ML20070M156

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Motion to Admit Portions of Rj Budnitz Deposition as Evidence.Testimony Probative Re Quality & Scope of Pra. Certificate of Svc Encl
ML20070M156
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 01/06/1983
From: Twana Ellis
HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8301120327
Download: ML20070M156 (17)


Text

_ - _ _ _ _ _ _ _ _ _ _

i LILCO, Janunry 6, 1983 00tK,ET,ED 7

33 p.10 NO 59 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

)

Docket No. 50-322-(OL)

)

(Shoreham Nuclear Power Station,

)

Unit 1)

)

MOTION TO ADMIT PORTIONS OF DEPOSITION OF ROBERT JAY BUDNITZ AS EVIDENCE Long Island Lighting Company ("LILCO") makes this motion to admit portions of the deposition of Robert Jay i

Budnitz as evidence on Suffolk County Contention 7B1/ on the grounds that this testimony of Dr. Budnitz is material, 1/

10 C.F.R.

$ 2.740a(g) (1982) authorizes making a deposi-tion, or part et a deposition, part of the record when it is received in evidence.

That provision does not, however, indi-cate the proper circumstances for admitting a deposition as evidence.

Where, as here, the Commission Rules of Practice are silent on a procedural rule or practice, guidance is found in the rules and practices followed in the federal courts.

Consumers Power Company (Midland Plant, Units l 'and 2),

ALAB-379, 5 NRC 565, 568 n.13 (1971).

i Federal Rule of Civil Procedure 32(a)(3)(B) allows the use of depositions at hearings when the deponent."is at a greater distance than 100 miles'from the place of trial or hearing.

unless it appears that the absence

. was procured by the party offering the deposition."

This provision authorizes the use of Dr. Budnitz's deposition at the hearings in this pro-ceeding because Dr. Budnitz lives in California, clearly more than 100 miles from the location of the hearings.

0301120327 830106 PDR ADOCK 05000322 O

PDR 3 503

relevant, and probative regarding the quality and scope of the Probabilistic Risk Assessment ("PRA") performed'at the Shoreham Nuclear Power Station ("Shoreham").

Dr. Budnitz, a former director of NRR (1979-80), was retained as a PRA expert by Suffolk County, inter alia, for the purpose of reviewing the Shoreham PRA.

More specifically, during the depositions conducted in connection with the contentions filed on Phase I of emergency planning, Suffolk County offered Dr. Budnitz as one of its experts regarding the PRA performed at Shoreham.2/

Dr. Budnitz's deposition, currently on file with the NRC, was taken on August 17, 1982, in Beverly Hills, California.

In the course of his deposition, Dr. Budnitz made clear his opinion on the thoroughness and high quality of the Shoreham PRA:

Q.

You indicated, Dr. Budnitz, that you had reviewed -- read critically the PRA for Shoreham.

A.

Yeah, but it's too long to do.

You know, it's not something you --

Q.

Right.

A.

It's not something you read each page of, and it's not something that we attempted to -- to review thoroughly item by item.

2/

Suffolk County, in addition to Dr. Budnitz, offered Fred C.

Finlayson as an expert on this issue.

9.

Q.

On the basis of what you've done, have you formed any opinion or expressed any opinion to anyone concerning the thoroughness of it?

A.

Yes.

Q.

All right.

What is that?

A.

We are impressed by its thoroughness and quality, generally.

We believe that it is a report that was at the state of the art.

That is, these analysts are as competent as the best in the business.

It's hard to say whether they're better than the other three or four teams that carry out such work, but they're certainly at that level.

That opinion is preliminary but is unlikely to change even if we find in the end some differences, large or small, with details.

That's a preliminary opinion that I'm willing to state and stand behind as opposed to, for example, if you asked me what is my preliminary view of the internal flooding question.

I'll say, " Wait a minute.

I'm still wrestling with that one; okay?"

But I would be capable of stating now and believing that it won't change in the end; that we believe that the analysis is technically good.

In fact, better than good.

It's -- I said it's at the state of the art.

Dep. Tr. at 52, line 23 through page 53, line 26.

Contrary to the County's position on the PRA, Dr.

Budnitz also made equally clear his expert opinion that he has no doubt the Shoreham PRA considers systems interactions.

Q.

