ML20245A777

NRC Staff Motion to Strike Testimony of G Thompson.* Thompson Testimony Considered Irrelevant & Immaterial to Any Issue in Proceeding.Testimony Should Be Stricken & Environ Contention 3 Dismissed

ML20245A777
Person / Time
Site:	Vermont Yankee
Issue date:	06/09/1989
From:	Patricia Jehle NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20245A775	List: ML20245A773 ML20245A777 ML20245A788 ML20245A798
References
LBP-89-06, LBP-89-6, OLA, NUDOCS 8906220177
Download: ML20245A777 (3)

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J form irD UNITED STATES OF AMERICA M NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '89 JUN 14 P5 :01 l Or: u , f In the Matter of DM

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VERMONT YANKEE NUCLEAR ) Docket No. 50-271-0LA POWER CORPORATION (Spent Fuel Pool Amendment)

(VermontYankeeNuclearPower )

Station)

NRC STAFF MOTION TO STRIKE THE TESTIMONY OF GORDON THOMPSON The Nuclear Regulatory Commission staff moves that the " Testimony of Gordon Thompson" submitted in support of "New England Coalition on Nuclear  !

Pollution's Brief and Summary of Relevant Facts and Arguments on which NECNP Intends to Rely at Oral Argument on Contention 3" be stricken.

Althcugh 10 C.F.R. 5 2.743(c) is not strictly applicable because i Thompson's testimony is not offered as evidence, its standard should be followed. In a Subpart K proceeding, the provisions of Subpart G of 10 C.F.R. Part 2 are applicable, except where inconsistent. 10 C.F.R. 9 2.1117. Section 2.743(c) provides that "[o]nly relevant, material, and i

reliable evidence which is not unduly repetitious will be admitted. l Immaterial or irrelevant parts of an admissible document will be l segregated and excluded so far as is practicable." Mr. Thompson's i

testimony is not relevant or material to any issue in this proceeding in that it concerns in its totality an issue that is before the Appeal Board on referral and is not before the Licensing Board.

In a Subpart K proceeding, each party shall submit facts, data and arguments to support the existence of a genuine and substantial dispute of fact. 10 C.F.R. 6 2.1113(a). The Thompson testimony does not present r;906220177 890609 DR ADOCK 050 1

.Oi facts or data supporting the existence of-a; genuine.and substantial dispute of fact raised by Environmental Contention 3. As discussed above, j the testimony is irrelevant to any issue:that:might:be raised by d Environmental Contention 3.

The Licensing Board excluded severe accidents as~a basis for 1 Environmental Contention 3'in its October 11, 1988 Memorandum and Order,-

VermontYankeeNuclearPowerCorporation(YermontlYankeePowerStation)~,.

LBP-88-26A,28NRC440,450.(1988); also see generally Vermont Yankee at-444-46. Furthermore, the' Licensing Board in LBP-89-6, which reconsidered a severe-accident basis for Environmental Contention 3 and referred the-ruling to the Appeal Board, stated that this basis "would be litigated simultaneously with Environmental Contention 1 and would not be a ground--

for delaying litigation of the remainder of Environmental Contention 3."

VermontYankeeNuclearPowerCorporation(VermontYankeeNuclearPower Station), LBP-89-6, 29 NRC 127 (1989). Further, in LBP-89-6, the Licensing Board deferred discovery c.a the. severe-accident basis for Environmental Contention 3 until the dur W urvice of an Appeal Board (or Comission)- 3 decision which makes LBP-89-6 effective. Thus, parties have not had an opportunity to conduct discovery on the severe-accident basis' for Environmental Contention 3 and Gordon Thompson's testimony deffes the Licensing Board's order in LBP-89-6. l Wherefore, the NRC staff moves that the Testimony of Gordon Thompson, submitted by the New England Coalition on Nuclear Pollution, be stricken i

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stricken and the contention dismissed'for NECNP's failure to provide support for its contention other than Gordon Thompson's testimony.-

Respectfully submitted, i 2-<b Patricia Jehle Counsel for NRC Staff Dated at Rockville, Maryland this 9th day of June, 1989.

