ML101410744
| ML101410744 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/14/2010 |
| From: | Lampert M Pilgrim Watch |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-293-LR, ASLBP 06-848-02-LR, RAS J-226 | |
| Download: ML101410744 (18) | |
Text
DOCKETED ,PAS s-2,Z 6 USNRC May 14, 2010 (9:46a.m.)
OFFICE OF SECRETARY RULEMAKINGS AND UNITED STATES OF AMERICA ADJUDICATIONS STAFF NUCLEAR REGULATORY COMMISSION BEFORE JUDGE PAUL B. ABRAMSON THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: Docket No. 50-293-LR ASLBP No. 06-848-02-LR ENTERGY NUCLEAR OPERATIONS, INC.
(Pilgrim Nuclear Power Station)
License Renewal Application May 14, 2010 MOTION ON BEHALF OF PILGRIM WATCH FOR DISOUALIFICATION OF JUDGE PAUL B. ABRAMSON IN THE PILGRIM NUCLEAR POWER STATION RE-LICENSING PROCEEDING I. INTRODUCTION Pursuant to 10 C.F.R. §§ 2.313(b)' and 2.323, Pilgrim Watch moves that Administrative Judge Paul B. Abramson disqualify himself from participating as a member of the U.S. Nuclear Regulatory Commission's ("NRC's") Atomic Safety and Licensing Board ("ASLB") for the renewal of Entergy Nuclear Operations Inc.'s ("Entergy's") operating license for the Pilgrim nuclear power plant.
Judge Abramson should disqualify himself because of (i) his previous work on and personal knowledge of the MACCS2 code (the code was used by Entergy to perform their
§ 2.313. Designation of presiding officer, disqualification, unavailability, and substitution. (b)
Disqualification. (1) If a designated presiding officer or a designated member of an Atomic Safety and Licensing Board believes that he or she is disqualified to preside or to participate as a board member in the hearing, he or she shall withdraw by notice on the record and shall notify the Commission or the Chief Administrative Judge, as appropriate, of the withdrawal.
2 required Severe Accident Mitigation Analysis (SAMA), and (ii) his apparent bias relative to Pilgrim Watch's expert witness, David Chanin. The MACCS2, the computational code with respect to which Mr. Chanin is an expert, is central to this entire adjudication proceeding brought forward by Pilgrim Watch in Contention 3 and to the issues remanded by the Commission to the Board (CLI-10-1 1).
As required by 10 C.F.R. § 2.313(b) and Hope Creek,2 Pilgrim Watch submits our motion to Judge Abramson rather than the full ASLB. The motion is founded on statements by Judge Abramson himself during the May 4, 2010 Teleconference call attended by the full ASLB panel, parties to the Pilgrim license Renewal proceeding (Entergy, NRC Staff and some witnesses). Pilgrim Watch is providing a declaration, together with a copy of the pertinent page of the transcript of that hearing.
II. ARGUMENT A. Standard for Disqualification of NRC Judges The NRC follows 28 U.S.C. § 455's standards for the disqualification of judges. 19 NRC at 20. Suffolk County and State of New York Motion for Disqualificationof ChiefAdministrative Judge Cotter (Shoreham Nuclear Power Station, Unit 1), LBP-84-29A, 20 NRC 385, 386 (1984),
citing Houston Lighting and Power Co. (Allens Creek Nuclear Generating Station, Unit 1), CLI-82-9, 15 NRC 1363, 1365-67 (1982); see also Hydro Resources, Inc., (2929 Coors Rd. Suite 101, Albequerque, NM) CLI-08-9, 47 NRC 326, 331 (1998). ASLB judges are governed by the same disqualification standards as federafljudges. Relevant portions of Section 455 provide that:
2 Public Service Electric and gas Company (Hope Creek Generating Station), ASLB-759, 19 NRC at 21 n.26 (1984) ("Hope Creek")
3 (a) Any justice, judge, or magistrate3 of the United States shall disqualify himself in any proceeding in which his impartiality might reasonably be questioned.
(b) He shall also disqualify himself in the following circumstances:
(1) Where he has a personal bias or prejudice concerning a party, or personal knowledge of disputed evidentiary facts concerning the proceeding; Any ground for disqualification under subsection (b) cannot be waived.
