ML17342A382
| ML17342A382 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/18/1986 |
| From: | Minns J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17342A383 | List: |
| References | |
| OLA-2, NUDOCS 8602240049 | |
| Download: ML17342A382 (13) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
FLORIDA POWER a LIGHT COMPANY )
)
(Turkey Point Plant, Units 3 and 4)
)
Docket Nos50-250 OLA-2 50-251 OLA-2 (SFP Expansion)
AFFIDAVITOF JOHN L. MINNS REGARDING CONTENTION 'j I, John L. Minns, being duly sworn, state as follows:
1.
I am a Health Physicist in the Plant, Electrical, Instrumentation and Control Systems Branch, Division of PWR Licensing-B in the OfQce of Nuclear Reactor Regulation, U.S.
Nuclear Regulatory Commission.
Prior to November 24,
- 1985, I
was a
Health Physicist in the Radiological Assessment
- Branch, Division of Systems Integration in the OfQce of Nuclear Reactor Regulation.
A summary of my professional quaiiQcations and experience is attached hereto.
I certify that I have personal knowledge of'the matters set forth herein with respect to assessment of occupational radiation exposures to onsite personnel and that the statements made are true and correct to the best of my knowledge.
2.
The purpose of this afQdavit is to address Contention 7 and the Bases for that Contention.
Contention 7
and the Bases for the Contention state:
Contention 7
That there is no assurances that the health and safety of the workers will be protected during spent fuel expansion, and that the NRC estimates of between 80-130 person-rem will meet ALARA requirements, in particular 'those in 10 CFR Part 20.
~\\
Bases For Contention FPL's estimates of between 80-130 rem/person are much higher than the NRC's estimate for reracking of 40-50 person/rem fsic],
and much higher than experience at other nuclear plants.
- Thus, there
[sic] estimates are not ALARA.
3.
I have read "Licensee's Motion for Summary Disposition of Intervenors'ontentions" and "Licensee's Statement of Material Facts as to Which There is No Genuine Issue to be Heard With Respect to Intervenors'ontentions",
dated January 23, 1986.
The facts presented in relation to Contention 7 are consistent with the findings and conclu-sions of the NRC Staff's Safety Evaluation, dated November 21, 1984.
With the exception of the Qnal dose equivalent for the Unit 3 rerack, I
. have no personal knowledge of the facts presented in the statement of material facts relating to the actual implementation of the Unit 3 spent fuel pool reracking which has been completed.
According to the NRC Resident Inspector at the Turkey Point plant, the actual dose equivalent required to complete the Unit 3 modifications was 13.2 person-rem.
This exposure is considerably less than the estimate approved by the Staff.
4.
While Part 20 of the Commission's regulations does not impose quantitative limits on collective radiation dose exposures, Section 20.1(c)
- provides, in pertinent
- part, that persons engaged in activities under licenses issued by the Nuclear Regulatory Commission should, in addition to complying with the requirements of Part 20, make every reasonable effort to maintain radiation exposures...
as low as is reasonably achievable.
The term "as low as is reasonably achievable "means as low as is reasonably achievable taking into account the state of technology, and the economics of improvements in relation to benefits to the public health and
- safety, and other societal and socioeconomic considerations, and in relation to the utilization of atomic energy in the public interest.
Most simply described, the "as low as is reasonably achievable" (ALARA) concept is an onpoing requirement that NRC applicants and licensees consider the radiation dose implications at each step of every activity potentially involving signiQcant radiation dose rates.
In the course of planning,
- design, construction, operation, maintenance,
- repair, replacement, decontamination and decommissioning, applicants and licensees must think through each step, with a view to evaluating possible dose reducing
- actions, and implementing those that are reasonably achievable.
The Qnal ALARA responsibility rests with the applicants and licensees to consider conditions and situations expected, or known to be present in a particular licensed activity, and to take appropriate dose reducing actions.
5.
As indicated in Section 2. 6 of the Staff Safety Evaluation, Licensee's spent fuel pool modifications can be performed in a manner that will ensure that doses to personnel will be maintained within the limits of 10 C.F.R. Part 20 and as low as is reasonably achievable.
6.
The Licensee wiQ be required to operate in accordance with the radiation protection standards set forth in 10 CFR Part 20.
