ML20039B793
| ML20039B793 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 12/02/1981 |
| From: | Stoddart P Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20039B771 | List: |
| References | |
| NUDOCS 8112230561 | |
| Download: ML20039B793 (10) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Cincinnati Gas and
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Docket No. 50-358 Electric Co.
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(Zimmer Nuclear Power Station,
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Unit No.1)
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DIRECT TESTIMONY OF PHILLIP G. ST0DDART REGARDING DR. FANKHAUSER CONTENTIONS 2(c) and 2(e)
State of Maryland
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County of Montgomery )
Phillip G. Stoddart, having first been duly sworn, hearby states as follows:
I am employed as a Senior Nuclear Engineer in the Effluent Treatment Systems Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation, of the U.S. Nuclear Regulatory Commission, Washington, D.C.
My professional qualifications are set forth immediately below.
EXPERIENCE My present assignment with the NRC dates from August 1973, in the areas of radioactive ef fluent monitoring, radioactive ef fluent treatment and control, and radioactive waste management, with the Effluent Trectment Systems Branch, Division of Systems Integration.
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_2-I came to the NRC in August 1973, on a temporary technical assistance assign-ment from the Idaho Facilities of the Argonne National Laboratory to the Ef fluent Treatment Systems Branch, and, subsequently joined the NRC staff as a nuclear engineer in October 1974.
In this position I am responsible for the review and evaluation of radioactive waste systems and for the calculation of releases of radioactivity from nuclear power reactors. I am also responsible for determining the adequacy of instrumentation provided for detecting and reasuring the radioactive discharges from nuclear power plants and for providing technical bases for guides and standards.
I have participated in generic
. studies of the relationship between reactor operation and radioactive waste generation and in the preparation of staff reports related to effluent control technology and effluent monitoring.
From 1953 to 1973 I was on the radiation safety staff of the Argonne National Laboratory, working from 1953 to 1957 at Argonne's Illinois site and from 1957 to 1973 at Argonne's test facilities at the National Reactor Testing Station Idaho Falls, Idaho. My duties there included conduct of radiation safety programs, including ef fluent control and waste management, for several research and test reactors and a fuel recycle facility.
From 1949 to 1953 I was on active duty with the United States Air Force, assigned as a radiological instrumentation specialist with the Armed Forces Special Weapons Command and as a radiological safety instructor with a Strategic Air Command special weapons unit.
. t I have published in journals of the American Nuclear Society and the Health Physics Society.
In addition, I have published technical reports at the Argonne National Laboratory.
I am a member of the American Nuclear Society.
I am a member of the joint American Nuclear Society / Health Physics Society standards subcommittee ANS/HPSSC 6.8, which is preparing a draft American National Standard
" Selection and Design Criteria for Continuous Process and Effluent Radiation Monitors for Light Water Nuclear Reactors".
} Witn regard to the monitoring of radioactive effluents frcm the Zimmer Nuclear 1
Power Station, Unit No.1, Dr. Fankhauser's Contentions 2(c) and (e) state as follows:
2.... "The Applicant's plans for monitoring radiological releases i
from the plant are inadequate because:...
I (c)
It is unclear from the Applicant's plans whether all radioactive emissions will be monitored or whether only certain isotopes will be monitored."
(e) The statement by Applicant's that the monitoring will be "as comprehensive as possible" is vague and monitoring methods are unclear."
Intervenor Contention 2(c)
This contention concerns the Licensee's provisions for the monitoring of radioactive plant releases and whether or not all radioactive emissions will be monitored.
-_____a____.________
The applicant's provisions for monitoring emissions of radioactive materials from the Zimmer plant are described in Sections 7,11, and 12, and Appendix L of the Final Safety Analysis Report and are shown schematically in Figures 7.6-1, 7.6-2, 7.6-40 and 9.3-4 (Sheet 5 of 5) in the FSAR.
The range capabilities of monitoring equipment, sampling equipment, and measure-ment and analytical facilities and procedures, provided by the applicant for the monitoring of gaseous and liquid radioactive emissions from the plant, include the complete spectrum of radioactivity concentrations from the detec-tion and measurement of radionuclides naturally occurring in the environment,
. through radioactive materials expected to be released as a consequence of norraal operation of the plant, during relatively minor upset conditions, and releases from a wide range of postulated accidents.
For gaseous release points, such as the main plant vent at Zimmer, the NRC staff guidance in Regulatory Guides 1.21(1} and 1.97(2), and in Standard Review
- 3) specifies the continuous instrumented monitoring of radioactive Plan 11.5 noble gases, the continuous sampling of radioactive particulates and radio-iodines (followed by regular laboratory analysis, 'oy gamma spectrum analysis, for all detectable radionuclides), as well as regular periodic sampling and analyses of tritium and gross alpha activity. The Zimmer ef fluent monitoring l
program provides for all of the above and, in addition, provides continuous l
instrumented monitoring for halogens (iodines) and particulates (such as Cs-137
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or Co-60). With the variety of monitoring, sampling, and analysis programs provided at Zimmer, all environmentally significant radioactive gaseous emis-sions are monitored. Essentially the same moritoring programs are provided for all potentially radioactive gaseous emission points at Zimmer. Certain buildings at Zimner are not considered to be actual or potential sources of radioactive gaseous emissions and, therefore, emissions such as ventilation exhausts from these buildings are not monitored; examples of such buildings are the office and service buildings, sewage treatment plant, gatehouse, ware-house, and other miscellaneous structures.
