ML20071H655
| ML20071H655 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/16/1983 |
| From: | Harris S UNION ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20071H409 | List:
|
| References | |
| ISSUANCES-OL, NUDOCS 8305250436 | |
| Download: ML20071H655 (14) | |
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UNITED STATES OF AMERICA.
NUCLEAR REGULATORY COMMISSION,
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BEFORE THE ATOMIC SAFETY AND L CENSING BOARD
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In the Matter of )
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UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL
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(Callaway Plant, Unit 1) )
AFFIDAVIT ~OF SAUL HARRIS IN RESPONSE TO REED CONTENTIONS 6 AND 16 (PROTECTIVE ACTIONS AGAINST RADIOIODINES
& MFSSAGES WITH INSTRUCTIONS FOR LONG-TERM SHELTERING)
City of St. Louis )
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State of Missouri )
SAUL HARRIS, being duly sworn, deposes and say.s as follows:
- 1. I am Principal Health Physicist, Union Electric Company. Since 1947, I have been involved in monitoring l
airborne radionuclides both for occupational exposure and public health. This work has included extensive industrial hygiene practical. experience relating to prevention of inhala-tion of airborne radionuclides. A summary of my qualifications
.and experience is attached as Exhibit "A". I have personal
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knowledge of the matters stated herein and believe them to be true and correct. I make this affidavit in response to Reed Contentions 6 and-16 (Protective Actions Against Radioiodines &
Messages with Instructions for Long-Term Sheltering) .
- 2. The purpose of this affidavit is to explain the effectiveness of ad hoc respiratory protection as a protective action in the unlikely event of a release of radioactive 1
material, including radiciodine, from the Callaway Plant during a radiological accident.
- 3. As a possible result of a reactor accident which results in a significant atmospheric release of radioactive material, the public may be exposed to radiation from three exposure modes. These include: (1) exposure to external radiation as the released material passes in the form of a cloud or plume; (2) exposure to external radiation from radionuclides deposited on the ground and other surfaces during and after passage of the cloud or plume; and (3) internal exposure due to inhalation of radioactive material settling out of the cloud or plume but essentially suspended in breathing air. In the event that projections of possible airborne concentrations of active materials indicate that projected internal doses to the public may exceed recommended protective
. action guides, protective action should and can be taken to minimize such inhalation exposure.
- 4. Among the several alternatives to minimizing internal exposure to radioactive material is the deliberate action by
the public to take advantage of emergency respiratory protection offered by the use of common household material as.
ad hoc respirators. Ad hoc respiratory protection from readily available materials such as fabrics, towels, sheets, etc., has been shown to be effective for both particles (dusts or aerosols), vapors, and radioactive gases including radioiodine.
Such inhalation protection would be valid for the public remaining indoors (sheltering) or for brief movement outdoors during passage of a radioactive cloud or plume. Ir. addition, such ad hoc respiratory protection would increase the inherent inhalant protection provided by sheltering within a structure.
This protection is afforded either by natural sealing of the 1
building or by certain ventilation strategies which inhibit air )
and dust movement from the exterior of the building into areas occupied by the public during passage of a released radioactive cloud or plume.
- 5. The effectiveness of ad hoc respiratory protection is j expressed in terms of filter efficiency or penetration of l dusts, aerosols or gases through the ad hoc respirator mate-rials. Research into the effectiveness of emergency respira-tory protection using common household and personal items has been undertaken for.over 20 years, with much of.the early work done at the request of the Atomic Energy Commission. Initial research studied some eighteen variations of eight household and personal items, with military personnel using these materials as respiratory protection expedients in a calibrated
atmosphere of particles in an aerosol. These early tests gave results (see attached Table "A") indicating that five varia-tions involving a man's cotton handkerchief, commercially available toilet paper, and a bath towel, had a filtration efficiency greater than 85 percent (meaning that 85% of the particles were not inhaled because of the ad hoc respiratory protection). Resistance to breathing offered by each medium also was evaluated with a few of the variations rejected because of excessive breathing resistance. In general, the medium needs to be damp but not too wet (see footnote A in Table "A"); however, excessive wetting of the initial test material could increase resistance to breathing, indicating that use of very wet items is not generally practical. In all instances, a good fit on the face, to assure edges were sealed,
'io essential to obtain maximum effectiveness of the expedient material; however, this is also a limitation applicable to commercial? -available respirators. (See the 1963 American Industrial Hygiene Association Respiratory Protective Devices Manual, " Household Items for Emergency Use in Civilian Defense," pages 123-126; and the A.M.A. Archives of Industrial Health, " Emergency Respiratory Protection Against Radiological and Biological Aerosols," Vol. 20, page 91-95, Aug. 1959.)
