ML17340A885
| ML17340A885 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/10/1981 |
| From: | Minns J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17340A884 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8103240405 | |
| Download: ML17340A885 (14) | |
Text
gpjya/gy UNITED STATES OF At1ERICA NUCLEAR REGULATORY COl1HISS ION BEFORE THE ATOflIC SAFETY AND LICENSING BOARD In the tlatter of FLORIDA POWER 8
LIGHT CONPANY (Turkey Point Nuclear Generating Units 3 and 4)
Docket Nos.
50-250-SP
,'50-251-SP (Proposed Amendments to Facility Operating License to Permit Steam Generator Repairs.)
AFFIDAVIT OF JOHN L. HINNS ON CONTENTION 2 I, 3ohn L. Ninns, being duly sworn, state as follows:
1.
I'm employed by the U.S. Nuclear Regulatory Cormission as a Health Physicist in the Division of Systems Integration, Office of Nuclear Reactor Regulation.
2.
Contention 2 states:
A.
The programs and procedures proposed to be followed by the Li'censee in making the steam generator repairs demonstrate
'tilat it will not make every reasonable effort to maintain occupational radiation exposures as low as is reasonably achievable (ALARA) within the meaning of 10 CFR Part 20 or that it will not comply with 10 CFR 5 20.101, in that the Licensee intends to use transient workers with unknown radiation exposure histories.
B.
A sufficient work force, both skilled and unskilled, cannot be obtained to perform the repairs without violating the limits on individual exposures contained in 10 CFR 5 20.101.
8 io s p:4o'/o0>>
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(A)
ALARA considerations I have prepared section 2.8.1.5 of the Safety Eva'luation Report related to tne Turkey Point steam generator repair (SER)
(NUREG-0756),
entitled "ALARA Considerations",
dated
- December, 1980.
This rep-resents the staff review of "as low as reasonably achievable" (ALARA) considerations for occupational exposures involved in the proposed steam generator repair.
The contents of this section are true and correct to the best of my knowledge and I hereby adopt it as a part of my direct testimony on Contention 2.
This section concluded, in relevant part, that the programs and procedures proposed by the licensee in making the steam generator repairs demonstrate that it will meet (1) 10 CFR Part 20 limits and requirements, including efforts to maintain radiation exposure 1/
"ALARA"; (2) Regulatory Guide 8.8 with respect to management policy and organization, personnel qualifications and training, design of facilities and equipment, radiation protection
- program, plans, and procedures, and the availability of supporting equipment, instrumentation, and facilities; 2/
and (3) Regulatory Position C.l.f of Regulatory Guide 8.10 on modifi-cations to reduce radiation exposures.
Regulatory Guide 8.8 outlines NRC policies regarding maintenance of occupational doses during nuclear power operation.
The document stresses local decontamination, temporary lead shielding, pre-job planning and training, and the use of remote tools as 1/
Information Relevant to Ensuring That Occupational Radiation Exposures at Nuclear Power Stations Mill Be As Low As Is Reasonably Achievable.
2/
Operating Philosophy for Maintaining Occupational Radiation Exposure As Low As Is Reasonably Achievable.
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desirable dose reduction measures.
All of these measures will be
- employed, in varying degrees, during the proposed repair operation.
Regarding control of doses to transient workers, the licensee will be required to operate in accordance with the provisions of 10 CFR 520.102, adopted to control transient workers'uarterly doses.
Pur-suant to 10 CFR 520. 102, a licensee shall require any individual, prior to first entry into a restricted area under ci rcumstances in which that individual could receive in any period of one calendar quarter an occupational dose in excess of 25 percent of the applicable standards speci fied in 1 0 CFR 520. 1 01(a ). and 520. 104, to disclose in a written, signed statement, either that the individual had no prior occupational dose during the current calendar quarter or the nature and amount of such exposure.,
That regulation also provides that, before permitting any individual in a restricted area to receive an occupational dose in excess of the standards specified in 10 CFR 520.101(a),
each licensee obtain a certificate on Form NRC-4 or signed statement from the individual containing all the information required in that form relative to such individual's accumulated occupational dose.