You don't have any doubt, though, do you, that systems interactions were consid-ered in the SAI work? --

m n

A.

No, none whatsoever.

In fact, in conversations with Erdmann, Burns, and.

colleagues a month ago, we had some questions about some of.the stuff they did that they resolved just by answering, you know, what it was that they had done, and I could state here my tentative conclusion that, you know, they did a good job, and there are some good insights, and I learned a lot more on that stuff just by reading that long transcript in which Burns and Joksimovich said more on some of that than was in the report.

Q.

You're referring to the transcript of the hearing?

A.

Of the hearing, yeah, June or July, whenever it was on'the 4th of July.

Dep. Tr. at 89, line 15 through page 90, line 1.

These opinions, offered by an expert retained by Suffolk County, are unquestionably material and relevant with respect to the PRA conducted at Shoreham.

Moreover, this tes-timony is particularly probative because it is the County's own expert reaching conclusions contrary to positions taken by the County with respect to the Shoreham PRA.

See, e.g.,

Goldsmith, et al.,

ff. Tr. 1114, at 66 ("Unfortunately, the PRA currently being done at Shoreham excludes systems interactions

").

Wherefore, LILCO moves that the following excerpts from the deposition of Dr. Budnitz be admitted in evidence and made a part of the record.3/

3/

Copies of these excerpts are attached for the convenience of the Board.

1.

Page 52, lines 23-28 2.

'Page 53, lines 1-26 3.

Page 89, lines 15-28 4.

Page 90, line 1 5.

Budnitz Exhibit 1 (resume)

Respectfully submitted, LONG ISLAND LIGHTING COMPANY

/ '7L m

/1 T. S. Ellis II W ~

g7 Anthony F.

riey, Jr.

W.

Jeffery Edwards Hunton & Williams Post Office Box 1535 Richmond, Virginia 23212 DATED:

January 6, 1983 s-

LILCO, Janunry 6, 1983 g

L.. t v-h 10' N059 83 4..

CERTIFICATE OF SERVICE

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In the Matter'of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 (OL)

I hereby certify that copies of LILCO's MOTION TO ADMIT PORTIONS OF DEPOSITION OF ROBERT JAY BUDNITZ were served upon-the following by first-class mail, postage _ prepaid,_by. Federal Express (as indicated by an asterisk), or by hand (as' indicated by two asterisks) on January 6, 1983:

Lawrence Brenner, Esq.**

Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing 1

Washington, D.C.

20555 Appeal Board Panel U.S. Nuclear Regulatory Dr. Peter A. Morris **

Commission Administrative Judge Washington, D.C.

20555 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555 Dr. James H. Carpenter **

Administrative Judge Daniel F. Brown, Esq.

Atomic Safety and Licensing Attorney Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555

' 0 4

Bernard M. Bordenick, Esq.**

David J. Gilmartin, Esq.

David A. Repka, Esq.

Attn:

Patricia A. Dempsey, Esq.

I U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C.

20555 Veterans Memorial Highway Hauppauge, New York 11787 i

Herbert H. Brown, Esq.**

Stephen B.

Latham, Esq.*

Lawrence Coe Lanpher, Esq.

Twomey, Latham & Shea Karla J.

Letsche, Esq.

33 West Second Street Kirkpatrick, Lockhart, Hill, P. O.

Box 398 Christopher & Phillips Riverhead, New York 11901 8th Floor 1900 M Street, N.W.

Ralph Shapiro, Esq.*

Washington, D.C.

20036 Cammer and Shapiro, P.C.

9 East 40th Street Mr. Mark W. Goldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road Howard L. Blau, Esq.

Waltham, Massachusetts 02154 217 Newbridge Road Hicksville, New York 11801 MHB Technical Associates 1723 Hamilton Avenue Matthew J.

Kelly, Esq.

Suite K State of New York San Jose, California 95125 Department of Public Service Three Empire State Plaza Mr. Jay Dunkleberger Albany, New York 12223 New York State Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223 g

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17

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Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED:

January 6, 1983 l

1

L'11LM.

52 1

A Well, th2 quaationa cro numbercd, to I crn 2

just tell you which ones they are.

3 0

Fine.

4 A

Number 1 is still open for us and bumber 2, a

bhmber 5, Number 13.

