ML26022A348
| ML26022A348 | |
| Person / Time | |
|---|---|
| Site: | 05000614 |
| Issue date: | 01/22/2026 |
| From: | Hanson S, Perales M Perales, Allmon & Ice, P.C., San Antonio Bay Estuarine Waterkeeper |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 57585, ASLBP 25-991-01-CP-BD01, 50-614-CP | |
| Download: ML26022A348 (0) | |
Text
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
Long Mott Energy, LLC (Long Mott Generating Station)
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§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 January 22, 2026 SAN ANTONIO BAY ESTUARINE WATERKEEPERS MOTION FOR LEAVE TO FILE OUT OF TIME San Antonio Bay Estuarine Waterkeeper (Waterkeeper or Petitioner) hereby requests a one-day extension of Waterkeepers deadline for the Reply in Support of its December 31, 2025 Motion to Add a New Contention and Amend Contention 4 Based on Long Motts Supplements to the PSAR.1 The original deadline for the filing of Waterkeepers Reply Pleading was January 21, 2026, and Waterkeepers requested extension would make the new deadline January 22, 2026.
The August 28, 2025 Initial Prehearing Order states that a motion for extension of time shall be submitted at least three business days before the due date for the pleading for which an extension is sought.2 It further states, A motion for extension of time must (1) indicate whether the request is opposed or supported by the other participants to the proceeding; and (2) demonstrate appropriate cause that supports permitting the extension.3 This Motion is opposed by both Long Mott Energy, LLC (LME) and NRC Staff.
1 See Exhibit 1.
2 Memorandum and Order (Initial Prehearing Order) (Aug. 28, 2025), at 5.
3 Id.
2 Good cause exists for Waterkeepers filing of this motion less than three business days before the original deadline of January 21, 2026, in accordance with the Initial Prehearing Order. Just before the filing deadline, Counsel for Petitioner, awaiting a document from Petitioners expert, notified counsel for the NRC Staff and LME by email that they were experiencing technical difficulties that delayed his finalizing the document and transmitting it to her for filing. Counsel for Petitioner advised that she intended to seek a one-day extension of time to submit Waterkeepers Reply, though she anticipated needing less time to resolve the issues. By email, today, Counsel for NRC Staff and LME indicated that they both oppose this request.
Waterkeepers counsel had another deadline (to submit a hearing request, with accompanying expert reports) on Tuesday, January 20, 2026, in the matter of: Application by Fermi Equipment Holdco, LLC for Proposed Air Quality Permit Nos. 181009, PSDTX1670, and GHGPSDTX254, pending before the Texas Commission on Environmental Quality. This limited the amount of time available for Counsel to address any technical difficulties ahead of the January 21, 2026 filing deadline in this matter.
Neither NRC Staff nor LME will be prejudiced by this requested one-day extension.
The requested deadline extension is for a Reply to Staffs and LMEs Answers to Waterkeepers Motion to Add a New Contention and Amend Contention 4 Based on Long Motts Supplements to the PSAR. This Reply pleading does not seek to add or amend a contention, but rather, provides responsive arguments in support of the Motion that Waterkeeper timely filed. A one-day extension for filing this Reply will not affect Staff or LME because there is no applicable deadline for Staff or LME to submit further pleadings
3 in response to Waterkeepers Reply. LME and the Staff already filed their Responses a full 14 days after Waterkeepers timely filed Motion.
Waterkeeper respectfully requests the Board grant a one-day extension of Waterkeepers deadline for the Reply in Support of its Motion to Add a New Contention and Amend Contention 4 Based on Long Motts Supplements to the PSAR.
Date: January 22, 2026 Respectfully submitted, Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com Sidra Hanson Texas Bar No. 24149049 sidra@txenvirolaw.com PERALES, ALLMON & ICE, P.C.
1206 San Antonio St.
Austin, Texas 78701 512-469-6000 (t) l 512-482-9346 (f)
Counsel for San Antonio Bay Estuarine Waterkeeper
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
Long Mott Energy, LLC (Long Mott Generating Station)
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§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 January 22, 2026 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I hereby certify that, on January 22, 2026, copies of the foregoing San Antonio Bay Estuarine Waterkeepers Motion for Leave to File Out of Time were served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above-captioned docket.
Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com Sidra Hanson Texas Bar No. 24149049 sidra@txenvirolaw.com PERALES, ALLMON & ICE, P.C.
1206 San Antonio St.
Austin, Texas 78701 512-469-6000 (t) l 512-482-9346 (f)
Counsel for San Antonio Bay Estuarine Waterkeeper
EXHIBIT 1
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
Long Mott Energy, LLC (Long Mott Generating Station)
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§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 January 22, 2026 SAN ANTONIO BAY ESTUARINE WATERKEEPERS REPLY IN SUPPORT OF MOTION TO ADD A NEW CONTENTION AND AMEND CONTENTION 4 BASED ON LONG MOTTS SUPPLEMENTS TO THE PSAR Pursuant to 10 C.F.R. § 2.309(i)(2), San Antonio Bay Estuarine Waterkeeper (Waterkeeper or Petitioner) submits this Reply in Support of its Motion to Add a New Contention and Amend Contention 4 Based on Long Motts Supplements to the PSAR.
I.
Reply to NRC Staffs Answer Staff argue that Waterkeepers Motion to Amend Contention 4 should be denied because Waterkeeper does not identify any requirement to address climate change in a PSAR and requests more than the NRCs rules require. Staff likewise oppose Waterkeepers Motion to add a new contention, arguing that the proposed new contention is not adequately supported. These arguments are addressed in turn below.
2 A.
Motion to Amend Contention 4 Staff maintain that because Waterkeeper has not identified any requirement for the NRC to consider climate change as part of its review of a construction permit application (CPA), by its request to amend Contention 4, Waterkeeper seeks more than is required.1 In its Petition to Intervene and in its Reply in Support of its Petition to Intervene, Waterkeeper explained the basis for its contention that LMEs PSAR and ER failed to consider the effects of climate change and thus were deficient.2 The same rationale applies to its proposed amended Contention 4: PSAR Supplement 2 fails to consider the effects of climate change in its analyses. These flaws propagate into the Environmental Report because it relies on the analyses conducted in the PSAR.
B.
Waterkeepers request to add a new contention is properly supported and raises a legitimate dispute.
The crux of Staffs argument, in response to Waterkeepers proposed new contention, is that neither LMEs PMP and PMF analyses nor its dam failure analyses are the bounding design basis external flooding event analyzed in the LME PSAR. And so, it is not clear how the asserted deficiencies result in the plant not being adequately safe as currently designed or how any regulatory requirement is not met.3 In other words, Staff 1 NRC Staff Answer, pp. 4-5.
