ML100150761
| ML100150761 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/23/1980 |
| From: | Jordan W, Weiss E Sheldon, Harmon & Weiss, Union of Concerned Scientists |
| To: | NRC/OCM |
| Shared Package | |
| ML100150759 | List: |
| References | |
| NUDOCS 8006260188 | |
| Download: ML100150761 (20) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
)
In the Matter of )
)
CONSOLIDATED EDISON COMPANY )
OF NEW YORK, INC. (Indian Point, ) Docket Nos. 50-247 Unit No. 2) ) 50-286
)
POWER AUTHORITY OF THE STATE OF )
YORK (Indian Point, Unit No. 3) )
)
UNION OF CONCERNED SCIENTISTS' MOTION TO DISQUALIFY COMMISSIONER HENDRIE The Union of Concerned Scientists (UCS) moves that the Commission disqualify Commissioner Hendrie from further participation in any deliberations or decisions by the Commission concerning UCS' Petition for Decommissioning of Indian Point Unit 1 and Suspension of Operation of Units 2 &
- 3. This Motion is based on the likelihood of actual prejudice and the inescapable appearance of prejudice and unfair treatment that stems from Commissioner Hendrie's previous extensive involvement in the consideration of the Indian Point reactors as a member of the Advisory Committee on Reactor Safeguards (ACRS) and as Deputy Director of the Division of Technical Review.
UCS first requested Mr. Hendrie's disqualification at Paragraph 69 of its Petition. This request was ignored both by the Director of Nuclear Reactor Regulation in his Order 800626 0/o' '
-2 of February 11, 1980, and by the Commission in its request for comments on his Order, published on February 22, 1980, at 45 FR 11969. UCS raised the point again in its comments dated March 10, 1980.
Having received no response, UCS wrote the General Counsel on April 15, 1980, asking for a ruling on the disqualification issue before the Commission reached any decisions with respect to UCS' Petition. Relying on a brief memorandum from the Gefteral Counsel, Mr. hendrie notified the parties on April 23, 1980, that he would not remove himself from the case.
Commissioner Hendrie's refusal to recuse himself is ill-advised and contrary to settled law. Since the inte grity of its proceedings is at stake, the Commission as a whole must now rule on UCS' request that Mr. Hendrie be disqualified.
I. Commissioner Hendrie's Previous Involvement in Consideration of the Indian Point Reactors Commissioner Hendrie participated in the Commission's decisionmaking process concerning the Indian Point reactors in two separate and highly influential roles. As a member of the ACRS, and later as Deputy Director for Technical Review, he addressed many of the issues raised by UCS' Petition, and recommended that the reactors in question met all necessary requirements and posed no safety hazard at the Indian Point site.
-3 The extent of Commissioner Hendrie's ACRS activities concerning Indian Point is indicated in the letter of Septem ber 23, 1970, that he, as Chairman of the ACRS, wrote to AEC Chairman Seaborg approving the operation of Indian Point Unit 2 (Attachment 1). As a whole, the letter establishes that Mr. Hendrie reviewed the reactor in detail and reached a personal conclusion that it could be operated safely without posing a threat to :the public health and safety, the fundamental conclusion that is now at issue as a result of UCS' Petition.
More specifically, the first paragraph on Page 3 estab lishes that Mr. Hendrie saw no need for a reactor pit crucible, which was originally proposed to mitigate the consequences of a Class 9 accident. Similarly, on Page 4, Mr. Hendrie referred to what are now termed unresolved safety issues, and saw no need to address them with any urgency. These precise points, and particularly the Class 9 accident miti gation question, have now been raised by UCS and are at issue in this proceeding.
After Mr. Hendrie left the ACRS in 1972, he became Deputy Director for Technical Review. According to his own statement of professional qualifications (Attachment 2), he coordinated and supervised the Technical Review staff in the review and evaluation of power reactor applications in the areas of reactor safety, containment safety, engineering, and site *safety.
His Position Description for that post (Attachment 3) provides greater detail concerning his duties and establishes that he
-4 was responsible for reviewing and approving all staff positions on technical issues of reactor safety. His personal involve ment in and commitment to the staff position with respect to the Indian Point reactors, and particularly to the suitability of the Indian Point site, are ref lecteA in his letter of September 3, 1973, to Mr. Franklin L. Gage (Attachment 4),
in which he defends the reactors and the site in detail, arguing specifically at the bottom of Page 2 that safe evacuation will be possible in the event of an accident.
