ML12048B455
| ML12048B455 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/15/2012 |
| From: | Gundersen A Fairewinds Associates, Riverkeeper |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 21933, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
| Download: ML12048B455 (4) | |
Text
RIVERKEEPER, INC. AND HUDSON RIVER SLOOP CLEARWATER, INC.
OPPOSITION TO ENTERGYS MOTION IN LIMINE TO EXCLUDE PORTIONS OF PRE-FILED TESTIMONY AND EXHIBITS FOR CONTENTION RK-EC-3/CW-EC-1 Attachment 1
UNITED STATES OF AMERJCA NUCLEAR REGULATORY COMMISSION ATOMIC SAFI.!TY ANO LICENSINO HUARD
)
In the Matter of ) Docket Nos.
) 50-247-LR Entergy Nuclear Operations, Inc. ) and 50-286-LR (Indian Point Nuclear Generating )
Units 2 and 3) ) February 15. 2012
)
Dl'Ciaration of Arnold (iundcrst~n Arnold Gundersen, hereby declares under penalty of perjury that the following is true and correct I. I haw been retained by Riverkccper, Inc. as an expert witness in proceedings concerning the application by Fntcrgy Nuclear Operations, Inc. ("D1h.:rgy") H>r a runcwal of the two separate operating licenses for twenty years beyond their current expiration dates f(>r the nuclear power generating facilities located at Indian Poim on the east bank of the Hudson River in the Village of Buchanan, Westchester County, New York.
- 2. I submit thi5 declaration in support of"Rivcrkccpcr, In~.;, and Hudson River Sloop Clearwater Inc.'s Opposition to Entergy's Motion in Limine to Exclude Portions of Pre-Filed Testimony and Exhibits for Contention RK-EC-3/CW-FC- I."
- 3. I have reviewed Entergy's Motion in Limine to Exclude Portions of Pre-Filed Te~timony and Hxhihit~ for Contontion RK-EC-3/CW-EC-1 ("1-:ntergy's Motion in Limine"),
and understand that Entergy questions my qualifications to testify about the radiologiclll contamination plumes in the groundwater at Indian Point as well as the potential impacts of radiological leaks on the public and the Hudson River.
- 4. I disagree with the chaructcrizutions nmde in Hntergy Motion in Limine relating to my qualifications to provide testimony rclutcd to radiologicallcukug(! issues at Indian Point.
- 5. In relation to my qualifications to testily about the radiological contamination plumes at Indiun !'(lint, I huv..: <1 long history or successfully identifying and analyzing radiological leak problems involving Entcrgy-owm:d nuclear power plants This includes, but is not limited to, the following:
- In 2007, I was accepted us an expert in the Pilgrim Nuclear Generating Station license rcm:wal proceeding and provided testimony before an Atomic Safety and I,icensing Aoard about Entcrgy's Buried Tank and Pipe Inspection Program.
- In relation to Entcrgy's Vennont Yankee nuclear power plant, I was appomtcd by Vermont Governor Peter Shumlin, then Senate President Pro Tern, to be the first chair of the Vermont Yank~.:e Public Oversight Panel that specitlcally was chartered to evaluate buried pipes tit Vermont Yankee. In my consultancy role with the State Legislature as Chil:fEnginecr for Fairewinds Associates, Inc, I accurately predicted the presence of and flow pattern of tritium in the ground water at Vermont Yankee. I al~o predicted the presence of Strontium-90 in the soil and was praised in writing by Fntcrgy Vice l're~idcnt John McCann lor my valuable in~1ghts.
- The Umtcd States General Accounting Office (GAO) rcquc~tcd my expertise and I was interviewed as an expert on underground pipes and radwlogicalleakagc issues at nuclear power plants for the GAO report that was issued in June 2011.
- I was recently accepted as a witncs~. and tcstillcd befbrc Administrative Law Judge$
of the New York State Department of Environmental Conserv<~tion concerning the radiological leaks at Indian Point; this testimony included my opinions about the movement and persistence of the radiological contamination at Indian Point, a.nd potential consuqucnccs of the contammation on the public and the Hudson River.
2
My education and background as a nuclear engineer, along with decades of professional I!Xp~:ricncl!, hav~: providt.!d llltl with the qualilications to provide testimony about leaking plant components and tht! behavior of radiological contmnination at nuclear power plant sites.
- 6. In relation to my qualifications to t~stify about the potential impacts of radiological leaks on the public and the Hudson River, as stated in my curriculum vitae and in my pre filed t~stimony, my 3'1 years of nudear industry experience includes experience in radiological and dose assessment My cducuti1mal and prol()ssiunal background in nuclear engineering, and familiarity with the nature and effect ofth~ various radionuclidcs at issue at Indian Point, provides me with the qualifications to provide an opinion about potential consequences of radiological teaks from Indian Point.
In accordance with 2R \I. S C. §1746, 1 declare under penalty of p0~j ury that the foregoing is true and correct.
Executed this J..?' 11 day of February, 2012 t:_*-;"'
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Arnold Gundersen, MSNE
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Chief J*:ngin~Jcr, Jiaircwinds Associates, Inc 3