ML20078G166
| ML20078G166 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/30/1983 |
| From: | Grant T CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20078F754 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8310110412 | |
| Download: ML20078G166 (16) | |
Text
. - . -- . . .
September 30, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~
In the Matter of ) .
)
CAROLINA POWER & LIGHT COMPANY )
AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
AFFIDAVIT OF THOMAS J. GRANT IN SUPPORT OF APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF INTERVENOR WELLS EDDLEMAN'S CONTENTIONS 29/30 l
City of New York )
) ss.
State of New York )
Thomas J. Grant being duly sworn, deposes and says:
- 1. I am the Supervising Radiation Protection Engineer for the Shearon Harris Project employed by Ebasco Services In-corporated. My area of responsibility includes the design and procurement of the radiation monitoring system. My business address is Two World Trade Center, New York, New York. The 8310110412 831005 PDR ADOCK 05000400 0 PDR
statement of my background and qualifications is attached hereto as Attachment 1.
- 2. This affidavit addresses allegations raised by Inter-venor Wells Eddleman concerning an issue under Contention No.
29/30 in the above captioned proededing: That the radiation monitoring system at the Shearon Harris Nuclear Power Plant
("SHNPP") will not adequately measure radioactive iodine
("radioiodine") releases from the plant.
I. INTRODUCTION
- 3. All fixed radiation monitors within the plant are part of the Radiation Monitoring System. This system contains numerous monitors each with a specific function and design.
Included in the system are monitors designed to monitor radioiodine releases from the plant. The Radiation Monitoring System at SHNPP is manufactured by General Atomics Inc. of San Diego, California. The system and the individual monitors are described in detail in the SENPP FSAR, sections 11.5 and 12.3.4. Specific aspects of the monitoring system are discussed below.
II. SEALING MATERIAL
- 4. The radiciodine monitors are being procured based on specifications which set the requirements for performance, materials of construction, fabrication, testing and shipment of plant equipment. The monitoring system undergoes a series of
acceptance tests both at the factory and upon installation at 4
the plant as part of the initial test program. This program is described in SHNPP FSAR 14.2.12.1.14 and the procurement speci-fications.
- 5. The choice of all materials used in, and design and testing of, the monitors is aimed at preventing filter bypass or any other leakage prior to detect. ion. The radiation moni-toring system uses stainless steel tubing and steel mechanical fittings for the inlet and outlet sampling points to and from ,
the sampled effluent streams which are sampled. The stainless steel is of standard #304 grade. The iodine filter cartridges consist of carbon granules contained in a crimp metal case with fine wire mesh ends. The carbon filter cartridges are held in the detector shield of the radiation monitor via mechanical
, means. The cartridge is sealed in place by "0" ring seals and compression by the filter holder assembly, pressure bar, and filter locking screws. The moving particulate filter system is enclosed in a steel cabinet with an access panel using neoprene (polychloroprene) as a seal. The fixed particulate filter system also uses "0" rings seals.
- 6. The "O" ring seals are made of "Buna-N" rubber (acrylonitrile-butadiene). Neoprene rubber seals and Buna-N rubber seals have been tested to determine their resistance to radiation damage. The Space Material Handbook, Technical Report AFML-TR-68-205, July 1968, indicates that incipient
damage starts at approximately one megarad. Mild to moderate damage occurs between 1 and 10 megarad, integrated dose. Cal-i culations show that the plant locations for the iodine monitors will be subjected to an integrated dose of less than 0.001 megarad due to normal plant operation for 40 years, as docu-mented in SENPP FSAR $ 12.3.2.
- 7. The equipment manual requires that the "0" ring seals
- be visually inspected at each filter change and be replaced if signs of wear and damage are noted. Similarly, the neoprene ,
seal on the moving particulate filter is inspected each time the-filter paper roll is replaced. In addition, a leak in the 4
access panel neoprene seal would be detected by the vacuum dif-i ferential pressure switch and noted on the Radiation Monitoring System display console as indicated at SHNPP FSAR $ 11.5.2.3.1.
- 8. The iodine monitors are located in normally accessi-ble areas of the plant and are not subject to excessive pres-sures or temperatures. The integrity of the iodine cartridge and fixed particulate filter seals are also assured by the fact i
that the filter cartridges and filter papers are replaced on a i
periodic basis; every 7 days, as specified in NUREG 0472, which is referenced in SHNPP FSAR $ 16.2.