2 See, e.g., Waterkeeper Petition to Intervene, pp. 45-51 & Mr. Mitmans Declaration (labeled Exhibit F),
wherein Waterkeeper explained: As a major federal action, LMEs proposed facility must undergo a NEPA review, which must assess the direct, indirect, and cumulative effects of the proposed action. When such a proposed action will have a reasonably foreseeable significant effect on the quality of the human environment an environmental impact statement is required. Here, there is a reasonably foreseeable and potentially significant effect on the quality of the human environment at least due to the risk of accidents.
As drafted, the PSAR and ER obscure the actual risk of accidents because of erroneous assumptions and omissions in these documents, including the failure to adequately address climate change impacts.
3 NRC Staff Answer, pp. 6-7.
3 appear to argue that the deficiencies identified by Waterkeeper in its Motion are not material to the requirements that must be satisfied in this proceeding.
Staffs argument is inconsistent with both LMEs CPA and with the regulatory requirements. PDC 2 in LMEs PSAR incorporates the language from Criterion 2 of the GDCs.4 Under LMEs PDC 2, safety-significant SSCs must be designed to withstand the effects of natural phenomena, such as hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions.5 Section 2.4 of LMEs PSAR, in turn, describes natural phenomena related to hydrology that have the potential to affect the LMGS design basis.6 And it describes the site and safety-related systems, structures, and components (SSC) from the standpoint of hydrologic considerations.7 The PSAR examined several potential flooding scenarios, including: probable maximum flood on streams and rivers, potential dam failures, probable maximum surge and seiche flooding, among others.8 And LME identified the probable maximum storm surge as the bounding flooding event9excluding PMF and PMP and dam failures as the limiting design basis flood.
As Waterkeeper explained in its Motion, with support from Mr. Jeffrey T. Mitman, there are inadequacies in LMEs PMF and PMP and dam failure analyses, rendering them unreliable, and so, this renders LMEs determination of the PMSS as the limiting design 4 Compare 10 C.F.R. § 50.34(a)(3)(i), App. A, Criterion 2, with LME-CPA, p. 5.3 5.3-3 (PDC 2).
5 10 C.F.R. § 50.34(a)(3)(i), App. A, Criterion 2; LME-CPA, p. 5.3-2 (PDC 2).
6 LME-CPA, p. 2.4-1.
7 LME-CPA, p. 2.4-3.
8 Id.
9 Supp. 2, Encl. 5 at 2.4.10-2.
4 basis flood event unreliable and deficient. In other words, had LME performed its analyses correctly, based on reliable assumptions, the final flood elevations for the different scenarios would be different, and one of those scenarios could exceed the existing bounding elevations (the PMSS). It is not Waterkeepers burden to conduct the analyses for each of the scenarios and determine the limiting design basis flood event. Waterkeeper has instead raised legitimate disputes with LMEs analyseswhich affect the bounding event, which, in turn, is used to demonstrate that the SSCs are designed to withstand the effects of natural phenomena. Waterkeepers Motion presents a genuine material dispute in this regard.
NRC Staff next dispute observations of deficiencies noted in Waterkeepers Motion and in Mr. Mitmans Declaration. But these disputes do not change or affect the overall contention raised by Waterkeeperwhich is that the analyses in PSAR Supplement 2 used to determine the limiting design basis flood event and to demonstrate that the SSCs are safely designed to withstand natural phenomena are deficient. For instance, Staff argue that Green Lake was indeed included in LMEs modeling, and thus, there was no gap in LMEs PMF and PMP analyses.10 But Staff miss the point, here.
The deficiency identified in Waterkeepers Motion is that there is a gap between the Guadalupe River model and the Coloma Creek model, not that Green Lake is missing from the model. Mr. Mitmans reference to Green Lake, in his Declaration in support of Waterkeepers Motion, was intended to help illustrate the gap in the model, not as 10 NRC Staffs Answer, p. 7.
5 documentation of the specific gap in the model. That Supplement 2 includes one figure Figure 2.4.3-26, depicting HEC-RAS Cross Section Locationsthat shows Green Lake in the cross sections does not negate Waterkeepers and Mr. Mitmans complaint, which is that there is a gap between the Guadalupe River model and the Coloma Creek model. That is, the land East of the Gudalupe River and West of the LME site is in neither model.
Indeed, Figure 2.4.3-26 does not identify the limits of the Guadalupe River model, whereas other figures do document the extent of the model outline, but do not include Green Lake within those limits.11 Staff further argue that Waterkeepers and Mr. Mitmans references to the left bank elevation are immaterial because they do not affect LMEs conclusion that the PMSS is the bounding event.12 But here again, Staff miss the point.
To prevent water traveling over the left riverbank, the left riverbank must be higher than the flood height along the entire left riverbank, not just at the highest flood elevation.
The PSAR supplement does not demonstrate that this is the case. Instead, it states only that the riverbank is higher at the point of highest flooding.13 But, as Mr. Mitman explains in his declaration:
[T]he elevation along the left riverbank must be higher than the flood height along the entire left riverbank, not just at the point of the highest flood elevation, to prevent water traveling over the left riverbank. PSAR 11 Compare PSAR Supp. 2, Encl. 2, p. 2.4.3-47 (Figure 2.4.3-26), with id., p. 2.4.3-83 (Figure 2.4.3-37) which documents the extent of the model outline and boundary conditions. It is worth noting, here, that there are two pages that include the page number 2.4.3-47one that includes Figure 2.4.3.-1, and another that includes Figure 2.4.3-26. The second onethe one that includes Figure 2.4.3-26is likely misnumbered, as it follows page 2.4.3-71 and precedes 2.4.3-73; there does not appear to be a page bearing the page number 2.4.3-72.
12 NRC Staff Answer, p. 7.
13 Mitman Supplemental Declaration, ¶ 21.
6 Supplement #2 does not demonstrate that this requirement is satisfied. It simply states that the riverbank is higher at the point of highest flooding (the accuracy of which is suspect, as explained above).14 In other words, the concern here is that LMEs analyses fail to consider areas along the left riverbank where its height will not prevent overtopping. Staff point to nothing in the CPA to dispute this observed deficiency. LME used this analysis to identify the limiting design basis flood event, which, in turn, it used to demonstrate that the SSCs are designed to withstand the effects of natural phenomena. Thus, this deficiency is germane to the requirements implicated by LMEs CPA.
