ML20080L405

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Affidavit of Bd Mcfeaters That No Factual Basis Exists for Eddleman Contention 80 Since Util Mixing & Dispersion Models Based on site-specific Data.Certificate of Svc Encl
ML20080L405
Person / Time
Site: Harris  Duke Energy icon.png
Issue date: 09/26/1983
From: Mcfeaters B
CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20080L376 List:
References
ISSUANCES-OL, NUDOCS 8309300299
Download: ML20080L405 (14)


Text

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e UNITED STATES OF AMERICA NUCIEAR REX 3UIA'IORY CCbMISSION 00CKETED USHRC BEFORE THE A'IU4IC SAFEIY AND LICENSING BCARD

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CrRCE CT SEc;;r7-C7ELINA PCMER & LIGHT COMPANY

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00cm nug 4 ggpf AND NORIH CAROLINA EASTERN

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Docket Nos. 50-400-OL DRANQi MUNICIPAL POWER AGENCY

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50-401-OL

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(Shearon Harris Nuclear Power

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Plant, Units 1 and 2)

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AFFIDAVIT OF BRIAN D. MCFFATERS IN SUPPORI' T APPLICANTS' REPLY 'IO hmA EDDLH4AN'S MOI' ION FOR PARPIAL SGNARY DISPOSITION ON EDDIIMAN CONIINI' ION 80 County of Wake

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State of North Carolina

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. BRIAN D. FCFEATERS, being duly sworn, deposes and says as follows:

1.

I am a Project Scientist - Meteorological Supervisor erployed by j

i Applicant Carolina Power & Light Company. My business address is 7C3 Center

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Plaza Building, 411 Fayetteville Street Mall, Raleigh, NC 27602. A Sumary.

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

I have personal knowledge of the matters stated herein and believe then l

to be true and correct. I make this Affidavit in support of Applicants' Reply to Wells Eddleman's. Motion for Partial Sumary Disw Etion on Eddisnan l

l Contention 80 in this proceeding.

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2.

The function of the Physical Sciences wunit, meteorological l

ggg operations at Carolina Power & Light Company is to provide the carpany with nie n.

o8 professional expertise in all matters associated with meteorological data MO mno collection, analysis and assessment as they affect Carolina Power & 11oht

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@8 Canpany. This function includes operation of onsite meteorological monitoring OQf stations at nuclear plant sites, emergency preparedness support through ocr no m a.o operational synoptic forecasting assistance, atnespheric analysis of diffusion

. and transport for potential accident and routine nuclear plant operation and

professional consultation services as related to meteorological concerns affncttng the cocpany.

A c a cember of the Operational Training & Technical Services Department, I have direct supervisory responsibility for all iteteorological conitoring and assase=ent activities and bave prepared the diffusion studies and assesecente for the Shaaren Ha.rrie Nucioar Power Plant.

3 I have prepared a technical paper attached hereto as Exhibit "E."

The statements contained thereio are incorporated into this Affidavit ae if set forth in full herein. The purpose of Exhibit B is to decortstrate that there is no factual basis for Eddleman Contention 80.or Welle Eddleman's

- Hetion for Partial Su:=ary Diesosition on Edd1*:nn Contention 80, because Applicants' ciy.ing and dispersion crodels are based on site specific data collected at the Shearon Earris alte and beaaa the failure to in'clude any

" rainout" ofrect in those codels does not result in underestiention of dose to the persons in the vicinity of the Shearon Harris Nuclear Power Plant.

YW Brian D. ricredtera Subscribed and sworn to before ce this 26f,^ day of.">eptember, 1983

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Hotary Public Hy cor.:LnaLon c2pires A -/d ' $b-4 e

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. f ~ r, EXHIBIT A BRIAN D. MC FEATERS PROJECT SCIENTIST - METEOROLOGICAL SUPERVISOR OPERATIONAL TRAINING & TECHNICAL SERVICES DEPARTMENT CAROLINA POT R & LIGHT COMPANY EDUCATION:

The Pennsylvania State University - 3. S.

