ML20032A100

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Witness List & Documents Per ASLB 811015 Memorandum & Order. Evidentiary Hearing Unwarranted on Licensee Request to Conduct Sleeving Demonstration Program.Prof Qualifications Encl
ML20032A100
Person / Time
Site: Point Beach  
Issue date: 10/26/1981
From: Bachmann R, Treby S
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
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ML20032A101 List:
References
NUDOCS 8110280293
Download: ML20032A100 (16)


Text

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g' 't UNITED STATES OF At1 ERICA

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g %,

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Docket No. 50-266 1

(Repair to Steam Generator Tubes) 50-301 (PointBeachNuclearPlant, Units 1 & 2)

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NRC STAFF WITNESS LIST AND DOCUMENTS In its Slemorandum and Order Setting Agenda and Rules for October 29-30 Hearing" dated October 15, 1981, the Licensing Board directed the parties to exchange a witness list and documents that will be relied on at the October 29-30 hearing at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the hearing. The information to be included as part of the witness list was indicated at

p. 2 of the Board's Order and during the October 20, 1981 on-the-record telephone conference call. Tr. at 184-191. While the Staff does not believe that an evidentiary hearing will be required for the reasons dis-cussed below, the Staff is providing the information to the extent the issues have been identified.

The scope of the October 29-30 hearing has been discussed in Board Orders and during the on-the-record telephone conference calls among the Board and parties. The scope is the four Decade contentions admitted by the Board to the extent they are pertinent to the Licensee's proposed

.leeving demonstration program and any issues raised... the form of show cause motion by Decade based upon the Licensee's responses to the two sets of questions posed to the Licensee by the Board. The date for filing the show cause motion was set for 8:00 a.m. Saturday, October 24, 1981. T r.

at 175. Decade's filings of October 23, 1981 did not show that there are j

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any issues other than those specifically raised in the four filed con-tentions which Decade desires te be heard at the hearing scheduled for October 29-30, 1981. As to the four admitted contentions, Licensee has noved for summary disposition on Contentions 3,4 and 5. In its answer filed this day, the Staff supports the Licensee's motion. As noted therein, once a motion for summary disposition has been made and supported by affidavit, a party opposing the motion rey not rely on mere allegations, but instead must demonstrate by affidavit or otherwise that a genuine issue exists as to a material fact. 10 C.F.R. f 2.749(b); Virginia Electric and Power Company (North Anna Nuclear Power Station, Units 1 and 2), ALAB-584, 11 NRC 451, 453 (1980). This decision also establishes precedent for the termination of a license amendment proceeding in its entirety on summary disposition. " Decade's Answer to Licensee's Motion for Summary Disposition" dated October 24, 1981 does not demonstrate by affidavit or otherwise that a genuine issue exists as to a material fact. In sum, the Staff dces not believe that an evidentiary hearing is warranted on Licensee's request to conduct the sleeving demonstration pro-gram. However, in the event an evidentiary hearing is held, the Staff will provide the following panel: Timothy G. Colburn Robert A. Clark Emmett L. Murphy. Bernard Turovlin Dr. Tin Mo Dr. John V. Nehemias Copies of the professional qur$ ifications of the witnesses are attached.

Contention 3 This contention deals with the pctential of the Licensee's heat treatment process causing a weakening of the tube material, leading to a circuaferential rupture of the tube. The Staff will testify as to the extent of its review and the basis for its conclusion that while the Licensee's process could cause some weakening of the tube material, there is reasonable assurance against a structural failure of the joint during the interim period of the sleeving demonstration program. The substance of the facts and opinions to be presented by the panel are contained in Sections 2.E. 2.3, 2.5, 2.6, 3.1, 3.3 and 3.4 of the Staff's Safety Evaluation Report. , Contention 4 This contention deals with the possibility of an unexpectedly corro-sive environnent arising in the annulus between the tube and sleeve due to secondary water impurities. The Staff will testify as to the extent of its review and the basis for its conclusion that the corrosive environment between the tube and sleeve will be no greater than the normal causLic environment in the secondary and that the sleeve material is more corrosion-resistant than the original tube. The substance of the facts and opinions to be presented by the panel are contained in sections 2.6 and 3.3 of the Staff's Safety Evaluation Report. Contention 5 This contention deals with difficulity in interpretation of ed.dy current test results due to the presence of the sleeve and the probability of incipient failures going undetected, leading to a tube rupture during a