Just to give you an example, we asked "The discussion" a question in Number 14, and the answer was, 6

-- on page something-something -

"is no longer applicable,"

7 a

and the thing is being revised.

So what we didn't like, they realized, too.

9 10 This is, of course, a draft, and they're revising.

So that's the sort of interaction that, you know, i. a fairly typical 11 12 thing in this.

Number 18, their response has a clear typo; 23 14 okay?

They've got a probability of 1.2 that we think is

.12, and I'm sure they'll agree when we tell them that.

ss Number 20.

16 okay.

So the stage you're in now --

27 0

is A

And that's all, and there are 23 questions altogether, and those are the ones where I think we're 19 liable to go back and ask another question, but for two or 20 three of them, Lambert in the past day or two or Pete Davis 23 in the last day or,tana may have found the answer.

22 23 0

You indicated, Dr. Budnitz, that you had reviewed -- read critically the PRA for Shoreham.

24 23 A

Yeah, but it's too long to do.

You know, it's not something you --

2s Q

Right.

2; I

It's not,something you read each page of, and j

A 23 i

r 53 it'c not comething thut wa ctt mpt;d to.-- to r; view 1

2 thoroughly item by item.

o 3

Q on the basis of what you've done, have you formed any opinion or expressed any opinion-to anyone 4

a concerning the thoroughness of it?

E i O

6 A

Yes.

7 O

All right.

What is that?

8 A

We are impressed by its thoroughness and 9

quality, generally.

We believe that it is a report that 10 was at the state of the art.

That is, these analysts'are as competent as the best in the business.

It's hard to say 11 whether they're better than the other three or four teams 12 that carry out such work, but they're certainly at that j

13 i

14 level.

i i

That opinion is preliminary but is unlikely is to change even if we find in the end some differences, large 1s i

17 or small, with details.

That's a preliminary opinion that I'm willing to state and stand behind as opposed to, for 18 19 example, if you asked me what is my preliminary view of the internal flooding question.

20 I'll say, "Wa,it a minute.

I'm still wrestling 21 22 with that one; okay?"

But I would be capable of stating f

j now and believing that it won't change in the end; that we l

23 i

believe that the analysis is technically good.

In fact, I

24 23 better than good.

It's -- I said it's at the state of the l

2r, art.

l Q

Are you familiar with the so-called 2-deterministic studies that have been done at Shoreham?

23

89 l

Q

, How th3 SAI cccccced cystem7 --

1 2

A Okay.

I mean, it's eclectic.

That~little 3

comment was intended to tell you that I think that the phrase 4

" systems interaction," which now has a life of its own, has 5

become -- has encompassed too many specific issues for its B

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(

-own good.

3 7

Okay.

Witness some June, July discussions ir.

s which people in this room were all swearing to tell the truth 8

and so on and cross-examining each other somewhere in Long zu Island in which so many issues were brought into -- so many 11 issues were brought in, you know, that I can't possibly even 12 think about covering all_of them here, and I'm not going to 13 cover them all.

I can't.

It's unbelievable what went on.

1 14 15 0

You don't have any doubt, though, do you, that j to systems interactions were considered in the SAI work?

t li A

No, none whatsoever.

In fact, inconversationsl i

is with Erdmann, Burns, and colleagues a month ago, we had some 19 questions about some of the stuff they did that they resolved 20 just by answering, you know, what it was that they had done, I

21 and I could state here.my tentative conclusion,that, you I

22 know, they did a good job, and there are some good insights, i

..3 l

23 and I learned a lot more on that stuff just by reading that i

24 long transcript in which Burns and Joksimovich said more on

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25 some of that than was in the report.

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l 26 0

You're referring to the transcript of the a

,y.

hearing?

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t 28 A

Of the hearing, yeah, June or July, whenever

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it wcc cn tha 4th cf July.

2 O

Okay.

1.2.5 then is simply the --

3 A

Conclusion.

4 0

-- conclusions.

Do you know what the possible l

3 major issues are that will require special treatment?

i 6

A Yeah.

Generally they go as follows:

There 7

'are five classes into which all the accidents at Shoreham a

have been lumped for the purposes of this analysis, the SAI e

analysis, and the question is whether the accidents have

~

10 been grouped properly;"'That is, whether, for_ example, an 11 accident stuck into Class 3 might better be a Class 1 or a 12 5, let's say, because, in fact, each of those then is 13 generically used to do other things with, you know.

