ML071440333
| ML071440333 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/16/2007 |
| From: | Mogolesko F Entergy Nuclear Generation Co, Entergy Nuclear Operations |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML071440314 | List: |
| References | |
| 50-293-LR, ASLBP 06-848-02-LR, RAS 13684 | |
| Download: ML071440333 (7) | |
Text
May 16, 2007 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
Entergy Nuclear Generation Company and ) Docket No. 50-293-LR Entergy Nuclear Operations, Inc. ) ASLBP No. 06-848-02-LR
)
(Pilgrim Nuclear Power Station) )
DECLARATION OF FREDJ. MOGOLESKO IN SUPPORT OF ENTERGY'S MOTION FOR
SUMMARY
DISPOSITION OF PILGRIM WATCH CONTENTION 3 Fred J. Mogolesko states as follows under penalties of perjury:
L. I am a Senior Project Manager with Entergy Nuclear Generation Company and Entergy Nuclear Operations (hereinafter and. collectively, "Entergy") for the Pilgrim Nuclear Power Station ("PNPS"). I am the Project Manager for the Pilgrim License Renewal Project.
- 2. My professional and educational experience is summarized in the curriculum vitae attached as Exhibit 1 to this affidavit. I hold both a Bachelor's Degree and a Master's Degree in Aerospace Engineering and Applied Mechanics from the Polytechnic Institute of Brooklyn. I also hold a Master's Degree in Meteorology/Oceanography and a Ph D. in Oceanography from New York University. I am certified by the American Meteorological Society as a Certified Consulting Meteorologist.
- 3. In my capacity as the Project Manager for the Pilgrim License Renewal Project I am responsible for, among other things, consequence analysis modeling and assessment, and dispersion modeling of radionuclide and other pollutants in air and water environments for PNPS license renewal. I am knowledgeable of the Severe Accident Mitigation Alternative ("SAMA")
analyses prepared by Entergy for the Environmental Report that is part of the PNPS license renewal application. I have reviewed the analysis and provided advice and input on its preparation. Specifically, I am knowledgeable of and provided advice and input on the meteorological data used in the PNPS analysis.
- 4. I am familiar with Contention Pilgrim Watch 3, which was raised by Pilgrim Watch in the NRC licensing proceeding for the PNPS license renewal. As admitted into the proceeding by the Atomic Safety and Licensing Board, Pilgrim Watch Contention 3 asserts that "Applicant's SAMA analysis for the Pilgrim plant is deficient in that the input data concerning (1) evacuation times, (2) economic consequences, and (3) meteorological patterns are incorrect, resulting in incorrect conclusions about the costs versus benefits of possible mitigation alternatives, such that further analysis is called for."
- 5. My declaration addresses claims raised by Pilgrim Watch in Pilgrim Watch Contention 3 concerning the adequacy of the meteorological patterns and data used in the PNPS SAMA analyses. I will demonstrate that the PNPS SAMA analysis performed in support of license renewal used representative meteorological data for PNPS.
- 6. PNPS obtains meteorological data from its 220 Foot Meteorological Tower from both an upper level and lower level sensor. Data is obtained from the Tower on a daily basis.
Personnel perform quality screening of data to look for grossly anomalous or missing data, as well as. zero and span calibration checks of equipment. Sensor equipment is replaced on a regular, quarterly basis using sensors calibrated in accordance with applicable industry standards.
Qualitative checks (wind direction alignment to cardinal sectors, ice bath tests for temperature sensors, etc.) were performed during these quarterly calibration/equipment exchanges.
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- 7. On a monthly basis, data files were submitted to a contractor for processing of joint frequency distributions of wind direction, class and speed and X/Q calculations. As part of this contracted service, data were screened using NUREG-0917 quality screening criteria and found to be suitable for use.
- 8. The following table summarizes the percentage of data recoverable for the six year period prior to the performance of the SAMA analysis:
Year 220 Foot 220 Foot Met.Tower- Met.Tower-Lower Level Upper Level.
1996 96.8% 96.0%
1997 93.7% 95.4%
1998 96.7% 92.1%
1999 94.8% 90.8%
2000 91.8% 91.0%
2001 98.1% 98.1%
- 9. Overall data recovery for the six-year period was approximately 94%, with the lowest recovery during any individual year being 90.8%. Joint frequency distributions wind direction, class and speed were calculated for the six years and found to be comparable on a yearly basis with each other and also comparable to historical joint frequency distribution for data available for the years 1992 and 1993.
- 10. PNPS used the 2001 meteorological data in the 2002 PNPS SAMA analysis that was performed to support license renewal because the 2001 data was both the most complete and the most recent set of data available at the time the SAMA analysis was performed. There is.
nothing atypical or extra-ordinary regarding the meteorological data for 2001, and the data are representative of the meteorological data gathered for the PNPS site.
3
I declare under penalty of perjury that the foregoing is true and correct.
Executed on May 16, 2007.
Fred J. Mogolesko 4
Exhibit 1 Fred J. Mogolesko 508-830-7832 (0)
Summary:
Program manager for the electrical power generation and environmental impact assessment arena. Significant responsibilities include:
- Developing strategic plans, process reengineering, and structuring decisions under uncertainty
- Asset marketing and due diligence
- EPA Regulation 316 a & b regulatory and design concepts
- Technical quality, program management, budgeting, and planning for cross-functional projects
- Power uprate, extended power uprate, and license renewal programs
- Safety, financial risk, and consequence analysis modeling and assessment
- Dispersion modeling of radionuclide and other pollutants in air and. water environments
- Natural hazard characterization (seismic, hurricane, flooding) and assessment
- Regulatory process, prudency review, and emergent issue management
- NEPA 2005.
