ML20034F223
| ML20034F223 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 02/22/1993 |
| From: | Greer L MASSACHUSETTS, COMMONWEALTH OF |
| To: | |
| References | |
| FRN-58FR5427 58FR5427, OLA, NUDOCS 9303020423 | |
| Download: ML20034F223 (2) | |
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UNITED STATES OF. AMERICA NUCLEAR REGULATORY' COMMISSION-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
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In the Matter of
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Vermont Yankee Nuclear
)
Dkt. No. 50-271-OLA Power, Corporation
)
)
(Vermont Yankee Nuclear.
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Power Station)
)
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MASSACHUSETTS ATTORNEY GENERAL'S CONMENTS IN OPPOSITION:TO-PROPOSED FINDING OF NO SIGNIFICANT HAZARDS CONSIDERATION-The Commonwealth of Massachusetts-by its Attorney General, Scott Harshbarger, joins in the comments submitted by'the~New England Coalition on Nuclear Pollution-("NECNP") in-opposing the proposed determination.of no significant hazards consideration-t for the license amendment requested by Vermont' Yankee Nuclear Power Corporation for the Vermont Yankee. Nuclear. Power Station.-
Notice of the proposed license amendment is found a ti F e d. : R e g'.
Vol. 58, No. 12, page 5435.
For the reasons set forth~in NECNP's Comments'in Opposition 1
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to Proposed Fin' ding of No Significant Hazards Consideration, l
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-attached hereto as an exhibit,- and, incorporated. herein by l'
reference, the: Massachusetts Attorney' General requests that the
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y proposed finding be rejected' and an order issue requiring '~a" t-
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h, hearing on tile proposed license amendment.
Respectfully submitted, SCOTT HARSHBARGER ATTORNEY GENERAL s
Leslie B. Greer Public Protection Bureau One Ashburton. Place, 19th' Floor Boston, MA 02108 (617) 727-2200 q
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, JCB 22 '93 03:29Pt1 UNITED STATES OF AMERICA DEFORE THE NUCLEAR REGULATORY COMMISSION
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In the Matter of
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Vermont Yankee Nuclear Docket No. 50-271-OLA Power Corporation
)
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(Vermont Yankee Nuclear
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Power Station)
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NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S COMMENTS IN OPPOSITION TO PROPOSED FINDING OF NO SIGNIFICANT HAZARDS CONSIDERATION Introduction the Nuclear Regulatory Commission On January 21, 1993, issued public notice of an operating li-("NRC" or " Commission")
cense amendment request by the Vermont Yankee Noclear Power Cor-which would permit Vermont Yankee to poration (" Vermont Yankee"),
perform extensive maintenance on the Vermont Yankee Nuclear Power
'B" diesel generator for fourteen days dur-Station's ("VYNPS's")
ing the current operating cycle, while the reactor is operating at power.1 50 Fed. Reg. 5,435.
The NRC proposes to make a determination of no significant hazards consideration regarding the proposed license amendment.
The New England Coalition on Nuclear Pollution ("NECNP") op-poses the proposed finding of no significant hazards considera-NECNP's Opposition is supported by the affidavit of Robert tion..
As dis-D. Pollard, a nuclear safety engineer.
NECNP has requested a hearing on the proposed license amend-New England Coalition's Request for Hearing on Proposed 1
ment.
Operating License Amendment (February 22, 1993).
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cussed below, the intentional disabling of one of Vermont Yanken two diesel generators would Nuclear Power Station's ("VYNPS's")
17, the NRC's fundamen-violate General Design Criterion ("GDC")
tal requirement that onsite ciectric power supplies must "have redundancy, and testability to perform sufficient independence, 10 C.F.R.
their safety functions assuming a single failure."
In addition, the proposed amendment Ptrt 50, Appendix A, GDC 17.
which contain no violates the technical specifications for VYNPS, provision for deliberate removal of the diesel generators from service during power operation.
On its face, ty, 2-2 in the intentional disabling of an essential safety system, the URC's General Design Criteria, NRC regulatory violation of and VYNPS technical specifications, raises significant
- guidance, Accordingly, pursuant to Section hazards considerations.
189a ( 2) ( A) of the Atomic Energy Act, 42 U.S.C.
