ML20087J636

Testimony of Mc Cordaro,Ca Daverio,Ml Miele & Rj Watts on Contention 88 Re Dose Criteria & cost-benefit Analysis for Reentry.Related Correspondence

ML20087J636
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/21/1984
From:	Cordaro M, Daverio C, Miele M, Watts R ABB IMPELL CORP. (FORMERLY IMPELL CORP.), LONG ISLAND LIGHTING CO.
To:
References
CON-DSB-69 OL-3, NUDOCS 8403230016
Download: ML20087J636 (43)

Text

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L -!; . j f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning (Shoreham Nuclear Power Station, ) Proceeding)

Unit 1) )

LILCO'S TESTIMONY ON CONTENTION 88 (DOSE CRITERIA AND COST-BENEFIT AJALYSIS FOR REENTRY)

)

Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 (804) 788-8200 8403230016 840321 N /

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U%:c?n UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *g4 W 22 pp;47 0

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Before the Atomic Safety and Licensing Board .

In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning (Shoreham Nuclear Power Station, ) Proceeding)

Unit 1) )

LILCO'S TESTIMONY ON CONTENTION 88 (DOSE CRITERIA AND COST-BENEFIT ANALYSIS FOR REENTRY)

PURPOSE Contention 88 states that the LILCO Transition Plan is inadequate because (1) the Flan fails to provide a basis for determining that it is safe fcr the public to reenter previous-ly evacuated areas, (2) the acceptable surface contamination levels are set forth in disintegraticr>e per minute, rather than in radiation doses to the public, and (3) the Plan does not in-clude provisions explaining h6w te apply cost-benefit analysis-for reentry. This testimony will establish that the ra-l l diological criteria in the LILCO Transition Plan for de-l termining whether a previously evacuated area is safe for reen-l l try are adequate. Specifically, (1) the LILCO Transition Plan l includes a table of acceptable surface contamination levels for reentry, (2) the table in the IILCO Transition Plan is.taken 1

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directly from Table 1 of Regulatory Guide 1.86, and (3) the ,

levels in Table 1 of Regulatory Guide 1.86 are representative of the levela for reentry used throughout the nuclear industry.

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. This testimony will also establish that pre isions in the LILCO Transition Plan for cost-benefit analysis of reentry do not apply to reentry by the general public into a previously evacu-ated area, are not relevant to public health and safety, and are not required by the regulations or NUREG-0654 guidelines.

Attachments Attachment 1 OPIP 3.10.1, Attachment 1 Attachment 2 Regulatory Guide 1.86, Table 1 Attachments 3-7 Acceptable surface' contamination levels for reentry from other emergency response plans Attachment 8 Draft ANSI 13.12 i

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O, Maich 21,'1984

• TTCPGl:phy UNITED STATES OF AMERICA ;h[U NUCLEAR REGULATORY COMMISSION T' " "' ? ? o n . q Before the Atomic Safety and Licensing Board In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning (Shoreham Nuclear Power Station, ) Proceeding)

Unit 1) )

LILCO'S TESTIMONY ON CONTENTION 88 (DOSE CRITERIA AND COST-BENEFIT ANALYSIS FOR REENTRY)

1. Q. Please state your names and business addresses.

A. [Cordaro]' My name is Matthew C. Cordaro and my business address is Long Island Lighting Company,

._ 175 East Old Country Road, Hicksville, New York, 11801.

[Daverio] My name is Charles A. Daverio and my business address is Long Island Lighting Company, 100 East Old Country Road, Hicksville, New York, 11801.

[Miele] My name is Michael L. Miele and my busi-ness address is Long Island Lighting Company, l

Shoreham Nuclear Power Station, North Country Road, Wading River, New York, 11792.

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l I [ Watts) My name is Richard J. Watts and my busi- l l

ness address is Impell Corporation, 225 Broad Hol-low Road, Melville, New York, 11747.

2. Q. Please summarize your professional qualifications and your role in emergency planning for the Shoreham Nuclear Power Station.