The Licensee has made a commitment in the updated Turkey Point-Final Safety Analysis Report to provide personal dose monitoring instrumentation including:
(1) thermoluminescent dosimeters and self reading pocket dosimeters in accordance with 10 C.F.R. 0 20.202(3) (b) (1);
- and, (2) portable air
- monitors, samplers and bioassays in accordance with 10 C.F.R. 0 20.103.
Equipment to be used for radiation protection purposes includes portable radiation survey instruments, personal monitoring equipment, fixed and portable area and airborne radioactivity monitors, laboratory equipment, air
- samplers, respiratory protective equipment and protective clothing.
The number and kinds of equipment to be used are adequate, meet the criteria of Regulatory Guide 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident,"
and provide reasonable assurance that the Licensee will be able to maintain occupational exposures as low as is reasonably achievable.
7.
In addition, the Licensee has committed to follow Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable,"
and Regulatory Guide 8.10, "Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable."
The Licensee has also made a commitment that the "Spent Fuel Expansion Program" will be designed, constructed and operated in a manner consistent with Regulatory Guide 8.8, as it relates to management
- policies, periodic reviews and modiQcations, as well as operating and maintenance
- features, utilizing exposure data and experience gained from operating nuclear power
- plants, in order to ensure that occupational exposures will be kept as low as is reasonably achievable.
8.
The occupational exposure for the Licensee's plan for removal and disposal of the high density
- racks, and installation of the higher density racks is approximately 59 person-rem.
The Licensee had originally estimated the total occupational exposure required to complete the spent fuel pool modiQcations to be 109.3 person-rem.
In response to a Staff request for additional information regarding the collective dose equivalent for this operation, the Licensee lowered its estimate to 59 person-rem.
The revised exposure estimates are based on a detailed breakdown of occupational exposure for each phase of the spent fuel pool expansion from the point of view of maintaining doses as low as is reasonably achievable.
The Licensee considered the number of individuals performing each job task, the expected occupancy time while performing each job task, and the average dose rate in each working area.
In accordance with Regulatory Guide 8.19, "Occupational Dose Assessment in Light-Water-Reactor Power Plants Design Storage Man-Rem Estimates," the Licensee has provided a dose assessment, including a completed summary table of occupational radiation exposure estimates in sufficient detail to explain how the assessment process was performed, a systematic process for considering and evaluating dose-reducing changes in design and operations as part of the comprehensive ongoing design
- review, and a
record of the review procedures, documentation requirements and identiQcation of principle ALARA-related changes resulting from the dose assessment.
9.
The Staff concluded, taking into consideration the existing design of the spent fuel
- pools, the leng th of time spent fuel pool assemblies have been
- stored, the number of stored assemblies, the required movement of the existing stored fuel assemblies, and the detailed breakdown of all job tasks required to complete the modiQcations, that the Licensee's revised exposure estimate of 59 person-rem is as low as is reasonable achievable.
Taking into account the variations in plant-speciQc considerations, the Staff also approved as being "as low as is reasonably achievable" occupational exposure estimates of 50 person-rem at Ginna, 20 person-rem at Connecticut Yankee and 1V3 person-rem at H. B. Robinson.
10.
The Staff estimated that the 59 person-rem would likely be divided among not fewer than ten occupational workers and no more than 80 occupational workers.
This represents about a seven percent increase in the average annual dose from routine occupational exposure at the plant which was approximately 870 person-rem/year/unit over the five year period 1978-1982.
"Occupational Radiation Exposure at Commercial Nuclear Pressurized Water
- Reactors, 1982,"
(NUREG-0?13, Vol. 4, December 1983).
11.
The Staff's estimate of as many as 80 occupational workers is based on experience in performing similar modiQcations at other plants and on the Licensee's estimates.
The lower estimate of ten workers is
, based on the Licensee's 59 person-rem exposure estimate and on the asumption that each individual in this population could receive an upper limit of 3 rem/calendar quarter without exceeding the regulatory limits of 10 CFR 0 20.101.
Section 20.101 limits radiation exposure to the whole body to 14 rem per calender
- quarter, except that an individual may be permitted to receive a dose equivalent in excess of this amount if all the following conditions are satisQed:
a.
