ML20024E853
| ML20024E853 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/31/1983 |
| From: | Eddleman W EDDLEMAN, W., JOINT INTERVENORS - SHEARON HARRIS |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20024E830 | List: |
| References | |
| 48-468-1-OL, 82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8309070137 | |
| Download: ML20024E853 (10) | |
Text
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DOCKETED use:
UNITED STATES OF AMERICA August 31, 1983 NUCLEAR BEGULATOBY COMMISSION 83 SE -6 N1 :07 0FFICE OF SECRETAR 00CKETmG & SERVir"e BEFORE THE ATOMIC SAFETY AND LICENSING BOAgMCH Glenn O. BriFht Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of
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Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al.
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50 401 OL (Shearon Harris Nuclear Power Plant,
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Units 1 and 2)
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ASLBP No. 82-h68-01
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OL JOINT INTE9VEK0"S8 RESPONSE TC STAFF INTE""OGA"'ORIES 2h j
Under our readin6 of theBonrd's 8-58-83 Order and pursuant i
to an oral request from counsel for the Staff, Joint Interveno*s l
Conservaticn Council of NC, CEAUGE/ELP,i,-
_m Alliance and Wells j
Eddlenan nrovide the follouing responses to URC Staff Interrogato-les 1
l to Joint Intervenors.
I GENERAL IUTERROGAT0"IES Preliminary:
Discovery is not onen on Joint Contentions I and VII (see Board Order of 3-10-83) so no answers on these are provided.
We understand (C. Barth to W. Eddleman, 5-83) that the Staff has dronped its requests for identity of non-witness exne=ts.
1.
Joint II: See resronses of 5-16-83 and 8-31-83 to Anplicants.
hf o
8 The inadecuacies are explained in considerable detail there and it "o
is burdensone to repeat it here.
l g
ff Joint IV, V, VI do not assert inadecuacy of "snalysis" by 04 Applicants or Staff.
g 2.
We don't have resumes of most of then.
Gornants background is in Radiation and Hunan Health, 1981.
Not Anrlicable to IV,V & VI.
~2-3 Joint II:
See referenced works and answers to Apnlicants' Interrogatories on Joint II.
It is burdensone for us to write out a sunnary of views of individualc or grouns expressed in their books or scientific papers.
Staff can sunnarize as well as we can (though we do not guarantee Staff will).
Not Apolicable to IV,V,VI
- 4. See references in papers cited in resnonses to Apnlicants' those Interrogatories on Joint II, and citations in resnonses.
We will nake these available-to Staff where they are in our possess!en.
Not Apnlicable to IV, VI, V.
- 5. See 4. Yes.
6.
None identified so far.
7, 8: See 6.
9.
Any calculations made resnonsive to snecific interrogatories will be identified under. then.
To our knowledge, we have not calculated to substantiate our cententions at this ooint.
Analysis is generally set forth in the basis for the contentions and those they sunersede.
We do not possess the infornation in the form you reouest it in.
Joint II: Analysis-(see resronses to Aunlicants, 5-16 and 8-31-83) i shows that there are nany factors leading to underestination of health effects.
These have not been precisely cuantified by us yet.
Joint,IV:
Error of TLD's nlus or ninus 30% was established as basis of a contention in Catawba.
Lack of real-ti e monitoFine Aprlicants' Resp to JI's Inter-ogstery lb, 8-1483 ability of TLDs is admitted.
Ability of pressurized ionization monitors to detect specific nuclides in real time is known fron l
We dcn't have these in hand.
l nanufacturers' specifications; Aprlicants say (resn to our int. 15(a))
l that recordin6 ocuirnent is available for it.
We believe that it 1s not ALARA unless doses are ncasured accurately, and the best l
Arnlicants can cone un with is about plus or ninus 20%.
Thet isn't At nininun, accurate enough to determine exnosure levels safely.
j
. the error should be assuned to be at maximun (including expected drif t after calibration) in settin6 exnosure limits, e.g. if calibration is within 20% and exnected drift is 5% at the time of use, real dose should be assuned as 125% of indicatod, and the limit used should be o.8 (1/1.25) of that allowed were the instrunent accu
- ate.