14 There's a time of release that, for example, u

for one class might be a 30-hour release and one class might is be a prompt release and that sort of thing, and that's an 17 issue which we're looking at.

18 Q

Any conclusions to date on that?

19 A

No, no, no.

Not yet.

20 Q

Is there any particular issue within that issue that you're focus'ing on?

Is there any particular 21 22 sequence that is grouped in one class or another that you're 23 particularly focusing on?

24 A

No, no.

That's not an area where we'd have 2:.

problems, but we're still -- I'm still looking at it.

2c Q

Okay.

2:

A Now, another one is the question of what is 2s the probability of each one of those classes, which is the

f h Q g & m & Sn 2000 Center Street Berkeley. California 94704 412/526-5111 ROBERT J. BUDNITZ Occupation:

Physicist in Energy / Environmental Research and Nuclear Safety' I

Birth:

October 12, 1940 in Pittsfield, Massachusetts Family:

Married in 1961 to Barbara Paresky Budnitz, Licensed Clinical Social Worker. Three children: Paul (born 1957), Benjamin (born 1970), Elizabeth (born 1976)

Present Address:

Future Resources Associates, Inc.

Education High School:

Pittsfield High School, Pittsfield, Massachusetts (1957)

Universities:

Yale University, New Haven, Connecticut B.A. Physics (1961)

Harvard University, Cambridge, Massachusetts M.A.

Physics (1952)

Ph.D. Physics (1968) i Present Professional Position President, Future Resources Associates, Inc.

d Past Professional Positions Teknekron, Inc.

Berkeley, California 1980 - 1981 Vice President, and Director of the Energy and Environmental Technologies Division U.S. Nuclear Regulatory Commission Washington, D.C.

1979 - 1980 Director, Office of Nuclear Regulatory Research 1978 - 1979 Deputy Director, Office of Nuclear Regula-tory Research fidl.m.rr 3.

~ -- ~ 6

-'" ' n* L.i sti C !.R. is P' Es" -

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Lawrence Berkeley Laboratory University of California 1978 - 1980 Leave of absence status 1975 - 1978 Associate Director of LBL, and Head, Energy & Environment Division I

1974 - 1975 Program Leader, LBL Environmental Research Program 1971 - 1974 Physicist, LBL Environmental Research Program 1967 - 1971 Post-Doctoral Physicist, LBL High-Energy,

Physics Program Other Professional Activities ~

q 1.

Member, Subpanel on Energy, U.S. Atomic Energy Comission High Energy n

Physics Advisory Panel (1974) 2.

Member, Reactor Safety Study Group American Physical Society (1974 - 1975) 3.

Member, Panel on Sources and Control Techniques. Environmental Research Assessment Comittee of the National Academy of Sciences

..i (1975 - 1977) 4.

Member, Reactor Hazards Comittee, University of California, Berkeley (1974 - 1978).

5.

Co-organizer (with T. H. Pigford). University of California Extension Course on " Environmental Impacts of Electricity Generation," week-long course given in 1974, 1975, 1976, 1977.

6.

Editor-in-Chief, " CRC Forums on Energy," CRC Press, West Palm Beach, Florida (1976 - Present).

l 7.

Member, Editorial Advisory Board " Electric Power Systems Research,"

journal published by Elsevier (1977 - Present).

t 8.

Member, Risk Assessment Review Group, U.S. Nuclear Regulatory Comission (1977 - 1978).

9.

Speaker, ENERGY-2020. Lecture Series, sponsored by National Science Foundation (1978)

\\

10. Member, Panel on Public Affairs, American Physical Society (1978 - 1981)

'=

Honors and Awards f

' Phi Beta Kappa, Yale University (1951)

L Sigma X1, Yale University (1961)

B.A. from Yale awarded Magna Cum Laude (1961)

Student Marshall, Yale Baccalaureate Procession (1961)

Varsity Letter, Track Team, Yale University (1961):

team won National Intercollegiate Indoor Championship National Science Foundation Graduate Fellowhip in Physics (1951 - 1963)

+

Conaressional Testinony 96th Congress, Hearing before Subcommittee on Environment, Energy, and Natural Resources of House Committee on Government Operations:

