ML19289D589
| ML19289D589 | |
| Person / Time | |
|---|---|
| Site: | Green County  |
| Issue date: | 02/16/1979 |
| From: | Calkins G, Murphy T, Wood R Office of Nuclear Reactor Regulation, NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML19289D585 | List: |
| References | |
| NUDOCS 7903080297 | |
| Download: ML19289D589 (18) | |
Text
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February 16, 1979 r
UtlITED STATES OF AMERICA NUCLEAR REGULATLRY COMMISSI0il g
BEFORE THE ATOMIC SAFETY Af!D LICEilSING BOARD In the Matter of
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POWER AUTHORITY OF THE STATE
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Docket tio. 50-549 0F NEW YORK
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(Greene County fluclear Power Plant)
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STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE BOARD ON ELECTRI: GENERATION SITING AND THE EtiVIRONMEilT In the Matter of tne Application
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of the
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POWER AUTHORITY OF THE STATE
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Case 80006 0F NEW YORK
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(Greene County Nuclear Generating
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Facility)
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SUPPLEMEf;TAL TESTIMONY OF NRC STAFF ON DECOMMISSIGNING CCA, STIPULATED CONTEitTION II G.2, CCSC AflD ARTHUR L. REUTER, REVISED UNSTIPULATED CONTENTION 4, AliD STIPULATED CONTENTION 10, GC, STIPULATED CONTEilTION II C.5, MHNO AND SHIRLEY A. BRAT:0 STIPULATED CONTErlTI0ti 8 By G. D. Calkins William E. Kreger Thomas D. Murphy Robert S. Wood 7903080Ab7
G. D. Calkins William E. Kreger Thomas D. Murphy Robe'rt S. Wood 1
This testimony addresses the following contentions:
2 Greene County et al., Stipulated Contention II C.5 3
II. The Applicant's Environmental Report and the Staff's 4
Environmental Impact Statement do not comply with the requirements 5
of 10 CFR Part 51 in the following respects...
6 C.
The Applicant and the Staff have underestimated 7
the cost of the proposed facility in the following respects...
8 5.
The nuclear costs do not adequately reflect 9
the ultimate costs,of decommissioning.
10 Mid-Hudson Nuclear Opponents and Shirley A. Brand, Stipulated 11 Contention 8 12 8.
Petitioners contend that the cost of operating and constructing 13 the proposed facility are understated in view of the... uncertainty 14 as to the ultimate cost of decommissioning the proposed facility..
15 Cementon Civic Association, Sticulated Contention II G.2 16 II. The Applicant's Environmental Report and the Staff's 17 Environmental Impact Statement do not comply with the requirements 18 of 10 CFR Part 51 in the following respects...
19 G.
The Applicant and the Staff have underestimated the 20 cost of the facility in the following respects...
2.
The nuclear costs do not adequately reflect the 21 22 ultimate economic and environmental cost of decommissioning if the 23 proposed facility shculd become economically unfeasible either 24 before or after actual operation.
G. D. Calkins William E. Kreger Thomas D. fiurphy Robert S. Wood I
Columbia County Survival Comittee and Arthur L. Reuter, Revised 2
Unstipulated Contention 4 3
The Petitioner contends that the PSAR has not adequately considered 4
the environmental impacts and environmental dangers of decommissioning 5
the proposed facility.
6 The Licensing Board stated in Memorandum and Order dated August 24, 7
1977, " Revised Unstipulated Contention flo. 4 of the Columbia County 8
Survival Committee is admitted insofar as Petitioner is contending 9
that the Applicant has not adequately considered the environmental 10 impacts of decommiss.oning the proposed Greene County facility 11 as regards the aesthetic, economic and ecological effects of any 12 remaining materials which were related to the facility."
13 Columbia County Survival Comittee and Arthur L. Reuter, Stipulated 14 Contention 10 15 10.
The Petitioner contends that the Applicant's and Staff's 16 cost / benefit analyses have inadequately considered both the cost of 17 decommissioning of the proposed facility and the funding of such 18 costs.
19 Decomissionina Options and Their Costs 20 The development of detailed, specific decommissioning plans for 21 nuclear power plants is not currently required until an NRC licensee 22 seeks to terminate his operating license. Nevertheless, the decom-23 missioning options have been analyzed by the Staff.