Finally, Staff take issue with Waterkeepers argument that the PSAR Supplement 2 is deficient because it fails to consider a hydrologic or seismic failure of the Canyon Dam.
Staff maintain that Waterkeepers argument that an overtopping event will lead to higher flood levels near the LME site than the failure mode analyzed in Supplement 2 is not adequately supported. But this argument was supported by Mr. Mitman, a nuclear engineer with significant expertise in nuclear power, risk analysis and the impact of external events on nuclear power plant risk.15 Moreover, Waterkeepers argument is that in its PSAR Supplement 2, LME referenced a Staff guidance documentJLD-ISG-2013-01to demonstrate compliance with regulatory requirements.16 And so, LME bears the burden of demonstrating that it performed the required analysesincluding by demonstrating 14 Id.
15 Mitman Declaration in Support of Waterkeepers Motion, ¶ 2.
16 See Intl Uranium (USA) Corp. (Request for Materials License Amendment), CLI-00-1, 51 NRC 9, 19 (2000) (guidance documents merely constitute NRC Staff advice on one or more possible methods licensees may use to meet particular regulatory requirements).
7 compliance with the guidance document methods that it referenced. This it failed to do. As with the deficiencies discussed above, this deficiency is germane because LME used this analysis to support its determination of the limiting design basis flood event, which, in turn, it used to demonstrate that the SSCs are designed to withstand the effects of natural phenomena.
In sum, Waterkeeper presented a germane, legitimate dispute in its Motion, supported by Mr. Mitmans Declaration, identifying deficiencies in the analyses in LMEs PSAR Supplement 2analyses that inform LMEs efforts to demonstrate compliance with PDC 2 and Rule 50.34.
II.
Reply to LMEs Answer By its Answer, LME raises arguments in opposition to Waterkeepers Motion that are similar to Staffs arguments. Thus, to the extent the discussion above (responding to Staffs arguments) addresses LMEs arguments, Waterkeeper incorporates those arguments by reference in response to LMEs Answer opposing Waterkeepers Motion.
A.
Motion to Amend Contention 4 LME argues that because the applicable regulations do not require consideration of the impacts of climate change in safety-related or environmental analyses, Waterkeepers Motion to amend Contention 4 should be denied.17 This argument is similar to the one presented by Staff, and Waterkeeper incorporates by reference its response to Staffs argument.
17 LME Answer, pp. 2-3.
8 B.
Waterkeepers Motion to add a new contention is properly supported and presents a legitimate, material dispute.
LME argues that Waterkeepers request to add a new contention should be denied because it fails to identify an unmet requirement. Like NRC Staff, LME disputes the deficiencies identified by Waterkeeper in its Motion, and it argues that Waterkeepers proposed contention is immaterial and inadmissible.
- 1.
Waterkeeper identified requirements that LME failed to satisfy.
As explained above in response to NRC Staffs argument, the analyses that are the subject of PSAR Supplement 2 and the subject of Waterkeepers Motion affect LMEs determination of the limiting design basis flood event, which, in turn, it used to demonstrate that the safety-significant SSCs are designed to withstand the effects of natural phenomenaas required by Rule 50.34(a)(2)-(4).18 This is explained in LMEs PSAR.
The cases cited by LME in support of its argument are not relevant here. For instance, Commonwealth Edison Co. (Zion Nuclear Power Station, Units 1 and 2), CLI-99-4, 49 NRC 185, 194 (1999), involved a petitioner who, on appeal, attempted to support his standing allegations with newly minted arguments. The petitioner claimed that these newly minted standing arguments were included in one of his contentionsContention 10.
The NRC concluded that the petitioners standing arguments were neither presented in the discussion labeled Standing in the petitioners Board pleading, nor were they clearly referenced in the petitioners Contention 10 as support for his alleged standing. In rejecting 18 As discussed above, PDC 2 in LMEs PSAR incorporates the language from Criterion 2 of the GDCs.
Under PDC 2, SSCs must be designed to withstand the effects of natural phenomena, such as hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions. Compare 10 C.F.R.
§ 50.34(a)(3)(i), App. A, Criterion 2, with LME-CPA, p. 5.3 5.3-3 (PDC 2).
9 petitioners argument on appeal, the NRC explained that adjudicatory boards are not expected to sift through pleadings to uncover arguments not advanced by litigants. That is not the case here.
Waterkeeper stated its proposed contention, provided a basis for it, included a supporting declaration, and cited relevant regulationsregulations that were referenced in LMEs own CPA. Indeed, LME provided Supplement 2 because it was required to do so to support its determination of the limiting design basis flood event, which, in turn, was necessary to support its demonstration that the safety-significant SSCs are designed to withstand the effects of natural phenomena. LMEs implication that Waterkeepers Motion amounted to only notice pleading is simply inaccurate.
- 2.
Waterkeeper identified deficiencies in Supplement 2 that demonstrate a legitimate, material dispute.
Next, LME raises many of the same arguments that NRC Staff raiseddisputing the deficiencies identified by Waterkeeper in its Motion. But Waterkeepers Motion was supported by the sworn declaration by Mr. Mitman, a nuclear engineer with significant expertise in nuclear power, risk analysis and the impact of external events on nuclear power plant risk.19 It was also supported by references to LMEs PSAR Supplement 2 and specific information included within the supplement. That there may be inconsistencies in Supplement 2 demonstrates that there is a material dispute regarding the analyses performed by LME in support of its PSAR Supplement 2.
19 Mitman Declaration in Support of Waterkeepers Motion, ¶ 2.
10 LME challenges Waterkeepers critique of LMEs flooding analysis and its riverbank elevations. It does so by erecting a strawmanarguing that Waterkeeper made no attempt to engage with the modeling tools LME used, and that Waterkeepers declarant does not possess the educational background or professional work experience to examine the modeling.20 But there are several problems with this argument. First, although the modeling software is publicly available, LMEs specific model, with its inputs and assumptions, is not publicly available. Second, Waterkeeper did not attempt to challenge the modeling tools used by LME. Third, Waterkeeper does not bear the burden, at this juncture, of performing its own modeling exercise to verify the representations and analyses in LMEs application.
LME also criticizes Waterkeeper for referencing a Google map in support of its argument regarding the riverbank elevations and argues that Waterkeeper offered no modeling of its own to demonstrate that a PMF event or dam failure could yield water heights exceeding 34 to 36 feet the specific locations identified by Waterkeeper.21 But LME misunderstands Waterkeepers contention.
