ML18008A018

Affidavit Re Lack of Adequate Precautions in Storing Wastes Resulting from Steam Generator Repair.Prof Qualifications Encl

ML18008A018
Person / Time
Site:	Turkey Point
Issue date:	06/27/1981
From:	King D AFFILIATION NOT ASSIGNED
To:
Shared Package
ML17341A284	List: ML17341A283 ML17341A285 ML17341A286 ML17341A287 ML18008A018
References
ISSUANCES-SP, NUDOCS 8107020497
Download: ML18008A018 (12)

Text

STAT iv"-'NT OF PHOrrlSSXONAL BACKGHOU1,'D AND QVALXFXCATIONS LZONAHD G. PAHDVZ I am a fully oualified meteorologist Following many years with the Natiorial Weather Service, including 25 years in Mimi, Florida at the National Eurricane Center, I left the Government to enter private practice as a consultant. I have assisted many law f'irms and assistant state's attorneys and defenders, appearing of'ten as an expert in Circuit 'ublic Court and Federa1 District Court in Dade, Broward, Palm Beach, and Lee Counties and washington, D. C.

1 entered the:jeather Bureau at <montgomery, alabama, serving

~

also at other points in Alabama, Louisiana, and X attended Spring Hill College at labile, Florid~

Florida.'eanwhile Southern College at Lakeland, Tulane University at. hevr Orleans, and the University of'iami, f'o11owed by a,year at the Graduate School of. Meteorology at Hew York University, vrhere I had been awarded a f'ull scholarship. Upon completing my year at NYU 1 was assigned to EKami. 1 have taught weather courses at the University of'iami, 'Florida. A. 4. M University, Eliami-Dade Community College, the Air Force Reserve, and adult evening high- school. For two y'ears X was president of'he Euseum .of Science and Planetarium and, novi am president Friends. of Physics of'he University of'iami. I have of'he been certif'ied as a consultant by the American Zeteorologica3.

Soc3.etym During my private practice X have worked v~ith attorneys in cases involving railroads, air lines, public utilities, aircraft manufacturers, municipal'.'ties, and the United States Government- I have been consulted by commodity traders, architects, engineers, and insurance companies.

8zevoaofff

~I ~ '

UNXTED 'STATES OF AMERICA.

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMXC SAFETY AND LICENSING BOARD

)

Xn The Mattev of ) Docket Nos. 50-250-SP

) 50-251-SP FLORXDA POWER 8 LIGHT COMPANY )

) (Pvoposed 'Amendments to (Turkey Point Nuclear ) Facility .Opevating Licenses Genevating,Units Nos.. 3 ) to Pevmit Steam Generatov and '4) ) Repaivs;)

)

)

),

AFFIDAVIT OF DOUGLAS KlNG STATE OF FLORXDA )

) ss.

COUNTY OF DADE )

I, DOUGLAS KING, being fir st duly sworn do state and af firm that:

1. My name is Douglas King. My business address is'Physics. Department, Miami Dade Junior College, South Campus. *A statement of my professional backgvound and qualifications is attached to this affidavit and made a pavt thereof.

,'2. I pavticipate'd in the Turkey Point s'ite inspection on April 19, 1981 as a membev of Intervenor, Mavk Oncavage' party. The inspection was authovized by the Atomic Safety and Licensing'oard..

3. I observed 'several locations of loosely stacked, sealed drums in roped off .areas. 'These dvums were identified as containing vadio-active matevi;al. At no time duving the inspection did I observe LSA boxes on site.

In the fivst six .weeks of the steam generator vepair., accovding to Bechtel Power Corp.'s "Steam Generator Replacement Summavy Schedule,"

the containment building will be decontaininated. the nuclear cove will be off loaded, and the channel, heads on steam genevatovs., A, B, and C, 0-

gl ~ ~

P ty

will be decontaminated.

5. If, during off loading of the nuclear core, the primary coolant is drained, processed and released, the entire inventory of radioactive isotopes, extracted from the coolant, must be stored as solid radioactive waste. This radioactivity is estimated to be approximately 270 ci-pex'nit, according to .'NUREG CR/1595;. PNL 3454, Page 40.

