ML18079B061
| ML18079B061 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/20/1979 |
| From: | Valore C LOWER ALLOWAYS CREEK, NJ, VALORE, C. |
| To: | |
| References | |
| NUDOCS 7910090038 | |
| Download: ML18079B061 (22) | |
Text
,.
.;,~f.
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing lBoard In the Matter of PUBLIC SERVICE ELECTRIC
& GAS CO.
(Salem Generating Station Unit il)
Docket ilS0-272 RESPONSE TO THE ATOMIC SAFETY AND LICENSINIG BOARD ORDER DATED JULY 10, 1979 QUESTION. NO. 4 The Intervenor, Township of Lower All<oways Creek; hereby submits the technical report of Dr. Cha1uncey Kep~ord in response to Board Question #4.
August 20, 1979 TOWNSHIP OF LOWER' ALLCMAYS CREE~~,
INTEJ~..VENO?
)
/
<.@!_ ~/;: (J_y__ *;.
~.(~lj 0/(
--*~
- CARL VALORE, JR.
. ~
i
\\:.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION' Before the Atomic Safety and Licensing Board
~n the Matter of PUBLIC SERVJ~*ELECTRIC
& GAS CO.
(Salem Generating Station Unit #1)
DOCKET NO. 50-272 CERTIFICATE OF SERVICE I hercb+ certify that copies of Chauncey Kepford' s technical report in response to the Board Question #4 in the above captioned matte.IC have been served upon Lhe attached list by deposit* in the United States. mail at the post office in Northfield, N.J., with proper postage thereon, this 20th day of August,
Dated: August 20, 1979 1979~.*<A ~ n
(./
~-
ARL1!E ©
- '-;s~a& u-c*1:ar
.Counsel for tfue Inte-rvenor, the Township of Lower Alloways Creek
Gary L. Milhollin, Esq.
Chairman, Atomic Safety
& Licensing Board 1815 Jefferson Street Madison, Wisconsin 53711 Glen 0 *. Bright Member.,* Atomic Safety
& Licensing Board U. S. Nuclear Regulatory Commission
. Washington, D. c.. 20555 Dr. James C. Lamb, III Member, Atomic' Safety &
Licensing Board Panel 313 Woodhaven Road Chapel Hill, N. C.
27514 Chairman, Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D. c.
20555 Chairman, Atomic Safety &
Licensing Board Panel U. S. Nuclear Regulatory Commission
. Washington, D. c.
20555 Barry Smith, Esquire Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Mark L. First, Esquire Deputy Attorney General Department of Law & Public Safety Environmental Protection Section 36 West.State Street Trenton, N. J.
08625 Mark J. Wetterhahn, Esquire for Troy B. Conner, Jr., Esq.
1747 Pennsylvania Avenue, N. W.
Suite 1050 Washington, D. c.. 20006 Richard Fryling~ Jr., Esquire Assistant General Solicitor Public Service El.ectric &
Gas Company 80 Park Place Newark, N. J. ** 07101 Keith Ansdorff, Esquire Assistant Deputy Public Advocate >
Department 0£ the Public Advocate<...
- Division of Public Interest Advocacy P. o. Box 141.
Trenton, New* Jersey 08601 Sandra T. Ayres,. Esquire Department o*f the Puhl ic Advocate 520 East State Street Trenton, N *.J..
08625 Mr. Alfred C. Co*leman, Jr:
Mrs. Eleanor G. Coleman.
35 "K" Drive Pennsville, N. J -
08070 Office of tha Secretary Docketing and Ser:vice Sect ion U. S. Nuclear Regulatory Commission Washington~ D. C-20555 June D. MacArtor!t Esquire Deputy Attorney General Tatnall Building, P. 0. Box 1401 Dover, Delawaire 19901
.Mr. Frederick J. Shon Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington~ D-c.
20555 Mary O. Henderson, Clerk Township of Lower Alloways Creek Municipal Building Hancock's Bridge, N. J.
08038
- .. /
The purpose of this report is to attempt tto answer the-question:
Was the accident at the Three Mile ~sland Nuclear Station, Unit 2 (TMI-2) Which began March 28, 1979, a Class 9 accident?