The present 24 decommissioning regulations are contained in Section 50.33(f) and
- 3. D. Calkins William E. Kreger Thomas D. Murphy Robert S. Wood I
50.82 of 10 CFR Part 50.
Initiatives are under way to improve the 2
Comission's future decomissioning practices for all nuclear 3
facilities.
(See for example, Plan for Reevaluation of NRC Policy 4
on Decommissioning of Nuclear Facilities, NUREG-0436, Rev.1, 5
December 1978).
6 Should license termination be desired, Section 50.82 of 10 CFR 7
Part 50 requires that the licensee provide the Commission with 8
information on the proposed procedures for disposal of the radio-9 active material, decontamination of the site, and assurance of 10 public safety.
11 As a part of the initiatives mentioned above, the Cocmission is in 12 the process to improve the information base on decommissioning.
13 Battelle, Pacific Northwest Laboratory (PNL), Richland, Washington, 14 was placed under contract to study and prepare reports on t M 15 de.omissioning of light water reactors, both pressurized and 16 boilir.g water reactors. As a result report NUREG/CR-0130, " Technology, 17 Safety and Costs of Decommissioning a Reference Pressurized Water 18 Reactor Power Station" was published in June 1978.
This study covered a 1175 MWe plant. l/
19 20 Subsequently, Battelle PNL was requested to prepare an addendum to 21 NUREG/CR-0130 for the propose of showing for pressurized water 22 reactors the sensitivity of cost and safety factors to the power 23 rating, number of coolant loops, level of radioactive contamination
_1/ reene County would be a 1191 MWe PWR.
24 G
G. D. Calkins William E. Kreger Thomas D. Murphy Robert S. Wood 1
and degree of craft union requirements.
In addition, a need for 2
further information on entombment was indicated.
Some preliminary 3
information from the addendum has been supplied to the NRC Staff, 4
but it is subject to change during the report review process.
5 Mr. Calkins served as the Technical Monitor for the subject report, 6
and as such, reviewed progress on a day-to-day basis and served 7
as a member of the group that reviewed and commented on the draft 8
report prior to the publication of the final report.
9 The present methods which the Staff believes are feasible for de-10 comissioning are found in Regulatory Guide 1.86, " Termination of 11 Operating Licenses for Nuclear Reactors." The alternatives for 12 reactor retirement consists of safe storage ("mothballing") with 13 continuing surveillance, entombment with continuing surveillance, 14 and dismantlement with unrestricted release, i.e., no restriction to 15 public access.
However, NRC is in the process of reevaluating its 16 policies on decommissioning, and it is doubtful that the entombment mode as described would now be acceptable.
Since Regulatory Guide 17 1.86 was prepared it has been discovered that Niobium-94 and Nickle-59, 18 having half-lives of 20,000 and 80,000 years, respectively, are produced jg in sufficient quantities in large reactors to limit their release on 20 an unrestricted basis for extremely long periods.
A specialized g
ntombment including no very long lived radioactive materials might 22 be acceptable.
g It appears that feasible decommissioning alternatives for large power g.
G. D. Calkins William E. Kreger Thomas D. Murphy Robert S. Ilood 1
reactors would be as follows:
2 1.
Imediate dismantlement consisting of decontamination and 3
removal of radioactive materials and equipment from the facility 4
and site to permit unrestricted release of the property.
5 2.
Safe storage followed by delayed dismantlement consisting of 6'
a) partial decontamination and removal of radioactive mateials and 7
equipment together with strongly securing the structures to place 8
and maintain the facility and site in such a condition that future g
risi to public safety is within acceptable bounus, b) storage for 10
.about 30 years with surveillance and maintenance to allow decay of 11 much of the radioactivity and c) eventual dismantlement to permit 12 release on an unrestricted basis.
13 3.
Entombment (partial) consisting of a) decontamination and removal 14 of all material and equipment containing significant amounts of 15 long-lived radioactivity, such as Niobium-94, b) strongly securing 16 the remaining structures and equipment by sealing (e.g., with concrete) 37 within a structure integral with the biological shield, and c) sur-veillance and maintenance to assure the security of the entombed
)g structure until the radioactivity decays to the point that it can gg be released on an unrestricted basis.
20 Based upon NUREG/CR-0130 and its addendum (draft) the estimated g
costs for the alternative methods of decommissioning are as follows:
23 24.