A. [Cordaro] I am Vice President of Engineering for LILCO and have held this position since the spring

! of 1978. My professional qualifications are being

offered into evidence as part of the document enti-tied " Professional Qualifications of LILCO Witness-es." I am sitting on this panel to provide the

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LILCO management perspective on emergency planning

, and to answer any questions pertinent to manage-ment. My role in emergency planning for Shoreham is to ensure that the needs and requirements of emergency planning are being met and that the tech-nical direction and content of emergency planning are being conveyed to corporate management.

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[Daverio) I am employed by LILCO as Assistant Man-ager of LILCO's-Local Emergency Response Imple-l menting Organization (LERIO). My professional l

qualifications are being offered into evidence as part of the document.ent'itled " Professional i

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Qualifications of LILCO Witnesses." In my capacity as Assistant Manager of LERIO, I am responsible for  !

developing and implementing the local emergency re-sponse plan for Shoreham.

[Miele] I am employed by LILCO as the Radiation i

Protection Section Supervisor in the Nuclear Engi-neering Department. My professional qualifications are being offered into evidence as part of the doc-ument entitled " Professional Qualifications of LILCO Witnesses." I am responsible for the overall management and technical direction of all onsite and offsite aspects of radiological protection for Shoreham. As such, I am familiar with the issues surrounding this contention.

[ Watts] I am the Health Physics Supervisor for the Radiological Services Section-Northeast of Impell Corporation. My professional qualifications are .

being offered into evidence as part of the document entitled " Professional Qualifications of LILCO Wit-nesses." I have been retained _by LILCO to serve as a Radiological Health Coordinator for LERIO. As such, I am familiar with the issues surrounding this contention. .

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3. Q. What is the " Preamble to Contentions 84-91"?

A. The " Preamble to Contentions 84-91" reads as fol-lows:

Preamble to Contentions 84-91. The LILCO Plan proposes that short-term and i'

long-term recovery and reentry operations will be performed by LILCO_ personnel fol-lowing & radiological emergency at Shoreham (Plan, at 3.10-1 and 3.10-2; i

OPIP 3.10.1). For the reasons specified in Contentions 84-91, Intervenors contend that contrary to the emergency planning standards of 10 CFR Secti .1 50.47(b)(13) and NUREG 0654,Section II.M, the LILCO

Plan fails to include general plans for i recovery and reentry, including the de-I velopment of necessary procedures and methods that are capable of being imple-mented.

4. Q. What is Contention 88?

A. Contention 88 reads as follows:

l Contention 88. OPIP 3.10.1 sets forth " Acceptable Surface Contamination i Levels" in units of disintegrations per l minute. The Plan does not include a

method for converting such information i into radiation-doses to the public (e.g.,

persons-rems). The Plan also fails to state the dose criteria that will provide.

the' basis for a determination that it is safe for the public to reenter previously l

evacuated areas. The Plan calls for a cost benefit analysis based on a

$1,000/ person-rem during temporary reen-try (OPIP 3.10.1 at 5), but provides no guidance on how to analyze a situation in  !

order to apply this criterion. Thus the q Plan fails to comply with 10 CFR Section 50.47(b)(13) and NUREG-0654,-Sections II.I.10, and II.M.1.

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5. Q. What are the legal standards cited in C'ontention '

88?

A. The legal standards cited in Contention 88 are the following:

10 C.F.R. 6 50.47(b)(13)

General plans for recovery and reen-try are developed.

NUREG-0654, II.I.10 Each organization shall establish means for relating the various measured parameters (e.g., contamination levels, l water and air activity levels) to dose rates for key isotopes (i.e., those given in Table 3, page 18) and gross radio-activity measurements. Provisions shall be made for estimating integrated dose from the projected and actual dose rates and for comparing these estimates with

, the protective action guides. The de-

! tailed provisions shall be described in separate procedures.

NUREG-0654, II.M.I i

Each organization, as appropriate, shall develop general plans and proce-dures for reentry and recovery and de-scribe the means by which decisions to j relax protective measures (e.g., allow reentry into an evacuated area) are reached. This process should consider both existing and potential conditions.

I. Acceptable Surface Contamination Levels

! 6. Q. Does the LILCO Transition Plan provide radiological criteria that will serve as a' basis for a determi-i nation that it is safe for the public to reenter previously evacuated areas?