" Nuclear Regulatory Commission - The Rogovin Report",

February 13, 1980, p. 1-67 96th Congress, Hearing before Subcommittee on Energy and Power of the House Committee on Interstate and Foreign Commerce:

" Nuclear Regulatory Commission Authorization for Fiscal Year 1981",

February 22,.1980, p. 124-170 96th Congress, Hearing before Subcommittee on Nuclear Regulaticn of the Senate Committee on Environment and Public Works,

" Nuclear Regulatory Commission:

Fiscal Year 1981 Authorizations", March 24, 1980, p. 36-82 96th Congress, Hearing before Subcommittee on Energy Research and Production of the House Committee on Science and Technology,

" Nuclear Safety Research and Development Act. of 1980", June 19, 1980,

p. 43-63 96th Congress, Hearing before Subcommittee on Energy Research and Development of the Senate Committee on Energy and Natural Resources, "Neclear Safety Research and Development Act of 1980",
p. 15-29 I

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Publications

" Unsuccessful. Search for an Excited Electron", R.J. Budnitz, J.R. Dunning, M.Goitein, N.F. Ramsey, J.K. Walker, and Richard Wilson, Physical Review 141, 1313 (1955)

" Measurements of Elastic Electron-Proton Scattering at High Momentum Transfers by a Coincidence Technique",fi.Goitein, R.J.Budnitz, L. Carroll, J.Chen, J.R. Dunning, K. Hanson, D. Imrie, C. Mistretta, J.K. Walker, Richard Wilson, G.F. Dell, M. Fotino, J.11. Patterson, and H. Winick, Physical Review Letters 18, 1015 (1967)

" Quasi-Elastic Electron-Deuteron Scattering at Forward Angles", R.J. Budnitz, J. Appel, L. Carroll, J. Chen, J.R. Dunning, M. Goitein, K. Hanson, D.

Imrie, C. Mistretta, J.K. Walker, and Richard Wilson, Physical Review Letters 19_, 809 (1957)

" Neutron Form Factors from Quasi-Elastic Electron-Deuteron Scattering",

R.J. Budnitz, J. Appel, L. Carroll, J. Chen, J.R. Dunning, H. Goitein, e

D. Imrie, D. Mistretta, J.K. Walker, and Richard Wilson, K. Hanson, Physical Review 173, 1357 (1968)

" Search for the Electroproduction of the N'(1470) Resonance from Deuterium",

J. Alberi, J. Appel, R.J. Budnitz, J. Chen, J.R. Dunning, M. Goitein, K. Hanson, D. Imrie, C. Mistretta, and Richard Wilson, Physical Review 176, 1631 (1958) t

" Differential Cross-Sections for Neutral-Pion Electroproduction Near the First Pion-Nuciect Resonance", C. Mistretta, D. Imrie, J. Appel, R.J.

Budnitz, L. Carroll, J. Chen, J.R. Dunning,fi. Goitein, K. Hanson, A.

2_0, 1070 (1968) 0 Litke, and Richard Wilson, Physical Review Letters Angular Distributions for Pi-plus Electroproduction and the Pion Form Factor", C. fiistretta, D. Imrie, J. Appel, R.J. Budnitz, L. Carroll, M. Goitein, K. Haason, and Richard Wilson, Physical Review Letters 20,

~

1523 (1958)

" Coincidence Measurements of Single-Pion Electroproduction Near the l{I Delta (1236) Resonance", C. Mistrette, J. Appel, R.J. Budnitz, L. Carroll, I

J. Chen, J.R. Dunning, M.

Goitein, K. Hanson, D. Imrie, and Richard Wilson, Physical Review 184, 1487 (1969) t "Eleastic Electron-Proton Scattering Cross-Sections Measured by a Coinci-i dence Technique", M. Goitein, R.J. Budnitz, L. Carroll, J. Chen, J.R.

I

Dunning, K'. Hanson, D. Imrie, C. Mistretta, and Richard Wilson, Physical Review D, 1, 2449 (1970) i

Publications (continued)

" Survey of Instrumentation for Environmental Monitorina",

Report L5L-1, 1972. Environmental Instrumentation Group, Lawrence Berkeley Laboratory, Berkeley, California "A Charge Asymmetry Measurement System", R.M. Graven, J.H. Brewer,.