B. Judge Abramson should disqualify himself because, "he ... has personal knowledge of disputed evidentiary facts concerning the proceeding."
During the Teleconference call, May 4, 2010, Judge Abramson said, ADMIN. JUDGE ABRAMSON: Let me ask you to submit Shannon's [corrected spelling, Chanin's] resume because I don't believe he wrote the code. I was involved with a lot of that 5
personally.
The MACCS2, the computational code, is central to the entire proceeding on Pilgrim Watch's Contention, the issues remanded by the NRC Commission to the Board (see Commission Order CLI 11), and by the Board's May 4 reading of the Commission's Remand Order, CLI-10-11. For example, the Commission's Remand clearly said that Contention 3 addresses Entergy Environmental Report's SAMA analysis for the Pilgrim facility (CLI-10-11, at 3); that Entergy's SAMA analysis utilized the MACCS2 code to evaluate the off-site consequences (population dose and economic costs) of a radioactive material release to the environment from severe accidents (CLI- 10-11, at 4); and that the issues before the ASLB on remand include the adequacy of the MACCS2 code (CLI 3 In 1990 the term "magistrate" was changed to "magistrate judge." Pub. L. 10 1-650.
4 28 U.S.C. § 455 (e) No justice, judge, or magistrate shall accept from the parties to the proceeding a waiver of any ground for disqualification enumerated in subsection (b). See Hope Creek, 19 NRC at 20.
5Neal R. Gross & Co., Inc., page 665, lines 8-11, Attachment A.
4 11, at 14.1) Judge Abramson's statement makes clear that he has personal knowledge of the code that helped develop, and that he has (or at the very least reasonably appears likely to have) his personal views of its adequacy. Thus, Judge Abramson should disqualify himself because, "he ... has personal knowledge of disputed evidentiary facts concerning the proceeding."
C. Judge Abramson Should Disqualify Himself Because His Actions Would Cause a Reasonable Person to Question his Impartiality and that he has a personal bias or prejudice concerning a party Judge Abramson's statement (quoted and referenced above) that "let me ask you to submit Shannon's resume because I do not believe he wrote the code" clearly would cause a reasonable person to question Judge Abramson's impartiality and whether he has a personal bias or prejudice concerning Mr. Chanin, Pilgrim Watch's expert witness. No other participant on the Teleconference call, neither Entergy nor NRC Staff, raised any question as to the credentials or competence of David Chanin, 6 only Judge Abramson. Judge Abramson's statement creates the appearance that, without any evidence other than his personal knowledge, Judge Abramson doubts the credibility of David Chanin and would discredit any evidence that he provides for Pilgrim Watch in this proceeding.
The May 4, 2010 telephone conference is the first time that the Petitioner was made aware of Judge Abramson's involvementwith the MACCS2 and personal knowledge of disputed evidentiary facts concerning the proceedings.
6 With respect to Mr. Chanin's credentials, attached to Pilgrim Watch's declaration are copies of cover pages of the Code Manual for MACCS2:Volume 1, User's Guide and cover NUREG/CR-6613, Vol.2; Mm. Chanin's resume (that was previously submitted to the Board (Pilgrim Watch Answer Opposing Entergy's Motion for Summary Disposition of Pilgrim Watch Contention 3, June 2007, Adams ML071840568); and a page from the Board's summary disposition decision in which Judge Young says that, " David Chanin, who states that he 'was the primary developer of the MACCS and MACCS2 computer codes under sponsorship of the U.S. NRC and DOE while working at Sandia National Laboratories 1982-1996"' (Attachment B)
5 IV. CONCLUSION For these reasons, Judge Abramson should disqualify himself from participation in this proceeding as a member of the ASLB. Pilgrim Watch requests that until this issue is resolved, a stay is placed on these proceedings.
In conformance with 10 C.F.R. § 2.323(b), and as discussed in the attached Certification of Counsel, counsel for Petitioners contacted counsel for Entergy and the NRC Staff. Counsel for Entergy said that they would oppose the Motion; whereas Counsel for NRC said that they would not take a position on this motion until they had an opportunity to review it.
