted lining causes concern By ROGER WITIHRSPOON (c) TEE JOURNAL NEWS (Original publication: Feb. 15,2002)

The U.S. Nuclear Regulatory Commission has asked for proof that rusted areas in the steel lining of.Indian Point 2's containment building do not indicate holes in the massive.

concrete structure that could jeopardize its ability to protect. the public.

Utficials at Entergy Nuclear, which owns the nuclear power plant in Buchanan, said yesterday that the rust stems from water leaks inside the building, and that the building's structural integrity has not been compromised.

"There is no hole in my containment building," Entergy Vice President Fred Dacimo said.

"But there is a thinner part of the steel liner than there would have been if there had not been any rust. There are areas that are very high in the containment building, and areas under the insulation on the walls that have rust, and they want us to better justify why those areas are OKI" Entergy was given 30 days on Feb 5 to explain why it is certain the rust stems from water

.contamination inside the building, and poses no threat to the steel lining. The directive from Patrick Milano, project manager of the NIRC's Office of Nuclear Reactor Regulation, told Entergy to prove that the rusted spots were not the result of a 6.5-square-inch leak area that would release radiation into the atmosphere in an emergency.

'The rust has developed in the three-quarter-inch steel lining inside the reinforced concrete building.

During a catastrophic accident at a nuclear power plant, fuel would melt through the nuclear reactor's steel walls, creating a radioactive lava that would flow into water pooled on the building's floor. That would generate a radioactive steam explosion, instantly doubling or tripling the pressure inside and sending a steady plume of radiated steam through any hole in the containment building.

Containment buildings are pressure-tested every decade, though extensions can be granted for up to five years. Indian Point 2 is due to have a full pressure test in August, but has asked for a five-year extension, citing other, more important work that needs attention.

"We're reviewing that request," NRC spokesman Neil Sheehan said, "but we've asked for more information to justify the extension, particularly how the corrosion might impact a severe accident at-the plant."

That information,. Sheehan said, "could very well indicate there is no increased risk," and

The Journal News 02/15/02 Entergy, which also owns Indian Point 3, bought Indian Point 2 from Con Edison last Sept. 6 and has encountered a series of problems since then. The NRC considers Indian Point 2 to be the most trouble-plagued of the nation's 103 nuclear stations.

Dacimo said Entergy has spent "multiple millions of dollars" on repairs and the replacement of electrical system equipment that did not meet industry standards. The company intends to wait to repair the steam-generator at Indian Point 2 until a scheduled shutdown in the fall, when it intends to replenish the fuel.

Until last week, Indian Point 2 also had been on probation for unacceptable mechanical, electrical and engineering training. The accrediting arm of the Institute of Nuclear Power Operations put the plant on probation last August and could have decertified the plant had it not passed a re-examination last week.

While the plant was on probation last October, four of Indian Point 2's seven control room room operating crews failed their relicensing exams. Two of the crews have since -een removed from control room duty and the others have been retrained and retested, Dacimo said.

lHe said the company is continuing to revramp the training of its control room operators, who were trained under Con Edison.

Though Entergy has defended its operations in recent months as no threat to public safety, despite Indian Point 2's continuing problems, demands for Indian Point's shutdown have grown more vocal following the Sept. 1I terrorist attack on the World Trade Center.

Fearing that the plant could become a terrorist target, creating an unacceptable threat to the region, numerous environmental groups and elected officials and more than 7,000 residents in Westchester, Rockland and Putnam counties have signed petitions calling for the plant to be decommissioned.

The Indian Point Safe Energy Coalition, an organization of roughly 40 environmental and civic. groups that want Indian Point closed, is holding a rally at noon tomorrow at Peekskill's Riverfront Green to further publicize their concerns and mark -the anniversary of the accident in 2000.

"The events of Sept. 1. have ushered in a new world," U.S. Rep. Nita Lowey, D Harrison, said yesterday. "We should begin the process of decommissioning the plant as soon as possible."

The NRC confirmed yesterday that it would soon order all nuclear plants to institute tougher security measures. Since Sept. 11, the agency has sent advisories to the plants and security improvements have been voluntary, Sheehan of the NRC said. The decision to require the security measures -

which include increased vehicle searches and guards at the plants -

is being made at the request of the White House, Department of Defense and the Office of Homeland Security.

"Because the ongoing terrorist threat has persisted so long," Sheehan said, "the administration feels it is prudent to formalize some of these requirements. The situation is not going to change anytime soon. The terrorist threat is going to be with us."

The Joumal News 02/15/02 an extension could be granted. Indian Point 3 has received a five-year extension for its next pressure test.

-The current rust problem at Indian Point 2 is a lingering legacy of water corrosion that began on the steel lining about 15 years ago, said John McCann, manager of nuclear safety at Indian Point 2.

The building's air conditioning system uses Hudson River water for cooling and, when the system's pipes began leaking, 200,000 gallons of water spread throughout the buildi before the leaks' source was found.

"It reached nine feet around the reactor, and the NRC wasn't too happy about that," said the ng

- uIcid-aWum, a nuclear saiety analyst with the Union of Concerned Scientists. "They fixed the holes in the pipes, but didn't look at the damage from the water."

"In the last four or five years, we had to remove a lot of insulation looking for this,"

McCann said.