G. D. Calkins William E. Kreger Thomas D. Murphy Robert S. Wood 1
DECOMMISSIONIt!G COSTS ($ millions in 1978)(I)
Safe Storage 2
Immediate Followed by Entombment Dismantlement Dismantlement (partial) 3 Immediate Dismaatlement 32.5 4
Preparations for Safe 5
Storage or Entombment 9.5 31.4 6
Continuing Surveillance and Maintenance 2.2(2) 1.0(3) 7 Deferred Dismantlement 29.0 8
Totals 32.8 40.7 31.5 9
Deep Geologic Disposal, 1.8 1.8 1.8 Instead of Low Level 10 Waste Burial Ground (4) 11 Demolition of non-12 radioactive structures 8.0 8.0 6.7(5) 13 (1) Values include 25% contingency 14 (2) 30 years at $73,000/yr.
(3) 100 years at $10,000/yr 15 (4) Additional cost if materials containing very long lived radio-activities such as Niobium-94 have to be disposed of by deep 16 geologic disposal rather than in a low-level waste burial ground.
(5) All facilities except containment building.
17 18 19 20 The key assumptions utilized in deriving these costs were:
1.
Technology and methods to be utilized must be presently available.
21 22 Decomissioning must be accomplished within the framework of 2.
the existing regulations.
23 The key steps utilized in deriving these costs were:
24 G. D. Calkins William E. Kroger Thomas D. Murphy Robert S. Wood 1
1.
Select and describe in detail reference facility and site in-2 cluding radionuclide inventories.
For NUREG/CR-0130 the Trojan 3
Nuclear Plant was used for the reference plant and detailed drawings 4
of it were made availaMe.
The radionuclide inventories were extra-5 polated to full lifetime values from known measurements in the 6
literature at less than full lifetime.
7 2.
Perform highly detailed engineering studies on a step-by-step 8
basis on acceptable decommissioning methods estimating more power, 9
materials and services.
i 10 With respect to aesthetic impact of the plant after decommissioning, 11 it will be no greater than while it is operational and probably 12 less due to the dismantling of the radiological elements described 13 in the following table:
14 Time of Ultimate Discosal 15 Imediate Safe Storage &
Entombment Element Dismantlement Delayed Dismantlement (Partial) 16 Fuel Immediate Immediate Immediate 17 Containment Bldg.--
Internals--very long lived Immediate 30 years (j)
Immediate 18 19 Containment bldg.
0 years (1)
MO yrs.(2) emain er me ae 20 Auxiliary Bldg.
Immediate 30 years (I)
Immediate 21 Fuel Bldg.
Immediate 30 years (I)
Immediate
,,2 4
Control Bldg.
At Final Demolition At Final Demolition At Final Demolition 23 Turbine Bldg.
At Final Demolition At Final Demolition At Final Demolitior 24 -.
G. D. Calkins William E. Kreger Thomas D. Murphy Robert S. Wood Immediate Safe Storage &
Entombment 1
Element Dismantlement Delayed Dismantienen (Partial) 2 Administration Bldg.
At Final Demolition At Final Demolition At Final Demolition 3
4 (1) Or time of delayed dismantlement (2) Or time of decay to unrestricted level.
5 6
Present NRC regulations do not require dismantlement of non-radiological
- tructures and based on comments received at regional State Decommis-8 sioning Workshops, September 1978 (See Conference Proceedings fiUREG/CP-0003),
9 the State believes that is their prerogative to deal with the dismantling of 10 non-radiological structures and that flRC should not involve itself.
11 Ecological Effects Associated with Decommissioning 12 Two approaches to decommissioning, immediate dismantlement and safe 13 storace with deferred dismantlement, were studied in NUREG/CR-0130 14 to obtain comparisons between occupational radiation exposure, potential 15 radiation doses to the public and other safety impacts.
16 Conclusions of this study that are pertinent to our testimony are as 17 follows:
18 1.
There are no major technical impediments to the successful decom-jg missioning of large commercial power reactors.
2.
Regulations are, in general, in place to cover the subject of 20 decommissioning.
21 3.
A methodology for detennining acceptable residual radioactive 22 centamination levels for unrestricted use of a decommissioned reference 23 PWR facility has been developed and acceptable levels have been 24 3-
G. D. Calkins William E. Kreger Thomas D. Murphy Robert S. Wood 1
calculated.