As Mr. Mitman explains in his supplemental Declaration, Waterkeepers point is that PSAR Supplement 2 fails to demonstrate that the elevation along the entire left riverbank is higher than the highest flood elevation.22 To illustrate this deficiency in the analysis, Mr. Mitman referenced Google Earthnot to prove the precise elevations along 20 LME Answer, p. 7 & n.33.
21 Id. at 8.
22 Mitman Supplemental Declaration, ¶ 21.
11 the left riverbank, but rather, to demonstrate that there is a reliable basis for his concern that the overtopping of the riverbank could occur, allowing flood waters to flow towards the LME site. LMEs analysis fails to reliably and accurately demonstrate that it excluded this possibility.
In sum, Waterkeeper raises a genuine dispute regarding the riverbank elevations that LME relied on to support its flooding analyses. This affected LMEs determination of the bounding event that it used to demonstrate that its safety-significant SSCs are designed to withstand the effects of natural phenomena.
Next, LME takes issue with Waterkeepers comments regarding Green Lake. Like Staff, LME points to PSAR Figure 2.4.3-26 to argue that there is no gap in its modeling.23 However, Waterkeepers argument was that there is a gap between the Guadalupe River model and the Coloma Creek model, not that Green Lake is missing from the model. As explained above and in Mr. Mitmans supplemental Declaration, the fact that Green Lake is depicted in one of the Figures in Supplement 2 does not negate Waterkeepers central criticism that there is a gap in the modeling. Mr. Mitman explains, LME offers no model documentation showing that the Guadalupe River model and the Coloma Creek model cover all the relevant area.24 LME also argues that Waterkeepers critique of LMEs Potential Dam Failures discussion is untimely because the subject of Waterkeepers critique is not new. LME 23 LME Answer, pp. 8-9.
24 Mitman Supplemental Declaration, ¶ 15.
12 maintains that Waterkeeper fails to present good cause for raising this critique only now, instead of at the outset of this proceeding.25 While LMEs potential dam failure analysis in PSAR supplement 2 may not be new, its reference to and reliance on a guidance document is new. And, it indicates that LME is relying on the guidance document to demonstrate compliance with regulatory requirements.26 LME argues that the guidance only recommends such analyses (of potential seismic or hydraulic failure modes) if certain preconditions are not met, and Waterkeeper does not assert that these preconditions are satisfied here.27 However, it is LME that bears the burden of demonstrating that the preconditions do not apply here, not Waterkeeper.
Finally, LME argues that Waterkeeper failed to confront publicly-available information showing that Canyon Dam withstands its PMF and is located in the lowest seismic hazard zone in the United States.28 Setting aside that Waterkeeper does not bear the burden of providing an alternative flooding analysis to support its contention, Mr.
Mitman explains, in his supplemental Declaration, that publicly-available information (cited by LME) reveals no statement that the Canyon Dam can withstand its PMF. In fact, the U.S. Army Corp of Engineers report comes to the opposite conclusion... the 25 LMEs Answer, p. 9.
26 See Intl Uranium (USA) Corp. (Request for Materials License Amendment), CLI-00-1, 51 NRC 9, 19 (2000) (guidance documents merely constitute NRC Staff advice on one or more possible methods licensees may use to meet particular regulatory requirements).
27 LME Answer, p. 10.
28 LME Answer, p. 10, n.53.
13 PMF exceeds the design by 4.3 feet.29 Accordingly, it is LME that has failed to demonstrate that the preconditions in the guidance document do not apply here.
In sum, LME, like NRC Staff, dispute the deficiencies identified by Waterkeeper in its Motion to add a new contention, but their disputes concern the merits of the PSAR.
Neither LME nor NRC Staff have offered any justification for rendering Waterkeepers proposed new contention inadmissible.
III.
Conclusion For the foregoing reasons and those described in its Motion, Waterkeepers Motion to Add a New Contention and Amend Contention 4 Based on Long Motts Supplements to the PSAR should be granted.
Date: January 22, 2026 Respectfully submitted, Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com Sidra Hanson Texas Bar No. 24149049 sidra@txenvirolaw.com PERALES, ALLMON & ICE, P.C.
1206 San Antonio St.
Austin, Texas 78701 512-469-6000 (t) l 512-482-9346 (f)
Counsel for San Antonio Bay Estuarine Waterkeeper 29 Mitman Supp. Declaration, ¶¶ 25, 26.
14 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
Long Mott Energy, LLC (Long Mott Generating Station)
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§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 January 22, 2026 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I hereby certify that, on January 22, 2026, copies of the foregoing San Antonio Bay Estuarine Waterkeepers Reply in Support of its Motion to Add a New Contention and Amend Contention 4 Based on Long Motts Supplements to the PSAR were served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above-captioned docket.
Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com Sidra Hanson Texas Bar No. 24149049 sidra@txenvirolaw.com PERALES, ALLMON & ICE, P.C.
1206 San Antonio St.
Austin, Texas 78701 512-469-6000 (t) l 512-482-9346 (f)
Counsel for San Antonio Bay Estuarine Waterkeeper
ENCLOSURE A
Declaration of Jeffrey T. Mitman Page 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
Long Mott Energy, LLC (Long Mott Generating Station)
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§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 January 22, 2026 SUPPLEMENTAL DECLARATION OF JEFFREY T. MITMAN IN SUPPORT OF MOTION TO ADD A NEW CONTENTION AND AMEND CONTENTION 4 I, Jeffrey T. Mitman, declare as follows:
- 1. My name is Jeffrey T. Mitman. I am over eighteen (18) years of age and of sound mind, have never been convicted of a felony, and am otherwise capable of making this declaration. The information in this declaration is based on my personal experience and my review of documents filed in this proceeding and publicly available information.
Expert Qualifications and Relevant Experience
- 2. By education and experience, I am a nuclear engineer, with a significant level of expertise in nuclear power, risk analysis and the impact of external events on nuclear power plant risk.
- 3. As set forth in my attached Curriculum Vitae (Enclosure A-1), I have more than 40 years of experience in the nuclear industry and 16 years as a regulator with the U.S.
Nuclear Regulatory Commission (NRC). My experience includes 16 years on the technical staff of the NRC as a Reliability and Risk Analyst. During my last 15 years at the NRC, I served as Senior Reliability and Risk Analyst, with significant responsibility for managing a number of risk analysis projects and teams.
- 4. During my employment in the nuclear industry and the NRC, I became very familiar with NRC regulations and guidance regarding nuclear power plant safety, and with
Declaration of Jeffrey T. Mitman Page 2 the application of risk analysis to reactor safety analysis. I am also familiar with the NRCs requirements regarding Preliminary and Final Safety Analysis Reports.