At the same time Entergy must work to defend the safety of the rusted steel and its request for a pressure test extension, the company this week had to notify the NRC and local officials of a small leak in one of its new steam generators.. The leak, first noticed on Wednesday, is allowing radioactive water from the nuclear reactor to mingle with clean, pressurized water ied to turn the giant, electric generating turbines. About a tenth of an ounce of radioactive water is pouring through the system daily, Dacimo said, though there is no immediate harm to the public..

Officials are not sure of the leak's exact source and are monitoring the problem.

News of the leak was publicized a day before today's-two-year anniversary of the worst accident in Indian Point's history, when Indian Point 2 was owned by Consolidated Edison. On Feb. 15, 2000, a burst tube in an aging steam generator in Indian Point 2 sent 20,000 gallons of radioactive coolant into-the clean water system. In addition, a. small.

amount of radioactive steam was released into the atmosphere.

The 2000 leak began about 6 p.m., but was essentially ignored during a shift change, and coolant surged from the steam generator for more than an hour. The accident triggered the plant's first nuclear alert, prompting county officials to staff their emergency center and wonder if a radiation alert would trigger the need for an evacuation.

County Executive Andrew Spano said yesterday that an initial lack of information about the accident from Con Edison made it difficult to gauge the severity of the situation. At the time, he became critical of the plant's management and the NRC's oversight and threatened to sue to force the plant's shutdown.

"It wasn't-the only one calling for its shutdown, but I was one of the most vocal," Spano said.

Spano later rescinded his call for a plant shutdown after receiving assurances from the NRC that the plant was safe.

ATTACHMENT C

arn-cI-a iU:iH COLUMBIA UNIVERSITY 1 212 654 6267 P.02 COLUMBIA UNIVERSITY IN TI"E CITY OF NEW YORK DEFARTMENZI 0;

CIVII. ENGINEERING AND rNGIN-ECRINC MLCHANICN Karl S. Coplan Pace Environmental Litigation Clinic, Inc.

Pace University School of Law 78 North Broadway White Plains, NY 10603 April 29, 2002

Dear Mr. Coplan,

You provided ine with documentation identifying the corrosion damage detected in the containment building of the Indian Point Nuclear Power Plant, and you have asked my opinion concerning the potential of such damage to jeopardize the plant's safety. As I do not have access to information of adequate detail, I cannot make any quantitative analysis, yet I am in a position to provide the following qualitative assessment.

The primary purpose of the steel liner is to maintain the containment building's leak tightness in the case of a loss of coolant accident, which shall be verified by periodic pressure testing. Corrosion damage, even if only of limited extent, can impair the integrity of the liner in three ways.

I. Corrosion reduces the stress-resisting material, thereby increasing the stress in the remaining steel. For the depth of corrosion mentioned in the documentation provided, this source of stress increase appears to be of no major concern.

2. Depending on the detailed geometric nature of the corrosion pattern, it can create stress concentrations in the surrounding sound steel, which could be significant.

3. Corrosion damage has also the potential of causing embrittlement of the surrounding sound steel, depending on the specific metallurgical makeup of the steel and corrosion products. Since I am not a metallurgist, I cannot further characterize the potential consequences of such embrittlenient.

The above three factors can cause cracks in the containment liner during a pressure test (or an actual loss of coolant accident), thereby jeopardizing its leak tightness. In order to quantify this threat, an expert in metal fracture and corrosion could perform a detailed analysis to determine the probability of the liner losing its leak tightness rissorn Meyer Professor of Civil Engineering 610 S.W. MuIcd Mail Code 4701 500 West I0tlth Srtcvt New York. NY 10027 21Z-854-3343 Fax 21Z-1454-6267

-WLUI'IIIH UNrI bL< IY 1 212 854 6267 P.03 Resume Christian Meyer Date of Birth: March 26, 1943 Place of Birth: Magdeburg, Germany Citizenship:

U.S.A.(Naturalized 1978)

Current Position and Affiliation:

Professor of Civil Engineering Department of Civil Engineering and Engineering Mechanics Columbia University, New York, NY 10027 Telephone (212) 854-3428/3143, Fax (212) 854-6267 Education:

Vordiplom, 1965, Technical University Berlin, Germany M*S., 1966, University of California, Berkeley, Calif.

Ph.D., 1970, University of California, Berkeley, Calif.

Professional Experience:

1966-1970, Teaching Assistant and Research Assistant, Civil Engineering Department, University of California, Berkeley 1971-1973, Senior Systems Engineer, Albert C. Martin & Associates, Los Angeles, California 1973-1978, Structural Engineer (1973-75), Computer Applications Engineer (1976-78), Consultant (1978), Stone and Webster Engineering Corporation, Boston, Massachusetts 1978-1989, Associate Professor of Civil Engineering, Columbia University, New York 1989-, Professor of Civil Engineering, Columbia University, New York Conuultantships and Other Experience (Partial List):

California Department of Transportation (formerly Division of Highways), 1969-1970 Stone and Webster Engineering Corp., Boston, 1978-1979 Weidlinger Associates, New York, 1979-1992 ORC Consultants, New York, 1989-1996 Auton Computing Corp., Edison, New Jersey, 1979-1981 U.S. Army Armament Research and Development Command' Dover, New Jersey, 1981-1985 Research Engineers, Cherry Hill, New Jersey, 1982-1984 Lecturer in Civil Engineering, Northeastern University, Boston, 1976-77 US District Court, Brooklyn, 1996-1997 Halliburton Energy Services, Duncan, OK, 1997-1

