ML16314D362
| ML16314D362 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/09/2016 |
| From: | Brunot W Pacific Gas & Electric Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML16314D362 (12) | |
Text
TESTIMONY OF WILLIAMK. BRUNOT ON BEHALF OF PACIFIC GAS AND ELECTRIC COMPANY DECEMBER 1976 DOCKET NOS. 50-275'0-323 My name is William K. Brunot.
I am a Senior Engineer in the Mechanical and Nuclear Engineering Department of Pacific Gas and Electric Company.
My business address is 77 Beale Street, San Francisco, California 94106.
My educational background is as follows:
10 14, le University of Notre Dame - B. S. in Mechanical Engineering (1957)
University of Virginia M.N.E. in Nuclear Engineering (1962)
University of Maryland - Ph.D. in Nuclear Engineering (1969)
From 1957 to 1959, I worked in the Technical Evaluation 17 18 19 20 25 Section of the Army Reactors
- Branch, Atomic Energy Commission, at Germantown, Maryland.
This work consisted of evaluating and checking contractor's design reports, conducting technical feasibility studies, and providing technical consultation.
The subjects of the work were heat transfer, fluid flow, mechanical
- design, stress
- analysis, and shielding.
From July of 1962 until late 1963, I was employed as a
Test Engineer at. the Westinghouse Astronuclear Laboratory in Pittsburgh, Pennsylvania.
My work there included mechanical
1 design, heat transfer, thermodynamics, and activation analysis.
2 3
From October of 1963 until early 1965, I was employ'ed by Gulf General Atomics in the Nuclear Analysis and Reactor 4
Physics Group.
After completing the doctorate, I joined 5
Westinghouse Nuclear Energy Systems in the Licensing.and Reliability Department.
As Lead Engin'eer of the Radiation 7
Effects and Release Models Group, my work included planning, directing, and carrying out off-site dose calculations and 9
activity transport calculations.'0 In May of 1970, I joined the Mechanical and Nuclear Engineering Department of Pacific Gas and Electric Company,.and I am participating primarily in environmental radioactivity analysis for the Diablo Canyon Project.
I am a member of the American Nuclear Society and have 15 served on a number of industry advisory committees related to lB reactor safety, and I have published a number of technical papers 1'/
in the area of safety analysis.
19 The purpose of my testimony is to briefly summarize the content and extent of the work performed by Pacific Gas 20 and Electric Company in the area of potential radiological 21 exposures.
This testimony is relevant to Contention 4 in this 22 hearing.
The radiation safety experience of Pacific Gas and Electric Company personnel extends back to 1957, beginning with the Vallecitos project, and includes thirteen years of successful
operating experience at the Humboldt Bay Nuclear Power Plant.
The Company maintains personnel experienced in radiation safety and analyses in its Engineering and Operating Departments, and J
most of the required analysis is conducted in-house.
In the area of radiological effects of Diablo Canyon 6
relevant to this hearing, the requirements which the Pacific 7
Gas and Electric Company must meetare explicitly defined in, 8
the following documents:
9 l.
10 CFR, Part 50, Licensin of Production and Utilization 10 Facilities, Section 50.34A, Appendix I.
11 2.
10 CFR, Part 20, Standards for Protection A ainst Radiation Sections 20.101 to 20.106.
3.
USNRC Regulatory Guide 1.109, Calculation of Annual Doses to Man From Routine Releases of Reactor Effluents for the Pur ose of Evaluatin Com liance with 10 CFR Part 50, 16 17 Standards Development,
- March, 1976.
16 4.
USNRC Regulatory Guide l. 111, Methods for Estimatin 19 20 Atmos heric Trans ort and Dis ersion of Gaseous Effluents in Routine Releases from Li ht-Water Cooled Reactors, U.S. Nuclear Regulatory Commission Office of Standards 23 24 Development,
- March, 1976.
5.
USNRC Regulatory Guide 1.112, Calculation of Releases of Radioactive Materials in Gaseous and Li id Effluents from, 26 Li ht-Water-Cooled
- Reactors, U.S. Nuclear Regulatory
Commission Office of Standards Development, April, 1976.
6.
USNRC Regulatory Guide 1.113, Estimatin A uatic Dis ersion of Effluents from Accidental and Routine Reactor Releases for the Pur ose of Im lementin A
endix I, U.S. Nuclear Regulatory Commission Office of Standards Development, May, 1976.
7.
USNRC Regulatory Guide 1.70, Standard Format and Content of Safet Anal sis Re orts for Nuclear Power Plants LWR 9
Edition, September, 1975.
10 8.
USNRC Regulatory Guide 4.2, Pre aration of Environmental Re orts for Nuclear Power Plants,
- March, 1973.
These regulations and guides specify actions to be
- taken, and analyses to be performed by both the applicant for a license and the staff of the Nuclear Regulatory Commission.'7 18 It is my testimony that all the analyses recpxired of Pacific, Gas and Electric Company by these regulations and guides are completed and docketed, and that. the plant meets all the
\\
relevant regulatory design objectives with regard to radiation 19 exposures.
20 21 The results of all these analy'ses are expressed in terms of radiation exposures, as are the Federal Regulations.
It is not the formal responsibility of PGandE to make calcula-tions of the number of cancers or other health effects resulting from these exposures, or to compare the results of such calcula-tions with standards not in the regulations, or to make formal
judgments as to the absolute significance of such comparisons.
5 It is the responsibility of the regulatory agencies to make these judgments as a part of their role in setting regulatory.
limits on radiation exposure.
The particular exposure limits and design objectives contained in Appendix I to 10 CFR Part 50 were arrived at after extensive generic review, which involved public hearings at'he federal level.
In these proceedings, the full range of 10 somatic and genetic effects of exposures at the limiting levels were given consideration.
Beyond the requirements of the regulations, and in 12 'rder to offer comments on the various effects of radiation 13 exposure identified in Contention 4, we have requested testi-mony and assistance in response to interrogatories from Dr. G. Hoyt Whipple, who is a Professor of Radiological Health at the Scho'ol of Public Health of, the University of Michigan.
18 19 20 21
.'2 23 Dr. Whipple's testimony has been submitted separately, and contains the general conclusion that somatic and genetic effects on the surrounding population have been given adequate consideration and will be insignificant compared to spontaneous effects of the same kind which occur in the population.
We also note that as a result of their independent
- analyses, the staff of the Nuclear Regulatory Commission, in testimony submitted by Parsont and Boegli '(Sept.
28, 1976),
concluded that:
1 2
3 4
"Accordingly, it. is concluded that the liquid and gaseous radwaste treatment systems will reduce radioactive materials in effluents to
'as low as is reasonably achievable levels'n accordance with 10 CFR Part 50, Section 50.34a and, therefore, are acceptable."
10 In conclusion, we believe that all potential radio-logical effects have been given adequate consideration in the various analyses made and that the plant systems and analyses conform to regulatory requirements.
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