ML20023D769
| ML20023D769 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/31/1983 |
| From: | Dorsey J DORSEY, J.A., LIMERICK ECOLOGY ACTION, INC. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8306030280 | |
| Download: ML20023D769 (27) | |
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NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board .
In the Matter of :
ocket Nos. -35 PHILADELPHIA ELECTRIC COMPANY 53 Limerick Generating Station, ,
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Units 1 and 2 LIMERICK ECOLOGY ACTION RESPONSE TO
~12 CENSING BOARD'S ORDER OF MAY 16, 1983 Introduction
/
On May 16, 1983, the Licensing Board issued a Memorandum and Order (Order) directing the NRC Staff to describe how it will use the Limerick Probabilistic Risk Assessment (PRA) relative to the licensing of that facility, particularly including the EROL-EIS Chapter 7 analysis and any use of comparisons with WASH-1400. Limerick Ecology Action (LEA) was directed to reply to the Staff's submission, and specifically to discuss the effect of recent Commission policy statements and the Staff's intended use of the PRA on its proposed contentions. LEA was directed to indicate which contentions l it wishes to pursue with regard to the PRA and which contentions it wishes to pursue only with regard to Chapter 7 of the EROL.
LEA's response follows.
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NRC Staff's Use of the PRA As LEA understands the NRC Staff's April.13 and May 25 submissions, the Staff intends to use the Limerick PRA as follows:
- 1. In the Staff's safety review of Limerick, it intends to use the PRA as one of its tools for assessing conformance to NRC licensing requirements, particularly through a review of~ dominant accident sequences and the causes for those sequences.
Should its review identify a dominant sequence that is significant to overall safety but is due not to a failure to conform to NRC regulations but to a unique design aspect of the facility itself, compensating measures will be considered for recommendation by the Staff.
As part of its PRA review, a review of other existing PRA's, including WASH-1400, will be carried out by the Staff to test the reasonableness of data and assumptions used in and conclusions resulting from the Limerick PRA.
- 2. In the Staff's environmental review of Limerick for NEPA purposes, it intends to use the PRA to assess the risk of accidents beyond the design bases, for so-called internally initiated accidents other than pressure vessel failure. [ So-called external initiated accidents and pressure vessel failure are addressed in a separate document, the Severe Accident Risk Assessment (SARA) . ] That is, the accident sequence analysis in the PRA, as incorporated into SARA and EROL section 7.1, will be used for the Staff's DES /FES.
3.
- 3. Finally, the Staff intends to compare the overall risk of Limerick with the overall risk of othe~r nuclear facilities, using, in part,.other existing PRA's, including WASH-1400.
Should the overall risk of Limerick be determined to be dis-proportionate, the Staff will consider possible compensatory measures in its recommendations for licensing. (Hereinafter referred to as " comparative risk study.")
The Board has ordered LEA to indicate which of its proposed contentions it wishes-to pursue with regard to the PRA and which existing contentions it wishes to pursue only with regard to Chapter 7 of the EROL.
LEA assumes, though the Staff has not so stated, that the overall risk for Limerick, to be used for its comparative risk study as well as its environmental review, will be derived from its review of section 7.1 of the EROL and its backup document, SARA. Those documents, of course, to a very large extent, incorporate the accident sequence analysis for internal initiators from the PRA.
l LEA also assumes, though again the Staff has not so stated, that it will rely upon the consequence analysis of SARA for its comparative risk study and environmental review, and not on the consequence analysis of the PRA. If LEA's assumptions prove to be incorrect, it may be necessary for LEA to adjust its position on contentions accordingly.
4.
While the Staff's decision to include PRA's other than WASH-1400 for comparative purposes affects some of LEA's contentions, as later noted, LEA strongly supports the Staff's approach to this licensing proceeding, as described in its April 13 and May 25 submissions. Its approach is a sound one for determining whether Limerick can be operated without undue risk to the public health and safety, and LEA believes that existing regulations and present Commission policy permit the approach the Staff has chosen.
Effect of Commission Policy State-ments on Staff Use of PRA Staff Safety Analysis June 13, 1980 Policy Statement In its Statement of Interim Policy, Nuclear Power Plant Accident Considerations Under the National Environmental Policy l
Act of 1969 (" June 13, 1980 Policy Statement"), 45 Fed. Reg.
I 40101, the Commission stated:
I However, it is also the intent of the Commission that the staff take steps to identify additional cases that might warrant early consideration of either additional features or other actions which would prevent or mitigate the consequences of serious l accidents. Cases for such consideration are those j for which a Final Environmental Statement has already been issued at the Construction Permit stage but for which the Operating License review stage has not yet been reached. In carrying out this directive, the staff should consider relevant site features, in-l cluding population density, associated with I accident risk in comparison to such features at presently operating plants. Staff should also consider the likelihood that substantive changes in plant design features which may compensate further for adverse site features may be more easily in-corporated in plants when construction has not yet
5.
progressed very far. Id. at 40103.
