ML20112B035

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Affidavit of DE Wolfe Re Adequacy of Operating Basis Wind for Facility in Light of Historical Data on Wind Speeds
ML20112B035
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 03/07/1985
From: Wolfe D
WOLFE, D.E.
To:
Shared Package
ML20112B019 List:
References
OL, NUDOCS 8503180572
Download: ML20112B035 (17)


Text

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'65 XO is m1 :15 EXHIBIT 1

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C0CAEm. ; A HRV!CF UNITED STATES OF AMERICA M ANC" NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) .

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HOUSTON LIGHTING & POWER ) Docket Nos. 50-498 OL COMPANY, ET AL. ) 50-499 OL

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(South Texas Project, )

Units 1 and 2) )

AFFIDAVIT OF DALE E. WOLFE

1. My name is Dale E. Wolfe, My business address is 11309 Windermere Meadows, Austin, Texas 78759. A statement of my background and qualifications is provided as Attachment I to this Affidavit.
2. The purpose of this Affidavit is to address the adequacy of the operating basis wind (OBW) for the South Texas Project (STP) in light of the historical data on wind speeds in the Texas Gulf coast region. In preparing this Affidavit, I have directed and reviewed the confirmatory analyses described herein.

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3. Before addressing the STP OBW, it is important to clarifj terminology and methods of measurement and analysis. The i "OBW" is defined as the " fastest-mile of wind" expected to occur
with a frequency of once in 100 years (NRC Standard Review Plan (SRP) S 2.3.1). ,
4. A " fastest-mile of wind" is defined as the greatest average wind speed associated with the passage of one linear mile of air past a measurement point (Reference 1 at A10-3). Thus, for example, one linear mile of air passing a j measurement point in 60 seconds represents a fastest-mile wind speed of 60 mph. One linear mile of air passing.a measurement point in 30 seconds represents a fastest-mile wind speed of 120 mph. The fastest-mile wind speed is commonly measured, recorded f

hourly and reported daily at major National Weather Service (NWS) stations. It represents a sustained wind rather than an instantaneous gust.

5. " Gusts" are rapid fluctuations in wind speed with l,  ;

l a variation of at least 10 knots (12 mph);between peaks and lulls 1

(Reference 1 at A10-3). The duration of a gust from lull to peak i to lull is generally considered to be no greater than 20 seconds (Reference 2 at 266).

The reported value for a gust is the

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absolute-maximum wind speed, which may be of very short duration, i

l often only lasting one or two seconds, that occurs during the last 10 minutes immediately preceding the observation time.

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6. In addition to the fastest-mile wind and gusts,

" peak Vinds" represent the maximum wind speed observed during an hour of observation time. The peak wind may be a. gust or, if wind fluctuations are not of sufficient magnitude to meet the definition of gusts, the peak wind may simply be the greatest instantaneous value of wind speed observed.

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7. The STP OBW has been determined to be 125 mph at a standard reference height of 30 feet. FSAR at 3.3-1. Current,
NRC guidance for determining the OBW for nuclear power plants i

(including the selection of historical tropical (hurricane) and extra-tropical (non-hurricane) wind data) is contained in SRP section 2.3.1 (Rev. 2 - July 1981). SRP section 2.3.1 (Rev. 2 -

July 1981) calls for the determination of a "100-year return period ' fastest mile of wind'" and provides that "[d]ata on i severe weather phenomena should be based on standard

. meteorological records from nearby representative National Weather Service (NWS), military or other stations recognized as j standard installations which have long periods of record."

8. As indicated above, the OBW for a nuclear power I plant is based upon fastest-mile wind speed data. Fastest-mile wind speeds are the only high wind speed values observed, l j recorded [ and reported in a consistent manner such that recur-rence statistics can be meaningfully determined. Thus, gust and instantaneous wind speed data are not utilized. It should be i

noted, however, that wind loading design criteria include allowadces for gusts and instantaneous winds as a conservative design factor in order to account for the additional loads which may result from shorter duration wind speeds in excess of the fastest-mile wind speed. See Affidavit of R. Bruce Linderman (Linderman) at 1 12.

l 9. In order to determine the 100-year recurrence fastest-mile wind speed for a given location, it is necessary (o 1 apply the relevant historical data to a statistical model. While i

a number of statistical models may be utilized, the method most appropriate for the Texas Gulf coast is presented in Reference 3 at 8-10. That model, which was prepared by M. J. Changery of the National Climatic Center, National Oceanic and Atmospheric 3

Administration, for use by the NRC, is based upon the most recent general study of high winds and specifically addresses the winds associated with hurricanes.

