ML19289F088
| ML19289F088 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 05/11/1979 |
| From: | Hoefling R, Ketchen E NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML19289F083 | List: |
| References | |
| NUDOCS 7906010342 | |
| Download: ML19289F088 (48) | |
Text
,
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g #RE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket No. 70-2623 DUKE POWER COMPANY
)
)
(Amendment to Materials License
)
SNM-1773 for Oconee NuclearStation )
Spent Fuel Transportation and
)
Storage at McGuire Nuclear Station))
NRC STAFF'S MOTION FOR
SUMMARY
DISPOSITION -
CAROLINA ACTION CONTENTION NO. 4 AND THE CONTENTION OF THE DAVIDSON CHAPTER OF THE NORTH CAROLINA PUBLIC INTEREST RESEARCH GROUP Edward G. Ketchen Counsel for NRC Staff Richard K. Hoefling Counsel for NRC Staff May 11, 1979 2235 246
- 0eos osy
TABLE OF CONTENTS Page I. M0 TION....................................................
1 II. INTRODUCTION AND BACKGROUND...............................
1 III. GENERAL POINTS OF LAW.....................................
2 IV. ARGUMENT IN SUPPORT OF MOTION FOR
SUMMARY
DISPOSITION.....
6 V.
CONCLUSION................................................
12 ATTACHMENTS - Affidavit And Professional Qualifications of C. Verdon Hodge, William H. Lake, Jr. and R. Daniel Glenn i
Affidavit of Brett S. Spitalny Statement of Material Facts As To Which There Is No Genuine Issue 2235 247
I.
MOTION The United States Nuclear Regulatory Commission Staff (Staff) moves that the contentions which are the subject of this Motion be dismissed pursuant to 10 C.F.R. Section 2.749 for war.t of a genuine material issue of fact to be adjudicated at the upcoming hearings scheduled for June 19-29, 1979. The Staff is of the opinion that the attached affidavit, together with the various responses to discovery requests,1/ emonstrate that the d
Intervenors, Carolina Action and the Davidson Chapter of the North Carolina Public Interest Research Group (PIRG), have failed to produce a suffi-cient factual basis for these contentions and that there are no issues of fact worthy of adjudication at the hearings.
Accordingly, this Atomic Safety and Licensing Board (Board) should dismiss the contentions which are the subject of this motion because there is no genuine issue as to any material fact and, therefore, the NRC Staff is entitled to a decision as a matter of law.
II.
INTRODUCTION AND BACKGROUND This proceeding began pursuant to the Federal Register notice of oppor-tunity for public participation in the proposed NRC licensing action for amendment to special Materials License SNM-1773.2/ The amendment to SNM-1773 v;culd authorize the Applicant, Duke Power Company, to transport spent nuclear fuel from the Oconee Nuclear Station for storage in the spent fuel pool located at the McGuire Nuclear facility in accordance with Duke Power Company's application dated March 9,1978.
1/
It should be noted that Intervenor Carolina Action has not rerponded to any discovery requests in this proceeding.
~2/
2235 248
e 9 Carolina Action was admitted as an Intervenor in the above-referenced docket by Order of November 2,1978.M PIRG was admitted as an Intervenor to this proceeding by the Board's Order of February 27, 1979 wherein PIRG was also consolidated with Intervenor Carolina Action.
PIRG advances only one contention.
PIRG's only contention and Carolina Action Contention No. 4 are the subject of this motion.
The Atomic Safety and Licensing Board (Licensing Board) by Order of April 12,1979 has set the hearing for June 19-29, 1979.
The Licensing Board's April 12, 1979, set May 4,1979 as the date summary disposition motions are due.
By its Order of May 4,1979, the Board extended the filing date until May 11, 1979 for the NRC Staff.
III.
GENERAL POINTS OF LAW The rcquirement that there be a factual basis for each contention in issue in a Nuclear Regulatory Commission proceeding derives from two sources :
- 1) the cor..ention requirement of 10 C.F.R. Section 2.714 and
- 2) the summary disposition provisions of 10 C.F.R. Section 2.749. As will be shown below, a notion to dismiss will lie on the basis of either rule.
-1/
On October 24, 1978 Applicant, Staff, and Carolina Action submitted a " Stipulation of Carolina Action, the Nuclear Regulatory Commission Staf f, and Duke Power Company Relating to the Admission of Contentions" (October 18, 1978).
2235 249
. A.
Factual Bases for Contentions Under 10 C.F.R. Section 2.714(a) 10 C.F.R. Section 2.714(a) requires that there be a factual basis for each contention set forth in a petition to intervene.M That Section states:
"...the petitioner shall file a supplement to his petition to intervene which must include a list of the contentions which petitioner seeks to have litigated in the matter, and the bases for each contention set forth with reasonable specificity."
Prior to any hearing, the Atomic Safety and Licensing Board cust assure itself that each contention presents a genuine issue appropriate for resolution in the proceeding.
"Before commencing an evidentiary hearing, a licensing board must, of course, pass upon the sufficiency of every contention contained in an intervention petition which has previously been granted. And... the board is to exclude from consideration at that hearing any contention which does not present a genuine issue appropriate for resolution in the proceeding.
Stated otherwise, the hearing is not to embrace a contention which either (1) as presented, fails to satisfy the requirements of 2.714; or (2) can be summarily rejected on the merits under the provis Section 2.749 of the rules of practice.gns of
~1/
See Duquesne Liaht Co., et al (Beaver Valley Power Station, Unit tio.1), ALAB-108, 6 AEC 243, 245 (April 2,1973); Virginia Electric and Power Co. (North Anna Power Station, Units 1 and 2), ALAB-146, 6 AEC 631, 633 (Sept.14,1973); Wisconsin Electric Power Co., et al.
(Point Beach tiuclear Plant, Unit 2), ALAB-137, 6 AEC 491, 505 (July 17, 1973),
y Mississippi Power and Light Co. (Grand Gulf fluclear Station, Units 1 and 2), ALAB-130, 6 AEC 423, 424-25 (June 19, 1973).
2235 250
. As an illustration of this principle, in the Beaver Valley case, the Appeal Board stated that a Licensing Board:
"... must be satisfied, with respect to each con-tention which the petitioner seeks to litigate, that a genuine issue in fact exists.
Any con-tention which on preliminary examination does not survive the application of that standard is to be excluded pom consideration at the evidentiary hearing.'-
[ Emphasis added]
As will be shown later, by the attached Staff affidavit, both the PIRG and Carolina Action Contention lack a sufficient factual basis to be allowed to go to hearing in this proceeding. The inadequacy of the Intervenors' position are further spotlighted by the discovery responses to the Staff interrogatories.
B.
Summary Disposition Under 10 C.F.R. Section 2.749 In addition to the factual basis requirement of Section 2.714, the Commis-sion's rules provide that a moving party is entitled to summary disposition if it can be shown that there are no material issues of fact to be adjudi-cated at the hearing.
10 C.F.R. Section 2.749. That Section states:
Summary Disposition on Pleadings Section 2.749 Authority of presiding officer to dispose of certain issues on the pleadings.
(a) Any party to an initial licensing proceeding may, at least forty-five (45) days before the time fixed for the hearing, move, with or without supporting affidavits, for a decision by the presiding officer in that party's favor as to all or any part of the matters involved in the proceeding.
