ML20005B707
| ML20005B707 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/25/1981 |
| From: | Cutchin J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 8109010289 | |
| Download: ML20005B707 (20) | |
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8/25/81 l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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PENNSYLVANIA POWER AND LIGHT C0.
Docket No. 50-ALLEGHENY ELECTRIC COOPERATIVE, INC.
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(Susquehanna Steam Electric Station, h"b y[.[ "I'UG 31193;s Units 1 and 2)
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IDENTITIES, QUALIFICATIONS AND
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'A TESTIMONY OF NRC STAFF WITNESSES
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In its "Memorandun and Order on Prehearing Conference a
August 14, 1981 the Licensing Board directed that identities, qualifications, subject matter and substance of testimony of expert witnesses on the first seven contentions (or portions of contentions) to be heard at the evidentiary hearing scheduled to begin on October 6,1981 be filed by August 25, 1981.
The identities of the Staff's witnesses on the first seven contentions to be heard and the subject matter and substance of their testimony are provided below. Copies of the professional qualificaticr.s of the witnesses are attached.
1 Contention _1 Those portions of tne contention dealing with the quantities of radon-222 (Rn-222) that will be released during the fuel cycle for the facility.and the radiological health effects of tnose radon releases are KO) the subjects of a motion for summary disposition that was filad by the y
Applicants on August 7th.
If those portions of the contention are
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litigated the Staff's witness on Rn-222 quantities, doses and health effects will be Dr. Edward F. Branagan, Jr. The Staff's witnesses on technetium-99 (Tc-99) will be Dr. Fred D. Fisher on quantities, Dr.
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Richard K. Struckmeyer and Dr. Branagan on doses and Dr. Branagan on health effects. The testimony of the Staff's witnesses will provide current estimates of Rn-222 and Tc-99 and will demonstrate that the estimates of the potential radiological health effects of those isotopes were conservatively presented in the FES (NUREG-0564). The Staff's witness on the radiological health effects of all other isotopes that are listed in Table S-3 of 10 CFR 51 will be Dr. Branagan. His testimony will demonstrate that the estimates of the potential radiological impacts of those radionuclides were conservatively presented in the FES. Thus, the Staff's testimony will demonstrate that the cost-benefit balance for operation of the Susquehanna facility will not change.
Contention 2 Those portions of the contention dealing with the quantities of low-level radioactive releases from the Susquehanna facility and particularly the amounts of cesium-137 and cobalt-60 that will be released into the Susquehanna River are the subjects of a motion for summary disposition that was filed by the Applicants on August 13th.
If those portions of the contention are litigated the Staff's witness on quantities of radioactive releases will be Dr. Charles L. Miller. The Staff's witness on doses and health effects will be Dr. Edward F.
Branagan, Jr. The tertimony of the Staff's witnesses will demonstrate
that the estimates of releases presented in the FES are reasonable for assessing environmental impacts and that the estimates of potential health effects were conservatively presented in the FES. Thus the Staff's testimony will demonstrate that the cost-benefit balance will not change.
Contention 4 The issues raised by this contention (need for power and alternative energy issues) are the subjects of a proposed rule that would amend 10 CFR 51 to preclude consideration of these issues in operating license proceedings. 46 Federal Register 39440-2 (August 3, 1981).
If this contention is litigated nevertheless the Staff's witness will be Dr. Raghaw Prasad.
His testimony will demonstrate that operation of the Susquehanna facility, regardless of the growth in electrical demand or the assumptions made about conservation or solar energy, will result in substantial economic savings from substitution of electricity generated by the Susquehanna facility for other sources of electricity available to Applicants. The Staff's testimony will further demonstrate that at the operating license stage the only reasonable alternative to granting the license is not granting the license and that even that alternative is not environmentally cost-beneficial.
Contention 5 This Contention is the subject of a motion for summary disposition that is pending before the Licensing Board.
If the contention is litigated the Staff's witness will be Pr. Edward F. Branagan, Jr. His testimony will consist primarily of the information contained in his affidavit supporting summary disposition of the contention.
4 Contention 7(a), 7(b), 7(c), and 7(d)
Contention 7(a) is the subject of a summary disposition motion filed by the Applicants on August 4th.
If the contention is litigated the Staff's witnesses will be Dr. Farouk Eltawila and Dr. Chen P. Tan.
Dr. Eltawila will testify that the dynamic forces that would be experienced during postulated blowdown of the Susquehanna reactors have been conservatively specified, and Dr. Tan will testify that the containment structures have been designed to withstand those dynamic forces.
The Staff's witness for Contentions 7(b) and 7(c) will be Felix B.
Litton.
He will testify that the concerns expressed by these contentions have been resolved for the Susquehanna reactors in that the Applicants will comply to the extent practicable with the recommendations of HUREC-0313, Revision 1, " Technical Report on Material Selection and Proccssing Guidelines for BWR Coolant Pressure Boundary Piping" and NUREG-0619, "BWR Feedwater Hozzle and Control Rod Drive Return Line Nozzle Cracking," by replacing service sensitive piping and will conduct augmented inservice inspection of or heat treat that service sensitive piping not practical to replace.
