ML20210C670

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Affidavit of a Ghosh Re Contention Utah K & Confederated Tribes Contention B.* Affidavit Addresses Applicant Motion as Motion Relates to Issues Pertaining to Whether Credible Hazard to Proposed ISFSI Posed by Events or Conditions
ML20210C670
Person / Time
Site: 07200022
Issue date: 07/22/1999
From: Amitava Ghosh
AFFILIATION NOT ASSIGNED, CENTER FOR NUCLEAR WASTE REGULATORY ANALYSES
To:
Shared Package
ML20210C667 List:
References
ISFSI, NUDOCS 9907270006
Download: ML20210C670 (5)


Text

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July 22,1999 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAE In the Matter of

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PRIVATE FUEL STORAGE, LLC

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Docket No. 72-22-ISFSI

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(Independent Spent

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Fuel Storage Installation)

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AFTiDAVIT OF DR. AMITAVA GHOSH CONCERNING CONTENTION UTAH K AND CONFEDERATED TRIBES CONTENTION B I, Amitava Ghosh, having first been duly sworn, do hereby state as follows:

1.

My name is Amitava Ghosh. I am employed as a Principal Engineer at the Center for Nuclear Waste Regulatory Analyses (CNWRA), which is a division of the Southwest Research Institute (SwRI),in San Antonio, Texas. I am providing this affidavit under a technical assistance contract between the NRC Staff and the SwRI. A statement of my professional qualifications is attached hereto.

2.

This Affidavit is prepared in response to " Applicant's Motion for Partial Summary Disposition of Utah Contention K and Confederated Tribes Contention B"(Motion), filed on June 7, 1999 by Private Fuel Storage L.L.C. (Applicant or PFS), and the " Statement of Material Facts" attached thereto. In panicular, this Affidavit addresses the Applicant's Motion as it relates to issues pennining to whether a credible hazard to the Applicant's proposed Independent Spent Fuel Storage Installation (ISFSI)is posed by events or conditions at Dugway Proving Ground, the Tekoi Rocket Test Engine Facility, the Salt Lake City Intemational Airport, and the Utah Test and Training Range 7270006 990722 C

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-(UTTR), with the exception of military aircraft crashes. This Affidavit also addresses the Applicant's Motion as it relates to wildfires.

3.

As part of my official responsibilities, I have reviewed the adequacy of the 1

Applicant's analysis of design basis events, submitted with its application for an ISFSi license, the Applicant's responses to the Staff's Requests for Additional Information (R AIs), and the Applicant's June 30,1999 Responses to NRC Staff's questions pertaining to aircraft crashes and air-delivered ordnance at the PFSF. I am also involved in preparing the accident analysis section of the NRC Staff's Safety Evaluation Report (SER). In addition, I panicipated in preparing the "NRC Staff Position" on Contention Utah K/ Confederated Tribes B as set fonh in the "NRC Staff's Statement of Its Position Concerning Group I Contentions," dated June 15,1999. The NRC Staff Position accurately represents my views with respect to this combined contention.

4.

At the time that the NRC Staff Position was issued, the Staff's review of issues involving (a) commercial and military aircraft crashes, and (b) munitions testing at the U1TR, had j

not been completed. The Staff, therefore, could not state a position at that time with respect to those issues. Since then, the Staff has completed additional pcnions of its review and is able to take a l

i position regarding munitions testing at the UTTR and c ;mmercial aircraft crashes, as set fonh in I

paragraphs 5 and 6 below.

5.

Regarding munitions testing at the UTTR,I concl,ude that no significant hazard to the ISFSI exists, based on the following: 1) targets for air-delivered weapons, including cruise missiles at the UTTR area, are at least 25 miles from the ISFSI, and run-ins for the delivery of these weapons do not cross Skull Valley; 2) a safety review process is conducted prior to testing: 3) the UTTR has never experienced a weapon released outside a designated release area; and 4) Flight i

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l I l Termination Systems are used on all weapon systems having the capability of exceeding range l

boundaries, to prevent hazards outside of their intended target areas. Accordingly, it is my l

conclusion that munitions testing at the UTTR does not pose a credible hazard to the Applicant's l

proposed ISFSI.

6.

With respect to the credibility oraircraft crashes at the ISFSlinvolving aircraft taking off and landing at SLCIA and other nearby municipal airports do not pose a credible hazard to the -

l ISFSI because of distance involved, which is greater than 10 statute miles. Further, with respect to i

aircraft in transit to or from the Salt Lake City Intemational Airport (SLCIA) through Routes J-56 i

and V-257, I conclude, based on an evaluation conducted in accordance with NUREG-0800, that the i

4 probability of an aircraft crash occurring at the ISFSI site is well below 10 per year and is, i

therefore, acceptable. Accordingly, it is my conclusion that commercial aircraft crashes do not pose a credible hazard to the Applicant's proposed ISFSI.

7.

At this time, the Staff has not yet completed its review and is unable to take a position with respect to whether a credible hazard to the Applicant's proposed ISFSIis posed by military aircraft crashes. Therefore, no opinion is expressed herein regarding Statement of Material Facts TH C17, Cl8. D2, and DS-D10. In addition, no opinion is expressed herein regarding Statement of Material Fact 1C20, insofar as it relates to matters other than " hung bombs or other malfunctioning l

ordnance," and Statement of Material Fact C22.subpart 6, insofar as it relates to matters other than i

" hung bombs" and landings of the X-33 experimental aircraft.