,-UL-A',OIH UNIVt-<jIT 1 212 854 62*7 P.04 Fields of Research Interest:

Analysis and design of concrete structures Concrete material science and technology Earthquake engineering and structural dynamics Computer analysis and design of structures Professional Engineering Registration:

Massachusetts, No. 27547 New Jersey, No. 25753 New York, No. 66380 Professional Societies:

American Society of Civil Engineers American Concrete Institute Earthquake Engineering Research Institute Int Association for Bridge and Structural Engineering Concrete Industry Board, New York Honorz:

Alexander Yon Humboldt Research Prize for Senior American Scientists, 1998 Committees (Partial List):

Committee on Electronic Computation, Structural Division, ASCE, 1972-1989 Chairman, Committee on Education, 1979-1981 Chairman, Task Committee on Finite Element Idealization Technical Council on Computer Practices, ASCE, 1979-1989 Chairman, Education Committee, 1979-1982 Committee on Finite Element Analysis of Reinforced Concrete Structures, Structural Division, ASCE, 1978 Chairman, 1981-1985 Task Committee on Flexural Members, Structural Division, ASCE, 1972-1975 Committee on Methods of Analysis, Structural Division, ASCE, 1971-1973 Seismic Analysis of Safety Class Structures Committee, Committee on Nuclear Standards, ASCE, 1978-1980 Metropolitan Section, ASCE, Director, 1997-1998 Infrastructure Group, Chairman, 1991-1994 Technical Council on Forensic Engineering, Committee on the Practices to Reduce Failures, 1993 ACI Committee 442, Response of Buildings to Lateral Forces, 1979.

ACI Committee 118, Use of Computers, 1979-1994 ACI Committee 446, Fracture Mechanics, 1993 New York City Seismic Commission Columbia University, Strategic Planning Commission Columbia University Senate, Budget Review Committee, Chairman, 1989-1996 2

1 212 854 6267 P.85 Research Contracts:

Seismic Reliability of Damaged Reinforced Concrete Buildings, NSF Contract No. PFR-7924695, $90,000, M. Shinozuka, Co-Principal investigator, May 1980-April 1982 Load Combinations for Design of Category I Structures, Brookhaven National Laboratory Contract No. BNL-517722-S, $69,000, M. Shinozuka, Principal Investigator, May 1980- Sept. 1980 Seismic Reliability of Damaged Concrete Buildings, NSF Contract No. CEE-8121359, $115,000, May 1982-April 1984 Program to Organize and Correlate Material Property Data For Large - Deformation Finite Element Programs, U.S. Army Research and Development Command, Dover, New Jersey, $25,000 Seismic Response and Reliability of Building Structures and Bridges, NCEER Contract No.

87-1006A and 87-3008A Bridge Maintenance System, New York City Department of Transportation, as part of Columbia University Institute of Infrastructure Simulation of Nonlinear Response of Wall Panels to Cyclic Load, NCEER Contract No. 89-1008,

$55,000, 1989/90 Damage Prediction for Concrete With and Without Fiber Reinforcement, NSF Contract MSS-91-13127, $178,000, 1991-1993 Engineering Research Equipment Grant Upgrade of MTS 810 Universal Testing Machine, NSF Award MSS-93-10491, $42,350, 1993-1994 Use of Recycled Glass as Aggregate for Concrete Masonry Blocks, NYSERDA Award 4113-IABR-BR-95, $230,790, 1995-1997 Use of Recycled Glass and Fly Ash for Precast Concrete, NYSERDA Award 42291-IABR-IA-96,

$198,000, 1996-1997 Summer Institute in Civil Engineering, ASCE, $2900, 1996 Seismic Design Review of Ward's Island Vehicle Maintenance Facility and Third Water Tunnel, New York City Dept. of Environmental Protection, $36,354, 1996-1998 Development of Glascrete Products, New York State Department Of Economic Development, Project No. C 003089, $73,813, 1997-1998 Fiber Reinforcement for Oil Well Cements, Halliburton Energy Services, $185,000, 1997-1999 Precast Concrete Panels with Glass Concrete, NYSERDA, $248,724, 1998-2000 Chemical Containment of Toxic Materials in Concrete and Development of Glascrete Products, Echo Environmental, $490,000, 1999-2001 3

H*--*--*

du:

COLUMBIA UNIVERSITY

1 212 854 6267 P.O8 Patents;

1.

Complex Admixture for Gypsum Systems to Control the Time of Setting According to Needs, U.S. Patent No. 5,725,656

2.

Use of Waste Glass in Concrete, U.S. Patent No. 5,810,921 Publications:

1.

"Wheel Load Distribution in Concrete Box Girder Bridges", Report No. SESM 69-1, University of California, Berkeley, Jan. 1969 (with A.C. Scordelis).

2.

"Computer Program for Prismatic Folded Plates with Plate and Beam Elements", Report No.

SESM 70-3, University of California, Berkeley, Feb. 1970 (with A.C. Scordelis).

3.

"Analysis of Curved Folded Plate Structures", Report No. SESM 70-8, University of California, Berkeley, Dec. 1970 (with A.C. Scordelis).