These site suitability and evacuation feasibility issues are now directly before the Commission pursuant to UCS' Petition.
In addition to the involvement reflected in Mr. Hendrie 's letter to Mr. Gage, Mr. Hendrie must also have been involved in and approved two significant actions with-respect to Indian Point by virtue of his position as Deputy Director.
First, the Safety Evaluation Report on Indian Poi nt Unit 3 was issued in September 1973, during his tenure as Deputy Director. That document represents the staff 's position approving the reactor, which would, in effect, have been recommended by Mr. Hendrie to his superior, the Director of Licensing. Second, although Unit 2 was granted an Operating License in October 1971, steady state full power operation has not permitted until September 1973. This delay and eventual start-up involved the resolution of serious questions within the scope of responsibility of the Deputy Director.
In a Memorandum to Counsel for the Parties of October 20, 1977, Mr. Hendrie effectively admitted his involvement
-5 in making recommendations to his superiors concerning the Indian Point reactors, stating, Although I was not directly and personally involved in any of the licensing proceed ings for Indian Point 2, I received and reviewed technical reports on Indian Point 1, Indian Point 2, and Indian~ Point 3 and reported to my superiors on these facilities.
A copy of the papers in my file on Indian Point is attached.
It should be noted that the memorandum states only that the papers in Mr. Hendrie's file concerning the reactors were attached. It makes no claim that those are all of the papers relevant to his involvement or that they tell the whole story.
Further investigation by the Commission would be necessary to know the precise details.
II. Fundamental Considerations of Due Process Require That Commissioner Hendrie be Disqualified From this Proceeding.
The requirement that a Federal agency official be dis qualified from presiding over a decision where he has previously addressed the same questions in a prosecutorial, investigatory, or advisory role is by now well established.,
In Amos Treat &'COjnc.,v. SEC, 306 F. 2d 260 (D.C. Cir.
1962), for example, the Court ruled an SEC decision invalid on the ground that one of the Commissioners involved in making the decision had been a member of the SEC staff when it began the investigation of the company in question. Much like Mr. Hendrie, the Commissioner had been in charge of the division that was "'responsible to the Commission for the initiation, conduct, and supervision" of the proceeding. .In
language that is reflected throughout the case law, and that must govern here, the Court held, Enough has been said to demonstrate the basis for our conclusion that an administrative pro ceeding of such importance and vast potential consequences must be attended, not only with every element of fairness, b'dt with the very appearance of complete fairness. Only thus can the tribunal conducting a quasi-adjudicatory proceeding meet the basic requirements of due process.
1/
Id. at 267. See American General Insurance Co. v. FTC, 589 F. 2d 462 (9th Cir. 1979), Trans World Airlines, Inc. v.
CAB, 254 F. 2d 90 (D.C. Cir. 1958).
Both the fact and appearance of lack of fairness are involved in this case. Commissioner Hendrie was involved in decisions concerning both the basic policies and the factual findings that allowed these reactors to be licensed and to continue operation in the face of the hazards that UCS has raised in its Petition. He can hardly be expected to have forsaken his past commitments. Even if he has, however, and as he stated in his Memorandum of April 23, 1980, he believes he will be unbiased, the serious appearance of bias and unfairness necessarily remains.
1/ The Court also criticized the SEC's denial of the com pany's request that it should take evidence on the question of whether the Commissioner should be dis qualified, and it ordered that a permanent injunction would issue unless the Commission held an evidentiary hearing and showed why the Commissioner should not be.
Accordingly, if the Nuclear Regulatory Commission has any doubt that Mr. Hendrie should be disqualified, it must hold an evidentiary hearing to determine the full extent of his involvement in Indian Point.
Mr. Hendrie's decision to remain in this proceeding was based largely on a Memorandum of April 21, 1980, in which the General Counsel presented four reasons that recusal was not required. The first two are legally irrelevant or incorrect, and the last two'reflect a treatment of the facts that is inconsistent with the regulations and applicable case law.
The first point is that the UCS Petition is a "new matter," and is not a continuation of an adjudication in existence when Mr. Hendrie was a member of the NRC Staff.
