ML110600867

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Official Exhibit - ENT000002-00-BD01 - Declaration of Kevin R. O'Kula in Support of Entergy'S Pre-filed Testimony on Pilgrim Watch Contention 3
ML110600867
Person / Time
Site: Pilgrim
Issue date: 12/30/2010
From: O'Kula K
Entergy Nuclear Generation Co, Entergy Nuclear Operations, URS Corp
To:
Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML110030986 List:
References
50-293-LR, ASLBP 06-848-02-LR, ENT000002, RAS 19383
Download: ML110600867 (7)


Text

Nuclear Regulatory Commission Exhibit # - ENT000002-00-BD01 Docket # - 05000293 Identified: 02/22/2011 Admitted: 02/22/2011 Withdrawn:

Rejected: Stricken:

Exhibit N o . E N T O 0 0 0 0 2 P i l g r i r n LR P r o c e e d i n g ENT - O I K u l a D e c l a r a t i o n and R e s u m e 5 0 - 2 9 3 -LR, 0 6 - 8 4 8 - 0 2 -LR UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safetv and Licensing Board Panel In the Matter of 1 1

Entergy Nuclear Generation Company and } Docket No. 50-293-LR Entergy Nuclear Operations, Inc. 1 ASLBP NO.06-848-02-LR 1

(Pilgrim Nuclear Power Station) 1 DECLARATION OF KEViN R.O'KULA IN SUPPORT OF ENTERGY'S PM-FILED TESTIMONY ON PILGRIM WATCH CONTENTION 3 I, Dr.Kevin R. 0'Kula, do hereby state the following:

I am an Advisory Engineer with URS Safety Management Solutions LLC. My business address is URS Safety Management Solutions LLC 2 131 South Centennial Avenue Aiken, SC 29803-7680. 1 have over 28 years of experience as a technical professional and manager in the areas of safety analysis methods and guidance development, computer code evaluation and verification, probabilistic safety assessment, deterministic and probabilistic accident and consequence analysis applications for reactor and non-reactor nuclear facilities, source term evaluation, risk management, reactor materials dosimetry, and shielding. I am the principal author and was responsible for the preparation of the Washington Safety Management Solutions Report entitld "Radiological Dispersion and Consequence Analysis Supporting Pilgrim Nuclear Power Station Severe Accident Mitigation Alternative AnalysistfRevision 1 (May 2007). A statement of my professional qualifications is attached.

I provide this declaration in support of Entergy 's pre-filed testimony on Pilgrim Watch Contention 3. I attest to the accuracy of those statements attributed to me (that material marked by my initials in Entergy's pre-filed testimony for both Meteorological Matters and Source Term),support them as my own, and endorse their introduction into the record of this proceeding. I declare under penalty of perjury that those statements, and my statements in this declaration, are true and correct to the best of my knowledge, information, and belief.

Executed on 1213 "//IQ (Date) &. 2.0%

Kevin R O'Kula

URS SAFETY MANAGEMENT SOLUTIONS LLC KEVIN R. OKULA Advisory Engineer URS Safety Management Solutions LLC 2131 South Centennial Avenue Aiken, South Carolina 29803-7680 Telephone: 803.502.9620 - Email: kevin.okula@wsms.com KEY AREAS:

  • Computer Model Verification and Validation
  • Severe Accident and Quantitative Risk Analysis
  • Accident and Consequence Analysis for Design Basis
  • Regulatory Standard & Guidance Development
  • MACCS2 Code Applications
  • New Reactor Design Accident Analysis and PRA Support
  • Level 3 PRA Standard Development PROFESSIONAL

SUMMARY

Dr. OKula has over 28 years experience as a manager and technical professional in the areas of accident and consequence analysis, source term evaluation, commercial and production reactor probabilistic risk assessment (PRA) and severe accident analysis, safety software quality assurance (SQA), safety analysis standard and guidance development, computer code evaluation and verification, risk management, hydrogen safety, reactor materials dosimetry, shielding, and tritium safety applications. He is a member of the American Nuclear Society (ANS) Standard working group ANS 58.25 on Level 3 Probabilistic Safety Assessment, and is a member of the Peer Review Committee for the Nuclear Regulatory Commissions (NRCs) State-of-the-Art Reactor Consequence Analysis (SOARCA) Program. Kevin was part of the Department of Energy (DOE) team writing DOE G 414.1-4, Safety Software Guide. He coordinated technical support for the DOE Office of Environment, Safety, and Health (EH) in addressing Defense Nuclear Facilities Safety Board (DNFSB) Recommendation 2002-1 on Software Quality Assurance (SQA), and was a consultant to DOE/EH-31 Office of Quality Assurance for disposition of SQA issues.