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A. Yes. Included in Attachment 1 of OPIP 3.10.1 (Re-covery/ Reentry) is a table of " Acceptable Surface l Contamination Levels." Although the table is not expressly labeled " Acceptable Surface Contamination Levels for Reentry," it is included as Attachment 1 to the recovery and reentry section of the imple-menting procedures of the LILCO Transition Plan and l

1s intended to be used in determining whether sur-face contamination levels within a previously evac-uated area are reduced sufficiently to allow for reentry. The table is appended to this testimony as Attachment 1.

7. Q. Contention 88 alleges that the " Acceptable Surface Contamination Levels" contained in OPIP 3.10.1 are inadequate because they are set forth in disinte-grations per minute (dpm) rather than in millirems per hour (mR/hr). Why have you set forth the ac-ceptable surface reentry levels in disintegrations per minute rather than in millirems per hour?

! A. The acceptable surface reentry levels in OPIP l

3.10.1 are set forth in disintegrations per minute primarily because (1) the only NRC standards or l guidelines used to determine acceptable reentry I

levels are set forth in disintegrations per minute,

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'U and (2) the NRC guidelines set forth in disintegra-tions per minute are representative of the ones used throughout the nuclear industry.

The NRC guidelines regarding contamination levels for reentry are found in Table 1 of NRC Regulatory Guide 1.86, which is appended to this testimony as part of Attachment 2. As can be seen from Table 1, the acceptable surface levels for reentry are set forth in disintegrations per minute. The " Accept-able Surface Contamination Levels" in OPIP 3.10.1 are taken directly from Table 1 of NRC Regulatory Guide 1.86.

The acceptable surface cont' amination levels in Table 1 are set forth in disintegrations per minute for different groupings of radionuclides. The spe-

[ cific unit, used to describe surface contamination, disintegrations per minute per 100 cm 2, refers cor-rectly to the quant cy of radioactive material present per unit area and, as such, is not depen-dent on the particular type of radiation detector used to measure contamination.

The levels in Table 1 of Regulatory Guide 1.86 are representative of the ones used throughout the nu-clear industry. Similar tables from other 1

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emergency plans, including emergency plans from (1) the Campbell County, Kentucky Plan (Wm. H. Zimmer Nuclear Power Station -- Ohio), (2) the Delaware State Plan (Salem Generating Station -- New I

Jersey), (3) the Maryland State Plan (Calvert l Cliffs Nuclear Pcwer Plant -- Maryland), (4) the New Jersey State Plan (Salem Generating Station --

New Jersey), and (5) the New Jersey State Plan .

(Oyster Creek, Nuclear Generating Station -- New Jersey), are appended to this testimony as Attach-ments 3-7.

8. Q. But Regulatory Guide 1.86 has to do with "Termina-tion of Operating Licenses for Nuclear Reactors."

How does this relate to radiological levels for re-entry?

A. Both involve releasing areas for unrestricted use once the area has been decontaminated or the ra-dioactivity has decayed to less than prescribed limits. NRC Regulatory Guide 1.86 at page 1.86-2, which is appended to this testimony as part of At-tachment 2, states that "[b]efore areas may be re-leased for unrestricted use, they must have been decontaminated or the radioactivity must have de-cayed to less than prescribed limits (Table 1)."

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Table 1 of Regulatory Guide 1.86, like Attachment 1 of OPIP 3.10.1, is labeled " Acceptable Surface Con-tamination Levels." The figures in Table 1 have come to'be recognized in the nuclear industry as the prescribed radiological criteria for reentry.

See response to question 7 above.

9. Q. Do the NRC regulations or NUREG-0654 guidelines specify acceptable radiation levels for reentry?

] A. There are no NRC regulations or NUREG-0654 guidelines that address acceptable offsite ra-diological levels for reentry. NUREG-0654, K.6.C.,

4 however, states that "Each licensee shall provide

• onsite contamination control measures including:

criteria for permitting return of areas and items to normal use. See Draft ANSI 13.12." The draft ANSI is appended to this testimony.as Attachment 8.

While this document, which applies to the release of materials for uncontrolled use, is still in i

draft form, it is-significant that the surface ra-dioactivity guides are set forth in disintegrations per minute and are either equal to or' greater than the acceptable surface contamination levels found in Attachment 1 of OPIP 3.10.1.