While that statement is technically accurate in that the UCS Petition instituted a new formal legal proceeding, it is irrelevant. In terms of the factual questions now before the Commission and the fundamental issue of the safety of, the Indian Point reactors at that site, this matter has been before the Commission for a decade, and Mr. Hendrie has been involved throughout. The General Counsel's technical legalistic argument must give way to the underlying reality of Commissioner Hendrie's previous involvement. American Cyanamid Company v. FTC, 363 F. 2d 757 (6th Cir. 1966), (FTC Chairman's involvement in investigation in previous position as Senate Subcommittee Chief Counsel requires disqualifica tion when FTC later considers the same facts and issues, although forum is entirely different.)
In his second point, the General Counsel relied on Porter County Chapter of the Izaak Walton League v. NRC, 606 F. 2d 1363 (D.C. Cir. 1979), for the proposition that the
-8 staff is presumed to be unbiased, so that disqualification is not required. That case involved an entirely different situation in which the staff itself was, in effect, asked to reverse its position. The Court held that since the Director of Nuclear Reactor Regulation was not -itting as a judicial officer in ruling on that request, the standards for dis qualification of such officers did not apply. Since Mr.
Hendrie would be sitting as a judicial officer in this case, the Porter County case is irrelevant.
The last two points in the advice given to Mr. Hendrie are that the record does not show an "irretrievable commit ment" on the issues before the Commission, and that Mr.
Hpndrie's involvement occurred many years ago. The first of these points is of no help because "irretrievable commitment" is not the standard by which recusal is to be judged..' Rather the standard is one of previous involvement in an advocacy or advisory role and, more importantly, one of the appearance, not the fact, of prejudice. These standards are met here.
The final point that the passage of time vitiates any bias is refuted by a Commission regulation governing the analagous situation of former employee involvement in matters before the NRC. 10 CFR 0.735.26 prohibits any former NRC employee from representing anyone other than the United States with respect to a matter in which he participated personally and sub stantially as an employee, through decision, approval, recommendation, the rendering of advice, investigation, or otherwise, while so employed.
0 0
-9 Mr. Hendrie was involved in approval, recommendation, advice, and investigation with respect to the Indian Point reactors.
He would be precluded from everrepresenting the utilities on these issues. Similarly, he is precluded from judging the issues in which he was previously involved. There can be no time limit on that prohibition.
Finally, the requirement that Mr. Hendrie be disqualified is reflected in the Commission's regulations at 10 CFR 2.719(d), which states inter alia, that
[I]n any case of adjudication, no officer or employee of the Commission who has engaged in the performance of any investigation or prose cuting function in the case of a factually related case may participate in the initial or final decision, except as a witness or counsel in the proceeding.
Commissioner Hendrie was responsible for the Staff's investi gation and the Staff's position with respect to Indian Point when he was Deputy Director for Technical Review. This regulation specifically precludes him from participating in any decisions concerning the Indian Point reactors.
CONCLUSION For the reasons stated above, UCS requests that the Commission as a whole rule that Commissioner Hendrie be disqualified from participation in this proceeding. UCS further requests that the Commission expedite its decision on this matter so that UCS will have an opportunity to
0 0
-10 appeal to the Court of Appeals, if that should be necessary, before the Commission reaches any substantive decisions concerning UCS' Petition.
Respectfully submitted, Ellyn'-R. Weiss General Counsel to UCS William Sc Jordan, III Harmon & Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C. 20006 (202) 833-9070 Dated: -... &?-
-88 APPENDIX B ADVISORY COMMITFTEE ON P.EACTfOR SAFEGUARDS UNITED STATES ATO'MIC ENERGY CMMISSIO.N WASHINGTON, D.C. 20545 SEP 2 3 1970 Honorable Glenn T. Seaborg Che irman U. S. Atomic Energy Commission Washington$ D. C. 20545
Subject:
REPORT ON II)DIAN POIN4T IVUCL&'A GESMBATIRC UNIT No. 2
Dear Dr. Seaborg:
At its 125t!2 meetings September 17-19, 3.970, the Advisory Committee on F-eactor Safeguards. completed its reviewof th pltaiz-by Consoli dated Edisoa Company of Niew York, Inc., for authorizatien to operate the Indian Point Th4clear Generating Unit No. 2. This project. had, pre viously been considered at the Committee's 95th, 96th, .122nd, and 124th meetings, an& at Subcommittee meetings on August 23, 1969,.A'arch.13, 1970, April 25, 1970, Miay 28, 1970, July 2b-29, 1970, and.September 15, 1910. Subco~unittees also met at the site on December 28, 1967 and M~ay 1L.1970.~ The Comittee last reported on this project to youx on August 16, 1966. During the review 9 the Cc~ittee had the benefit of diseussions with. representatives of the Congo lida t.nd Edison Compauy and their con~tractors and consultants, and with represetatives of the ABC Regulatory Staff. The Con ittee also had the be~iaftt of tha doctm nts listed.