Thus, in its June 13, 1980 Policy Statement the Commission, along with its directive that so-called Class 9 accidents be considered in NEPA environmental reviews, publicly announced its then-recently initiated policy of a more in-depth consideration of severe accidents and their prevention or mitigation at selected, high risk sites, largely in response to the accident at TMI. Due to the high population density around Limerick, the NRC Staff requ'ested submission of a PRA for that facility, to be used for the purposes stated in the June 13, 1980 Policy Statement.
Plant-specific safety work related to facilities presently operating is also ongoing, and much of that work is focussed on prevention and mitigation of accidents based upon PRA analyses; in some cases, changes in plant design or procedures are being undertaken. ,
Safety Goal Policy Statement On March 14, 1983, the Commission issued its Policy Statement on Safety Goals for the Operation of Nuclear Power Plants (" Safety Goal Policy Statement"), 48 Fed. Reg. 10772, in which it adopted both qualitative safety goals and quantitative design objectives for use during a 2-year evaluation period. The Commission stated:
6.
The qualitative safety goals and quantitative design objectives contained in the Commission's Policy Statement will not be used in the licensing process or be interpreted as requiring the per-formance of probabilistic risk assessments by applicants or licensees during the evaluation period. The. goals and objectives are also not to be litigated in the Commission's hearings. The staff should continue to use conformance to regulatory requirements as the exclusive licensing basis for plants. Id. at 10775.
The applicant contends that the Commission's directive that its Safety Goal Policy Statement will not be interpreted as requiring performance of PRA's, means that the safety-related PRA work for selected, high-risk sites such as Limerick is to be terminated, and the PRA's for those high-risk sites ignored other than for research purposes. LEA strongly dis-agrees with this interpretation of the Commission's directive, and believes, rather, that there is not, through this policy statement, an across-the-board requirement for performance of PRA's by all licensees and applicants. Nor, in those in-stances where PRA's have been performed and in some cases required, is there to be a requirement in licensing procesdings that the safety goals and design objectives be met as a condition for licensing.
LEA notes for the Board's consideration that had the Commission intended that all safety-related PRA work be terminated and all PRA results ignored, by its directive that its Safety Goal Policy Statement not be interpreted as requiring performance of PRA's, its further directive that safety goals and design objectives not be used in licensing proceedings would have been superfl,ous. Probabilistic risk assessment a
7.
1 is the existing mechanism for deriving information against which to measure conformance to safety goals and design objectives, if and when the Commission decides to institute such a require-
- ment.
It should also be noted that none of the uses to which the Staff intends to put the Limerick PRA constitute an assessment of conformance with the safety goals or design objectives, as suggested by the applicant. The goals and objectives are nowhere even mentioned in the Staff submissions, and the applicant has failed to point out how the Staff's intended uses of the PRA can in any way be interpreted as an assessment of conformance with those goals or objectives.
Rather, the Staff's uses of the PRA constitute a sound approach to a consideration of additional features or other actions which could prevent or mitigate the consequences of serious accidents at a high-risk site, as directed by the Commission in its June 13, 1980 Policy Statement, and as permitted in any case.
by existing regulations.
LEA points out the following sampling of regulatory bases upon which the Staff may rely in its use of the PRA for licensing i purposes:
- 1. 10 CFR SS50.57 (3) and (6), respectively, state that I
an operating license may be issued upon finding that "[t]here is a reasonable assurance (1) that the activities authorized l
by the operating license car, be conducted without endangering i
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the health and safety of the public," and that [t]he issuance of the license will not be inimical to the common defense and security or to the health and safety of the public."
- 2. 10 CFR 550.109(a) states that "[t]he Commission may, in accordance with the procedures specified in this chapter, require the backfitting of a facility if it finds that such action will provide substantial, additional protection which is required for the public health and safety or the common defense 4
and security. As used in this section, backfitting of a production or util'ization facility means the addition, elimi-nation or modification of structures, systems or components of the facility after the construction permit has been issued."
- 3. 10 CFR S100.10 states that "the site location and the engineered features included as safeguards against the hazardous consequences of an accident, should one occur, should insure a low risk of public exposure."
- 4. The introduction to 10 CFR Part 50, Appendix A, states:
There will be some water-cooled nuclear power plants for which the General Design Criteria are not sufficient and for which additional criteria must be identified and satisfied in the interest of public safety. In particular, it is expected l that additional or different criteria will be needed to take into account unusual sites and environmental conditions, and for water-cooled
- nuclear power units of advanced design.
The Limerick PRA is one of several tools that can be used by the Staff to determine whether Limerick can operate without undue risk to the public health and safety, as required by the l
Commission's regulations.