S 2239 (a) (2) ( A),
the NRC must provide a hearing on the proposed license amendment beforn it can be issued.
I.
STATsarJiT OF FACTS VYNPS has two standby diesel generators which constitute the onsite electrical power supply for the plant's structures, sys-GDC 17 requires that tems, and components important to safety.
i each of the diesel generators must be safety grade and designed 1
i to " provide sufficient capacity and capability" to maintain plant safety during design basis accidents, assuming a loss of offsite i
power.
Pursuant to GDC 17 and the plant's Limiting Conditions for VYNPS cannot be operated at. power unless Operation ("LCO's"),
., FEB 22 '93 03: 30Pt1 K3J
, As provided by Technical both diesel generators are functional.
Specification ("TS")
3.10.A.1, Both emergency diesel generators shall be operable and and fre-capable of starting and reaching rated voltage quency in not more than 13 seconds.
A limited exception to this requirement is provided in TS 3.5.H.1:
During any period when one of the standby diesel gener-continued reactor operation is ators is inoperable, permissible only during the succeeding seven days, pro-vided that all of the Low Pressure Core Cooling and Containment Cooling Subsystems connecting to the operible diesel generator shall be operable.
However, TS 3.5.H.1 also states that "If this requirement cannot an orderly shutdown shall be initiated and the reactor be met, shall be in the cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
On three previous occasions, Vermont Yankee has invoked TS 3.5.H.1 for the purpose of repairing diesel generators at power.
the NRC granted Vermont Yankee permission to inten-In 1990, tivnally disable and overhaul one of its diesel generators while i
operating at power, on the ground that a local hydroelectr c sta-tion was available to provide backup power.2 Ene Memorandum from Murley, Office of Nuclear Reactor Regulation, to Thomas Thomas E.
1990) and Martin, Regional Administrator, Region I (May 18, T.
enclosures, Attachment 2.
the practice of intentionally disabling As discussed below, diesel generators while at power in order to make routine 2
repairs is not permitted by either GDC 17 or the technicalThus specifications for VYNPS. erred when it granted permission for the 199
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P.5 FEB 22 '93 03: 30PM 4'
-4 Vermont Last year, on two separate occasions a month apart, b
Yankee declared.its "A" diesel generator inoperable after "a -
normalities were encountered with the jacket cooling system.
to United States Lotter from Warren P. Murphy, Vermont Yankee, Proposed Change No. 166, One-Nuclear Regulatory Commission ro:
LCO Period to Sup-Time Extend,ed Emergency Diesel Generator (EDG)
(December 15, 1992) (hereinafter port Maintenance Activities at 2
" Murphy Letter"), Attachment 3.
On May_28, 1992, and again on Vermont Yankee began diesel generator repairs June 23, 1992, while the reactor was at power, as permitted by TS 3.5.H.1_for When Vermont Yankee found that
" inoperable" diesel generators.
as required these repairs could not be completed within 7 days, it applied for and received temporary waivers by TS 3.S.H.1, which allowed a one-day extension for the repairs begun in May, Egg BVY and a two-day extension for the repairs begun in June.
to United Lotter from Warren P. Murphy, Vermont Yankee,92-068, 1992);
BVY 92-074, States Nuclear Regulatory Commission (June 3, Murphy, vormont Yankee, to United States Letter from Warren P.
1992), Attachments 4 and Nuclear Regulatory Commission (June 29, 5, respectively.
surveillance-of the "B" diesel According to Vermont Yankee, generator "has not revealed any indication" of the problems which Murphy Letter at 2.
rendered "A" diesel generator inoperable.
Nevertheless, Vermont Yankee deemed it " prudent" to make the same it had made to the "A" repairs to the "B" diesel generator that Id.
Rather than diesel generator "at the earliest opportunity."
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-S-waiting until the next refueling outage or scheduling an outago to make the repairs, Vermont Yankee submitted a letter 1to NRC re-quenting a change to TS 3.5.H.1 which would allow a "one-time ex-tension" from the LCO of 7 days to 14 days in which to make those as well as to conduct the routine 18-month overhaul of
- repairs, On January Murphy Letter, Attachment 3.
the diesel generator.
the NRC published a Federal Register notice of the pro-21, 1993, along with a proposed finding that no posed license amendment, is required because it poses no prior hearing on the amendment significant hazards consideration.
