ML20054F609
| ML20054F609 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/11/1982 |
| From: | Lamastra M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20054F597 | List: |
| References | |
| NUDOCS 8206170152 | |
| Download: ML20054F609 (7) | |
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UNITED STATES OF AMERICA o
NUCLEAR REGULATORY C0". MISSION BEFORE THE AT0i4IC SAFETY AND LICENSING BOARD In the Matter of
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ILLIN0IS POWER COMPANY Docket No. h-461 (Clinton Power Station, Unit 1)
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8 NRC STAFF TESTIMONY OF MICHAEL. A. LAMASTRA REGARDING TP.E CONTINUOUS AIRBORflE RADI0 ACTIVITY AND AREA RADIATION MONITORING INSTRUMENTATION (PRAIRIE ALLIANCE CON 1ENTION 9)
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Please state your name and position with the NRC.
A1. My name is Michael A. Lamastra.
I am enployed by the U. S. Nuclear Regulatory Commission, as a Senior Radiological Engineer in the Division of Systems Integration, Radiological Assessment Branch. A copy of my professional qualifications is attached.
Q2. What is the purpose of your testimony?
A2. The purpose of this testimony is to respond to Prairie Alliance Contention 9, which reads as follows:
9(PA#13). The CPS should not be licensed to operate until Applicants have denonstrated that radiation exposure levels will be maintained as-low-as-reasonably i
achievable as required in 10 CFR 20.1.
The FSAR does not adequately consider accupational radiation exposure to be expected from either the normal operation of CPS Unit 1 or that which may occur during an abnormal occurrence or serious accident.
Specifically, 8206170152 820611 PDR ADOCK 05000461 T
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2-(a) Applicants hav failed to provide a sufficient numbpr of monitors to continuously measure airborne radioactivity; additionally theimonitors provided are not sufficiently sensitive in that they require up to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to detect emissions; (b) The area radiation monitoring equipnent does not provida a reasonably f
assurance of accuracy in that it is only accurate within plus or minus 20%.
Q3. With regard to Contention 9A, what commitments has the applicant made in the FSAR?
A3. The applicant has connitted to use a Continuous Airborne Radioactivity Monitoring Systen (CAMS) composed of 13 fixed CAMS located in selected branch exhaust ducts of the R/AC system and 10 portable CAMS ttat can be used throughout the plant to meet the following objectives; (1) To warn of inadvertent release of airborne radioactivity to prevent overexposure of personnel to excessive concentrations of radioactive material; (2) To assist in maintaining occupational radiation exposure to airborne contaminants ALARA by informing personnel of area airborne radioactivity concen-trations prior to commencing work so that appropriate precautions can be taken; 9
(3) To check on the integrity of systems containing radioactivity in areas monitored.
The CAM system is not designed to be used as personnel monitoring instrumen-tation i.e., measurements from CAM's should not be routinely used to assign intakes to plant personnel in accordance with the requirements of 10 CFR Part 20.103 unless l
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it can be shown that the samples taken are representative of workers' breathing Normally intakes \\ould be determined based on results\\from portable air zo n es.
samplers located in specific work areas. The applicant has committed to provide 22 portable sampiers to sampie during such work.
p Q4. What acceptance criteria did the NRC staff use to evaluate the Clinton's CAM system?
A4. The staff acceptance criteria stated in NUREG-0800 " Standard Review Plan" (SRP) Section 12.3.4 is 10 MPC-hours. This minimum detection limit is sufficient to meet the criteria of 10 CFR 20.103. 10 CFR 20.103 sets an intake limit of 40 MPC-hours a week over a 13 week quarter for a total of 520 MPC-hours.
It also requires the consideration of engineering and other controls to reduce the intake of radioactive materials to workers at 10 MPC-hours in any week.
It is important to note that NRC regulations and acceptance criteria for air-borne radioactive materials are based on time-weighted exposure to concentration of radioactive material. This method indirectly sets a maximum limit on the amount of radioactive material a worker may inhale in any quarter.
It does not set an absolute detection time for a monitor to detect radioactivity enissions. For example an air monitor set to alarm at 10 MPC-hours will alarm in 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> if concentrations sampled are at 1 MPC, 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> at 2 MPCs or 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 10 MPCs.
In all three examples, even if a worker was continuously present, he would receive less than 2 percent of NRC quarterly intake limit (10 MPC-hrs /520 MPC-hrs).