That the dose to the whole body not exceed 3 rem in any calender quarter; b.
that the dose to the whole body when added to the accumulated occupational dose to the whole body shall not exceed 5(N-18) where "N" equals the individual's age; and, c.
that the licensee has determined the individual's accumulated occupational dose to the whole body on Form NRC-4, or on a clear and legible recording containing all the information required in that form, and has otherwise compiled with the requirements of 10 C.F.R. 0 20.102.
12.
In addition to the measures taken by the Licensee to assure that occupational exposures during the spent fuel pool modiQcations are
maintained within the applicable limits of Part 20 and as low as is reasonably achievable, the Licensee maintains spent fuel pool monitors which are used to monitor the spent fuel pool areas and cleanup systems which are used to reduce the radioactivity in the pool water.
The Intervenors
- assert, in support of Contention 7, that these systems are not operational.
Intervenors base their assertions on an NRC memorandum, dated March l5,
- 1985, from P.
Bernie to H.
Thompson in which NRC Region II expressed concern that the spent fuel pool monitors should be required to be operational at all times by technical speci6cations, not just during refueling.
In response to this concern, the Staff stated, by memorandum dated May 3, 1985, that:
(1) the fuel storage pool areas are continuously ventilated; and (2) the Licensee, in addition to maintaining spent fuel pool monitors to continuously monitor the spent fuel pool areas, is using the plant's vent monitoring system, as
'n Section 3.9 and Table 3.9-4 of the Plant Technical requll'ed 1
SpeciQcations, and spent fuel pool area monitors to monitor total plant airborne radioactivity released (noble gas, iodine and particulates),
thus assuring that exposure to workers occupying plant areas, including the spent fuel pool buildings, and to the offsite population, are maintained as low as is reasonably achievable.
Regarding the cleanup
- system, the Staff identified only a
minor increase in radioactivity in the spent fuel pool due to the capabilities of the cleanup system.
- However, the Region expressed concern that with the spent fuel pool water level lowered eight feet during rerack, as
- allowed, the cleanup system would not be functional.
The Staff responded that although the cleanup system is expected to be out of service periodically, the buildup of radioactivity in the spent fuel pool is
0
not expected to be significantly accelerated by this shutdown.
Accordingly, the Staff does not believe that the 'ntervenors'ssertions I
relating to the spent fuel pool monitors and the cleanup systems are valid and support their contention.
13.
In summary, there is reasonable assurance that the Licensee will implement a radiation monitoring program that will maintain onsite radiation exposures within the applicable limits of 10 C.P.R.
Part 20 and will maintain occupational exposures as low as is reasonably achievable during the spent fuel pool expansion.
The foregoing and attached statement of professional qualiGcations and experience are true and correct to the best of my knowledge and
, belief.
I ri~
Gukscrjbed and sworn to before me
< at/9~ day of February, 1986.
o L. Mxnns otary u hc My. commission expires:
I participate in the preparation and processing of NRC Safety Evaluation Reports in support of NRC licensing functions, pursuant to requirements of the Federal Regulations.
I am a member of the American Health Physics Society (National Chapter) and of the Baltimore-Kashington Chapter (Local Chapter).
0 I
PROFESSIONAI, QUALIFICATIONS JOHN L. MINNS Plant, Electrical, Instrumentation, Control Systems
- Branch, PWR-B I am a Health Physicist in the Plant, Electrical, Instrumentation, Control Systems
- Branch, Division of PWR Licensing -B, Office of Nuclear Reactor Regulation, U.S.
Nuclear Reg ulatory Commission, Washington, D.C.
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.
After graduation from Columbia University, I worked for E.I. Dupont de Nemours a
- 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 and improving present methods of analysis for elements such as Plutonium, Uranium and Americum.
I was also a Quality Control Chemist in the Uranium Chemistry Section.
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 release of radioactivity from nuclear power plants.
Prior to transfer, I
was a
Nuclear Engineer for 2$ years in the Effluent Treatment Systems Branch.
In 1978, I was transferred to the Radiological Assessment Branch as a
Radiological Engineer.
In November 1979, my title was changed to Health Physicist.
My principal function is the review of power reactor appli-
- cations, 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.