ML20216D647
| ML20216D647 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 07/28/1999 |
| From: | Sullivan R NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20216D637 | List: |
| References | |
| ISFSI, NUDOCS 9907300043 | |
| Download: ML20216D647 (6) | |
Text
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UNITED STATES OF AMERICA l
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-ISFSI
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(Independent Spent Fuel
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Storage Installation)
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AFFIDAVIT OF RANDOLPH L. SULLIVAN CONCERNING UTAH CONTENTION R (EMERGENCY PLANNING)
COUNTY OF MONTGOMERY
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SS:
STATE OF MARYLAND
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Randolph L. Sullivan, having first been duly sworn, does hereby state as follows:
1.
I am employed as an Emergency Preparedness Specialist, in the Operator Licensing, Human Performance, and Plant Support Branch, Division of Inspection Program Management, Office of Nuclear Reactor Regulation, 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 Disoute Exists" (" Statement of Material Facts") attached thereto.
3.
As part of my official responsibilities, I reviewed the Applicant's Emergency Plan, as revised on May 19, 1999, and its responses to the NRC Staff's Requests for Additional Information (RAls) dated May 19,1998, June 15,1998, and February 10, 1999, concerning emergency planning issues related to PFS' application for a license for an Independent Spent Fuel 9907300043 990728 PDR ADOCK 07200022 C
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Storage Installation ("ISFSI"), to be locate'd on the reservation of the Skull Valley Band of Goshute Indians.
4.
In addition, I participated in preparing 'the "NRC Staff Position" on Utah Contention R, as set forth in the "NRC Stafi's Statement of Its Position Concerning Group I Contentions," dated June 15,1999 (at 20-22). The NRC Staff Position accurately represents my views concerning this contention.
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 Emergency Plan and PFS' responses to the Staff's RAIs, I am satisfied that the factual statements contained in the foregoing Staff Response are correct. No position is expressed herein with regard to th; Statement of Material Facts attached to the Applicant's Motion.
7.
I hereby certify that the foregoing is true and correct to the best of my knowledge, information and belief.
i Randdiph 1" Sullivan Sworn to before me this 28th day of July 1999 j'/
/D Notary Public My commission expires:
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4 Randolph L Sullivan Statement of Professional Qualifications Mr. Sullivan is a board certified health physicist with more than 25 years of experience in emergency preparedness and radiological protection. He has held senior technical and managerial positions within the commercial nuclear industry and the Federal Government. His expertise includes health physics, technical hazards assessment, engineering and emergency preparedness. He has provided consulting assistance to more than 12 commercial nuclear utilities and several private firms. He has performed on projects for Department of Energy prime contracto.s. His experience in private industry has included responsible management and technical staff positions. ' He managed a full-scope nuclear power plant emergency preparedness program and was the Project Manager on the startup of an emergency preparedness program. As a Radiation Specialist at the Nuclear Regulatory Commission, he inspected commercial nuclear power plants, large byproduct-materiallicensees, a waste disposal site, and a fuel fabrication facility. Mr. Sullivan currently is an Emergency Preparedness Specialist with the Nuclear Regulatory Commission.
EDUCATION B.S. Engineering Science, Illinois Institute of Technology U.S. Atomic Energy Commission, Reactor Health Physics Training Courses BACKGROUND At U. S. Nuclear Regulatory Commission, he is an Emergency Preparedness Specialist, performing licensing activities for nuclear licensees.
At Advanced Technologies and Laboratories, Inc. he was a consultant to DOE, supporting the Office of Environmental Management in the assessment of LLW disposal site radiological capacity, the Office of Environment, Safety and Health (ES&H)in the development of professionallevel Radiation Protection training programs and the Office of Emergency Management in the assessment of demonstration exercises and the development of performance measurements. He assisted the Waste isolation Pilot Plant site in the conduct of emergency management exercises during their Operational Readiness Review and in the mentoring of Emergency Preparedness staff At Program Management Inc., Mr. Sullivan provided technical support to DOE's Office of Environment, Safety and Health in radiation protection standards and policy development. He supported the development of an Environmental Assessment for amendments to 10 C.F.R. Part 835
" Occupational Radiation Protection" and finalization of Revision 2 to the DOE Radiological Control Manual.
At Natural and Technical Hazards Management Inc.(NTHMC), Mr. Sullivan developed emergency action levels for the Power Burst Facility and the Test Area North at Idaho National Engineering Laboratory. This included detailed efforts to assess radiological and toxic chemical hazards.
At mbs Consulting Partners, Mr. Sullivan was the Chief Partner of this consulting group, which provided custom dose projection software to seven nuclear power plant sites. The software implemented the new 10 C.F.R. Part 20 and EPA 400 regulations. mbs was also the American distributer for the Safe Training System, a chemical and radiological contamination simulation system.
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At GPU Nuclear, Mr. Sullivan was the Oyster Creek Nuclear Generating Station Emergency Preparedness Manager, responsible for a full scope Emergency Preparedness (EP) program and a staff of senior technical personnel. He implemented numerous improvement projects leading to the only NRC rating of SALP-1 at this site for several reporting periods. He establisM a " state of the art" Technical Support Center including automated data projecibn systems and ar, Aline dose projection system. He upgraded and standardized training prop. rams to minimize student time while maximizing training impact by the use of case studies and hands on testing. He developed numerous drill / exercise scenarios: conducted the associated critiques and assigned corrective actions. Mr. Sullivan critiqued over 30 actual emergency events, assigning corrective actions where appropriate and presenting findingu to Management and NRC. He was responsible for extensive interface with State ar.d local officials in the implementation of supportive emergency plans as well as conducting media briefings and responding to media inquiries. He was responsible for all NRC interface for emergency preparedness. He participated in Iristitute for Nuclear Power Operations EP assessments at nuclear plant sites and was requested to critique several exercises at neighboring power plants. Mr. Sullivan was selected as Secretary of the Site Management Team, a senior level committee created to foster a culture of excellence. He managed engineering, technical and craft personnel during the 15R outage as the Turbine Building Manager.