Tbe Indian. Point sate is located in Westchester County, Not; Ycrk, approx imataly 24 niiies north of the New York City -limits.* Thea minimum radius of the exclusion area for Unit N~o. 2 is 520 mittere and Peekkill, the nearceot population canter, is appro:-xiately oiic-balf mile frbm the unit.
Also at .thirs site are lnd-icu Poiut Unit 1, Lhich is licensed forZ opera tion at 615 Iiit, and Unit 3, v'hicb' in under canstru' tiuu.
Thea applicant haa re-evaluate4 floo.~ing thot could ccur at the site in the event of Lhe prz)'able ratlxiaum LI"'rriccane and flvod. in the lisght of more rece~nt inforiation, and has vonclud.ed tbhit c:.iate protection extste for vi1tal co- ponerits and services.
Additional scismic rcoinforcenment b~ein~g provieed for the Ineian Point Unit 11.o. 1 ;parlhnat2!r building and reorivil of L*h-e tcqp 80 ft. of -the
~
sup_-rvr:te-: ztack wil'l. ena!MG. the stack to wiv.~i wds in the range.
of 300-360) rph correvpond ing Lo current tornar1o der1s.'n criteria. Since 8006260
S. S
-89 Honorable Glean T. Seaborg - 2 - SEP 23 17970 the reinforcement of the superheater building, which supports the stack, enables the stack to resist wind loads of a mxagnitude most likely to be experienced from a tornado, the Committce believes that removal of the top 80 ft. of the stack, to enable it to resist the maximm effects from a tornado, may be deferred until a convenient time during the next few years, but prior to the commencement of operation of Indian Point Unit No. 3. The applicant has stated that truncation of the stack will have no significant -adverse effect on the environment..
The Indian Point Unit No. 2 is-the first of the large, four-loop Westing house pressurized water reactors to go into operation, and the proposed power level of 275S Mi t will be the largest of any power reactor licensed to date. The nuclear design of Indian Point Unit No. 2 is similar to that of H. B. Robinson with the enception that the initial fuel rods to be used in Indian Point Unit No. 2 sill not be prepressurized. Part length control rods will be used to shape the axial pcwer distribution and to suppress axial xenon oscillations. The reactor is designed to have a zero or negative moderator coefficient of reactivity, and the applicant plans to perform tests to verify that divergent azimuthal Ve.non oscillations cannot occur in this reactor. TheCommittee recommends that the Regulatory Staff follow the measurements and analyses related to these tests*
Unit 2 has a reinforced concrete containment with an internal steel iner Vhich is provided .Ath facilities for continuous pressurization of weld and penetration areas for leek detection, and a seal-water system to back up piping isolation valves. In the unlikely event of an accident, cooling of the containment is provided by both a contaiuvamnt spray systers and an eir-recirculation system with fan coolers. Sodiu hydroxide additive is used in the contaim-ent spray system to rexaove elemental iodine from the peot-accldent containrMent atmosphore. An impregnated charcoal filter is provided to remo-ve organic iodine.
Major changes have bcnixmade in thi design of the cmergenacy tore cooling system as origln.lly propoced at tb': tLa of the construction permit re view. Four accu:, uiatous are provided to rccoalpli;h rapid reflooding of the core in the t nlik2ly event of a large pipe bre.sk, and redundant paps ore included to -,maintain long-terr core cooling, The applicant has analyzed the effica-cy of th. ;ergcmcty core c: oiig system and concludes that the system TA-.l haep thme co;:o intact rnd the pe!'k clad temperature well below the point -;her- :ir ioy-.zzer reacti.n ?ight have an adverse affect on cl.d d.ctii.Ly and, h~nc. , on #h-. contintuzd structural integrity of the fuel element- T, z Co tee believes th--ut there. ia reasonable assuramce that th.e "Indien Point Vit. No. 2 e., rc "ncy core cooling systema will perform adeqcuately rt the, profozcd pmt:r kel.
