ML20211G903
| ML20211G903 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 08/26/1999 |
| From: | Gaukler P AFFILIATION NOT ASSIGNED, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | UTAH, STATE OF |
| References | |
| CON-#399-20771 97-732-02-ISFSI, ISFSI, NUDOCS 9909010048 | |
| Download: ML20211G903 (12) | |
Text
L ' 8 o 17/
l REl.ATED CORRESPONDENCE O
00CHETED USNRC August 26,1999 4
'99 AUG 30 A8:13 UNITED STATES OF AMERICA i
OFFi -
NUCLEAR REGULATORY COMMISSION R'Jo ADJJ
.F 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 j
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(Private Fuel Storage Facility)
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ASLBP No. 97-732-02-ISFSI APPLICANT'S SECOND SUPPLEMENTAL RESPONSE TO STATE'S FIRST REQUESTS FOR DISCOVERY Applicant Private Fuel Storage L.L.C. (" Applicant" or "PFS") files this Supplemental Response to " State of Utah's First Set of Discovery Requests Directed to i
the Applicant (" State's First Discovery Requests"). The Applicant files this Supplemental Response pursuant to 10 C.F.R. Q 2.740(e), to name additional witnesses it expects to call at hearing. The Applicant's original response to the State's First Discovery Requests noted that it would file such supplemental responses as it identified additional witnesses.'
' Applicant's Objections and Non-Proprietary Responses to State's First Requests for Discovery, dated April 21,1999, at 17.
9909010048 990026 PDR ADOCK 07200022 C
PDR 3503
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L' GENERAL DISCOVERY REQUESTS A.
GENERAL INTERROGATORIES Pursuant to agreement between the State and PFS, these general interrogatories apply to all Utah admitted contentions, are in addition to the ten interrogatories per contention allowed b,r the Board's Order dated April 22,1998 (LBP-98-7), and are continuing in accordance with 10 CFR 2.740(e).
GENERAL INTERROGATORY NO. 3. For each admitted Utah contention, j
give the name, address, profession, employer, area of professional expertise, and
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educational and scientific experience ofeach person whom PFS expects to call as a witness at the hearing. For purposes of answering this interrogatory, the educational and scientific experience of expected witnesses may be provided by a resume of the person attached to the response.
APPLICANT'S RESPONSE: The Applicant supplements its response to the State's First Discovery Requests by identifying the following additional persons whom the Applicant expects to call as witnesses at the hearing with respect to the State's l
admitted contentions, l
Utah K-Credible Accidents Name and Address:
Wayne O. Jefferson Profession:
Consultant, Retired Air Force Major General Employer:
Burdeshaw Associates, Ltd.
Professional Expertise:
U.S. Air Force senior executive, military aircraft operations and quantitative probabilistic analysis j
Educational, Scientific Experience, and Professional Qualifications:
See Attached Resume Publications in the last ten years:
None Testifying experience in last j
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s four years:
None Subiect matter of testimonv:
Hazards posed to the PFSF by military aircran operations and weapons testing activities on the Utah Test and Training Range and Dugway Proving Ground and by nearby commercial and general aviation, including probabilistic calculations of potential aircran hazards to the PFSF.
Documents reviewed and/or relied upon:
The documents reviewed and relied upon by General Jefferson include the PFSF SAR and Responses to NRC dated June 30,1999,"Aircran Crashes, Air-Delivered Ordnance at the PFSF" and Responses to NRC dated August 13,1999,
" Potential AircraA Crashes at the PFSF," including references therein and attachments thereto, and documents previously identified as being reviewed and relied upon by General Cole. In addition, General Jefferson may review and rely upon documents produced by the State as well as any new information that may come into PFS's possession.
Name and Address:
Jeffrey R. Johns Stone & Webster 7677 Berry Avenue Denver, Colorado 80111-2137 Profession:
Licensing Engineer Emnlover:
Stone & Webster Engineering Corp.
Professional Exnertise:
The engineering, design, construction, operation and maintenance of nuclear power plants and Independent Spent Fuel Storage Installations, including the performance of accident analyses for nuclear power plants and ISFSIs.
Educational and Scientific Exoerience. and Professional Oualifications:
See Attached Resume 3
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l Publications in the last ten years:
None -
- Testifying experience in last four years:
None Sub_iect matter of testimony:
Resistance provided by the spent fuel cask storage systems to be used at the PFSF to the effects of an aircraft crash impact.
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. Documents reviewed and/or relied upon:
The documents reviewed and relied upon by Mr.