Joint Intervenovs still believe pressuvized ionization measurenent is the most anpronriate and accurate way to assess actual radionuclides workers are exposed to.
V.
Our analysis is based on known highev drift in lonEer intervals between calibrations.
Look at the setvoint drift eroblems CF&L's Brunswick plant has had, and how much nore frecuent calibrations were needed to keep then nore of ten within limits as required by technical snecs.
Air monitors and sanviews are energency also subject to variations in volume.
Applicants say their air sanplers will be within plus or minus 15% when calibrated, on volune intaken versus arturt reading of intake.
In - plant menitors accuracy is not now known to Aeplicants (vesnnnse to intev"ogato"y 16(II) l (a) 8-1-83)
This can't be considered accu
- ate enough when it's not even known.
Joint Intervenors believe 5% e*ror is genevous on air sampling volumes and could incornorate substantial e="or over time, especially since va-iation of air volune deverds on the intake i
suction and thus nay stayx off or nove further off frcn the l
l calibratieri standard ove" tine.
JOINT VI:
Lack of srecific radionuclide detection on a pronpt basis is shown in Anplicantn' resonnse to our interrogatory i
rix f
16 (III) pp 15-17 8-1-83 They need pressugied donization monitors l
te do it as those are the only nonitors we Ynow that can rapidly l
1
)
detect specific radionuclides. They also (see resp te 16(II)) have to take time to analyze samples from air sanulers.
This shows that l
l
-h-the data from these sanplers isn't pronnt either.
Knowing what nuclides are being released is necessary to protect publize health and safety and to protect the public and energency response personnel in and out of the nuclear plant.
ALA9A is not satisfied if only sone nuclides are detected, af ter sono tine, when eouipnent is available to pronptly detect then all, both at release and in the environnent and where energency personnel and the nublic are at risk of bein6 exposed.
10.
Analysis was nade by the representatives of the Joint Intervenors, and by those (nancs not known to resnonder) who helped fornulate their contentions; Analysis also incitdes ideas fron nonwitness experts, as to whon the Staff has dropped its inouiry pursuant to the Board's 5-27-83 Order.
You know the eddresses and telephone nunbers of all representatives of the Joint Intervenors.
We object to providing the other infornation as to nenwitness exnerts.
If we find other responsive infornntion we will supplenent thisanswer.
11.
Please see resnonse to Interrogatory 9; its answer is yes, and summaries are given for Joint IV, V and VI: objection to sunnarizing for Joint II because the info is so extensive and it's been given in resnonse to Arnlicants ' interacgatories.
12.
You have a copy en pages 2-h above;
_ Yes, other analys3s will be nade available; identification of nonwitness exnerts will be deleted fron it if any were involved in it.
13 Wells Eddlenan, 718-A Iredell, Durhan NC 27705, 919-286-3076.
Information on who else contributed to each answer is not available in the form reouested; nonuitness experts are not identified.
SPECIFIC INTERDOGATOFIES (Joint IV): 14 We do not have this ir;fo yet by sannlin6 distribution.
Our analysis is not connlete of the info received
. fron Anplicants 8-1.
E.g. the Health Physics article they refer to re TLD's, April (1983, though they don't say that) (8-1-83 respon*e at 11) was not available at the UNC-CH Health Sciences Library when Wells Eddlenansas there last week.
The unreliability of TLDs to ulus or ninus 30% is established as the basis for an admitted contention in the' Catawba proceeding.
Inaccuracies in the plus or ninus 50% and more range hnve been renorted, but the cite on that is not readily available.
We understand it was a study done for the NRC and that when accuracy bv nost laboratories of rius or minus 30% could not be achieved fon do sir.e try, th e NRC relaxed its standards.
Joint intervenors de not believe such relaxation of standards is censistent with ALARA or the p*otection of the publime health and safety. We believe the info may be in m*EG C7 2891 and 2892 which we haven't yet reviewed. 15.
See response to lh.
Will sup-len6nt when analysis done.
16.
We don 't know yet.
We object to "which nay be used" since we should only have to answer for what CF6L says it will use.
CP&L plans to use TLDs made in Japan, not the USA, see resnonne to our interrogatory 16(I)(a) 8-1-83 at 9, top.
17.
See response to Ih.
We will surnlenent when more info is available.