1/
Duquesne Light Co., et al. (Beaver Valley Power Station, Unit No.1), ALAB-109, 6 AEC 243, 245 ( April 2,1973).
2235 251
. The rules governing wmmary disposition are analogous to the law of Summary Judgment in the Federal Courts under the Federal Rules of Civil Procedure,1/ n that the moving party must demonstrate that there is no i
genuine issue of fact remaining to be decided and that the uncontroverted facts entitle him to judgment as a matter of law.2/ Affidavits setting forth the material facts about which there are no genuine issues to be heard may accompany the motion to dispose of issues on the pleadings, and the affivadits may be supplemented or opposed by depositions, answers to interrogatories, or further affivadits.3_/
Summary disposition is appropriate in administrative hearings because it makes possible the prompt disposition of a case on its merits without a formal hearing by permitting a party to pierce his opponent's pleadings by presenting material evidence in affidavit fona which establishes that no factual dispute exists.O The Staff submits that such a procedure for saving hearing time by culling out baseless allegations is particularly appropriate in the instant case since, as will be shown below by affi-davits, and by the parties' discovery responses, there is no factual basis for the contentions which are the subject of this motion.
~1/
Alabama Power Company (Joseph M. Farley Plant, Units 1 and 2),
ALAB-182, 7 AEC 210, 217 (March 7,1974); Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), LBP-74-36, 7 AEC 877, 78 (May 17,1974); Gulf States Utilities Comoany (River Bend Station, Units 1 and 2), LBP-75-10, i NRCI 246, 247 (March 20, 1975).
2/
Adikes v. Kress, 398 U.S.144,158-161 (1970).
3/
10 C.F.R. Section 2.749(b).
-4/
Gellhorn and Robinson, Summary Judament in Administrative Adjudication, 84 Harvard L. Rev. 612 (1971).
2235 252
. IV.
ARGUMENT IN SUPPORT OF MOTION FOR
SUMMARY
DISPOSITION The Staff's Motion for Summary Disposition deals with the following contentions.
P!RG's Contention reads as follows:
Intervenor contends that the prospect of a traffic accident involving a reactor waste carrier and involving leakage of some of the contents of said carrier poses an emergency situation which public safety of ficials in Charlotte (i.e., police chief, fire chief, civil defense head, etc.), are not adequately preparedyo handle in regards to protec-tion of the public.-
Carolina Action's Contention No. 4 reads as follows:
Carolina Action contends that Oconee spent fuel should not be shipped to McGuire because North Carolina has an unproven ability to deal with an emergency accident of the proportions that a nuclear transport accident would cause. The cost of repairs and evacua burden to the taxpayers of this state.gons are an unfair As these two contentions cover essentially the same subject matter, and, as PIRG and Carolina Action have been consolidated in this proceeding, the Staff addresses both contentions in this Motion for Summary Disposition.
1/
PIRG's contention was admitted to this proceeding by the Board's Order of Fet,ruary 27, 1979 wherein PIRG was also consolidated with Intervenor Carolina Action.
2/
This contention was stipulated to by the parties in the " Stipulation of Carolina Action, the Nuclear Regulatory Commission Staff and Duke Power Company Relating the Admission of Contentic7s" dated Octo-ber 18, 1978. These stipulations were accepted by the Board in its Order following prehearing conference dated November 2,1978.
2235 253
. With regard to PIRG's contention, the underlying presumption is that an accident involving spent fuel would be of significant portions.
See PIRG's Response of April 21, 1979 to the Staff's Interrogatories specifi-cally Response B wherein PIRG asserted the position that "...the nature and magnitude of the detrimental results or effects of an accident require that safety be given an extreme priority...."
This presumption, i.e.,
that a nuclear transport accident would produce severe consequences, is invalid.
For spent fuel casks which will be used in the proposed action are designed to stringent U.S. Nuclear Regulatory Commission standards.
(Statement of Material Facts, No.1.)E Compliance with the Commission's regulations, specifically the require-ments of 10 C.F.R. Part 71, provides high assurance that the spent fuel cask can survive a wide range of transportation accidents without the release of significant radioactivity.
(Statement of Material Facts, No. 2).
Thus, PIRG's presumption that a spent fuel accident, no natter how unlikely, will nevertheless be severe, is faulty.
PIRG's erroneous presumption is further exposed by actual testing perfonned on coent fuel casks and experience gained from actual transportation accidents.
Both extensive testing and actual accident transportation experience demonstrate that spent fuel cask accidents
't result in significant radioactive releases.
(Statement of Materia Facts, Nos. 3 and 4).
-1/
References are to the " Statement of t'aterial Facts as to Which There is No Genuine Issue", which is attached.
2235 254
. The Commission accidert test standards are equivalent to conditions for severe accidents. The risk associated with spent fuel transport acci-dents beyond the severe category is low because the probability of extreme accidents occurring is remote.
(Statement of Material Facts, Nos. 5 and 6).
It should be noted that the types of accidents upon which PIRG relies to make its claim of severe consequuces are precisely those analyzed by the Staff in its EIA.
See PIRG Response A wherein PIRG concedes that:
...PIRG's postulated accidents correspond to the five categories of severity outlined in the Environ:. ental Impact Appraisal developed for the proposed transport of spent fuel.
But the Staff's analysis of these precise scenarios demonstrates that the consequences of such postulated accidents will not be significant.
Llhile certain amounts of radioactivity can be released under the Commission's regulations in accidents up to and including the severa category, the consequences of such releases are minimal.
Doses range from a total body dose to the maxinum individual of 1x10-4 mrem for an undetected leakage of coolant accident to a total body dose to the maximum individual of 1.1x10- mrem for the cask overpressurization accident.
(Statement of Material Facts, No. 7 and 8).
In addition, the Staff analyzed accidents beyond the severe category even though such accidents are extremely remote and the associated risk is low.
(Statement of Material Facts, No. 9).
.g.
The Staff analyzed the extra severe collision or overturn accident.
By virtue of cask design, massive rupture and subsequent release is pre-cluded, flonetheless, the Staff analyzed consequences presuning cask failure and some creep rupture of the fuel cladding. The maximum individual whole body dose commitment is estimated as 0.28 rem.
The population whole body dose commitment for Population Center B is esti-mated at 370 person-rem.
Th#s population dose would mean 0.04 latent cancer fatalities or essentially no health effect.
(Statement of Material Facts, flos.11 and 12.)
Finally, the doses from any decrease in shielding capability of the cask would not be significant. An accident may bring about some reduction in shielding capability but, by regulation, such reduction shall not be sufficient to increase the external radiation dose rate to more than one rem per hour at 3 feet from the external surface of the package.
In this case, the dose rate would be only 10 mrem /hr at a distance of 30 m.
It is not likely that the general public would acquire significant doses under these circumstances.
(Statement of Material Facts, t!os.13 and 14.)
Thus, there simply will not be, even in the worst case, the type of accident which PIRG envisions.
Should a scent fuel accident occur of even severe portions, cask breach is unlikely.
And even in the event of cask breach, the radiological releases are minor and the consequences insignificant.
2235 256
. This is why no specific Commission regulation relative to emergency response exists in this area. There is no demonstrated basis for con-sidering that spent fuel accidents are signficantly different from other trans,portation accidents which nomally occur and with which state and local officials are capable of dealing.
(Statement of Material Facts, No. 15.)
