ML19029A476

the Intervener Lower Alloways Creek Township Amended Answers to Licensee'S Interrogatories (Set No. 1)

ML19029A476
Person / Time
Site:	Salem
Issue date:	02/15/1976
From:	Donelson S Lower Alloways Creek Township, NJ
To:	Office of Nuclear Reactor Regulation
References
Download: ML19029A476 (6)

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  1~~"'D°EN-°'. UNITED STATES OF AMERICA TED co~ NUCLEAR REGULZ\TORY COMMISSION In the Matter of DOCKET NO. STN-50-272 Proposed Issuance of Public Serv'ic1:: E'.lectric Amendment to Facility

/ & Gas Co. Operating License (Salem Nuclear Generating No. DPR-70 Station, Unit 11)

• THE ..INTERVENOR LOWER ALLOWAYS CREEK TOWNSHIP Mft..ENDED *ANSWERS TO r.JICENSEE' s -INTERROGATORIES UmT Nn. 1)

1. The calculations may be referred to which are contained in NUREG-404, Vol. 1 and 2, and the Report to the President by the Interagency Task Force dated October, 1978 -

Draft #TID-28817.

2. Insofar as NUREG-404, Vol. 1 and 2, and the Report to the President by the Interagency Task Force Dated October, 1978 - Draft #TID-28817 are a study or analysis there may be some reliance on conclusions and data.

3. NUREG-404, Vol. 1 and 2, and the Report to the President by the Inteiagency Task Force Dated October, 1978 -

Draft #TID-28017.

\.

4. Yes - research is presently being done by Dr. John Lamarsh, Dr. William Harding and Dr. George Luchak.

a) The research is ongoing and has not produced any document - the next work session is scheduled for February 9, 1979.

b) Tlle research is being conducted independently by the above named persons.

c)

d) The ongoing research is focused on whether adequate consideration has been given to the alternativ of expansion of the spent fuel pool. The alternative of permitting expansion may be a statutory reaulatory responsi-bility pursuant to 42 U.S. Code, Section 5877, in that such

• action by the Nuclear Regulatory Commission would insure and promote action by the Utilities and the Department of Energy for the immediate safe and permanent disposal of spent fuel away-from-reactor sites. By permitting the alternative of re-racking the Nuclear Regulatory Commission is avoiding its statutory bbligation and perpetuating a potentially unsafe condition. The CJUPst.ion of safety and health of the public is paramount. The ramifications of storing 24 cores at Salem 11; Salem #2, and Hope Creek

1. 1 and #2, within a 17 year-period is the natural consequences of perrni tting re-racking at. Salem ~f.1.

5. In addition to the original answers to interroga-tories, the following names are supplied:

George Luchak 59 MacLean Avenue Pricenton, N. ,J.

William Harding, 113 Valley View Road Norristown, Pennsylvania

6. Dr. George Luchak - Dr. Luchak's professional qualifications are attached. Other expert witnesses are in the process of being obtained.

LOWER ALLOWAYS CR.EEK TOWNSHIP

/' . .

BY: 'dv-c ~cl.* _,_v' c. ~..C..

• __ .,L.--~,.z-~ayor

-* -SN1UEL E. oom~L[j()N

GEORGE LUCHAK, Ph.D.

59 Maclean Avenue Princeton, N.J.

PROFESSIONAL QUALIFICATIONS Presently a Professor of Civil Engineering at Princeton University teaching undergraduate courses in Systems Engineering and Solid .Mechanics and a graduate course on "American Nuclear Power Systems and the Energy Economy".

Graduated from the University of Toronto in 1942 with a B.A., M.A., and a Ph.D. in 1953 in Mathematics and Physic~.

Past experience includes seven years with the* government in the fields of atomic, biological and chemical warfare, 10 years with industry (General Electric and Radio Cor?oration of America) with team efforts on an ad-hoc basis with Grumman Aircraft, Lockheed Aircraft and others, and nine years with Princeton as a full professor.

The systems engineering work in industry ranged from ballistics missile early warning system to requirements for missile systems to the design of the lunar excursion modular for Apollo. While involved in ballistics missile early warning systems managed a group responsible for determing the decision process to be used to defend the nation against enemy missile attack and the automation of such processes by computer controls.

In Apollo, managed the system reliability and safety team which was responsible for allocating reliability, performance, weight and cost between the various subsystems of the lunar excursion modular in order to ensure a successful mission and a safie system.

I.

. . During the Apollo program proposed a new manasement system to match the design process necessary for the development of the system.

Prior to civilian career, spent four years with the Canadian Corp. of Signals with a discharge rank of Captain.

Also graduated from the British Air Ministry Weather Forecaster's Course and acted as an Air Force Meterowogist, ana graduated from the British Joint Services Staff College which prepares military men and civilian scientists for posts in NATO at the level of Colonel and above.

Various papers on the magnetic fields of the earth, sun and _stars to papers on Colloid Chemistry, the theory of queues.

and the theory of smokes to mechanics.

e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety nnd Licensing Board In The Matter of DOCKET NO. STN-50-272 PUBLIC SERVrCE ELECTRIC GAS COc (Salem Generating Station Unit 11)

CERTIFICATE OF SERVICE I hereby certify that copies* of Lower Alloways Creek Township's Amended Answers to Interrogatories (Set #1) in the above captioned matter have been served upon the attached list by deposit in the United States mail this 15th day of Feb. , 19 79.

Dated: February 15, 1979

Gary L. Milhollin, Esq. Richard Fryling, Jr., Esq.

Chairman, Atomic Safety Assistant General Solicitor

& Licensing Board Public Service Electric &

1815 Jefferson Street Gas Company Madison, Wisconsin, 53711 80 Park Place Newark, N.J., 07101 Glen o. Bright Member, Atomic Safety R. William Potter, Esq.

& Licensing Board Assistant Deputy Public Advocate U.S. Nuclear. Regulatory Commission Department of the Public Advocate Washingto?, D.C, 20555 Division of Public Interest Advocacy Dr. James C. Lamb, III P.O. Box 141 Member, Atomic Safety & Trenton, N.J., 08601 Licensing Board Panel 313 Woodhaven Road Sandra T. Ayres, Esq.

Chapel Hill, N.C. 27514 Department of the Public Advocate 520 East State Street Chairman, Atomic Safety and Trenton~ N.J., 08625 Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Mr. Alfred C. Coleman, Jr.

Washington, D.C., 20555 Mrs. Eleanor G. Coleman 35 "K" Drive Chairman, Atomic Safety & Pennsville, N.J., 08070 Licensing Board Panel U.S. Nuclear Regulatory Commission Office of the Secretary Washington, D.C., 20555 Docketing and Service Section U.S. Nuclear Regulatory Commissic Barry Smith, Esq. Washington, D.C., 20555 Office of the Executive Legal Direcbor U.S.. Nuclear Regulatory Commission June D. MacArtor, Esq.

Washington, D.C., 20555 Deputy Attorney General Tatnall Building, P.O. Box 1401 Mark L. First, Esq. Dover, Delaware, 19901 Deputy Attorney General Department of Law & Public Safety Environmental Protection Section 36 West State Street Trenton, N.J., 08625 Mark J. Wetterhahn, Esq.

for Troy B. Conner, Jr., Esq.

1747 Pennsylvania Avenue, N.W.

suite*1050 Washington, D.C., 20006