At Hydro Nuclear Services, Mr. Sullivan provided health physics audit and consulting services to Nuclear Pharmacy Inc., a large byproduct-materiallicensee. He supported several emergency preparedness and health physics projects for nuclear power plants.
W At Impell Corporation, Mr. Sullivan was Project Manager for an emergency preparedness startup and licensing effort at e nuclear power plant. He managed a group responsible for the development of n uniqua simulator-based training and drill program. He trained and coached executive and senior rnanagement personnel through a successful first exercise.
At Allen Nucl ear Associates, Mr. Sullivan was part of a technical staff performir.g the start-up of a full scope nuclear plant health physics program. He assisted in the oevelopment of the emergency preparedness program and the ALARA program. He performed management analysis for the selection of appropriate staff for senior emergency plan positions.
At Quadrex Corporation, Mr. Sullivan was Manager of Health Physics Services, responsible for multiple projects including preparation of emergency plans and procedures, nuclear plant decommissioning, accident analy&, diffusion modeling, environmental monitoring, and the Systematic Evaluation Program fc. two power plants. He participated in the assessment of the General Atomic Fusion Reactor and supported the Hanford Tank Farm remediation project. He performed a hazards assessment in support of the startup of the Loss of Flow Test Facility at INEL.
While with the NRC (in the 1970s), Mr. Sullivan was responsible for the regulation and inspection of Health Physics and Emergency Preparedness programs at nuclear plants, research reactors, a fuel fabrication facility, hosp'tals, universitiss, and large industrial byproduct-material licensees, i
As a Health Physics Technician at the University of Illinois, Mr. Sullivan routinely inspected over 100 medical researcn labs, developed procedures, shipped rad-waste, implemented a TLD system, and supported radiation therapy dosimetry.
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00CKETED UNITED STATES OF AMERICA US"RC NUCLEAR REGULATORY COMMISSION
'99 JUL 29 P12:21 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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ADJL r
PRIVATE FUEL STORAGE L.L.C.
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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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CERTIFICATE OF SERVICE I hereby certify that copies of the "NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR PARTIAL
SUMMARY
DISPOSITION OF UTAH CONTENTION R - EMERGENCY PLAN" in the above captioned proceeding have been served on the following through deposit in the Nuclear Regulatory Commission's internal mail system, or by deposit in the United States mail, first class, as indicated by an asterisk, with copies by electronic mail as indicated, this 28th day of July,1999:
G. Paul Bollwerk, III, Chairman Atomic Safety and Licensing Board Panel Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 l
U.S. Nuclear Regulatory Commission l
Washington, DC 20555 Office of the Secretary (E-mail copy to GPB@NRC. GOV)
ATTN: Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline Washington, DC 20555
- Administrative Judge (E-mail copy to:
Atomic Safety and Licensing Board HEARINGDOCKET@NRC. GOV)
U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the Commission Appellate (E-mail copy to JRK2@NRC. GOV)
Adjudication Mail Stop: 16-C-I OWFN i
Dr. Peter S. Lam U.S. Nuclear Regulatory Commission Administrative Judge Washington, DC 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission James M. Cutchin, V Washington, DC 20555 Atomic Safety and Licensing Board (E-mail copy to PSL@NRC. GOV)
U.S. Nuclear Regulatory Commission Washington, DC 20555 (by E-mail to JMC3@NRC. GOV)
Danny Quintana, Esq.*
Diane Curran, Esq.*
Danny Quintana & Associates, P.C.
Harmon, Curran, Spielberg 68 South Main Street, Suite 600
& Eisenberg, L.L. P.
Salt Lake City, UT 84101 1726 M. Street N.W., Suite 600 (E-mail copy to quintana @Xmission.com)
Washington, D.C. 20036
' (E-mail copy to Jay E. Silberg, Esq.*
dcurran@harmoncurran.com)
Ernest Blake, Esq.*
' Paul A. Gaukler, Esq.*
John Paul Kennedy, Sr., Esq.*
SHAW, PITTMAN, POTTS &.
1385 Yale Ave.
TROWBRIDGE Salt Lake City, UT 84105 2300 N Street, N.W.
(E-mail copy to john @kennedys.org)
Washington, DC 20037-8007 (E-mail copies to jay _silberg, Joro Walker, Esq.*
paul _gaukler, and ernest _blake Land and Water Fund of the Rockies
@shawpittman.com) 2056 East 3300 South, Suite 1-Salt Lake City, UT 84109 Denise Chancellor, Esq.*
(E-mail copy to joro61@inconnect.com) l Fred G. Nelson, Esq.
Utah Attorney General's Office Richard E. Condit, Esq.
160 East 300 South,5th Floor Land and Water Fund of the Rockies P.O. Box 140873 2260 Baseline Road, Suite 200 Salt Lake City, UT 84114-0873 Boulder, CO 80302 (E-mail copy to dchancel@ State.UT US)
(E-mail copy to rcondit@lawfund.org)
Connie Nakahara, Esq.*
Utah Dept. of Environmental Quality 168 North 1950 West P. O. Box 144810 Salt Lake City, UT 84114-4810 (E-mail copy to cnakahar@ state.UT.US)
Sherwin E. Turk Counsel for NRC Staff l'
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