Even though there is no Commission requirement for an emergency response plan, it should be noted that North Carolina has responded to radiological accident situations and that both North Carolina and the City of Charlotte have taken steps to enhance their respective response capabilities.
(Statement of Material Facts, Nos.17 and 18.)
In summary, PIRG's contention is without merit.
It presumes that spent fuel cask accidents would be of significant proportions.
The record does nct support this presumption.
Rather, it overwhelmingly rejects it.
Spent fuel accidents, should they occur, are simply not significant. And should they occur, state officials operating under present emergency response procedures can adequately deal with them.
The Carolina Action contention may be dismissed in like fashion.
It is also rooted in the presumption that a spent fuel accident would be sig-nificant in its effects.
The arguments made above with regard to PIRG apply with like force to Carolina Action's contention.
Spent fuel 2235 257
. transportation accidents are simply not significant and state officials are capable of dealing with them.
Carolina Action's contention does raise an element which is beyond the PIRG contention. Carolina Action claims that the cost of repairs and evacuations associated with spent fuel accidents would be an unfair burden to the taxpayer. Again, this claim presumes that spent fuel transport accidents are significant.
The facts clearly reject this proposition.
As the types of accidents associated with spent fuel shipments are largely no different than those of any other traffic accidents with which State and local of ficials nave a demonstrated ability to deal (Statement of Material Facs,
. 15), there is no basis to support Carolina Action's claim that the ;ost of repairs and evacuations associated with spent fuel accidents would be an unfair burden to the taxpayers to the State of North Carolina.
Rather, should a spent fuel traffic accident occur, the repairs and evacuations associated with such an accident would be of the same nature and kind as the repairs and evacuations that would be associated with other traffic accidents and thus could not be considered an unfair burden to the taxpayer.
(Statement of Material Facts, No.16).
2235 258
. V.
CONCLUSION For these reasons given above, both the PIRG and the Carolina Action Contentions are without merit and should be summarily dismissed by this Board.1/
Respectfully submitted, Richard K. Hoefling Counsel for NRC Staff Edward G. Ketchen Counsel for NRC Staff Dated at Bethesda, Maryland, this 11 day of May,1979
-1/
It should be noted that Carolina Action has repeatedly refused to respond to Staff discovery and the Staff suggests that this con-duct be considered by the Board in its ruling on the Carolina Action contention.
2235 259
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
DUKE POWER COMPANY
)
Docket No. 70-2623 (Amendment to Materials License
)
SNM-1773 for Oconee Nuclear Station
)
Spent Fuel Transportation and
)
Storage at McGuire Nuclear Station)
)
STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS N0 GENUINE ISSUE 1.
The spent fuel cask which will be used to transport spent fuel from the Oconee facility to the McGuire facility will require a certificate of compliance from the Nuclear Regulatory Commission certifying that the cask meets all applicable Commission regulations.
(Affidavit of C. Vernon Hodge, William H. Lake, Jr. and R. Daniel Glenn (Hodge Affidavit), pp. 2-3; Environmental Inpact Appraisal Related to Spent Fuel Storage of Oconee Spent Fuel at McGuire Nuclear Station - Unit 1 Spent Fuel Pool (EIA, pp. 17, 33.)1/
2.
Certification of a spent fuel cask to the Commission's regulations provides high assurance that the cask can survive a wide range of trans-portation accidents without the release of significant radioactivity.
(Hodge Affidavit, pp. 4-5; EIA, pp. 33-37).
-1/
The attached affidavit of Brett S. Spitalny attests to the accuracy of the Staff's EIA.
2235 260 7H 6cloW F
. 3.
Spent fuel casks have been the subject of extensive testing including Department of Energy sponsored full-scale impact tests demonstrating that casks can contain and shield their contents under accident conditions.
(Hodge Affidavit, p. 5; EIA, p. 33).
4.
Actual experience with spent fuel cask shipments includes data on two accidents.
In neither case did a radioactivity release occur.
(Hodge Affidavi t, pp. 6-7. )
5.
Transportation accidents have been classified by degree of severity.
That classification shows that as accident severity increases, the con-sequences increase but that the risk (probability x consequences) remains small for all accident conditions. This is so because the probability of extreme accidents occurring is remote.
(Hodge Affidavit, pp. 7-8; EIA, pp. 33-34).
6.
The 10 C.F.R. Part 71 accident test standards are equivalent to conditions for severe accidents. The acceptance standard for these tests is no release of radioactive contents except for radioactive gases and contaminated coolant containing total radioactivity not exceeding the specified small quantities of 10 C.F.R. Part 71.36.
(Hodge Affidavit, pp. 8-9; EIA, pp. 33-34).
7.
The Staff has analyzed a minor accident of undetected leakage of coolant and moderate accidents associated with loss of neutron shield water and cask overpressurization.
(EIA, pp. 34-35.)
2235 261
. 8.
The radiological consequences of these accidents are insignificant ranging from a total body dose to the maximum individual of 1x10- arem for undetected leakage of coolant to a total body dose to the maximum
-2 individual of 1.1x10 mrta for the cask overpressurization accident.
In the case of loss of neutron shield water, a member of the public at 10 m from the cask for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> would receive a dose equivalent to 1% of natural background.
(EIA, pp. 34-35).
9.
For postulated accidents beyond the severe category, the likelihood of occurrence is extremely low and so the associated risk is low.
(Hodge Affidavit, p. 8; EIA, p. 34).
10.
The Staff has analyzed an extra severe collision on overturn acci-dent.
By virtue of cask design, massive rupture and subsequent releases are precluded.
(EIA, p. 36).
11.
The Staff has further analyzed the consequences of this accident presuming cask failure by breach of the closure head seal by failure or by the cask lid bolts being sheared off.
The Staff postulated some creep rupture of the fuel cladding.
(Hodge Affidavit, p. 10; EIA, p. 37).
12.
Doses due to this postulated accident were calculated.
The maximun individual whole body dose commitment is estimated as 0.28 rem.
The population whole body dose commitment for Population Center B is estimated at 370 person-rem. This population dose would mean 0.04 latent cancer 2235 262
fatalities or essentially no health effect.
(Hodge Affidavit, pp.10-11; EIA, pp. 37-38.)
- 13. A spent fuel transportation accident may bring about some reduction in shielding capability but, by regulation, such reduction shall not be sufficient to increase the external radiation dose rate to more than one rem per hour at three feet from the external surface of the package.
(Hodge Affidavit, p.12.)
14.
By virture of this shielding requirement, the distance at which the dose rate would be 10 mrem /hr is estimated to be about 30 m.
It is unlikely that the general public would acquire significant doses under these circumstances.
(Hodge Affidavit, p. 12.)
15.
Sufficient care is taken with designs of spent fuel casks that consequences of transportation accidents involving them are largely no different from those of any other transportation accidents.
(Hodge Affidavit, p. 12.) For this reason, the NRC does not require emergency response capabilities for the protection of public health and safety.
(Hodge Affidavit, p.17.)
16.
The possibility of a transportation accident involving a spent fuel cask would not be an unusual burden to the taxpayers of North Carolina as these accidents are largely no different from those of other transporta-tion accidents.
(Hodge Affidavit, pp. 12-13.)
2235 263
, 17.
State and local officials do have the capability to respond to transportation accidents involving spent fuel casks. North Carolina has responded to two such incidents.
(Hodge Affidavit, pp.12-15.)