THE PROPOSED LICENSE AMENDMENT POSES SIGNIFICANT II.
CONSIDERATIONS.
Statutory and Regulatory Framework A.
of the Atomic Energy Act and Pursuant to Section 189a(2) ( A) the NRC may not issue an operating license 10 C.F.R. 50.92(c),
amendment before granting a public hearing unless it determines that the proposed amendment poses "no significant hazards consid-eration,"
i.e., that the amendnent would ngA:
(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; create the possibility of a new or different kind of accident from any accident previously evaluated; or (2)
Involve a significant reduction in the margin of (3) safety.
In passing the enabling legislation for this regulatory provi-sion, Congress recognized that issuing the order in advance of a hearing would as a foreclose the public's right to have practical matter, In addition, the licensing board its views considered.
would often be unable to order any substantial relief as a result of an after-the-fact hearing.
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. 97th Cong., 2d Sess., at 37-38 (1982).
Conf. Rep. No.97-884, Thus, the conferees noted their intent that in-in determining.whether a proposed license amendmont volves no significant hazards consideration, the Com-mission should be especially sensitive to the issues posed by license amendments that have irreversible con-in the sequences (such as those permitting.an increaseamount of e to coerate for a period of ity or allowina a facility time without full safety protections.)
Id. (emphasis added)
In response to Congress' expression of concern, the Commis-sion "made clear" in the preamble to S 50.92 that an amendment which allows a plant to operate'at full power during which one or more safety systems are not operable would be treated in the same way as other ex-amples considered likely to involve a significant hazards consideration.
Final Procedures and Standards on No significant Hazards Consid-orations, 51 Fed. Reg. 7,744, 7,750, Col. 3 (March 6, 1986).
In addition, the Commission " charge [d] the NRC staff to assure that doubtful or bordorline cases are not found to involve no sig-51 Fed. Rog. at 7,753, Cols.
2-nificant hazards consideration."
3.
The Proposed License Amendment Raises Significant B.
Hazards Considerations involving the disabling of_a The circumstances of this case, major safety component in violation of NRC General Design Critoria and VYHPS technical specifications, raise significant Even were these hazards considerations in the starkest terms.
violations more " doubtful or borderline" (51 Fed. Reg, at 7,753',
the serious safety questions raised by the proposed Cols. 2-3),
,, FEB 22 '93 03: 32Pt1 h8
-7 amendment would dictate against the issuance of a no significant hazards consideration finding, and require the granting of a prior hearing on Vermont Yankee's proposed license amendment.
The Proposed Amendment Involves the Intentional 1.
Disabling of A Safety System, In violation of GDC 17.
Under the Commission's standards for finding no significant Col.
3, there hazards considerations, sge 51 Fed.-Reg._at 7,750, can be no question that the proposed amendment raises "sig-nificant hazards" considerations, because it would allow the VYNPS to operate "at full power during which one or more safety systems [i.e., the "B" diesel generator) are not operable," in direct violation of GDC 17.
The importance of compliance with GDC 17 cannot be gainsaid.
GDC 17 is one of the NRC's " minimum requirements" that establishes the " principal design criteria" for " structures, systems, and components that provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public."
Introduction to 10 C.F.R. Part 50, Appendix A.
In evaluating the sufficiency of the onsite power supply to power safety systems, GDC 17 assumes that offsite power systems are unavailable, and requires the provision of onsite power supplies "with sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure."
Thus, in evaluating whether Vermont Yankee's diesel generators comply with GDC 17, it must be assumed that (a) no offsite power in available and (b) one of the two diesel gen-erators han failed.
If the remaining diesel generator were in-3
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.. FEB 22 '93 03:32Fl1
. license tentionally disabled, as proposed in Vermont Yankes's.
amendment application, VYNPS would have no protection against a in direct violation of CDC single failuro of a diesel generator, 17.
could is clear that such a violation of GDC 17 Moreover, it increase accident risk at VYNPS in all.three of the aspects by S
which NRC judges "significant hazards" under 10 C.F.R.