Respectfully submitted, Electronicallysigned by Mary Lampert Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332 May 14, 2010 CERTIFICATION BY PILGRIM WATCH'S REPRESENTATIVE PURSUANT TO 10 C.F.R. § 2.323(b)
Pursuant to 10 C.F.R. § 2.323(b), I certify that on May 14, 2010, I contacted counsel for Entergy and NRC Staff. Counsel for Entergy said they would oppose the Motion; whereas NRC Staff Counsel said that they would not take a position on the motion until they had an opportunity to review it.
tiA4
6 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before Judge Abramson The Atomic Safety and Licensing Board In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application May 14, 2010 DECLARTION OF MARY ELIZABETH LAMPERT IN SUPPORT OF PILGRIM WATCH'S MOTION FOR DISQUALIFICATION OF JUDGE PAUL ABRAMSON IN THE PILGRIM NUCLEAR POWER STATION RE-LICENSING PROCEEDING I, Mary Elizabeth Lampert under penalty of perjury declare that I was a Participant on the May 4, 2010 Teleconference Call attended by the Atomic Safety Board Licensing Panel for the Pilgrim re-licensing Proceeding (Judge Ann Marshall Young, Judge Richard Cole, Judge Paul Abramson); representatives from the Parties to the proceeding (e.g., Entergy, Pilgrim Watch, and the Town of Plymouth); and some of the witnesses in the proceeding. The Teleconference call began at 1:00. During the call, I heard Judge Abramson say, "Let me ask you to submit Shannon's 7 resume because I don't believe he wrote the code. I was involved with a lot of that personally." His statement is affirmed by the attached copy of the pertinent page of the official Transcript prepared by Neal R Gross and Co., Inc. (NRCCO) Court Reporters and Transcribers.
I have also attached copies of cover pages from a DOE and NRC document; Mr.
Chanin's resume as it appears on his website and an extract from Judge Young's dissenting opinion of October 30, 2007.
7 "Shannon" is an incorrect spelling; the correct spelling is "Chanin"
7 I declare that under penalty of perjury and to the best of my knowledge, the foregoing is true and correct.
Mary Elizabeth Lampert 148 Washington Street Duxbury, MA 02332 Email: mary.lampertcomcast.net May 14, 2010
8 ATTACHMENT A Pagec 55'?
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9
[Note that page 665 is a pasted copy; a scan would not copy; the scan is provided by mail]
Page 665 1 Shannon goes to site restoration costs.
2 MS. LAMPERT: Well, no. Shannon, 3 remember, he wrote the code, so I think he goes to 4 quite a few things.
5 MR. LEWIS: Okay.
6 MS. LAMPERT: And Lyman and a couple of 7 the others can --
8 ADMIN.. JUDGE ABRAMSON: Let me ask you to 9 submit Shannon's resume because I don't believe he 10 wrote the code. I was involved with a lot of that 11 personally.
12 MS. LAMPERT: Okay. I'd be more than 13 happy to.
14 CHAIR YOUNG: Let me just ask--
15 COURT REPORTER: Who was that?
16 CHAIR YOUNG: That was Judge Abramson and 17 Ms. Lampert. Ms. Lampert, which of your experts are 18 not going to be available until September again?