We don't know what " generation" of TLDs you mean, as the Har*ris TLD's identified by Applicants appear to be a new true on which data is just being published this year, ref, their 8-1 83 resuonse at 11, article by Takenaga, Yananoto and Yanashita, April (1983) "A New Phosnhor lib 0:Cu for TLD", Henith Physics kh(E) no page cite given.
As noted above, we locked for this docunent (WE did ) and it was not available last week.
'A.
Joint Intervenors have not dete-nined all this data.
We believe portable pressurized ionizat* on ronitors with real-tine recording dquipment attached are available in packages sr.all enough
' I and light enough in weight to be noved near werk stations and used in radiation hazawd areas are available.
Ou" analysis is l
not yet connlete.
19.
Yes, if equipped with recording equipment which Applicants f
agree is available.
Computation may be reouired.
The dose found in this way, however, will be nuch nore accurately detern'nted than by a TLD with an accuracy of plus or ninus 30%. Connare EPA docunenS RD 71-1, p.33, end of section 3 3.8, desirability of knowing nuclides.
20.
See Annlicants' resnonse to15(a) 8-1-83; we niso rely c
on opinions of nonwitness expe=ts Wells Eddjenan has spoken with in the past.
We object to identifyin6 then here; we uhderstand Staff is not recuesting identification of such nonwitnes9 exnerts anyway.
- 21. Analysis is inconnlete.
Additional data was supplied by Apelicants 8-1-83 We will supplement but do not have tine now to undertake this review just to answer your ouestion.
The contention does not deal directly with the accuracy of self-reading dosineters, but we have not established their accuraer eithd 22, 23: olease see 21.
Addendun to 23: If the TLD readings are inaccurate, the other dosineter cannot vewify them and should not.
The only useful information would be when either the range of error (plus and ninus) of both the TLD and the s&lf-reading dosineter used at the SAME POINT and SAE TIMES either (1) cenpletely overlap, t'hus confirning each other within their margins of er ror, or (2) conpletely fail to overlar, indicating that one on the 6ther, or perhaps both, are wrong.
JOINT CCUTENTION V 2h.
Wells Eddlenan doesn't possess PG 8.25 Travis Payne We will sunalement when has looked for it and cannot locate it.
i we 6et a cony.
Wells Eddlenan has ordered one.
25 See 2h.
I 1
. 26.
The only ones known to us to be for use at Harris are those identified by Apnlicants 8-1-83 to us.
If we learn nore we will supplement.
The identification of nonitors is given by then and we don't have time to rebrue it for you.
27 We relied on opinions of those who formulated or helped to fornulate contentions for the individual intervenors --
not list is available -- this includes nonwitness exnerts.
have nore.
Further analysis is inconclete and we will supplenent when we Applicants concede that NRC reconnends every 6 nonths, not every year.
We believe See their questions to us, and our responses, on thet.
this is in their first set, January 1983 date (31st), but can't readily locate it when these resnonses are being rwenared.
Joint VI Second 27.
We believe that exce7t for sone rad'ciodines (e.g. I-131) and sone noble gases (e.g. sone Kr and Xe isotopes), all radionuclides escaring the Harris plant will not be detected as these snecific radionuclides in the enounts released.
Applicants are not installing equipnent te detect specific radionuclides.
- 28. Fron the nain vent stack, all EVAC exhaust points, all and release points identified by Applicants so far in the FSAD in response to interrogatories by any parties, and f*on other points, and as liquids both through the radwaste processing systen and by bypassin6 it.
None of the detectors identified by Applicants has the 29 ability to detect snecific radionuclides othe" than I-131 and sone The contention is Kr and Xe isotones, so far as we are aware.
l that the snecific radionuclides and anounts released will not be detected (in part: this is the last nart of it).
Environmental monitoring cannot cure this deficiency because
. environmental nonitors are not sensitive enough nor nunevous enough to detect what the plant is actually releasing.
A study by D.
Pisello et al (cony not yet in hands of any of JI to best of WE's current knowledge) points out that the mininun release detectable a
even by a ring of nonitors such as in Applicants' environnental monitoring pro 5ran is still on the order of a billion tines the mininun detection limit of the detector (or analysis method for nonitor the nonitor, assuming no decay in getting to the datwater or in getting analyzed).