4.

"Analysis and Design of Curved Box Girder Bridges", Ph.D. Dissertation, Report No. SESM 70-22, University of California, Berkeley, Dec. 1970.

5.

"Analysis of Curved Folded Plate Structures", Journal of the Structural Division, ASCE, Vol. 97, No. STIO, Oct. 1971 (with A.C. Scordelis).

6.

"Computer Program for Non-Prismatic Folded Plates with Plate and Beam Elements", Report No.

SESM 71-23, University of California, Berkeley, Dec. 1971 (with A.C.Scordelis).

7.

inelastic Dynamic Analysis of a 60 Story Building", 5th World Conference on Earthquake Engineering, Rome, 1973 (with J. Lord, J.B. Hoemer, and M. Zayed).

8.

"Multi-Degree of Freedom Response Spectra for Elastic Systems", 5th World Conference on Earthquake Engineering, Rome, 1973 (with E.J. Teal and J. Lord).

9.

"Solution of Linear Equations - State of the Art", Journal of the Structural Division, ASCE, Vol. 99, No. ST7, July 1973.

10.

"Inelastic Dynamic Analysis of Tall Buildings', Int. Journal of Earthquake Engineering and Structural Dynamics, Vol. 2, No.4, May 1974.

11.

"Steel Box Girder Bridges - Ultimate Strength Considerations", Journal of the Structural Division, ASCE, Vol. 100, No. STI2, Dec. 1974 (Subcommittee on Ultimate Strength of Box Girders, ASCE-AASHTO Task Com. on Flexural Members, C.G. Culver, Chairman).

12.

"Special Problems Related to Unear Equation Solvers", Journal of the Structural Division, ASCE, Vol. 101, No. ST4, April 1975.

13.

"Converting SAP to a User-Oriented General Purpose Program", First SAP User's Conference, University of Southern California, Los Angeles, June 1976.

14.

"Seismic Design of Nuclear Power Plant Structures", ASCE Annual Convention, San Francisco, Oct. 1977 (with E. Kausel)

15.

"Quasi-NonFinear Dynamic Analysis", 5th Int. Conference on Structural Mechanics in Reactor Technology, Berlin, Paper M10/4, Aug. 1979.

16.

"Earthquake Damage Assessment of Reinforced Concrete Buildings', ACI Convention, Washington, D.C., Oct. 1979 (with M. Shinozuka).

17.

"Building Response Under Random Earthquake Ground Motions", Research Conference on Earthquake Engineering, Skopje, Yugoslavia, June 1980 (with M. Shinozuka).

18.

"User-Oriented Programming", Second Conference on Computing in Civil Engineering, ASCE, 4

"rMQ1VeUU1:ý luzu (UJLUMBIA UNIVERSITY

5

_ULI'J1H UNIVE1bi I Y 1 212 854 6267 P.07 Baltimore, June 1980.

19.

"Dynamic Finite Element Analysis of Reinforced Concrete Structures", ASCE Annual Convention, Hollywood, Florida, Oct. 1980.

20.

"Response of the STARSAT Satellite to Shock and Retrieval Loadings During the Huron King Test", Weidlinger Associates, New York, Final Report Under Contract DNAO01-80-C-0275 to Defense Nuclear Agency, Oct. 1980 (with F.L. DiMaggio, J.M. McCormick, and M.L. Baron).

21.

"Dynamic Finite Element Analysis of Reinforced Concrete Structures", Introductory Report to JABSE Colloquium on Advanced Mechanics of Reinforced Concrete, Delft, The Netherlands, June 1980.

22.

"Static Analysis of Nuclear Fuel Cask (Drop Test)", Final Report to Transnuclear, Inc., Weldlinger Associates, June 1980 (with J.M. McCormick and R. Smilowitz).

23.

"Probability Based Load Criteria for Design of Nuclear Structures: A Critical Review of the State of the Art", Brookhaven National Laboratory, Feb. 1981 (with M. Shinozuka, B.R. Ellingwood, P.C.

Wang, Y.K. Wen, S. Kao, M.L. Shoeman).

24.

"Modeling-Reinforced Concrete Beams Subjected to Cyclic Loadse, Report No.

NSF-PFR-7924695-CU-1, Columbia Univer-sity, March 1981 (with S.G. Arzoumanidis).

25.

"Computer Analysis and Design of Structures', Journal of the Technical Councils, ASCE, Vol. 107, No. TC1, April 1981.

26.

"Design Loads for PWR Containment Buildings", Report No. BNL-517722-S-CU-1, Columbia University, Sept 1981.

27.

"Earthquake Reliability of Reinforced Concrete Buildings", ASCE Symposium on Probabilistic Methods in Structural Engineering, St. Louis, Proceedings, Oct. 1981 (with S.G. Arzoumanidis and M. Shinozuka).

28.

"Nonlinear Analysis of Reinforced Concrete Frames for Dynamic Loading", Report No.

NSF-PFR-7924695-CU-3,.Columbia University, Dec. 1981 (with M.S.L. Roufaiel).

29.

"The SSTG Set of a 688-Class Submarine: Some Finite Element Models*, Weidlinger Associates, New York, Report Under Contract DNA001.-80-C-0275 to Defense Nuclear Agency, Jan. 1982 (with J.M. McCormick and J.M. Klosner).

30.

