ML20216D641

Affidavit of Pw Lain Re Utah Contention R (Emergency Planning).* Affidavit Relates to Applicant SAR & Emergency Plan,As Revised on 990519,re Fire Protection Equipment & Firefighting Capabilities

ML20216D641
Person / Time
Site:	07200022
Issue date:	07/28/1999
From:	Lain P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20216D637	List: ML20216D633 ML20216D641 ML20216D647
References
ISFSI, NUDOCS 9907300042
Download: ML20216D641 (5)

Text

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1 UNITED STATES OF AMERICA l 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. ) Docket No. 72-22-ISFSI

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(Independent Spent Fuel )

Storage Installation) )

AFFIDAVIT OF PAUL W. LAIN CONCERNING UTAH CONTENTION R (EMERGENCY PLANNING)

COUNTY OF MONTGOMERY ) {

) SS:

STATE OF MARYLAND )

Paul W. Lain, having first been duly ; worn, does hereby state as follows:

1. I am employed as a Fire Protection Engineer in the Fuel Cycle Licensing Branch, Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, in Washington, D.C. A statement of my professional qualifications is attached hereto.

2. This Affidavit is prepared in response to the " Applicant's Motion for Partial Summary Disposition of Utah Contention R" (" Motion"), filed on June 28,1999, by Private Fuel Storage L.L.C. (" Applicant" or" PFS"), and the " Statement of Material Facts on Which No Genuine Dispute Exists" (" Statement of Material Facts") attached thereto.

3. As part of my of'icial responsibilities, I reviewed the Applicant's Safety Analysis Report (SAR) and Emergency Plan (EP), as revised on May 19, 1999, pertaining to the Applicant's fire protection equipment and firefighting capabilities, as well as its related responses to the NRC Staff's Requests for Additional Information (RAIs) dated May 19,1998, June 15, 9907300042 990728 PDR C

ADOCK 07200022 PDR

, 1998, and February 10,1999, related to PFS' application for a license for an Independent Spent Fuel Storage Installation ("ISFSI"), to be located on the reservation of the Skull Valley Band of Goshute Indians.

4. In addition, I have reviewed the "NRC Staff Position" on Utah Contention R, as set forth in the "NRC Staff's Statement of Its Position Concerning Group I Contentions," dated June 15,1999, as it pertains to the means and equipment for fighting fires onsite (Staff Position, at 21-22). Based on my review of the Applicant's submittals, I believe that the statements contained in the NRC Staff Position concerning these matters are correct.

5. Also as part of my official responsibilities, I have reviewed the Applicant's Motion and the attachments thereto, in which PFS seeks summary disposition of Utah Contention R; and the foregoing "NRC Staff's Response to Applicant's Motion for Partial Summary Disposition of Utah Contention R - Emergency Plan," dated July 28,1999 (" Staff Response").

6. On the basis of my review of the Applicant's SAR, Emergency Plan, and responses to the Staff's RAIs, I am satisfied that th- factual statements contained in the foregoing Staff

' Response are correct. No position is e , pressed herein with regard to the Statement of Material Facts attached to the Applicant's Motion.

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, 7. I hereby certify that the foregoing is true and correct to the best of my knowledge, information and belief.

Paul W. Lain l l

Sworn to before me this 28th day of July 1999 Notary Public.

My commission expires: /M ! Ndd/

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. Paul W. Lain, P.E.

Statement of Professional Qualifications I i

l Mr. Lain is a board certified professional engineer with more than 15 years of experience in fire protection engineering. He has held technical and project management positions for the U.S. Navy, Department of Energy (DOE), and the Nuclear Regulatory Commission (NRC). He has conducted inspections on aircraft carriers, battleships, plutonium and uranium manufacturing facilities, and a  !

nuclear waste storage facility. He has conducted over 100 shipboard fire tests to test the  !

effectiveness of smoke control systems onboard naval vessels. He was the fire protection expert on multiple Operational Readiness Reviews for DOE nuclear facilities. Mr. Lain authored the Fire Protection Chapter of the Standard Review Plan for NRC fuel cycle facilities, and conducted the fire protection review for the re-licensing of the Nuclear Fuel Services facility in Tennessee. Currently, Mr. Lain currently conducts all fire protection licensing reviews for fuel fabrication facilities licensed by the NRC. l l

i EDUCATION Bachelor of Science in Fire Protection Engineering from the University of Maryland,1983 Master of Science in Fire Protection Engineering from Worcester Polytechnic Institute,1996 l

PROFESSIONAL EXPERIENCE From 1983 to 1991, Mr. Lain was a fire protection engineer for the Fire Protection Systems Branch of the Naval Sea Systems Command. He was the project manager for many research projects pertaining to fire protection onboard U.S. naval ships and submarines. He conducted over 100 large scale fire tests onboard the navy's test vessel USSX Shadwell, to determine the feasibility of active smoke control utilizing the existing shipboard ventilation system. He performed fire protection

- inspections and design reviews on a variety of naval vessels.

I From 1991 to 1997, Mr. Lain was a fire protection engineer for the Division of Nuclear Material and Facility Stabilization at DOE. Mr. Lain was the fire protection subject matter expert for reviews of l Safety Analysis Reports (SARs) at Rocky Flats Environmental Technology Site and Idaho National )

Engineering Laboratory, for Operational Readiness Reviews of F-Canyon, FB-Line, and the Inter Tank Processing facilities at the Savanna River Site, and the Fire Protection Vulnerability Review of Y12 and K25 facilities at Oak Ridge.

Since May of 1997, Mr. Lain has been a fire protection engineer for the NRC Office of Nuclear Materials Safety and Safeguards, in the Licensing and International Safeguards Branch. He conducts fire safety reviews for fuel cycle facilities licensed by the NRC and is the NRC project I manager for the Siemens Power Corporation facility in Richland, Washington. Additional duties have included the development of the Fire Safety Chapter of the Standard Review Plan for fuel  ;

cycle facilities, inspection of Oak Ridge National Laboratory's Research and Engineering Development Center for the DOE Pilot Study, and inspection of the Gaseous Diffusion Plant at Paducah, KY.

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MEMBERSHIPS Mr. Lain is a member of the National Fire Protection Association (NFPA) and has served on several

- standards committees of the NFPA. He is a licensed professional engineer in the State of Maryland.

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