The answer to this question is obscuired by the fact that there** is no unambiguous dividing line betw~en a Class 8 ac.cident and a Class 9 accident. The 'situation :ls on~y slightly
- less ambiguous for a definition of Class 8 accidents.
Th!;! Class 8 accident is a kind of postulated or hypothetical accident which the nuclear power plant is desig,:ned to withstand and which produces offsite consequences--measured in terms of radiation exposures to the public--which the Nuclear Regulatory Commission (NRC) considers acceptable for members of the public.
(The question of whether or not these exposures: of the public to radiation are acceptable to those members'. of' the public affected, is beyond the scope of this testimony). These )?QStulated* accidents are usually cal led "design basis accidents" CDBA' s) and result from a single failure of some component or system in the reactor.
This limitation to accidents caused by a single failure is imposed by the rules of the NRC, 10 CFR 50, Appendix A.
The nature of the accident at TMI-2 and its causative events are not the subject of this report. This report addresses solely
'the offsite consequences of the accident which !began March 28, 1979, at TMI-2.
Chapter 15 of the* Final Safety Analysis Report (FSAR} for TMI-2 contains the discussion of the design basis acc~dents
e*
prepared for, the review of the NRC Staff for licensing purposes.
For the purpose of this report these accidents are accepted as a collective definition of the Class 8 accidents for TMI-2.
Furthermore, since each accident has its own characteristics~
it must be. assumed that any accident which goes beyond the most s~vere of the FSAR Chapter 15 ac6idents,. or DBA's, in terms of radioactive releases to the environment and the resulting exposures of the public will constitute a Class 9 accident.
The discussion of the DBA' s in Chapter 15 includes a series of Tables which list the quantities of radioactive materials expected* to be.,..released to the* environment and the calculat:t!d exposures. These accidents, with the calculated releases of Xenon-133 and Iodine-131 and the two exposure values, are listed in Table 1. From these data, it is possible to derive a sec of simple equations relating the release of a given quantity of Xenon-133 and Iodine-131* to an exposu*re for two hours, at:
the exclusion zone boundary and a 30-day exposure at the boundary of the low population zone. These equations are of the form:
y = mx (1}
where i. is the dose in rems to the whole body for a Xenon-133 release and to the thyroid for a release of Iodine-131. The
- parameter ~ is a proportionality constantt which is dependent upon the particular isotope and the distance from the release site. *The parameter x is the quantity of the isotope released to the environment.
2
... e
-5 For a release of Xenon-133, the values of m are 2.16x10
-6 and 3.46x10 for the 2-hour exclusion zone boundary exposure and the 30-day low population zone boundary dose, respectively.
The values of m for an Iodine-131 release are 2.35x10-l and
-2.
4.1x10 for the above respective locations. As an example, a release o.f 0.0~.4 curies of Iodine-131 would produce a dose
. to the thyroid of an l.ndividual at the exclusion zone boundary for two hours of:
0.054x0.235 = 0.013 rem, or 13 rnrem.
This apprpximation, which relates Iodine-131 and Xenon-133 releases from the accidents analyzed in the FSAR to the to~al dose from the design basis accident, introduces some error into the calculation because other isotopes of not only Xenon and Iodine, but. also Krypton are expected to be released. However, both Iodine-131 and Xenon-133 dominate all anticipated gaseous releases in terms of the resulting thyroid dose and whole body exposures, respectively.. The errors introduced by this approximation overestimate the doses due to these isotopes by about 20% in the case of Iodine-131 and by about 40% in the case of Xenon-133.
This error is believed to be much smaller than that introduced by the necessity of back-calculating the releases from TMI-2 from an inadequate data base, as was done in Reference t.
The quantities of these two isotopes have been estimated to be 1. 3xl07 curies of Xenon-133 2and 13 curies of Iodine-131.