LOCA. Tne Staff will testify as to the extent of its review and the basis for its conclusion that, while the sleeve joint aay make regular eddy current inspections more difficult, there are other, special methods of inspection and any potential tube failure would oe identified by leak rates and the reactor shut down before a rupture could occur. The substance of the facts and opinions to be presented isy the panel are contained in Sections 2.4, 2.7 and 3.5 of the Staff's Safety Eval-uation Report. Contention 7 This contention deals with the large number of workers required for the full scale sleeving program and the possibility of deterioration in quality of the work because of the necessity of using untrained workers or " jumpers". In view of the small number of tubes tc be sleeved for the den.onstration program, the Staff does not believe this contention is rele-vant to the subject matter of the October 29-30 hearing. It should be noted that the Staff has addressed the Licensee's program for reduction of occupational exposures to meet the ALARA standards in Section 4.0 of the Staff's Safety Evaluation Report and Section 4.1.1 of the Staff's Environ-mental Impact Appraisal. In the event the Staff determines to conduct cross-examination of any of the parties, at this time the only documents it has identified it would use in preparation of cross-examination are the documents the Licensee has filed in support of the demonstration program and the Staff's Safety

F. Evaluation Rep 07t and Environmental Impact Appraisal. Respectfully submitted, Stuart A. Treby Assistart Chief Heari g Counsel Richard G. Bachmann Counsel for NRC Staff Dated at Bethesda, Maryland this 26th day of October,1981. 'I k

ROBERT A. CLARK DIVISION OF LICENSING OFFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COMMISSION J PROFESSIONAL QUALIFICATIONS My name is Robert A. Clark. I am Chief of the Operating Reactors Branch #3, Division of Licensing, United States Nuclear Regulatory Commi-ssion (NRC). In this position I am responsible for the overall safety and eavironmental project management for assigned licensed operating power reactors. This includes review of technical and procedural aspects of proposed amendments to operating licenses. I hold a Bachelor of Science degree in chemical engineering from the University of New Mexico and have also completed three semesters of gradu-ate study in chemical engineering at the same university. I am a registered professional engineer in the State of New Mexico. I have had a total of 30 years of professional experience all of which has been in the nuclear field. For 17 years I was employed by the Los Alamos Scientific Laboratory (LASL) as a member of the technical staff. During my employment at LASL, I served in a variety of staff and supervisory engineering positions and in the Laboratory's experimental power reactor division. In this capacity I worked in the design, development and operation of two i homogeneous reactors (LAPRE I and II); a sodium-cooled, plutonium-fueled fast reactor (LAMPRE); and the Fast Reactor Core Test Facility.

2-In 19671 accepted a position as a nuclear engineer with the regulatory staff of the Atoiaic E'argy Commi,sion (AEC) and participated in the safety reviews of both power -d expertinental reactors. (Fort St. Vrain, SEFOR, UHTREX, Maine Yankee, Calvert Cliffs, Palisades, and FFTF). In ny assign-ments with the AEC and NRC. I have served as Chief of BWR Branch #3, Gas Cooled Reactors Branch, Special Reactors Branch Operating Reactor Safe-guards Branch and Reactor Safeguards Licensing Branch prior to my appointment to qy present position. These assignments covered a wide range of reactor types and the technical review and evaluation associated with project management related to applications for limited work authorizations, construction permits, operating licenses and amendment to such licenses as well as physical security plans for operating nuclear power plants. I am a member of the American Nuclear Society (ANS) and have worked with the ANS subcommittee developing criteria f or liquid metal cooled fast reactors (ANS-54) and for gas coaled reactors (ANS-53). a <w---


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TItt0 THY G. COLBURN DIVISION OF LICENSING OFFICE OF NUCLFAR REACTOR REGULATION PROFESSIONAL QUALIFICATIONS My name is Timothy G. Colburn. I am a project managcr in Operating Reactors Branch No. 3, Division of Licensing, United States Nuclear Regulatory Conaission. In this position I am respons'ble for the techni-cal reviews, analyses and evaluations of applications for amendiaents to operating reactor licenses. I have held this position for ora year. I hold a Bachelor of Science degree in Mechanical Engineering from the University of Notre Dame. I have five years of professional experience in the Navy's Nuclear Power Program. In that capacity I completed a one-year intensive program in nuclear pcwer classroom and prototype training. I also served for four years as a qualified Eng'.ieering Officer of the Watch. I have been division officer of all shipboard engineering divisions supervising all phases of shipboard engineering operations and maintenance and have participated in an intensive non-refueling shipyard overhaul of a nuclear submarine. I have also had two years expe ience with Potomac Electric Power Company, a non-nuclear utility, working in a staff function as assistant to the Manager of Production Operations.