Observance of these requirements will assure that transient workers wi 11 not receive impermissible radiation doses during their participation in the proposed steam generator repair.
(8)
Work Force Sufficienc With regard to worker staffing, the licensee will be required to operate in accordance with the permissible dose levels in 10 CFR 5 20.101.
Limitations, if any, on the size of the available work force, could
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necessitate extending the work into a new quarter.
This could be accomplished without exceeding the exposure limits in 10 CFR 5 20. 101.
According to the licensee, there are expected to be 840 workers in-volved in the steam generator repair.
The Staff believes that this is a sufficient workforce to satisfactorily and safely perform the necessary repair activities based on the Surry repair experience.
J hn L. Hinns iJ Subscribed and sworn to before me thi; i'D~~ g't~, HS'i 1
I otery Pub]:c Hy Commission expires:
c'
~
?.8. 1. 5 ALARA Consideration
- SER, December,1980 HUREG-0756 f PL's total estimate of 2084 person-rem per unit for the channel cut method
'.akes into account the dose reduction measures described in Regulatory Guide 8.8, Rev.
3, "Information Relevant to Ensuring That Occupational Radiation Exposures At Nuclear Power Stations Will Be As Low As Is Reasonably Achievable," which include local decontamination, temporary lead shielding, pre-hob planning, pre-
- ob training, and use of remote tools were practicable.
In addition, FPL "t.in ated a range of exposures from 1830-2480 person-rem/unit based on i-ncertainties regarding job person-hours, radiation fields, and the effective-ess of temporary shielding.
PNL has estimated a minimum total dose of
.'400 person-rem per unit for a generic repair program.
.'PL has committed to making every reasonable effort to keep radiation exposure
.'.CLARA in accordance with 10 CFR Section
- 20. 1(c) and Regulatory Guide 8.8, Rev.
3 and is responsive to the Regulatory Staff Positions in Regulatory Guide 1.8, "Personnel Selection and Training", 8.2, "Guide for Administrative Practices in Radiation Honitoring," and 8. 10, "Operating Philosophy for Hain-taining Occupational Radiation Exposures As Low As Is Reasonably Achievable."
We conclude that the FPL efforts to maintain occupational doses ALARA during the repair efforts meet our positions in Regulatory Guide 8.8 and are there-fore acceptable.
)PL will use some experienced personnel from the Surry Unit 2 steam generator removal and replacement.
These individuals will provide, added expertise to FPL for dealing with health physics problems associated with the repair.
Communication of this knowledge gained during the Surry Unit 2 operation is a
key ingredient in an effective ALARA program.
All craft personnel will be required to take training in radiological protection.
The course will include instructions and demonstration in radiation protection principle, theory and practice, emergency planning and the FPL Radiological Protection Program.
Personnel will be requi red to pass a comprehensive exami-nation to have unescorted access in the radiation-controlled area.
Extensive training in other areas will be used throughout the repair.
FPL has stated that scale models will be used to familiarize supervisory and key craft personnel with the repair effort.
The models will be used to develop construc-tion work. plans to establish the most efficient work procedures.
The models will also supplement work plans and allow supervisors andi craft personnel to achieve the most efficient use of manpower which will reduce occupancy in radiation fields and, thus, reduce the total occupational dose.
These models include a model of the entire containment which will be used in conjunction with radiation survey data to establish temporary shielding requirements.
The r,ndel will also be useful in making person-rem assessments for particular work activities in radiation fields.
FPL will provide additional facilities for the repair effort including radio-logical protection training facility, additional health physics area (include separate offices for HP personnel) counting room, access control station, laboratory facilities, change
- room, and decontamination facilities.
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Pnstoperational dob> iefings will be used for jobs incurring major radiation exposure.
