ML20008F982
| ML20008F982 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 05/11/1981 |
| From: | Nehemias J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20008F949 | List: |
| References | |
| NUDOCS 8105120441 | |
| Download: ML20008F982 (10) | |
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.05/11/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI0ii~
BEFORE THE AT0iilC SAFETY AND LICENSING BOARD In the Matter of..
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HOUSTON LIGHTING & POWER COMPAliY
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' Docket No. 50-466
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(Allens Creek Nuclear Generating
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Station, Unit 1)
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fiRC STAFF SUPPLEMENTAL. TESTIM 0ilY OF.
JOHit V. NEHEHIAS RELATIVE TO OCCUPATIONAL RADIATI0il EXPOSURE-
[TEXPIRG Contention AC 21]
i Q.
Please state your name and position with the ilRC.
A.
My name is John V. Nehemias, a Senior Health Physicist in the i
Radiation Protection Section of the Radiological Assessment Branch.
Q.
Have you prepared a sta'.enent of educational and professional qualifications?
4 A.
Yes.
It is attached to this testimony.
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What is the purpose of this testinony?
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A.
The purpose of my testinony is to respond to TEXPIRG Contention AC 21, which concerns projected occupational radiation exposures at the proposed Allens Creek Nuclear Generating Station (ACitGS).
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This contention basically asserts that the Staff has underestinated the environmental impact of radiation exposure to the workers.at the Allens Creek plant.
Q. What is the asserted basis for this contention?
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8105120 %
A.
TEXPIRG asserts that occupational radiation exposure _ at certain boiling water reactors (BWRs) has exceeded substantially the Staff's projections of average annual person-reu doses.
The contention refers to the value of 570 person-reas per Gigawatt-year (electric) in the Final Generic Environmental Statement on the Use of Recycle Plutonium in Mixed 0xide Fuel in Light Water Reactors (GES 10), HUREG-0002 (/ugust 1976). The Final Supplement to the Allens Creek Final Environmental Statenent (NUREG-0470) projects an annual average dose of 500 person-rems per reactor.
The contention also asserts that actual experience at Millstone 1, Hine Mile Point, Oyster Creek, and Pilgrim has indicated annual doses of about three times the projected average person-rem dose.
Q.
Is this assertion essentiallly correct 7 A.
Yes. Each of these four reactors have experienced relatively high person-rea doses, as shown in Table 1.
During the 5-year period, 1975-1979, the average annual person-rea dose for all operating BWRs has been:
i 1975 701 person-reas 1976 547 1977 828 1978 604 1979 733
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Q.
What has been the operating experience in terms of occupational dose for BWRs in general?
A.
Based on actual operating experience, occupational. dose has varied considerably fran plant to plant and from year to year. Average individual and collective dose information is available froa over 125 reactor-years of operation between 1974 and 1979. These data indicate l
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that the recent average annual reactor dose at BWRs have been about 700 person-reas, with particular plants experiencing average annual doses ranging froa as high as 1850 person-reas to as low as 220 person-reas.
i Thus, these averages are based on widely varying yearly doses. ForL example, annual collective doses for BWRs have ranged from 44 to 3626-person-reas per' reactor. The average annual dose per nuclear plant worker has been dbout 0.8 rea. " Occupational Radiation Exposure at Connercial Nuclear Power Reactors, 1979," NUREG-0713, Vol. 1, B. Brooks (March 1981).
_ Q.
Why is there a wide range of occupational doses at different BWRs?
A.
The wide range of annual doses experienced by U.S. BWRs is dependent on a number of factors, such as the amount of required routine and special naintenance and the degree of reactor operations and inplant surveillance.
Since these factors vary in an unpredictable nanner, it is topossible to determine in advance a specific year-to-year or average annual occupational radiation dose for any particular plant over its operating lifetine. Operations requiring high doses can occur, even at plants witn radiation protection prograas that have been developed to assure that occupational radiation doses will be kept at levels that are l
as low as. reasonably achievable (ALARA). These differences result priuarily fron the occurrence of random events, such as specific component failure, which involve significant exposure and requires prompt repair or replacement. These events can cause radiation doses in any given year to be significantly higher than in other years.
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1 Q.
Can the occupational doses.from operating experience be used to-project average annual occupational radiation exposures. for ned plants?
l A.
Yes. Tne Staff uses theLexperience to date witn nodern-BWRs to project the average annual doses to nuclear plant workers for environmental impact purposes.. Host of the dose,to nuclear plant workers is due to external ' exposure to radiation from radioactive naterials outside the body rather than from internal exposure fron inhaled or ingested radioactive materials. Licensed 1000 flue BURS docketed since 1975 have been reviewed on the basis of the new-(post-1975) regulatory requirenents and guidance regarding ALARA coqsiderations, and coanitted accordingly to ALARA considerations in design, construction and 7
operation. These new requirements and guidance place increased emphasis -
on maintaining occupational exposure at nuclear power plants as lot as 4
reasonably achievable (ALARA) and are outlined in 10 C.F.R. Part 20, the NRC Standard Review Plan, Chapter 12 (NUREG-75/037),Jand RegulatoryL Guide 8.8, "Information Relevant to Ensuring tnat Occupational Radiation Exposures at Nuclear Power Stations Will 3e As Low As Is Reasonably-Achievable."
Q.
How does the Staff project occupational radiation exposures at new nuclear plants?
A.
We project occupational radiation exposures at new nuclear power plants by using average figures, based on nany reactor-years of data. We can predict that some plants will experience higher total dose; and some plants will experience lower total doses; we cannot predict, however, which specific plants will experience relatively high or relatively low total doses. We use the average annual dose as a basis for projecting i
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Q i expected average doses in the future, not as a prediction of what is to be expected at any particular plant. We can project with reasonable confidence the average occupational radiation dose for large, nodern plants going on line.
