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Category:AFFIDAVITS
MONTHYEARML20073T0281983-05-0606 May 1983 Affidavit of TB Cochran Re Answers to Interrogatories. Related Correspondence ML20065N6711982-10-20020 October 1982 Affidavit of TB Cochran Clarifying Testimony at 820826-27 Hearings.Shock Wave Production Not Required for Nuclear Explosion to Occur ML20065N6571982-10-20020 October 1982 Affidavit of TB Cochran Listing Qualifications to Be Considered as Expert Interrogator ML20065N6441982-10-20020 October 1982 Affidavit of Er Weiss.Ucs Scientist R Pollard Allowed to Act as Expert Witness for Ucs & as cross-examiner of Other Witnesses During TMI Restart Hearing ML20065M4371982-10-19019 October 1982 Affidavit of TB Cochran Re Environ Analyses for Fuel Cycle & Timing Objective.Prof Qualifications & Certificate of Svc Encl.Related Correspondence 1983-05-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20106J8711985-02-15015 February 1985 Notification Concerning Site redress.Near-term Planning for Site Redress Predicated Upon Commencing Redress by May 1985. Certificate of Svc Encl ML20107M9411984-11-0808 November 1984 Response to Motion to Dismiss Proceeding Re Revocation of Lwa.Authorization of Revocation of LWA & That Proceedings Be Dismissed W/O Prejudice Recommended.Certificate of Svc Encl ML20106J7951984-10-30030 October 1984 Response to Applicant 841019 Motion to Dismiss Proceeding. Motion Acceptable Subj to Conditions Set Forth in Redress Plan & NRC .Certificate of Svc Encl ML20093M2611984-10-19019 October 1984 Motion to Dismiss Proceeding.Applicable Conditions of Existing Federal Water Permit & State Water Quality Requirements Will Remain in Effect.Supporting Documentation & Certificate of Svc Encl ML20098F9571984-09-28028 September 1984 Notice of Change of Address & Telephone Number.Certificate of Svc Encl.Related Correspondence ML20098F7391984-09-28028 September 1984 Notice of Change of Address & Telephone Number.Certificate of Svc Encl ML20097G9671984-09-19019 September 1984 Notice of Change of Address & Telephone Number.Certificate of Svc Encl.Related Correspondence ML20087F4701984-03-15015 March 1984 Answer to Applicant Petition for Review of ASLB 840229 Memorandum & Order Re Crbr LWA Proceedings on Site Redress Plan.Intervenors Main Concern Is That Redress Be Rapid & Effective.W/Certificate of Svc ML20086T0141984-03-0505 March 1984 Petition for Review of Appeal Board 840229 Memorandum & Order Readmitting Intervenors to Proceedings.Intervenor Participation Will Protract Proceeding for Project Which Is Terminated.Certificate of Svc Encl ML20080N0471984-02-21021 February 1984 Answer Opposing NRDC & Sierra Club Appeals to ASLB Decisions.Certificate of Svc Encl ML20080C6411984-02-0606 February 1984 Brief of Intervenors in Support of Appeal of ASLB 840120 Order.Certificate of Svc Encl ML20080C6121984-02-0606 February 1984 Notice of Appeal of ASLB 840120 Notice Denying NRDC Motion to Intervene ML20080C6021984-02-0606 February 1984 Brief in Support of Appeal of ASLB 840120 Order Re NRDC Motion to Intervene ML20083J4351984-01-0909 January 1984 Response to NRDC Reply Per ASLB 831228 Order.Contentions Raised in NRDC Motion to Intervene Moot.Motion Should Be Denied.Certificate of Svc Encl ML20083E4231983-12-27027 December 1983 Notice of Project Termination.Certificate of Svc Encl ML20082S4471983-12-12012 December 1983 Request to Reply to Util 831205 & NRC 831208 Responses to NRDC Motion to Intervene ML20082S4541983-12-12012 December 1983 Reply to Util 831205 & NRC 