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II. Cost-Benefit Analysis of Reentry

10. Q. Does the LILCO Transition Plan provide for  ;

cost-benefit analysis in determining whether a pre-viously restricted area can be released for public reentry?

A. No. The only provisions in the LILCO Transition Plan for cost-benefit analysis are found in Section 5.5 of OPIP 3.10.1. Section 5.5 of OPIP 3.10.1 does not address reentry of a previously evncuated area by the general public. Rather, it addresses the situation in which it is necessary for an indi-vidual to reenter an evacuated zone temporarily to deal with a " pressing matter," such as the need to turn utilities off or on or to attend to livestock.

The person reentering the evacuated area would be, in effect, acting as an emergency worker.

11. Q. Do either the NRC regulations or NUREG-0654 guidelines cited in Contention 88 require estima-tion of the cost of reentry?

A. No. The cited NRC regulations and NUREG-0654 guidelines do not mention anything about the costs-of reentry. Moreover, we do not believe that

provisions about possible costs of reentry need be included in an emergency plan.

12. Q. Why do you believe that possible costs of reentry need not be included in an emergency plan?

A. As emergency planners, we are familiar with NRC li-censing standards, and we take into account emer-gency plans for other nuclear facilities and guid-ance from NRC licensing boards. In the licensing proceeding for the Diablo Canyon Nuclear Power Plant, Units 1 and 2, In re Pacific Gas and Electric Company, LBP-82-70, 16 NRC 756, 788 (1982), the intervenors abjected that neither the applicant nor the State had estimated or provided for possible costs of reentry and recovery in their emergency plans. The lic'ensing board stated that

"[n]o such estimates or provisions are required in either NRC regulations or NUREG-0654. No such re-quirement should be imposed since such cost esti-mates would not be relevant to public health and

. safety." Moreover, we note again that the provi-sions in OPIP 3.10.1 relating to cost-benefit anal-ysis do not apply to reentry by the general public of a previously evacuated area. Thus, the issue of public health and safety is of even less concern than in the Diablo Canyon proceeding.

13. Q. Are the provisions in the LILCO Transition Plan for cost-benefit analysis of temporary reentry relevant to public health and safety?

l A. No. As stated previously, the provisions in OPIP 3.10.1 for cost-benefit analysis do not apply to reentry of the general public into a previously evacuated area. See response to question 10 above.

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Attachment 1 I

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Attachment 1 Page 1 of 2 OPIP 3.10.1 Page 7 of 8 Attachment 1 Page 1 of 2 ACCEPTABLE SURFACE CONTAMINATION LEVELS l

Average (2)(3) Maximum (2)(4) Removable (2)(5)

Nuclide (1) 2 2 2 100 cm 100 cm 100 cm U-nat, U-235 5,000 dpm (6) 15,000 dpm 1,000 dpm 2 U-238, and alpha alpha alpha .

associated decay products Transuranics 100 dpm 300 dpm 20 dpm RA-226, Ra-228, Th-230, Th-228, Pa-231, Ac-227, I-125, I-129

, Th-nat,Jrh-232 1,000 dpm 3,000 dpm 200 dpm Sr-90 Ra-22d,Ra-223U-232, I-126, I-131, I-133 Beta gamma emitters 5,000 dpa 15,000 dpm 1,000 dpm (nuclides with decay beta gamma beta gamma beta-gamma modes other than alpha emission or spontaneous fission) except Sr-90 and -

others noted above NOTES:

l l (1) Where surface contamination by both alphs- and beta gamma-emitting nuclides exists, the limits estaelished for alpha- and beta gamma-emitting nuclides should apply independently.

(2) As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.

Rev. 0

, 5/9/83

Attcchment 1 Page'2 of 2 OPIP 3.10.1 Page 8 of 8 Attachment 1 Page 2 of 2 ACCEPTABLE SURFACE CONTAMINATION LEVELS (continued)

NOTES: (continue)

(3) Measurments of average contaminant should not be averaged over more than 1 square meter. For objects of less surface area, the average should be derived for each such object.

(4) The maximum contamination level applios to an area of not more than 100 cm 2, (5) The amount of removable radioactive material per 100 cm 2 og surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency.

