ML20071H956

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Affidavit of Kv Miller Re Reed Contention 17 on Radiological Monitoring.State Resources in Trained Personnel & Radiation Monitoring Equipment Adequate.Prof Qualifications Encl
ML20071H956
Person / Time
Site: Callaway Ameren icon.png
Issue date: 05/17/1983
From: Keith Miller
MISSOURI, STATE OF, UNION ELECTRIC CO.
To:
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ML20071H409 List: ... further results
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ISSUANCES-OL, NUDOCS 8305250544
Download: ML20071H956 (12)


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UNITED STATES OF AMERICA 1-NUCLEAR REGULATORY COMMISSION */S,

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~,y, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 2' In the Matter of

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UNION ELECTRIC COMPANY

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Docket No. STN 50-483 OL

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(Calraway Plant, Unit 1)

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AFFIDAVIT OF'KENNETH V. MILLER ON REED CONTENTION 17 (RADIOLOGICAL MONITORING)

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County of Cole

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State of Missouri

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KENNETH V. MILLER, being duly sworn, deposes and says as follows:

1.

I am Administrator of the Bureau of Radiological Health of the Missouri Division of Health.

My business address is P.O.

Box 570, Jefferson City, Missouri 65102.

In the event of an accident at the Callaway Plant, it would be the responsi-bility of the Bureau of Radiological Health to direct opera-tions specifically related to nuclear radiation affecting the environment outside the Callaway Plant exclusion area.

This 8305250544 830520 PDR ADOCK 05000483 C

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responsibility includes radiological monitoring, determining the need for implementing protective actions, advising other agencies.regarding actions that should be taken, determining individual exposure levels and determining the need for decontamination.

2.

This statement addresses only radiological monitoring.

I_make this affidavit'in response to Reed Contention 17 (Radiological Monitoring).

I have personal knowledge of the 1

matters stated herein and believe them to be true and correct.

A summary of my professional qualifications and experience is attached hereto as Exhibit "A".

3.

The Bureau of Radiological Health has a staff of six professional personnel.

In the event of an accident at the Callaway Plant, four Radiological Health personnal will be available to serve on monitoring teams.

Other personnel of the Bureau will be assigned to the emergency off-site facility or to the emergency operations center.

4.

Each monitoring team will consist of one person provided through the State Emergency Management Agency ("SEMA")

- and one person from the Bureau of Radiological Health ("BRH").

The SEMA will be responsible for transporation.and communica-tions essential to monitoring activities. -The team member

-provided by SEMA will serve as driver and assistant and will have been trained in the use of radiation detection instru-ments.

The BRH member will act as team leader and will be re sponni hl =

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=^nitnring The deployment of the

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field monitoring teams is fully described in the BHR section of Annex A to the Missouri Nuclear Accident Plan - Callaway

(" State Plan") (at BRH 12 and Attachment A6B, which are attached hereto as Exhibit "B").

5.

The emergency instruments, equipment and supplies to be used by BRH for radiological assessment are listed in the j

BRH plans and procedure (in Annex A to the State Plan, at Attachment A2B, a copy of which is attached hereto as Exhibit "C").

As indicated in the Attachment, BRH will have the

~7 capability to measure radioiodine levels as low as 10 uCi/cc under field conditions.

This reflects a change in the portion of the State Plan which was the basis of Reed Contention 17.B.

6.

All members of the BRH. staff have participated in emergency response training programs sponsored by federal assucies.

They periodically review and discuss emergency procedures.

BRH personnel are regularly engaged in radiation protection activities.

That is their primary responsibility.

They are experienced in conducting radiological surveys and in the use of radiation detection instruments and are familiar with the instruments and protective equipment which is available to them.

They routinely respond to various kinds of radiological incidents and are accustomed to working both individually.and as team members.

The following quotation from the Final' Report Evaluation of the-Exercise for Radiological Acaid--t et-Cooper-Nuolear. Station, Brownville, Nebraska,

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r March 10, 1982 prepared by Federal Emergency Management Agency, Region-VII, tends to support the competence and adequacy of training of BRH monitoring teams:

" Field monitoring teams were t

well managed and capably directed _from the FCP [ Forward Command Post].

Menitoring procedures were excellent and rigorously followed.

Fiald data was received by the FCP, promptly analyzed, and used as the basis for recommending appropriate protective actions."

7.

All BRH personnel will be faiailiar with both the

. terrain around the Callaway Plant and with preselected moni-toring points prior to plant operation.

In the event of an emergency at the plant, BRH monitoring team members will be t

. dispatched from the emergency off-site facility or directly from the Jefferson City office of the BRH.