Dr. OKula was a member of the Partner, Assess, Innovate, and Sustain (PAIS) Safety Case team for the Sellafield Site in the United Kingdom in the early 2009 period. The PAIS team identified and began implementation of improvement opportunities in nuclear safety and related areas. Recommendations were documented in comprehensive reports to the Sites Nuclear Management Partners consortium in March 2009.

He is, or has supported, Atomic Safety Licensing Board (ASLB) relicensing issue resolution for several commercial plants including Indian Point, Prairie Island, and Pilgrim Nuclear Power Station, on severe accident mitigation alternatives (SAMA) analysis. He was also part of the accident analysis and PRA/severe accident teams supporting the Design Certification Document for the U.S. Advanced Pressure Water Reactor (US-APWR) a joint effort with URS Washington Division and Mitsubishi Heavy Industries (MHI). He has provided similar support for an alternative reactor technology, the Pebble Bed Modular Reactor (PBMR).

Kevin is coordinating WSMS support to the Quantitative Risk Analysis (QRA) for evaluation of hydrogen events in a waste vitrification plant design, including fault tree and human factors areas. He is 1

URS SAFETY MANAGEMENT SOLUTIONS LLC K. R. OKULA also a contributor to the DOE response on the use of risk assessment methodologies as part of the DNFSB Recommendation 2009-1 implementation action for Risk Assessment. He led work in reviewing EIS food pathway consequence analysis performed on assumed accident conditions from the Mixed Oxide Fuel Fabrication Facility (MFFF), sited at the Savannah River Site. This project compared and evaluated the impacts calculated from three computer models, including MACCS2, GENII, and UFOTRI.

He is past chair of the American Nuclear Society (ANS) Nuclear Installations Safety Division (NISD),

and the Energy Facility Contractors Group (EFCOG) Accident Analysis Subgroup. He is a member of the Nuclear Hydrogen Production Technical Group under the ANSs Environmental Sciences Division, and is chair for the EFOCG Hydrogen Safety Interest Group. He was the Technical Program Chair for two ANS embedded topical meetings on Operating Nuclear Facility Safety (Washington, D.C., 2004) and the Safety and Technology of Nuclear Hydrogen Production, Control and Management (Boston, MA, 2007).

Dr. OKula was PRA group manager for K Reactor at the time of restart in the early 1990s. He led a successful effort demonstrating Savannah River Site (SRS) K-Reactor siting compliance to 10 CFR 100, and tritium facility compliance with SEN-35-91.

He was the project leader for independent Verification and Validation (V&V) of urban dispersion software for the Defense Threat Reduction Agency (DTRA) and is the current V&V project manager for the evaluation of several chemical/biological software tools for the U.S. Army Test and Evaluation Command (ATEC) and Chemical-Biological Program (Dugway Proving Ground (Utah) and Edgewood Chemical/Biological Center in Maryland.

EDUCATION:

Ph.D., Nuclear Engineering, University of Wisconsin, 1984 M.S., Nuclear Engineering, University of Wisconsin, 1977 B.S., Applied and Engineering Physics, Cornell University, 1975 TRAINING:

Conduct of Operations (CONOPS), 1994 Harvard School of Public Health, Atmospheric Science and Radioactivity Releases, 1995 Consequence Assessment, (Savannah River Site, 1995)

U.S. DOE Risk Assessment Workshop (Augusta, GA, 1996)

MELCOR Accident Computer Code System (MACCS) 2 Computer Code, 1997, 2005 MCNPX Training Class (ANS Meeting, 1999)

CLEARANCE:

Active DOE Q PROFESSIONAL EXPERIENCE:

Washington Safety Management Solutions 1997 to Present Advisory Engineer and Senior Fellow Advisor Dr. OKula is a member of the State-of-the-Art Reactor Consequence Analysis (SOARCA) Project Peer Review Committee that provides recommendations on applying MACCS2 in the context of accident 2

URS SAFETY MANAGEMENT SOLUTIONS LLC K. R. OKULA phenomena and subsequent off-site consequences in the context of severe reactor accidents. This activity supports the efforts of Sandia National Laboratories (SNL) and the Nuclear Regulatory Commission (NRC) to provide more realistic assessment of severe accidents.

Dr. OKula is also part of the Level 3 PRA Standard working group charged with developing an ANSI/ANS standard for Level 3 PRA analysis. He participated in a team that conducted an SQA gap analysis on the bioassay code [Integrated Modules for Bioassay Analysis (IMBA)] based on DOE G 414.1-4 requirements. He identified safety analysis codes that were designated as DOE toolbox codes, and oversaw production of the first documents (QA criteria and application plan, code guidance reports, and gap analysis) for six accident analysis codes designated for the DOE Safety Software Toolbox. He provided support to DOE/EH-31 (now DOE/HSS) for addressing SQA issues for safety analysis software. He was a contributor to DOE G 414.1-4, Safety Software Guide on SQA practices, procedures, and programs.