(6) dpm-Disintegrations per minute

Reference:

Regulatory Guide 1.86, Termination of Operating License for Nuclear Reactors, Table 1.

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Rev. 0 5/9/83 1

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Attachment 2

on the hte. Those radu.actne maten..is temainmg on the fluids and waste should be removed from tne sirc. Attachm site muu be isol.ited f rom the pubhc by physical barners Adequate radiation monitonng. environmental surved.Page 1 of 2 or other means to present pubhe access to hazardous lance, and appropriare secanty procedures should be a a ..hanon Suneill.mee is necessary to assure the estabhshed under a possession <mly hcense to ensure that the health and safety of the puSlie is not endangered.

Mg teon uneg, i ! the b,rriers. The amount of

- %.e n quoed depends upon (In the potential

. ... .o ; :o ths h. .ib 's .o ! safety of the pubhc from b. In Place Entombment. In-place entombment con-tad.vutne rn.ne ii' remannag ut, the see and (2) the snts of seahng all the remammg highly radio- tive or inreemt of the ninuai ha'nen]itenore are.is may : e contaminated components (e g., the pressure vessel and reicaea ior mucsinued use, use) imot h.ne been reactor internalsi withm a structure integral with the biolocical shield after having all fuel assembhes, radm-l decontammated on the radioastmtv must have deca >cd l te less than presenbed hnnis (Tahle i L aenvc ilmds and wastes. and certam selected com-ponents shipped offsite. The structure should provide The hai.nd assoaated woh the rerned facihty is integnty over the period of time in which sigmticant evaluated by considenng the amount and type of quantines (greater than Table I levels) of radioactivity remmmg contammatmn. the degree of confinement of remam wnh the material m the entombment. An the remairling rad.oactive materials, the physical security appropriate and continuing surveillance program should pmvided by Ihe con 6nement, the susceptibihty to be established under a possession-only license.

release of radiation as a result of na' ural phenomena, and the Juranon ut required survedlance. c. Removal of Radioactive Ccmponents and Dis-mantling, All fuel assemblies, radioactive fluids and C. REGULATORY POSITION waste, and other materials havmg activities above ae.

cepted unrestricted activny levels (Table I) should be

1. APPLICATION FOR A LICENSE TO POSSESS BUT removed from the site. The facility owner may then have NOT OPERATE (POSSESSION ONLY LICENSEI unrestricted use of the site with n, requ.rement for a license. If the facihty owner so desires.the remainder of ,

A request to amend an opera *mg hcense to a the reactor facihty may be dismantled a;.d all vestiges pmessionsmly beense should be made to the Director removed and disposed or.

of Licensmg. U.S. Atomic Energy Commission. Washing.

ton. D C. 20545. The request should include the d. Conversion to a New Nuclear System or a Fossil followmg mformation: Fuel System. This alternative, which apphes only to nuclear power plants, utilites the existing turbine system

a. A descnption of the current status of the lacdity. with a new steam supply system. The origmal nuclear steam supply system should be separated from the

b. A desenpuon of measures that will be taken to electric generating system and disposed ofin accordance present entieahty or reactmty chaup and to mmimi/c with one of the previous three retirement alternauves.

releaws of radioacavay from tiie faakty.

3. SURVEILLANCE AND SECURITY FOR Tile RE.

c. Any pro;wed changes to the tesinn.al >pealica- TIREMENT ALTERNATIVES WilOSE FINAL nens that reGesi the posesuon-on'y faahi> status and STATUS R EQUIRES A POSSESSION-ONLY the necessary disass:mbly/ retirement actmnes to be LICENSE pe: formed.

A fachty which has been heensed under a posses.

d. A safety analy sis of both the actnities to be sion only license may contain a significant amount of accomphshed and the proposed changes to the technical radmactmty in the form of activated ind contaminated speci6 cations hardware and structural materials. Survedlance and commensurate secunty should be provided to assure that

e. An msentory of activated materials.and their the public health and safety are not endangered.

locanon in the facility.

a. Physical security to prevent inadvertent exposure

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2. ALTERNATIVES FOR REACTOR RETIREMENT of personnel should be provided by multiple locked l barriers. The presence of these barners should make u i