EMMETT L. MURPHY DIVISION OF ENGINEERING OFFICE OF NUCLEAR REACTOR REGULATION PROFESSIONAL QUALIFICATIONS My name is Eamett L. Murphy. I am a Materials Engineer in *5e Inservice Inspection Section, Materials Engineering Branch, Division of Engineering, Office of Nucle;ar Reactor Regulation, of the United Ststes Nuclear Regulatory Commission. In ny present position, I am responsible for performing technical reviews and evaluations of PWR steam generator tube surveillance and repair programs for NTOL and operating plants. I hold a Bachelor of Science Degre 'n Aerospace Engineering and a Master of Science Degree in Civil Engineering, both fran the University of Maryland. I h' nad a total of ten years of professional experience of which eight years has been in the nuclear field. I was employed for almost six years as a structural engineer at the Bettis Atomic Power Laboratory by Westinghouse Ccrporation. During qy employment at Bettis, I was involved in the structural design and analysis of core and core structurals of naval reactors. i Since joining the iiRC in July 1979, I have been involved exclusively in the steam generator review area. I have been involved in the safety reviews of most nf the steam generators which have experienced significant tubr degradation during the past two years, including Point Beach Units 1 and 2 and San Onch e Unit 1. i A


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BERNARD TUR0VLIN PROFESSIONAL ENGINEER - CALIFORtRK !9180 MAY, 1949 I am a Corrosion Engineer in the Chem)~ cal Enc'aeering Branch of the Office of Nuclear Reactor Regulation, Nuclear Regulatory Commission. I am responsible for safety review and evaluation of the corrosion of materials used in the construction and operation of nuclear power plants. I have been associated with nuclear energy development and construction as an en3 neer or metallurgist since 1942. I have been employed in these capacities by numerous organizations beginning with the Metallurgical Laboratory of the University of Chicago transferring to Los Alamos Laboratory, Brookhaven National Laboratory, Combustion Engineering Inc., General A+omic, General Dynamics /Convair, U. S. Army Nuclear Power Group. I have spent a minimum of 4 years at each location. v. I have been responsible for the development of basic fabrication techniques, non-destructive examination, and failure analysis.'I have done engineering design and component testing for various components used in the nuclear energy field. I.have more than 15 patents for various components and techniques used in the above* field. I have published more than a dozen papers related to this field. L.

Tin Mo PROFESSIONAL QUAllFICATIONS Radiological Impact Section Radiological Assessment Branch Division of Systems Integration I am an Environmental Scientist in the Radiological Assessment Branch, Division - of Systems integration, Office of Nuclear Reactor Regulation. My formal education consists of study in Chemistry at Rangoon Univertity, Rangoon, Burma where I received a B.Sc. (Honours) degree in 1960 and at the University of Arkansas where I received an M.S. in Neclear and Radiochemistry in 1963. I received a Ph.D in Nuclear and Radiochemistry from Texas A&M University in 1P71. Before joining the U.S NRC, I worked as an Environmental Health Physicist at the Radioactive Waste Standards Branch, Criteria and Standards Division, Office of Radiation Programs, U.S. Environmental Protection Agency, from October 1979 to April 1981. In this position I provided the Radioactive Waste Standards Branch and the Office of Radiation Programs with primary expertise in the area of environ-mental health physics with particular emphasis on the technical evaluation of the transport of radionuclides through the environment and application to the develop-ment of radiation protection standards and guides. I developed specific information and knowledge bases for modeling the movement of radionuclides through the environ-ment by alternative pathways, including transport through the air, water, soil, and food chains. From May 1978 to Octobte 1979 I was associated with the Lovelace Biomedical and Environmental Research Institute, LBERI (a U.S. DOE contractor laboratory) as an Associate Scientist / Radiochemist. Ir. this capacity I collaborated in inhalation toxicology research on the metabolism and dosimetry of aerosols of uranium and plutonium oxide nuclear fuel material. Tnis work resulted in two research reports covering the fields of radiochemistry, radiobioassay, aerosol physics and radio-biology. Prior to this assignment I served for three years (February 1975 to May 1978) as the Principal Radiochemistry Operations at LBERI and also collaborated in all the toxicology research with radionuclides at LBERI. From October 1972 to February 1975 I worked as a Staff Scientist / Radiochemist for the Radioecology Divis ion, Puerto Rico Nuclear Center, PRNC (a U.S. Atomic Energy Commission research fa ility). In this position I conducted marine radiobiology and radioecology resea.ch on plutonium using nuclear debrii associated with the Bikini-Enewetak Nuclear Testing areas. At PRNC I was also involved in environmental monitoring for radioactivity and't'oxic heav/ metals in the coastal atmosphere of Puerto Rico as part of the baselini studies for selection of sites for a nuclear power plant. After receiving the Ph.D. degree from Texas A&M University in December 1971 I held Postdoctoral Research Fellowships in the Departments of Chemistry and Chemical Oceanography at Texas A&M Unisersity and collaborated in researches on Radf ation Chemistry, water pollution and marine geochemistry of urgnium from January 1972 to June 1972. v w - + -