9.
Proposed Policy on Severe Accidents
- 4
. In opposing much of the Staff's use of the Limerick PRA, the applicant relies on the Commission's~ Proposed Commission Policy Statement.on Severe Accidents and Related Views 3x1 Nuclear Reactor Regulation (" Proposed Policy on Severe Accidents"),
issued April 13, 1983, 48 Fed. Reg. 16014. LEA believes this reliance to be misplaced.
It must of course be pointed out that the policy.
statement in question is a proposal-and nothing more.
Consequently, the Board is not bound by nor should it rely upon any directives contained therein. Given th'e history of the l Commission in issuing final rules, regulations and policy.
statements after issuing proposals for comment, a final policy statement on severe accidents may not appear before this licensing proceeding is completed.
! LEA also brings to the Board's attention a comment in
, the Proposed Policy on Severe Accidents that is very relevant l
l to its determination of whether and how the Limerick PRA can 1
i be used by the Staff in this licensing proceeding. In its l
proposal for use of PRA's in severe accident decisionmaking, the Commission states:
Some discussions of. provisional numerical guide-lines and PRA methodology will emerge in certain licensing hearings where PRAs have been required
[e.g., OL applications for plants in hiah popu-lation density sites and new CP applications.]
f Id. at 16016. (Emphasis added.)
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10.
By that statement the Commission acknowledges that 1) PRAs have been required for selected, high-risk sites; 2) those PRAs will be a subject in licensing proceedings for those facilities; 3) PRA methodology will be one of the specific topics brought up in those licensing hearings.
Given the Commission's acknowledgement,_it is hard to imagine that the Commission intended in its Safety Goal Policy Statement, issued prior, to prohibit what it subsequently acknowledges will be taking place. Further, it casts doubt on the validity of the Staff's assumption that it will have to forego consideration of mitigation alternatives in the licensing proceeding if the Proposed Policy'on Severe Accidents becomes final,as presently drafted j at some point in the future.
LEA believes that the directives in the Proposed Policy on Severe Accidents would prohibit any attempt at a broad attack on Commission regulations relating to accident mitigation.
The Staff has no intention of doing that in any case.
Further, LEA believes that in light of the Commission's acknow-ledgement of the current PRA investigations in licensing pro-ceedings for certain high-risk sites, Limerick might well be l
considered an exception to a broad prohibition against addressing the capability of current designs and procedures to control or mitigate severe accidents in case-related safety hearings.
LEA reiterates that the attempt to interpret the Proposed Policy on Severe Accidents is academic at this point, since it is merely a proposal. The Limerick site is one of the three i
most heavily populated sites in the country, and properly so, the Staff is not treating it as if it were an average site.
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- 11.
s Existing regulations and Commission policy provide a basis for the Staff to take into consideration the abnormal nature of the site and to protect the public health and safety accordingly.
S$aff Environmental Analysis LEA agrees with the position of the Board, as stated at the May 9-11 prehearing conference, that applicant's attempt to rely on the PANE decision (Metropolitan Edison Company v. People Acainst Nuclear Energy, No. 81-2399, 51 U.S.L.W. 4371) in order to preclude the consideration of risk of Class 9 accidents in the Staff's NEPA review, was at best, misleading. Nothing in that judicial decision or the Commission's recent policy statements precludes such consideration. In fact, the Commission's Proposed Policy on Severe Accidents refers to the Class 9 NEPA requirement established in its June 13, 1980 Policy Statement.
LEA supports the Staff's plant-specific approach to its NEPA review for Limerick, and believes that PRA methodology for establishing risk is appropriate.
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- 12. .
i Context of Litigation for PRA Contentions The NRC Staff's decision to review a variety of PRAs, including but not limited to WASH-1400, in order to determine whether the overall risk of Limerick is dispropor-tionately high (PRA use #3) , satisfies contention I-3.
Those contentions that are directed toward deficiencies in the analysis of accident sequences and sequence probabilities i affect the results of the Staff's PRA-related safety review i
(PRA use #1). In addition, those contentions affect its environmental review (PRA use #2) and its comparative risk
~
study (PRA use #3) -- le, they affect bott.om-line risk --
due to the fact that the PRA accident sequence / sequence probability analysis is largely incorporated into SARA and therefore into section 7.1 of the EROL. Consequently, contentions directed 4
toward PRA accident sequence / sequence probability deficiencies, if admitted, would be litigated in both a PRA and EROL context.
l Those contentions are the following, with comments where appropriate I-4. Pressure vessbl failure, which was not addressed in the PRA, is addressed in the applicant's section 7.1 EROL and supporting document, SARA. Until LEA has reviewed SARA, it is unable to state whether pressure vessel failure is adequately treated and incorporated into the PRA analysis that 4
was used in SARA. New contentions may be submitted on August 16.