19 MS. LAMPERT: The two on the telephone.
20 CHAIR YOUNG: Oh, Egan and Qndersen?
21 MS. LAMPERT: Correct.
22 CHAIR YOUNG: Okay, all right. Correct me 23 if I'm wrong, but I think that what we need to get 24 from the parties at this point are, first, indications 25 whether you would like to have a settlement judge Neal R. Gross & Co., Inc
10 ATTACHMENT B David Chanin's resume is provided on his website http://chaninconsulting.com; a copy of it was previously submitted to the Board (June 2007) and is below. Additionally a search of the Office of Scientific and Technical Information (OSTI's) website will indicate that Mr. Chanin wrote the preprocessor codes FGRDCF, COMIDA2, IDCF2, and DOSFAC2 that were included in the code package, e.g.:
t)
SANDIAIREPORT SAND97-0594 e UCG-610 Unlimited Release PrintedMarch :1997 Code Manual for MACCS2: Volume 1, I USer's Guide p
h Dlavid 1,Chanin, Mary L Young i ~Cajit-g 04550-I ~1E~y~C-oyt, DF-AC04 PW94Aiabi ii i,
I Lo Sadi National Laboratories, H g
2" s*
22
11 NUREG/CR-6613, Vol. 2 SAND97-0594 Code Manual for MACCS2 Preprocessor Codes COMIDA2, FGRDCF, IDCF2 Manuscript Completed April 1998 Date Published: May 1998 Prepared by D. Chanin Technadyne Engineering Consultants Albuquerque, NM 87112 M.L. Young Sandia National Laboratories Albuquerque, NM 87185 J. Randall, NRC Project Manager K. Jamali, DOE Project Manager Prepared for Division of Systems Technology Office of Technical and Environmental Support Office of Nuclear Regulatory Research Defense Programs U.S. Nuclear Regulatory Commission U.S. Department of Energy Washington, DC 20555-0001 Washington, DC 20585 NRC Job Code W6231 USDOE Contract DE-AC04-94AL8500 https://radtran.sandia.gov/docs/SAND97-0594.pdf
12 The following two attachments are part of the record in this proceeding: David Chanin's Resume attached to Pilgrim Watch Answer Opposing Entergy's Motion for Summary Disposition of Pilgrim Watch Contention 3, June 2007 - Adams Accession Number ML071840568; and a Statement by Administrative Judge Ann Marshall Young in the Board's Memorandum and Order (Ruling on Motion to Dismiss petitioner's Contention 3 regarding Severe Accident Mitigation Alternatives, Dissenting Opinion of Administrative Judge Ann Marshall Young, October 30, 2007, at 30.
- 1. David I Chanin Resume David I. Chanin 1125 Vassar Dr. N.E. Albuquerque, NM 87106-2620 Major Strengths: Team leader, research, software development, English writing and editing Security Clearances: DOE "Q" 1983-1996, Previous DoD SECRET Education: 1980 B.S. in Mathematics, University of New Mexico Computer Proficiencies: C, C++, FORTRAN 77/90/95, Java, PHP, XHTML, and UNIX scripting/sysadmin/security Primary Career Accomplishments:
29 years of professional experience in development, application, maintenance, and verification/validation of large scientific codes, primarily for assessing the environmental impacts of radiological releases. Main career accomplishments were (1) adoption worldwide of MACCS (NUREG/CR-4691) and MACCS2 (NUREG/CR-6613) computer codes as results of my technical and programmatic leadership; and (2) development of a new method for analyzing the economic impacts if land and structures were contaminated with plutonium from a weapons accident (SAND96-0957). Both projects were multi-year efforts where my roles were obtaining funding, managing multi-person teams, devising novel models, creating QA and configuration management systems, performing testing/review, and writing or editing project documentation.
Primary evidence of value of MACCS2 to DOE and others interested in nuclear safety was its selection as one of the three dose/consequence codes for the DOE "Toobox": seven computer codes chosen for analyzing facility authorization basis. Conceived and developed the modeling enhancements of MACCS2 intended to make it a general-purpose code for diverse DOE nuclear facilities, as compared to the commercial nuclear power plant focus of its predecessor, the NRC-sponsored MACCS.
The cleanup-cost model of SAND96-0957 is recognized as state of the art, but, since conventional nuclear accident analysis generally focuses on doses and health effects (not economic costs), only two government agencies are known to routinely use it in accident analyses: DOE and NASA.
13 The cleanup-cost model of SAND96-0957 is recognized as state of the art, but, since conventional nuclear accident analysis generally focuses on doses and health effects (not economic costs), only two government agencies are known to routinely use it in accident analyses: DOE and NASA.
The SAND96-0957 models were adopted as-is into DOE's RADTRAN/RADCAT transportation-accident codes and therefore integral in all NEPA studies evaluating transportation risks of spent nuclear fuel (SNF) sent to the proposed Yucca Mountain Project for geologic disposal. Its cleanup-cost models are routinely used by NASA for NEPA studies of risks associated with catastrophic launch failure of Pu-238 RTG-powered space missions, e.g. Cassini and Galileo.
2009-- Expert Witness before Atomic.Safety & Licensing Board (ASLB)
Relicensing of commercial nuclear power plants. Engagement from authorship of MACCS2 and SAND96-0957.
