ML20065N657

Affidavit of TB Cochran Listing Qualifications to Be Considered as Expert Interrogator

ML20065N657
Person / Time
Site:	Clinch River
Issue date:	10/20/1982
From:	Cochran T National Resources Defense Council
To:
Shared Package
ML20065N625	List: ML20065N623 ML20065N644 ML20065N657 ML20065N671 ML20065N692 ML20065N721
References
NUDOCS 8210220279
Download: ML20065N657 (5)

Text

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DOCKETED USNRC

• fs2 dCT [0 PS:d1 r ~ c v. u v UNITED STATES OF AMERICA . .;

NUCLEAR REGULATORY COMMISSION

• ATONEC SAFETY AND LICENSING BOARD Before Administrative Judges:

Marshall E. Miller, Chairman Gustave A. Linenberger, Jr.

Dr. Cadet H. Hand, Jr.

)

In the Matter of )

)

) Docket No. 50-537 UNITED STATES DEPARTNENT OF ENERGY )

PROJECT MANAGEMENT CORPORATION )

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

)

i AFFIDAVIT OF THObaS B. COCHRAN 1

I, Thomas B. Cochran, being duly sworn, do hereby state as follows:

1. My name is Thomas Brackenridge Cochran. I reside at 4836 North 30th Street, Arlington, Virginia 22207. I am presently a Senior Staff Scientist at Natural Resources Defense l

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Council, Inc., and a co-director of the NRDC Nuclear Nonproliferation Project.

2. I am a member of the Department of Energy's Energy Research and Advisory Board; the Three Mile Island (TMI) Public Health Fund Advisory Board; the Nuclear Regulatory Commission's TMI Advisory Board; and the American Nuclear Society.

3. I have a B.S. degree in electrical engineering and M.S.

and Ph.D. degrees in physics, all from Vanderbilt University.

I have held the positions of Assistant Professor of Physics, U.S. Naval Postgraduate School, and Senior Research Associate, Resources for the Future.

4. I have been a consultant to numerous government -

agencies and testified before Congress on numerous occasions on matters related to nuclear energy generally and liquid metal fast breeder reactors (LMFBRs)- in particular. I was a member of DOE's Nonproliferation Advisory Panel and ERDA's LMFBR Review Steering Committee. I am the author of The Liquid Metal l Fast Breeder Reactor, An Environmental and Economic Critique, (Johns Hopkins Univ. Press, 1974).

5. With regard to matters of LMFBR safety, I was also a member of the NRC's Advisory Group on Reactor Safety Goals and l

NRC's Advisory Group on Operator Training. I have had extensive hands-on experience with systems modeling and computer programming, both in relation to my Ph.D. dissertation in high energy physics and while serving as a Modeling and I

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l Simulation Group Supervisor at Litton Scientific Support  ;

Laboratory at Fort Ord, California.  !

6. I was one of two U.S. citizens invited to testify on safety aspects of the SNR-300, the Federal Republic of Germany's demonstration breeder, before the Enquete-Kommission "Zukunf tige Kernenergie-Politik," Deutscher Bundestag, FRG (June 3, 1982).

7. With regard to radiation protection, my M.S. thesis was in Radiation Chemistry. I was an AEC Health Physics Fellow at Vanderbilt University between 1962 and 1964, during which period I had 3 months of on-the-job training at Oak Ridge

- National Laboratory. I was the campus Radiation Safety Officer while pursuing my Ph.D. degree at Vanderbilt University.

8. While at NRDC I co-authored with Dr. Arthur Tamplin two radiation standards petitions to the NRC, " Petition to Amend 10 CFR 20.101, Exposure of Individuals to Radiation in Restricteo Areas," September 1975 (PR M-2 0-6) , and " Petition to Amend Radiation Protection Standards as They Apply .to Hot Particles,"

February 1974 (PR PF20-5) .

9. I have been a member of the Health Physics Society for-the past 18 or so years.

10. My statement of professional qualifications is attached.

11. Because of my scientific and technical training and experience, I am familiar with many aspects of the Clinch River

Breeder Reactor, and its proposed fuel cycle facilities, that are discussed in Intervenors' Contentions.

12. I have participated actively in all phases of the NRC Clinch River Breeder Reactor licensing proceedings since 1975, including assisting in the preparation of Intervenors' contentions.

13. I prepared substantial portions of NRDC's comments on the 1977 CRBR Final Environmental Impact Statement and the 1982 Draf t Supplement to the 1977 CRBR Final Environmental Impact Statement.

14. I testified before the NRC Advisory Committee on Reactor Safeguards on several occasions regarding the Clinch River Breeder Reactor and related issues.

15. I have attended numerous meetings held by Staff and Applicants to discuss the NRC licensing review of the Clinch l

River Breeder Reactor.

16. I have participated actively in discovery proceedings

'related to CRBR licensing from 1975-1977, and from March 1982 to the present, including the preparation of interrogatory l

l questions and responses, and requests for admissions and i

responses, and have conducted several depositions of witnesses for Applicants and Staff.

17. I have read or examined many of the documents upon which Applicants and Staff purport to rely for their positions on Intervenors' Contentions.

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18. I fully intend to read all written testimony submitted by Staf f and Applicants on which I intend to cross examine, and any documents to be used or referred to in the course of the cross-examination.

19. I have prepared myself, and will continue to prepare myself to conduct a meaningful and expeditious cross-examination.

20. I intend to limit my cross-examination to areas within my expertise.

bSL3 Thomas B. Cochran Date: October 20, 1982 Sworn and subscribed to before me this so t4 day of October, 1982.

O hi W&V Notary Public My Commission Expires 7/3/ ///7 I

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