Under these levels, no member of the public will be 2
allowed to receive an annual dose in excess of a limit yet to be 3
established by U.S. regulatory agencies.
The acceptable levels 4
were based on a dose range of from 1 to 25 millirem / year to the 5
most exposed individual. 2/
6 4.
For each reactor the accumulated occupational radiation exposure 7
ranges from over 1200 man-rem for immediate dismantlement to over 8
400 man-rem for placing the facility in safe storage, with an ad-9 ditional 10 to 14 man-rem for surveillance and maintenance for 10 postulated periods of continuing care that range in length from 10 11 to 100 years. The total for safe storage and a 30-year deferred 12 dismantlement is 460 mar-rem per reactor.
These collective exposures 13 compare to an average occJpational radiation exposure at operating 14 light water reactors of 500 man-rem / year per reactor. The doses 15 would be considered acceptable provided the decommissioning activi-16 ties were carried out using all appropriate practices for assuring 17 that the exposures would be as low as reasonably achievable.
18 5.
Additional radiation dose would be received by truck drivers, 19 garagemen, trainmen, onlookers and the general public as a result of 20 transporting the spent fuel and the radioactive material to disposal 21 sites.
Such doses would have to meet all pertinent regulations at 22 2/ A standard of 25 millirem / year is established in 40 CFR Part 190 23 and an appropriate regulatory change will be made by the NRC 24 for its licensees.
_g_
G. D. Calkins William E. Kreger Thomas D. Murphy Robert S. Wood 1
the tima of decommissioning, and are expected to be, per reactor, less than 2
100 man-rem to transport workers and 22 man-rem to the public for imediate 3
dismantlement, and 14 man-rem to workers and 3 man-rem to the public 4
for preparation for safe storage.
These collective doses are made 5
up of exposures to individuals that are well below present regulatory 6
limits and, in the case of members of the public, are very small 7
fractions of natural background radiation exposures.
8 6.
Radiological and non-radiological safety impacts from normal 9
decommissioning operations and potential accidents have been 10 identified and evaluated for both decommissioning modes for the 11 reference Ph?. The safety evaluation includes consideration of 12 radiation dose t3 the public from normal operation and postulated 13 accidents, industrial type accidents and potential chemical 14 pollutants.
For immediate dismantlement, the fifty-year population 15 dose comitment to the total body from routine airborne releases
-4 is calculated to be about 1 x 10 man-rem per reactor and the 16 17 fifty-year dose commitment to the maximum exposed individual
-2 18 from the worst postulated accident is calculated to be about 4 x 10 19 millirem per reactor to the total body.
Radiation doses to the 20 public resulting from preparations for safe storr.,e are about a 21 factor of 100 less than those calculated for immediate dismantlement.
22 These radiation doses to the public are far less than those 23 calculated or measured for operating nuclear stations, and can be 24 considered to be so small as to have a negligible consequence on G. D. Calkins William E. Kreger Thomas D. Murphy Robert S. Wood I
health and safety of the public.
They are far below the "as low 2
as is reasonably achievable" normal operational releases allowed 3
under Appendix I of 10 CFR Part 50.
4 7.
On the basis of the information presented above and our review 5
of the documentation in NUREG/CR-0130, the staff concludes that the 6
decommissioning of the Greene County Nuclear Station can be carried 7
out with acceptable environmental impact.
8 Funding of Decommiss:oning 9
In its analysis of alternatives for assuring the financir.g of reactor 10 decommissioning, the NRC staff has determined that there are six 11 basic approaches, which can be used individually or in combination 12 with each other.
13 First, funds or other assets may be set aside in advance of the 14 reactor start-up.
Such funds could cover the total estimated 15 cost of decommissioning or they could be invested such that 16 principal plus accumulated interest together would be sufficient 17 to pay for decommissioning.
18 Second, a reserve accumulated over the estimated life of the plant 19 could be established. This could be a funded reserve (or sinking 20 fund) where a prescribed amount is accumulated and set aside 21 annually in some manner such that the sinking fund would accumulate interest.
The fund could be invested in the company's assets, in other 22 23 high-grade securities, in state tax-free securities, in federal 24 debt obligations, etc.
G. D. Calkins William E. Kreger Thomas D. !!urphy Robert 5. Wood 1
Alternatively, an unfunded reserve account could also be established 2
using negative net salvage-value depreciation.