13.
I-7. No comment necessary.
I-8. The Brookhaven review of the Limerick PR?., NUREG/CR-3028, section 4 (PP. 4-4, 4-5, 4-17; tables 4.1 and 4.4) provides the appropriate calculation for an accurate reflection of the frequency for the loss-of-offsite-power initiator as related to this contention. This Brookhaven calculation should be incorporated into the analysis of the PRA, which is carried over to SARA. If Brookhaven's calculation is adopted, this contention is satisfied.
I-10. No comment necessary.
I-11. In light of the Staff's decision to compare Limerick risk to risk of reactors other than that in WASH-1400, LEA wishes to reword its contention (last sentence) to say that "the effects of equipment aging on risk may reveal a larger effect on risk at Limerick than upon the generic BWR at the composite site of WASH-1400 and/or than upon other plants surrounded by averace-sized populations."
I-12. For purposes of this contention, it may fairly be assumed that intentional and accidental construction errors at all nuclear power plants affect risk approximately equally.
However, due to the pervasiveness of poor construction practices and poor regulation of this industry, intentional and accidental construction errors could, if investigated, be revealed to be a major contributor to risk, affecting the Staff's environmental review (PRA use #2).
I
14.
J I-14. No comment necessary.
I-15. No comment necessary.
I-23. Some so-called external initiators that were not treated in the PRA were treated in SARA. Until LEA has reviewed that document, it is unable to state whether those portions of the contention (a and b) are satisfied. Neither part (c) nor part (d) is addressed in SARA. Both are relevant to all three Staff uses of the PRA, and would, if admitted, be litigated in both a PRA and EROL context.
New PRA contention 1. This contention goes to the heart of the PRA accident sequence analysis for safety purposes, and due to PRA incorporation into SARA, seriously affects the calculation of overall risk (PRA uses ##2 and 3).
New PRA contention 2. No comment necessary.
New PRA contention 3. No comment necessary.
New PRA contention 4. LEA reiterates its clarification that the last sentence of this contention should read, "Incorpo-ration of the new model (ANSI /ANS-5.1-1979) results in ...."
It is the NRC's impression (not yet verified) that the 1978 ANS decay heat standard used to generate success criteria is the predecessor of the 1979 published standard, and is thus very similar. If this is the case, part (a) of the contention will be dropped. This matter should be clarified in a meeting with the NRC on June 8. The remainder of the contention is unaffected by the applicant's written response.
15.
Some of LEA's contentions are directed toward deficiencies in the consequence analysis of the PRA, which impacts on the Staff's environmental review as well as on-its comparative risk study. The consequence analysis used'in SARA differs in several respects from that in the PRA, and thus, assuming the PRA version will not be used by the Staff, certain of LEA's contentions have been partially or wholly satisfied.
In some cases, new concerns have arisen in SARA, which will be addressed in LEA's August 16 submission. Following are LEA's consequence-related contentions, with comments where appropriate:
I-16a. This contention is satisfied by changes made in SARA. LEA cannot drop this contention without knowing how the Staff intends to use the PRA consequence analysis.
I-16b. The applicant has used a different model in SARA than it used in the PRA. LEA may submit new contentions on the model in its August 16 submission. Again, LEA cannot-otherwise drop this contention without knowing how the Staff l intends to use the PRA consequence analysis.
I-26. The applicant used different sheltering assumptions in SARA than in the PRA. LEA may submit new contentions on this matter in its August 16 submission. LEA cannot otherwise drop this contention without knowing how the Staff intends to use the PRA consequence analysis.
16.
I-30. Malignant thyroid nodules are addressed in SARA as a contribution to latent cancers. LEA may submit new contentions on the model used, in its August 16 submission.
LEA cannot otherwise drop this contention without knowing how the Staff intends to use the consequence analysis of the PRA.
I-31. This contention is not adequately addressed in SARA. Further discussions between the Applicant, LEA and PEMA may permit LEA to drop this contention at a later date.
New contention 5. No comment necessary.
LEA attaches the resume of Robert K. Weatherwax, its risk analysis consultant. At the May 9-11 prehearing conference, several of the Board's questions reflected an apparent belief that details related to PRA contentions, details that LEA believes are most appropriately addressed during litigation, should have been supplied within the contentions themselves.
LFA requests that the Board take note of the fact- that LEA is making use of a consultant knowledgeable in the area of risk analysis. LEA would appreciate the opportunity to respond in writing via a submission from its consultant, to Board questions which counsel for LEA was unable to answer, if such a written submission would be helpful to the Board in making its admissibility determinations.
17.
Conclusion In summary, it is LEA's position that the irtent of the Commission to make an in-depth investigation of certain high-risk facilities, and to take the appropriate steps to insure no undue risk to the public health and safety from operation of nuclear power plants at these site $ was not reversed by its March 14, 1983 Safety Goal Policy Statement.