With respect to the first criterion, the inton-50.92 (c) (1)-(3).
i tly tional disabling of the "B" diesel generator would signif can compound the " probability or consequences" associated'with a the unavailability of i.e.,
"previously evaluated" accident one of the diesel generators during a loss.cf offsite power, as If the "B" diesel generator is inten-contenplated by GDC 17.
tionally disabled and the "A" diesel generator must be assumed.to this would leave VYNpS without be disabled as required by GDC 17, a design Under such circumstances, any source of onsite power.
basis accident would be transformed to a beyond design basis ac-with the potential for meltdown and catastrophic con-
- cident, Thus, the proposed amendment raises significant sequences.
hazards considerations under the second criterion of.S 50.92(c).
Finally, the significantly increased probability and consequences of a serious accident would obviously involve a "significant thus establish-reduction in the margin of safety" at the plant, ing a significant hazard under S So.92 (c) (3).
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FEB 22 '93 -03: 73PM P.10
,. The Intentional Disabling of a Diesel Gencretor for Repairs at Power Violates Vermont' Yankee's 2.
Technical Specifications and NRC Regulatory Guid-ance.
Vermont Yankee's operating license amendment application is through its based on the assumption that it is already entitled, to disable and repair the "B" diesel technical specifications, generator at power, and that'all it requires is an extension'of Egg Mur-the seven-day period for repairs' allowed by TS 3.5.H.1.
However, Vermont Yankee's position is based on phy letter at 1.
an incorrect interpretation of VYNPS's technical specifications.
7 the intentional disabling of a diesel generator for In fact, f
repairs that could otherwise be postponed until a planned outage violates the VYNPS technical specifications.
the principal VYNPS technical specifi-Pursuant to GDC 17, requires cation governing standby diesel generators, TS 3.10.A.1, that both diesel generators must be " operable and capable'of reaching rated voltage and frequency in not more than 13 sec-upon which Vermont Yankee relies, creates a onds."
TS 3.5.H.1, limited exception to this rule, providing that "During any period when one of the standby diesel generators is inoperable, con-tinued reactor operation is' permissible only during the succeed-ing seven days l
Vermont Yankee apparently interprets the term " inoperable",
i to include the intentional disabling of as used in TS 3.5.H.1,
- Thus, the diesel generators for routine or non-urgent repairs.
TS 3.5.H.1 permits it to intentionally as read by Vermont Yankee, disable one of its diesel generators for repairs at any time,
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4 t-F EB 21 = '93 ' 03: 33pri P.11 10 -
How-long as the duration of C.
repairs does not exceed 7 days.
ever, such a broad interpretation of the exception in TS 3.5.H.1 would swallow the general rule established by GDC 17 and TS operato unless both diesel generators 3.10.A.1, that VYNPS cannot are operable and available.
In effect, under Vermont Yankee's interpretation of the technical specifications, a diesel genera-tor could be disabled for repairs overy two weeks, as long as the repairs could be finished in seven days.
Yankee's interpretation of its techr.ical specifica-Vermont tions is also inconsistent with the guidance sat forth in Rog.
which contemplatna at power repairs only aftgr the Guide 1.93, down thg rengtor have been balanced acainst the rjoke of 5. hutting i
l cenerator:
,_sku of contlnuina to operate with onJv ene d ese it may be safer to continue Under certain conditions, operation at full or reduced power for a limited time than to effect an immediate shutdown on the loss of Such de-some of the required electric power sources.
cisions should be based on an evaluation that balances l
i the risks associated with immediate shutdown against those associated with continued operation.
If, on the l
immediato shutdown is the safor course,
- balance, unit should be brought promptly to an orderly shutdown, For exam-and to a cold shutdown as soon as possible.
the risks associated with an immediate shutdown on
- plc, the loss of onsite a.c. power supply during a period of light system load would tend to be less than those dur-ing a peak load period because the stability of theIf, offsite power system would be relatively higher.
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continued power operation is the safer on balance, the period of continued operation should be
- course, used to restore the lost source and to prepare for an of course, that these ac-orderly shutdown, provided, tivities do not risk further degradation of the elec~
tric power system or in any way jeopardize plant safety.