~

R.J. Budnitz, R.L. McCarthy, and D.H. Miller, Nuclear Instruments and Methods 102, 45 (1972)

"CP-Violating Charge Asymmetry in the Decay KU+vuv,"

R.L. McCarthy, J.H. Brewer, R.J. Budnitz, A.C. Entis, R.M. Graven, D.H. Miller, and W.H. Ross, Physics Letters 42B, 291 (1972)

O

" Charge Aspraetry in the Decay K +vuv ", R.L. McCarthy, J.H. Brewer, -

R.J. Budnitz, A.C. Entis, R.M. Graven, D.H. Miller, and W.N. Ross,

'~

Physical Review 7_,-687 (1973)

Tritium Instrumentation for Environmental and Occupational Monitoring -

A Review", R.J. Budnitz, Health Physics 26, 165 (1974)

[

" Radon-222 and Its Daughters - A Review of Instrumentation for Occupational and Environmental Monitoring",

R.J. Budnitz, Health Physics 26, 145 (1974)-

" Krypton-85: A Review of Instrumentation for Environmental Monitoring",

R.J. Budnitz, in Noble Gases. R.E. Stanley and A.A. Moghissi (editors),

U.S. Environmental Protection Agency, Las Vegas, Nevada (1975)

" Plutonium:

A Review of Measurement Techniques for Environmental Monitoring",

R.J. Budnitz, IEEE Transactions on Nuclear Science, NS-21(1), 430 (1974)

" Instrumentation for Environmental Monitoring in Biological Systems",

N.A. Amer, R.M. Graven, R.J. Budnitz, and D.A. Mack, IEEE Transactions on Nuclear Science, NS-22(1), 633 (1975)

" Report to the American Physical Society by the Study Group on Licht-Water Reactor Safety", H.W. Lewis, R.J. Budnitz, A.W. Castleman, D.E. Dorfan, F.C. Finlayson, R.L. Garwin, L.C. Hebel, S.M. Keeny, R.A. Muller, T.B.

Taylor, G.F. Smoot, and F. von Hippel, Reviews of Modern Physics 4_7_,

Supplement No. 1 (1975)

~

" Review of the American Phy'sical Society Light h'ater Reactor Safety Study",

R.J. Budnitz, JEEE Transactions on '!uclear Science NS-23f1), 25 (1976)

" Social and Environmental Costs of Energy Systems", R.J. Budnitz and J.P.

Holdren, in Annual Review of Enercy, J.M. Hollander (editor) Vol. _1, 553 (1976) i

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  • .O Publications (continued)

" Sources of Residuals and Techniques for Their Control:

Research and i

Development Needs",

Panel on Sources and Control Te'chniques, Environ-mental Research Assessment Cor.ittee, National Academy of Sciences (1977) a

" Risk Assessment Review Group Report to the U.S. Nuclear Regulatory Commission", H.W. Lewis, R.J. Budnitz, H.J.C. Kouts, W.B. Loewenstein, W.D. Rowe, F. von Hippel, and F. 7.achariasen, Report NUREG/CR-0400, O.S. Nuclear Regulatory Commission (1978)

" Human Disease from Radon Exposures:

The Impact of Energy Conservation in Residential Buildings", R.J. Budnitz, J.V. Berk, C.D. Hollowell, W.W.

Nazaroff, A.V. Nero, and A.H. Rosenfeld, Energy and Buildings 2, 209 (1979)

" Highlights of the NRC Licensing Process and the NRC R&D Program for Deep Geological Storage Facilities", R.J. Budnitz, IEEE Transactions on Nuclear Science, NS-27(4), 1258 (1980)

Three Mile Island: A ReDort to the NRC and to the Public, U.S. Nuclear Regulatory Commission Special Inquiry Group, in four volumes: Mitchell Rogovin, Director; R.J. Budnitz, Technical Coordinator; U.S. Nuclear Regulatory Commission (1980)

"How Reactor Safety is Assured in the United States" and "The Role of Risk Assessment in Reactor Safety", articles in Enerav for the Year 2000, Richard Wilson (editor), Plenum Press, New York (1981)

"The Response of the Nuclear Regulatory Commission to the Accident at Three Mile Island", article in The Three Mile Island Accident:

Lessons and Implications, T.H. Moss and D.L. Sills (editors), Annals of the New York Academy of Sciences, Vol. 365 (1981) b l

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