10. The model presented in Reference 3 combines a probability function which best estimates; extra-tropical (non-hurricane) high winds with one which best estimates tropical (hurricane) high winds. Since the OBW takes into account both, the combination of these two distributions provides the most appropriate mechanism for determining 100-year recurrence j

l fastest-mile wind speeds.

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11. Two confirmatory analyses utilizing this methodology were performed in 1983 and reported in Amendment 38 to the FSAR filed on April 30, 1984. The first employed available data for the period 1872 through 1982 from each of four Texas near coastal NWS stations - Port Arthur (30 years),
Galveston (111 years), Corpus Christi (41 years), and Brownsville (40 years). These stations were selected because they provide the longest record of representative and reliable data for near 4 coastal stations in the region. See FSAR at 2.3-4. Unlike the original FSAR analysis, data from Victoria were not utilized i since hurricane wind speeds typically decrease as storms move 1

l inland, and Victoria is approximately 45 miles from the coast.

The second confirmatory analysis was performed on a composite data set consisting of the highest annual fastest-mile' wind speed from any of the four stations each year from 1953 through I 1982. */ ,

See FSAR at 2.3-4a. Since only the highest fastest-

! mile wind speeds from each station were utilized in the composite l analysis, a more conservative result was obtained than by i calculating individual values for each station.

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12. Consistent with the guidance in section 2.3.1 of j the SRP and the methodology utilized in prior authoritative j analyses (References 3, 4 and 5), data that were not from a j .
  • / 1953 was the first year that data were available from all

! four stations. In order to weight each station equally in the composite analysis, earlier data was not utilized.

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standard (NWS caliber) observation station with a long period of record'-were generally not included in the analyses. */ See FSAR at 2.3-4a.

13. The analyses utilizing data for the four stations individually resulted in a 100-year recurrence fastest-mile wind speed of 116 mph at a standard reference height of 10 meters.

This value was calculated for Corpus Christi. Values at the other stations were lower. The composite analysis yielded a ,

100-year recurrence fastest-mile wind speed of 118 mph. **/ See FSAR at 2.3-4a. Furthermore, application of another appropriate method for calculating the STP OBW resulted in a 100-year recurrence fastest-mile wind speed which was equal to that

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  • / Data from locations such as Matagorda and Port Lavaca (which are not NWS stations) were not utilized in any of the analyses because the measurement instruments and recording systems could not be verified as reliable and calibrated, and because the quality of observer training could not be verified. Because Reference 4 did utilize a few " estimated" fastest-mile wind speeds which were obtained at NWS stations by trained weather observers, such data have been' included in the STP analysis. See PSAR at 2.3-4a to 4b.
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Although the original FSAR analysis has based upon a 30 foot standard reference height, a 10 meter value was used for these analyses because that value has become, in recent l years, the recognized world-wide standard height for measurement of surface winds. In any event, fastest-mile wind speed calculations based upon a reference height of 10 meters will slightly overestimate wind speeds at 30 feet, since wind velocity generally increases with height within a few-hundred meters of the earth's surface. Thus, the results of the more recent analyses are conservative and would be slightly lower if adjusted to a reference height of 30 feet. Consideration of wind speed fluctuations with height in the STP design is addressed in Mr. Linderman's Affidavit at T 12.

originally determined for the STP. See FSAR at 2.3-3. Thus, the existing OBW for the STP of 125 mph at 30 feet is a conservative ,

value which is supported by the most recent data and current
analytical methods. ,

! 14. It is also important to understand the various references to wind speeds in excess of the 125 mph OBW which have been cited by the parties and the Atomic Safety and Licensing Board. As described above, section 2.3.1 of the SRP states that l "[d]ata on severe weather phenomena should be based on standard I meteorological records from nearby representative National 4

) Weather Service (NWS), military or other stations recognized as l standard installations which have long periods on record." In order to reliably calculate a fastest-mile wind speed value, data

, possessing appropriate indicia of reliability must be utilized.

Other data, such as gust values, wind speed references from non-authoritative documents, or wind speed values measured at unknown anemometer heights, cannot provide a reliable or consistent basis

! for calculation. The wind speed accounts in excess of 125 mph I  ;

cited by the parties and the Board do noti however, meet these basic criteria for inclusion in the data base used to determine the STP OBW. */

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  • / One value in excess of 125 mph cited in the FSAR and by the NRC Staff was appropriate for such usage and was, therefore, included in the data base for the STP confirmatory analyses, i See T 19, infra.