831208 Responses to NRDC Motion to Intervene.Appropriate ASLB Course of Action Is Termination of Proceedings on Grounds of Mootness. Certificate of Svc Encl ML20082Q6841983-12-0909 December 1983 Amended Notice of Appearance in Proceeding.Certificate of Svc Encl ML20082M5401983-12-0505 December 1983 Response Opposing NRDC 831123 Motion to Intervene.Proceeding Moot Due to Project Cancellation.Cp Partial Initial Decision Should Be Issued.Certificate of Svc Encl ML20082M5271983-12-0505 December 1983 Response Supporting Intervenor 831123 Motion to Terminate Appeal Proceedings,Vacate Partial Initial Decision & Authorize Revocation of Lwa.Certificate of Svc Encl ML20082E1261983-11-23023 November 1983 Petition of NRDC for Leave to Intervene & Request for Hearing Re Effect of Crbr Termination on CP Proceedings. Contentions Listed ML20081D7931983-10-31031 October 1983 Confirmation of Info Re Legislative Status Discussed W/Aslb in 831028 Telcon.Certificate of Svc Encl ML20081A5041983-10-25025 October 1983 Supplemental Citations Supporting Thesis That Following Hydrodynamic Core Disruptive Accident,Reactor Vessel Closure Head Is More Susceptible to Failure than Reactor Vessel Head.Certificate of Svc Encl ML20078B9771983-09-26026 September 1983 Response Opposing NRC 830913 Motion for Leave to File Supplemental Affidavit of Lg Hulman.Affiant Revised Testimony Incorrect,Misleading & Irrelevant.Certificate of Svc Encl ML20076C9811983-08-22022 August 1983 Motion to Correct Transcript of Aug 1983 CP Evidentiary Hearings.Certificate of Svc Encl ML20076A7871983-08-17017 August 1983 Motion to Reschedule 830929 Oral Argument to 830928. Certificate of Svc Encl ML20077J5051983-08-15015 August 1983 Proposed Initial Decision,Findings of Fact & Conclusions of Law Re Cp.Certificate of Svc Encl ML20077B6661983-07-22022 July 1983 Response Opposing Intervenor 830518 Exceptions to ASLB 830228 Partial Initial Decision on Lwa.Aslab Should Affirm ASLB Decision.Site Suitability Arguments Incongruous. Certificate of Svc Encl ML20024C3641983-07-0808 July 1983 Limited Appearance Statement of TB Cochran Re Issues Raised in CP Proceeding.Discusses Radiological Consequences of Crbr Core Disruptive Accident & Site Suitability.Certificate of Svc Encl ML20072F2651983-06-22022 June 1983 Response to Intervenor 830621 Motion to Withdraw Contentions 1,3,9(c),9(f) & 9(g) from Consideration at Jul 1983 CP Hearings.Intervenors Should Be Dismissed as Parties. Certificate of Svc Encl ML20079R2631983-06-21021 June 1983 Response Opposing Applicant 830519 & 23 Motions for Summary Disposition of Contentions 9(g),9(c) & 9(f).Motions Moot Since Intervenors Moved to Withdraw Contentions from Consideration ML20079R2491983-06-21021 June 1983 Motion to Withdraw Contentions 1,3,9(c),9(g) from Consideration at Jul 1983 CP Hearings & Request for Leave to Submit Written Statement on Issues Raised.Limited Resources Prohibit Continued Full Participation ML20071M3191983-05-27027 May 1983 Notification of Pending Litigation Re NRDC 821001 Motion to Expedite Consideration of Emergency Motion to Amend Us District Court of Appeals Remand & to Review EPA Regulations.Certificate of Svc Encl ML20071H0321983-05-23023 May 1983 Motion for Summary Disposition of Intervenor Contentions 9(c) & 9(f) Re Adequacy of Evacuation Time Analysis in Psar. No Genuine Issue of Matl Fact Exists & Applicant Entitled to Favorable Decision.Certificate of Svc Encl ML20071H0461983-05-23023 May 1983 Statement of Matl Facts as to Which There Is No Genuine Issue Re Contentions 