7 JUN 0 91989L

, UNITED STATES OF AMERICA TCg~fD NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC' SAFETY AND LICENSING BOARD '89 JLN 14 ~ P5 :01

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In the lhtter'of. '

y y g ;'y g g VERMONT-YANKEE NUCLEAR' Docket! No. 50-271-OLA-POWER CORPORATION l(Spent Fuel Pool Amendment)-

(Vermont.YankeeNuclear-Powera ,

Station). I NRC S1AFF REPLY TO BRIEFS OF THE NEW ENGLAND COALITION ON, NUCLEAR POLLUTION AND VERMONT YANKEE ON ENVIRONMENTAL CONTENTION ~3 q

The Nuclear Regulatory Commission:(NRC) staff hereby submits.its reply to the facts, data and legal arguments raised. by the New: England Coalition'

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onNuclearPollution:(NECNP)andVermontYankeeNuclearPowerCorporation 1 in their briefs dated May 23, 1989. "New England Coalition.on Nuclear-Power's Brief and Summary of Relevant Facts and Arguments on which NECNP Intends-to Rely at Oral Argument on Environmental Contention 3" (NECNP Brief),datedMay 23,1989; " Memorandum of Vermont Yankee Power Corporation L :s on the Existence of a Genuine and Substantial Question of. Fact Regarding.

Environmental Contention 3" (Licensee Brief), dated May-23,'1989. It is the Staff's position-that no genuine and substantial dispute of fact-relating to Interveners' Environmental Contention 3.has been raised in the J Interveners' brief or its supportingLtestimony. .The Staff has met its burden of proof on Environmental Contention 3 and is entitled,'as a matter.  !

of law, 9 a decision in its favor on Environmental Contention 3. This reply brief is supported by an " Affidavit of Frederick C. Sturz and Morton B. Fairtile of the NRC Staff Regarding New England Coalition on Nuclear Pollution and the Commonwealth of Massachusetts' Environmental Contention q 3"(StaffAffidavit). '

i 8906220181 890609 l PDR ADOCK 05000271 .;

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I. : INTRODUCTION' The Supreme Court has stated "that NEPA, while establishing.

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'significant goals for the Nation' imposes'upon agencies duties ~that are'

' essentially procedural';" - Strycker's Bay Neighborhood Council v. Karlen, l

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444 U.S. 223, 227; citing Vermont Yankee Nuclear Power Corp. v. NRDC,

'435 U.S. 519. 558 (1978); see also Marsh v.-Oregon Natural Resources.

Council, 57 U.S.L.W. 4504'(May 1,'1989) and Robertson v. Methow Valley Citizens Council, 57 U.S.L.W. 4497 (May 1, 1989). The Court further.' defined j the scope of the National Environmental Policy Act (NEPA)' stating:

Vermont Yankee cuts sharply against the Court of' Appeals' conclusion that an agency, in selecting a course' of action, must' elevate environmental concerns over other appropriate considerations. 'On the' contrary, once an agency has made a decision. subject to NEPA's procedural requirements, the only role for the court is to. insure the agency has considered the environmental; consequences;' .~ . ..

Strycker's Bay, supra, at 227. The NRC staff adequately carried out Lits -

procedural duties under the National Environmental Policy Act in its review of the proposed licensing amendment.

The Interveners imply that the Licensing Board has a unique role in. l any proceeding which involves. a NEPA claim. NECNP Brief at"6. The Intervenorscite10C.F.R.Il51.105(a)(2)and(3)assupport-forthe i

Licensing Board's special powers and obligations'in reviewing NEPA claims.

The Staff points out that these subsections refer to:a Licensing Board's responsibilities when public hearings are conducted in proceedings for the -!

H issunnce of construction permits or licenses to manufacture and therefore- i do not apply to this proceeding. See10C.F.R.I51.105(a). d j

l II. SEVERE ACCIDENTS ARE BEYOND THE SCOPE OF ENVIRONMENTAL CONTENTION 3 j

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NECNP. should not be able. to raise the issue of severe accidents in- i

.this proceeding. First, there is an element of surprise; severe accidents o _ _ _

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were specifically excluded as a basis for Environmental Contention 3.

VermontYankeeNuclearPowerCorporation(VermontYankeeNuclearPower I Station), LBP-88-26, 28 NRC 440, 450 (1988); LBP-89-6, 29 NRC 127, 134-36 (1989). Secondly, NECNP appears to be redefining its. contention by claiming that expansion of spent fuel pool storage capacity will have a l

l significant effect on the human environment. In otherwords, NECNP is treating.9102(2)(E)asifitwere6102(2)(C). Thirdly, NECNP has failed to provide any technical support for its claim that expanded wet storage {

carries "substantially increased risk" and that dry cask storage is

" unquestionably an environmentally preferable alternative." NECNP.Brief-at 10-11; " Testimony of Gordon Thompson," Parts VI, at 8-9.