Basically, negative 3
net salvage value depreciation allows estimated decommissioning costs 4
to be depreciated over the estimated life of the plant, either by 5
the straightline or accelerated methods. As a depreciation reserve 6
accumulates, funds collected from the customers could be invested 7
in the utility's productive plar.t. When decommissioning begins, the 8
utility has plant assets in the amount of the depreciation reserve 9
that are not encumbered by securities. Securities could then be 10
. issued against such plant with the funds raised used to pay for 11 decommissioning. This is basically the approach that the New York 12 State Public Service Comission has.: commended for the electric utilities under its jurisdiction. 2 PASNY has indicated that it 13 14 will establish a reserve fund, which could be utilized for decom-15 missioning costs.
(Tr. J-12925).
16 Third, decommissioning costs can be expensed when they are incurred 17 at the end of plant life.
18 Fourth, surely bonds issued in conjunction with any of the first 19 three alternatives could, if available, be required.
20 Fifth, the nuclear insurance industry could institute some form of 21 pooled approach to decommissioning, where the insurance industry or 22 l/ Letter from Charles A. Zielinski, Acting Chairman, New York State 23 Public Service Commission to Robert G. Ryan, Director, Office of 24 State Programs.
U.S. NRC; dated January 9, 1978..
G. D. Calkins William E. Kreger Thomas D. Murphy Robert S. Ucod I
some other body could administer both a general fund and also provide 2
a form of decommissioning " insurance" in case of premature reactor 3
shut-down.
Letters have been sent by flRC to appropriate individuals 4
in the insurance industiy concerning this approach. S S
Sixth, funds could be collected out of general revenues at the state 6
or fede al level.
7 Each of these approaches is made more complex by sen ral variables 8
and alternative assumptions.
For example, the expected life of a 9
nuclear plant may be shorteneJ by a reactor accident or it may be 10 lengthened by future economic considerations or plant performance.
11 How should the shortfall or excess of funds from such occurrences 12 be treated? Inflation and interest rates rise and fall according 13 to general economic conditions, thus casting the ultimate return 14 on a fund or escrow account in doubt.
Interest rates also vary 15 according to risk and the profit or non-profit nature of the entity 16 issuing the securities.
Tax treatment oy IRS and the states will 17 vary depending both on the structure of the fund and whether the 18 utility is public or private.
Various accounting treatments (e.g.,
19 normalized vs. flow-through accounting) that utilities are allowed 20 to use will also have an effect on the cost and efficacy of various 21 funding options.
22 4/ Letters to Joseph Marrone and Hubert Nexon, dated flovember 2 23 and November 3,1978, resaectively.
24 G. D. Calkins William E. Kreger Thomas D. Murphy Robert S. Wood 1
As indicated in NUREG-0436, Rev.1, December 1978, a more complete 2
analy:is of financirJ assurance for decommissioning is expected 3
to be coinpleted by the NRC staff by July 1979.
A draft Environ-4 mental Impact Statement on decommissioning, including analysis of 5
financial assurance questions, is scheduled to be published in 6
December 1979.
Finally, a proposed rule is scheduled to be published 7
in the Federal Register in March 1980.
8 In summary, the NRC staff is evaluating various alternatives for 9
assuring the funding of decommissioning.
PASNY and its Greene 10 County plant would, of course, be subject to any changes in NRC 11 regulations or other policies implemented as a result of this 12 evaluation.
Notwithstanding any such changes, PASNY's stated 13 method of providing decommissioning fundt for its Greene County plant 1
would be evaluated at the OL review stage by NRC staff and would be 15 approved or disapproved on the merits of its particular proposal.
16 We can, however, conclude at this time that mechanisms are available 17 for assuring adequlce funds for ' decommissioning of nuclear power 18 plants, including the proposed Greene County plant.
19 20 21 22 23 24 PROFESSIONAL QUALIFICATIONS OF W. E.
KREGER Dr. Kregar is Chief, Radiological Assessment Branch for the U.S. Nuclear Regulatory Ccmission.
He joined the U.S. Naval Radiological Defense Laboratory as a radiological physicist in 19c2 and served in various techuical and supervisory positions in work on radiation protection in the defense against nuclear weapons.
In 1952 he became Director of the Physical Sciences Division of that Laboratory.