- 18. Both the State of North Carolina and the City of Charlotte, North Carolina are taking steps to improve their respective response capabili-ties.
(Hodge Affidavit, pp.15-16.)
2235 264
UtiITED STATES OF AMERICA fiUCLEAR REGULATORY COM11ISSIOt1 BEFORE THE ATOMIC SAFETY Ar4D LICEtiSItG BOARD In the Matter of
)
)
DUKE POWER COMPAt4Y
)
)
(Amendment to Materials License
)
Docket tio. 60-2623 Stim-1773 for Oconee fluclear Station
)
Spent Fuel Transportation and Storage )
at McGuire fluclear Station)
)
AFFIDAVIT OF BRETT S. SPITAL?lY I, Brett S. Spitalny, am employed by the fiuclear Regulatory Commission in the Office of i;uclear Material Safety and Safeguards, Fuel Reprocessing and Recycle Branch, as the project manager for the amendment to materials license Stim-1773.
I have prepared, or assisted in the preparation of, the f4RC Staff's " Environmental Impact Appraisal Related to Spent Fuel Storage of Oconee Spent Fuel at McGuire fluclear Station - Unit 1 Sper : Fuel Pool", Docket tio. 70-2623, dated December, 1978.
~
That document is true and correct to the best of my knowledge.
d) u Brett S. Spitalny _E Subscribjdandsworntobeforeme 7
this //.-day of A14y,1979.
tiotar_ Public 2235 265 My Commission Expires: h M f Q,
[./
s STATEMENT OF PROFESSIONAL QUALIFICATIONS BRETT S. SPITALNY I have been employed as a Process Licensing Engineer by the U. S.
Nuclear Regulatory Commission since January 1978.
This position is in the Fuel Reprocessing and Recycle Branch of the Division of 3
Fuel Cycle and Material Safety of the Office of Nuclear Material Safety and Safeguards.
This branch is responsible for licensing actions for irradiated fuels including licensing facilities for spent reactor fuel storage, facilities for spent fuel processing, and facilities for processing of materials recovered from spent fuel.
I am the NRC Project Manager for the Duke Power Company proposal of transporting spent fuel, and in this capacity am directly respor.sible for the health, safety and environmental reviews of thi action. My.
responsibilities also include that of environmental project manager for the proposed expansion and license renewal of General Electric's Morris Operation Fuel Storage Facility.
Prior to my assignment at NRC, I was employed by the Department of the Navy.
My affiliation with the Navy for 31/2 years was separated into two major capacities.
From November 1976 until January 1978, while located with the Naval Ship Enginee-ing Center 2235 266
3 s
2_
in Washington, D. C., I was employed as a General Engineer for a maintenance and reliability. group for the extended operation of Polaris / Poseidon SSBN Nuclear Submarines.
Responsibilities included evaluating system performance and response to maintenance and testing.
The ultimate Soal was to improve system reliability and extend the operating cycle of the systems and subsequently the ships.
From 1974 until October 1976, I was employed at Norfolk Naval Shipyard as a Mechanical Engineer in the Nuclear Production Department.
I was assigned as a Nuclear Ship Superintendent.
Responsibilities included scheduling, authorizing and overseeing all nuclear production on the overhaul of the ships.
I became qualified to work on SSN 637 class nuclear submarines, and CVN-68 class nuclear aircraft carriers.
This position required extensive training on Westinghouse and General Electric design (~ ubmarine) reactor power plants, and s
Westinghouse (carrier) plants.
Qualifications also included successful completion of the eight week U. S. Navy Nuclear Ship Superintendent School at Puget Sound Naval Shipyard, Bremerton, Washington.
I was also assigned the man-rem reduction program for Norfolk Naval Shipyard under direct control from Naval Reactors.
Prior to joining the Department of the Navy, I was employed by Cessna Aircraf t Company through 1973 and 1974.
I was employed as a Structural Engineer, and analyzed T-37 aircraf t for structural damage and fatigue.
2235 267
3 r
~
,, ~
I received a Bachelor of Aeronautical Engineering Degree from Embry-Riddle Aeronautical University in 1973 and have done graduate work in Business Administration and Thermal Engineering at Wichita State University and Old Dominion University.
~
2235 208
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
DUKE POWER COMPANY
)
)
(Amendment to Materials License
)
Docket No. 70-2623 SNM #1773 for Oconee Nuclear
)
Station Spent Fuel Transportation
)
and Storage at McGuire Nuclear
)
Station)
)
AFFIDAVIT OF C. VERNON H0DGE, WILLIAM H. LAKE, JR.
and R. DANIEL GLENN Introduction Our names are C. Vernon Hodge, R. Daniel Glenn, and William H. Lake, Jr.
Copies of our professional qualifications are attached.
This affidavit addresses the following contentions:
Carolina Action contends that Oconee spent fuel should not be shipped to McGuire because North Carolina has an unproven ability to deal with an emergency accident of the proportions that a nuclear transport accident would cause. The cost of repairs and evacuations are an unfair burden to the taxpayers of this state.*/
Intervenor contends that the prospect of a traffic accident involving a reactor-waste carrier and involving leakage of some of the contents of said carrier poses an emergency sit-uation which public safety officials in Charlotte (i.e., police chief, fire chief, civil defense head, etc.) are not adequately prepared to handle in regards to protection of the public. **/
- / This contention is raised by Carolina Action as Contention 4 of the " Stipulation" dated October 18, 1978.
- / This contention is the only contention raised by the Davidson Chapter of the North Carolina Public Interest Research Group.
2235 269
_2 Discussion These contentions imply that a transportation accident involving one of the proposed spent fuel shipments from Oconee to McGuire would be of such severe consequences that State and local emergency response forces could not manage the situation, that the health and safety consequences could not be minimized, and that the economic consequences would be extraordinary. Concern over the adequacy of State and local emergency response capabilities is minimized when it is realized that the probability is very small that one of these shipments would be involved in an accident severe enough to challenge the containment capability of the spent fuel cask and that even if such an accident occurred, the radioactive release would not cause significant health consequences.
Spent fuel is highly radioactive and requires heavy shielding for safe handling. Massive, durable, heavy casks are required to transport these materials. The form of spent fuel is the same as that of new fuel except for differences in chemical composition and physical properties due to irradiation - spent fuel pellets contain fission products in both gaseous and solid state. The pellets are clad with light metal and assembled in rods and elements which are tightly inserted into spent fuel casks. Both the form of the material and the heavy casks in which it is shipped protect against consequences to public health and safety that would otherwise result from transportation accidents.
2235 270
. A spent fuel cask is generally cylindrical in shape and about 20 feet long. The basic components include a steel inner vessel which contains the fuel elements and spacers or neutron absorbers to assure nuclear subcriticality. The inner vessel is surrounded by several inches of shielding (dense metal for attenuation of gamma radiation) encased in a steel jacket. Several inches of hydrogenous material (such as water) for attenuation of neutron radiation surround the gamma shield. A steel outer jacket completes the package. The cask may also be equipped with sacrificial impact limiters to absorb forces involved in impact accidents.
The closed inner vessel is filled with the primary coolant (air, helium, water) to aid in the dissipation of heat generated by radioactive decay.
The designs of spent fuel casks are regulated by the Depar tment of Transportation (D0T; 49 CFR Parts 170-189) and by the Nuclear Regulatory Commission (NRC; 10 CFR Part 71). The NRC reviews the designs for certification of compliance with the requirerents of 10 CFR Part 71.