Education and Certification:
0 Ph.D., Oceanography, New York University
- M.S., Meteorology/Oceanography, New York University a M.S., Aerospace Engineering and Applied Mechanics, Polytechnic Institute of Brooklyn
- B.S., Aerospace Engineering and Applied Mechanics, Polytechnic Institute of Brooklyn
- CCM, Certified Consulting Meteorologist, American Meteorological Society Experience:
1999-Present ENTERGY NUCLEAR OPERATIONS Plymouth, MA Senior Project Manager - Pilgrim Station Managed the development of strategies, processes, and programs to address emerging nuclear industry issues. Specific emphasis focused on calculation enhancement programs, power and extended power uprates and license renewal assessment ($43M Program) and technology adoption related to changing the current licensing bases. Presently in the last stages of managing the Pilgrim License Renewal Program. I was past Chairman of BWROG Committee on instrument uncertanties.
1986-1999 BOSTON EDISON COMPANY Plymouth, MA Senior Project Manager - Pilgrim Station Proposed and managed strategies, programs, and processes in support of economic and competitive generation of electrical power. Represented BECo in the regulatory environment, public forums, and prudency reviews.
- Responsible for the Pilgrim Station design and licensing basis recovery program [$12-17M project].
- Through cross-functional groups of 5 -70 scientists and engineers, managed developmental and technical aspects of key programs, conceiving, implementing, and obtaining win-win outcomes.
- As Chair of the Customer/Marketing Committee, identified threats and opportunities in the external environment, predicting possible impact on Boston Edison Company, 3-15 years into the future.
- Responsible for the Pilgrim Station power uprate and license extension technical and economic assessments.
- As corporate inspection liaison to the NRC and INPO, successfully coordinated 24 major, inspections.
0 Coordinated R&D activities with MIT faculty, EPRI, and BWR Owners Group to develop environmental and risk management tools.
- Evaluated and assessed known natural hazard impacts including full seismic verification (USI-A46), soil-structure interaction, probabilistic fire and seismic risk assessments, hurricane, northeaster wind, site flooding, and aircraft accidents for Pilgrim Station under the IPE and IPEEE Programs.
- Developed a decision support model/process for corporate strategic planning.
- Steered programs of from $1-45M in value to on-target completion, while developing and empowering accomplished professionals.
Developed and utilized tools to assess proposed management policies for Pilgrim Station utilizing market value and options theories. These tools are the foundation for Life Cycle Management and License Renewal.
1977-1986 Principal Engineer/ Division Manager Boston, MA Environmental Sciences Led a diverse professional staff in environmental and radiological programs supporting continued station operation. Focused on regulatory process and environmental risk assessments, developing the foundations for a subsequent severe accident management program, shutdown risk tools, and integrated plant risk models.
1974-1977 STONE AND WEBSTER ENGINEERING CORPORATION Boston, MA Lead Environmental Engineer Developed licensing strategies and oversaw engineering construction of power production facilities, and served as liaison to clients and regulatory agencies. Specialized in regulatory analysis, thermal and radiological dispersion modeling, coastal erosion processes, probabilistic modeling of natural phenomena, and project management.
1968-1972 GEOPHYSICAL SCIENCES LABORATORY New York, NY Research Scientist; Department of Meteorology and Oceanography, New York University Developed circulation and dispersion models of natural and man-made pollutants. Developed hurricane and storm surge progression models. Conceptualized the salvage scenarios for submarine disabled at continental shelf depths.
1964-1968 GRUMMAN AEROSPACE AND EDO CORPORATIONS Bethpage, NY Senior Aerospace Engineer 2
Performed computer-based structural and aero-elastic analyses of aircraft and space vehicles such as the Lunar Excursion Module, the Gulfstream, and the F-I 11 fighter-bomber. Developed anti-submarine warfare strategies.
Additional Experience:
1995 - Present FRW, Inc. and Seamat, Inc.
Senior Vice President FRW and Seamat are technology development corporations specializing in product development utilizing space age thermo-plastics (proprietary and patented processes) for military, environmental, and energy industry requirements.
1977 - Present M&L ENVIRONMENTAL CONSULTANTS Sharon, MA Managin2 Partner Specializes in characterization and analyses associated with air and water phenomena and their potential societal impacts. Expert testimony and due diligence services.
Teaching Experience:
Adjunct Professor, Civil Engineering, Northeastern University, 1982-1984 Adjunct Professor, Geography Department, Boston University, 1978-1980 Lecturer, Physics Department, Brooklyn College, 1969-1971 Organizations:
- Chairman, BWROG Non-LSSS Technical Specifications Instrument Uncertainty Committee e Member, Pilgrim Station Information Technology Steering Committee
- Chairman, Pilgrim Station Severe Accident Management Task Force
- Member, Boston Edison Company Asset Utilization Optimization Task Force 0 Member, EPRI, Life Cycle Management Sub-Committee and EQ Working Group e Member, BWROG, Severe Accident Management and License Renewal Committees
- Member, NEI, License Renewal and Severe Accident Management Committees Member, Pilgrim Station ALARA Committee 3