III. THE NRC STAFF FULLY COMPLIED WITH THE REQUIREMENTS OF THE NATIONAL ENVIRONMENTAL POLICY ACT A. Requirements of NEPA li 102(2)(C) and 102(2)(E)

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1 l TheNationalEnvironmentalPolicyAct(NEPA)setsforthtwo {

1 l provisions which require a federal agency to evaluate alternatives'to a proposed action. Sections 102(2)(C)and(E)ofNEPA;42U.S.C.

i l 94332(2)(C)and(E). The relevant provisions are: '

l l (2) all agencies of the Federal government shall.

(C) include in every recommendation a report en proposals for l l legislation and other major Federal actions significantly 1 affecting the quality of the human environment, a detailed j statement by the responsible official on -- 1 (iii) Alternatives to the proposed action.

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(E) Study, develop, and describe appropriate alternatives to recommended courses of action fn any proposal which involves unresolved conflicts concerning alternative uses of available resources. (Emphasis added).

The requirement that a federal agency evaluate alternatives to a 1

proposed action is triggered in two ways

(1) by a major federal action significantly affecting the human environment and/or; (2) by an unresolved conflict concerning available resources. The two-pronged threshold question must be addressed before determining whether an agency's scope of review of alternatives is sufficient. If neither prong of the threshold question is triggered a federal agency has no oblio= tion to evaluate alternatives to a proposed action under NEPA.

In River Road Alliance v. Corps of Engineers of U.S. Army, 764 F.2d 445, 452 (7th Cir. 1985), the Seventh Circuit considered the threshold question of 6 102 and found there were unresolved conflicts concerning alternative uses of available resources. Only after 9102(2)(E) is triggered does NEPA require an examination, of the appropriate alternatives to recommended courses of action, which is " independent of the question of environmental impact statements, and operative even if the agency finds no significant environmental impact." Id. "[N]onsignificantimpactdoesnot equal no impact; so if an even less harmful alternative is feasible, it ought to be considered. But the smaller the impact, the less extensive a search for alternatives can the agency reasonably be required to conduct." Id. Where "the objective of a major federal project can be achieved in one of two or more ways that will have differing impacts on the environment, the responsible agent is required to study, develop and describe each alternative for appropriate consideration." Triniiv Episcopal School Corporation v. Romney, 523 F.2d 88, 93 (2d. Cir. 1975).

(Emphasisadded). The Trinity dictum does not imply that the requirements .

1 of 9 102(2)(E) of NEPA are triggered when the objective of any action j can be achieved in two or more ways, as the Interveners suggest. NECNP Brief at 8. The Trinity court does not define the limits of 6-102(2)(E) of NEPA, but finds that where the objective of a major federal action'can be achieved in one or more ways there is by definition an unresolved J i

conflict concerning alternative uses of available resources. Trinity, supra, .

l at 93. The mere fact that the storage of spent fuel at Vermont Yankee can be achieved by various methods does not trigger a statutory requirement that I the Staff evaluate and recommend a particular method. I B. The Proposed Action Does Not Involve Unresolved Conflicts Concerning .)

Alternative Uses of Available Resources -

The Appeal Board has addressed the issue of what are the "available resources" in a spent fuel pool expansion and what constitutes " unresolved conflicts" over such resources. Virginia Electric and Power Company j (North Anna Nuclear Power Station, Units I and 2), ALAB-584, 11 NRC 451, 458(1980). The Appeal Board found:

the interveners have never endeavored to explain why the installation of new racks in a spent fuel pool might engend e alternative uses of anilable resources. And it is just as difficult now as it was a year ago (when Trojan was decided) to fathom how such a conflict might arise.

North Anna, supra, at 458. The Appeal Board was not persuaded that the materials used in a pool expansion, notably stainless steel and engineering talent, constitute resources over which unresolved conflicts l

exist. Id. at 458 n.14. Similarly, the Interveners here have raised no L

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1 genuine factual issue which constitutes an unresolved conflict over the i available resources involved in the proposed action.