- 6. Further research conducted by the Department of Environmental Health Sciences, Harvard School of Public Health, has been published as NUREG/CR-2272, Expedient Methods of Respiratory Protection, November 1981, for the U.S. Nuclear -mm-m ...
Regulatory Commission; and as " Emergency Respiratory Protection with Common Materials," Am. Ind. Hyg. Assoc. Journal 44(1): 1-6 (1983) by D..W. Cooper, W. C. Hinds, and J. M. Price. In addition, remarks "On the Efficacy of Ad Hoc Respiratory Protection During a Radiological Emergency" were presented by James A. Martin, Jr., an NRC Staff member, as paper P/50 at the 1981 Annual Meeting of the Health Physics Society, based in part on the data by Cooper, et al. (Harvard University). The Harvard data were also included in a paper presented by D. C.
Aldrich at an' Electric Power Research. Institute symposium on radiological emergency planning held January 12 and 13, 1982 and published in NSAC-50, "Are Current Emergency Planning ,
Requirements Justified," NSAC-EPRI, May 1982. As discussed below, these papers reflect the current state of the art with respect to ad hoc _ respiratory protection.
- 7. The reports by Cooper and associates were the result
- of extensive studies of the ability of readily available fabrics to filter aerosols, gases and vapors expected to be emitted in the event of a major nuclear reactor accident using calibrated particles. The results, while somewhat different,
,were consistent as to the value of ad hoc material from those obtained earlier. Decreases in particle concentrations by a factor of ten or more-were possible from the fabrics tested, when operated.at'a pressure drop deemed acceptable for breathing comfort. Protection from Krypton-85 by dry fabrics and-from radiciodine using wetted fabrics (with water-or r-
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baking soda solution) was appreciable. Follow-up studies by Harvard University are continuing.
- 8. These test results show that readily available materials can provide substantial reductions in concentrations of particles and certain water-soluble gases and vapors at pressure drops acceptable for respiratory protection during nuclear power plant accident conditions. Leakage around the seal to the face could reduce the protection provided, as noted in the earlier studies, but'this problem is associated with the use of commercially-available respirators as well. Table "B" summarizes the data from these studies. Of importance was the finding that wetted sheets and towels would provide respiratory protection from iodine vapor, reducing iodine concentrations by a factor of ten.
- 9. While neither of the studies specifically address the duration of the protection, the earlier report stated that the dry bath towel and man's handkerchief variations did not appear to have any serious limitations as to the duration of use. The Harvard research did not indicate any significant breathing difficulties could be anticipated by the use of towels or handkerchiefs even when wetted. Comparing these materials with a 3M dust respirator, a half-mask fabric respirator, the authors of the reports felt the masks could be worn for hours withou*, substantial discomfort and the fabrics could be tied or taped to the face for shorter periods during the passage of a puff-or plume, during travel to shelter,=a daing r:laation;------ -
indicating suitable duration of use during nuclear accident scenario conditions.
- 10. In a qualitative sense, then, these research studies indicate that it would be advisable to cover the nose and mouth during possible exposure to airborne radioactive material following a' nuclear reactor accident if the plume is likely to cause airborne concentrations that could result in radiation doses to the public in excess of protective action guides.
Further research is underway to quantify this perhaps self-evident statement. As stated by Martin in the abstract for paper P/50, "These studies demonstrate that application by the public of ad hoc shelter and respiratory protection could provide inhalation pathway protection factors (PFs) of ten or more, _ with shelter providing a PF of two to ten and ad hoc respiratory protection providing an additional PF of three to twenty, or so."
- 11. Martin points out that "These potential PFs are very competitive with that of potassium iodide (KI) for the thyroid, but the former would protect other organs as well . . . ."
(emphas'is added). Martin further adds that ". . . ad hoc shelter and respiratory protection could be used to reduce doses in cases where expeditious evacuation would not be feasible . . . ."
- 12. Following an accident at the Callaway Plant, the public would be' instructed in appropriate protective action by l l
appropriate authoritiesy- m ekuding d.:. to-4nitiate-and when to l
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stop the use of ad hoc respiratory protection (if needed at all). Proper instruction to families as to the use of ad hoc respiratory protection will be done through pre-established public messages and public information previously sent to residents. Parents would be able to monitor the proper use and comfort of ad hoc respiratory protection by the younger members of the family according to these instructions, with no likeli-hood that young children could suffocate from the use of ad hoc respiratory protection.