- 9. Intervenor Eddleman alleges that the iodine moni-toring system installed at the SHNPP will not perform adequate-ly due to PVC and epoxy, cracking, embrittlement, and distor-l tion caused by pressure, temperature and radiations. The i
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i allegation cites findings noted in the following reports:
! Sandia National Laboratory and Nuclear Regulatory Commission i
reports NUREG/CR-2157, 2763, and 2877. The Reports relied on by the intevenor refer to different materials and much harsher exposure and environmental conditions than will be experienced by the monitors. Furthermore, the routine maj.tenance and sur-veillance requirements of the radiciodine monitoring system require that such seals and gaskets be frequently inspected and replaced if signs of wear or damage are noted. -
- 10. In summary, the integrity of the radiciodine monitor seals and gaskets will not be impaired by the ambient radiation levels. The performance of the radiciodine monitoring system ,
will not be impaired by any of the phenomena observed in the I cited reports.
4 III. HIGH HUMIDITY
- 11. Iodine monitors that utilize paper filters (to collect particulate iodine), and charcoal cartridges (to collect gaseous iodine), can function in a high humidity envi-1 ronment. They cannot function in a condensing environment, however, since condensed water vapor will remove particulates prior to the filter and also severely degrade the charcoal per-formance.
- 12. The radiciodine and particulate monitoring system samples and monitors gaseous effluents from two types of 1
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a gaseous effluent streams: (1) from building vents and (2) directly from system effluent streams. The humidity in occupiable spaces, during normal plant operation, is controlled throughout the plant over the expected winter and summer tem-perature ranges. SHNPP FSAR, S 9.4.0 and Table 9.4.0-1 provide a range of the temperatures g60 to 122 F) and relative humidities (30 to 60%). Nevertheless, the monitoring system is designed to operate in a 95% humidity environment. Gaseous effluents will be sampled from the following facilities, as i
listed in the SHNPP FSAR at Table 9.4.0-1: Reactor Auxiliary Bldg., Fuel Handling Bldg., Containment Bldg., Waste Processing
, Bldg., and Turbine Bldg. These occupiable areas are monitored under controlled and known environmental conditions. In addition, the sample lines to all gaseous effluent monitors are heat traced to preclude any possibility of condensing liquid.
- 13. For gaseous effluents streams that cannot be practi-cally monitored with filters and charcoal, i.e., moisture laden 1
or steam exhaust streams, indirect monitoring methods have been proven to be practicable.
Such methods rely on monitoring for gross activity and then calculating the concentration of io-dines and particulates in that effluent stream based on known ratios. Sampling provides verification. In addistion, the sam-pling analyses of other plant process streams provide verifica-tion of the calculated concentrations. For example, analysis of the steam generator blowdown provides a direct relationship
-. - _- -= . .. _ - . _ -_- -
to the concentrations of gaseous effluents being released by the main condenser evacuation system and turbine gland seal I
condenser exhausts.
- 14. Intervenor Eddleman alleges that the monitoring system cannot accurately function due to the high humidity content of the gaseous effluent streams. The allegation asserts that the effect of humidity on particulate and radiciodine monitors is not discussed. Contrary to the allega-
. tion, as demonstrated by the discussion above the concentration -
of radioiodines in gaseous effluents will be assessed by both direct and indirect monitoring methods. Humidity will not affect iodine monitoring except in certain process effluent streams where indirect methods will be used. The radiciodine monitors, the gross activity monitors, and sample data all com-bine to give an accurate estimate of iodine releases.
IV. RELEASE POINTS
- 15. The SHNPP radiciodine sampling and monitoring systems have been designed within the requirements specified in 10 C.F.R. Part 20, 10 C.F.R. Part 50, General Design Criteria 60 and 64, and in accordance with the recommendations outlined in 4
NRC Regulatory Guides 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident" and 1.21,
" Measuring, Evaluating and Reporting Radioactivity in Solid 7-d y----%-- --
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l i Wastes and Releases of Radicactive Materials in Liquid and
- Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants." Guidance was also sought from American National ;
i Standard Institute documents, ANSI N13.10-1974 and ANSI N 13.1-1969.
- 16. All significant gaseous effluent release points are monitored in compliance with NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 11.5, Table 1. For those source terms which -
are individually too small to be monitored, the radiciodine concentrations from such releases are based on indirect mea-surement methods. For example, main steam, steam generator blowdown, and feed water samples are routinely sampled and ana-4 lyzed as part of the process sampling requirements of the sec-ondary system, as specified in SENPP FSAR sections 9.3.2.2.2, Table 4.7-1 and Technical Specifications 3.7.1.4, 4.7.1.4. The radioiodine concentraticns are determined by standard laborato-ry analytical techniques. Offsite releases are then determined using esti.nated leakage rates from valve stem packings and other miscellaneous system releases, e.g. auxiliary feedwater turbine exhaust.