- 5. As an NRC Staff member, I participated in NRC safety reviews and performed risk analysis on U.S. nuclear reactors. I also participated in reviews related to the risk to Oconee Nuclear Plant, Units 1, 2 and 3 (Oconee) posed by potential failure of the upstream Jocassee Dam. In addition, I coauthored a generic study by NRC of dam failure risk, with particular application to Oconee. I also worked on the NRC post-Fukushima analysis, which included preparing and reviewing flooding analysis methodologies and procedures.
- 6. In 2021, I retired from the NRC and became a private consultant. In that role, I have participated as an expert consultant to environmental organizations in the subsequent license renewal proceedings for the Oconee and North Anna reactors and in the administrative proceeding for revisions to the License Renewal Generic Environmental Impact Statement.
New Contention Addressing PSAR Supplement 2, Enclosures 2, 3, and 5
- 4. Following my review of Long Mott Energy, LLCs (LME) PSAR Supplement 2, I provided a Declaration in support of Waterkeepers Motion for a new contention, explaining my concerns regarding LMEs Probable Maximum Precipitation (PMP) and Probable Maximum Flood (PMF) analyses; potential dam failures analysis; and flood protection analysis.
- 5. I am submitting this supplemental Declaration in support of Waterkeepers Reply to the Answers submitted in response to Waterkeepers December 31, 2025 Motion and my initial Declaration. I focus solely on clarifying and explaining my position in response to the arguments raised by LME and the NRC Staff.
- 6. The omissions and deficiencies I identified in my initial Declaration and have responded to in this supplemental Declaration are germane because as written, the PSAR excludes PMP/PMF and dam failures from consideration as the potential limiting design basis flood. If a PMP/PMF or dam failure-induced flood does, in fact, approach the LME site, it may be more limiting than the probable maximum
Declaration of Jeffrey T. Mitman Page 3 storm surge-induced flood. Thus, the safety-significant structures, systems and components (SSC), as currently designed, may not be protected from these natural phenomena as required by 10 C.F.R. § 50.34.
- 7. SSCs must be designed to withstand the effects of natural phenomena, such as hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions.1
- 8. As I demonstrated and emphasized in my initial Declaration, the crux of my analysis for Waterkeepers new Contention is the significant effect of these PSAR Supplement #2 deficiencies on what flood waters would reach the LME site and inundate it.2
- 9. Thus, I address several of LME and the Staffs arguments in turn below.
Gap Between the Guadalupe River Model and the Coloma Creek Model
- 10. First, I address the arguments related to my identification of a gap in LMEs modeling and Green Lake. My initial Declaration3 describes a gap between the Guadalupe River model and the Coloma Creek model. It uses Green Lake as an illustration of that gap, i.e., an exampleGreen Lake is not the gap itself.
- 11. Both the Staffs Answer4 and LMEs Answer5 argue that there is no gap by stating that Green Lake is included in LMEs modeling. However, this assertion misunderstands and mischaracterizes my critique of LMEs analyses.
- 12. First, Green Lake is an examplea point in space to observe the gap in LMEs modeling, but it does not document the extent of the gap.
- 13. Second, both Answers reference PSAR Supplement 2, Enclosure 2s Figure 2.4.3-26, which does include Green Lake, and they assert that this Figure constitutes evidence that there is no gap because Green Lake is included in several of the cross sections in that Figure. However, this Figure does not identify the limits of the 1 10 C.F.R. § 50.34(a)(3)(i), App. A, Criterion 2 (GDC 2); LME-CPA, p. 5.3-2 (PDC 2).
2 E.g., Mitman Declaration, ¶ 11, 16, 17, 20, 28. My point is not limited to these examples.
3 Mitman Declaration, ¶ 16.
4 Staff Answer, p. 7.
5 LME Anwer, p. 9.
Declaration of Jeffrey T. Mitman Page 4 Guadalupe River model, compared to, for example, Enclosure 2s Figure 2.3.4-37, Guadalupe River Basin, documents the extent of the Guadalupe River model.
- 14. LMEs Answer ignores my observation when it offers as evidence, the following statement in Footnote 45:
See, e.g., Encl. 2 at 2.4.3-17 (The first analysis is the PMF over Guadalupe River Basin combined with 500-year flow from San Antonio River Basin. The second analysis is the PMF over San Antonio River Basin combined with 500-year flow from Guadalupe River Basin.)
(Emphasis in original.)
- 15. This statement fails to properly engage with my analysis, as I was referring to a gap between the Guadalupe River model and the Coloma Creek model, not between the San Antonio River model and the Guadalupe River model. LME offers no model documentation showing that the Guadalupe River model and the Coloma Creek model cover all the relevant area.
- 16. This omission is germane because as written, the PSAR excludes PMP/PMF and dam failures from consideration as the potential limiting design basis flood. If a PMP/PMF or dam failure-induced flood does, in fact, approach the LME site, it may be more limiting than the probable maximum storm surge-induced flood. Thus, the SSCs as currently designed, may not be protected from these natural phenomena as required by 10 C.F.R. § 50.34.
Modeling of Bounding Water Levels for a PMF Event and Hypothetical Dam Failure
- 17. Second, I address LMEs justification of its modeling of bounding water levels for a PMF event and a hypothetical dam failure. LMEs Answer states:
LMEs updated analyses showed that the bounding water levels for a PMF event, 40.80 ft NAVD 88, and a hypothetical dam failure, 38.42 ft.
NAVD 88, would occur along a barge canal (located between the Guadalupe River and the LMGS site), known as station 1.255, which has a corresponding embankment elevation of 41.72 ft NAVD 88.6 6 LME Answer, p. 8.
Declaration of Jeffrey T. Mitman Page 5
- 18. The corresponding footnote identifies the source of these elevations as PSAR Supplement 2, Enclosure 2 at 2.4.3-18, and Enclosure 3 at 2.4.4-13, respectively.7 identifies the peak dam failure flood elevation location as station 1.255 and identifies the corresponding riverbank elevation as 41.72 feet. However, does not identify the peak PMF flood elevation location at station 1.255. Instead, it states:
This elevation is the average of Stations (STA) 8.7744 and STA 11.1811 from HEC-RAS (Hydrologic Engineering Centers River Analysis System). The left bank elevation at this location is 41.72 ft (12.7 m)
NAVD 88, which indicates that the left bank of the river is not overtopped at the site location.8
- 19. The corresponding Figures9 delineating the respective station locations show that both locations (i.e., station 1.255 and the average of stations 8.7744 and 11.1811) are in proximity to each other. Supplement 2 indicates that these two apparently distinct locations have the identical riverbank elevation to the 100th of a foot, i.e.,
41.72 feet. Based on my professional experience, it is unusual, and even unlikely, for these two distinct locations to have the exact same elevations.