- 13. There is no mystery to the concept that ad hoc respiratory protection can be effective in providing inhalation filtering of potentially hazardous airborne material. It is common knowledge that covering the nose and mouth of family members with damp cloths is an effective ad hoc method of minimizing smoke inhalation during fires. Common sense as well as scientific research dictates that similar action be taken upon instruction by appropriate authorities following the release of significant quantitites of airborne radioactive material-during a radiological accident at the Callaway Plant.
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Saul Harris Subscribed and sworn to before me this 16th day of May , 1983.
1+vh[M Notary TubY1cFu NOTARY UBL C STAhE O MISSOURI My c0MMissioN EXPlRES APRll 22,1985 i
l ST. LOUIS COUNTY l My Commission expires: 4/22/85 .
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Exhibit A I ROcume SAUL JOSEPH HARRIS Education: BS - Physics and Mathematics l Queens College, NY 1943 '
Electrical Engineering - ASTP Mass. Inst. of Techn. 1943-1944 MS - Industrial and Management Engr.
Columbia Univ., NY 1959 MPA - Public Administration New York Univ., NY 1972 DPA Candidate - Public Admin.
New York Univ., NY Thesis Pending Certification, Honors, Certified Health Physicist Awards: American Board of Health Physics 1960 Certified Safety Professional Board of Certified Safety Professionals 1973 Recognized for " Devoted Leadership" by Boy Scouts of America for developing the Atomic Energy Merit Badge 1963 Appointed Health Physicist Member, NY State Board of X-ray Technician Examiners by_ State Health Commissioner 1964-1975 Military Service: US Army Signal Corps, Tech. Sargent, Carrier-Repeaterman, Overseas Duty in India-Burma Theatre 1943-1946 Special Skills: Adjunct Lecturer, College of the City of inf, Dept. of Civil Engineering, MS-level Course in Radiation Safety Engineering 1967-1971 Instructor in Public and Business Administration, Central Michigan University (DC Area) 1977-1982 Experience: 1943-1946. Military Service ,
Included electrical engineering study at M.I.T., and Carrier-Repeaterman School at Fort Monmouth,;NJ, and service in the India-Burma Theatre i
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Stul Jo cph Harris P. iga 2 1946-1947 Western Electric Co.
Equipment engineer on long-distance telephone equipment installation specifications, NYC 1947-1951 Brookhaven National Laboratory l Research associate in nuclear reactor physics, testing materials, metallurgy, i and cooling system design; Health Physics surveyor for occupational and environmental radiation, design of nuclear instrumentation, Upton, NY 1951-1955 NY State Department of Labor, Division of Industrial Hygiene organized and managed a full-time radiation control program, including field inspections, chaired and directed a 24-member expert advisory committee to develop the first state-level comprehensive radiation code, NY, NY 1955-1959 Atomic Industrial Forum, Inc.
Technical secretary to committees on standards, public education, nuclear instrumentation and ASA standards com-mittees; Assistant Manager for State Activities (in atomic energy) , NY, NY 1959-1961 Baird-Atomic, Inc.
. Technical Director of Atomic Accessories (Subsid. of Baird-Atomic) for product development and testing; served as regional nuclear sales engineer for nuclear instrumentation, Valley Stream, NY 1961-1972 US DHEW With the US Public Health Service, then Food and Drug Administration and Environ-mental Protection Agency, served as regional radiation protection director in Region II of DHEW (initially NY, NJ, Penn. and Del.; later NY, NJ, Puerto Rico and VI), administration and technical.
assistance to state and local radiation protection programs, administer Federal formula and research grants, NY, NY
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Stul Jonsph;Hcrria
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1972-1975 NY City' Department of Health
[ Directed a major radiation control program
- to regulate medical and educational use i of x-ray units and radioactive material, NY, NY 1975-1982 . Edison Electric Institute
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Engage in nuclear activities in the field of public health, radiation protection, j- nuclear power, emergency planning,
- i. Washington, DC j_ 1982 - present Union Electric Company i Principal Health Physicist Presentations and Papers: Major Publications:
Nuclear Power Safety Economics, Pilot Books, 1961 1
i- The Impact of the Peaceful Use of Atomic l Energy on State and Local Government, AIF, 1958 State Activities in Atomic Energy, AIF, 1958 Administrative Problems in Radiation Protection, NUCLEONICS, December 1954 Other Publications and Papers:
Over 150 presentations, papers,. articles, and interviews on the following topics: ,
t - monitoring fallout, instrumentation design, x-ray film characteristics I - --radiation hazards from mass dental.