I C. The Interveners Have Not Established That Dry Cask Storage Is E_ environmentally Superior Therequirementsof6102(2)(E)ofNEPAarenottriggeredwherethere 1

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are negligible environmental impacts and no unresolved conflicts over the commitment of available' resources. Virginia-Electric Power Company (North .;

Anna Nuclear Power Station, Units 1 and 2), ALAB-584, 11 NRC 451, 457 (1980); Portland General Electric Company (Trojan Nuclear Plant), i ALAB-531, 9 NRC 263, 266 (1979). "[T]here is no obligation to search out ,

i possible alternatives to a course which itself will not either harm the environment or bring into serious question the manner in which this J country's resources are being expanded." Trojan, supra, at 266. An

" alternative which would result in similar or greater harm need not be discussed." Sierra Club v. Morton, 510 F2d 813, 825 (5th Cir. 1975). l In a review of the Staff's obligations under NEPA.to examine alternatives to a spent fuel pool expansion, the Appeal Board stated: I there was no necessity to explore further the Interveners' suggested alternatives unless there was some basis for believing that the proposed modification might either have a significant environmental effect or give rise to a controversy over the allocation of resources. Moreover, in order to reject the Applicant's proposal, it would have to be determined both that (1) at least one of the alternatives was environmentaTTysuperior;and(2)thatenvironment61 superiority was ' tot outweighed by the other considerations such as compar: h ve costs.

NorthAnna, supra,at457-58;(emphasisinoriginal).

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i Interveners have not alleged in Environmental Contention 3 that the ,

proposed action involves a significant environmental impact nor have they -

pointed to a specific unresolved conflict concerning available i resources.II Neither have they established that their p' referred l

alternative, dry cask storage, is environmentally superior and that any alleged superiority is not outweighed by the comparative costs of the y faethods.

The Staff and the Licensee established that wet 'and dry ca:;k storage methods have negligible impacts on the environment. Sturz Affidavit at 11 24, 33-36, 38-39; Vermont Yankee Testimony at 12-17. Economic costs of dry cask storage are estimated to be high, higher in fact than those associated with the proposed action. Vermont Yankee Testimony at 17-19. j i

In addition, there are presently no NRC-approved casks for boiling water 1 reactor (BWR) fuel. Sturz Affidavit at i 27; Vermont Yankee Testimony at

10. The Staff is neutral on the issue of the superiority of the two storage methods. The Staff evaluated the consequences of each method; both methods were approved because they are. environmentally benign. The proposed rule for Part 72 is not a Staff statement as to the environmental or economic superiority of dry cask storage but is merely based on the acceptability of such storage.

-1/ The Interveners aust be required to identify the "available resources" over which they contend unresolved conflicts exist. Only by establishing that there are unresolved conflicts over available resources would the Interveners provide a basis for Environmental Contention 3. Without such a showing the Interveners' contention is a bald statement devoid of legal basis.

-8 D. Alternatives to the Proposed Action Were Properly Considered by the NRC Staff The Interveners have misconstrued both the NRC Staff's role and'its.

actions in the review of the proposed licensing-amendment. NECNP Brief-Part III, Section C at 9-10. In preparing an EA the Staff is not required to conduct _ comparative analyses of_ alternatives under NEPA, nor is the-Staff required to choose among alternatives to a proposed action. The.

Staff must meet the requirements of 10 C.F.R. Part 51 and 5 102(2) of NEPA. The Staff EA did so in the review of the proposed' action.

The Interveners are. mistaken when they suggest the Staff was negligent in the preparation of the Environmental Assessment. NECNP Brief at 12. The Staff performed its review of the Vermont _ Yankee amendx nt application and prepared its EA as required by the Commission's regulations. The length of time required to complete this work is a reflection of the demand on Staff resources, not a subterfuge to delay the amendment proceeding. The Environmental Assessment did not include a site-specific analysis of dry cask storage because neither NEPA nor the Commission's regulations require it. 42 U.S.C l'4332 (2); 10 C.F.R. Part

51. However, the Staff relied on its past licensing experience and the Part 72 proposed rulemaking in its consideration of the dry cask alternative. Sturz Affidavit at i 27.

IV. CONCLUSION For the reasons discussed !bove and set forth in the NRC Brief dated May 23, 1989, the Licensing Board should find that there is no genuine and substantial dispute of fact in the Interveners' Environmental Contention 3 l

to be litigated, that the Staff has met its burden of proof on Environmental

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.9 Contention 3, and that the Staff is entitled to.a' decision in its' favor on l Environmental Contention 3 as a matter of law. )

Respectfully submitted .