Due to the unanticipated quantity of releases of radioactive 3
.. 9 materials in the first few days of the accident, the in-pl ant monitoring devices went off-scale2 Since these instruments might reasonably be expected to be capable of monito;ring the releases of radioactive materials from any DBA, the fact: that they all went off-scale suggests immediately that. the TMr-2* accident was greater than Class 8, and indeed therefore: was a Class 9 accident. From Table 1., it is seen that for the OBA' s the maximum releases are 88, 000 curies of Xenon-133 in. one' DBA and 29 curies of Iodine-131 in a different accident.
Using. the methodology outlined above 7. which is obtained
- directly from ~hapter 15 of the FSAR for TMI-2., and the releases estimated in Reference 1, the exposures in: Tab:le 2 are calculated as a result of the TMI-2 accident. The value o;:f 28C') rem for a 2-hour exposure at the exclusion zone bounda::ry is over 10 times the value of 25 rem whole body exposure 'ri;Jhich is specifically referred to in 10 CFR Part 100.11 as not being, implied to be an acceptable level of exposure.. It is here as:sumed that the number 25 rem whole body exposure which is* no~ implied to be accep 1ta ble is therefore unacceptable.
Similarly, the exposure of 45 rem from Ta,ble 2 also exceeds the *25 rem "limit" of 10 CFR Part 100.11.. Thes;e two exposures beyond the regulatory value are two more piece~s of evidence that the TMI-2 accident was a Class 9 accident:.
It should be noted here that the Iodine-1l31 exposures do not exceed the* 300 rem thyroid exposure of 10, CFR 100. 11. However, 4
it is clear from part 100.11(a)(1) of 10 CFR that neither exposure is implied to be acceptable, singly or in combination. Thus~
either an exposure excecding*25 rem to the whole body or an exposure exceeding 300 rem ~o the thyroid is deemed unacceptable.
The releases of radioactive materials estimated in Reference 1 and listed in Table 2 should be viewed with skepticism. Those estimates are based upon back calculations from exposures recorded -
- by the dosimeters placed around TMI-2. There were sufficiently few dosimeters in place, however, that in certain c:ompas.s sectors there were no monitoring devices at all. As a result~ the back-calcu-lati~n esticiatet must be considered a lowest possible estimate of releases.
A further problem with the release estimates of Reference 1 is that the data therein pertain to the period from Marc:rn 28,. 1979 through April 5; 1979. Daia from other sources suggests that significant releases of both Xenon-133 and Iodine-13i corncinued for at least three more weeks.
Another source of data on the TMI-2 accident i& the report of the Ad Hoc Population Dose Assessment Group. 2 This rep-.ort utilized the environmental radiation monitors distributedt in the yicinity of TMI-2 by the operator-licensee, Metropolitan Edison Co.* (Met. Ed.), and the NRC. While no data on actual releases from the reactor was given in this report, some estimates of the population exposure within 50 miles* of TMI-Z were made~
and an estimate of the dose to some maximally exposed indii..viduals 5
was also made. The authors estimated a populat'.ii.on exposure through April 7, 1979, of about 3500 person-rem, with the maximum exposure to any individual estimated to be around 0.080 rem, or 80 mrem.*
I have carried out a detailed review of tbis data and, with regard to the population exposure, I have concluded that there was a much higher level of population exposure than is,
stated in.the report. My estimate which r do not consider to be an "upper estimate," is about 63,000 person-rem for the March 28, 1979 through Apri 1 7, 1979 time period. This exposure is whole-body exposure due to radiation from* Xenon-133.
)-.
The data in the Ad Hoc Report, as I call it, can be divided into four groups. The first is what is referred'. to as "background" moni taring data. This represents nothing more t5han the data gathered around the TMI-2 site during the period..ifram about December 30, 1977, through about March 31 ~ 1979'.. Included in this data are whatever exposures are due to* the-operation of TMI-1.
The second set of data are t~e readings of* these same dosimeters during the accident period. The data from a muc!h larger number of dosimeters deployed by the NRC on March 31, 1979, comprises the third and largest and most detailed set of mronitoring data yet released by the NRC.* The fourth set of data.in the Ad Hoc Report is a small set of background readings fr~om dosimeters supplie~ by Radiation Management Corporation, m wholly-owned subsidiary of Philadelphia Electric Company. This. last set of
- It *should be noted here that all monitoring data was specif Lcally requested from the NRC on May 16, 1979, but nmue has been received as of August 1, 1979.
