ML19289C482

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Affidavit of Rd Pollard.Certifies That Author Has Reviewed Staff Submissions Re Protection Against low-trajectory Turbine Missiles & Provided the Technical Analysis in the Ucs Reply Brief.Certificate of Svc Encl
ML19289C482
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 12/13/1978
From: Pollard R
UNION OF CONCERNED SCIENTISTS
To:
References
NUDOCS 7901120249
Download: ML19289C482 (4)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

( ,

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )

)

VIRGINIA ELECTRIC AND POWER )

COMPANY ) Docket Nos. 50-338 OL

) 50-339 OL (North Anna Nuclear Power )

Station, Units 1 and 2) )

AFFIDAVIT OF ROBERT D. POLLARD I, ROBERT D. POLLARD, hereby make my affidavit as follows:

I am the staff nuclear safety engineer in the Washington, D.C., office of the Union of Concerned Scientists.

My formal education in nuclear technology began in May, 1959, when I was selected to serve as an electronics technician in the nuclear power program of the United States Navy. After completing the required training, I became an instructor responsible for teaching naval personnel both the theoretical and practical aspects of operation, maintenance and repair of naval nuclear power plants.

From February, 1964, to April, 1965, I served as the senior reactor operator and supervised the reactor control division aboard the U.S.S. Sargo, a nuclear-powered submarine.

In 1965, I was honorably discharged from the U.S. Navy and attended Syracuse University, where I received the degree of Bachelor of Science magna cum laude in Electrical Engineering in June, 1969.

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s-In July, 1969, I was hired by the U.S. Atomic Energy Commission (AEC) and continued as a technical expert with the AEC and its successor, the NRC, until February, 1976. After joining the AEC, I stud.ed advanced electrical and nuclear engineering at the Graduate School of the University of New Mexico in Albuquerque. I subsequently advanced to the positions of Reactor Engineer (Instrumentation) and Project Manager.

As a Reactor Engineer assigned to the Electrical, Instru-mentation and Control Systems Branch, I was prinarily responsible for analyzing and evaluating the adequacy of the design of reactor protection systems, control systems and emergency electrical power systems in proposed nuclear facilities. In September, 1974, I was promoted to the position of Project Manager and became responsible for planning and coordinating all aspects of the design and safety reviews of applications for licenses to construct and operate several commercial nuclear power plants.

I am a member of the Institute of Electrical and Electronics Engineers (IEEE). I have served as the NRC representative on various IEEE committees that developed some of the IEEE standards used by the NRC to evaluate the safety of nuclear power plants.

One of the duties to which I was assigned while at the AEC was to act as the principal staff reviewer for the turbine missile generic issue. My duties in that area during the

period of'1972 - 1973 were approximately equivalent to those now assigned to the Task Action Manager for this subject.

Among other tasks, I performed the calculations for proba-bility of strike for high and low trajectory missiles, analyzed the possible mitigating effect of reinforcing steel and steel liners for reinforced concrete structures, and performed calculations attempting to analyze the damage caused by missile impact as a function of the angle of incidence.

Portions of this work were used to support the con-clusions reached by S. II . Bush in " Probability of Damage to Nuclear Components," Nuclear Safety, Vol. 14, No. 3, May-June, 1973, which is a major document referenced in Regulatory Guide 1.115, " Protection Against Low-Trajectory Turbine Missiles." So far as I am aware, the staff has developed no new information or analysis inconsistent with my work.

I have reviewed the staff submissions on this issue in the North Anna proceedings and provided the technical analysis contained in the UCS reply brief which accompanies this affidavit. The technical statements are accurate to the best of my knowledge.

By: ni!J - -

N Robert D. Pollard Union of Concerned Scientists December 13, 1978 I hereby affirm that the foregoing is true and correct to the best of my knowledge and holief.

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< m&x . .-f Y)0]Miy g <v 5 Robert D. Pollard Subscribed and sworn to on December 13, 1978, at Washington, D.C.

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )

)

VIRGINIA ELECTRIC AND POWER ) Docket Nos. 50-338 OL COMPANY ) 50-339 OL

)

(North Anna Nuclear Power )

Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies'of the foregoing, UCS Reply Brief, Amicus Curiae, and Affidavit of Robert D. Pollard were mailed postage pre-paid this 14th day of December 1978, to the following parties:

Secretary James N. Christman, Esquire U.S. Nuclear Regulatory Commission Hunton & Williams Washington, D.C. 20555 P.O. Box 1535 ATTENTION: Chief, Docketing & Richmond, Virginia 23212 Service Section Daniel T. Swanson, Esquire Michael C. Farrar, Esquire U.S. haclear Regulatory Commission

  • Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U.S. Nuclear Regulatory Richard M. Foster, Esquire Commission 1908-A Lewis Mountain Road Washington, D.C. 20555 Charlottesville, Virginia 22903 Anthony J. Gambardella, Esquire Office of the Attorney General Suite 308 11 South 12th Street Richmond, Virginia 23219 Alan S. Rosenthal, Esquire Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20G55 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 s

Atomic Safoty and Licensing Appeal Board ,,

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U.S. Nuclear Regulatory Commission  ; ,/ IA w (M h S Washington, D.C. 20555 ,

,(( P Ellyn-R. Weiss

  • Hand-delivered