2001-2004 Senior Risk Analyst, Technadyne Engineering, Albuquerque, NM Hired into the RADTRAN project to serve as new code developer in October 2001, was soon given full project-leadership responsibilities in acting capacity (due to contractor status) when SNL staff member heading project retired unexpectedly. Led project for two years when primary achievement was obtainment of DOE funding to revamp the architecture from 1970s-based UNIX system to modern web/Java-based system. Leadership role was unusual for contractor because budgeting/oversight responsibilities are normally reserved for SNL employees.
Due to expertise on economic impacts of radiation accidents, supported National Security Studies Dept. of SNL by evaluating relative dose potential of isotopic sources found in commerce. Also helped assess the costs and cleanup standards that might result from a deliberate dispersal event. Effort lasted over a year with work done at OUO level.
Provided MACCS2 support to NRC-sponsored Vulnerability Assessment (VA) of Spent Nuclear Fuel (SNF) performed at SNL in 2002-2003. Performed preliminary assessments and gave briefings to NRC staff on potential cleanup costs using SAND96-0957 methods. Funding from NRC was expected, but never received, for inclusion of cost estimates in VA. Also at NRC request, provided confirmatory analysis of a State of Nevada NEPA contention that cleanup costs from a "worst-case" SNF railcar accident in Salt Lake City would amount to roughly $280 billion, results almost identical to Nevada contention.
As architect and developer of MACCS2, reviewed DOE Toolbox draft documents pertaining to the code for the now-finalized "Gap" and "Guidance" documents.
1996-2001 Consulting Risk Analyst, Albuquerque, NM and Kauai, HI Fulfilled three separate consulting contracts with Pantex Plant relating to the development and validation of modeling methods for assessing the on-site and off-site consequences of radiological accidents involving weapons-grade plutonium and tritium dispersed to atmosphere
14 via explosion, fire, and leak. Performed sensitivity studies in conjunction with an emergency response exercise. Assembled a large body of declassified data from the 1963 Operation Roller Coaster, later utilizing that data for code-to-code comparisons as documented in Hills, Chanin, and Dickerman (1998) and Steele, Wald, and Chanin (1998). Assisted with the processing of meteorological data from Pantex weather tower in conjunction with upper-air soundings from the National Weather Service. Final product of those three contracts was a set of draft Plant Standards codifying calculational methods deemed acceptable for evaluating radiation doses from potential severe accidents at Pantex Plant.
In coordination with the work being done for Pantex, provided 1997 support to DOE LANL Operations Office relating to LANL meteorology, development of a validated methodology for modeling explosive dispersal, and performance of site-specific analyses. This work resulted in LA-UR-98-1901.
Under an ongoing consulting contract with SNL, provided technical support to the RADTRAN development team in adapting the food-chain model of MACCS2 for use in assessing transportation accident risks. Provided a detailed review of agricultural food-chain pathway parameters based on national-average agricultural conditions. In addition to adoption by RADTRAN of the MACCS2 food-chain model (COMIDA2), RADTRAN also adopted the economic-cost model of SAND96-0957.
Under auspices of Technadyne Engineering, prepared and presented training workshops in 1997 for users of the MACCS2 code. These meetings led to the use of MACCS2 in assessing accidents involving dispersal of plutonium via explosion and fire by DOE LANL Operations Office and Pantex Plant. Same training workshops were repeated for the Accelerator Production Tritium (APT) team at SNL, and then for staff at Savannah River Site (SRS).
Provided technical support and training in 1997 to Westinghouse Savannah River Company relating to the use of MACCS2 and the preparation of site-specific data for its application at SRS. The main goal was development of models and data assessing risks to on-site workers, which entailed data-gathering interviews with SRS first responders and detailed reviews of the site.
1982-1996 Senior Risk Analyst, Technadyne Engineering, Albuquerque, NM Performed diverse duties relating to the development of MACCS and MACCS2. From 1992-1996 was technical leader of the MACCS2 project after obtaining DOE sponsorship for it.
Participated in expert review panels and drafted white papers relating to the New Production Reactor, the NASA Cassini Mission, a space nuclear propulsion concept, legacy Hanford Waste Tanks, the Pantex Zone 4 SAR and Site-Wide EIS, and the Defense Programs Transportation Risk Assessment (DPTRA). MACCS2 is the most widely-used code of its type, with over 500 recipients worldwide applying it to both reactor and non-reactor nuclear facilities. MACCS2 has usage that spans numerous M&Os across DOE, as well as wide use by NRC staff and its licensees.