6
- --*---.~---
data was not used in my analysis because it contained the smallest number of data points--too few to be of any use.
The initial step in my analysis, which I shall summarize, was to sum the dosimeter readings from the NRG dosimeters, (Table.
3-4 of the Ad Hoc Report) for each dosimeter station. After locating each. station (Table 3-2 of the Ad Hoc Report), the appropriate measured background readings, (adapted from Table 3-5 of the Ad Hoc Report) were subtracted. from each total, and the resulting doses were plotted according to compass sector as a function cµ distance from TMI-2. An example of. s*ucb a graph is shown in Figure 1.
From Tables 3-7 and 3-8 (Ad Hoc Report), for the 5-10, 10-20, 20-30 mile and out to 40-50 mile segments, popula.*.t:ion
- values were multiplied by the estimated dose at the. midpcoint:
of the distance segment. These values were then summed. giving a population exposure of 5760 person-rem.
Figure 1 and the population exposure value just described require more comment. Figure 1 co.ntains two sets of curved 1-ines, each through circled points. These two curves represent the dose vs. (distance)-1.S. model used by the Ad Hoc Group. 'The curve on the far left of this figure has an initial value of 10 mrem at one mile. It is very clear from the figure* that the data for those sectors shown do not fit the model. at all. beyond three or four miles. In fact, rather than rapidly decreasing with distance from the plant, in some sectors the exposures 7
9*
increase with distance. For this reason, this model was not:
used in this analysis.
The second curve is based on the same model, as it was used in the Ad. Hoc Report. *Here it is seen to force the exposures*
to fall off more rapidly than the data would indicate, and is arbitrarily terminated at ~O miles. For my analysis, I used the segme.nted line in the figure to estimate doses beyond 14.
miles for the Northwest (NW). sector. For other sectors, I also used a straight line from the termination of the. data to a dose*
of 1 mre.m at s.p miles.
The procedure outlined above gave a popula.ttion exposure only for the March 31 through April 7 time period. To estimate the dose for the first three days of the accident, I assumed that the spatial distribution of exposures would be approximately the same as for the March 31 through April 7 period. The exposures from Table 3-3 {Ad Hoc Report) were. summed to get. exposure for the December 27, 1978 to March 31, 1979 and March 31, 1979 to April 6, 1979 time periods for ea~h dosimeter scation. These data were then grouped according to whether the dosimeter was an "indicator" or "control" station, as in Table 3-5 (Ad Hoc Report). From these exposures were subtracted t.!he appropriate background exposures for the appropriate time period.
For each of the two time periods, then, the exposures werec summed over all "indicator" and all "control" stations. The total exposures for both sets of locations for the March 28 to March 31 time period were compared with the corresponding 8
- e.
total exposures for the.March 31 through April 6 periods. For the "indicator" locations, the total exposure for the initial period was slightly greater than 10 times as. great a.s the t:otal exposure for the latter per~od. Similarly,. for the nindica.tor" locations farther away from TMI-2 this same rat::i.o was* over SO.
The factor of 10, as a measure of the. difference in exposure between the two time periods from the Met.. Ed. data, allowed a more realistic computation of the total expoSlUre for the entire period. Thus, the population exposure I calcuiaa:ed is 5760 + 57,600 person-r~m, or-,.:about 63,000 person-rem.
The advantages of using my procedure over tthat of the. Ad Hoc Report include avoidances of total reliance on the very scanty monitoring data recorded during the first three days of the accident. Since the NRC data is far more:* COMf)lete (and more internally consistent) than the Met. Ed. £"ata for the latter period, it forms a more solid base from which t© judge the spatial distribution of exposures.