The review addresses the capability of the package design under both normal and accident conditions to retain its radioactive contents, to shield the external environment from the radiation of its contents, to dissipate its internal heat to the external environment at a safe rate, and to assure nuclear subcriticality.
In addition, the package design is reviewed with respect to quality assurance in acceptance, operations, and maintenance.
Standards for these apsects are also prescribed in 10 CFR Part 71.
2235 271
. In seeking to protect public health and safety from the effects of transportation accidents, the NRC regulations prescribe a performance standard and an acceptance standard for each pac < age of radioactive material.
In the case of a spent fuel cask, the performance standard is a series of tests applied sequentially and the acceptance standard is essentially no release of radioactive material.
It must be recognized under the test conditions some coolant or gaseous material entrained in the coolant or in the gap between fuel cladding and fuel pellet may be released from the cask.
Release of this material would not be significant to public health and safety; the acceptance standard limits the quantities of such releases to assure that they would not be significant.
These casks are designed to withstand, without release of radioactive material in excess of the regulatory limits specified in 10 CFR Part 71.36(a)(2), a severe accident damage test sequence to simulate the effects of severe impact, puncture, fire, and immersion in water as specified in Appendix B of 10 CFR Part 71. The test sequence includes:
(1) a free fall from a height of 30 feet onto an essentially unyielding horizontal surface, striking the surface in a position for which maximum damage is expected; (2) a free drop of 40 inches striking (in a position which is expected to cause maximum damage) the top end of a vertical cylindrical steel bar, 6 inches in diameter and at least 8 inches long, mounted on an essentially unyielding horizontal surface; (3) a thermal test in which the cask is exposed to a heat input equivalent to that of 2235 272
. an oil fire (1475 F for 30 minutes); and (4) immersion in water to the extent that all portions of the cask are under at least 3 feet of water for a period of not less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. These test conditions make up the design basis accident for a spent fuel cask, meaning that package designs which meet the criteria under the above conditions provide reasonable assurance that the cask will withstand most severe transportation accidents without the release of significant radioactivity.
Spent fuel casks have been subjected to manytests and analyses to find the most vulnerable aspects of the package designs. Recently, the Department of Energy (DOE) sponsored full-scale impact testing of casks mounted on trucks and a rail car by colliding the vehicles with concrete abutments or speeding locomotives.
In these tests, the casks were not damaged significantly and conclusions were drawn that the abilities of the casks to contain and shield their contents were not impaired in the tests.1/ In a full-scale fire test described in the same document, the rail cask was set in a large pool of jet fuel which was ignited and burned for about two hours. After an hour and a half, the lead shielding had all been melted but was still contained. After that time, a _ mall crack appeared in the outer steel skin of the cask and molten lead was slow)y expelled.1/ The results of these full-scale tests are interpreted by the NRC Staff as data which increases its confidence in the NRC regulations and in the TE reviews of each cask design submitted for approval.
2235 273
. Spent fuel casks have been allowed in the public transpor-tation system for the past thirty years or so.
In a recent survey conducted by the NRC, the annual shipping rate for spent fuel in the United States was estimated for 1975 as about 270 shipments per year.2/
As of 1972, about 3600 shipments of spent fuel had been made. I Two accidents to spent fuel casks have occurred during that time. On December 8, 1971, a truck carrying a spent fuel cask was overturned on a highway in Tennessee.O The accident was apparently caused by an oncoming tractor-trailer veering into the lane of the cask vehicle on a curved portion (150 foot radius) of the road. The driver of the cask vehicle negotiated about 300 feet of the curve, but lost control of the vehicle.
The vehicle came to rest upside down in the ditch beside the road with the leading end of the cask embedded three feet deep in soft soil. The cask had skidded about thirty yards along a ditch with the tractor-trailer attached. Only minor cask damage was discovered in the initial investigation and no additional damage was discovered in subsequent more detailed inspection.
The driver of the cask vehicle was killed in the accident; no other injuries occurred. An Atomic Energy Commission (AEC) emergency response advisory team from its nearby Oak Ridge Operations Office arrived on the scene within an hour of the accident and determined that no radioactive material had escaped from the cask.
Later, careful health physics surveys also revealed no additional radiation from the cask due to the accident. The wreckage and cask 2235 274 were removed from the highway and traffic was restored by law officers.
The cask was transported to its destination on the same day, having been delayed by the accident by seven hours.
In the other accident, which occurred February 9,1978, on a highway in Illinois, a truss-type trailer in which a spent fuel cask was being carried experienced a structural failure.E The vehicle was traveling about 50 mph when it struck a sharp road surface heave, causing the top trailer longerons (structural supports) to buckle and the trailer bottom to drop to tha road surface, after which the driver maneuvered the vehicle to a stop at the edge of the road.
Early observations, later confirmed by closer visual examination, indicated no visible damage to the cask.
No injuries or other property damage occurred. An Illinois agency responded to the accident.
Radiological surveys showed no abnormal conditions.
The trailer was cut away from the cask and the cask was loaded into another trailer and transported the next day to its destination. Traffic was restored by law officers; the highway had been closed to traffic for fifteen hours.
The analysis of transportation accidents involving radioactive materials shipments beings with a study of how severe they are, how frequently they occur, and what might be the possible consequences of them.
In 1972, the Atomic Energy Commission ( AEC), the predecessor agency to the Nuclear Regulatory Commission (NRC), issued " Environmental Survey 2235 275 of Transportation of Radioactive Materials to and from Nuclear Power Plants," WASH-1238.
In this document, accident severity is broken down into five categories.
In order of increasing severity, they are minor, moderate, severe, extra severe, and extreme. The categories are described in Table 6-1 of " Environmental Impact Appraisal Related to Spent Fuel Storage of Oconee Spent Fuel at McGuire Nuclear Station - Unit 1 Spent Fuel Pool" (EIA).N This table includes estimates of the frequencies of these accident severities.
These frequences become more meaningful when they are applied to the proposed shipping campaign. Assuming this campaign consist of 300 shipments in one year of 170 miles each, the number o.' years between accidents of the same severity is given by:
Minor 14 years Moderate 50 years Severe 2500 years Extra Severe 25,000,000 years Extreme 1,000,000,000 years In WASH-1238, the Staff considered that spent fuel casks would meet the regulatory standards for containment, shielding, and criticality in accidents classed as minor, moderate, and severe.
The DOE sponsored accident tests described above indicated that the particular spent fuel cask tested would meet these standards in accidents of greater severity. Accident scenarios of greater severity than the severe category have been considered in both WASH-1238 and in the EIA.
The evaluated consequences in these documents (Appendix B of WASH-1238; 2235 276
. Section 6.1 of FIA) lead to the conclusion that the risk to public health and safety from transportation accidents involving radioactive materials shipments is small.
Even in the event of an extra severe or extreme accident it can be shown that melting of the nuclear fuel is not credible.
Considering for the moment the source of heat within the cask, it should be noted that the maximum internal heat load for a spent fuel cask is limited by an approval condition specific to each cask design.
In setting a maximum acceptable internal heat load, the applicant must demonstrate that the heat can be passively dissipated (that is. without the assis-tance of active auxiliary heat removal systems that may be mounted on the cask vehicle) from the cask following the accident damage tests discussed above, while the cask meets all the shielding, containment, and subcriticality requirements of 10 CFR 71.36. The maximum internal heat load is not sufficient to melt the fuel (uranium dioxide melting temperature exceeds 4500 F) or the fuel cladding (typical cladding material melting temperature ranges from 2600 F to 3300 F).