surveys, static el'iminators, veterinary
. . medicine, non-uranium mine radon f . exposure, x-ray shoe fitting-fluoroscopes, radium dial: painters
- planning.and' zoning aspects',of atomic-
, energy, examinations - for. x-ray techniciansi ~ '
and;for radiation' professionals, develop--
ment of, national radiation standards, i .
publicTunderstanding of atomic energy
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Professional Societies and Committees: . American Nuclear Society American Association of Physicists in I
Medicine -1 Health Physics Society Included in Who's Who in Atoms; American Men & Women of Science - the Medical Sciences E
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TABLE A 124 RESPIRATORY PROTECTIVE DEVICES MANUAL TABLE ILS RESPIRATORY PROTECTION PROVIDED BY C'JMMON HOUSEHOLD AND PERSONAL ITEMS AGAINST AEROSO13 OF 1 TO Sg PARTICLE SIZE Number - Number Geometric 95% Confidence of Resist- of Mean Limits for ance, Obser. Efflet'ency,. Mean,13 Thick. Lower Upper Item nesses. mm of H,0 vations T Handkerchief, 94.2 92.6 95.5 16 36 32 man's cotton-13 32 91.4 89.8 92.8 Totlet paper 3
' Handkerchid, 85.5 91.6 8 18 32 88.9 man's cotton
- Handkerchief, 85.1 90.5 -
Crumpled -- 32 88.1 man's cotton Bath towel, 83.3 86.8 2 11 32 85.1 i turkish Bath towel, 5 30 73.9 70.7 76.8 turkish 1 22 32 72.0 68.8 74.9 Bed sheet, muslin 1 Bath towel, 3 31 70.2 68.0 72.3 turkish 1 (wet)
>150" 15 65.9 57.9 72.3 Shirt, cotton 1 (wet) '
2 7 30 65.5 60.8 69.6 shirt, cotton ,
Handkerchief, 848 32 63.0 57.3 67.9 woman's cotton 4 (wet) .
Handkerchief, 98 8 30 62.6 57.0 67.5 1 (wet) man's cotton i Dress material, 62.0 180a 31 56.3 49.6 cotton 1 (wet)
Handkerchief, 2 32 55.5 52.2 58.7 woman's cotton 4 6 32 50.0 46.2 53.6 Silp, rayon 1 Dress material, 5 31 47.6 41.4 53.2 cotton 1 3 32 34.6 29.0 39.9 Shirt, cottpa 1 Handkerchief 22.0 32.5 man's cotton 1 2 32 27.5 e
- a. Resistance obtained when checked immediately after hand wringing. This resistance began to decrease j
after about one minute when the n%terial started to dry.
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TABLE ' B ~ ESTIMATED PENETRATION THROUGH EXPEDIENT RESPIRATORY
~ PROTECTION MATERIALS AT 50 Pa (0.2 IN H 0) 2 PRESSURE DROP AND 1.5~CM/S FACE VELOCITY DRY b b No, layers Aerosol particle CH I Material 1 2 3 diameter (um) 0.4 1 5 a <.01 3M respirator 2 .03 .004
= 8710 c
Sheet 20- .66 .64 .020 f.0 0.6 Shirt- 15 .54 .59 .070 Lower-quality 20 .53 .41 .015 towel c
Higher-quali ty 6 .24 .13 <.01 0.6 towel Handkerchief 14 .61 .54 .032 WET b
Material. No. layers. Aerosol particle 1 2
CH I 3
diameter (um) 0.4 1 5 c
Sheet 6 .91 .88 .22 .45 .8
.15 d 1.0d Shirt- 6 1." .51 <.02 Higher-quality 4 .20 <.01 <.01 .21 1.0 towel
.10 d Handkerchief 2' .98- .95 . 37-
- a. .Available commercially'in single-layer thickness. '
- b. Taken from tests'at-1.0.cm/s,; assuming penetration is the-product
'of single-layer penetrations.
c; Not shown to be statistically different from 1.00.
-d. Wetted with 5?; by: weight baking soda solution.
Taken'from NUREG/CR-2272 (Nov. 1981) . at 84.
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