-90 Honorable Glenn T. Seaborg SEP 2 3 1970 The Comittee concurs with the applicant that the reactor pit crucible, proposed at the time of the construction perait review, ig not essen tial as a safety feature for Indian Point Unit io. 2 end need not be in cluded.
To control the concentration of hydrogen whlch could build up in the containment following a postulated loss-of-coolznt accident, the appli-.
cant has provided redundant fla7.e recc,..biner units within the contain ment, built to engineered safety feature standards. Provisions are also included for. adequate mixing of the 'atmosphere. and for s.napling purposes.
The capability exists also to attach additional equipment so as to permit controlled purging of the containment atmosphere with iodine filtration, The Committee believes that such equipment should be designed and provided in a manner satisfactory to the Regulatory Staff during the first two years of operation at power.
The applicant plans to install a charcoal filter systera in the refueling building to reduce the potential release of radioactivity in the event of damage to an irradiated fuel assembly during fuel handling. This in..
stallatior will be completed by the end of the first year of full power operation.
The reactor instrumentation includes out-of-core detectors, fuel assembly exit thermocouples, and movable in-core flux monitors. Power distribution heasuremants will also ordinarily be available from fixed in-core detec tors.
The applicant has proposed that a limited nunber of manual resets of trip points, made deliberately in accordance with explicit procedures, by approved personnel, independently monitored, end with settings to be cali brated and tested, should provide an accepteble basis for the occasional operation of IndLan Point Unit ho. 2 with only three of the four reactor loops in service. The Committee conure in this position.
The applicant stated that neutron noise rteasure.zents will be made period ically and analyzed to provide developmental infor atien concerning the possible usefulness of this technicue in iscer~aining cllha in core, vibration or other displacements. On a similar basis, accelerometers will be intnllsd on the pressure vessel and steani gei-rators to ascertain the practicality of their use to detcct the presence of loose par*s.
Me reactor includes a delayed neutron, monitor in one hot leg of the re actor coolant system to detect fuel elemcnt failure, Suitable operability requirements will be maintained on the sevcral ser.aitive mveans of primnry system leak detectioa.
-91 Honorable Glenn T. Sadborg SEP 2 3 1970 A conservative raethod of defining pressure vessel fracture toughness should be employed that is satisfactory to the Rulzatory Staff.
The applicant stated that existing experi.mantal results and analyses provide considerablo assurance t-at high burnup fuel of the design employed will be able to u..dergo anticipated transients and power per turbations without a loss cf clad integrity. le also described addi tional experiments and analyses to be performed in the reasonably near future which should provide further assurance in this regard.
The Committee has, in recent reports on other reactors, discussed the nee4 for studies on further mears of preventing comnon failure modes from negating scram action, and of possible desl.gn features to make tolerable the consequences of failure to scram during anticipated tran siente. The applicant has provided the results of analyses. which lie be lieves indicate that the consequences of such transients are tolerabla with the existing Indian Point Unit No. 2 desi n at the proposed power level. Although further study is required of this general question, the Ccmittee believes it acceptable for the In-J.an Point Unit Vo. 2 reactor to operate at the proposed power level while final resolution of this matter is made on a reasonable ti-e scale in a manner satisfac tory to the Regulatory Staff. The Co-mittee wishes to be kept advised.
Other matters relating to large water reactors which have been identi fled by the Regulatory Staff and the ACRS and cited in previous ACRS letters should, as in the case of other reactors recently reviewed, be dealt with appropriately by the Staff and the applicant in the Indian Point Unit No. 2 as suitable approaches are developed.
The ACRS believes that, if due regard is given to tho itens recommended above, and subject to satisfactory comletioa of construction and preop erational testing of Indian Point Unit No. 2, there is reaspnable ausr ance that this reactor can be operated at power levels up to 2758 12t without undue risk to the health an4 safety of the public.
Sincerely yours, Original bigned by Joseph M. Hendrie J beph Ii.flcndrie Chairman References attached.