Nor is it at all clear that halting of such investigations would be the intent of the Commission's April 13, 1983 Proposed Policy on Severe Accidents, were that to become effective some time in the future. In any case, at this point in time the proposal is not binding.upon and should not be given any effect by this Board.
LEA supports the Staff's intended use of the Limerick PRA and subsequent risk-related documents, and believes that present Commission policy and existing regulations permit the Staff to take the approach to the Limerick licensing proceeding that it has chosen to take as stated in its April 13 and May 25, 1983 submissions to the Board.
Respectfully submitted,
- /b J ITH A. DORSEY CHARLES W. ELLIOTT Counsel for Limerick Ecology Action May 31, 1983
. Resume curront as of lato 1981 ROBERT K. WEATHERWAX, JR.
EXPERIENCE: Position: President Organization: Sierra Energy and Risk Assessment, Inc., Loomis, CA.
Dates: January 1981 to Present Duties: Founder and Chief Executive Officer of small enerov and
. risk analysis consultino firm. Current research and development contracts involve (1) developing regional energy demand forecast-ing models of tne commercial and residential sector throughout tha nation for use in conservation and solar energy policy ana-lysis, (2) assessing the physical and economic potential of available solar technology in California as compared to various conservation initiatives and alternative energy generation tech-niques, (3) evaluating the economic opportunities associated with geothermal energy conversion to electricity from the geo-thermal field developer's prospective, and (4) evaluating natural gas supply. options for California and surrounding regions.
Management responsibilities address all facets of consulting firm operations.
Position: Visiting Scientist (Part-time appointment)
Organization: Energy and Resources Group, University of Califor-nia, Berkeley Dates: July 1980 through June 1981 Duties: Perfonn research involving re's idential end-use, micro-economic energy demand forecasting models and their data bases.
Particular emchasis is placed on assessing the applicability of the Energy Information Administration's Residential Energy Consumption Survey to tne ORNL and California Energy Commission end-use forecasting models. Appointment requires teaching a seminar and working witn graduate students.
Position: Chief Energy Forecaster Orcanization: California Energy Commission, Sacramento, California Dates: July 1977 through December 1930 Outies: Responsible for forecasting electricity and natural gas requirements and peak loads of utility service areas for use in determining the need for power plants within California. Tech-nically directed others in the performance of the following tasks: (1) development and implementation of state-of-the-ar; microeconometric and-use models of energy consumption by fuel type and electric oeak load by economic sector by utility service area, (2) develurment, validation and implementation of building thermal equipment modeling codes to predict energy consumption and electric peak load in selected residential and comnercial structures;
. o EXPERIENCE: (3) identification of energy conservation options and evaluation (Continued) of their' cost effectiveness and potential energy impact, and (4) definition of potential solar and cogeneration application, and evaluation of their cost effectiveness and implementability.
Management responsibilities included definition, planning and implementation of intensive forecasting methodology development program; direction of a maximum of twenty-five post graduate level professionals, coordination and oversight of contract support activities and coordination and presentation of staff's forecast during energy forecast adoption hearings.
Position: Staff Scientist Organization: Science Applications, Inc., Palo Alto, California Dates: January 1977 - June 1977 Duties: Performed energy and risk analyses of various systems.
In particular, (1) reviewed the manner in which fusion systems were factored into long-term energy supply strategies and models under EPRI sponsorship, (2) managed risk analysis of the Hanford Reservation PUREX plant under ARHC0 sponsorship and (3) managed the initiation of the risk analysis of a Swedish PWR under Swedish Government sponsorship. Management responsibilities included acquisition of new businesses, program planning and implementation, contractor direction, and technical staff direction.
Position: Member of the Professional Staff Organization: School of Engineering, Princeton University,
--Princeton, New Jersey Dates: May 1974 - January 1977 Duties: Research consisted of: (1) investigating environmental
- spects of the mixed oxide nuclear fuel cycle, especially fuel reprocessing an? waste disposal, to identify and define important policy and technical issues; (2) identifying and evaluating energy canservation and peak load pricing options within the Consolidated Edison francnise district in order to reduce energy costs and oil consumption; and (3) parametrically modeling per-formance and cost properties of TOKAMAK fusion reactor concepts and associated power conversion technologies of CIRCA 2000.
Management respcosibilities included direction of a fusion system research program including supervision of five post-graduate level researchers and coordination with senior faculty participants, direction of contractor activity, and coordination with the sponsor.
Position: System Safety Supervisor Organization: McDonnell Douglas Aeronautics Company, Huntington Beacn, California Dates: January 1969 - April 1974 Duties: Responsible for ensuring that the Site Defense, ABM System as conceived and designed. conformed to acceptable levels of nuclear, personnel, and equipment safety and reliability.