Contention 7(d) is the subject of a motion for summary disposition that is pending before the Licensi.ng Board.
If the contention is litigated the Staff's witness will bc Warren Minners. His testimony w'll consist primarily of the it.f ormation presented in the SER on pages C-8 and C-9 dnd in his affidavit supporting summary disposition of the contention.
Contention 8 Contention 8 is the subject of a motien for summary disposition that is pending before the Licensing Board.
If the contention is
. litigated the Staff's witness will be Felix 8. Litton. His testimony will consist primarily of the information presented in his affidavit supporting sunmary disposition of the contention.
Contentien 17 Only that portion of the contention dealing with the biological health effects of electrostatic fields on living organisms survives and that is the subject of a motion for summary disposition filed by the Applicants on August 18th.
If that portion of the contentien is litigated the Staff's witness will be Gerald E. Gears. He will testify that there is no evidence at the present time that electrostatic fields associated with the operation of a 500 KV transmission line will have significant biological health effects on living organisms.
Respectfully submitted, k
James M. Cutchin IV Counsel for NRC Staff Dated at Bethesda, Maryland this 25th day of August, 1981.
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D' Professional Qualifications h
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I am a Radio' logical Physicist wi I
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l Wy name is Edward F. Er anagan, Jr.
ting the environmental radiologic h
Radiological Assessment Branch in t ePresently, I a in reactor and health effect models for uset Branch for a icpacts from nuclear power seacters,I have been l
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evaluating radioecological mode s in '
h lic University in 1969, an M. A.
licensing.
ity in 1970, and a Ph.D. in Radiat
- years, I received a B.A. in Physics from Cat o Radiation Technology at Haskell Junior Science Teaching from Catholic Univers in 1976.
Biophysics from Kansas University f DNA base damage, and was sup-for my Ph.D., I vas an instructor ofMy research work w My dissertation was ported by"a U.S. Public HealthNuclear Magnetic Resonance Spect College.
been with both the Of fice entitled Bases."
ent and technical Since joining the NRC in 1976, I have
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Material Safety and Safeguards (NMSS, anIn NM55 I was involve timating Regulation (NRR).I was the project man.ger for two contrac These contracts were concerned with e i
mills.
As-radium-226 releases from uran um t on' ric Environmental Impact Stateme work.
Ridge National Labora'.>ry.
ilings.
radiation doses from radon-222 anu Effects of part of my work on NRC's Draf t Gene ted a paper entitled " Health Uranium Milling (DGEIS), I calculate i l Nuclear Power" at a Conferenc Upon publication of the DGEIS, I presen Since joining NRR, I havet entitled Uranium Mining and Milling for Cwmerc a h ologies.
Pl ant'"
(1) managed and main author of a repor Health' Implications of New Energy Tec n ent of the Wyh1 Nuclear Power Argonne ical contact on an NRC contract worked on several projects:
"Staf f Review of 'Radioecological Assessm l te t of a computer program to ca (NUREG-0568), (2) served as a techn d
National Laboratory involving developmenhealth ing Laboratory involving estimated an) dionuclides in the environment; (4 contract with Idaho National Engineer t y ce t with. Lawrence Livermore Labora l es for parameters in terrestrial raidge Nat measured concentrations of ra technical mor.itor on an NRC contrac a technical monitor with Dak R h
s cerning a literature review of va u transport models; and (5) served asLaboratory co ci-Presently, I am a member of the Healt i
e ation for the Advancement of Sc enc.
STATEMENT OF PROFESSIONAL QUALIFICATIONS FRED D. FISHER My name'is Fred D. Fisher.
I am the Leader of the Environmental Radiation and Emergency Support Section in Th fuel Cycle Uranium Fuels Branch in the Division of Fuel Cycle and Material Safety in the Office of Nuclear Material Safety and Safeguards, United States Nuclear Regulatory Commission.
I joined the Nuclear Regulatory Commission in 1972 and have worked in various nuclear j
material licensing and policymaking activities since then including several years on the plutonium recycle (GESMO) proceeding. I testified before the GESM0 hearing board and subsequently upon fuel cycle costs in the Pilgrim II power reactor construction permit proceeding.
Prior to joining the Nuclear Regulatory Commission, I was employed by Westinghouse Electric Corporation, Nuclear Materials and Equipment Corporation (NUMEC), and The General Electric Company in the development, design and operation of radiochemical processes and facilities.
I received a Ph.D. in chemical engineering from Oregon State University in 1960 and a Bachelor of Arts in chemistr from Linfield College in 1954.