In either case the teams will be under-the direction of the PRH representative in s

the emergency off-site facility and should be in the field within one hour after initial notification.~

Radio communica-tions will be available between the emergency off-site facility and monitoring teams dispatched by the BRH and the Callaway Plant.

Monitoring activities will be coordinated from the EOF.

8.

In conclusion, the Bureau of Radiological Health can, if necessary, provide four trained radiological. monitors.

Augme'ntedeby personnel provided by the State Emergency Management Agency,'this would result in four off-site'moni-toring Lteams.(two :for each of two 12-hour. shifts) equipped by

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and.under the direction of the BRH.

.These,..in. conjunction with g

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Callaway Plant personnel, should meet the critical needs for off-site radiological monitoring during the early stages of an accident at the Callaway Plant.

Although the need is not p

anticipated, additional monitors would be available from the Missour.1 Nuclear Emergency Team - a group of some forty

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individuals who have been trained by the SEMA or whose quali-fications have been reviewed and found acceptable by that agency.

It is anticipated that after the first twenty-four y

hours assistance would be available from federal agencies if needed.

In my opinion, and contrary to Reed Contention 17, l

State resources in trained personnel and radiation monitoring equipment are adequate to properly perform monitoring tasks in the plume exposure EPZ and the ingestion exposure EPZ, aM h

without support'from local governments.

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Kenneth V.

Miller 9

P Subscrib d and sworn to before me 3

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this 1/F' day of May, 1983.

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My Commission expires W,t e. A A 4, \\ R T Y'-

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EXHIBIT A PROFESSIONAL-QUALIFICATIONS STATEMENT FOR KENNETH V. MILLER Education:

B.S. Degree in Physics from Western Illinois University One academic year of graduate study in radiological health, University of' Michigan Experience: Twenty-two years with Missouri's radiological health program.

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BRH field monitoring teams will be dispatched from the Forward Command Post as deemed war-ranted by BRH, but not later than at the de-c3aration of a Site Area Emergency

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classification.

At Jeast two teams, consisting of at least two persons, will be deployed to i

predesignated monitoring and sampling points i -

(see Attachment A5B).

Each team will be com-prised of one person from BRH vho will be responsible for actual monitoring gnd one emergency worker provided by SEMA who will act as monitoring assistant, communicator, and driver.

Transportation and communications eculpment wi13 be provided to each team by j-SEMA.

The BRH representative will be ex-i perienced in the use of monitoring instruments and wi33 have received emergency response l

training.

The SEMA emergency worker will also i

be trained in emergency response and in the use j

of field monitoring equipment.

The field moni-toring equipment and appropriate protective gear wi33 be provided to each team by BRH from the Forward Command Post.

The radiological j-monitoring equipment, protective gear, and i

miscellaneous equipment to be utilized by field monitoring teams is listed in Attachment A2B.

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The time required for deployment of Bureau of j

Radiological Hea3th personnel at the site' of an i

emergency will depend upon several factors in-c3uding the specific site and the locations of j

BRE personnel at the time of the emergency.

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the case of the callaway Nuclear Power Plant, it is estimated that this could be accomplished i

in less than one hour.

Mobilization and trans-portation wi31 be coordinated by SEMA.

Various RADCON and/or MoNET Team members may be utilized with other individuals of Federal, State, and local agencies, as appropriate, in forming additiona] teams if required.

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i CALLAWAY-BRH12 MAY 1983 m

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NUCLEAR ACCIDENT PLAN ATTACHMENT A6B l

(h FIELD MONITORING AND PLUME VERIFICATION

~ The objectives of field monitoring defined by this procedure l

are to define..the plume edges of a projected radiological

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reJense', to determine the doses at the plume centerline, and tb verify dose projections of the utility.

For this pur-

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pose, the fo13owing procedures will be used by BRE field monitoring personnel:

Two field monitoring teams composed of a BRE staff person 1.

and a SEMA designated emergency worker will be deployed into l

the field simultaneously from the EOF / Forward Command Post.

2.

FieJd monitoring team personnel will acquire protective gear, radiological monitoring equipment, and constunications eauipment at the EOF Forward Cormand Post.

Radiologica3 monitoring equipment and communications (high 3.

band portable radios provided by SElu) will be operationally checked by fie3d monitoring personnel at the Forward Command Post prior to deployment into the fieJd.

Portable radio l

communications between the field monitoring teams and the EOF Forward Comsand Post will be established at this time.

4.

Communication of information between state and utility field monitoring. teams will be coordinated by BRE and utility per-fa sonnel at the EOF /FCP.