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Patricia A. Jehle t j

Counsel for NRC Staff.' ,

i Dated at Rockville, Maryland this 9th day of June, 1989.

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UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD:

In the Matter of VERMONT YANKEE NUCLEAR. Docket No. 50-271-OLA POWER CORPORATION ~(Spent Fuel Pool Amendment)-

(VermontYankeeNuclearPower Station)

AFFIDAVIT OF FREDERICK C. STURZ AND

.MORTON B. FAIRTILE OF THE NRC' STAFF REGARDING NEW ENGLAND COALITION ON NUCLEAR POLLUTION AND THE COMMONWEALTH OF MASSACHUSETTS' ENVIRONMENTAL CONTENTION 3 The NRC staff has reviewed the " Testimony of Gordon Thompson" (Thompson Testimony) and responds as follows:

The testimony presents a generic analysis of severe accidents in spent fuel pools. Because severe accidents are outside the scope of Environmental Contention 3 the Staff.will not rebutt the technical statements of Mr. Thompson. Mr. Thompson's testimony shows no familiarity with the design of the spent fuel racks at the Vermont Yankee Nuclear.

Power Station, and furthermore, no connection has been made between severe' j accidents and the design and construction of the' Vermont Yankee racks. '

Thompson Testimony, Part IV, at 4-5. Mr. Thompson has not addressed the probability of . severe accidents in his testimony. Nor has Mr.

Thompson identified a probable event that could initiate a' severe accident.

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Mr. Thompson expresses his opinion that " cask technology!1s relatively simple" and that there is "no fundamental reason" for the delay

i. of several years which is required to design, license-and construct an on-site dry cask ' storage facility. Thompson Testimony at 10. No technical support is provided for this statement; the testimony is devoid of a technical discussion of dry cask storage, its costs, its benefits, or

.its consequences. The Staff has.provided estimates for the time needed to.

design, license, and construct a dry cask storage facility on' the basis of its past licensing experience. " Affidavit of Frederick C. Sturz of the NRC Staff Regarding NECNP's Environmental Contention 3" (Sturz Affidavit),

dated May 26, 1989, at 11 27, 28; see also " Sworn Testimony of Donald A. Reid, l Michael J. Marian, Rudolph M. Grube, John M. Buchheit, Richard P. Pizzuti, andPeterS.Littlefield,"(LicenseeTestimony)at10-12.

The Nuclear Regulatory Commission staff has reviewed the testimony submitted by Vermont Yankee Power Corporation. The Staff's comments on the Licensee Testimony are provided below.

The Staff concurs with the facts and data set forth in the Licensee Testimony as indicated below. The Staff concurs with Part III, Vermont Yankee Experience / Decision Process'without reservations.

The Staff concurs in general with Part IV, Factors'Affecting Schedular Availability with the following clarifications. In Section C Vermont Yankee states that the time necessary to process an independent spent fuel storage installation (ISFSI) and issue a license would be 1 1/2 to 31/2 years. Licensee Testimony at 11-12. The Staff has previously stated that the time required to license an ISFSI is 1 to 1- 1/2 years.

Sturz Affidavit at 1 28. The Licensee's estimate of the time to design,

license, construct, and implement a dry storage facility is.between four to six years. Licensee Testimony at 12. The Staff notes that these steps in the process will overlap and that six years is a reasonable estimate.  !

The Licensee states that the Staff has not completed any safety evaluations for topical safety analysis reports (TSARS) for dry storage of boiling water reactor (BWR) fuel. Licensee Testimony at 11-13. The NRC f staff has completed safety evaluations for TSARS for dry storage of BWR fuel. "NRC Staff Response to NECNP's Third Set of Interrogatories and Request for Production of Documents to the NRC Staff on the Staff's Environmental Assessment and Finding of No Significant Impact-Spent Fuel Expansion," dated March 14, 1989 at 11-13. The'first was on May 15, 1985 i for General Nuclear Systems, Inc. Castor Ic Topical Report. Id. The l l

safety evaluation (SER) was completed and a letter of approval was issued.

Id. However, the cask vendor did not resubmit an updated TSAR to bring it I into compliance with the Staff's SER. Id. The future availability of this cask is uncertain. The second SER issued for dry storage of BWR fuel )

was on March 22, 1988 for FWEnergy Applications, Inc. Modular Vault Dry Storage Topical Report. The subject of the SER was a vault design, not a dry cask storage design. The Staff concludes that no storage casks for BWR fuel currently have active hRC approval. See Sturz Affidavit at 11.  !