Johns include those portions of the August 13,1999 l
response to NRC on " Potential Aircraft Crashes at l
the PFSF" pertaining to the "PFSF Spent Fuel Storage Cask Resistance to Aircraft Impact," the references cited therein, and the supporting information and calculation at Tab H thereto. In addition, Mr. Johns may review and rely upon new information that may come into PFS's possession.
l-Utah R-Emergency Plan Name and Address:
Jeffrey R. Johns See Contention Utah K for information Subject matter of testimony:
The ability of the PFSF to withstand the effect of credible fires.
Documents reviewed and/or relied upon:
The document: reviewed and relied upon by Mr.
Johns include the PFSF SAR and the documents cited to and referred to in his declaration of June 28, 1999 filed in support of Applicant's Motion for Summary Disposition of Utah R.
The Applicant is still in the process ofidentifying the witnesses that it expects to call at the hearings and will supplement this response in accordance with TO C.F.R.
{ 2.740(e).
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O GENERAL I TERROGATORY NO. 4. For each admitted Utah contention, identify the qualifications of each expen witness whom PFS expects to call at the hearing, including but not limited to a list of all publications authored by the witness within the preceding ten years and a listing of any other cases in which the witness has testified as an expert at a trial, hearing or by deposition within the preceding four years.
APPLICANT'S RESPONSE: See Response to GeneralInterrogatory 3 above.
The Applicant is still in the process ofidentifying expert witnesses that it expects to call at the hearings and will supplement this response in accordance with 10 C.F.R.
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Q 2.740(e).
GENERAL INTERROG ATORY NO. 5. For each admitted Utah contention, describe the subject matter on which each of the witnesses is expected to testify at the hearing, describe the facts and opinions to which each witness is expected to testify, including a summary of the grounds for each opinion, and identify the documents (including all pertinent pages or parts thereof), data or other information which each witness has reviewed and considered, or is expected to consider or to rely on for his or j
her testimony.
AP_PLICANT'S RESPONSE. See Applicant's Response to General Interrogatory No. 3 above. Applicant will supplement this response in accordance with 10 C.F.R. f 2.740(e) as it obtains funher information.
Respectfully submitted, j
f-i Jay E. Silberg Emest L. Blake, Jr.
Paul A.Gaukler SHAW PITfMAN 2300 N Street, N.W.
Washington,DC 20037 (202) 663-8000 Dated: August 26,1999 Counsel for Private Fuel Storage L.L.C.
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DOCKE1ED US!1f:0 i
UNITED STATES OF AMERICA 99 AUG 30 A 8 :13 NUCLEAR REGULATORY COMMISSION OtJj
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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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l CERTIFICATE OF SERVICE I hereby certify that copies of the Applicant's Supplemental Response to State's First Requests For Discovery, the accompanying Declaration of Paul A. Gaukler and the attached resumes of Wayne O. Jefferson and Jeffrey Johns were served on the persons listed below (unless otherwise noted) by e-mail with conforming copies by U.S. mail, first class, postage prepaid, this 26th day of August 1999.
G. Paul Bollwerk III, Esq., Cnairman Dr. Jerry R. Kline Administrative Judge Administrative Judge Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 e-mail: GPB@nrc. gov e-mail: JRK2?nrc. gov: kjerry@erols.com i
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Dr. Peter S. Lam
- Susan F. Shankman l
Administrative Judge Deputy Director, Licensing & Inspection Atomic Safety and Licensing Board Panel Directorate, Spent Fuel Project Office U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety &
Washington, D.C. 20555-0001 Safeguards e-mail: PSLQnre. gov U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of the Secretary
- Adjudicatory File U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission Attention: Rulemakings and Adjudications Washington, D.C. 20555-0001 StafT e-mail: hearingdocket@nrc. gov (Original and two copies)
Catherine L. Marco, Esq.
Denise Chancellor, Esq.
Sherwin E. Turk, Esq.
Assistant Attorney General Office of the General Counsel Utah Attorney General's Office Mail Stop O-15 B18 160 East 300 South,5* Floor U.S. Nuclear Regulatory Commission P.O. Box 140873 Washington, D.C. 20555 Salt Lake City, Utah 84114-0873 e-mail: pfscase@nrc. gov e-mail: dchancel@ state.UT.US John Paul Kennedy, Sr., Esq.
Joro Walker, Esq.
Confederated Tribes of the Goshute Land and Water Fund of the Rockies Reservation and David Pete 2056 East 3300 South, Suite 1 1385 Yale Avenue Salt Lake City, UT 84109 Salt Lake City, Utah 84105 e-mail: joro61@inconnect.com e-mail: john %kennedys.org Diane Curran, Esq.
Danny Quintana, Esq.
Harmon, Curran, Spielberg &
Skull Valley Band of Goshute Indians Eisenberg, L.L.P.
Danny Quintana & Associates, P.C.