- 20. Using Google Earth Pro,10 I observe that at a cross section near and parallel to river station 11.1811 cross section, but about 500 feet south of Texas State Highway 35 (at a point near the barge canal), the maximum elevation on the left riverbank is only 36 feet. Thus, the LME-calculated flood level of 40.80 feet at this Google Earth Pro-identified location would overtop the riverbank, allowing flood waters to flow towards the LME site. But if the embankment is earthen, with overtopping, the earthen embankment will quickly erode, allowing additional flood waters to flow across the overtopped area and cause a breach. See Figure 1 below.
7 LME Answer, p. 8 n.40.
8 PSAR Supplement 2, Enclosure 2, at 2.4.3-4.
9 Figure 2.4.4-6 and Figure 2.4.3-47, respectively, which I reference in my December 31, 2025 Declaration on this topic.
10 To be clear, I am not offering a Google Earth Pro image as definitive evidence of the riverbank elevation.
I was not tasked with performing such an exercisei.e., identifying the elevation of the entire length of the left riverbank. I offer this image only for demonstrative purposes.
Declaration of Jeffrey T. Mitman Page 6
- 21. In any case, assuming that the riverbank elevation in this vicinity is 41.72 feet, the elevation along the left riverbank must be higher than the flood height along the entire left riverbank, not just at the point of the highest flood elevation, to prevent water traveling over the left riverbank. PSAR Supplement #2 does not demonstrate that this requirement is satisfied. It simply states that the riverbank is higher at the point of highest flooding (the accuracy of which is suspect, as explained above).
- 22. As I discuss in the subsection above, this omission is germane because the PSAR excludes PMP/PMF and dam failures from consideration as the potential limiting design basis flood. If a PMP/PMF or dam failure-induced flood is more limiting than the probable maximum storm surge-induced flood, then the SSCs, as currently designed, may not be protected from these natural phenomena as required by 10 C.F.R. § 50.34.
Canyon Dam Overtopping (Hydraulic) and Higher Flood Levels Near the LME Site
- 23. The Staff assert that my statement that a Canyon Dam overtopping event will almost certainly lead to higher flood levels near the LME site than the failure mode analyzed in Supplement 2 is speculation.11 This statement is based on my professional expertise and experience, not speculation. Sunny day and overtopping failures constitute two different scenarios for calculating potential flood levels and risks. Overtopping typically results in higher peak flood levels and breach discharge because a reservoir is at its maximum level before breachingas compared to a sunny day failure at normal pool levels. Additionally, compounding flows from an overtopping event can combine with flood levels from a storm, exacerbating peak flood levels in comparison to a sunny day event.
11 Staff Answer, p. 9.
Declaration of Jeffrey T. Mitman Page 7 Figure 1: Example Google Earth Pro Elevation Cross Section Near and Parallel to River Station 11.1811 Cross Section, Approximately 500 Feet South of Texas State Highway 35
Declaration of Jeffrey T. Mitman Page 8 LMEs Use of USACE Canyon Dam Water Control Manual
- 24. Third, I address the challenges to my reference to JLD-ISG-2013-01 and its guidance for performing analysis of dam failure from overtopping and seismic events. In its Answer, LME states: The guidance only recommends such analyses if certain preconditions are metnamely, that the dam cannot withstand its location-specific PMF or seismic hazards, respectively. Waterkeeper does not assert that either precondition is satisfied here.12 LME also provides: Waterkeeper did not even confront basic publicly-available information showing the Canyon Dam withstands its PMF.... See, e.g., USACE, Canyon Dam Water Control Manual at A-4 [PDF p. 104] (Sept. 2018) (dam height 974.0 ft. versus PMF height 973.4)[.]13
- 25. However, my review of the Canyon Dam Water Control Manual reveals no statement that the Canyon Dam can withstand its PMF. In fact, the U.S. Army Corp of Engineers report comes to the opposite conclusion.
- 26. The reports Table on Page XV, Pertinent Data - Canyon Dam and Lake, states that the Max. Design Water Surface (1959 Study) elevation is 969.1 feet while the PMF Design Water Surface (1983 Study) indicates that the PMF elevation is 973.4 feet. Thus, the PMF exceeds the design by 4.3 feet. The report also states:
From the Canyon Lake, Guadalupe River, Guadalupe River Basin, Dam Safety Assurance Study, Hydrology and Hydraulics, March 1983 report, the design wind speed for the Probable Maximum Flood (PMF) is 57 mph, the fetch for wind setup is 5.90 miles and the needed freeboard of 5.6 feet. This freeboard was computed for a Probable Maximum Flood (PMF) elevation of 973.4 feet.14
- 27. This discussion ends with the conclusion that: Since top of dam is at elevation 974.0 feet, the freeboard is inadequate.15
- 28. The subsection Probable Maximum Flood Hydrographs states:
The routing computations for flow into a full reservoir indicated that the lake would rise to a maximum level of 973.4 feet and the peak inflow 12 LME Answer, p. 10 n.52.
13 Id.
14 USACE, Canyon Dam Water Control Manual, at 4-10.
15 Id. (emphasis added).
Declaration of Jeffrey T. Mitman Page 9 would be 750,641 cfs with a volume 1,748,000 acre-feet. Freeboard requirement based on design wind speed of 57 mph is 5.6 feet for the PMF. Thus freeboard is deficient by approximately 5 feet.16
- 29. The Figure titled Canyon Dam Stage Frequency documents the computed stage flood elevation in feet versus annual chance of exceedance. The frequency for a PMF event appears to be 2E-4 per year. This PMF frequency would qualify as a LMGS design basis event (DBE) if the LMGS criteria were applied, as the DBE range is from 1E-4 to 1E-2 per year.
- 30. Thus, the JLD-ISG-2013-01 Staff position that A dam should be assumed to fail due to hydrologic hazard if it cannot withstand its basin specific PMF, with associated effects is not met.
Watersheds Dams in a Low Seismic Hazard Zone
- 31. Finally, the JLD-ISG-2013-01 Staff position on seismic failures is, A dam should be assumed to fail... if it cannot withstand the more severe of the following combinations:
- 10-4 annual exceedance seismic hazard combined with a 25-year flood
- half of the 10-4 ground motion, combined with a 500-year flood.17 LME offers no analysis of the ISG exclusion criteria.