2-I have written and published about 24 technical cesearch papers and reports in professional journals and other pubitcotions in the general areas of cuclear and radiochemistry (nuclear fission), environmental health physics (radioactive fallout studies), nuclear geochemistry, marine pollution and radioecology, radio-bioassay, inhalation toxically and radiobiology and environmental chemistry of radionuclides. I have beer, a member of the American Chemical Society (Nuclear Chemistry and Technology Division) since 1963. \\ e

T'in Mo. Ph.D Page i i (. List of Research Publications, Papers and Presentations: - 1. " Chemistry of Uranium in Aqueous Environments". (Draft Prepared -September 1980. To be published as an EPA Technical Note).

2. " Chemical and Crystalline Properties of High Temperature Treated Aerosols of U, (U-Pu), (U-Th) Oxides" (To be submitted to the Journal of Aerosol Science. (1980-1981).

3.'. "Effect of the Chemical Form of Uranium Oxide on the Radiation Dose Distribution in the Rat of Plutonium from Inhaled Mixed Uranium-Plutonium Oxides". Experimental Research Protocol, May 1979. Inhalation Toxicology' Research Ins titute (ITRI), Alb,uquerque, New Mexico.

4. "Effect of Elemental Composition (U/Pu Ratio) on the Radiation Dose Distribution in the Rat of Inhaled Mixed Actinide Oxide (UO -Pu0 )'

3 2 Particles". Experimental Research Protocol, March 1979. ITRI, Albuquerque, New Mexico.

5. " Generation and Characterization of Actinide oxide Aerosols of Specific Physicochemical Forms", pp.18-23, ITRI Annual Report 1978-1979 LF-69, 1979
6. "In Vitro Dissolution Behavior of Pure and Mixed U and Pu 0xide Aerosols pp.24-29, ITRI Annual Report 1973-1979, LF-69, 1979

" Mixed Actinide Oxide Aerosols-Metabolism and Dosimetry Study". Positio'n ' aper - Draft, November 1978. ITRI, Albuquerque, New Mexico. 8. Development of Radioanalytical Procedures for Mixed Oxides of Plutoniu: Americium and U. anium in Biological Specimens". ITRI Annual Report (1975-1976), LF-56, pp.105-107 1977 210

9. " Improved Analytical Procedures for Po in Biological Specimens".

ITRI Annual Report (1975-1976), LF-56, pp.108-110.1977..

10. " A Simple Liquid Scintillation Counting Procedure for ' Americium in Biological Samples". ITRI Annual Report (1974-1976), LF-52 1976.
11. " Comparison of-Leaching versus Total Dissolugjgn Procedures for Liquid Scintillation Counting of Fecal Samples for Pu". ITRI Annual Report 1

(1974-1976), LF-52, 1976.

12. "Labora tory Experiments on the Transfer of Plutonium from Marine Sediments to Seawater and to. Marine Organisms". In: Proceedings of the 4th National Synposium on Radioecology, Corvallis, Oregon, May 11-13, CONF-750503 5 (1975).
13. " Recoil "ritium Reactions with Tert-butyl Chloride". J. Inorg. Nucl.

l-Chem. 37:1322 (1975). i 14. " Nondestructive Multielement Ins,trumental Neutron Activation Analysis of Toxic Metals in the Atmosphere of Southern Puerto Rico". Jn Toxic ' Metals in the Atmosphere, PRNC-186: 1-20 (1975).

15. " A Revaluation of the Marine Geochemistry of Uranium". IAEA-SM-158/51:

757-769 (1973). l 16. " Uranium Concentrations in Marine Sediments". Geochim. Cosmochim. Acta. 37: 35-51 (1973). a . r w e, m e-w w e - w - e r-v re evm -r w- -etwo ,-rw cr-3-,,, y -vw---y v -,e r wve., m wy ---,,,+.r--,w+ --y-9#ww.w,--ww--o,-* ge ,e y-ytpe r-y-r- e--3-t-. w-e n-w

,J$E f:L.l.h.D page 2 hist of Ecsearch Publications, Pauers and Presentions:

17. " Thermal Neutron Activation Analysis of Airborne Particulate Matter in the South Coastal Area of Puerto Rico". Aquirre Power Project.

