ML20040E425

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Affidavit of Ta Steele Re Contention 8,supporting Util 820202 Motion for Summary Disposition.Operation for Facility Indicates NRC Size, Frequency & Distribution Requirements for Monitoring Met & Exposure Pathways Adequately Monitored
ML20040E425
Person / Time
Site: La Crosse File:Dairyland Power Cooperative icon.png
Issue date: 12/01/1981
From: Steele T
DAIRYLAND POWER COOPERATIVE
To:
Shared Package
ML20040E414 List:
References
ISSUANCES-FTOL, NUDOCS 8202040316
Download: ML20040E425 (6)


Text

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UNITED STATES OF AMERICA MUCLEAR REGULATORY COMMISSION In the Matter of

.)

)

DAIRYLAND POWER COOPERATIVE

)

Docket No. 50-409

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(FTOL Proceeding)

(La Crosse Boiling Water

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Reactor)

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AFFIDAVIT OF REGARDING CONTENTION HO. 8 My name is Thomas A. Steele.

I am employed by Dairyland Power Cooperative (Dairyland) as Director of Environmental Affairs.

I have been employed in this position since 1971.

My professional qualifications are attached as Appendix A to this af-fidavit.

The purpose of this affidavit is to present written testimony in support of Dairyland's Motion for Summary Disposition and the NRC Staff's Amended Motion for Summary Disposition.

Contention No. 8 reads as follows:

CREC Contention No. 8 CREC contends that LACBWR's radiological environmental monitoring program is in-adequate in terms of (a) the metilodology of the testing (b) the size and distribution of the sample, and (c) the frequency of the sampling, in light of the off-gas levels, the geo-graphy of the area to the east of the plant, and the fact that the area is primarily a dairy region.

8202040316 920202 PDR ADOCK 05000409 0

PDR

, 1.

As described in the Table attached as Exhibit 1 to this affidavit, Dairyland's radiological environmental monitor-ing program for LACBWR complies with requirements of the NRC Staff Regulatory Guide 4-1, and the practices approved by the U.

S.

Environmental Protection Agency.

2.

Dairyland's radiological environmental monitoring program employs standard sampling and testing methodologies for detection of radioactivity, including gamma isotopic analysis, gross beta analysis and I-131 analysis.

Testing for these elements is conducted comprehensively and accounts for site specific con-ditions in the vicinity of the LACBWR area.

Dairyland monitors for radioactivity in the air, surface water, ground water, drinking water, milk, river sediment, fish, and food.

Dairyland's monitor-ing program has been operated over the past ten years and is tailored to the local meteorology, growing seasons, topography, population distribution and agricultural and human activities in the area.

3 The operation of LACBWR over the past ten years accompanied by a comprehensive radiological environmental monitor-ing program, indicates that the size, frequency and distribution requirements for monitoring established by the NRC have been met and that exposure pathways are being monitored adequately.

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. 4 I have read the foregoing affidavit and swear that it is true and correct to the best of my knowledge and belief.

J/ V'~

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Sworn to and subscribed before me this /4/'

day of

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1981.

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Appendix A Thomas A. Steele Professional Qualifications I am Director of Environmental Affairs for Dairyland Power Cooperative.

My formal education consists of a B.S.

from the Univer-sity of Wisconsin-River Falls in 1961, and an M.S.

from the University of Washington, Seattle, in 1963.

Before joining Dairyland Power Cooperative in 1968, I was employed as a Health Physicist for Argonne National Laboratory, Argonne, Illinois from 1963 - 1968.

At Argonne I was responsible for radiation protection at various facil-ities including the CP-5 Reactor, Zero Power Plutonium Reac-Lors, Plutonium Fuel Fabrication facility and Zero Gradient Synochron.

While at Argonne, I published papers on person-nel dosimetry and radiation protection associated with plutonium fuel fabrication.

l Since joining Dairyland Power Cooperative in 1968, I was Health & Safety Engineer at LACBWR until 1971, where the LACBNR radiation protection program and environmental survey program were developed under my supervision.

Since 1971, I have been Director of Environmental Affairs for

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Dairyland Power Cooperative.

I organized and developed the Environmental Department for Dairyland, which is responsible for environmental and regulatory functions associated with Dairyland Power Cooperative's generation and transmission systen.

I am certified by the American Board of Health Physics and have served on various industry and power pool commit-tees.

Thomas A.

Steele

Eshibit 1 SENSITIVITY SMtPLING SAMPLING ANALYSIS ANALYTICAL DETECTION SAMPLE SITES METIOD DURATION FREQUENCY PERFORMED PROCEDURES LIMIT j

Airborne

a. Radio-7. samples Constant Flow Continuous Charcoal Isotopic Count Immediately 3sl0'3 pC1/m lodine &

!) la Crosse Sampler and Canister Analysim for Particulates

2) Farm on Ridge to No.

Flater Analyzed 1-131

3) lock & Das #8 Weekly
4) Crib House Continuous Particulate Cross Beta Count After 24-
5) Farm on Ridge to Ea.

3 Class Faber Filter Activity Hour Decay 2s10' pC1/m

6) Trailer Ct. to So.

g y

7) Farm on Ridge to So.

Direct bosation 38 locations Themoluminescent Continuous At least once Camma Vendor I mR/ Quarter Dosimeter Every 92 Days Waterborne

a. Surface 3 Sites Rinse Bucket With Crab Monthly Cross Beta Evaporation And Isl0' pC1/1 I) lock & Dan #8 River Water Pull Analysis f.,
2) Boat Launch Area in Sample Making 8
3) Victory Sure Bucket Doesn't Scrape Bottom
b. Drinking Cenoa Flush Line For One Crab At Least Quarterly Cross Dried and Counted Isl0' pC1/1 1ACBWR Minute. Collect Beta Trailer Court Sample Cenoa Fish Hatchery

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c. Rain lock & Dam #8 Collec t ion Continuous Monthly Cross Beta Dried and Counted IsIO pC1/1 Pedretti F.a r m Container P. Malin Fara Soil
a. River Silt /

Plant Intake Sc rape Sediment crab Two Times /Yr.

Camma Isotopic Dried and Counted Is10'I PC1/g Shoreline Boat launch From Shoreline

  • Analysis Sediment Plant outfall Drop Dredge or Scoop In River

.._1

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Eahibit I (Continued)

SENSITIVITY SAMPLING SAMPl.1NC ANALYSIS ANALYTICAL DETECTION SAMPLF.

SITES HETHOD DURATION ETEQUENCY PERfDRMED PROCEDURES LIMIT Ingestion

a. Milk P. Malin From Proprietor Crab At least Sr-90 Radiocheetcal

! pC1/1 A. Malin B1 Weekly 1-131 Separation When Cous P. Pedretti Are On Pasture

-2

b. Fish Mississippi Commercial Crab 81-Monthly Camma c - Isotopic 3 10 pC1/3 River Fish Analysis On Edible Portions Dried and Counted At Time Of Camuna Dried and Counted 1 10' pC1/3
c. Food Products 3 locations Tsom Propriator Crab Ha rve s t.

Isotopic Analysis Ciano11 Farm Carden Vegetables y

f da P. Malin Farm i

Broadleaf Vegetation Pedretti Farm e

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