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l The FSAR reports "[i]nstantaneous wind gusts

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estimated at 175 mph" at Port Lavaca and "160 mph at Matagorda."

FSAR at 2.3-6a. Since such data represent estimates of non-fastest-mile wind speeds they are not appropriate for calculating the STP OBW.

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16. Similarly, the data cited by the intervenors are inappropriate for use in calculating the STP OBW. In CCANP's l Response to Applicants' Motion to Compel Answers to Its Seventh ~

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! Set of Interrogatories and requests for Production of Documents i

i to CCANP (May 31, 1983) at 7-8, it cites the following wind I

j speeds which are inappropriate for use in calculating the STP OBW for the following reasons:

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l 1. 121 mph -location unrepresentative of STP site; observation height unknown; quality of observer training and equipment indeterminate.

155 mph -non-fastest-mile wind speed; location unrepresentative of i

STP siter observation height j unknown; quality of observer training and equipment l indeterminate.

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! 2. 135 mph -estimated value; observation

! height unknown; quality of 4

observer training and j equipment indeterminate.

3. 145 mph -estimated values observation i
  • height unknown; quality of j .

observer training and equip-l ment indeterminate.

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_9-i l 153 mph -non-fastest-mile wind speed; observation height unknown; l quality of observer training and equipment indeterminate.

175 mph -estimated value; observation height unknown; quality of observer training and equipment indeterminate.

4. 135 mph -estimated value; observation height unknown; quality of observer training and equipment indeterminate.

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5. 136 mph -observation height unknown; quality of observer training and equipment indeterminate.'
6. 100 mph -estimated valuer location i unrepresentative of distant i from STP site; observation i height unknown; quality of i

observer training and equipment indeterminate.

150-175 mph -non-fastest-mile wind speed; location unrepresentative of STP siter observation height unknown; quality of observer training and equipment j indeterminate.
190 mph ' estimated valuer location 1 unrepresentative of STP site; observation height unknown; 4

quality of observer training i and equipment indeterminate.

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7. 130 mph -observation height unknown; quality of observer training j and equipment indeterminate.

161 mph -non-fastest-mile wind speed; 1

observation height unknown;

. quality of observer training

- and equipment. indeterminate.

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160-180 mph -non-fastest-mile wind speed.

. 8. 186 mph -observation height unknown; a

quality of observer training

), and equipment indeterminate.

l l 9. 140-145 mph -non-fastest-mile wind speed; i observation height unknown.

17. In CCANP's Supplemental Answers to Applicants' Seventh Set of Interrogatories and Requests for Production of Documents (June 14, 1983) at 1, it cites the following wind I speeds which are inappropriate for the following reasons:

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l 1. 170 mph -observation height unknown; 4

quality of observer training

. and equipment indeterminate.

2. 183 mph -observation height unknown; quality of observer training and equipment indeterminate.

j 18. In CEU's Petition for Leave to Intervene (February 23, 1979) at V.(1) and its Answer to Interrogatories in Compliance with Board Order Ruling on Motions to Compel ( April 23, 1980) at 12, it cites the following wind speeds which are

! inappropriate for the following reasons:

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1. 170 mph -non-fastest mile wind speed; (Port Lavaca) estimated value; observation

, height unknown; quality of l observer training and equipment indeterminate.

2. 75 mph to 150 mph -observation height unknown; i (Texas-Louisiana quality of observer training border) and equipment indeterminate.
3. 150 mph to 175 mph -observation height unknown; (Matagorda area) quality of observer training and equipment indeterminate.

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4. 175 mph -observation height unknown; (Port Lavaca) quality of observer training

. and equipment indeterminate

19. Furthermore, intervenors' references to fastest-mile wind speeds well in excess of 125 mph are inconsistent with authoritative source material such as References 3, 4, 5 and 6.

In fact, the highest fastest-mile wind speed based upon recorded data which was documented by any of these authoritative sources for the Texas Gulf coast is 128 mph (at 10 meters) at Corpus Christi during hurricane Celia */ (Reference 3 at 132; Reference 4 at 266).

20. Similarly, the various wind speeds cited by the NRC Staff are either consistent with the STP OBW or inappropriate for use in calculating the OBW. **/

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21. The Board has cited wind speeds associated with hurricane Allen " reportedly as high as 180 mph." Memorandum and Order (October 15, 1982) at 14. Although similar wind speeds were estimated offshore, recorded NWS mainland wind speed gust measurements for hurricane Allen do not exceed 92 mph (Reference  !
7) and the cited wind speed value is not $ppropriate for use in OBW calculation.