In addition, any procedure eliminates the wnnecessary and dangerous assumption required to support the comclusions of
-the Ad Hoc Report that the scanty Met. Ed. data1 for both time periods represents the total exposure for both* :periods. This assumption is faulty for the single reason that because o( the small number of dosimeters, the probability becomes high that the dosimeters which were in place at the time of the accident were too few in number to record exposures whi.ch were representative of what ex~osure could have been recorded. As a result, the
. 9
full environmental effects of the actual releases have been grossly underestimated because of the shnllow data base: *. The dosimeters were simply not in place to record what was. there.
The population exposure estimate which I have derived is to be compared with what the Atomic Energy Commission (AECl has told the. publ,ic about Class 8 and Class 9 accidents, and
- the resulting population *exposures. In a widely distributed 1973 *report entitled "The Safety of Nuclear Power Reactors and Related Facilities" (WASH-1250), the AEC presented :in: considerable detail a discu,ssion of reactor accidents. Tables 3 and 4 are two tables from this report which are largely self-explanatory.
Here the AEC has told the public what is to be expected in terms
~f off-site consequences from a reactor accident.
In Table 5, is.contained a comparison among the resul c:s reported in WASH-1250 for a Class 8 accident~ the results of the Ad Hoc Report, and two. of the values for exposures estimated here. Both the figures from the Ad Hoc Report and those* dcri ved herein exceed by a considerable margin the values the: AEG stated would be the consequences of a Class 8, or design basis, accident.
Again, indications are clear that the accident at TMI-Z went'
- far beyond a Class 8 accident. In addition, as shown in Table 2, the exposures to Xenon-133 exceeded. by a large margin the guidelines of 10 CFR 100. The accident at TMr.:.2 must therefore be called a Class 9 accident.
In closing, it must be pointed out that this analysis is based on data for the March 28, 1979 to April 7~ 1979, time 10
... e period ~nly. Releases of gaseous effluents continued long after that date, when the publicly available data stops. In addit.ion, there remains to be seen what levels of land and water contamination, not only have resulted, but *will result from releases of Stron-.
tium-90 and Cesium-137, both of which have escaped in large quantities t.o not _only the reactor cooling system,. but also, into the* containment building basement and other places.
The accident at TMI-2 has not yet ended. The worst:. population exposures mny occur in the future. This possibility will become a reality if extreme care is not taken during clean-up operations to prevent the release of Strontium-90 and Cesium-137.into t:he air as dust and into the Susquehanna River, and then to Chesapeake Bay.
11
- 1.
Preliminary Estimates of Radioactivity Releases fran Three Mile Island.
Menu of Lake H. Barrett, USNRC, April 12, 1979.
- 2.
"Population Dose an:i Health Impact of the Accident: at the Three Mile Islard Nuclear Station," report of the Ad Hoc Popul.ation Dose Assessment Group, May 10, 1979, FDA, tJSHEl.1.
12
.-e TABLE 1 EXPOSURES, REM RELEA5ES, Ci XE-133 I-131.
ACCIDENI'
30 DAY 2 HR.
30 DAY Loss of Ext. El. Focxi 2.98 0.54 9xlo-5 1x10-S 1.. 3x10-2 2.2xlo-3 Loss of A-C. Power SS
- o. 74 1.Sxl0-3 3x10-4 *.*
0.17 Jxlo-2 Stearn*Line Failure S40 7.2 0.014 2.sxio-3 1.. 7 0.29.
Waste Gas Tank Rupture 88,000 0.012 1.9 0.32 2*.ax10-3 4.7x10-4
- Stearn C.enerator Tube Rupture 23,000 29 6.8 0.087 6.8 1.2 R~ Ejection Accident 139 1.lxl0.:.;3 2.9x10-3 S.1x10-4 1..9x10-4 3.3x10-5 Setdown Fine Fupture 1320 1.8
.029 5x10-J 0.42 0.071
- 1.
Exposures are in rem, whole l:xxiy due to Xenon-133, to the thyroid gland\\ fat" Icdine-131.
The two-mur exposure is at the edge of the exclusion zone, Y.hile the t:ihirty-day exposur-is at the edge of the low population zone.