Meteorology - June 1972 Member American Meteorological Society Member American Nuclear Society Member Eastern North Carolina Nuclear Society PROFESSIONAL EXPERIENCE:

Present to Project Scientist - Meteorological Suoervisor -

August 1981 Operational Training & Technical Services Department.

Presently supervising the Physical Sciences sub-unit which is responsible for all meteorological and seismological concerns of the company.

The sub-unit supports nuclear power plants with operation of onsite meteorological monitoring stations and diffusion analysis, with emergency preparedness support through coerational synoptic forecasting, with analysis an' assessments of atmospheric transport and dispersion and through general professional consultations on all P

meteorological and seismological activities as they relate to the company.

August 1981 to Senior Scientist - Meteorologist - Technical Services September 1976 Department, Licensing & Permits Section.

Responsible for the meteorological program and operation of the meteorological monitoring stations, assuring that all regulatory requirements had been fulfilled.

Additionally responsible for the preparation of the FSAR and ER sections pertaining to meteorology and atmospheric dispersion.

September 1976 to Scientist - Meteorologist - Westinghouse Electric May 1973 Corporation, Environmental Services Division, Pittsburgh, PA.

As a staff scientist, responsible for conducting and assisting in the preparation of environmental impact statements for both fossil and l

nuclear power plants.

Conducted and wrote l

meteorological analysis for both the FSAR and ER at the Clinch River Breeder Reactor as well as other nuclear power and fuel fabrication facilities.

Developed computer models to assess dispersion from fossil, nuclear and cooling tower facilities.

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e May 1973 to Ferecast Meteorologist - DeNardo & McFarland 'deather January 1976 Services, Inc., Pittsburgh, PA.

A staff forecaster responsible for the preparation of public weather forecasts for radio and television and for the briefing of private corporate clients.

Assisted in the environmental assessment of fossil facility impact upon local air quality regulations Performed field measurements of meteorological and air quality parameters using state-of-the-art instrumentation.

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EXHIBIT B I.

INTRODUCTION The purpose of this paper is to demonstrate:. 1) that the atmospheric dispersion modeling techniques used by Applicants account for site specific meteorological data, and 2) that, based on these meteorological data, any effect from " rainout" of radionuclides released in normal operatio'ns from the Shearon Harris Nuclear Power Plant ("SENPP") would be insignificant.

II.

SITE METEOROLOGY Carolina Power & Light Company has operated a meteorological monitoring station at the SHNPP site continuously since January, 1976.

This station fully complies with or exceeds the require-ments of NRC Regulatory Guide 1.23 (February 17, 1972) and is capable of measuring ambient temperature, barometric pressure, solar radiation, precipitation, wind direction, wind velocities and wind variance, at 33 feet above the ground and approximately 200 feet above the ground on a continuous basis.

The system integrates the sensor signals for each 15 minute interval, recording the averaged value for the historical record.

Details of sensor accuracies and system operations can be found in Applicants' FSAR at S 2.3.

On-site meteorological data currently included in the FSAR consists of three years of information collected from January, 1976 through December, 1978.

The information reported in the

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FSAR was compared to longer records of information from various 3

reporting services.

For instance, the data from the Raleigh-Durham airport were utilized to provide a' comparison point fcr wind data and temperature information.

The cooperative weather observer network data were reviewed to provide a comparison of temperature and precipitation information for the area.

Moreover, data have been collected continuously from the on-site monitoring station up to the present time.

All of the information reviewed indicated that the weather data collected by the on-site meteorological monitoring' system at SHNPP provided information which was representative of meteor-ological conditions within the area.

Those conditions, such as total precipitation values, which did show a variation were within

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~ expected normal variations of such high variable parameters.

No major differences in meteorological conditions were noted.

s III. DEPOSITION PROCESSES Radioactivity is removed from the atmosphere and deposited on the ground by two processes, generally referred to as dry and wet deposition.

Dry deposition includes the movement of radio-activity to the, surface by the turbulent motions of the atmosphere and also, in the case of large particles, by the influence of gravity.

In wet deposition, on the other hand, deposition of

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effluent occurs as a result of precipitation scavenging by water droplets in the case of rain and by ice crystals in the case of snow.

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  • The dominant contributor to the amount of radioactivity deposited on the ground is dry deposition.