I 8.

I have reviewed the Applicant's Motion and the attachments thereto,in which PFS seeks partial summary disposition of Contention Utah K and Confederated Tribes B. On the basis of my review of the Applicant's Safety Analysis Report, the Applicant's responses to the NRC l

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Staff's Requests for AdditionalInformation, and the documents attached to the Applicant's Motion,

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I do not dispute the Applicant's Statement of Material Facts - except that no position is expressed herein with respect to Statements of Material Fact involving military aircraft crashes (set fonh in paragraph 7 above), as to which the Staff's review has not been completed.

9.

Funber, for the reasons set fonh in the NRC Staff Fosition of June 15,1999, and in paragraphs 5 and 6 above,'I am satisfied that activities involving the Tekoi Rocket Test Engine l

Facility, Salt Lake City Intemational Airpon, munitions testing and other activities at the Utah Test and Training Range (except for military aircraft crashes), Dugway Proving Ground, Michael Army Airfield (involving aircraft with " hung bombs" and the X-33 experimental aircraft), and wildfires l

would not pose a credible hazard to the Applicant's proposed ISFSI. In sum,I am satisfied that none of the issues identified in Contention Utah K/ Confederated Tribes B present a credible hazard for i

the Applicant's proposed facility, except for military aircraft crashes as to which no opinion is expressed herein.

l 10.

I am familiar with the Affidavits of Fas21 Lain and Jack Guttmann pertaining to the issue of wildfires (attached hereto), and agree with the statements made in those Affidavits.

l 11.

I hereby certify that the foregoing is true and correct to the best of my knowledge, t

j information, and belief.

M Amitava Ghosh l

Subscribed and sworn to before me i

this 22nd day of July,1999.

D Notary Public[I' M"O I d

ornmission expires:

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JOHN W. Mete 0D '

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.o AMlTAVA GHOSH Principal Engineer Center for Nuclear Waste Regulatory Analyses Southwest Research Institute B. Tech., Mining Engineering, Indian Institute of Technology, Kharagpur, India; 1978 M.S., Mining Engineering, University of Arizona, Tucson, Arizona; 1983 Ph.D., Mining Engineering, University of Arizona, Tucson, Arizona; 1990 Dr. Ghosh has over 20 years of experience in conducting both academic and industrial research, consulting, and teaching in mining, geological, and geotechnical engineering with special emphasis on numerical simulations, field and laboratory experiments, rock mechanics and rock engineering, explosives and blasting, soil mechanics, rock fracture mechanics, and application of probabilistic methods, theory of fractal geometry, geostatistics, and artificial intelligence. Since joining the Center for Nuclear Waste Regulatory Analyses, he provide; technical support to the U.S. Nuclear Regulatory Commission on the design and experimental programs for site characterization of the proposed repository, spent fuel project, and reclamation of active mill tailings sites.

He was the principal investigator for modeling rock joint response under cyclic, pseudostatic, and earthquake loads, evaluating rock joint constitutive models and their implementation in UDEC code, selecting computer codes for simulating coupled thermal mechanical-hydrological processes at the proposed high-level nuclear repository site at Yucca Mountain, and lead a multi-disciplined team for developing the Centralized Interim i

Storage Facility Assessment Report. He has developed a part of the Standard Review Plan is relamation of active mill tailings sites under Title II of the Uranium Mill Tailings Radiation Control Act. to % part of the team developing a module for Total system Performance Assessment (TPA) code to assess the risk associated with waste package disruption from fault slippage at Yucca Mountain.

Dr. Ghosh worked as a postdoctoral research fellow at the University of Nevada, Reno. He quantified the utilization of explosive energy in blasting from the energy required to crush the blasted fragments. Dr. Ghosh was awarded the Rocha Medal in 1992 by the International Society for Rock Mechanics in a worldwide competition for his PhD research on the applicrtion of fractal geometry and numerical methods to examine fracture formation and propagation in rock udg explosives. A paper based on the application of fractal geomeny to quantify the effects of natural fractures on rock blasting won the Society of Mining Engineers Outstanding Student Paper contest in Graduate Division in 1989. He worked as a Technical Services Engineer at IDL Chemicals Ltd with emphasis on ground vibration and air blasts from blasting. Dr. Ghosh j

has taught several courses at the University of Arizona. He has published about 30 technical papers and 15 research reports. He has reviewed papers for severaljoumals and rock mechanics symposiums and chaired the session of Rock Fragmentation from Blasting at the 35th US Symposium on Rock Mechanics.

PROFESSIONAL CHRONOLOGY: Technical Services Eq;ineer, IDL Chemicals Ltd., 1978-1981; Graduate Assistant / Associate, University of Arizona, 1982-1990; Postdoctoral Fellow, University of Nevada, Reno,1990-1992; Research Engineer, Southwest Research Institute,1992-1994; Senior Research Engineer, Southwest Research Institute, 1994-1999; Principal Engineer,1999-Present.

MEMBERSHIPS: International Society for Rock Mechanics; American Rock Mechanics Association; Intemational Association for Mathematical Geology; American Geophysical Union; Society for Mining, Metallurgy, and Exploration, Inc.

Rev. July 1999