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QS. Has the NRC staff evaluated the Clinton's CAM system against the criteriastatedinNUREg08007 k
AS.
The staff has evaluated f.he CAi systen at Clinton against the acceptance critcria stated in NUREC 0800 Section 12.3.4 and found the systen acceptable.
This conclusion was reached in N'JREG-0853, " Safety Evaluation Report related to the operation of Clinton Power Station, Unit No.1", Section 12.3.4.
Q6. Can you summarize the NRC staff conclusions regarding the Clinton's CAM system?
A6.
It is the staff's finding that the continuous airborne radioactivity monitoring system at Clinton is adequate to detect normal and abnormal releases of radioactive material in order to meet the criteria of NUREG-0800 and to maintain plant personnel intakes ALARA.
Q7. With regard to Contention 9B, what commitments has the Applicant made in the FSAR?
A7. The applicant has committed to use an Area Radiation Monitoring System (ARMS) at Clinton that meets the folowing objectives; I
(1) To monitor the radiation levels in areas where radiation levels could become significant and where personnel may be present in order to determine proper precautions prior to entry into such areas; (2) To sound an alarm when the radiation levels exceeds a preset limit so that corrective action can be taken; l
(3) Provide a continuous record of radiation levels at key locations through-l l
out the plant to evaluate previous radiation levels and for use in planning future I
activities.
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The ARM systen is not designed to be used as personnel dosimeter i.e., mea used to routinely assign doses to plant personnel in ment from ARMS could not b The applicant has pro-accordance with the requirements of 10 CFR Part 20.202.
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Neither is it alone to be used as input to posed using TLDs for such monitoring.
The applicant has proposed planning precauations necessary for work in areas.
using portable survey instruments to determine dose rates in actual wo Can the Clinton's ARM system stated accuracy of plus or minus 20 Q8.
percent meet the above objectives?
The stated accuracy of Clinton's ARM system'of plus or minus 20 percent A8.
of the actual exposure rate over a gamma eiiergy range of 0.05 to 3 MeV for meet the intended objectives and is within the present state-of-the-art accuracy such monitors.
Can you summarize the NRC staff conclusions regarding the Clinton' Q9.
ARM system?
It is the staff's finding that the Area Radiation Monitoring System at A9.
Clinton is adequate to inform plant personnel of area radiation levels prio dose entering specific areas, to warn plant staff of unanticipated changes in are rates and to maintain plant personnel doses ALARA.
The above statements and opinions are true and correct to the b knowledge and belief.
iiichael A. Lamastra Subscribed and sworn to before me this 10th day of June,1982 Notary Public My Commission Expires:
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o Michael A. l_ ac/stra '
Professional Qdkifications kadiologicalAssessmentBranch
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Divit,fon of1 Systems Integration q,) ~
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I am a Senior Radiological Engineer in ~the Radiological Assessment Branch, 1
Division of Systems Integration, Of fice of Nuclear Reactor Regulation.
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liy formal education consists of an A.A. degree in Radiation Science from
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Montgomery Community College in 1972, a B.S. degree in. Physics from Towson
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State College in 1974, and an M.S. degree in Radiological Health from the s
University of Pittsburgh in 1975.
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n Before joining NRC, I served three pears as a part-time employee of the Radiation Protection Department of the Naticnal Institutes of Health in Bethesda, Maryland.
My duties included collecting air sampfes to determine ths-level of radioactivity
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for specific isotopes, radiation ~ contimination surveys of research labs, and advising research personnel in safety procedures involving the use ofl radioactive isotopes.
I joined the NRC in June 1975 as a health physicist,in th'e, Radioisotopes Licensing Branch, Office of Nuclear Material Safety and Safeguards.
fy principal function was to review applications from medical and academic institutions for byproduct, source, and special nuclear material to determine the adequacy of their proposed radiation safety program and the,related cf forts proposed to assure.that occupational radiation exposure and release of radioactive material to the general public are as low as is reasonably achievable.
Since february 1981, I have served as a Senior Radiological Engineer in the Radiation Protection Section of the Radiological Asstssment Eranch.
ty principal function is the review of power reactor applications, both at the construction permit and operating license state, to determine the adequacy of proposed t
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Michael A. Lamastra 2
'2 occupational radiation protection programs and the related efforts proposed to assure that occupational radiation exposures will be maintained as low as is reasonablyachievable.I 1
I am a member of the flealth Physics Society and the Baltimore-k'ashington local 7 + Chapter of the llcalth Physics Soc.icty.
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