13
TABLE 2 2-HOOR 30-DAY EXCI.IBION ZDNE POPULATION
~Ifi BOUNDARY OOSE ZONE BOUNDARY ISOI'OPE a.JRIES RJ:M REM xeron-1332 1.3x107 280 45 Icxiine-1313 13 3*.1 0.53
- 1. Data are fran Ref. i'.
- 2. Dose fran Xenon-133 is to the \\Jlole l:xxiy.
- 3.
- Dose fran Icxiin~131 is to the thyroid glarrl.
14
- e TABLE 3 REACTOR. FACIUT'l CLASSIPICATIOll Olf' POS?Vl.ATID ACCIDDTS ARD OCCUUIJICIS Ho. Of Clu*
1>!SCl.IPTI011 1
Trivial Incident*
. 2 Misc. small release* outeide Containment 3
Radvaata Sy*tem Failure*
4 6
7 a
9 Events that Relea*e Radioacti*ity into th* Primary Sy*tea Eventa that Release R..adioactiYity into Secondary Syatea Refueling Accident* Iuaid*
Containment Accident. to Spent Juel Out*ide Containmeftt Accident Initiation ~vent* coa-
- idered in D.. ign-Ba~i*
eTaluation in th* Safety Analy*i*
R.eport Hypothetical Sequence* of failures More Severe tbu Clua I 15 S*all aptlla
- Saall laae iut.. coracatmaeac Spilb Laaka and pipe *nab
!quipaae~ Pallure Seriou -lfuacttoe or huaaa error Fuel defect* durlas; aotwal operatloa Traiwi&ata outalda aapec~e&
range of **riabl-Drofl fu.1 el-Dt Drop he~ obj.ct oa~o fuel Mechanical aalfuneti'GG or loae of coolt111 1* tr-fel' tt:dt*
Drop fuel al.... t Drop h**Y)" obj*CC Oll&O ftMl Dro, *ll1e1cliq caak -
i..&* or cool1a1 to eaak. tr&Dapona,1oa inc14ent aa atte baccintr Tl'-laC:
Rupture of *~t.ary P£*1*a Flov Deer... * - Staant!a. Ire&
Succea*i** Pallcar.. O>f Mal.ti*le larri*r* aoraaJ.17 tftl!ft._....
.uiataiu4
- ~*-*~*** *-*.
~-
.e Till.I 4 IADIOLOGICAL IKPAt:r OF TYPICAL P1lll ACCID!ll'tS*
(JlEALISTIC CASE) lndiTidual Do** at Indirldual Doae
!zcl*ion Jladiu*
at 2.5 Hilu Aecideat Crea/event)
(rem/event)
Clu* 2 5 z io-6 1 z 10-1 10 gallou per d.sy coiatinaoaa leak rate from *ourc** autmide CODt&iDeDt Clas* 3
.5 z 10-9 1 z io-11 Gue* f ra. iudvertat di*charg* of part of boric acid coadenaat*
tank Clu*.5 2 z 10-a 4 z io-11 Loea of load Clu* 6.
6 z 10-6 1 z 10-a Fuel handling accident 11191de contaimaent (3 daya after *hut-down)
Cla* 7 l z 10-4 6 z io-1 Fuel bandliug accident out.ide COGtainment ClaH 8 a z io-3 2 z 10-5 Lo.a of coo let Dose to Pop"1atloa Vitbia 50 Kil-(.. n-re111/ eTent)
- 2 :I: 10-2 2 :I: 10_,
I z 10-.5 2 z io-2 1 z io0 l z 101
- I>Ceea are whole body doeea.
lfatural background dose ta ap.proldaately io5 aur.ra./yr. for the u*m.d popalati01a within the 50 ml.la radiu of th* nuclear plant (1.e., 750.ooo to 1,000.ooo people).
16
.. e TABLE 5 (Estimated Exposures fran 1MI-2 Accident}
Class 8*.
. Ad Hoc-TI1I-2 This Report+
}-
- Wash 1250 Table 5-5.