- 32. LME referenced and relied on this ISG to satisfy PDC 2, Design bases for protection against natural phenomena.18 As discussed in Waterkeeper's August 11, 2025 petition to intervene, PDC 2 requires that safety-significant structures, systems and components shall be designed to withstand the effects of natural phenomena.
These phenomena include floods, such as floods from dam failures. And, as articulated in the ISG, these include dam failures from all sources, including seismic and overtopping failures.
16 Id. at 8-5 (emphasis added) 17 JLD-ISG-2013-01, at 1-8.
18 LME-CPA, p. 5.3-2 (PDC 2); PSAR Supp. 2, Encl. 3, p. 2.4.4-20 (referencing JLD-ISG-2013-01).
Declaration of Jeffrey T. Mitman Page 10 Conclusion
- 33. The omissions and deficiencies I identified in my initial Declaration and responded to in this supplemental Declaration are germane because as written, the PSAR excludes PMP/PMF events and dam failures from consideration as the potential limiting design basis flood. If a PMP/PMF or dam failure induced flood is more severe than the probable maximum storm surge induced flood, then the safety-significant SSCs, as currently designed, may not be protected from these natural phenomena as required by 10 C.F.R. § 50.34.
Declaration Signature
- 34. My name is Jeffrey T. Mitman, my date of birth is January 7, 1957, and my address is 18407 Jerusalem Church Road, Poolesville, Maryland 20837, USA. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
Executed on the 22nd day of January, 2026, in accordance with 10 C.F.R. § 2.304(d).
Signed (electronically) by Jeffrey T. Mitman Jeffrey T. Mitman 18407 Jerusalem Church Road Poolesville, Maryland 20837, USA 301-633-7525 jmitman@gmail.com
ENCLOSURE A-1
CURRICULUM VITAE FOR JEFFREY T. MITMAN Poolesville, MD December 2025 QUALIFICATIONS Reliability and risk analyst with more than 45 years experience in the nuclear industry. Skills include evaluation of probabilistic risk analyses (PRA) and management of PRA projects and teams. Highly experienced in low power and shutdown (LPSD) risk modeling issues. Solid record of bringing projects in on schedule and budget.
MAJOR ACCOMPLISHMENTS Transitioned NRC to detailed PRA models for LPSD significance determinations process evaluations.
Guided development of and managed industrys first configuration risk management software tool.
Obtained regulatory approval of EPRIs risk informed in-service inspection (RI-ISI) methodology.
Managed first PRA of bolted spent fuel storage cask.
EXPERIENCE PRIVATE CONSULTANT (Poolesville, MD)
Nuclear Risk Analyst 2021-Present Reviewed North Anna Subsequent License Renewal application and prepared technical report on adequacy of environmental and safety analyses.
Reviewed Oconee Subsequent License Renewal application and prepared technical report on adequacy of environmental and safety analyses to address flooding risks.
Reviewed and submitted comments on NRCs draft (2023) Generic Environmental Impact Statement (NUREG-1437 Revision 2).
US NUCLEAR REGULATORY COMMISSION (Rockville, MD) 2005 - 2021 Senior Reliability and Risk Analyst (NRC Office of Nuclear Reactor Regulation)
Conducted Significance Determination Process (SDP) evaluations of reactor events including development and/or modification of required risk models.
Served as lead analyst for low power and shutdown event issues and concerns.
Guided development of shutdown Standardized Plant Analysis Risk (SPAR) models.
Conducted extensive Human Reliability Analysis (HRA).
Evaluated external event risk from dam failures.
Served on NRCs Japan Team (part of USAID disaster assistance response team for Fukushima Daiichi accident), providing technical advice and support through the U.S. Ambassador to Japanese government.
Participated in post NRCs Fukushima Near Term Task Force (NTTF) flooding guidance development.
Developed NRCs guidance on crediting FLEX in risk-informed regulatory applications.
Advised NRC National Fire Protection Association (NFPA) 805 team on issues related to shutdown fire risk.
Performed evaluations of risk informed license applications.
Reliability and Risk Analyst (NRC Office of Nuclear Regulatory Research)
Project Manager for the development of shutdown SPAR models ERIN ENGINEERING AND RESEARCH, INC. (Walnut Creek, CA) 2004 - 2005 Lead Senior Engineer Prepared configuration risk management evaluation of at-power fire risk.
Prepared configuration risk management evaluation of loss of offsite power.
ABE STAFFING SERVICES (Palo Alto, CA) 2003 - 2005 Consultant to EPRI Brought project and team to closure involving Dry Cask Storage PRA involving Transnuclear bolted cask containing PWR fuel.
J e f f r e y T M i t m a n P a g e l 2 EPRI (Palo Alto, CA) 1998 - 2003 Project Manager Outage Risk Assessment and Management (ORAM-Sentinel)
- Grew first of a kind software application for performing configuration risk management in nuclear power plants.
Conducted research in low power and shutdown risk; shutdown initiating event and event frequency derivation.
Delivered multiple versions (including alpha, beta & production), testing and full documentation.
Administered utility user group, marketing, contract preparation, technology transfer, technical report publication and training.
Actively managed both development and application contracts with multiple suppliers and customers.
Managed annual $1M budget.
Dry Cask Storage PRA: Initiated innovative analysis of Transnuclear cask containing PWR fuel.
Managed unique team with diverse experience in both cask design and PRA backgrounds.
Risk Informed In-service Inspections Project (RI-ISI): Lead team in obtaining regulatory approval of methodology to safely reduce piping weld inspection requirements using combination of probabilistic and degradation analysis.
Responsible for methodology finalization and acceptance by industry and U.S. NRC.
Conducted marketing, sales, contract preparation, technology transfer, training and technical report publication.
Actively managed both development and application contracts with both suppliers and customers.
Managed annual $1M budget.
Human Reliability Analysis Project: Managed project to bring consistency on industry use of HRA methods.
Responsible for EPRI HRA area, including development of HRA Calculator software and establishment of associated users group.
ERIN ENGINEERING AND RESEARCH, INC. (Palo Alto, CA) 1992 - 1998 Lead Senior Engineer Collaborated with EPRI ORAM-SENTINEL Project Manager in project development and administration, user group administration, contract preparation, technology transfer workshops, technical report generation and editing. Performed ORAM analysis of the Diablo Canyon plant. Performed ORAM Probabilistic Analysis of Perry spent fuel pool. Drafted and edited ORAM V2.0 Users Manual. Assisted in ORAM-SENTINEL software design, performed software debugging. Principle researcher and author of BWR outage contingency report. Prepared marketing and training, materials.