9(c) & (F) on Emergency Plans ML20071H0911983-05-23023 May 1983 Motion for Extension Until 830722 to File Response to Intervenors 830518 Brief in Support of Exceptions. Certificate of Svc Encl ML20076D0191983-05-19019 May 1983 Statement of Matl Facts as to Which There Is No Genuine Issue Re Contention 9(g) on Emergency Planning.Certificate of Svc Encl ML20076C9801983-05-19019 May 1983 Motion for Summary Disposition of Contention 9(g) Re Emergency Plans.No Genuine Issue of Matl Fact Exists ML20023D1761983-05-18018 May 1983 Notification Re PRA Status Rept.Encl Phase I PRA Rept Not Submitted to NRC for Review.Results of Rept Insignificant to Proceeding.W/O Phase I Rept.Certificate of Svc Encl ML20071H2211983-05-18018 May 1983 Brief Supporting Exceptions to ASLB 830228 Partial Initial Decision Re LWA ML20023D0951983-05-17017 May 1983 Third Set of CP Interrogatories & Request to Produce. Certificate of Svc Encl.Related Correspondence ML20074A8791983-05-13013 May 1983 Response to 830425 Eleventh Set of Interrogatories & Request for Admissions.Certificate of Svc Encl.Related Correspondence ML20074A8621983-05-13013 May 1983 Response to 830427 Second Set of CP Interrogatories & Request for Admissions.Related Correspondence ML20023C2071983-05-0909 May 1983 Certifies Svc on 830509 ML20079Q3021983-05-0909 May 1983 Corrected Response to First Set of Interrogatories & Request to Produce.Requested Documents Will Be Made Available for Insp & Copying ML20079Q3001983-05-0909 May 1983 Responds to Second Set of CP Interrogatories.Aerosol Plateout & Fallout Calculations Discussed.Affidavit Encl. Related Correspondence ML20079Q2781983-05-0909 May 1983 Response to First Set of CP Interrogatories & Request to Produce.Requested Documents Will Be Made Available for Insp & Copying.Related Correspondence ML20079P9141983-05-0909 May 1983 Response Opposing Intervenor 830429 Motion for Extension of Time.Good Cause Not Demonstrated ML20023C1961983-05-0606 May 1983 Certifies Svc on 830506 of Intervenor Supplementary Response to Applicant Eighth & Ninth Set of Interrogatories Dtd 830401 & 08 & Intervenor Response to Applicant Tenth Set of Interrogatories Dtd 830421 ML20079P6971983-05-0606 May 1983 Supplementary Response to Eighth & Ninth Set of Interrogatories & 08.Review of SER & Related Documentation Incomplete,Hindering Response to Certain Interrogatories.Related Correspondence 1985-02-15
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DOCKETED USNRC
- fs2 dCT [0 PS:d1 r ~ c v. u v UNITED STATES OF AMERICA . .;
NUCLEAR REGULATORY COMMISSION
- ATONEC SAFETY AND LICENSING BOARD Before Administrative Judges:
Marshall E. Miller, Chairman Gustave A. Linenberger, Jr.
Dr. Cadet H. Hand, Jr.
)
In the Matter of )
)
) Docket No. 50-537 UNITED STATES DEPARTNENT OF ENERGY )
PROJECT MANAGEMENT CORPORATION )
TENNESSEE VALLEY AUTHORITY )
)
(Clinch River Breeder Reactor Plant) )
)
i AFFIDAVIT OF THObaS B. COCHRAN 1
I, Thomas B. Cochran, being duly sworn, do hereby state as follows:
- 1. My name is Thomas Brackenridge Cochran. I reside at 4836 North 30th Street, Arlington, Virginia 22207. I am presently a Senior Staff Scientist at Natural Resources Defense l
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Council, Inc., and a co-director of the NRDC Nuclear Nonproliferation Project.
- 2. I am a member of the Department of Energy's Energy Research and Advisory Board; the Three Mile Island (TMI) Public Health Fund Advisory Board; the Nuclear Regulatory Commission's TMI Advisory Board; and the American Nuclear Society.