EXPERIENCE: Supervised six engineering professionals. Performed and (continued) supervised the performance of the following tasks: (1) fault tree modeling of the system nuclear risk probability. (2)_devel-opment of simulation and analytical computer programs for use in computation or nuclear risk and reliability predictions,
~(3) investigation of possiole methods to assess software re-liability, (4) management of subcontractor safety engineering activities, and (5) coordination of custo.mer and associate contractor relations. Previous technical experience included performance of system effectiveness studies for the NASA Space Station and associated nuclear power systems, NERVA nuclear stage, Shuttle, Shuttle Payload Applications Program, Manned Orbiting Laboratory, and certain manuverable reentry vehicles.
CONSULTING McDonnell Douglas Astronautics Company, Huntington Beach, EXPERIENCE: California, concerning the safety and reliability of plutonium power systems, 1974-1976.
Battelle Memorial Institute, Richland, Washington, concerning risk assessment of reactor fuel reprocessing and waste oisposal
, concepts, 19/5-19/S.
Econ, Inc., Princeton, New Jersey, concerning the economic bene-fits to agricultural interests from the meteorlogical satellites, 1976.
Teledyne Energy Systems, Timonium, Maryland, concerning safety and availability of plutonium power systems, 1976-1977.
Science Apolicaticns, Inc., Palo Alto, California, concerning safety analyses of Swedish nuclear poaer ol. int and Hanforc Fuel Reorocessing Plant, 1977.
A. D. Little, Inc., Cambrioge, Massachusetts, ccncerning review of safety analysis of long-term disposal of .iaste under EPA aegis, 1977-1973.
1 Rockwell Hanford Operations, Richland, Washington, concerning review of PSAR on PUREX plant, 1978.
EDUCATION: B.S. ENGINEERING SCIENCE - California Institute of Technology -
June, 1966.
Major in fluid mechanics, minor in economics
- Armco Steel Corporation merit scholarship l M.S. AERONAUTICS AND ASTRONAUTICS - University of Washington -
Department of Aeronautics and Astronautics - June, 196C Major in fluid mechanics and applied mathematics l
l l
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EDUCATION 34 UNITS MATHEMATICS AND ENGINEERING - University of California (continued) and Princeton University - September,.1970 to January, 1976 Course work concerned stochastic processes, real analysis, fission and fusion reactor theory, and heat transfer FAULT TREE MATHEMATICAL APPROACH TO SYSTEM MODELING -
University of Washington Short Course - August, 190/
FORTRAN PROGRAF. MING - McDonnell Douglas course - February, 1970 BASIC PROGRAMMING - McDonnell Douglas course - September,1971 COMPASS PACHINE LANGUAGE PROGRAMMING - McDonnell Douglas course -
June, 1972.
SELECTED "Use of Physical Information in Commercial Sector End-Use Energy PUBLICATIONS Demand Modeling", EPRI End-Use Modeling and Conservation Analysis AND Workshop, Atlanta, Georgia, November, 1980.
PRESENTATIONS:
"An End-Use Approach and Attendant Data Base for Energy Fore-casting in'the Commercial Sector: Application to California,"
in Problems of Electric Utility Load Forecastina: Proceedinos of the 1979 EPRI Load Forecastina Symoosium. EPRI, EA-1729-SR, March, 1981.
"A Forecast of Utility Energy Demand and Peak Load for California:
1978-2000," An End-Use Model for Energy Forecasting of California's
, Commercial Sector, and " Computerized Building Energy Analyses for Denand Fore:asting in California," Chancing Enercy Use Futures,
, Ed R.A. Fazzolaire and C. S. Smith, Vol. I., 1979 Pergamon Press.
Several presentations to California Legislative Committees and Sub-Committees concerning future California Energy Demand, 1978 to 1980.
" Forecasting Natural Gas Demand in California," Proceedincs of Symposium c:. Energv and System Sciences, LSL, October, 1975.
" Comments on Assessment of Accidental Pathways. Subtask D Report ih' (Draft), A. D. Little, Inc., dated February, 1978," for Office of Radiation Programs, EPA, July 12, 1978.
Natural Gas Demand 1978-1995: Forecast and Technical Documentation Appendix A, featurai Gas Supply and Demana for California, California Energy Commission, May 26, 1978.
"A Forecast of Energy Censumption and Peak load in the Consolidated Edison Residential Sector," Proceedincs of the International Conference on Energy Use Manacement, Volume II, October 1977 Pergamon Press.
Survey of Energy Growth and Generation Projections as they pertain to EPRI Fusion Pcwer Studies, SAI, Inc., SAi-166-77-PA, August, 1977 (Draft).