ABB IMPELL CORPORATION (King of Prussia, PA) 1990 - 1992 Lead Senior Engineer Design Basis Documentation: directed team of three engineers to review PECO Feedwater System Design. Wrote Design Basis Documentation reports for Limerick and Peach Bottom power plants, identifying licensing and design concerns by reviewing the system design as documented in drawings, calculations, vendor manuals, Technical Specifications, UFSAR, SER, SRP, 10CFR50.59 safety evaluations etc. and by interfacing with utility engineering personnel. Prepared Engineering Change Requests as necessary.
Shift Outages: during Limerick Nuclear Power Plant refueling / maintenance outage. Coordinated all shift maintenance work and testing. Collaborated with all groups in power plant, allocating resources as needed to maintain schedule and reporting to senior plant outage management. Performed system reviews prior to placing them back in service. Conducted shift outage meetings. Tracked work group performance against schedule. Advised utility management on techniques for schedule and outage organizational improvements.
GENERAL ELECTRIC COMPANY (San Jose, CA)
Experience Prior to 1990 Startup-Test Engineer
J e f f r e y T M i t m a n P a g e l 3 Shift Startup Engineer: During power ascension phase coordinated all system testing on shift and startup interface with operations. During preoperational phase, acted as operations shift supervisor responsible for coordinating all system testing and flushing on shift from main control room. Updated senior utility management daily on testing status.
Additional positions: Shift Technical Advisor, Test Engineer, Lead QC / Welding Inspector.
EDUCATION / PROFESSIONAL DEVELOPMENT BSE, Nuclear Engineering, University of Michigan, Ann Arbor, MI.
Introductory VBA class, University of California, Berkeley, CA.
Misc. business courses at various colleges and universities.
Senior Reactor Operator Certified.
GE Station Nuclear Engineering.
Effective Utilization of PSA, ERIN Engineering & Research, Walnut Creek, CA.
PROFESSIONAL ASSOCIATIONS American Nuclear Society (ANS) member since 1978.
ANS Nuclear elected member of Installation Safety Division Executive Committee 2015 to 2021.
ANS Risk Informed Standards Committee (RISC).
ANS/ASME Risk Informed Standards Writing Group on Shutdown PRA Standard.
ASME Section XI, Working Group on Implementation of Risk Based Examination.
MIT Professional Summer Programs Guest Lecturer at Risk-Informed Operational Decision Management Course.
PAPERS
- 1. Technical Challenges Associated with Shutdown Risk when Licensing Advanced Light Water Reactors, PSAM 12 2014. Co-author.
- 2. Comparing Various HRA Methods to Evaluate Their Impact on the results of a Shutdown Risk Analysis during PWR Reduced Inventory, PSAM11 2012. Co-author.
- 3. Uncertainty Analysis for Large Dam Failure Frequencies Based on Historical Data, PSAM11 2012. Co-author.
- 4. An Assessment of Large Dam Failure Frequencies Based on US Historical Data, PSA 2011. Co-author.
- 5. Development of PRA Model for BWR Shutdown Modes 4 and 5 Integrated in SPAR Model, to be presented at PSAM10 2010. Co-author.
- 6. Development of Standardized Probabilistic Risk Assessment Models for Shutdown Operations Integrated in SPAR Level 1 Model, PSAM9 2008. Co-author.
- 7. Probabilistic Risk Assessment of Bolted Dry Spent Fuel Storage Cask, Presented at ICONE12. 2004. Co-author.
- 8. Low Power and Shutdown Risk Assessment Benchmarking, Presented at PSA 02 2002. Co-author.
- 10. Derivation of Shutdown Initiating Event Frequencies, Presented at PSAM5 2000. Co-author.
- 11. Quantitative Assessment of a Risk Informed Inspection Strategy for BWR Weld Overlays, Presented at ICONE 8 2000. Co-author.
- 12. EPRI RI-ISI Methodology and the Risk Impacts of Implementation, Presented at SMiRT 11 1999. Co-author.
- 13. Application of Markov Models and Service Data to Evaluate the Influence of Inspection on Pipe Rupture Frequencies published. PVP 1999. Co-author.
- 14. Progress in Risk Evaluation of Outages, International Conference on the Commercial and Operational Benefits of PSA. 1997. Co-author.
- 15. Control of Reactor Vessel Temperature/Pressure during Shutdown, GE SIL 357. June 1981. Co-author
J e f f r e y T M i t m a n P a g e l 4 SOFTWARE
REPORTS / STANDARDS
- 1. Requirements for Low Power and Shutdown PRA - ANS/ASME-58.22-2014 (Trial Use Standard).
- 2. Probabilistic Risk Assessment (PRA) of Bolted Storage Casks: Quantification and Analysis Report, EPRI 2003. 1002877. PM.
2002. 1003465. PM and principal investigator.
- 5. Guidance for Incorporating Organizational Factors into Nuclear Power Plant Risk Assessments: Phase 1 Workshop. EPRI and U.S. DOE 2002. 1003322. PM.
- 6. An Analysis of Loss of Decay Heat Removal Trends and Initiating event Frequencies (1989-2000):
- 7. Piping System Failure Rates and Rupture Frequencies for Use in Risk Informed In-service Inspection Applications: TR-111880-NP, EPRI 2000. 1001044. PM
- 8. Application of Risk-Informed Inservice Inspection Alternative Element Selection Criteria. EPRI, Charlotte NC: 2000. TE-11482. PM.
- 9. Revised Risk-Informed Inservice Inspection Evaluation Procedure, EPRI 1999. TR-112657 Revision B-A. PM & co-author.
- 10. Piping System Failure Rates and Rupture Frequencies for Use in Risk Informed In-service Inspection Applications, EPRI 1999. TR-111880. PM
- 11. Comparison between EDF and EPRI of Pipe Inspection Optimization Methods, EPRI Palo Alto, CA; Electricite de France, Paris, France: 1999. TR-113315. PM.
- 13. Evaluation of Pipe Failure Potential via Degradation Mechanism Assessment, EPRI Palo Alto, CA:
1998. TR-110157. PM.
- 15. Piping System Reliability Models and Database for used in Risk Informed Inservice Inspection Applications, EPRI 1998. TR-110161. PM.
- 18. Survey on the Use of Configuration Risk and Safety Management Tools at NPPs, EPRI, 1998. TR-102975. PM.
- 25. Outage Risk Assessment and Management Implementation at Fermi 2, EPRI 1997. TR-109013. Co-author.
TR-102973. Principal investigator.