Kevin has provided technical input for work packages on several recent commercial projects. In the first, he teamed with Entergy on MACCS2 code applications issues in the Severe Accident Mitigation Alternatives (SAMA) analysis area for the Pilgrim Nuclear Power Station. In the second, he was part of tritium environmental release analysis team that supported evaluation of tritium control and management areas for the Braidwood plant. A third effort developed an initial SAMDA document for the Mitsubishi Heavy Industries (MHI) US-APWR (1610 MWe evolutionary PWR), as well as complete a control room habitability study for postulated toxic chemical gas releases.

Kevin was part of a Washington Group team that developed a Design Control Document (DCD) for the MHI US-APWR using input information from MHI. He was Chapter lead on Chapter 15 (Transient and Accident Analysis), and later transitioned to severe accident evaluation and documentation support to Chapter 19 (PRA and Severe Accidents). He currently is the Chapter 19 lead for PRA and Severe Accident for COLA development for the Pebble Bed Modular Reactor (PBMR).

Dr. OKula developed the outline, coordinated contributors, and assembled the first draft of the DOE Accident Analysis Guidebook, a reference guide for hazard, accident, and risk analysis of nuclear and chemical facilities operated in the DOE Complex. He is also the primary author and coordinator for the Accident Analysis Application Guide for the Oak Ridge contractor. Dr. OKula also developed a one-day course and exam for the guide, which he later presented to the Oak Ridge, Paducah, and Portsmouth staff.

Dr. OKula also led an independent V&V review for the DTRA of the U.K.-developed Urban Dispersion Model (UDM) software for predicting chemical and biological plume dispersion in city environments, and is leading projects to verify and validate chemical/biological simulation suite software applications for the Dugway Proving Ground (Utah), and the Edgewood Chemical Biological Center (ECBC) in Maryland.

Managing Member, Consequence Analysis Dr. OKula was responsible for the consequence analysis associated with accident analysis sections of Documented Safety Analysis (DSA) reports and other safety basis documents for SRS, Oak Ridge, and other DOE nuclear facilities. He also developed the methodology and identified appropriate computer models for this purpose. Additionally, Dr. OKula developed training to enhance consistency and standardize analyses in the consequence analysis area. He was project manager for environmental assessment support to SRS on a transportation safety analysis using the RADTRAN code.

Dr. OKula coordinated development of a DOE Accident Analysis Guidebook involving over 10 sites and organizations. He also led the effort to produce Computer Model Recommendations for source term (fire, spill, and explosion), in-facility transport, and dispersion/consequence (radiological and chemical) areas.

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URS SAFETY MANAGEMENT SOLUTIONS LLC K. R. OKULA Westinghouse Savannah River Company 1989 to 1997 Group Manager Dr. OKula managed consequence analyses associated with accident analysis sections of DSA reports and other safety basis documents. He also developed the associated methodologies and identified appropriate computer models. He was a member of the management team supporting Criticality Safety Evaluation preparation assisting Safe Sites of Colorado and the dispositioning of final criticality safety issues for the decommissioning and decontamination of nuclear facilities at the Rocky Flats Environmental Technology Site.

In a teaming arrangement with Science Applications International Corporation, Kevin initiated discussions that led to development of an emergency management enhancement tool to better predict likely source terms. Applied to a Savannah River nuclear facility (K Reactor) and to the British Advanced Gas-Cooled Reactors (AGRs) (for the United Kingdoms Nuclear Installation Inspectorate).

Model was knowledge-based, and required development of an Accident Progression Event Tree (APET) for the facility in question.

Dr. OKula managed the completion of the SRS K Reactor PRA program. He was the lead for development of the K Reactor Source Term Predictor Model and assisted with the core technology lay-up program to preserve competencies in reactor safety. He coordinated a 25-person group responsible for K Reactor probabilistic and deterministic dose analyses, and led the examination of reduced power cases at project termination. He developed risk and dose management applications to cost-effectively prioritize facility modifications.

Kevin interfaced with DOE Independent and Senior Review teams to finalize study acceptance, and transitioned the risk assessment team to risk management functions for nuclear and waste processing facilities. In addition, he successfully prepared a 10 CFR 100 Siting white paper to resolve issues raised by the DNFSB, and teamed with DOE/HQ legal support to document resolutions. He led the development of a position paper demonstrating SRS Replacement Tritium Facility compliance with DOE Safety Policy (SEN-35-91).

Staff Engineer Dr. OKula led an analytical team quantifying the tritium source term during a Loss of River Water design basis accident. He evaluated airborne tritium levels with multi-cell CONTAIN model, interfaced with a multidisciplinary team to resolve Operational Readiness Review concerns, developed an SRS-specific methodology for applying MACCS as a tool for Level 3 PRA Applications, and applied CONTAIN code for K Reactor source term analysis.