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  • / Official NWS records document a 120 mph value at 23 feet for hurricane Cella. That value has been extrapolated to a value of 125 mph at 30 feet and 128 mph at 10 meters and ,

utiiized in the STP confirmatory analyses. See FSAR Table l 2.3-42.

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NRC Staff Response to the State of Texas' First Set of

, Interrogatories and Request for Production to NRC~ Staff on i

Contention 4 (October 18, 1983) at 5-23.

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22. Finally, according to one of the most comprehen-sive scientific wind speed studies available for an individual hurricane, the highest fastest-mile wind speed at 10 meters for the most recent hurricane to affect the Texas Gulf coast, hurricane Alicia (August, 1983), was 100 mph at Baytown, Texas.

(Reference 8 at 31).

CONCLUSION

23. Thus, while data exist showing wind speeds in ,

I excess of 125 mph, such data are inappropriate for use in calculating recurrent fastest-mile wind speeds for the STP site.

Application of reliable fastest-mile wind speed data to the most current statistical methods fully supports the 125 mph OBW for the STP. Utilization of the 125 mph OBW value in the design of the STP is the subject of the Affidavit submitted by R. Bruce Linderman.

REFERENCES h

1. Federal Meteorological Handbook No. 1, National Oceanic and Atmospheric Administration (1976).
2. Huschke, R.E., " Glossary of Meteorology," American Meteorological Society (1959) .

3.' Changery, M.J., " Historical Extreme Winds for the United States -- Atlantic and Gulf of Mexico Coastlines,"

NUREG/CR-2639, (1982).

4. Simiu, E., Changery, M.J., Filliben, J.J.,

"Extrese Wind Speeds at 129 Stations in the contiguous United States," NBS Building Sc"lence Series 118 (March 1979).

5. Thom, H.C.S., "New Distribution of Extreme Winds in the United States," ASCE Environmental Engineering Conference, Dallas, Texas ( February, 1967). ,
6. ANSI A58.1, Building Code Requirements for Minimum Design Loads in Buildings and Other Structures (1972).
7. Coleman, R. I. , Memorandum for the Record, National Oceanic and Atmospheric Administration (August 12, 1980).
8. Marshall, R.D., " Fastest-Mile Wind Speeds in Hurricane Alicia," NBS Technical Note 1197 (June, 1984).

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State of' N County:of Now3 ,

I, Dale E. Wolfe, of lawful age, being first duly sworn, upon my oath certify that I have reviewed and am a thoroughly familiar with the statements contained in this Affidavit and that all statements contained herein are true and correct to the best of my knowledge and belief.

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Subscribed and sworn to before me this day of hCAll i , 1985.

0Ankkh /) Po3%

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2 WOLFE AFFIDAVIT

] ATTACBMENT I

! DALE E. WOLFE 1

EDUCATION i Pennsylvania State University, B.S. , Meteorology,1964 j Massachusetts Institute of Technology, graduate courses in waste

heat removal, 1972
EXPERIENCE j Private Consultant, 1984-present '

! TRACOR, Aerospace, 1984-present l NUS Corporation, 1981-1984 1 Radian Corporation, 1979-1981 l Tennessee Valley Authority, 1976-1979 j Woodward-Clyde Consultants, 1972-1976 U.S. Air Force, 1962-1972 CURRENTLY - Consulting both individually and in cooperation with

. several consulting companies (including a continuing relationship

{ with NUS Corporation as an Associate Consultant) as well as serving as Manager, Applied Systems Marketing for TRACOR, Aerospace, Inc. Consulting activities include a broad spectrum l of business and technical services in atmospheric science i applications for utility, industrial, and government clients.

! Recent activities have involved environmental monitoring, j computer software applications, severe weather probabilistic l analyses, and air quality climatological studies.

! NUS - As assistant general manager for Air Sciences Programs,

! Mr. Wolfe had overall responsibility for programs in meteorology,

air quality, environmental noise, and environmental monitoring.

i These activities encompassed a wide range;of professional and j technical services in support of a variety of utility,

industrial, and government clients. Direct-involvement in the I

management and coordination of the development of the NUS l computerized real-time emergency assessment system for nuclear and nonnuclear hazardous accidents.