15 Supported SNL during 1995-1996 in the development of an updated version of the RADTRAN transportation accident analysis code. Major focus of project was to upgrade the economic cost,,
dosimetry, and food-chain modules and to make use of newly developed models obtained from SAND96-0957, as well as incorporation of several novel modeling approaches originally developed for MACCS2. In a related effort, participated with the RADTRAN team in a Complex-wide DOE/EM review that assessed the RISKIND transportation accident code of Argonne National Laboratory.
In 1982 was principal author of the TOXRISK code, developed by SNL for NRC to estimate risks to nuclear power plant control room operators from accidents involving nearby transportation of toxic materials.
All the specialized technical knowledge to perform these duties was learned on the job, without any formal training in health physics or nuclear safety.
1981-1982 Systems Analyst, Scientific Simulation, Inc., Albuquerque, NM Performed and documented computer simulations of the Airborne Laser Laboratory Program at the Air Force Weapons Laboratory (AFWL). For SNL, performed simulation of heat loss from steam injection into well-bores to enhance oil recovery.
1980-1981 Research Analyst, Falcon Research,, Albuquerque, NM Performed comparative evaluation of the GETOUT and SWIFT groundwater transport codes.
Participated in the incorporation of the GEMM missile model within the TAP code for AFWL.
Was one of the first users of the Cray-1 at AFWL.
Principal Publications:
Chanin, D.I., et al. (1990). MELCOR Accident Consequence Code System (MACCS), Vols. 1-3, NUREG/CR-469 1, SAND86-1562, Sandia National Laboratories.
Chanin, D.I. (1992). A New Emergency Response Modelfor MACCS, LA-SUB-94-67, DE94017051, Los Alamos National Laboratory.
Chanin, D.; et al. (1993). MA CCS Version 1.5.11.1: A Maintenance Release of the Code, NUREG/CR-6059, SAND92-2146, Sandia National Laboratories.
Chanin, D.; Young, M. (1994). "MACCS2: An Improved Code for Assessing Nuclear Accident Consequences," American Nuclear Society Transactions,New Orleans, LA, June 19-23, 1994.
Chanin, D.; Murfin, W. (1996). Site Restoration:Estimation of Attributable Costsfrom Plutonium-DispersalAccidents, SAND96-0957, DE9601166, Sandia National Laboratories.
Original 300-dpi OSTI version available at: http://chaninconsulting.com/downloads/sand96-0957.pdf (10.4 MB), OCR-readable courtesy S. Aftergood, FAS.
16 Chanin, D.; Murfin, W. (1996). "Site Restoration: Estimation of Attributable Costs from Plutonium-Dispersal Accidents," American Nuclear Society Transactions,Washington, DC, November 19-22, 1996.
Young, M.; Chanin, D. (1997). "MACCS2 Development and Verification Efforts," SAND97-0561 C, DE97004202, conference paper, Sandia National Laboratories. Available at:
http://www.osti.gov/bridge/product.biblio.jsposti id=453548&query id=2.
Chanin, D.I.; Young, M.L. (1997 & 1998). Code Manualfor MACCS2: Volume 1, User's Guide, SAND97-0594, NUREG/CR-6613, Sandia National Laboratories. Because of its recent disappearance from OSTI, now available here:
http://chaninconsulting.com/downloads/maccs2vl .pdf (925 KB).
Steele, C.M.; Wald, T.L.; Chanin, D.I. (1998). Plutonium Explosive DispersalModeling Using the MACCS2 Computer Code, LA-UR-98-1901, DE99000564, Los Alamos National Laboratory.
Download full text: LA-UR-98-1901 .pdf (3 MB).
Hills, C.R.; Chanin, D.I.; Dickerman, C.L. (1998). Validation Study ofAvailable Models for Considerationof Explosive Releases at Pantex Plant,RPT-30, Mason & Hanger Corporation.
Download full text: Validation Study of Explosive Releases.pdf (872 KB).
Chanin, D.I. (2005), "The Development of MACCS2: Lessons Learned," [written for:] EFCOG Safety Analysis'Annual Workshop Proceedings, Santa Fe, NM, April 29-May 5, 2005. Full text:
the development of maccs2.pdf (154 KB), revised 12/17/2009.