E.I. du Pont de Nemours & Company 1982 to 1989 Principal Engineer, Research Engineer Dr. OKula performed risk analysis duties for the Savannah River Laboratory (SRL) Risk Analysis Group, after earlier conducting research activities for the Reactor Materials and Reactor Physics Groups.

He performed initial planning for offsite irradiation of test specimens to evaluate remaining reactor lifetime for Savannah River reactor components.

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URS SAFETY MANAGEMENT SOLUTIONS LLC K. R. OKULA Westinghouse Electric Corporation 1975 Summer Student, Reactor Licensing Monroeville, PA American Electric Power Corporation 1973 to 1974 Co-op Student, Reactor Physics and Reactor Licensing New York, NY Long Island Lighting Company 1972 Summer Intern Riverhead, NY PARTIAL LIST OF PUBLICATIONS (2000-2010):

K. R. OKula, D. C. Thoman, J. Lowrie, and A. Keller, Perspectives on DOE Consequence Inputs for Accident Analysis Applications, American Nuclear Society 2008 Winter Meeting and Nuclear Technology Expo, November 9-13, 2008 (Reno, NV).

K. R. OKula, F. J. Mogolesko, K-J Hong, and Paul Gaukler, Severe Accident Mitigation Alternative Analysis Insights Using the MACCS2 Code, American Nuclear Society 2008 Probabilistic Safety Assessment (PSA) Topical Meeting, September 7-11, 2008 (Knoxville, TN).

K. R. OKula and D. C. Thoman, Modeling Atmospheric Releases of Tritium from Nuclear Installations, American Nuclear Society Embedded Topical Meeting on the Safety and Technology of Nuclear Hydrogen Production, Control and Management, June 24-28, 2007 (Boston, MA).

K. R. OKula and D. C. Thoman, Analytical Evaluation of Surface Roughness Length at a Large DOE Site (U), American Nuclear Society Winter Meeting, November 12-16, 2006 (Albuquerque, NM).

K. R. OKula and D. Sparkman, Safety Software Guide Perspectives for the Design of New Nuclear Facilities (U), Winter Meeting of the American Nuclear Society, November 13 - 17, 2005 (Washington, D.C.).

K. R. OKula and R. Lagdon, Progress in Addressing DNFSB Recommendation 2002-1 Issues: Improving Accident Analysis Software Applications, Fifteenth Annual Energy Facility Contractors Group Safety Analysis Workshop, April 30 - May 5, 2005, Los Alamos, NM (2005).

K. R. OKula and Tony Eng, A Toolbox Equivalent Process for Safety Analysis Software, Fourteenth Annual Energy Facility Contractors Group Safety Analysis Workshop, May 1-6, 2004, Pleasanton, CA (2004).

K. R. OKula, D. C. Thoman, J. A. Spear, R. L. Geddes, Assessing Consequences Due to Hypothetical Accident Releases from New Plutonium Facilities (U), American Nuclear Society Embedded Topical Meeting on Operating Nuclear Facility Safety, November 14 - 18, 2004 (Washington, D.C.).

K. OKula and J. Hansen, Implementation of Methodology for Final Hazard Categorization of a DOE Nuclear Facility (U), Annual Meeting of the American Nuclear Society, June 13-17, 2004, (Pittsburgh, PA).

K. R. OKula and Tony Eng, A Toolbox Equivalent Process for Safety Analysis Software, Fourteenth Annual Energy Facility Contractors Group Safety Analysis Workshop, May 1-6, 2004, Pleasanton, CA (2004).

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URS SAFETY MANAGEMENT SOLUTIONS LLC K. R. OKULA K. R. OKula, et al., Evaluation of Current Computer Models Applied in the DOE Complex for SAR Analysis of Radiological Dispersion & Consequences, WSRC-TR-96-0126, Westinghouse Savannah River Company (2003).

K. R. OKula, et al., Evaluation of Current Computer Models Applied in the DOE Complex for SAR Analysis of Radiological Dispersion & Consequences, WSRC-TR-96-0126, Rev. 3, Westinghouse Savannah River Company (2002).

K. R. OKula, A DOE Computer Code Toolbox: Issues and Opportunities, Eleventh Annual EFCOG Workshop, also 2001 Annual Meeting of the American Nuclear Society, Milwaukee, WI (2001).

PUBLICATIONS (1988-1999):

Dr. OKula authored or co-authored more than 20 publications between 1988 and 1999. Details are available upon request.

PROFESSIONAL SOCIETIES AND STANDARDS COMMITTEES

  • American Nuclear Society
  • Health Physics Society
  • Level 3 ANS PRA Standard Committee 58.25 6