2001 S Street, N.W.
68 South Main Street, Suite 600 Washington, D.C. 20009 Salt Lake City, Utah 84101 e-mail:DCurran.HCSE@zzapp.org e-mail: quintana @xmission.com I
- By U.S. mail only s
O Paifl A.Gaukler 2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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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ASLBP No. 97-732-02-ISFSI DECLARATION OF PAUL A. GAUKLER Paul A. Gaukler states as follows under penalties of perjury:
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I am counsel with Shaw Pittman in Washington, D.C.
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I am duly authorized to verify Applicant's Second Supplemental Response to State's First Requests for Discovery; specifically, those supplemental responses to General Interrogatory Nos. 3-5.
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I certify that the statements in such responses are true and correct to the best of my personal knowledge and belief.
I declare under penalty and perjury that the foregoing is true and correct.
Executed on August 25,1999.
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Paul A.Gaukler Document #; 807065 v.I
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Major General Wayne 0. Jefferson, Jr., USAF (Ret.)
Major General Jefferson is currently an Associate with Burdeshaw Associates, Ltd. (BAL),
From 1994 until the present, General Jefferson has been a consultant in management, management training, and quantitative probabilistic analysis.
i From May 1992 to May 1994, General Jefferson was employed in private industry as Executive Director of LCC, Inc. and responsible for the accounting and finance, human resources and training functions of that company. He also served as the acting chief financial officer for 6 months. From May 1991 to May 1992, l
he was the General Manager of TSI, Inc., with total profit and loss responsibility for this rapidly growing j
company. Both of these companies were involved with engineering design support and deployment of the wireless elements of cellular telephone systems.
From 1989 to 1991, General Jefferson was President of Jefferson Associates, Inc., a consulting firm, and an Associate with Burdeshaw Associates, Ltd. (BAL).
General Jefferson retired from the U.S. Air Force on 11 July 1989 after more than 30 years of highly successful experience in leadership, decision-making, planning and management.
From April 1988 until completing service, General Jefferson served as the Joint Staffs Deputy Director for
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Defense-Wide C3 Support, in this position, he ensured the integrity, interoperablity, evolutionary capability and technical efficiency of all systems employed in the Defense Department's entire command, control and communications system.
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From 1985 to 1988, he headed NATO's Communications and information Systems Division on the International Military Staffin Brussels, directing NATO's highest level military C3 policy structure.
From 1984 to 1986, General Jefferson headed the Joint Staff's first Deputy Directorate for C3 Connectivity and Evaluation, directing the exercise and evaluation of the Defense Department's command and control systems in order to assure their operational capability under severe stress.
From 1980 to 984, General Jefferson held positions of rapidly increasing responsibility with the Strstegic Air Command (SAC). In 1983-84, he was Assistant Deputy Chief of Staff for Operatiors, oversceing the entire scope of SACS worldwide bomber, tanker, missile and reconnaissance operations, including training, range development and flight operations, in 1982 83 he was SACS Director of Command Control, responsible for the operation of SACS tight command and control system, including the underground command center in Omaha and the airborne command post. In 1981, as SAC's Assistant Director of Plans and Policy, he was respcMible for the analysis and development of SACS future force requirements, the -
preparation of SACS annual budget, and bas'ng plans for new weapons systems. In 1980-81, he commanded a B-52 bomb wing with 17 B 52H bombers and 22 KC 135 tankers.
Prior expenence included nuclear test and evaluation, Air Staff mission area planning, Vietnam flight operations, and faculty member at both the US Air Force Academy and the National War College in simulation, economics and management, focusing on operations research and quantitative decision making involving probabilistic methods Educational Background Senior Managers in Government Program, Harvard University M.S. in Operations Research, Stanford University M.B.A, Auburn University Technical Usersity of Munich, Germany. Two years E.E. (in German)
B.S., U. S. Air Force Academy (distinguished graduate)
National War College (graduate and faculty member)
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Air Command and Staff College (distinguished graduate) l.
Overseas experience l
Belgium, Germany, Vietnam l
Language capability in German, French, and Spanish i
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JEFFREY R. JOHNS Licensing Engineer 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 ISFSI, 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 modificatior.s 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.
M*. 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 acedent 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.
l 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. Johns 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.
RELWANTPROJECTEXPERIENCE Pr'ivate 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 responsible 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 palth 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 concoming modifications which make the ISFSI cask load / unload port compatible with new spent fuel shipping casks. Mr. Johns
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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 ISFSt. The second amendment permitted storage of low-level radioactive waste and radioactive sources for instrument calibration at the ISFSt. 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.
Mr. Johns provided assistance to the FSV Emergency Planning Coordinator with ISFSI emergency procedures, event classific& tion, and in creating realistic dnli scenarios for the annual examinations of emergency preparedness, observed by the NRC.
EDUCATION B.S., Biological Science - Stanford University l
LICENSES AND REGISTRATIONS Professional Engineer - Colorado i
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