Reg. Guide 1.93 at 1.
Under this standard, the only acceptablo justification for repairing the diesel generators at power would 1
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,. FEB 22 '93 03:3aPr1
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be a showing that it is safer to do that than to shut the p an down -- an argunent that could be made only if the diesel genera-or so unreliable as to be effectively ter was ungble to function, Those circumstances do not exist here, where the "B" inoperable.
and Vermont Yankee seeks permis-diesel generator is functional, i
nion simply to make non-urgent repairs and to conduct rout ne the Thus, under the guidance of Reg. Guide 1.93, maintenance.
in-VYNPS technical specifications cannot be read to. permit the tentional disabling of the diesel generators in order to perform routine repairs.
Because Vermont Yankee's proposal to intantionally disable diesel generator during power operation constitutes a the "B"
departure from its technical specifications governing important it necessarily raises "significant hazards con-safety functions, while the NRC staff concluded (erroneous-siderations."
In fact, that Vermont Yankee's 1990 bid to overhaul its ly, NECNP submits) diccol generator during power operation was sanctioned by'its "this technical specifications, the staff noted its concern that Memorandum from maintenance practico poses a noteworthy risk,"
3, Region I, to R.
Johnson, Chief, Reactor Projects Branch No.
J.
Wessman, Directorate I-3, NFR (April 6, 1990), Enclosure to At-tachment 2.
P,13^
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l'EB 22 '93 ~ 03: 34Pt1 12 -
Tbc Existence of the Vernon Tie-Line would Not 3.
Compensato for the Disabled Diesel Generator Under GDC 17.
Vermont Yankee attempts to stisfy the no significant hazards standard by arguing that there will be no significant change in the types of potential accidents at VYNPS or decrease in the margin of safety of the plant, "because of the availability of other plant electriccl systems, including the Vernon tio line" from a local hydropower station.
Murphy letter at 5.
Ilowever, this argument ignorns GDC 17', which provides such as the Varnon tie quite clearly that offsite power sources, in line, cannot be used as substitutes for onsite power sources order to satisfy the requirements for backup power supply.
Moreover, even if GDC 17 could be ignored, and the Vernon tio line could be credited as a backup electricity supply, far too many questions exist about the capacity and reliability of the vernon tie line es a source of backup power to safety sys-tems.
For instance, as Vermont Yankee has conceded, it is im-possible to tant the Vernon tic-line under a full station black-out load.
BVY 92-94, Letter from Leonard A. Tremblay, Jr., Ver-to United States Nuclear Regulatory Commission, re:
mont Yankee, Response to NRC Request for 10CFR50.63 Station Blackout (SBO)
Additional Information, Attachment te BVY 92-94 at 3 (July 31, 1992), Attachment 6.
Moreover, Verment Yankee admits that "[d]uo to the vintage of the hydro station generators' voltage regulctors," it is unable to " analytically predict" what the voltage icvols will be upon application of the largest load to the 4160-volt emergency bus.
Id. at 3.
Instead, Vermont Yankee
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FEB 21 '93 03: 3fPl1 -
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,. relics on the engineering judgment of hydro operators and dis-patchers from outside Vermont' Yankee, who are not licensed by NRC and.who have no responsibility for the safety of VYNPS.
In sum, Vermont Yankee has neither empirical evidence nor analytical results to demonstrate that the Vernon tio line has " sufficient Ac-capacity and capability" to meet the requirements of GDC 17.
the existence of the Vernon tic-line provides no basis cordingly, for a no significant hazards fincing in this case.
CONCLUSION Vermont Yanken has failed to demonstrate that the proposed license amendment involves no significant hazards considerations; it would significantly increase the risk to in fact, on its face, Accor-public health and safety posed by operation of the VYNPS.
dingly, the NRC should reverse its proposed finding of no sig-nificant hazards considerations, and order a prior hearing'on the proposed license amendment.
Respectfully' submitted, mfk~
ane Curran HARMON, CURRAN, GALLAGHER &
SpIELBERG 2001 "S" Street N.W.
Washington, D.C.
20009 (202) 328-3500 Counsel to NECNP February 22, 1993 e
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m Attachment F UNITED STATES OF AMERICA.