Professional
References:
Available on request.
- 2. Memorandum and Order (Ruling on Motion to Dismiss petitioner's Contention 3 regarding Severe Accident Mitigation Alternatives), Dissenting Opinion of Administrative Judge Ann Marshall Young, October 30, 2007, at 30 Intervenors support their challenge to input data regarding costs with the declaration and certain supporting material provided by David Chanin, who states that he "was the primary developer of the MACCS and MACCS2 computer codes under sponsorship of the U.S. NRC and DOE while working at Sandia National Laboratories 1982-1996," and who according to his resume has co-authored several articles on the MACCS2 code as well as three NRC guidance documents including NUREG/CR-6613, Vol. 1, the NRC's User's Guide to the Code Manual for MACCS2.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE JUDGE PAUL B. ABRAMSON THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application May 14,2010 CERTIFICATE OF SERVICE I hereby certify that the Motion On Behalf Of Pilgrim Watch ForDisqualificationof Judge Paul B. Abramson In The Pilgrim NuclearPower Station Re-Licensing Proceedingwas served May 14, 2010 in the above captioned proceeding to the following persons by electronic mail this date, followed by deposit of paper copies in the U.S. mail, first class.
Secretary of the Commission Administrative Judge Attn: Rulemakings and Adjudications Richard F. Cole Staff Atomic Safety and Licensing Board Mail Stop 0-16 C1 Mail Stop -T-3-F23 United States Nuclear Regulatory US NRC Commission [2 copies] Washington, DC 20555-0001 Administrative Judge Office of Commission Appellate Ann Marshall Young, Chair Adjudication Atomic Safety and Licensing Board Mail Stop 0-16 C I Mail Stop - T-3 F23 United States Nuclear Regulatory US NRC Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Administrative Judge Atomic Safety and Licensing Board Paul B. Abramson Mail Stop T-3 F23 Atomic Safety and Licensing Board United States Nuclear Regulatory Mail Stop T-3 F23 Commission US NRC Washington, DC 20555-0001 Washington, DC 20555-0001
U.S. Nuclear Regulatory Commission Mark Stankiewicz Office of Commission Appellate Town Manager, Town of Plymouth Adjudication 11 Lincoln Street Mail Stop: 0-16C1 Plymouth MA 02360 Washington, DC 20555-0001 Sheila Slocum Hollis, Esq.
U.S. Nuclear Regulatory Commission Town of Plymouth MA Office of General Counsel Duane Morris, LLP Mail Stop: 0-15 D21 505 9th Street,D.C.
Washington N.W. 1000 20004-2166 Washington DC 20555-0001 Susan L. Uttal, Esq.
Marcia Simon, Esq. Richard R. MacDonald Andrea Jones, Esq. Town Manager, Town of Duxbury David Roth, Esq. 878 Tremont Street Brian Harris, Esq. Duxbury, MA 02332 Michael Dreher, Esq.
Brian Newell, Paralegal Fire Chief & Director DEMA, Town of Duxbury U.S. Nuclear Regulatory Commission 688 Tremont Street Office of Nuclear Reactor Regulation P.O. Box 2824 Mail Stop: 01 -Fl Duxbury, MA 02331 Washington, DC 20555-0001 Terence A. Burke, Esq.
Lisa Regner, Project Mgr. Plant Lic. Entergy Nuclear Branch 1-1, Operator Reactor Licensing Mail Stop M-ECH-62 Washington, DC 20555-0001 Jackson, MS 39213 Paul A. Gaukler, Esq. Katherine Tucker, Esq.
David R. Lewis, Esq. Law Clerk, Atomic Safety and Licensing Jason B. Parker, Esq. Board Panel Pillsbury, Winthrop, Shaw, Pittman, U.S. Nuclear Regulatory Commission LLP - 2300 N Street, N.W. 11545 Rockville Pike, Mail Stop T3-E2a Washington, DC 20037-1128 Rockville, MD 20852 Martha Coakley, Attorney General Matthew Brock, Assistant Attorney General Commonwealth of Massachusetts Office of Attorney General One Ashburton Place Boston, MA 02108 Mary Lampert Pilgrim Watch, pro se 148 Washington St.,
Duxbury, MA 023332 May 14, 2010 2