ML20195D751
| ML20195D751 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 06/07/1999 |
| From: | Johns J AFFILIATION NOT ASSIGNED, STONE & WEBSTER, INC. |
| To: | |
| Shared Package | |
| ML20195D715 | List: |
| References | |
| ISFSI, NUDOCS 9906100039 | |
| Download: ML20195D751 (8) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
Before the Atomic Safety and Licensing Board in the Matter of
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PRIVATE FUEL STORAGE L.L.C.
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Docket No. 72-22
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(Private Fuel Storage Facility)
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i DECLARATION OF JEFFREY JOHNS i
JefTrey Johns states as follows under penalties of perjury:
1.
I am a Licensing Engineer for Stone & Webster Engineering Corp. I am providing this declaration in support of a motion for partial summary disposition of Contention Utah K in the above captioned proceeding to show that smoke from a distant fire or explosion, including smoke from the Tekoi Rocket Engine Test Facility, would pose no significant hazard to the Private Fuel Storage Facility (PFSF).
2.
My professional and educational experience is summarized in the curriculum vitae attached as Exhibit I to this declaration. I have 21 years of experience in the nuclear power industry and nine years of experience with the licensing of independent spent fuel storage installations (ISFSis). I have experience in performing accident analyses for nuclear power plants and ISFSIs and in preparing ISFSI emergency plans. For the PFS project I am responsible for the preparation of the PFS Safety
' Analysis Report, including accident analysis and radiation protection for the spent fuel cask systems to be used at the PFSF. As part of my responsibilities I have performed estimates of the dispersion of plumes of radioactive material in air after a release.
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3.
I am knowledgeable of the design and operation of the PFSF and the spent I
' fuel casks that will be used there. I am knowledgeable of the means of projecting the I
propagation of smoke plumes through the atmosphere under different environmental conditions and I am knowledgeable of the effect of such propagation on the size and density of the plumes. I am also familiar with the relative locations of the PFSF and the Tekoi test facility.
4.
In its response to Private Fuel Storage L.L.C.'s (PFS) first discovery request, the State of Utah alleged that the function of the PFSF could be impaired by a smoke plume potentially created by a fire or explosion at the Tekoi Rocket Engine Test Facility. The State had alleged in Utah K that PFS had inadequately considered the impact on the PFSF of credible accidents at other facilities in the region, including potential rocket motor explosions at Tekoi.
5.
The Tekoi test facility is owned by Alliant Techsystems, Inc. and is located on the Skull Valley Band of Goshute Indian Reservation. Tekoi encompasses l
two operational areas: a high hazard explosive test area and a static test range. The static 1
test range includes three test bays. The PFSF is located over two miles from the Tekoi 1
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. test facility. Spec f ca ly, t e c osest part o t e PFSF Restricted Area,in which the spent ii l h l fh l,
fuel casks and all systems important to safety at the PFSF will be located, is 2.3 miles (12,100 ft.) north by northwest of the Tekoi test bay in which the largest rocket motors are tested. That bay is the location closest to the PFSF at which explosives or rocket motors are tested at Tekoi.
I 6.
Because of the 6,tance between the PFSF and Tekoi, smoke released from testing rocket motors or f:Om rocket motor detonations at Tekoi would not pose a significant hazard to the PFSF. The Environmental Impact Analysis performed for Tekoi indicated that a rocket motor would burn for approximately 70 seconds during a test and l
would emit "a cloud of non-toxic smoke and dust." Bureau ofIndian Affairs, Uintah and i
Ouray Agency, Environmental Im act Analysis, Rocket Motor Test Site, Skull Valley Band of Goshute Indians, Skull Valley Reservation (Mar. 28,1975), at 4. It stated 2
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' further, however, that "there will be no effect on... air quality with an accidental
- detonation" and that " essentially the same air pollutants and quantities will be released during an accidental detonation, compared to routine operating conditions, [thus] the efrects will be basically the same." Id. at 10. Thus, even at the Tekoi site, smoke and dust emissions associated with a rocket test or detonation' would not be significant.
7.
Furthermore, any smoke plume from Tekoi would be greatly diluted by the time it reaches the PFSF Restiicted Area,2.3 miles away. Calculations indicate that the density of smoke or concentration of particulates in air would be over 150 times lower at a range of 2 miles from the bum site than at a range of 150 meters from the burn site. PFS performed the calculations comparing x/Q plume dispersion factors for a' range of 150 meters from the point of origin to dispersion factors for a range of 2 miles (3,219 L
meters) from the point of origin, with the dispersion factors calculated in accordance with '
L NRC Regulatory Guide 1.145, " Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants," (Revision 1, Nov.1982). PFS -
conservatively assumed atmospheric conditions most conducive to maintaining a concentrated smoke plume at a distance from the bum site: atmospheric stability class F, j
wind speed of 1.0 meter /sec and no plume meander. Furthermore, the dilution between j
the Tekoi test facility and the PFSF would be significantly greater than that calculated due to the greater distance from Tekoi to the PFSF (2.3 miles vs. 2 miles) and the intervening Hickman Knolls, which would cause greater dispersion of the smoke in air traveling from Tekoi toward PFSF. Based on these calculations, smoke density at the PFSF from rocket motor testing or testing accidents at the Tekoi test facility would be negligible.