"The Main Propulsion Unit of a 688-Class Submarine: Some Finite Element Modelse, Weidlinger Associates, New York, Report Under Contract DNAOOO-14-76-C-0820 to Defense Nuclear Agency, March 1982 (with J.M. McCormick and J.M. Klosner).

31.

"Shell Construction With Precast Elements", Concrete International, ACI, April 1982 (with E.

Kaplunovich).

32.

"Finite Element Analysis of Reinforced Concrete', Special Publication, ASCE, April 1982 (ASCE Task Committee on Finite Element Analysis of Reinforced Concrete Structures, A.H. Nilson, Chairman).

33.

"Design Life Simulation of a PCRV", Journal of the Structural Division, ASCE, Vol. 108, No. ST5, May 1982.

34.

Nonlinear Analysis of R/C Structures in Practice", Joumal of the Structural Division, ASCE, Vol.

108, No. ST8, Aug. 1982 (with K.J. Bathe).

35.

"Designing Against Earthquakes" (in German), Proceedings of Seminar on Construction in Seismic Regions, Technical University Berlin, Germany, June 1982.

36.

"Tall Buildings" (in German), Proceedings of Seminar on Construction in Seismic Regions,

-13 1%

-- ULUIbII H UNJNI VYHI IY 1 212 854 G267 P.O8 Technical University Berlin, Germany, June 1982.

37.

"Analysis of Damaged Concrete Frames for Cyclic Loads", Int. Journal of Earthquake Engineering and Structural Dynamics, Vol. 11, Jan. 1983 (with M.S.L. Roufaiel and S.G. Arzoumanidis).

38.

"Computer Analysis in Engineering Practice", Journal of the Boston Society of Civil Engineers Section ASCE, April 1983.

39.

"Mathematical Modeling of Complex Structures for Dynamic Analysis", Computers and Structures, Vol. 18, No. 4, 1984 (with J.M. McCormick).

40.

"Analysis of Damaged Concrete Frame Buildings", Report No. NSF-CEE-81-21359-1, Columbia University, May 1983 (with M.S.L. Roufaiel).

41.

"Reliability of Damaged Reinforced Concrete Frames', 8th World Conference on Earthquake Engineering, San Francisco, July 1984 (with M.S.L. Roufaiel).

42.

"Earthquake Analysis of Structural Walls", Int. Conference on Computer-Aided Analysis and Design of Concrete Structures, Split, Yugoslavia, Pineridge Press, 1984.

43.

"Polygonal Prestressed Concrete Water Reservoirs", FIP Symposium on Concrete Pressure and Storage Vessels, Calgary, Aug. 1984 (with M.-C. Tang).

44.

"Concrete Block Masonry Test Program", Dept. of Civil Engin., Columbia University, Oct. 1985 (with R. Baussan).

45.

"Familiarization With DYNA2D/NIKE2D and Torsional Impulse Study", Dept. of Civil Engineering, Columbia University, Nov. 1985.

46.

"Mathematical Modeling of Concrete Masonry", Dept. of Civil Engineering, Columbia University, Dec. 1985 (with R. Baussan).

47.

"Finite Element Analysis of Reinforced Concrete Structures", Special Publication, ASCE, Proceedings of U.S.-Japan Seminar, Tokyo, 1986 (Editor, with H. Okamura).

48 "Modeling Large Inelastic Cyclic Response of Concrete", Proc. of U.S.-Japan Seminar, Tokyo, Special Publication, ASCE, 1986 (with H. Delgado-Saavedra).

49.

"Seismic Design of Reinforced Concrete Structures", Earthquake Prognostics, A. Vogel and K.

Brandes (eds), Vieweg Publishing, Wiesbaden, 1987.

50.

"IPMP WP85 Shock Analysis. Final Report Part 1: ELSHOK Velocity Time-History Response",

Weidlinger Associates, Report P2352 to General Dynamics Electric Boat Division, January 1987 (with J.M. McCormick and D. Ranlet).

51.

"Analytical Modeling of Hysteretic Behavior of R/C Frames", Journal of Structural Engineering, ASCE, Vol. 113, No. 3, March 1987 (with M.SL. Roufaiel).

52.

"Reliabirity of Concrete Frames Damaged by Earthquakes", Journal of Structural Engineering, ASCE, Vol. 113, No. 3i March 1987 (with M.S.L Roufaiel).

53.

"Finite Element Idealization", Special Publication, ASCE. 1987 (Editor and Chairman, ASCE Task Committee on Finite Element Idealization).

54.

"Analysis of Underwater Tunnel for Internal Gas Explosion", IABSE Colloquium on Computational Mechanics of Concrete Structures, Delft, The Netherlands, Aug. 1987.

55.

"Nonlinear Dynamic Finite Element Analysis of Underwater Tunnel Subjected to Internal Gas Explosion", Int. Conference on Computational Engineering Mechanics, Peking, 1987.

56.

"Examples of Non-Linear Analysis of Reinforced Concrete Structures with DIANA", Heron, Vol. 32, No. 3, Delft, The Netherlands, 1987 (J.G.M. van Mier, Editor).

57.

"Seismic Damage Assessment of Reinforced Concrete Members, Technical Report NCEER-87-22,

COLUMBIA UNIVERSITY 1 212 854 6267 P.09 National Center for Earthquake Engineering Research, State University of New York at Buffalo, 1987 (with Y.S. Chung and M. Shinozuka).