- Radioactive liquid release points are continuously monitored for gross radio-activity in releases, with this monitoring supplemented b/ periodic sampling and laboratory analysis of effluents for identification of radionuclides in releases. Additionally, releases of potentially radioactive liquids from tanks on a batch basis require sampling and laboratory analysis of tank con-tents prior to release.
The staff's review of the referenced material concludes that the applicant has provided for the continuous instrumented monitoring, and for supplemental periodic sampling and radiological analysis, of all expected and potential radioactive releases from all of the potential plant release points by all of the monitoring equipment and sampling and analysis techniques that the staff considers to be practicable, necessary, and within the known state of '
the art.
. 4 Intervenor Contention 2(e)
This contention concerns the adequacy of the Licensee's provisions for monitoring and monitoring methods.
This response is limited in scope to discussion of such portions of the con-tention as pertain to radioactive ef fluent monitoring.
The phrase "as comprehensive as possible" apparently refers to a statement made by the applicant on page 6.2-3 of the applicant's Environmental Report.
The phrase, taken out of context, as was done in this contention, and standing
- by itself could be construed as vague and unclear. The contention might be valid if this phrase constituted the applicant's entire discussion of monitoring of radioactive emissions; however, this is not the case.
The applicant's provisions for monitoring of radioactive emissions from the plant are discussed extensively and lucidly in Chapters 3 and 6 of the Environ-mental Report, in Sections 5, 7,11, and 12 of the Final Safety Analysis Report, and in Appendix L to the Final Safety Analysis Report. The total substance of these rtferences is not vague, in the staff's opinion, nor are the monitoring methods unclear. The applicant's proposed effluent monitoring systems meet the NRC staff's acceptance criteria as presented in appropriate regulatory guidance documents.
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CONCLUSION As' stated previously, the identity of the radioactive isotopes to be monitored in effluents from the Zimmer Nuclear Power Station is well established, and the Applicant's monitoring plans are clearly defined in the material referenced supra in my testimony.
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v'Phillip G. StoddaPt -
Subscribed and sworn to before me this: : day of December 1981.
F6tary Public My Commission expires:
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. REFERENCES (1) Regulatory Guide 1.21, " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous l
Effluents from Light-Water-Cooled Nuclear Power Plants."
U.S. Nuclear l
Regulatory Commission, Washington, D.C.
20555. Revision 1, June 1974.
(2) Regulatory Guide 1.97, " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident".
U.S. Nuclear Regulatory Commission, Washington, D.C.
20555.
Revision 2, December 1980.
l (3) Standard Review Plan, Section 11.5, " Process and Effluent Radiological Monitoring Instrumentation and Sampling Systems."
U.S. Nuclear Regulatory Commission, Washington, D.C.
20555.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
In the Matter of
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CINCINNATI GAS AND ELECTRIC Docket No. 50-358 COMPANY, _e_t_ _a_l_.
(Wm. H. Zimmer Nuclear Power Station, Unit No. 1 CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF MOTION FOR
SUMMARY
DISPOSITION OF DR. DAVID B. FANKHAUSER'S CONTENTION 2(b),(c),(e),(f) AND (g)" and "MEM0-RANDUM IN SUPPORT OF DR. DAVID B. FANKHAUSER'S CONTENTIONS 2(b),(c),(e),(f)
AND (g)" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 21st day of December, 1981:
John H. Frye, III, Chairman Timothy S. Hogan, Jr., Chairman Administrative Judge Board of Commissioners Atomic Safety and Licensing Board 50 Market Street, Clermont County U.S. Nuclear Regulatory Commission Batavia, Ohio 45103 Washington, D.C.
20555
- John D. Woliver, Esq.
Dr. Frank F.. Hooper Legal Aid Society Administrative Judge P.O. Box #47 School of Natural Resources 550 Kilnore Street University of Michigan Batavia, Ohio 45103 Ann Arbor, Michigan 48109 William J. Moran, Esq.
M. Stanley Livingston General Counsel Administrative Judge Cincinnati Gas & Electric Company 1005 Calle Largo P.O. Box 960 Santa Fe, New Mexico 87501 Cincinnati, Ohio 45201~
Troy B. Conner, Esq.
Atomic Safety and Licensing Board Conner & Petterhahn.
Panel 1747 Pennsylvania Avenue, N.W.
U.S. Nuclear Regulatory Commission Washington, D.C.
20006 Washington, D.C.
20555
- James H. Feldman, Jr., Esq.
David Martin, Esq.
216 East 9th Street Office.of the Attorney General Cincinnati, Ohio 45220.
209 St. Clair Street First Floor W. Peter Heile, Esq.
Frankfort, Kentucky 40601 Assistant City Solicitor Room 214, City Hall George E. Pattison, Esq.
Cincinnati, Ohio 45220' Clermont County Prosecuting Attorney 462 Main Street Mrs. Mary Reder Batavia, Ohio 45103 Box 270, Rt. 2 California, Kentucky 41007
2-Lawrence R. Fisse, Esq.
Assistant Prosecuting Attorney 462 Main Street Batavia, Ohio 45103 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Cornission Washington, D.C.
20555
- Andrew B. Dennison, Esq.
200 Main Street Batavia, Ohio 45103 Mr. Samuel H. Porter Porter, Wright, Morris & Arthur 37 West Broad Street Columbus, Ohio 43215 f/:
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s Charles A. Barth Counsel for NRC Staff l
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