0
-92 Honorable Glenn T. Se-borg SEP 2 3.1970 References - Indian Point Nuclear Gnerating. Unit P o. 2
- 1. Amendment Do. 9 to Application of Consolidated Edison Company of Vew York for Indian Point Nuclear Generating Unit No. 2. consisting of Volues I - IV, Final Safety Analysis Report, received October 16s 1968 Amendments 10 - 20 to the License Application Amendments 22 - 24 to the License Application
.(!JSEPH M-. PE!lDRIE9 JAttac 2 /PROFESSIONAL QUALIFICATIONS I am rz,, _ /Director of Licensing for Technical Review, U. S.
Atomic Energy Commission. I have held this position since Hay 1972.
In this position I coordinate and supervise the Technical Review staff in the review and evaluation of power reactor applications in the areas of reactor safety, containment safety,- engineering, and site safety. These functions include development and administration of programs and-policies governing the licensing and authorization of nuclear reactors in the United States.
From 1955 to 1972 I was employed at Brookhaven National Laboratory at Upton, New York. At Brookhaven I was a?Senior Physicist. and Head of the Engineering Division of the Department of Applied Science. I have held other positions at Brookhaven Laboratory, including.Chairman of the Steering Comittee and Project Chief Engineer of the High Flux Beam Reactor Project, acting Head of the Expdrimental Reactor Physics Division, and Project Manager of the Pulsed Fast Reactor Project. My work at Brookhaven has included
- - -. reactor physics research, the design and construction of research
. reactors and the expezirental facilities for these Tnachines, desigu of high-strength concrete structures, reactor safety analysis, blanket and magnet development for fusion pcwer machines, 'and develop ment of cryogenic -cables for electrical power -transmission.
-I was a member of the Advisory Commnittee on Reactor Safeguards irm 1966 until 1972 and was Vice Chairman of the Co-.ittee in 1969 and
" Chairman in 1970. .I was consultant to the Radiation Safety Comittee of Columbia University from 1964 until 1972... .
I lecture on nuclear power plant safety at summer courses -of such institutions as the Georgia Institute of Technology and Massachusetts Institute of Technology.
I was educated at Case Institute of Technology, where Ireceived the Bachelor of Science degree in physics in 1950, and at Columbia University, where I received the Ph.D. in physics in 1957. I am a Fellow of the American Nuclear Society and a member of the American
-. Physical Society, the American Society of Mechanical Engineers, the American Concrete Institute, and the Institute of Electrical and Electronic Engineers. I received the Com.-.iission's E. 0. Lawrence Award in 1970 for my work in the physics and engineering of research reactors and the safety of power reactors. I am a registered Professional Engineer and a member of the National Society of Professional Engineers, the New York Society of Professional Engineers, and the Maryland Society of Professional Engineers.
Attachment 3.
Deputy Director for Technical Review Directorate of Licensing GS-18 PURPOSE OF POSITION The Deputy Director for Technical Review, Directorate of Licensing, conducts, for the Director, the review and evaluation of power reactor applications in the area of reactor safety, plant safety and site safety. These functions include the development and administration of the programs and policies governing the licensing and authorization of nuclear reactors other than for export.
TECHNICAL KNOWLEDGE:
A broad technical knowledge of the scientific and professional fields involved in reactor design. construction and operation including nuclear physics, mechanical engineering, chemical engineering, as well as extensive experience in thefield of nuclear reactor design, construction, and operation.
. Specialized S p knowledge is also required to implement-safety and environmental standards, codes and guides for the purpose of assuring, to the maximum extent, that the design, -construction and operation of such facilities will not endanger the heal.th and se- :o6f . pu lc . .........
AD IrISTRA-TION:
As-. ..... Dir"ector for Technical Review, Directorate of Licensing
- -........conducts the following actions-on behalf of. the Direc tor.-:
Review and evaluation of reactor thermal hydraulic design; reactor coolant system design and associated auxiliary system design; emergency core cooling systems design.
Review and evaluation of: seismic and pipe whip design criteria; mechanical design of reactor vessels, reactor core supports, reactor fuel, reactor cool ant. pumps, steam generators, reactor coolant piping, pressurizers and component supports; seismic Category I mechanical components, and ASME Code Class 2 and 3 components'
Deputy Director for Technical Review Di rec torate of .Licensin '
GS-18 - -
Page 2 Materials evaluation of coinponents of the reactor coolant pressure boundary and ASME Class 2 and 3 components. Performs technical reviews, analyses, and evaluation of the materials and fabrication of nuclear power plant components and systems.