Dr. Kreger joined Physics International Company in 1969 as head of nuclear effects program for the Hard Rock Silo project and had several positions there, related to nuclear weapons effects.
In 1972 ha joined the Atomic Energy Commission as a senior radiological physicist and has had management positions until assuming his present
, position in 1975.
Dr. Kreger received his B.S. in Mechanical Engineering from Case Institute of Technology, in Physics from Miami University, and an M.S. and Ph.D. in Physics from University of Illinois, the latter in 1952. He is a Fellow of the American Nuclear Society and a member of several national committees related to shielding and radiation protection.
He was chairman of the ANS Shieldino Division in 1964-1965, and has served on numerous division and ANS Comnittees since joining AMS.
He has authored over thirty technical and professional papers.
i I
t b
.l
PROFESSIONAL Q'.4LIFICATIONS o..
-~
97 THOMAS D. fiURPh!
EXPERIENCE As a member of the Radiation Protection Section of the Office of Nuclear Reactor Regulation, USNRC since February 1973, and as leader of that group since February 1976, I have evaluated the adequacy of radiation protection programs in support of the licensing of commercial nuclear power plants.
I helped develop review programs, acceptance criteria, and solutions to managerial and technical activities associated with those evaluations.
- For, three years as Chief of the Quality Control Inspection Department at the Electric Boat division of General Dynamics Corporation, I managed a group of 200-300 personnel performing electrical, electronic, mechanical, piping and structural inspectinns and non-destructive test operations to assure compliance with plan and procedure requirements for all shipboard and shop work associated with the construction, test and overhaul of nuclear powered sub-marines. As Manager of the Radiological Control Department at Electric Boat, I supervised all radiological safety activities at the Groton shipyard for over four years.
For one year at Allis-Chalmers Manufacturing Company and four and one-half years as a civilian employee of the Army and Navy at Fort Belvoir, Virginia and Pearl Harbor Naval Shipyard, Hawaii, I managed audit, technical and operational radiological safety functions primarily associated with the construction, operation, test, overhaul and repair of nuclear power reactors.
For two and one-half years I worked as an Assistant Health Physicist on the staff of Brookhaven National Laboratory performing various research, training and monitoring activities.
EDUCATION M.S., Management, 1972, Rensselaer Polytechnic Institute, Troy, N.Y.
M.S., Radiological Physics,1957, University of Rochester, Rochester, N.Y.
B.S., Science,1956, Union College, Schenectady, N.Y.
SPECIAL TRAINING AIF Institute on OSHA Impact on Nuclear Industry,1975 Modern Management and Supervision. USDA, 1974 Management by Objectives, General Dynamics,1972 Statistical Quality Control Management Institute, Univ. of Conn.,1971 Nuclear Reactor Engineering and Operations, Ft. Belvoir, Va.,1964 Criticality Hazards Evaluation, ORNL,1959 Radiological Defense Officer's Course, OCD,1958 SOCIETIES AND SPECIAL APPOINTMENTS Health Physics Society; American Nuclear Society; Certified by the American Board of Health Physics; Member of the ABHP Panel of Examiners; present or past member of American National Standards Institute ANS Working Group; ex-officio member of two AIF/NESP Task Forces concerned with occupational exposure; and served one year on the Wisconsin State Industrial Commi:sion Radiation Protection Advisory Council.
f 0.IO}1Pilal.@A_i fica tions_oDgert S. "ood I
l I graduated from Drew University in 1963 with a B.A. degree in Economics.
I received a flaster's degree in Public Administration from the Ohio State University in 1971.
I have also attended several conferences and workshops, most recently at the University of Virginia in June,1978 on the " Economics of Regulation."
Since April,1976, I have been employed as Assistant to the Chief of the Antitrust and Indemnity Group, Office of fluclear Reactor Regulation, U.S.
flaclear Regulatory Commission. !!y general duties include preparing Commission papers, studies, and other staff reports in the areas of fiRC's antitrust, indemnity, and financial assurance for decommissioning programs.
I also assist the Chief of the Antitrust and Indemnity Group in the general admini,-
tration of the Group's programs.
Prior to my current position I served in other tiRC offices, primarily as a budget and planning specialist.
I began my government career with the former Atomic Energy Commission in 1971 as a systems analyst in that agency's Division of Management Information and Telecommunications Systems.