It is concluded that melting under normal or accident conditions from an internal heat source is not credible.
With respect to external heat sources, the regulatory accident tests include a half hour fire, equivalent to a heat source of 1475 F with an emissivity coefficient of 0.9 radiating to the cask which is assumed to absorb 80 percent of the incident radiant heat which completely 2235 277 surrounds it.
Each spent fuel cask is evaluated against the design basis accident conditions described above to assess the effects of the accident conditions on the ability of the cask to dissipate heat after the sequence of tests. Authorization to use a cask means that the cask can dissipate s'ach heat and therefore the contents will be maintained at temperatures below the melting temperature.
It has been determined that sucn an accident would not result in fuel melt but might result in some creep rupture of the fuel cladding.
Creep failure is a temperature time phenomenon evident at elevated temp-eratures, each material being characterized by its own onset temperature well below its melting temperature.
It is observed as progressive failure under fixed stress and temperature.
Increasing the load on the material or increasing the temperature results in accelerated failure.
Such failure may yield subsequent release of noble gases and possibly small quantitites of volatile solid radionuclides such as cesium and tellurium through an assumed breach in the containment vessel. The consequences to public health and safety from such releases are not significant.
For example, the maximum individual whole body dose commit-ment is estimated in Table 6.3 of the EIA as 0.28 rem.
The population whole body dose commitment estimated in Table 6.3 of the EIA for Population Center B is 370 person-rem.
The average individual dose commitment is estimated as 0.032 rem. Considering that one million person-rem of whole 2235 278 body population dose results in about 120 latent cancer fatalities,2
these population doses would mean 0.04 latent cancer fatalities, that is essentially no health effect.
Temperatures sufficient to produce creep rupture were observed in an analysis of a cask containing more than one fuel element.
For casks containing single fuel elements, such as are proposed to be used in the Oconee-McGuire transfer of spent fuel, significant creep rupture of fuel cladding failure would not be expected for loss of coolant or fire accident conditions.
The NRC Staff has recently examined its regulations on packaging and transportation of radioactive materials.2-Transportation accidents of all severities were considered to obtain an expectation vclue for public health and safety consequences. Assumed accidents involving spent fuel casks shipped at the 1975 rate infer an expected value of about 0.00004 latent cancer fatalities from that year's spent fuel shipping. Another way to express this result is that if the shipping rate is constant at the 1975 value, one would expect accidents to spent fuel casks to result in about 4 latent cancer fatalities in one hundred thousand years of shipping. These health effects would not be manifest at the time of any given accident, but might occur within significant fractions, say 30 years,of individual lifetimes after the accident.
2235 279 Applied to the proposed shipping campaign, and assuming the proposed shipping rate is constant, the expected rate of latent cancer fatalities from accidents is roughly a factor ten smaller than the national value for 1975.
Recognizing that the proposed shipments will not continue indefinitely, the expected health effects must be smaller yet.
The discussion above leads to the conclusion that for all but the most severe transportation accidents, the cask integrity will not reduced.
That is one would not expect the cask to breach in an accident so that a significant quantity of radioactive material could be released into the environment. An accident may bring about some reduction in shielding capability of the cask.
The regulations require that under the package test conditions specified in 10 C.F.R. Part 71, Appendix B, the reducticn of shielding shall not be sufficient to increase the external radiation dose rate to more than one rem per hcur at three feet from the external surface of the package (10 C.F.R. 71.36(a)(1)). This dose rate includes both gamma radiation and neutron radiation that might emanate from the cask. Under these conditions, the distance at which the dose rate would be the regu.latory limit for routine exposure at six feet from the truck (10 mrem /hr) is estimated to be about 30 m. (100 ft).
It is unlikely that indivicuals in the general public would acquire significant doses under such circumstances.
In summary, sufficient care is taken with designs of spent fuel casks that consequences of transportation accidents involving them are largely 2235 280 no different from those of any other transportation accidents.
That being the case, the possibility of a transportation accident involving a spent fuel cask would not be an unusual burder, to the taxpayers of North Carolina. Since no releases of radioactive material are expected in most accidents and only small releases which have no significant effect on public health and safety in severe accidents, protective actions such as evacuation would not appear to be necessary. The tolerated releases specified by the regulations are very small; extensive property damage and decontamination costs wnuld thus not be expected.
Inasmuch as State and local emergency response agencies are called upon to manage transportation accidents often and have some preparation for radiological measurements, they are adequately prepared for transportation accidents involving spent fuel casks.
Since 1975, two transportation incidents in North Carolina have drawn particular c.ctention. The first was a truck incident involving a load of low specific activity material being shipped from the Millstone Nuclear facility in Connecticut to Savannah River. When the driver pulled into a truck stop in North Carolina he noticed that the lid of one of the crates was loose. He immediately called the State Highway Patrol who in turn called a representative of the Radiological Health Office of North Carolina.
This office responded to the scene and deterinined that a leakage had occurred of about three tablespoons of water which was slightly radioactive and came from condensation on some 2235 281 of the metal parts in the box. The radiological health officer was slightly contaminated but was able to clean himself off by washing. The lid was then put back on the crate and the truck proceeded on its way.
An NRC inspector indicated that, in his professional judgment, the amount of radioactivity released was insignificant.
The State radiological health officer concurred with this opinion.
In this incident, concern was generated by lack of adequate communications and understanding rather than by health consequences. The actual response capabilities of the State, the shipper, or the carrier were not questioned.
The second incident involved a derailment of 29 cars from a Seaboard Coastline train at 7:30 a.m. on March 31, 1977 near Fort Bragg and Rockingham, North Carolina.
Included in the shipment were four 16-ton casks of unenriched uranium hexafluoride enroute to the Paducah, Kentucky gaseous diffusion plant. The UF casks were slightly damaged in the 6
accident and in the resulting fire, but no radioactivity was released.
A large number of agencies responded to this incident.
The Division of Civil Preparedness of North Carolina was notified at 8:30 a.m. of this accident and the Radiation Protection Branch of the North Carolina Department of Human Resources was notified at 8:45 a.m.
After preliminary inquiries to the designated consignee, Union Carbide in Paducah, Kentucky and to the carrier, Seaboard Coastline' in Raleigh, 2235 282
. the North Carolina Radiation Protection Emergency Team departed by Highway Patrol helicopter, arriving at the accident site at 11:00 a.m.
Before tnis team arrived, however, the following groups of people had arrived:
(1) State Highway Patrol, (2) County Sheriff, (3) Civil Preparedness Area Coordinator, (4) Seaboard Coastline officials, (5) Fire Department, (6) ambulance and rescue squad, (7) news reporters, and (8) the Fort Bragg Emergency Ordinance Disposal Team.
As assessment cad recovery operations proceeded, the following groups of people arrived at the accident site:
(1)
Energy Research and Development Administration (ERDA) team from Oak Ridge, Tennessee, (2) ERDA team from Savannah River in South Carolina, (3) South Carolina Division of Radio-logical Health Mobile Laboratory, (4) EPA representative from Atlanta, (5) NRC representative from Atlanta, (6) National Transportation Safety Board representative from Washington, (7) North Carolina Department of Natural and Economic Resources, Fayetteville Regional Office representative, (8) Union Carbide representative from Oak Ridge, Tennessee, and (9)
Transnuclear, Inc., representative (shipper).