Review and evaluation of the design of instrumen and electric power systems; and the nuclear design'of reactors.
Reviews Conduct of Operations and Preoperational and Safety Sections of Safety Analysis Reports, security; conducts periodic and including industrial special reviews and analyses of operational aspects of reactor safety for all licensed power, and research reactors; prepares test guidelines for the evaluation the administrative aspects of reactor of activities with' regard to emergency operation; coordinates
-reactor safety aspects of proposed and disaster planning; reviews berthing of nuclear powered
. warships.
. Reviews reactor license applications and related documents to evaluate the auxiliary and power conversion systems.
Reviews -reactor license appliain
- -. -Reviews
.eval ea tr .i e icat ons and rela ted documents to u ate-thec.ojtainment-.system -an'd associaed suSYStes
..... ncl.din..such.. actors.as.heat isolationequi prment and con rols, rem-,oval, heating and ventilation and combustibl e gas.cotrol,.
Review"- andeva.uates sle'desi
-.ands eel: containments,:-.-desin criteria; esignof concrete..
9-of _ther a tegory I plant structe .
Perors technical reviews, analyses, and design, construction and operation evaluation o h of nuclear power plant structures.
Reviews reactor license applications the Commission's quality assurance to assure compliance with construction and operation; reviews
... criteria during plant design, and develops technical speci fications, for reactor facilities.
Reviews reactor license applications equipment for fission product removal to evaluate plant systems and.
and-the treatment of radioactive
Deputy Director or TOccImical Review Directorate of LicenZing GS-18
. ____Page 3 waste, including the development of analytical models, assumptions and calculated methods for evaluating the effectiveness of proposed systems.
Reviews reactor- license applications to evaluate the consequences of postulated accidents; develops and prepares accident analysis for incorporation in environmental statements.
Reviews reactor license applications to evaluate site adequacy, hy including such factors as geography, demography, meteorology, drology, geology, seismology, and the problems posed by nearby industrial, transportation and military facilities; evaluates adequacy of protection for on-site personnel.
on Assessment of the radiological impact of licensee facilities the environment, including potential pathways for exposure to man and biota; develops and prepares radiological evaluations for
- environmental statements; develops technical specifications for off-si te measurements.
Provides specialized expertise in assessing the benefits of nuclear facilities and balancing these against the costs of environmental
- ipact;.develops related guides and methologies; and prepares the..
benefi-t/co0st ,!por-tions of .the.AE.e rnmeal s. tatze,,ents on the 27 aciltes. -
- ~~ Jj7--r
~ ~ - 'V p72.
iz.geiizdehnca. - xperci-se::on!_n S-. - .---- ,-environmental .tLchnica disciplines; d ev e.o ps. ten
- . for preparation of. environmental reports by. a ppl icants-and
-.envi ronmentastatements-.by REG- and l aboratori es..
" CONTACTS:
Contacts are with the Director, Directorate of Licensing, the
- Director of Regulation and his staff, representatives of private industry, other Government agencies and other AEC personnel for the purpose of managing and conducting the above functions. Daily and contact with his Assistant Directors to issue assignments instructions, to secure information, and to follow-up on activities of the various offices.
Deputy Director for Technical Review Directorate of Licensing GS-18 Page 4 RESPONSIBILITY FOR DECISIONS Supervision Received:
Director, Directorate of Licensing , GS-18. Work is reviewed for over-all adequacy..
Independent Action:
Reviews the overall performance of those organizational units reporting to him for accuracy and completeness.
Review incoming correspondence, documents and technical assignments; detrmines order of priorities, and issues assignments.
Prepares important correspondence not requiring a major policy decision for the signature of the Director, Directorate of Licensing, or the Director of Regulation, as appropriate."
lakes appointments , schedules meetings and conferences.
- ". Perfors research a.s needed to present completed staff work and-...
Cororinsareseadhsuevsstepeaaino ao Icydmnt).
.SUPERVISION . . . . -
Supervises the Assistant Director for Reactor Safety, Assistant Director for Containment Safety, and Assistant Director for Site Safety.
WORKING CONDITIONS:*
Nornal EFFORT:
Normal.