The negligible contribution to radioactivity on the ground by wet deposition (either " rainout"--precipitation in the clouds; or " washout"--

precipitation below the clouds) during normal plant operations over the course of a year is the result of a number of factors.

The precipitation scavenging process depends upon the size of the particle in the atmosphere.

Large particles provide more

, opportunity to collide with falling rain drops and to be removed from the atmosphere.

During routine operation of SHNPP, effluents released from SHNPP will be filtered.

Therefore, large particles will be considerably reduced, decreasing the opportunity for precipitation scavenging.

The probability of precipitation

~ scave'nging is further reduced by the fact that, as discussed below, on an annual basis SHNPP has fairly uniform distribution of precipitation during all seasons of the year.

FSAR at S 2.3.2.1.4.

As the FSAR indicates, the SHNPP site receives measurable precipitation only 4.96% of the time.

FSAR at Table 2.3.2-21.

The average annual precipitation at SHNPP during the period January, 1976 through Dec' ember, 1978 was 35.41 inches.

FSAR at Table 2.3 2-18.

This figure, which includes rain, snow and sleet, is slightly lower than the statewide average of 50 inches per year and is similar to the precipitation in other eastern states.

(James J. Geraghty, et al., Water Atlas of the United States, Water Information Center, Port Washington, New York, 1973).

Thus, SHNPP does not receive an unusually large amount of precipitation.

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The precipitation that does occur at the SHNPP site is rather uniformly distributed on an annual basis indicating the absence of a well-defined rainy season.

FSAR at S 2.3.2.1.4.

Because SHNPP does not have a " distinct rainy season which corresponds to the grazing season," the technique used to est'imate the deposi-tion of airborne radionuclides from SHNPP considered only dry deposition.

Absent a distinct rainy season corresponding to the grazing season, wet deposition processes are in most cases of little significance due to their infrequent and random occurrence.

See Regulatory Guide 1.111 at p.

1.111-12.

The conclusion that wet deposition is of little significance at the SHNPP site when compared to dry deposition is illustrated by the following calculation of the contribution of wet deposition

~ in th'e vicinity of the SHNPP site.

This contribution may be esti-mated from the following equation, which can be derived from Equation 5.6.4 of R.J.

Engelman, "The Calculation of Precipitation Scavenging," Meteorology and Atomic Energy, David Slade, U.S.

Atomic Energy Commission, TID-24190, July 1968.

C@D 8AF

=

YfUX Where:

5 is the annual average relative wet deposition 6

rate (M-2)

I w

is the rainout / washout coefficient (SEC-1)

F is the fraction of time that the wind blows toward the critical receptors while it is raining U

is the annual average wind speed for the direction of the critical receptors (M/SEC)

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X is the distance to the critical receptors (M) 8 is the number of wind direction sectors (16) divided by 2 The above equation is likely to overestimate the amount of wet deposition because it neglects rainout and washout of the airborne contamination prior to reaching the receptor location.

Thus, without the depletion of the cloud, more material is available for deposition at the critical location.

The rainout / washout coefficient, "A," can be estimated from the total depth of precipitation at the SHNPP site to be approxi-mately 6 x 10-5 sec-1 (R.J. Engelmann, "The Calculation of Precipitation Scavenging," in Meteorology and Atomic Energy, David Slade, U.S. Atomic Energy Commission, TID-24190, July 1968.)

~HoweveY, to account for the uncertainty in the accuracy of the I

estimate, a value of 1.0 x 10-4 sec will be used in the calculation,

-1 thus adding conservatism to the result.

Table 5.2.4-2 in' Applicants' Environmental Report shows

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that the critical receptor is a milk cow located 2,900 meters north of the plant at which location the value of the dry deposi-tion (D/2) is 3.2 x 10-9 per meter squared.

Figure 2.3.2-7 i

in the FSAR show5 that the annual average windspeed for wind blowing towards the north sector is 3.9 mph or 1.7 m/sec.

Figure 2.3.2-11 in the FSAR shows that the precipitation frequency of southern winds (blowing toward the north) is approximately 7%.