Feedback of dose experience will be exa-.ined wit;h the aid of com-puter p> intouts of doses.
FPL is committed to provide a qualified radiological engineer assigned the-responsibility and authority "to function as ALARA coordinator in accordance with Regulatory Guide 8.8.
This function will be the individual's p> i;:.cry function.
The FPL corporate staff is developing an ALARA program and the HP m::nual, incorporating the radiation protection program will be revised and the fo>mal CLARA program implemented in. early 1981.
An ALARA engineer is budgeted for )981 and will be integrated into the radiation protection organization.
Based on the above evaluation, we determine that the programs and p
- .:; lures proposed by FPL in making the steam generator repairs demonstrate Lh~t it will meet the requirements of (1) 10 CFR Part 20 limits and as it relates to effort to maint:ain radiation exposure as low as reasonably achievable; (2) R.>gulatory Guide 8.8, as it relates to management policy and organization; pe> so-.nel quali-fications and training; design of facilities and equipment; radiation p: otection program, plans, and procedures; and the availability of supporting eq'p;>ent, inst> u..entation, and facilities; (3) Regulatory Position C. l.f of R.gulatory Guide 8. l0, on modifications to reduce.radiation exposures.
O~
e
JOHN L. MINNS Professional Qualifications Vy name is John L. Minns and my business address is U.S. Nuclear Regulatory Commission, k!ashington, D.C.
20555.
My home address is 7351 Kerry Hill Court, Columbia, MD.
20465.
I am a Health Physicist working in the Radiological Assessment Branch.
I attended Columbia University and received a Bachelor of Science Degree in Chemistry in 1964.
I also attended Rutgers University, Graduate School of Chemistry, and Catholic University Graduate School of Nuclear Engineering.
I am currently enrolled at the University of Southern California at Crystal City, VA. for a Master of Science in safety degree.
After graduation from Columbia University, I worked for E. I. Dupont de Nemours 5 Company, as an Emulsion Chemist, Process Control Chemist and as a Quality Control Chemist.
My duties included Instrumentation Analysis, Process Research and Development, and Asst. Supervisor of the Control Laboratory Instrument Section.
In 1971, I joined the Atomic Energy Commission as a Plutonium Chemist (for the New Brunswick Health and Safety Laboratory).
I was responsible for performing general analysis on complex plutonium and other radioactive materials, using standard procedures with adaptations, and to improve present methods of analysis for elements such as Plutonium, Uranium and Americum.
I also did Quality Control work in the Uranium Chemistry Section, Wet and Dry Analysis of Raffinated solutions, dissolver solutions and of radioactive waste from nuclear fuel.
In 1974, I joined the Nuclear Regulatory Commission (formerly AEC) as a
Nuclear Chemist in the Effluent Treatment Systems Branch.
In this position, I was responsible for acquiring and evaluating source term data. and effluent measurements from operating nuclear facilities and from inplant measurement
- programs, investigating problems relating to radioactive waste treatment systems and assisting in the development of analytical model parameters and calculational methods for evaluating the effectiveness of proposed radioactive waste treatment systems.
I also reviewed and evaluated radwaste systems and the calculation of releases of radioactivity from nuclear power plants.
Prior to transfer, I was a Nuclear Engineer for 2 1/2 years in the Effluent Treatment Systems Branch.
In 1978, I was transferred to the Radiological Assessment Branch as a Radio-logical Engineer.
In November
- 1979, my title was changed to Health Physicist.
My principal function is the review of power reactor applications, both at the construction permit and operating license
- stage, to determine the adequacy of proposed occupational radiation protection programs and the related efforts proposed to assure that occupational radiation exposure will be maintained as low as is reasonably achievable.
I participate in the preparation and process-ing of NRC Safety Evaluation Peports in support of NRC licensing functions, pursuant to requirements of the Federal Regulations.
I am a member of the Health Physics Society and of the Baltimore-Washington Chapter.
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