The response to this transportation accident has been criticized, mainly because of a lack of adequate communications. The incident did show that State and other agencies were able to respond promptly and were willing and anxious to provide available resources to cope with radio-logical aspects of transportation accidents.
2235 283 To improve its capability for responding to all radiological incidents, the Radiation Protection Section of the North Carolina Department of Human Resources has developed an emergency plan for responding to emergencies at fixed nuclear facilities as well as a separate plan for responding to transportation accidents. The fixed facility plan is presently under review by the NRC sponsored Federal Regional Advisory Committee for Emergency Planning, which should be completed by July 1979. Additionally, the State of North Carolina has increased its technical staff and enhanced its analytical ability by developing fixed and mobile radiological laboratories. Also, through formal agreements that have been established through the Southern M.itual Radiological Assistance Plan (SMRAP) and the Interagency Radiological Assistance Plan (IRAP). the State of North Carolina would have available the radio-logical capabilities of other State and Federal Agencies in the event of a transportation accident. Also, the State of North Carolina recently passed a prior notification law that requires that the North Carolina State Patrol be notified in advance of radioactive shipments and the notification must include times and routes of the shipment. After receiving the notification, the State Patrol notifies the Radiation Protection Section, North Carolina Department of Human Resources.
The North Carolina Department of Human Resources has experienced success with the Notification program and has made radiation inspections of numerous shipments.
The inspectors have indicated that the shipments have been in acceptable order.
2235 284 Emergency planning for the City of Charlotte, North Carolina, for a transportation accident is coordinated by the Mecklenburg County Civil Defense Preparedness Agency.
Presently, the Agency is in the process of preparing additional accident planning coordinated with other State, County and City Agencies.
Discussions are underway between the City of Charlotte and the Duke Power Company concerning the escort by the utility of any Oconee-McGuire shipment.
Conclusion Sufficient care is taken with designs of spent fuel casks that conse-quences of transportation accidents involving them are largely no different from those of any other transportation accidents. The NRC has confidence in its regulations on packaging and in the cask designs it authorizes for transportation of spent fuel that public health and safety is protected under both normal and accident conditions. Accordingly, the NRC does not require emergency response capabilities for protection of public health and safety.
Officials of the State of North Carolina have responded to two transportation incidents. Officials of both the 2235 285 State of North Carolina and the City of Charlotte, North Carolina are taking steps to improve their response capability.
We certify that the above statements are true and correct to the best of our knowledge and belief.
AlheDt.
A C. Vernon Hodge g
b L,
William H. Lake, Jr.
R. Daniel Glenn Subscripgd and sworn to before me this /o dayofMA/
, 1979.
44 g gg 2235 286 Notary Public My Commission Expires:%/j /9 7.1.,
(/
0 If Jefferson, Robert M.:
" Statement for the Senate Subcommittees on Science, Technology, and Space and Surface Transport," Sandia Laboratories (August 16,1978).
2_/ " Final Environmental Statement on the Transportation of Radioactive Material by Air and Other Modes," NUREG-0170, U.S. Nuclear Regulatory Commission, Office of Standards Development (December 1977).
3] " Environmental Survey of Transportation of Radioactive Materials to and from Nuclear Power Plants," WASH-1238, U.S. Atomic Energy Commission, Directorate of Regulatory Standards (December 1972),
- p. 61.
y Chandler, John M..
"The Peach Bottom Spent Fuel Element Shipping Cask Accident, December 8,1971," ORNL-TM-3844, Oak Ridge National Laboratory (July 1972).
5] Best, Ralph E.:
Letter to C. E. MacDonald, U.S. Nuclear Regulatory Commission, with attached memorandum on the subject:
" Transportation Accident Involving NAC Truss-Type Trailer and NAC-1 Cask Serial Number C," Nuclear Assurance Corporation (February 22,1978).
6] " Environmental Impact Appraisal Related to Spent Fuel Storage of Oconee Spent Fuel at McGuire Nuclear Station - Unit 1 Spent Fuel Pool," (EIA), Docket No. 70-2623, U.S. Nuclear Regulatory Commission, Office of Nuclear Material Safety and Safeguards (December 1978).
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PROFESSIONAL QUALIFICATICNS C. VERNON H0DGE TRANSPORTATION BRANCH DIVISION OF FUEL CYCLE AND MATERIAL SAFETY My name is C. Vernon Hodge.
I have been employed by the U. S. Nuclear Regulatory Commission since February 1975. My position is in the Transportation Branch of the Division of Fuel Cycle and Material Safety of the Gffice of Nuclear Material Safety and Safeguards. My responsibilities and activities include the following endeavors:
Review of environmental statements dealing with transportation of radioactive materials, including:
" Transportation of Radioactive Materials by Air and Other Modes," NUREG-0170 (1977),
'IGeneric Environmental Statement on Use of Mixed Oxide Fuel in Light Water Reactors (GESM0)," NUREG-0002 (1976),
and
" Transport of Radionuclides in Urban Environs: Working Draf t Assessment, " SAND 77-1927 (1978);
Writing environmental statements dealing with transportation of radioactive materials, including:
"Calculaticns of Radiological Consequences from Sabotage of Shipping Casks for Spent Fuel and High Level Waste,"
NUREG-0194 (1977),
" Environmental Survey of Waste Management in the Light Water Reactor Fuel Cycle," NUREG-Oll6 (1976);
Testifying before Atomic Safety and Licensing Board panels on contentions dealing with radioactive materials in transportation to and from nuclear power stations; Serving on study panels dealing with emergency response tc radiological accidents, including:
2235 288 b
_2-Technical coordinator for an NRC/ DOT Study Group report
" Review and Assessment of Packaging Requirements (Yellow-cake) and Emergency Response to Transportation Accidents,"
(1978).
This study was initiated at the request of Congressman Timothy Wirth of Colorado after a serious spill of yellowcake in transit occurred in Colorado in September 1977.
Several recommendations were developed for Federal rulemaking and Federal-State interaction to enhance emergency response capabilities of various parties.
Representative for the Office of Nuclear Materials Safety and Safeguards on the NRC/ EPA Task Force on Emergency Planning. This Task Force was convened by the NRC Executive Director for Operations in late 1976 to write guidance for States in the matter of defining the light water reactor accident for which States should plan emergency responses.
The Task Force issued a draf t report MUREG-0396 in 1978, which is now out for public comment.
Advisory Committee to the International Atomic Energy Agency to consider emergency responses to transportation accidents involving radioactive materials.
I was able to contribute considerable data frcm recent NRC studies and activities to the draf t document. A Safety Series document may be produced from this effort in about one year.
Source selection panels for NRC contracts designed to survey the capabilities of State and local government agencies to respond to transportation accidents involving radioactive materials and to develop criteria for evaluating emergency plans for such accidcots.
Serving on groups studyingother aspects of transportation of radioactive materials, including:
Revision of the NRC/ DOT Memorandum of Understanding; Transportation Working Group of the Interagency Review Group on Management of Nuclear Wastes, convened by the President; and Research review group to monitor a recently initiated NRC research program to develop quantitative information on sabotage of spent fuel casks.
2235 289 O
Prior to employment with the NRC, I was employed by an engineering consulting firm, Holmes and Marver, Inc., Anaheim, California.