6. There is no estimate in the FES, NUREG 0743 for the amount that must be stored resulting from the decontamination ofadioactivity of the containment building.

7. In the FES, pages 4-12, Florida Power. 8 Light states that 1500 ci, of gamma radioactivity will be present in the six steam generators at the time of removal. NUREG CR/1595,, PNL 3454, page 5, estimates that each steam generator will contain between 400 and 1000 ci~

of radioactivity. The cx'itex'ion =or the large discrepency between Florida Power 8 Light's estimate and Battelle's estimate of activity pex'team generator has not been oxthcoming and demands further inves-tigation and clarification.

8. Florida Power 8 Light will attempt to remove the radioactivity from the channel head and divider plate areas of each steam generator by grit blast. Mhkther the 250 c='. or the 400 ci, or the 1000 ci, activity per steam generator is accurate, all radioactivity rom the decontamination process must be stored as solid waste.

CONCLUSION The initial six week pex'iod of the steam generator'epair'equires very large, potentially hazardous amounts of radioactivity to be stored as solid radioactive waste. The "ack of adequate precautions in storing these wastes can lead to an ix'x'ever'sible contaminating, accident if a hurricane or tox'o should breach the waste containers and scatter

1'

~

the contaminated material over the Turkey Point site and its surrounding water s.

DOUG S KING, Af iant BEFORE ME, the undersigned authority, personally appeared DOUGLAS KING, who by me first being duly sworn, state that. the foregoing facts are true and correct to the best of his knowledge and belief.

SWORN TO AND SUBSCRIBED before me on this +~gay of JUNE, 1981.

Notar~Pub1zc State of Florida at Large My Commission expires:

NOTARY PURL IC StATE OF fLORIDA AT LARGI MY COMMISSION EXPIRES JAN. II 1982 RONDED FHRU GENERAL INS. IINDIRWR I TERS

~ i l C

C

STAT-"Ii'u"HT OP PROFESSIONAL BACKGROUND'K AK) QUALIFICATIONS DOUGLAS KXHG

'r"DUCATION:

Bachelox of'cience, Physics, 1971 The Coopex Union, 7few York City, iVevr

. ~or3r.

GRADUATE STUDIES:

Physics Department, Radiation Biophysics Department, 1971 - 1977 University of'- Florida, Qainesville, Florida MSESBCH ABLS:

Nuclear I:agnetic Resonance, Radiation Biophysics, Biological Action of'onizing Radiation, Cell membrane Physiology, and TLD Dosimet y ZMPLO EVHT:

1975 1977 Teaching Assistant, Physics Dept. Univ. of'lorida 10/77 1/78 Biomedical engineer, Univ. oz. miami, Medical School 2/78 10/78 Radiation Health Physics Supervisor, Kedi + Physics Inc.

11/78 5/81 Physics and Advanced I';;athematics Teacher, The Palmer School VZ243~~RSHXPS AND HONORS:

Member of'igma Pi Sigma, Physics National Eonor Society President of'igma Pi Signa, Univ. of'lorida Chapter, 1976 1977 I'.ember of'nited States Chess Federation, 1964 1980.

0 2O[

l5 v IO K .p @4) 0 I886 I896 1906 l9I6 l926 l936 l946 l956 1966 l976 YEARS I~m $ .-Annuat dlslrlbullon of the 761 recorded Atlanllc tropical cyclonos reachlhg at least troplcdl storm strength (open bar) and tho 448 reaching hurricane strength (solid bar), 1886 through 1977. The averago number of such storms ls 8.3 aml 4.9, respectively (seo Tablo 4).

IQ 100 90-8C" 80 70 70 6O 50

~

y 40 20- 20 IO Q. E&2l

,0 0 10 20 30 10 20 30 10 20 30 10 20 30 KO 20 30 10 20 3 iO 20 30 10 20 30 MAY I JUNE I JULY I AUGUST I SEPTEMBER I. OCTOBER I NOVEMBER I DECEMBER t fWv 4-Number of tropical storms and hurricanes (open bar) and hurricanes (solid bar) observed on each day, May 1-December 30, 1886 through 1977.

19

'9

r~

>C

~g