',.* ~
EXPERIEllCE: (3) identification of energy conservation options and evaluation (Continued) of their cost effectiveness and potential energy impact, and (4) definition of potential solar and cogeneration application, and evaluation of their cost effectiveness and implementability.
Management responsibilities included definition,' planning and implementation of intensive forecasting methodology development program; direction of a maximum of twenty-five post graduate level professionals, coordination and oversight of contract support activities and coordination and presentation of staff's forecast during energy forecast adoption hearings.
Position: Staff Scientist Organization: Science Applications, Inc., Palo Alto, California Dates: January 1977 - June 1977 buties: Performed energy and risk analyses of various systems.
- In particular, (1) reviewed the manner in which fusion systems l were factored into long-term energy supply strategies and models 1
under EPRI sponsorship, (2) managed risk analysis of the Hanford~
Reservation PUREX plant under ARHC0 sponsorship and (3) managed the initiation of the risk analysis of a Swedish PWR under Swedish Government sponsorship. Management responsibilities included acquisition of new businesses, program planning and implementation, contractor direction, and technical staff direction.
Position: Member of the Professional Staff 4
Organization: School of Engineering, Princeton University,
--Princeton, New Jersey Dates: May 1974 - January 1977 Duties: Research consisted of: (1) investigating environmental aspects of the mixed oxide nuclear fuel cycle, especially fuel reprocessing an.f waste disposal,.to identify and define important policy and technical issues; (2)' identifying and evaluatinq energy conservation and peak load pricing options within the Consolidated Edison francnise district in order to reduce energy costs and oil consumption; and (3) parametrically modeling per-formance and cost properties of TOKAMAK fusion reactor concepts and associated power conversion technologies of CIRCA 2000.
, Management ruspensibilities included direction of a fusion
- system research program including supervision of five post-I graduate level researchers and coordination with senior faculty participants, direction of contractor activity, and coordination with the sponsor.
Position: System Safety Supervisor Orcanization: McDonnell Douglas Aeronautics Company, Huntington Seacn, California
' Dates: January 1969 - April 1974 Outies: Responsible for ensuring that the Site Defense, ABM System as conceived and designed. conformed to acceptable levels of nuclear, personnel, and equipment safety and reliability.
I t
a w EXPERIENCE: Supervised six engineering professionals. Performed and (continued) supervised the performance of the following tasks: (1) fault tree modeling of the system nuclear risk orobability. (2) devel-opment or simulation and ar.alytical computer programs for use in computation or nuclear risk and reliability predictions, (3) investigation of possiole methods to assess software re-liability, (4) management of subcontractor safety engineering activities, and (5) coordination of custo.mer and associate contractor relations.' Previous technical experience included performance of system effectiveness studies for the NASA Space Station and associated nuclear power systems, NERVA nuclear stage, Shuttle, Shuttle Payload Applications Program, Manned Orbiting Laboratory, and certain manuverable reentry vehicles.
CONSULTING McDonnell Douglas Astronautics Company, Huntington Beach, EXPERIENCE: California, concerning the safety and reliacility of plutonium power syste.ms, 1974-1976.
Battelle Memorial Institute, Richlanc, Washington,_concerning risk assessment of reactor fuel reprocessing and waste oisposal
, concepts, 19i5-19/3.
Econ, Inc., Princeton, New Jersey, concerning the economic bene-fits to agricultural interests from the meteorlogical satellites, 1976.
Teledyne Energy Systems, Timonium, Maryland, concerning safety and availability of plutonium power systems, 1976-1977.
Science Apolicaticns, Inc., Palo Alto, Califcrnia, concerning safety analyses of Swedish nuclear po.2er 31 ant and Hanford Fuel Reorocessing Plant, 1977.
A. D. Little, Inc., Cambricge, Massacnusetts, concerning review of safety analysis of long-term disposal of .;aste under EPA aegis, 1977-1978.
Rockwell Hanford Operations, Richland, '4ashington, concerning review of PSAR on PUREX plant, 1978.
EDUCATION: B.S. ENGINEERING SCIENCE - California Institute of Technology -
June, 1966.
Major in fluid mechanics, minor in economics Armco Steel Corporation merit scholarship M.S. AERONAUTICS AND ASTRONAUTICS - University of Washington -
Department of Aeronautics and Astronautics - June, 1960 Major in fluid mechanics and applied mathematics
.' l SELECTED Energy Conservation / Load Management Analysis for the Residential, PUBLICATIONS Small Commercial and Industrial Sectors of the Consolidated AND Edison Electric Franchise District, Center.for Environmental l PRESENTATIONS: Studies, Princeton University, March, 1977.
236 g
'The Penalty for Recycled Uranium," Under publication 92 review, Annals of Nuclear Energy.
Nuclear Safety Analysis Methodology for RTG Equipped Satellite Launches,.MDC G6751, McDonnell Douglas Astronautics Company, Huntington Beach, California, May, 1976.