58.

"Computational Model of the KOKANEE Vehicle", Weidlinger Associates, Report No.

WARAD-88/005, June 1988 (with J.M. McCormick and R. Vasudevan).

59.

"Automated Seismic Design of Reinforced Concrete Buildings", Technical Report NCEER-88-24, National Center for Earthquake Engineering Research, State University of New York at Buffalo, 1988 (with Y.S. Chung and M. Shinozuka).

60.

"SARCF - Seismic Analysis of Reinforced Concrete Frames", Technical Report NCEER-88-44, National Center for Earthquake Engineering Research, State University of New York at Buffalo, 1988 (with Y.S. Chung and M. Shinozuka).

61.

"A New Damage Model for Reinforced Concrete Structures", Ninth World Conference of Earthquake Engineering, Tokyo-Kyoto, Aug. 2-9, 1988, Paper 5133 (with Y.S. Chung and M, Shinozuka).

62.

"Response. of Concrete Buildings to Lateral Forces", ACI Committee Report 442R-88, 1988 (with ASCE-ACI Comm. 442).

63.

"Finite Element Applications to Study Stress States in End Blocks of Pretensioned Concrete Members" (in German), Finite Element Congress, Dortmund, 1988 (with M. Samkari and G.

Mehlhom).

64.

"A Damage Model for Reinforced Concrete', in "Seismic Engineering", C.A. Kircher and A.K.

Chopra, eds., ASCE Structures Congress, San Francisco, May, 1989 (with Y.S. Chung and M.

Shinozuka).

65.

"Structural Computing in Engineering Practice", in "Computer Utilization in Structural Engineering",

J.K Nelson, ed., ASCE Structures Congress, San Francisco, May 1989.

66.

"Inelastic Seismic Analysis of Concrete Buildings", in "Seismic Engineering", C.A. Kircher and A.K.

Chopra, eds., ASCE Structures Congress, San Francisco, May, 1989.

67.

"Modeling of Concrete Damage", AC! Structural Journal, May-June 1989 (with Y.S. Chung and M Shinozuka).

68.

"Automated Damage-Controlled Design of RC Buildings", ICOSSAR 1989, San Francisco, Aug.

1989 (with Y.S. Chung and M. Shinozuka).

69.

"Composite Material Modeling in HULRAD and WASCAr", Final Report to Naval Sea Systems Command, Weidfinger Associates, Dec. 1989 (with R. Daddazio and R. Smilowitz).

70.

"Damage of Plain Concrete as a Low-Cycle Fatigue Phenomenon*, Dept. of Civil Engineering and Engineering Mechanics, Columbia University, New York, Dec. 1989 (with M.S. Bang).

71.

"Automaic Seismic Design of RC Building Frames", ACI Structural Journal, May-June 1990 (with Y.S. Chung and M. Shinozuka).

72.

"Shouldn't We Have Professional Schools For Professional Engineers?", ASCE Nat. Forum on Education and Continuing Development for the Civil Engineer, Las Vegas, April 1990,

73.

"SARCF-11 User's Guide, Seismic Analysis of Reinforced Concrete FramesW, Technical Report NCEER-90-27, National Center for Earthquake Engineering Research, State University of New York at Buffalo, 1990 (with S. Rodriguez-Gomez and Y.S. Chung).

74.

"Reinforced Concrete Frames Subjected to Cyclic Loadsm, in Structures Subjected to Repeated Loading, Stability and Strength Series, T.M. Roberts and R. Narayan, eds, Elsevier Applied Science Publishers, London, 1991.

7

1 212 854 G2G7 P.10

75.

"Earthquake-Resistant Concrete Structures - Inelastic Response and Design", S.K. Ghosh, ed., ACI Special Publication SP-127, 1991.

76.

"Nonlinear Seismic Analysis of Reinforced Concrete Buildings", Proceedings, Second Civil Engineering Automation Conference, ASCE, New York, November 19, 1991.

77.

"An Energy-Based Damage Model for Inelastic Dynamic Analysis of Reinforced Concrete Frames",

Workshop on Nonlinear Seismic Analysis of RC Buildings, Bled, Slovenia, 1992.

78.

"Analysis of Concrete Structures for Dynamic Loading", Proceedings, 10th ASCE Structures Congress, San Antonio, April 1992 (with K. Maekawa and N. Bicanic).

79.

"Damage Prediction for Concrete with and without Fibre Reinforcement", Dept. of Civil Engineering and Engineering Mechanics, Columbia University, New York, April 1992, (with M. Grzybowski).

80.

'Damage Accumulation in Concrete with and without Fibre Reinforcement", ACI Materials Journal, November-December 1993 (with M. Grzybowski).

81.

"Finite Element Analysis of Reinforced Concrete Structures 11", Special Publication, ASCE, 1993 (Joint ASCE-ACI Committee 447, J. Isenberg, ed.).

82.

"Damage Mechanics of Concrete Under Cyclic Load", in Mechanics of Materials and Structures, G.Z. Vojiadjis et al, eds., Elsevier Science Publishers, 1994 (with T. Paskova).

83.

"Optimum Number of Specimens for Low-Cycle Fatigue Tests of Concrete", ASCE, Journal of Structural Engineering, Technical Note, July 1994 (with T. Paskova).