Thus, releases of many tines (un to nearly 1 billion ti.nes) the mininun detect $cn limit of any detector or analysis nethod nay go undetected es f ar as the specific nuclxxides and amounts in the environnent. Indeed, the entire release would go undetected in the environnent.
Applicants state that their stack nonitoring eouirnent ete can be out of s ervice without having the plant shut down.
- Thus, un nonitored releases (even as te counts per n'nute, which is not identifyinE specific nuclides and anounts) can occu".
The=e are also release points CP&L does not monitor. (see resronses to interrogatories on Eddlenan 29: as easy for you to look up as for us tc ).
There is also the oninior. of nonwitness errert "Xerxes Xoe" who says"you need to know what is coming out of the olant at all times" to assure radiological safety for the public.
30.
We don't have a catalog of nressuvized ionizat'on monitors accessible, and nay not have one at all.
We will sunple-ent as necessary as we continue our analysis.
We cannot guarartee that any given nonitor will detect and neasu*e all rad'onuclides =eleased fron Earris if CP&L operates it.
No believc dcubir o" triply redundant detectors would be treferable and allow "or outages.
Trinly redundant or nore would be bent as it gives nore veliability of function and nc=e ability to crosscheck readings.
9-31.
See 30 as to inconpleteness of present analysis.
Pressurized ionization detectors can d6tect specific fadionuclides beirg passed through then.
The ability to nake such detection, assess the anounts, and record the results (see Apns resronse to our interroratory 15(a), 8-1-83) is required.
- 32. (1) ALARA (2) Atonic Energy Act requirenent that safety of uublic be prinary responsibility of AEC (and successor NRC) (3) orinion of "Xerxes Xoe", nonwitness expert inforns117 cor sulted. (4) 10 CFR part 20 which sets linits for everv nuclide released, anong fission products, activation products, transuranics and other
)
radioisotopes found or produced in nuclen* power plantsend of section 3 3.8 a(e.g. H (5) RD-71-1, CP&L Docunent 000008, t page 33 Further analysis on this question is incomplete and we may supplement this restonce when we have nere informaticn.
33 There is no interrogatory 33 3h.
Analysis ir. not connlete.
We do net think the analyksis required for the contention can be done until the energeny plan is set forth and nade available to us fo" review.
Detection tine is only part of the problen, and while we would not argue it is irrelevant, it is incomplete and needs te be analyzed in the context of the energency plan.
- 35. Analysis incomplete.
Joint Intervenors have not yet l
quanitified this detection tine in any detail.
However, since even the fastest nethods pronosed by Apn11 cants involve taking samnles and analyzing then, direct-readout pressu*ized ionization nonitors will give faster readinEs.
As to nuclides Applicants do not have equipnent to directly detect, any nethod that detects then is faster (since not-detected is the sane as neve-detected).
Pressurized ionization equipnent with direct readout is nuch faster.
, Of course, this equipment should also record its readings for integrated dose calculations and future reference as well as direct use during ener6encies.
36.
See above resuonses for sone descriptions of deficiencies.
Our analysis is not connlete.
It is nnt available in the forn reouested and it would be burdensone to work it up in that forn.
As we develop our analysis further, we will supplenent thin response at an arpronriste tine.
We will attennt to locate the sections as best we can, down to the lines as we review then, if that is practical.
37.
See 36 above and above resnonses.
As noted above, analysis is presently inconplete.
See also cuestions and responses on Eddlenan 80 (release poirts ) and 29 (release noints and nethods of leakage /escare of radionuclides.
Where radiciodines can escape, in general other nuclides can too as gases, licuids or pa"ticles, particularly these in elenental on chenically-bonded fo"ns as or (1) volatile or (2) soluble than radioxiodines, but net limited nere to x these).
NOTE: ThT9E 'E9E No SP2CIFIC INTE'90GATORIES FROM STAFF ON JOI?:T II.
Production of docunents: Those we nossess, we will produce; please contact Wells Eddlenan by 9-30-83 to ar-ange nutually convenient place and tine and conditions.
I hereby affirn the above resnonses are true to the best 1
'F
/
of my present knowledge and belief.
y'4W 8-31-83 Wells Eddleman