ML17340B019

Affidavit in Support of Summary Disposition of Contention 2 Re Util Proposed Program to Control Occupational Exposure. Certificate of Svc Encl

ML17340B019
Person / Time
Site:	Turkey Point
Issue date:	04/07/1981
From:	Gram G FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17340B017	List: ML17340B016 ML17340B018 ML17340B019
References
ISSUANCES-SP, NUDOCS 8104220557
Download: ML17340B019 (10)

Text

UNITED STATES OF'MERICA NUCLEAR REGULATORY COMMISSION BEFORE: THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-250-SP .

) 50-251-SP FLORIDA POWER 5 LIGHT COMPANY )

) (Proposed Amendments to (Turkey Point Nuclear ) Facility Operating License Generating Unit Nos. 3 ) to Permit Steam Generator and 4) ) Repairs)

AFFIDAVIT OF GEORGE R. GRAM ON CONTENTION 2 My name is George R. Gram. I am employed by Florida Power h Light Company (FPL) as Turkey Point Site Manager, Project Management .Department.

Because of my position and duties, I am personally familiar with the work force FPL plans to use in making the steam generator repairs and tne availability of that work force, Tnis affidavit is addressed to that part of Contention 2 wnich states:

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 20.101.

The currently projected peak manual manpower requirements during tne steam generator repair outage is 190 persons, based upon two 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> shifts for a 6 day work week., Of this number, approximately 114 persons, or 60%, are estimated to be unskilled workers and approximately 76 persons, or 40%, are estimated to be skilled workers.

In addition to. the projected 190 manual personnel, an estimated 110 non-manual personnel are currently projected to supervise, monitor, certify, a'nd otherwise direct the work of these manual workers.

Thus, a total of approximately 300 personnel could be involved in the repairs on any given,.day.

The total number of personnel who will be issued a TLD badge and dosimeter during the entire repair outage can be estimated.

There will be a turnover due to workers completing their assigned work and,being no longer required, and to workers quitting or being discharged. In addition, it is projected that some workers may. reach their, quarterly radiation exposure limit, in whi;ch. case they may be reassigned to work not involving radiation exposures until the end

~1 ~i of the quarter, or until they, are again required after the end of the quarter. Further, non-manual and management personnel may be present on an irregular basis, An estimate of the total number of personnel issued a TLD badge and dosimeter during the repair of one unit has been made, It was assumed that the period for the repair of one unit will be approxi-mately 9 months, with two 10 ho'ur shi'fts, per day, six days per week, It .was also assumed that, for the reasons indi;cated above, approxi mately 60 new persons will be issued a TLD badge and dosimeter during each 30 day period. That is, after the first 30 day period, 360 persons will have been issued a badge and dosimeter, 420 persons after the second period, and so on, This would xesult in a total of 840 different workers issued a badge and dosimeter for work in connection with the repair of one unit.

Given.a total number of 840 persons involved in. the, entire 9 month outage and an estimated 2084 man>>rem occupational exposure, personnel involved in the repair'f one unit will receive an aVerage of approximately 2..5 man-rem per person, This, average is well within the limits of 10 CPR 20.101, PPL is considering modifying its present plans to use four shifts of personnel working four days on and four days off to cover two llew hour shifts per day, seven days per week, This. modification would require peak manual manpower of 340 persons, Of this number, approximately 204 persons, or 60%, are estimated to be unskilled workers and. approximately 136 persons, 40%, are estimated to be skilled workers.

In addition to the projected'340 manual personnel, estimated that 200 non-manual personnel would supervise, monitor, it is certify, and otherwise direct the work of these manual workers, Thus, a total of approximately 540 personnel could be involved in the repairs on any given day implemented.

if this modification of shifts is An estimate of the total number of personnel issued a TLD badge and dosimeter during the repair of one unit was calculated modified work plan should be adopted. It was assumed that if the the period for the repair of one unit will be approximately 9 months, It was also assumed that, for the reasons indicated above, approximately 105 new persons will be issued a TLD badge and dosimeter during each 30 day period. That is, after the first 30 day period, 445 persons will have been issued a badge and dosimeter, 550 persons after the second period, and so on. This would result in a total og 1505 different workers issued a badge and dosimeter for work in connection with repair of one unit,-

Given a total number of 1505 persons involved in the entire 9 montn outage and an estimated 2084 man-rem occupa,tional exposure, personnel involved in the repair of one unit wil'1 receive an average of approximately 1,4 man-rem per person, This average is well w'ithin the limits of 10 CPR 20.101.

II ~ ~ ~

FPL has. completed numerous outages and has not experienced any. appreciable difficulty in obtaining the numbers of skilled and unskilled workers needed to accomplish any, outage-related-work. FPL does not anticipate any difficulty in hiring a suf-ficient work force, both skilled and unskilled,, to perform the steam generator repairs whether the work force is as presently projected or is enlarged as described in the shift modification which is now being considered and is described above.

FURTHER AFFIANT SAYETH NOT.

Date A ril '7; 198l G. R. am STATE OF FTDRIQA )

) SS.

COUNTY OF QATB )

SWORN to and subscribed before m this of 1981.

Notary lic My Cprgnission iiotary rU&lc,

~ires:..

aU3 ot <sc'!da at Large

,",1y CcrnrnMcn Exirm October 30, lgo3 Bonded thrtr Maynard Bending Agency

4~ ~ 1 ~

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSON BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Docket 'Nos. 50-250-SP 50-251-SP IN THE MATTER OF )

FLORIDA 'POWER 6 LIGHT COMPANY ) (Proposed Amendments to (Turkey Point. Nuclear Generating ) Facili.'ty Operating Units Nos. 3 and 4 ) License to Permit Steam Generator Repairs)

CERTIFICATE OF SERVICE I HEREBY CERTIFY that copies of Licensee's Answer Supporting NRC Staff Motion for Summary Disposition of Contention 2 and. affidavits of Harvey F. Story and George R.

Gram on Contention 2 were served on the following by deposit in the United States mail, first class, properly stamped and addressed, on the date shown below:

• Marshall E. Mi.'lier, Esp., Administrative Judge Chairman, Atomic Safety and Licensing Board Panel U'.S. Nuclear Regulatory Commi.ssion Washington, D.C. 20555

• Dr. Emmeth A. Luebke, Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Dr. Oscar H. Paris, Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Mark P. Oncavage 12200 S.W. 110th Avenue Miami., Florida 33176

41 !i g) I l l1 C

Harold F. Reis, Esq.

Steven P. Frantz, Esq.

Lowenstein, Newman, Reis & Axelrad 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036

• Steven C. Goldberg, Esq.

Office of'he Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Burt Saunders, Esq.

Assistant Dade County Attorney 1626 Dade County Courthouse Miami,'Florida 33130

• Henry, H. Harnage, Esq.

Peninsula Federal Building

.10th Floor 200 S.E. First Street Miami., Florida 33131

• Neil Chonin, Esq.

1400 AmeriFirst Building One Southeast Third Avenue Miami, Florida 33131 STEEL HECTOR 6 DAVIS Co-counsel for Licensee 1400 Southeast First Nationa Bank Building Miami, F rida 33131 Telephon (305) 577-28 3 By No ma A. Coll April 13, 1981

• Additional Service By Hand or Courier

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