I was principal investigator for the study " Transportation Accident Risks in the Nuclear Power Industry, 1975-2020," EPA-520/3-75-023 (1975), and reported it to the Fcurth International Symposium on Packaging and Transportation of Radioactive Materials, Miami Beach, Florida, in 1974.
I also was principal investigator for a companion study on routine exposure from transportation.
Other assignments involved a conceptual design of a fuel handling facility in a twin HTGR complex, an environmental statement on cleanup, rehabilitation, and resettlement of the Eniwetok Atoll, and an environmental report for a proposed power plant at Kawaihae, Hawaii.
Prior to my employment with Holmes and Narver, my graduate work involved a post doctoral term in theoretical metallurgy at the School of Engineering and Applied Science, University of California at Los Angeles, and Ph.D. (1972) and M.S. (1969) degrees in physics from the University of Idaho.
Publications during this period include:
"On the Elastic Interaction of Tetragonal Precipitates io Cubic Metals," UCLA-ENG-7392;
" Spin-Orbit Interaction in Model Potential Calculation of Lattic Dynamics of Simple Heavy Metals," Ph.D. thesis (1971);
" Current-Induced Reflectivity Effects in a Semiconductor,"
Phys. Rev. B1, 3347 (1970).
- Prior to graduate school, I was employed with Idaho Nuclear, Inc., and Phillips Petroleum Co. at the National Reactor Testing Station, Idaho, as a critical facility supervisor and as a reactor engineer.
My responsibilities with the critical facility included planning, conducting, and rep]rting reactivity and flus distribution measurements of mockup assemblies of experiment, fuel, and poison simulation lcadings for a test reactor.
My responsibilities as a reactor engineer included operating a high power test reactor and associated engineered experiments.
2235 290
E-I PROFESSIONAL QUALIFICATIONS WILLIAM H. LAKE, JR.
I b
My name is William H. Lake, Jr.
I have been employed by the U. S.
Nuclear Regulatory Commission (U. S. Atomic Energy Commission) since November 1972.
I am in the Transportation Branch in the Division of Fuel Cycle and Material Safety which is in the Office of Nuclear fiaterial Safety and Safeguards.
The Transportation Branch is respon-sible for review and approval for use of shipping packages for fissile material and quantities of other radioactive materials' exceeding Type A quantity limits, in accordance with the requirements of 10 CFR Part 71.
One of my responsibilities is to review the heat transfer and thermal analyses of Safety Analysis Reports provided by applicants in support of approval requests under 10 CFR Part 71.
In addition to my primary technical functions as a heat transfer specialist, my responsibilities also include:
- 1) coordination of the technical evaluations of the various disciplines involved in issuance of a certificate of compliance and preparation of a staff position;
- 2) review of containment performance of packages from the standpoint of fluid dynamics, liquid and particle release; 3) evaluation of operating procedures proposed for the handling of packages (i.e.,
loading, unloading, etc.); 4) evaluation of specific test procedures determined to be significant to safety; and 5) assessment of the operational reliability of systems and components that comprise the containment system.
l I had been employed by Grumman Aerospace Corporation from June 1969 until joining the Atomic Energy Commission (USNRC).
There, I was employed as a thermodynamicist in the Thermodynamics Section.
I was assigned to space programs and was involved primarily in devel "ag technical proposals. My experience involved developing thermaf models of space vehicles in space, atmospheric re-entry environments, and thennal ascects of ground servicing.
I developed the computer programs for aerodynamic heating for the Grumman Aerospace Advanced Development Program which are described in the following reports.
i I
Lake, William, Aerodynamic Heating to Swept Cylinders Using i
the Energy Integral Method of Fleming and Krauss," Grumman Aerospace Corporation, Advanced Development Report No. ADR 01-04-71.2, December 1971 Lake, William, " Aerodynamic Heating Methods for Blunt-Nosed Hypersonic Vehicles," Grumman Aerospace Corporation, Advanced Development Report No. ADR 22-02-73.1, February 1973.
2235 291
My publications in the area of transportation of radioactive materials, which are available in the open literature, are:
Lake, William H., " Capabilities and Limitations of Heat Pipes for Use in Radioactive Materials Shipping Casks As An Alternative to Active Cooling Systems," Proc. 4th Int.
Symp. Packaging and Transportation of Radioactive Materials, Miami Beach, FL, Sept.1974 Lake, William H., " Reliability In Maintenance and Design of Elastomer Sealed Closures," Proc. 5th Int. Symp. Packaging and Transportation of Radioactive Materials, Las Vegas, NV, May 1978.
I earned both my B. S. M. E. and M. S. M. E. from the Polytechnic Institute of Brooklyn (Polytechnic Institute of N. Y.) in 1967 and 1970, respectively.
My graduate school specialization was thermal engineering which included:
heat transfer, thermodynamics, fluid dynamics, and combustion.
My masters thesis was titled, " Simulated Spark Ignition Engine," and involved the study of variations in flame growth of a methane air system, and the resulting engine cylinder peak pressure variations which contribute to performance inefficienty.
In addition, I worked on an experimental investigation of flame propagation in solid rocket fuels which resulted in the following technical note:
Blair, D. W. and Lake, W. H., " Solid-Propellant Flame Zone Radia-tion," A1AAJ, V7, No. 9, Sept. 1969.
I am a member of Sigma Xi, The Scientific Research Society of North Ame ri ca.
I joined, by invitation, as an undergraduate in 1967.
I am also a member of Pi Tau Sigma, which is the mechanical engin-eering honor society.
2235 292
'TW'
'Resley D. Glenn, Senior Development Encineer, Enviror. mental Evaluations Section, Occupational and Environmental. Safety Deoartment, Battelle Pacific North' est Laboratory Education B.S.
Enaineering Technology, Oklahoma State University 1971
~
M.S.
Environmental Health Sciences, University of Michigan 1972 Experience Mr. Glenn specializes in Health Physics and ha's exo5rience in the following areas:
Radiological Enoineerino.
Mr. Glenn has professional experience in radiological engineering which includes evaluation of potential hazards, safeguards, special requirements for new and unique R&D programs and training of health physics technicians.
Exposure Evaluation.
Mr. Glenn has additional experience as exposure evaluation for the Hanford Project.
Duties as exposure evaluation included evaluation of bioassay, invivo and TL dosimeter data in routine and non routine situations to determine occupational radiation exposure received in these situations.
Environmental Imoact.
Mr. Glenn assisted in the generation of the
~
Generic Environmental Impact Statement on Management of Commerically Generated Radioactive Wastes.
Duties included overseeing the evaluation of doses to various population groups from routine and postulated accidental releases.
Additional duties included evaluation of environmental impact associated with trasportation of spent fuel, fuel residues and other radioactive wastes.
Publications,,_
RD Glenn, KR Heid, JR Houston; Assessment of a Cerium-Praseodymium - 144 Inhalation Case; accepted for pu' lication in Health Physics Journal.
o RD Glenn, PE Bramson; Hanford Critical Radiation Dosimeter; PNL-2276.
LG Faust, RD Glenn, et al; A Guide to Good Practices at a Plutonium Facility; BNWL-2086.
KR Heid, RD Glenn; Internal Dosimetry Proaran in a Plutonium Facility, The Plutonium Fuel Cycle, Blil Harbour, Florica, May 1977.
2235 293