- 17. Radiciodines released from the Main Steam Relief f Valves, Atmospheric Dump Valves and Main Steam Power Operated i
Relief Valves are, as noted above, indirectly evaluated based
! on the result of the secondary system sampling program, ac 4
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described by the Technical Specifications contained in SHNPP ,
I FSAR Chapter 16.2. The source terms from such effluent release i points are monitored for noble gases (as described in SHNPP FSAR Section 11.5.2.7.2.16), and are sampled for radioiodines i
and particulates (as specified by " Clarification of TMI Action Plan Requirements," NUREG-0737 Section II.F.1.) only under potential accident conditions. The noble gas monitoring system along with the analysis of the grab samples from the secondary side provide the basis by which the radiciodines releases and ,
offsite doses are evaluated.
- 18. The effluent monitors are designed for continuous
- operation. The monitors are, however, temporarily taken out of operation for filter changes and for rout'ine functional checks I
and tests as part of the surveillance requirements. These
- functional tests are outlined in the Technical Specifications I .
contained in SHNPP FSAR Chapter 16.2, Table 4.3-13. These tests are typically performed daily and last only a few minutes. Similarly, the replacement of the radioiodine filter 3
cartridges takes only a few minutes. Should the monitoring 1
, system be shutdown for an extended time period, each gasecuc effluent stream is equipped with a manual sampling capability s
allowing for the periodic evaluation and analysis of releases.
. Periods of plant operation without particular effluent monitors 1
in operation are governed by the plant Technical Specifica-tions.
l !
- 19. Intervenor Eddleman alleges that the radiciodine mon-1 itors are incapable of an accurate determination of releases because not all release points are monitored and that release points are not continuously monitored. Contrary to the allega-tion, all gaseous effluents release points are monitored either directly or indirectly. The radiciodine monitoring system is also equipped with the capability to obtain grab samples from each effluent point to assess offsite releases when the moni -
toring system is not operational. In view of the above, it is, therefore, concluded that all gaseous efflue are monitored, and an accurate assessment of offsite releases can be made. '
Based on my review of appropriate NRC Guidance, the compo-sition and charactesistics of the SHNPP Radiation Monitoring i
i System, Contention 29/30, and the Responses of Intervenor Eddleman to both Applicants' and the NRC Staff's
- Interrogatories, I have no reason to believe that the SHNPP Ra-diation Monitoring System will not adequately or accurately monitor radiciodine releases from the Shearon Harris Plant dur-ing normal operations in compliance with Appendix I to 10 .
C.F.R. Part 50.
THOMAS J RANT
. Subscribed and sworn to before me this Si day of l September, 1983.
w/ G < J ,v. - ^$-
NOTARY PUBLIC :/ ,
My Commission Expires STELLK Of1T NOTARY PUBLIC. FTATE OF NEw 10RK No. 31 1444786 Quel.f sd in New York County CWm'W:n tag, ires Mar.30,19ff
Attachment 1 o
Statement of Professional Qualifications Dr. Thomas J. Grant Ebasco Services, Inc.
~
Dr. Grant is a registered professional engineer with over ten years design and engineering experience in the areas of chemical process systems, water chemistry, radioactive waste, water treatment, nuclear instrumentation and radiation protection for power plants and other facilities.
He received his PhD in Nuclear Chemistry from Purdue University in 1971 and his BS Degree in Chemistry from Rensselaer Polytechnic Institute in 1966. He is a professional engineer in the state of New York, and is a member of both the American Chemical Society and American Nuclear Society.
~
Supervising Engineer, Applied Physics-Ebasco Services, Inc. (1978-presalt) .
Supervise a multi-disciplinary engineering group which provides special analytical engineering support to Ebasco projects. Responsible for the direction of engineering work in the areas of shielding design, radiation transport, access control, radiation monitoring, occupational exposure, health physics and radiation damage to materials.
Worked on the design of Boiling and Pressurized Light Water Reactors, Department of Defense nuclear facilities and a Tokamak fusion device.
Involved in the Ebasco technology assessment program for examining advanced energy technologies. Responsible for the investigation of Fuel Cell Power Plants including design concepts, cogeneration con-figurations, and fuel studies. Acted as Ebasco representative to the Fuel Cell Users Group of EPRI and participated in User Group activities. Also provided engineering support for assessment studies of MHD power plant configurations, solar applications and other energy technologies.
Provided analytical support to Ebasco special projects in the areas of thermal hydraulics, heat transfer and chemica l engineering.
Directed environmental qualification analysis fc r component failure due to radiation, thermal degradation, pressure and temperature transients.
Developed and presented training programs for clients in the areas of IEEE Code qualification, plant chemistry, and radiation protection.