- 3. I have a B.S. degree in electrical engineering and M.S.
and Ph.D. degrees in physics, all from Vanderbilt University.
I have held the positions of Assistant Professor of Physics, U.S. Naval Postgraduate School, and Senior Research Associate, Resources for the Future.
- 4. I have been a consultant to numerous government -
agencies and testified before Congress on numerous occasions on matters related to nuclear energy generally and liquid metal fast breeder reactors (LMFBRs)- in particular. I was a member of DOE's Nonproliferation Advisory Panel and ERDA's LMFBR Review Steering Committee. I am the author of The Liquid Metal l Fast Breeder Reactor, An Environmental and Economic Critique, (Johns Hopkins Univ. Press, 1974).
- 5. With regard to matters of LMFBR safety, I was also a member of the NRC's Advisory Group on Reactor Safety Goals and l
NRC's Advisory Group on Operator Training. I have had extensive hands-on experience with systems modeling and computer programming, both in relation to my Ph.D. dissertation in high energy physics and while serving as a Modeling and I
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l Simulation Group Supervisor at Litton Scientific Support ;
Laboratory at Fort Ord, California. !
- 6. I was one of two U.S. citizens invited to testify on safety aspects of the SNR-300, the Federal Republic of Germany's demonstration breeder, before the Enquete-Kommission "Zukunf tige Kernenergie-Politik," Deutscher Bundestag, FRG (June 3, 1982).
- 7. With regard to radiation protection, my M.S. thesis was in Radiation Chemistry. I was an AEC Health Physics Fellow at Vanderbilt University between 1962 and 1964, during which period I had 3 months of on-the-job training at Oak Ridge
- National Laboratory. I was the campus Radiation Safety Officer while pursuing my Ph.D. degree at Vanderbilt University.
- 8. While at NRDC I co-authored with Dr. Arthur Tamplin two radiation standards petitions to the NRC, " Petition to Amend 10 CFR 20.101, Exposure of Individuals to Radiation in Restricteo Areas," September 1975 (PR M-2 0-6) , and " Petition to Amend Radiation Protection Standards as They Apply .to Hot Particles,"
February 1974 (PR PF20-5) .
- 9. I have been a member of the Health Physics Society for-the past 18 or so years.
- 10. My statement of professional qualifications is attached.
- 11. Because of my scientific and technical training and experience, I am familiar with many aspects of the Clinch River
Breeder Reactor, and its proposed fuel cycle facilities, that are discussed in Intervenors' Contentions.
- 12. I have participated actively in all phases of the NRC Clinch River Breeder Reactor licensing proceedings since 1975, including assisting in the preparation of Intervenors' contentions.
- 13. I prepared substantial portions of NRDC's comments on the 1977 CRBR Final Environmental Impact Statement and the 1982 Draf t Supplement to the 1977 CRBR Final Environmental Impact Statement.
- 14. I testified before the NRC Advisory Committee on Reactor Safeguards on several occasions regarding the Clinch River Breeder Reactor and related issues.
- 15. I have attended numerous meetings held by Staff and Applicants to discuss the NRC licensing review of the Clinch l
River Breeder Reactor.
- 16. I have participated actively in discovery proceedings
'related to CRBR licensing from 1975-1977, and from March 1982 to the present, including the preparation of interrogatory l
l questions and responses, and requests for admissions and i
responses, and have conducted several depositions of witnesses for Applicants and Staff.
- 17. I have read or examined many of the documents upon which Applicants and Staff purport to rely for their positions on Intervenors' Contentions.
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- 18. I fully intend to read all written testimony submitted by Staf f and Applicants on which I intend to cross examine, and any documents to be used or referred to in the course of the cross-examination.
- 19. I have prepared myself, and will continue to prepare myself to conduct a meaningful and expeditious cross-examination.
- 20. I intend to limit my cross-examination to areas within my expertise.
bSL3 Thomas B. Cochran Date: October 20, 1982 Sworn and subscribed to before me this so t4 day of October, 1982.
O hi W&V Notary Public My Commission Expires 7/3/ ///7 I
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