84.

"Concrete Durability and Our Infrastructure", NACE International Symposium on Corrosion of Infrastructure, Secaucus, NJ, April 11-12, 1994.

85.

"Low-Cycfe Fatigue Behavior of Fiber Reinforced Composites", First Intemational Conference on Composites Engineering, New Orleans, August 28-31, 1994 (with T. Paskova).

86.

"Damage Mechanics Based Model for Cyclic Response of Concrete", in Fracture and Damage in Quasibrittle Structures, Z.P. Bazant et al, eds, E & FN Spon, London, 1994 (with T. Paskova).

87.

"Damage of Plain and Fiber Reinforced Concrete Under Low-Cycle Fatigue Load", Dept. of Civil Eng. and Engin. Mech., Columbia University, New York, Sept 1994 (with T. Paskova).

88.

"Computing in Engineering Practice - What Will the Future Hold?", DIANA - Computational Mechanics, G.M.A. Kusters and M.A.N. Hendriks, eds, Kluwer Academic Publishers, Dordrecht, 1994.

89.

"Low-Cycle Fatigue Behavior of Fiber Reinforced Concrete Under Biaxial Stress States", 10th ASCE Engineering Mechanics Specialty Conference, Boulder, May 1995 (with Li Fang).

90.

"Architectural Concrete Products With Natural Stone Like Appearance", ACI Spring Convention.

Salt Lake City, March 1995 (with S. Shimanovich).

91.

"Gypsum - An Old Material With new Applications", ACI Spring Convention, Salt Lake City, March 1995 (with S. Shimanovich).

92.

"Smart Infrastructure Technologies", 4th Annual Symposium, The National Aviation and Transportation Center, Dowling College, July 1995.

93.

"Analysis of Viscoptastic Softening Behavior of Concrete Under Displacement Control", ASME Congress, San Francisco, Nov. 1995 (with S.H. Kim).

94.

"Automatic Design for Uniform Damage Distribution by Program SARCF", Int. Conf. on Open Building and Construction, Nanjing, October 1995 (with Jianli Yuan).

95.

"Numerical Analysis of Nonlinear Structural Behavior", (in German), Der Ingenieurbau (6 Vol.

Handbook for Civil Engineers, G.Mehlhom, ed.), Ernst und Sohn, Berlin, 1996 (with R. de Borst).

a 10: 2J COLUMB IA UN IV'ERS ITY

9 I M:

-)A

.,ULU'II.IH UNiNEvSITY 1 212 854 8287 P.11

96.

Design of Concrete Structures, Prentice Hall, Englewood Cliffs, 1996.

97.

"A Damage Mechanics Based Model for Low-Cycle Fatigue Behavior of Fiber Reinforced Concrete", Proc., 3rd Asian-Pacific Conf. on Computational Mechanics, Seoul, Korea, Sept. 1996 (with Li Fang).

98.

"A Comprehensive Description for Damage of Concrete", Proc.. 3rd Asian-Pacific Cont on Computational Mechanics, Seoul, Korea, Sept. 1996 (with X. Peng and X. Zeng).

99.

"Cyclic Behavior, Fatigue Strength, Endurance Umit and Models for Fatigue Behavior of Fiber Reinforced Concrete", in High Performance Fiber Reinforced Cement Composites 2, A.E.

Naaman and R.H. Reinhardt, eds., E & FN Spon, London, 1996 (with V. Ramakrishnan, A.E.

Naaman, G. Zhao, L Fang).

100.

"Biaxial Low-Cycle Fatigue Behavior of Steel Fiber-Reinforced Concrete", 4th Engin. Materials Conf., ASCE, Washington, D.C., Nov. 1996 (with L Fang).

101.

"Potential of Waste Glass for Concrete Masonry Blocks", 4M Engin. Materials Conf., ASCE, Washington, D.C., Nov. 1996 (with S. Baxter and W. Jin).

102.

"Alkali-Silica Reaction in Concrete With Waste Glass as Aggregate', 41 Engin. Materials Conf.,

ASCE, Washington, D.C., Nov. 1996 (with S. Baxter and W. Jin).

103.

"New Applications for Gypsum Products", 4th Engin. Materials Conf., ASCE, Washington, D.C., Nov.

1996 (with S. Shimanovich).

104.

"Gypsum - New Developments for an Old Material", Int. Conf. on Engin. Materials, Ottawa, June 1997 (with S.Shimanovich).

105.

"Glascrete -Concrete With Crushed Waste Glass Aggregate", Int. Conf. on Engin. Materials, Ottawa, June 1997 (with S. Baxter and W. Jin).

106.

"Low-Cycle Fatigue of Plain and Fiber-Reinforced Concrete", ACi Materials Journal, July-Aug. 1997 (with T. Paskova).

107.

"Thermomechanically Consistent Continuum Damage Model for Concrete Materials", ASCE, Engineering Mechanics Journal, Jan. 1997 (with X. Peng and U Fang).

108. "A Comprehensive Description for Damage of Concrete Subjected to Complex Loading", Structural Engineering and Mechanics, Vol 5, No 6 (1997), 679-689 (with X. Peng).

109.