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PROFESSIONAL QUALIFICATIONS Dr. R. K. Struckmeyer I am an Environmental Analyst employed by My name is Richard K. Struckmeyer.
the Radiological Assessment Branch in the Office of Nuclear Reactor Regula I am responsible for reviewing and evaluating the radiological impacts on the environment from proposed and existing nuclear power plants, and review of utilities' mergency ph::s :ith regard to their effectiveness for offsite dose m
assessment.
I received a B.S. degree in Physics from Bowling Gre M.?
respectively.
I have 41/2 years of professional experience in health physics and env assessment.
where my major responsibilities concerned dose calc i
f health physics instrumentation, and recommendation of in-plant monitoring instrumentation.ineld a position as a health physicist w radiation doses due to hypothetical releases from a model high-level radioa Agency, Office of Radiation Programs.
i waste repository and preparation of guidance on offsite emergency instrumen Since joining the for assessment of radiological impacts of nuclear incidents.
staff of the Nuclear Regulatory Commission, in March of this year, I h h
responsibilities in three major areas:
radiological impacts of both operating and proposed radiological impacts.
I am a member of Sigma Xi (Research Society of North America) and the H Physics Society, and a past menber of the American Nuclear Society and American Association for the Advancement of Science.
w CHARLES LEE MILLER PROFESSIONAL QUALIFICATIONS DIVISION OF SYSTEMS INTEGRATION OFFICE OF NUELEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY C0", MISSION M
I am currently employed by the U.S. Nuclear t nt Systc.us My name is Charles Lee Miller.
Regulatory Commission as a Nuclear Engineer, Effluent Trea me Reactor Branch, Division of Systems Integration, Office of Nuclear involving the cnvironmental reviews associated with,icensing act Regulation.
f nuclear reactor power plants.
f Maryland I recieved a PhD in Chemical Engineering frem t from the University of Maryland in August of 1971. I am a registered Professional B.S. in Engineering from Widener College.
Engineer (District of Columbia).
Maryland In 1974, I joined t +chtel Power Corporation in the Gaithersburg, l ff.
I was invo office as a Chemical Engineer in their nuclear sta t s and components the review, design, evaluation and selection of sys emI also was responsible f used for trcatrent of radioactive wastes. performing cherm f
lant accidents.
Va. as In 1976, I joined Science Applications Inc. located in Mc a Senior Engineer.
f 1:aste Disposal Alternatives, Nuch;ar Facility Sa egua Reprocessing schemes for Nuclear Fuel.
80.
I have held my position with the Commission since April, 19 l
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PROFESSIONAL QUALIFICATIONS Raghaw Prasad Argonne National Laboratory
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i f the I am an Economist with the Environmental impact Studies Divis o Argonne Nat,onal Laboratory at Argonne, Illinois.of finan h demand and supply cr.d trarepcrt network analysis, as part of theI of different energy resoun.es, preparation of environmental impact statements.1979, and half a dozen statements.
i from I have a Bachelor of Science degree (1961) in Electrical Engine i
degree (1973 Ranchi University, India, a Master of Business Administrat on in Economics from Master of Arts (1977) in Economics, and a Ph.D. CandidacyMy dissertat l
t icity Demand".
I Temple University, Philadelphia.of-day and Lifeline Rate Structure have completed all requirements of a Ph.D. degree.
My respon-From 1961 to 1970, I worked as an operations research analyst.
l cash management, sibilities involved production scheduling, inventory contro,
and capital budgeting.
lth center, From 1971 to 1973, I was a consultant dt a community mental he d family's Albert Einstein Hospital, Philadelphia. Eastern philosophy, yo mental and physical problems.
i Engineering From 1973 to 1974, I was a senior systems analyst with Combus Refractory Division at Valley Forge, Pennsylvania.
Management Infonnation System, and Business Planning Model.
- Univac, From 1974 to 1977, 7 worked as a senior systems plan handie the flow of Blue Bell, Pennsylvania.
oped a financial and accounting inventory control hout the wcrld.
e General Public From 1977 to 1978, I was employed as a senior eco i
Utilities, New Jersey.and industrial electricity demand models, regional e electricity demand forecast.
fit analyses, financial evaluations, and erergy supply and du be incorporated I developed a production and financial ial viability of U.S.
into the environmental impact statements.
i model for estimating the natural gas producticn and f nancThe res Lake Erie Gas Development Program.
the preparation of draft environmental impact statement oI was a Gas Development Program.before a public hearing at Buf falo, New York.
t of I also develope mmission Pennsylvania Emergency Management Agency Washington, D.C.
20555 Transportation and Safety Building
- Atomic Safety & Licensing T.ppeal Board Harrisburg, Pennsylvania 17120 Panel U.S. Nuclear Regulatory Commission Washingten, D.C.
20555
- Secretary U.S. Huclear Regulatory Commission
%TTH: Chief, Docketing & Service Branch Washington, D.C.
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,-.._- m _ % % w w James M. Cutchin, IV Ctunsel for NRC Staff
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