The purpose of this coordination d.9 will be to maximize information about the plume and to avoid unnecessary duplication of effort.

5.

Monitoring tracks will be established along pre-designated monitoring points (see Attachment A5B) by BRE personnel at

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the EOF /FCP.

6 The teams will be deployed initially to predesignated moni-toring points near the site.

The two teams will be seat into the plume from opposite directions along a monitoring track, and will take readings at pre-designated monitoring points 3ocated along the track.

(See TAB 1 for 133ustration.)

7.

Teams will report instrument readings to the BRE field moni-toring coordinator in the EOF /FCP as they proceed into the projected plume toward the plume centerline.

8.

Specific dose reading levels will be established by BRE per-sonnel in the EOF /FCP as turn back values.

When a dose reading at or above the turn'back vaJue is reached, the teams will return to the edge of the plume, move farther away from the site to more distant monitoring points, and repeat the procedure.

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CALLAWAY A6B.1 MAY 1983 w

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Tho BRE fiold tOam coordinatsrc in tho EOF /FCP will CCp Cnd d3 fine tha pluma baced on informaticn r0 ported by tho fiold monitoring teams.

Tho BRE coordinctoro will comp 3ro d3sec with those projected by the utility by conferring with util-

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ity radiological assessment personnel in the EOF.

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CALLAWAY

.A6B.2 MAY 1983 Y.

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dde TAB 1 TO ATTACHMENT A6B

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CONTENTION 17 MILLER AFFZDAVIT EXHIBIT C NUCLEAR ACCIDENT PLAN ATTACHMENT A2B BUREAU OF RADIOLOdICAL HEALTH EMERGENCY INSTRUMENTS, EQUIPMENT & SUh' PLIES Radiation Detection Instruments Alpha detec, tion' instrument, Eberline 2

PAG-6, 1 scinti13ation probe A3pha detection instrument, Ndclear 1

Chicago, Model 2672.

1 alpha probe Neutron Survey Meter, Nuc3 ear Chicago 1

Mode 3 2671.

1 neutron probe Geiger-MueJ3er survey instrument, NucJear Chicago, Model 2650.

2 1 beta, gasuna side window probe Geiger-MueJ5er survey instrument, Texas Nuc3 ear, Model 2650.

1 beta, gamma side window probe.

1 alpha, 2

beta, gamma and window probe

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Ion chamber survey meter.

EberJine 2

ModeJ PIC 6 Ion chamber survey meter.

Texas Nuclear Model 2590.

1 low-range probe, 8

1 hi-range probe Ion chamber survey meter.

Nuclear Chicago Model 2500.

1 low-range probe, I hi.

1 range probe Ion chamber survey meter, Nuclear Chicago 4

Model 2500.

1 Jow-range probe Protective Clothing-hs_pfrators -

Half mask, Comfo II 6

Rain suits, Jarge CoveraJIs, (3 3arge, 3 medium)

FuJ3 mask 2

Filters, type H Gloves, rubber FiJter, canister G3 oves,-cotton Gloves, disposabJe-

. Boots, rubber (3arge)

Boote, paper disposable Boots,' disposable A23.1 MAY 1983 CALLAWAY

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Dosimeters

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Charger 2

Dosimeters, 200R 4

Dosimeters, x-ray, 200 mR 4 Dosimeters, gasuna, 200 mR 8 Air Samplers i

Four (4) RADECO Mode] M809-c air samp3ers with radiciodine and/or particu3 ate filters.

Operates on 12V or 24V DC with jumper-cabJe type attachments.

i Misce 13aneous Rope Flash 31ghts Batteries:

6V & l.5v Tape, radioactive Tape, masking 1" Warning signs, 8 x 10 Warning signs, 5 x 7 Wipe smears Towe3ettes P3astic sheeting j

Notepads r,

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Steno pads i

Paperclips a

Heavy duty markers Penci3s, 92 Ba33 points Tongs Nex wrench sets Screwdriver sets Channe3 Jock p3iers Sponges Oven c3eaner Licuid detergent Instruments for Measurfnq Radioi x11ne Concentration The Bureau of Radiological Health (BRH) will sample for air-borne radioiodine using a low volume air sampler with a silver zeolite cartridge.

Analysis of the cartridge will be performed using an Eberline " RASCAL" PRS-1 portable Ratemeter-Scaler with an SPA-3 probe.

The sensitivity of this method enables measurement of iodine concentrations as low as lE-7 microcuries/

cubic centimeter.

In addition, backup monitoring support for this function can be provided by the DOE through implementation of FRMAP.

i CALLAWAY A23.2 MAY 1983 c

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