Environmental Studies 1972 Annual Report PRNC-162: 421-427 (1972). ' 18. " Uranium Concentrations in Marine Sediments". Ph.D. Dissertation, Texe.s A&M University, College Station, Texas. December 1971. 167 pages.

19. " Uranium: Purther Investigation of Uranium Content of Caribbean. Cores p6304-8 and p6304-9". Earth and Pl.an. Sci. Lett 10s.175-178 (1970).
20. " Significance of Symmetric Fission in Fallout Studies from'May 1966 Chinese Nuclear Explosion". Health Phys. 14: 269-270 (1968).

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21. " Symmetric Fission of, Th by 14 MeV Neutrons". J. Inorg. Nucl. Chem.

30: 245-247 (1968). -22. " Fission of 233 U by Thermal Neutrons". J. Inorg. Nucl. Chem. 29 257 (1967).. 2 3. " Yields of' Zirconium Isotopes from Spontaneous and 14 7 MeV Neutron Induced Fission of Uranium-238". J. Inorg. Nucl. Chem. 27: 503-508 (1965).

24. " Geochemical Studies on the Stratospheric' Pallout: U.S.A.E.C. Report TID-7632: 223-241 (1961).

Presentations at Scientific Meetinas:

1. " Assay of Uranium, Plutonium and Americium (Curium) in Biological Sample by Sequential Separation and ' Liquid Scintillation Counting". Presented at the American Chemical Society National Meeting and Symposium sponsore by the Nuclear Chemistry and Technology Division at Anaheim, California on March 12-17, 1978.
2. " A Fast, Simple and Economical Method of Preparing Counting Sources for Alpha Spectrometric Determination of Plutonium and Americium" at the 21st Bioassay, Environmental and Analytical Conference, San Francisco, California, October 8-9, (1975).
3. " Laboratory Experiments.on the Transfer Dynamics of Plutonium from Marine Sediments to Sea Water -and to Marine Organisms" at the 4th National Symposium on Radioecology, Corvallis, Oregon, May 11-13, 1975
4. " Uranium Concentrations in Marine Sediments" et the Annual American Ceophysical Union Meeting, Washington, D.C.,

A 'l 12-14, 1971. 3 o O e

i 4 John V. Nehemias PROFESSIONAL QUALIFICATIONS Radiological Assessment Branch Division of System Integration I am a Senior Health Physicist in the Radiological Assessnent Brar.ch, Division of Site Safety and Environmental Analysis, Office of Nutlear Reactor Regulation. My foraal education consists of study in Physics at Rensselaer Polytechnic Institute where I received a B.S. in 1948 and at Columbia University where I received an A.M. in 1949. I received a Ph.D. in Environnental Health (Radiological) from the University of Michigan in 1960. Before joining AEC/NRC, I served three years at Brookhaven National Laboratory as a health

  • physicist, six years at the University of Michigan as health physicist and assistant director of a radiation effects laboratory, and three years as Director of Radiological Health Surveys for the National Sanitation Foundation.

In the latter position, I designed, organized, and directed the environmental survey for the Enrico Fermi nuclear plant. I joined the AEC in September 1960, as a health physicist in the Offica of Health and Sarety. My principal duties there related to develop.ient of radiation protection standards. With the two exceptions noted below, I have continued with AEC (and NRC) since that time. My principal responsibility was in the development of Standards until September 1974; during cost of those years I served as a branch chief-through several nace changes and reorganization-oost recently as Chief, Occupational Health Standards Branch, March 1972 to Septemi.er 1974. Since September 1974, I have served as Senior health physicist in the Radiological Assessmeat Branch. My principal function is the review of. poser reacter applications, both at the construction permit and operating license stage, to determine the adequacy of prcposed occupational radiation protection prograns.and the related efforts proposed to assure that occupational radiation exposures will be maintained as. low as is reasonably achievable. From June 1963 to Septenber 1965, I took a leave of absence from AEC and served as principal nenber of the Occupational Safety and Health Division of the International Labor Office in Geneva, Switzerland. My work was principally in the development of international standards.

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3 2 In December 1971, I was transferred to the Criteria and Standards Division, EPA, serving as Chief, Criteria and Standards

  • ranch, until my return to AEC d

in Haren 1972. I nave published about 40 technical articles in professional journals and other publications in the general areas of low-level counting, environnental monitoring, radiation effects on biological systens, and control of occupational radiation exposures. I have been a C'ertified Health Physicist since 1960, and an a Charter member of the Health Physics Society and of the d' altimore-Washington Chapter. 'l 6 a i e a 9 ( m v-'&--}}