ML20054F612

Testimony of Jy Lee Re Prairie Alliance Contention 11a Re Methods Used to Calculate Atmospheric Effluents.Prof Qualifications Encl

ML20054F612
Person / Time
Site:	Clinton
Issue date:	06/11/1982
From:	Jun Lee Office of Nuclear Reactor Regulation
To:
Shared Package
ML20054F597	List: ML20054F596 ML20054F601 ML20054F604 ML20054F609 ML20054F612 ML20054F615 ML20054F618 ML20054F622 ML20054F627
References
NUDOCS 8206170155
Download: ML20054F612 (4)

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. UNITED STATES OF AMERICA NU LEAR REGULATORY COMMISSION -

BEFORE THE ATOMIC SAFETY AND LICENSING BOAku In the Matter of ) '

ILLIN0IS POWER COMPANY ) Docket No. 50-461 (Clinton Power Station, Unit 1) ) .

NRC STAFF TESTIMONY OF JAY Y. LEE (Regarding the Methods used-to Calculate Atmospheric Effluents)

(PRAIRIE ALLIANCE CONTENTION lla)

Q l. Please state your name and position with the NRC.

A 1. My name is Jay Y. Lee. I am employed by the U. S. Nuclear Regulatory Commission as a senior nuclear engineer in the Effluent Treatment Systems Branch of the Division of Systems Integration. A copy of my professional qualifications is attached.

Q 2. What is the purpose of your testimony?

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A 2. The purpose of this testimony is to respond$ to the Prairie Alliance Contention lla, which reads as follows:

The methods used to calculate atmospheric effluents of routine releases are inadequate in that c6nservative estimates were not, but should have been, used by Illinois Power Company.

Q 3. Are the estimates used to calculate atmospheric effluents of routine releases conservativei A 3. No. The estimates used to calculate atmospheric effluents of routine releases by Illinois Power Company are not conservative. Illinois Power Company or any other light-water-cooled reactor owner are not required to be. conservative for calculation of routine releases of 8206170155 020611 PDR ADOCK 05000461 T PDR

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radioactive materials in gaseous effluents other than atmospheric. - - -

releases resulting from an accident which does use conservative accident source tenns.

When the Nuclear Reg tory Commission announced its decision in the (.

rulemaking proceeding concerning numerical guides for design objectives (Appendix I to 10 CFR 50), the Commission reflected in its Statement of Consideration (40 CFR 19439) published May 5,1975) the desirability i' rd the use of the best available experimental data as well as calculational

.aodels in order to achieve increased accuracy and realism in view of ,

the economic penalty associated with needless overdesign for conservatism for meeting the numerical guides for design objectives in light-water-cooled nuclear power reactor effluents.

The Commission also has adapted an implementation policy that encourges the improvement of calculation models as well as the use of the best data available recognizing (1) measurements of environmental exposures and. quantities of radioactive materials in the environs are complicated by the very low concentrations that are encountered by routine releases, compared to natural background, and (2) it can be ensured that the average population exposure will still be a small fraction of doses from natural background radiation.

Q 4. Explain the methods used by Illinois Power Company to calculate the routine releases of radioactive materials in gaseous effluents including expected operational occurrences at Clinton Power Station, Unit No.

1.

A 4. The estimated releases of radioactive materials in gaseous effluents were calculated using the BWR-GALE Code described in NUREG-0016, " Calculation of Releases of Radioactive Materials in Gaseous and Liquid Effluents from boiling water reactors (BWR)" dated April 1976. The BWR-GALE, described in NUREG-0016, is a computerized mathematical model for calculating the routine release,s of radioactive material in effluents from boiling ,.

water reactors (BWR). The code has been in use since 1976 for all BWR licensing reviec. The calculations in the code are based on (1) data generated from operating reactors, (2) field and laboratory tests, (3) standardized coolant activities derived from American Nuc1 car Society (ANS) 18.1 Working Group reconimendations, (4) release and transport mechanisms that result in the appearance of radioactive material in gaseous streams, and (5) the Clinton radwaste system design features used to reduce the quantities of radioactive materials ultimately released to the environs.

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Section III of Appendix I to 10 CFR 50 requires demonstration of con-formity to the numerical guides for design objectives based upon models " .

and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. Accordingly, the staff developed vnd used a realistic model and data (based on actual operating experience t4 o the extent possible) of effluents. to the atmosphere (.

(not accident releases) including expected operational occurrences.

The staff believes therefore, the methods used to calculate the routine release of radioactive materials in gaseous effluents at Clinton Power

- Station, Unit No.1 are adequate.

The routine releases of radioactive materials in gaseous effluents from Clinton Pow 2r Station, Unit No. I have been reviewed and evaluated '

by the staff in Section 11.3 of the Clinton Safety Evaluation Report (NUREG-0853) dated February 1982. Based on this evaluation, the staff has concluded that gaseous radwaste system is capable of maintaining routine releases of radioactive materials is gaseous effluents to ALARA levels in accordance with 10 CFR 50.34a and Section II A of Appendix I to 10 CFR 50. -

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Jay Y. Lee Professional Qualifications Effluent Treatment Systems Branch Division of Systems Integration

{

My name is Jay Y. Leed! am a senior nuclear engineer in.the Effluen't Treat- g~

ment Systems Branch in the Office of Nuclear Reactor Regulation. I am responsible for Technical reviews, analyses, and evaluations of reactor plant systems and equipment for fission product removal and treatment of radioactive wastes, as to the adequacy of provision in meeting the applicable regulations.

- I am also responsible for the derivation of models used in the calculation of source terms to estimate the radiological impact on the environment, the '

adequacy of the instrumentation provided for maintaining radioactive discharges from nuclear power plant; and for providing technical bases for guides and

• standards.

During a period of approximately two years from April 1979 to April 1981, I was detailed to the TMI Technical Support T,ask Force at the THI site and subsequently to the TMI Program Office. In this position, I perfonned technical reviews, analyses, and evaluations df the recovery operations for TMI-2, the restart programs for TMI-1, and the TMI-2 Reactor Containment Building entrance program.

I received a Bachelor of Science degree in Chemical Engineering from the University of Minnesota in 1962 and a Master of Science degree in Nuclear

-- Engineering from the Catholic University of America in 1978.

My professional experience totals approximately 20 years of design, construction, start-up, operation, and licensing of central station nuclear power plants.

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From 1962 to 1966, I was emplyed as the plant chemical engineer by Northern States Power Company at Pathfinder Atomic Powcr Plant (decommissioned). In this position, I was responsible for operation and maintenance of radwaste treatment systems and for the implementation of the occupational health and ef fluent and environment'la monitoring programs.

From 1966 to 1969, I was a nuclear systems engineer with Bechtel Corporation at San Francisc6. In this position, I was responsible for technical review of the design and construction of reactor plant systems of central station nuclear power plants.

From 1969 to 1974, I was employed as the senior chemical engineer by Sacramento l

Municipal Utility District at Rancho Seco Nuclear Generating Station. In this position, I was responsible tur design reviews, construction and start-up operation of the radwaste treatment systems and the plant secondary system.

In 1974, I accepted the position of a senior nuclear engineer with the U. S.

Nuclear Regulatory Commission.

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