INDIVIDUAL OOSE AT EXCUJSION ZONE BOUNMRY, REM/EVENI' 8x10-3 sxio-2 280 DOSE TO l?OPUI.ATION WI'IlllN.50 MILES, REM PER E'VENI' 3x101.
3.5x1o3 6r3xla4
+ Extrapolated fran 'I-2 FSAR accident analyses using the rel.e:ase values fran Reference 1.
17
.. e e
Protessional Qualitieations..
Chauncey Ke~f ord "93~ o,.1... c1~ IJ Born:
S"kft c.11.. ~,/J:.1,tot 31'1) Z.J '1-J~4*
l'.ay-30, 19.38, Cod;y, l*',y'oming
.PhD., Cheznist:z:y, 1968, Uni versi 't7 ot Calgary, Cal.ga1"7.t JUberta, Canada.
Research Sc~entist, 1967-69, United Airera.f't Research Laboratories#
East Hartford, Connecticut Qunntitativc dctenninations ot tree-radicals generated. b3.' a 8000-curie Cobalt-60 source, Design and *operation ot a bromine-hydrogen 1od!:lde chemical. l.aser.
Assist31lt Professor o'£ Chemistry 1 York Campus ot the Penms;yl.vani.a. St.ate University, 1969-71.
Full-time *activity-since 1971 "'.'- the problems or nuclear l>OWer.
Testified as an expert 'Witness:
Three l'.ile I-,;land Unit 2 Operating License proceecli!T~,, JulT 5, 1971&-
Perkins 1, 21 and j Construction Permit hearings,, Ji:lne 8, 1978 Testified be£ore Legislative Committees ;uid AcL~inistratiw-~ he:trings in
.PennS"JlVa."'liJ?.1 M;iryla.'"ld, Haw York City, Vermont, anct ::Del.av.are,
'testified before the Joint Committee on Atomic Energy" in :l.974,.. 1975, 1976, on proposed revisions of the Price-Anderson Nuclear.' :Iilsur-ance Lav.
?rescmted an invited discussion paper at an E.?.A.. 1Norksmop on Setting
~iteria for Standards for High Level Radioactive 'WQste* D!.sposQJ.,
Albuquerque, N.M., April 12-14, 1977.
Testti'ied at various N.R.c., E.P.A., and D.O.J!;. public hmarings~ 1.975-78.
Initiated operating license proceedings for i'hiladalphia Zl.ect.ric Cor.ipa.n;y 1s Peach Bottom Nuclear lienerating Station, Units 2 6': ~, 1973.
Acting as Legal Representative ot two citizens' groups im Li.censi.ng Proceed:ings before the Atomic,'..;afety and Licensing Boards and Attomi.c Sa!ety and Licensing Appeal Boards of the N.n.c., and the U.S., Court ~ Appeal.a tor the District of Columbia Circuit, '1'bree.M:Ua Isa.and. un:Lt ~
Licensing Proceedings.
Served as a member ot the Executive Board of the Znvir0mt1ental Coaliti.on on Nu.clear fower and legal representative in the license proceecU.ngs
!or Philadelphia 31.ectric Company-' s F'u.l.ton Generatilng Stat:i.on and Pennsylvania Power ~ Light Company's Susquehanna S'tc>-aam i:l.ectrlc St.ation.
This testimony' caused the N.R.C. (l'iarch, Aoril, 1978) t.o void to.e 1r.m:ber o! curies ot radon to the environment as the resui t or. mi n1 ng and milling*
of ura.11iu:n ore !or one year* s reactor operation. As a: ~esalt,, the operatir.g licenses ~ ill reactors are open !or litigat..""1.on cm this issue
- VA LORE, McALLISTER, ARON 8c WESTMORELAND A PROFESSIONAL CORPORATION TO:
ATTORNEYS AT LAW 535 TILTON ROAD NORTHFIELD, N. J. 08225 Office of the Secretary Docketing and Service Section U. S. Nuclear Regulatory Commission Washington, D. C.
20555 FIRST CLASS MAIL
- * *,- r * * *. *1 * :* *** *o*;*--~.,-;*~*-.r:~ :1 '.'
e*'