Q.
liow are r,adiation protection programs reviewed by the Staff?
A.
These programs are reviewed by the Staff at both the construction pernit and operating license stages, and also durint actual operation, ageinst 10 C.F.R. Part 20, Regulatory Guide 8.3, and fiUREG-75/087. Approval of the proposed implementation of applicable requirements and guidelines is granted only af ter the Staff revies indicates that an ALARA program can be implemented satisfactorily.
Q.
What does the Staff's review of the Allens Creek radiation I
protection program indicate?
A.
As a result of our review, we have found t..at the Applicant is committed to design features and operating practices that will assure that individual and collective occupational radiation doses can be maintained within the limits of 10 C.F.R. Part 20 and as los as is reasonably achievable. The Staff's review is set forth in Chapter 12 of I
the Safety Evaluation Report, Supplement ido. 2, fiUREG-0515 (l1 arch 1979).
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Q.
Based on actual operating experience and its review of newly l
developed radiation protection programs, what does the Staff expect and project with respect to occupational radiation exposures at new BWRs?
A.
We cannot, of course, predict the future. At any given plant, unforeseen difficulties can result in high exposure levels.
Conversely, applica'. ion of new methods for reducing dose rates or maintenance
- t r<,uice nts can result in lower exposure levels.
In this regard, ho ever, two points can be made:
4 (1) As noted above, the data indicate, based on 125 BWR reactor years, that average annual doses h4ve. leveled off since about 1974, averaging around 700 person-reas.
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In' addition, also as noted &bove, we have been placing increased emphasis since 1975 on design, construction and operational features intended to maintain occupational i
radiation exposures at nuclear power plants as low as -is reasonably achievable.
Barring unanticipated new needs for major repairs, we expect that plants which have been designed, constructed and operated in accordance with these considerations will experience lower exposure rates as a 4
result.
4 Q.
What do you conclude regarding this contention?
A.
The estimate of the occupational exposure to workers at Allens Creek as stated in the Final Supplement to the Allens Creek FES (500 person-reas per reactor per year) was based on the data available at that time.
Operating experience of BWRs between 1974 and 1979 has averaged about /00 person-rens/ reactor /ye.
However, as noted above, the Staff expects that new BWRs will experience lower occupational exposure levels due to the implementation of ALARA radiation protection programs applied 4
to plants docketed since 1975.
In any event, the estinate of the occupational exposure in the FES is for purposes of estimating the average environmental impact of occupational radiation exposure at a large, modern plant. Any revision of the estinate of the average annual
. t occupational radiation exposure based on recent operating experience, would not danage any of the Staff's conclusions stated in the Allens Creek FES or SER.
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TABLE 1 Plant First Year Nuuber of liighest A,inual Total Dose Average Annual of Operation
- Years of Dose through 1980* Dose through 1980*
Opera tion *
(person-rens)
(person-rens)
(person-rems)
Millstone Point 1 1972 8
2202 10893 1361 Nine flile Point 1 1970 10 1497 6734 673 Oyster Creek 1970 10 1614 10355 1036 Pilgrim 1 1973 7
3626 12974 1853 Not including the initial year of operation.
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John V. liehemias PROFESSIONAL QUALIFICATIONS Radiological Assessment Branch-Division of System Integration I an a Senior Health Physicist in the Radiological Assessment Branch, Division of Site Safety and Environmental Analysis, Office of Nuclear Reactor Regulation.
My foraal education consists of study in Physics at Rensselaer Polytechnic Institute where I received a B.S. in 1948 and at Columbia University where I received an A.11. in 1949.
I received a Ph.D. in Environuental Health (Radiological) from the University of litchigan in 1960.
Before joining AEC/NRC, I served three years at Brookhaven flational Laboratory as a health physicist, six years at the University of Michigan as health physicist and assistant director of a radiation effects laboratory, and three years as Director of Radiological Health Surveys for the National Sanitation Foundation.
In the latter position, I designed, organized, and directed the environmental survey for the Enrico Fenni nuclear plant.
I joined the AEC in September 1960, as a health physicist in the Office of liealth and Safety. My principal duties there related to developaent of radiation protection standards. With the two exceptions noted below, I have continued with AEC (and NRC) since that time. My principal responsibility was in the development of Standards until September 1974; during most of those years I served as a branch chief-through several nace changes and reorganization-nost recently as Chief, Occupational Health Standards Branch,-
!! arch 1972 to September 1974.
Since September 1974, I have served as Senior health physicist in the Radiological Assessment Branch. !!y principal function is the revied of power reactor applications, both at the construction permit and operating license stage, to determine the adequacy of proposed occupational radiation protection prograns and the related efforts proposed to assure that occupational radiation exposures will be maintained as low as is reasonably achievable.
From June 1963 to September 1965, I took a leave of absence froa AEC and served as principal neaber of the Occupational Safety and Health Division of the International Labor Office in Geneva, Switzerland. My work was principally in the development of international standards.
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In December 1971, I was transferred -to the Criteria and Standards Division.
EPA, serving as Chief, Criteria and Standards Branch, until ny return to AEC in'Harch 1972.
I have published about 40 technical articles in professional journals and.
i other publications in the general areas of low-level counting, environnental monitoring, radiation effects on biological systems, and control of occupational radiation exposures.
I have been a Certified Health Physicist since 1960, and en a Charter nenber of the Health Physics Society and of the Baltimore-Washington Chapter.
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