BEFORE THE NUCLEAR REGULATORY COMMISS'~CN
)-
In the Matter'of
)
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vermont Yankee Nuclear
).
Power Corporation
)
Docket No. 50-271-OLA
)
i (Vermont Yankee Nuclear
)
Power Station)
)
)
AFFIDAVIT OF ROBERT D. POLIARD t
I, Robert D. Pollard, do make oath and say:
1)
My name is Robert D. Pollard.
Since February 1976,.I have been employed as a nuclear safety engineer by'the Union'of-Concerned Scientists.
My bubiness address.is 1616 PfStreet, N.W.,
Washington, D.C.
20036.
Previously, I was employed by the United States Nuclear Regulatory Commission as a Licensing Pro-ject Manager for commercial nuclear. power plants.
2)
In May 1959, I enlisted in the United States Navy'and was selected to serve as an electronics technician in the nuclear' After completing the required training, I'became power program.
an instructor. responsible for teaching naval personnel both the '
theoretical and. practical aspects of. operation, maintenance and repair for nuclear propulsion plants.
From_ February 1964 to April 1965,-I served as the' senior reactor. operator, supervising the reactor control' division aboard the U.S.S. Sargo, a nuclear--
powered submarine.
In May 1965, I was honorably dischargedifrom-the U.S. Navy and attended Syracuse University, where;I received-the degree of Bachelor of Science maana cum laude 1in electrical engineering in June 1969.
3)
In July 1969, I was hired by the United StatesiAtomic Energy Commission (AEC) and continued as a technical expert with-the AEC and its successor, the United States Nuclear Regulatory Commission (NRC) until February 1976.
After joining.the-AEC, I completed a year of graduate studies in advanced electrical and nuclear engineering at the Graduate School of the University of New Mexico in Albuquerque.
I subsequently advanced to the posi-tions ot Reactor Engineer (Instrumentation) and Project-Manager-As a Reactor Engineer, I was primarily responsible with AEC/NRC.
for performing detailed technical reviews analyzing and evaluat-ing the adequacy of the design reactor protection systems, con-q trol systems and emergency electrical' power systems.in proposed.
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nuclear facilities.
In September 1974i I was promoted to thel
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position of Project Manager and became responsible for safety reviews of applications for licenses to construct and operate, several commercial power plants.
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FEB 22 *53 03: 36Pl1 P.16
, In the course of my six and a half years with the AEC 4) and NRC, I' performed technical reviews, analyses and evaluations of designs of systems and components necessary for safe operation of reactor facilities under normal, abnormal and emergency condi-tions for the purpose of determining whether such systems com-plied with NRC rules and provided an acceptable level of safety for the public.
5)
For the past fifteen years, I, along with other members of the Union of Concerned Scientists' professional staff, have conducted numerous studies pertaining to the safety and reliability of nuclear power plants, both on a generic and plant-specific basis.
I have provided technical analysis for UCS's participation in rulemaking proceedings before the Nuclear Regulatory Commission and for UCS's litigation against the NRC for failure to fulfill its responsibilities under the Atomic En-ergy Act.
I testified before the President's Commission on the Accident at Three Mile Island which investigated that 1979 acci-I participated as an expert witness in the NRC's ad-dent.
judicatory proceeding on matters pertaining to reactor safety be-fore numerous committees of the United States Congress and vari-ous other state and local legislative and administrative bodies.
Thus, my 23 years of professional experience on the technical staffs of the AEC, NRC, and UCS have given me first-hand knowl-edge of !TRC regulations and how they are developed, administered, and interpreted.
6)
I have reviewed all of the documents referenced in New England Coalition on Nuclear Pollution's Comments in Opposition to Proposed Finding of No Significant Hazards Consideration (Feb-ruary 22, 1993).
I am also familiar with NRC regulations and regulatory guidance governing the design and operability of diesel generators.
7)
The factual statements made in the attached New England Coalition on Nuclear Pollution's Comments in Opposition to Pro-posed Finding of No Significant Hazards Consideration are true and correct to the best of my knowledge and belief.
Robert D.
Pollard Subscribed and sworn to before me this __ day of February, 1993.
Notary Public j
My Commission expiros i
,