"Low-Cycle Fatigue of Steel Fiber Reinforced Concrete -Theory and Experiment", Mehihom Festschrift, Materialmodelle und Methoden zur wirklichkeitsnahen Berechnung von Beton-,

Stahibeton-und Spannbetonbautei/en, Gesamthochschule Kassel, Germany, 1997.

110.

"Laboratory Studies of Alkali-Silica Reaction in Concrete with Waste Glass Aggregate Using ASTM C-1260", Dept. of Civil Engineering and Engineering Mechanics, Columbia University, New York, June 1997 (with S. Baxter and W. Jin),

111.

"Use of Recycled Glass for Concrete Masonry Blocks", Final Report to New York State Energy Research and Development Authority, Rep. No. 97-15, AlbanY, NY, Nov. 1997 (with S. Baxter).

112.

Modeling and Analysis of Reinforced Concrete Structures for Dynamic Loading, Editor, CISM Courses and Lectures No. 346, SpringerWienNewYork, 1998.

113.

"Concrete With Waste Glass as Aggregate", Proc., 130 FIP Congress on Challenges for Concrete in the Next Millenium, Amsterdam, May 1998 (with W. Jin and S. Baxter).

114.

"Microfracturing Caused by Alkali-Silica Reaction of Waste Glass in Concrete", 3rd Int. Conf. on Fracture Mechanics of Concrete and Concrete Structures, Gifu, Japan, Oct 12-16, 1998 (with Z.P.

Bazant and W. Jin).

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"A Chemo-Physical-Mechanical Approach", Proc. of the Sidney Diamond Symposium on Concrete Materials Science, Hawaii, Aug. 1998, in Materials Science of Concrete - The Sidney Diamond Symposium, S. Cohen et al, eds. (with W. Jin).

116.

"Theoretical Modeling of Expansion and Damage of Concrete due to ASR", Proc., ASCE 12m Eng Mech Conf, San Diego, May 1998 (with W. Jin, A. Suwito, and Y. Xi).

117.

"Microfractures Caused by Alkali-Silica Reaction in Concrete with Glass Particles of Different Sizes", Proc., ASCE 12th Eng Mech Conf, San Diego, May 1998 (with Z.P. Bazant and W. Jin).

118.

"Use of Recycled Glass and Fly Ash for Precast Concrete, Final Report to New York State Energy Research and Development Authority, Rep. No. 98-18, Albany, NY, Oct 1998 (with S. Baxter).

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"Testing and Modeling Alkali-Silica Reaction and the Associated Expansion of Concrete", in Mechanics of Quasi-Brittle Materials and Structures, A Volume in Honour of Prof. Z.P. Bazant 60th Birthday, G. Pijaudier-Cabot et al, eds., Hermes Science Publications, Paris, 1999, 217-232 (with Y. Xi, A. Suwito, X.Wen, and W. Jin).

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(April 2001)

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Xozr Narrk rvaints S.H TH L W LR -.

April 30, 2002 Nuclear Power Opponents Cite Link to Infant Death Rates By ANDREW C. REVKIN A

ntinuclear campaigners plan to announce today that a new study shows that infant death rates downwind of eight American nuclear power plants dropped significantly after they were shut down.

Some plan to use the findings to support calls for closing the nuclear reactors at Indian Point, the plant closest to New York City, in Westchester, County.

But federal officials, some radiation experts and representatives of the nuclear power industry said that there was no evidence to link illness and ?

proximity to nuclear plants and that minute, occasional releases from such plants were much lower than natural radiation levels.

The new statistical study, which is being published in the next issue of The Archives of Environmental Health, was conducted by a group of scientists who for many years have purported to show a link between mortality and illness and low levels of radiation from power plants, bomb tests and other sources.

But their past work has never been replicated by federal health researchers, and the statistical analysis they used in some earlier studies has been challenged by the National Cancer Institute.

GDTL ME°M~BER CENTER y.1-.

Now nytimes.com can work even harder for you.

nylimes.comlmi The study said the infant death rate in communities for two years preceding the plant shutdowns averaged 8.44 deaths per 1,000 births and, when all the mortality data for two years after the plant shutdowns were combined, the infant mortality rate dropped to 7.01 per 1,000 births.

The difference was statistically significant, the authors said, and the drop was greater than the general drop in infant death rates around the country in recent years.

The scientists, from the Radiation and Public Health Project, a nonprofit group, defended their new findings and cited the need for much more research.

1 of 2 4/30/2002 12:18 PM

Joseph J. Mangano, a public health statistician and the national coordinator for the group, said a statistical link does not prove a cause and effect, but points to the need for more work.

"A lot of things could affect infant deaths," he said. "The list is literally endless. This doesn't mean we've proved anything beyond a shadow of a doubt, but what I will say is we really need to do more follow-up."

Among other things, the study examined statistics from counties and cities downwind of eight nuclear plants that shut down either for a prolonged period or permanently -

in Connecticut, Maine, Massachusetts, California, Oregon, Colorado, Michigan and Wisconsin.

Dr. John Boice Jr., who directed a 1991 National Cancer Institute study of disease patterns around nuclear plants and other institutions using radiation, said no link emerged.

'There are so many other important things to worry about in terms of radiation -

like what are we doing to do with the waste and the terrorism issue," he said last night.

Home I Back to New York Region I Search I HUI Back to Top Copyriaht 2002 The New York Times Company I Privacy Information 2 of 2 4/30/2002 12:18 PM