Launch Vehicle Reliability Ccnsiderations for Nuclear Safety hssessment, MDC G5983, McDonnell Douglas Astronautics Company, Huntington Beach, California, April, 1976. ,
Nuclear Fusion Systems Analysis Research, AMS Report No. 1250, Princeton University, October, 1975.
h "Probabilistic Fission Power Plant Risk Analysis: Its Virtues and Limitations," presented as invited paper at the American Physical Society General Meeting, April,1975, and published
. in Bulletin of the Atomic Scientists, September, 1975.
g Probabilistic Risk Analysis of Nuclea~r Systems, Princeton University Seminar, May,-1975.
Site Defense Safety Analysis and Hazard Evaluation Report, MDC G4885, McDonnell Douglas Astronautics Company, Huntington Beach, California, October, 1973.
p " Applications of Multiphase Fault Tree Analysis," presented as part of industry course entitled RISK ANALYSIS, given at Flow Research, Inc., Kent, Washington, February, 1973.
"A Comparison of Fault Tree Quantification Techniques," presented i k to System Safety Society Symposium, University of Southern California, April, 1972.
Preliminary Safety Analysis Report, Volumes 1-6 (NASA Space Station 50 kW isotope and reactor power supplies), MDC G0744, McDonnell Couglas Astronautics.Co.;;any ,Huntington Beach, California, January, 1971.
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t PERSONAL DATA: Date of BirtS: June 1, 1944 Maritai Status: Married with two children Address: 8115 Morningside Drive' Loomis, California 95650 (916) 791-7630 - home telephone (916) 792-1212 - work telephone Clearance: Secret AFFILIATIONS: American Nuclear Society American Association for the Advancement of Science American Council for an Energy Efficient Economy CALTECH Alumni Association
REFERENCES:
J. W. Walker, Commissioner, California Energy Commission, Sacramento, California F. Von Hippel and R. H. Williams, Research Scientists, Center for Energy and Environmental Studies, Princeton University, Princeton, New Jersey Jerry Gray, Editor, American Institute of Astronautics and Aeronautics, f;ew York, New York E
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U,f-CERTIFICATE OF SERVICE ,
g2 N0'M
. . q I hereby certify that copies of the foregoing' Limerick Ecology Action Response to Licensing Board's Order of May 16, 1983, have been served upon the following by deposit in the United States mail, first-class postage prepaid, on this 31st day of May, 1983 (Express mail delivery to those by whose name appears an asterisk) :
Lawrence Brenner, Chairman Atomic Safety and Licensing Board Administrative Judge Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Dr. Richard F. Cole Appeal Panel Administrative Judge U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 Docketing and Service Section Office of the Secretary Dr. Peter A. Morris U.S. Nuclear Regulatory Commission Administrative Judge Washington, DC 20555 U.S. Nuclear Regulatory Commission Thomas Y. Au, Esq.
Washington, DC 20555 Commonwealth of PA Department of Environmental Resources o Ann P. Hodgdon, Esq. 505 Executive House Office of the Executive P.O. Box 2357 Legal Director Harrisburg, PA 17120 U.S. Nuclear Regulatory Commission David Wersan, Esq.
Washington, DC 20555 Assistant Consumer Advocate Office of the Consumer Advocate Troy B. Conner, Jr., Esq. 1425 Strawberry Square Conner and Wetterhahn Harrisburg, PA 17120 1747 Pennsylvania Ave., NW Washington, DC 20006 Director PA Emergency Management Agency Phila. Electric Company Basement, Transportation and ATTN: Edward G. Bauer, Jr. Safety Buildinc VP and General Counsel Harrisburg, PA 17120 2301 Market St.
Phila., PA 19101
l l
1 Thomas Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Fulton Bank Building, 5th fl.
Third and Locust Sts.
Harrisburg, PA 17120 Martha W. Bush, Esq.
Deputy City Solicitor City of Philadelphia Municipal Services Building 15th and JFK Blvd.
Phila., PA 19107 Robert Anthony 103 Vernon Lane, Box 186 Moylan, RA 19065 Donald Bronstein, Esq.
1425 Walnut St., 3rd fl.
Phila., PA 19102 Marvin Lewis 6504 Bradford Terrace Phila., PA 19149 Jacqueline I. Ruttenberg Keystone Alliance 3700 Chestnut St.
Phila., PA 19104 Frank Romano 61 Forest Ave.
Ambler, PA 19002 Joseph H. White III 8 North Warner Ave.
Bryn Mawr, PA 19010 Robert Sugerman, Esq.
Sugarman and Denworth Suite 510, North American Building 121 S. Broad St.
Phila., PA 10107 t',
H s( k D' dbf JUQTTH A. DORSEY /