. RADIAN _As department head, Air Quality Analysis, and senior

, staff sc4entist, Mr. Wolfe was responsible for technical direction of a. variety of air quality assessment projects, i

including Prevention of Significant. Deterioration (PSD) permit preparation for such industrial projects as pipeline compressor stations, natural gas treatment facilities, refineries, chemical l plants, coal-fired industrial boilers, and coal gasification and i

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liquefaction plants. These efforts included best available control technology analyses, emissions inventories, air quality modeling, analyses of impacts of induced growth, and impacts on visibility, soils, and vegetation. Conducted air quality impact analyses (including visibility impacts) for two coal-fired power plants in southern Nevada and southwestern Utah, a region of extremely complex terrain and sparse meteorological and air quality data sources; an optimum stack height evaluation to avoid building downwash problems at a chemical reprocessing facility near Houston, Texas; a permitting feasibility study for a cement plant / limestone quarry complex near San Antonio, Texas; and site selection studies and permitting feasibility analyses for three coal gasification plants and a PVC/VCM plant. Also responsible for the conceptual design of systems and services relating to nuclear power plant emergency response requirements and to accidental airborne releases of hazardous materials; and for an emissions inventory data base management system.

' TENNESSEE VALLEY AUTHORITY - Direct technical responsibilities' included meteorology / air quality activities to support the licensing and operation of TVA's seven nuclear power plants, and  :

site selection and permitting for future coal-fired baseload power plants, energy cogeneration complexes, and such new energy technology demonstration projects as an atmospheric fluidized bed combustion plant. The nuclear projects involved specification of meteorological monitoring system requirements; preparation of meteorological portions of safety analysis reports, environmental reports, technical specifications, and radiological emergency plans; and preparation and presentation of testimony for environmental and safety hearings. Was particularly concerned with meteorological considerations in effective decision making during radiological emergencies. Developed plans and specifications for a system to provide the optimum man-machine mix to obtain real-time, site-specific meteorological forecasts and dispersion and trajectory analyses during radiological emergencies and drills. Involvement in TVA's site selection and permitting activities included determining the generation capacity of each candidate site allowable under air quality and regulatory contraints; design of meteorological / air quality monitoring networks, coordination of monitoring activities, and preparation of air quality impact analyses that were required for construction permit applications under air quality nonattainment PSD regulations.

WOODWARD-CLYDE - Technical responsibilities included a wide variety of environmental consulting projects for industrial clients nationwide. Though primarily concerned with analytical and field measurement programs in meteorology, air quality, and noise, also assigned interdisciplinary project management responsibilities for such projects as environmental monitoring i

(air quality, surface water and groundwater quality, noise, terrestrial and aquatic ecology) during the construction of the Grand Gulf Nuclear Plant; and the complete environmental analysis

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  • of a proposed open-pit copper mine/ mill complex, including a

! company town, in Arizona. Representative meteorological / air quality. projects included the preconstruction licensing of the Grand Gulf Nuclear Plant, which involved meteorological monitoring system design and operation, dispersion modeling, and preparation of .the meteorological portions of the preliminary safety analysis report and the environmental report; air quality impact' analyses for synthetic natural gas refineries in Alabama,

, Louisiana, Texas, Pennsylvania, and New Jersey; air quality and i noise impact analyses for natural gas compressor stations and pipeline construction projects in Alabama, Louisiana, Texas, and the'Far West; and air quality impact analyses and i

meteorological / air quality monitoring at a coal gasification facility site in North Dakota.

U.S. AIR FORCE - Prepared forecasts for airfields, target areas, and aircraft missions over North America, the North Atlantic Ocean, Europe, the Gulf of Mexico, and Caribbean Sea. As a member of the " Hurricane Hunters," was responsible for technical direction of worldwide weather reconnaissance missions, including hurricane, tactical, synoptic, radiological sampling, and weather i modification. Final assignment's responsibilities included

. weather support planning for wartime operations and field training exercises of all U.S. tactical air and ground forces in the Western Hemisphere. Identified requirements for weather i observing, forecasting, and reconnaissance capabilities;

developed manpower and equipment force packages; identified l

' operating locations and sources of personnel and equipment; and coordinated transportation, logistics, and communications

requirements.

I BONORS

Air Medal, for hurricane reconnaissance i Air Force Commendation Medal, for technical improvements in i reconnaissance procedures i Air Force Commendation Medal, for improving cost effectiveness of l tactical weather communications systems and for development of j new equipment and procedures for meteorological support to
tactical military operations 1 i

! MEMBERSHIPS i

Air Pollution Control Association j American Meteorological Society l PUBLICATIONS i  :

! Several in the areas of industrial meteorology and air quality; i meteorology / air quality portions of over 50 environmental i reports; 4 military operations and training manuals, and numerous l other technical reports.

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