Since the frequency of precipitation is approximately 5%,

the value of F is equal to 0.07 x 0.05 - 3.5 x 10-3, 1

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i Substituting the above value into the wet deposition l

equation, one obtains an annual average relative deposition rate for the critical receptor of 1.8 x 10-10 per meter squared.

The resultant value of the wet deposition is more than an order of magnitude lower than the estimate for dry deposition:

( 3. 2-9 ) / (1. 8-10 ) = 17.78 i.e.,

(dry deposition)/ (wet deposition)

=

times less.

The above calculation demonstrates that the process of wet deposition will have an insignificant impact on the amount

.of radioactivity deposited at any location, and thus on the. dose from radionuclide releases when averaged on an annual basis for routine plant operations.

As the above discussion indicates, during specific isolated events, wet deposition can exceed dry deposition.

This fact does

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not, however, indicate that under assumed accident conditions, wet deposition could result in doses from radioactivity in excess of the values calculated in Applicants ' FSAR at Table 2.3.4-5.

I As discussed in detail in Appendix B to the McFeaters Affid&vit I

I in Applicants' Motion for Summary Disposition Of Intervenor Wells Eddleman's Contention 80 (Atmospheric Dispersion Model), the failure to account for rainout or washout of radionuclides during an assumed accident condition is conservative because it results in a higher estimate of dose from inhalation of radionuclides.

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September 27, 1983 00LKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'83 EP 29 PR:23

{Ih5hhhtT{;

BEFORE THE ATOMIC SAFETY AND LICENSING BO BRANCH 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)

)

CERTIFICATE OF SERVICE I hereby certify that copies of the documents listed on the attached " Document List" were served this twenty seventh day of September, 1983 by deposit in the United States mail, first class, postage prepaid, to the parties on the attached Service List.

Y LE J'e" Pamela H.

Anderson Dated:

September 27, 1983

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1 DOCUMENT LIST 1.

Applicants' Reply to Wells Eddleman's Motion for Partial Summary Disposition on Eddleman Contention 80 2.

Statement of Applicants' Position on Wells Eddleman's 1

Material Facts As to Which There Is No Genuine Issue To i

Be Heard

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3.

Affidavit of Maynard E.

Smith 4.

Affidavit of Brian D. McFeaters in Support of Applicant's' i

Reply to Wells Eddleman's Motion for Partial Summary i

Disposition on Eddleman Contention 80 1

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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CAROLINA POWER & LIGHT COMPANY

)

Docket Nos. 50-400 OL 1

and NORTH CAROLINA EASTERN

)

50-401 OL MUNICIPAL POWER AGENCY

)

)

Plant, Units 1 and 2)

)

(Shearon Harris Nuclear Power

)

SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Commission 307 Granville Road Washingtod, D.C.

20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board

.delstein and Payne U.S. Nuclear Regulatory Commission Post Office Box 12 607 Washington, D.C.

20555 Raleigh, North Carolina 27605 Dr. Richard'D. Wilson Dr. James H. Carpenter Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Co= mission Apex, North Carolina 27502 Washington, D.C.

20555 Mr. Wells Eddleman Charles A. Barth, Esquire (4)

-A Iredell Street.

Myron Karman, Esquire Durham, North Carolins 27705 Office of Executive Lhgal Director U.S. Nuclear Regulatory Commission Richard E. Jones, Esquire Washington, D.C.

20555 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 C11ANGE7EIP

  • Chapel Hill, North Carolina 27514 5 7 a7.W ayer oae :S t r e e t R.a re 1gh., N o.r.t h.C'a.r o 1in a 276.06 Dr. Linda Little 1

Governor's Waste Management Board 513 Albenarle Building 325 North Salisbury Street Raleigh, North Carolina 27611

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Service List i

Page Two 4

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~j Bradley W. Jones, Esquire U.S. Nuclear Regulatory Commission i

Region II i

101 Marrietta Street Atlanca, Georgia 30303 Ruthanne G. Miller, Esquire,

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Atomic Safety and Licensing Board Panel j

U.S. Nuclear Regulatory Co==ission i

Washington, D.C.

20555 l

1 Roberr P. Gruber l

Executive Director i

Public Staff - NCUC Post Office Box 991 l

Ralt,igh,, North Carolina 27602 l

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