Supervised the establishment of a comprehensive as low as reasonably achievable (ALARA) dose reduction program and participated in the personnel training, criteria selection and ALARA design review for several nuclear power plants. Performed studies concerning the decontamination of nuclear facilities and prepared a decontamination manual for Union Carbide. Performed several waste repository studies for ONWI involving monitoring instrumentation, radiation safety and criticality.
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i l Senior / Principal Chemical Engineer-Ebasco Services (1973-1978). l Chemical process design and licensing support for chemical and radioactive waste systems of power plants. Work included general arrangements, specification, and selection of equipment for solid, liquid, and gaseous radwaste treatment systems.
Remote handling equipment for solidified waste was designed and specified. Prepared sections of Environmental and Safety Analysis Reports; determined adequacy of radwaste systems to meet applicable NRC regulations and guidelines; developed computer programs for radioactive waste source terms and accident analysis; prepared technical reports on all aspects of radwaste management.
Specified process chemical and water treatment equipment. Performed several studies involving water chemistry and water purity require-ments for feedwater and auxiliary systems of power plants. Acted as Lead Chemical Engineer on Shearon Harris, a 4 unit nuclear ~
power plant.
Military Officer-U.S. Army (1971-1973).
Performed target and safety annlysis for nuclear and chemical weapons. Supervised approximately 80 personnel including a nuclear weapon assembly team.
Research Assistant-Purdue Univeristv (1967-1971).
Conducted experimental research in radiochemistry, chemical separations, ultra-cold neutron interactions and activation analysis. Experiments were also conducted on the effect of gamma rays on alkali halide crystals.
Analytical Chemist-Diamond Shamrock (1966).
Conducted experiments to determine fungicide residue in soils, and provided general analytical support services to a research labora-tory which emphasized plastics and agriculture chemicals.
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O October 5, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of all the documents listed on the attached document list were served this 5th day of October, 1983 by deposit in the United States mail, first class, postage prepaid, to the parties on the attached Service List, except that Mr. Eddleman has been served by overnight, express mail.
[,
W r JQhn H. O'Neill,.Jr. [
Dated: October 5, 1983 l
i
F' DOCUMENT LIST
- 1. " Applicants' Motion for Summary Disposition of Eddleman Contention 29/30 (Appendix I Compliance)"
- 2. " Applicants' Statement of Material Facts on Eddleman Contention 29/30 as to Which There is no Genuine Issue to be Heard (Appendix I Compliance)"
- 3. " Affidavit of John J. Mauro and Guy Martin, Jr. in Support of Applicants' Motion for Summary Disposition of Intervenor Wells Eddleman's Contention 29/30"
- 4. " Affidavit of Ronald L. Shearin in Support of Applicants' Motion for Summary Disposition of Tntervenor Wells Eddleman's Contention 29/30"
- 5. " Affidavit of Thomas J. Grant in Support of Applicants' Motion for Summary Disposition of Intervenor Wells Eddleman's Contention 29/30"
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of U.S. Nuclear Regulatory Commission North Carolina Washington, D.C. 20555 307 Granville Road Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright Atomic Safety and Licensing Board M. Travis Payne, Esquire U.S. Nuclear Regulatory Commission Edelstein and Payne Washington, D.C. 20555 Post Office Box 12607 Raleigh, North Carolina 27605 Dr. James H. Carpenter Atomic Safety and Licensing Board Dr. Richard D. Wilson U.S. Nuclear Regulatory Commission 729 Hunter Street Washington, D.C. 20555 Apex, North Carolina 27502 Charles A. Barth, Esquire (4) Mr. Wells Eddleman Myron Karman, Esquire 718-A Iredell Street Office of the Executive Legal Director Durham, North Carolina 27705 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard E. Jones, Esquire Vice President and Senior Counsel Docketing and Service Section (3) Carolina Power & Light Company Office of the Secretary Post Office Box 1551 U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27602 Washington, D.C. 20555 Dr. Phyllis Lotchin Mr. Daniel F. Read, President 108 Bridle Run CHANGE /ELP Chapel Hill, North Carolina 27514 5707 Waycross Street Raleigh, North Carolina 27606 Dr. Linda Little Governor's Waste Management Baurd
- 513 Albemarle Building 325 North Salisbury Street Raleigh, North Carolina 27611
_ . . . _ _ . _ _ . _ . _ . ~ . __ . , _ - - _ -
7._
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Service List Page Two Bradley W. Jones, Esquire U.S. Nuclear Regulatory Commission Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert P. Gruber Executive Director Public Staff - NCUC Post Office Box 991 Raleigh, North Carolina 27602 l
t