The Staff concurs in Part V, Incremental Environmental Comparison with minor reservations. Section A refers to commitments between the State of Vermont and Vermont Yankee Nuclear Power Corporation which are not the concern of the NRC and the Staff expresses no opinion on these issues. Licensee Testimony at 12-13. Regarding Section C the Staff emphasizes that the environmental impacts of both wet and dry storage are

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over dry cask storage is very small. See Licensee Testimony at 17.

The. Staff concurs with Part IV, Comparative Economic' Costs. .

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Frederick C. Sturz Senior Project Manager.for-The Fuel Cycle' Safety Branch  ;

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Morton B. Fairtile -

Project Manager for '

The Vermont Yanker. Nuclear i Power Plant- )

I Subscribed and Sworn to before me l this 9th day' of June,1989.

Notary Public

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STATEMENT OF PROFESSIONAL QUALIFICATIONS FREDERICK C. STURZ j i

Ny name is Frederick C. Sturz.. I am a Senior Project Manager for the Fuel Cycle Safety Branch in the Division of Industrial and Medical Nuclear Safety in the Office of Nuclear Material Safety and Safeguards, United States Nuclear ,

Regulatory Commission (NRC). I.have served in this Branch since joining'the l

NRC in June 1981. I am responsible for reviewing radiological safety and I environmental impacts of proposed licensing actions for facilities for spent fuel storage, low-level waste treatment and storage, and spent fuel processing.

I was project manager for licensing low-level radioactive waste storage facilities at the Sequoyah Nuclear Plant and at the Susquehanna Steam Electric Station. I was the environmental project manager for the licensing f

of Virginia Electric and Power Company's Surry Independent Spent Fuel Storage .i Installation (ISFSI), Carolina Power and Light's H. B. Robinson ISFSI, and Duke Power Company's Oconee ISFSI. I also assisted in the_ISFSI licensing safety reviews.

From December 1977, until joining the NRC, I was employed by the United States Environmental Protection Agency in the Office of Radiation Programs. As an

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engineer, I performed technical analyses in the nuclear, chemical, and environmental engineering fields. These analyses related to identification of radioactive sources in process waste streams and engineering systems, effluent control, and cost effectiveness of control systems and their. applicability. I

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also analyzed environmental impacts for a variety of nuclear facilities.

l From December 1971 to June 1976, I served as an officer in.the United States Navy. I served in positions in the engineering and operation departments aboard destroyers and as a destroyer squadron staff operations officer.  ;

I graduated from the Pennsylvania State University in December 1971, with a Bachelor of Science degree in Nuclear Engineering.

I attended graduate school at Rensselear Polytechnic Institute and received a Master of Science degree in Environmental Engineering in November 1977.

I am a member of the Health Physics Society.

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. I STATEMENT OF PROFESSIONAL QUALIFICATIONS MORTON B. FAIRTILE j I have served as an AEC/NRC staff member from April.24, 1967, to the present time. In the preceding 14 years I have been an Operating' Reactor Project

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Manager on the following plants: two B&W stations, Crystal River 3 and j Oconee; one CE station, Maine Yankee; four GE. stations, FitzPatrick,' Hatch, j Peach Bottom and Vermont Yankee; and four Westinghouse plants, Ginna, l Kewaunee, Surry and Yankee Rowe. Prior to my Project Management assignments i I worked as a technical reviewer in the Materials and Mechanical Engineering disciplines. I have participated in the review of over 75 nuclear power plants.

I have a BS in Civil Engineering (1950), Professional Engineers' license l (N.Y. 1954) and have been a member of the American Society of Mechanical Engineers since 1967. I have taken graduate courses in Nuclear Engineering (1961and1979)MechanicalEngineering(1962,1963and.1968),Mr,hematics-(1964)andEnvironmentalEngineering(1979). In addition. I have taken many AEC/NRC training courses.

My nuclear related experience began in 1952 on the Savannah River Project.

Prior to sty NRC employment I also worked in the aerospace applications of.

nuclear power and in the design phase, start-up testing and operation of the Fermi sodium cooled fast breeder reactor. I wrote and on November 15, 1973 delivered an invited paper. at the IEEE Nuclear Power Systems Symposium entitled, " Reactor Coolant Leakage Detection Systems." J was the' principal author of the Regulatory Guide on reactor coolant leakage detection' systems and co-authored other Regulatory Guides.

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