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I declare under penalty of perjury that the foregoing is true and correct.
Executed on June _,1999.
Jeffrey Johns i
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l JOHNS - -
i EXHIBIT 1 1
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e JEFFREY R. JOHNS Licensing Engineer i
EXPERIENCE
SUMMARY
Mr. Johns has 21 years of experience in the nuclear power industry, including 4 years as an officer in the U.S. Naval Nuclear Power Program and 17 years in nuclear licensing-engineering at Public Service Company of Colorado's (PSCo) Fort St. Vrain (FSV) nuclear power plant and ISFSI. He has been actively involved with ISFSI licensing work since plans were first formulated to license and construct the FSV ISFSI in 1990. Mr. Johns joined Stone & Webster recently as a permanent employee to assist in the licensing effort for the Private Fuel Storage Facility ISFSt.
j Mr. Johns was Supervisor of PSCo Nuclear Licensing from 1981 to 1991. He was responsible for the performance of 10 CFR Part 50.59 safety evaluations, for maintaining the FSV plant SAR up-to-date to reflect plant modifications and the current safety basis, and preparing amendments to the facility technical specifications. He was instrumental in helping PSCo comply with major regulatory changes, such as those stemming from the accident at Three Mile Island and the environmental qualification and fire protection rules. Mr. Johns developed acceptance criteria specific to FSV and interfaced with the NRC to obtain their approval.
He was responsible for directing the reactor vendor in accident analyses, which were necessary to license major modifications and determine compliance with new regulations. Mr. Johns received a $1,000 award for providing the analytical basis for the FSV plant symptom-oriented emergency operating procedures. He assisted in accident analyses for the ISFSI, was responsible for determining event classification of accidents assessed in the ISFSI SAR, and helped to prepare ISFSI emergency procedures.
Mr. Johns was PSCo's lead in developing the FSV decommissioning accident analyses and preparing major portions of the decommissioning plan (licensing basis for decommissioning). He chaired the Hazards Analysis Review of Decommissioning Committee, consisting of personnel with expertise in the areas of construction, nuclear safety, health physics and industrial safety.
Mr. John:, served on the team appointed to revise station procedures to make the FSV ISFSI a
" stand-alone" facility, in preparation for termination of the Part 50 license.
RELEVANTPROJECTEXPERIENCE Private Fuel Storage Facility, Private Fuel Storage, LLC - As Licensing Engineer, responsible for the preparation of the Safety Analysis Report (SAR), including accident analysis and radiation protection involving both of the selected storage system vendors.
Fort St. Vrain ISFSI, Public Service Company of Colorado - The FSV ISFSI is a Foster-Wheeler storage vault system. Mr. Johns assisted in licensing the FSV ISFSI under 10 CFR Part
- 72. He interfaced with the NRC on the ISFSI accident analysis, specifically resolving a licensing issue related to the source term and consequences of the ISFSI Maximum Credible Accident, postulated breach of a fuel storage container.
He was responslble for ISFSI SAR updates to maintain the ISFSI licensing basis up-to-date. He substantially revised the SAR to incorporate results of new analyses for reduced decay heat removal, following the occurrence of a natural convection cooling flow path blockage event in 1992 that exceeded the design basis.
He was also responsible for the performance of safety evaluations (per 10 CFR Part 72.48) on ISFSI design modifications, and prepared a safety evaluation conceming modifications which make the ISFSI cask load / unload port compatible with new spent fuel shipping casks. Mr. Johns
had the lead role in licensing the new spent fuel shipping casks, designed by Transnuclear Inc., to transport loaded fuel storage containers from the ISFSI without the need for transfer of fuel elements into a special cask liner.
He developed two amendment packages to the FSV iSFSI license. The first permitted installation of pipelines in the vicinity of the ISFSI that supply natural gas at high pressures to the combustion turbines used to repower the FSV plant. Mr. Johns directed analyses to determine natural gas plume dispersion under various meteorological conditions, pressures at the ISFSI resulting from postulated detonation of the natural gas cloud, and structural effects on the ISFSI. The second amendment permitted storage of low-level radioactive waste and radioactive sources for instrument calibration at the ISFSI. Mr. Johns prepared the safety analyses for both amendment packages. The safety analyses were reviewed and accepted by the NRC and their contractor without questions, and the NRC issued the license amendments.
l Mr. Johns provided assistance to the FSV Emergency Planning Coordinator with ISFSI emergency procedures, event classification, and in creating realistic drill scenarios for the annual examinations of emergency preparedness, observed by the NRC.
EDUCATION B.S., Biological Science - Stanford University LICENSES AND REGISTRATIONS Professional Engineer-Colorado 9
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