Four ahernaines for retuement of nuclear reactor extremel) difficult for an unauthoriecd person to gam fasihues are con >idered acceptable by the Regulatory access to areas where radianon or contaminahon levels staff. These are: exceed those specified in Regulatory Position C.4. To prevent inadvertent exposure, radiation areas above 5

a. Mothballing. Mothballing of a nuclear reactor mR/hr. such as near the activated primary system of a l

t faakty consists of putung the faahty in a state of power plant should be appropriately marked and should protect ye storage. In general. the facihty may be left not be accessible except by cutting of welded closures or mtact except that all fuel assemblies and the radioactive the disassembly and removal of substantial structures I .86. ' 1 1

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Attcchmnnt 2

- TABLEI Pcgo 2 of 2 ACCEPTAHLF SURFACE CONTAMINATION LEVELS NUCLIDE3 AVERAGEb c max 1yi;yb d REMOVABLEb e U-nat. U-235. U 233. and 5.000 dpm a/100 cm 2 15,000 dpm al100 cm 2 1.000 dpm a/100 cm2 associated decay products Transuranies. Ra 226. Ra 228, 100 dpm/100 cm 2 300 dpm/100 cm 2 20 dpm!!00 crn 2 Th-230 Th-228, Pa 231, Ac 227.1125,1129 Th-nat Th 232, Sr 90, 1000 dpm/100 cm 2 3000 dpm/100 cm 2 200 dpm/100 cm2 Ra 223. Ra 224. U-232, 1126.1131.1133 Beta-gamma emitters (nuchdes 5000 dpm 0 7/100 cm 2 15,000 dpm 0-7/100 cm 2 1000 dpm #-7/100 cm2 with de a) modes other than alpha cmissmn or spontaneous fission) except St 90 and others noted above.

{ %e:e wrrue contaminatron b) both alpha- and beta-gamma-emitting nuchdes exists, the hmits estabhshed for alpha- and

{ beta-pmnia-emitting nuchdes should apply independently.

bAs used in this table, dpm e, disintegrations per rninute) means the rate of emsssio's by radaoactise matenal as determined by correcting

! the cour.ts per mmute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.

'\leasurements of nerage contaminant could not be averaged over more than I square meter. For obpets of less surface area, the average 4tould be densed for each such object.

dThe maumum contamination level apphes to an area of not more than 100 cm2.

'The amount of removabic radioactive material per 100 cm 2of surface area should be determined by s1pmg that area with dry filter or wit abwrbent paper applying moderate preuure, and assesurig the amount of radioactive matenal on the wipe with an appropnate instrument of known efficieno. When removable contamination on objects of less surface arca is determined, the pertinent levels shald be reduced proportioriaUy and the entire surface should be wiped.

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e 1.86 5

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, Attachment 3 Page 1 of 3 i

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I Campbell County, Kentucky, Radiological Emergency Plan (Disaster and Emergency Services),

4 Appendix E, Radiation Exposure Control i (Wm. H. Zimmer Nuclear Power Station-Ohio) i (June-1982). R l

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Attachment 3 Page 2 of 3 APPENDIX E-2 TRANSFERABLE SURFACE CONTAMINATION CRITERIA Average'2,an/ Maximumta,*'/ Removable <a,sif 2 Nuclide'1' __100_cm a __100_cma 100_cm _

U-nat, U-235, U-238, 5,000 dpm 15,000 dpm 1,000 dpm and associated decay alpha alpha alpha ,

products ,

i Transuranics, R-226, 100 dpm 300 dpm 20 dpm Ra-228, Th-230, Pa-231, Ac-227, I-125, I-129

Th-nat, Th-232, 1,000 dpm 3,000 dpm 200 dpm Sr-90, Ra-223, Ra-224, U-232, I-126, I-131, I-133 Beta-gamma emitters 5,000 dpm 15,000 dpm 1,000 dpm (nuclides with decay beta-gamma beta-gamma beta-gamma modes other than ,

alpha emission or spontaneous fission) except Sr-90 and others noted above.

NOTES:

1. Where surface contamination by both alpha- and beta-gamma-j emitting nuclT' des exists, the limits established for alpha-and beta-gamma-emitting nuclides should apply independently.

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2. As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric far. tors l

associated with the instrumentation.

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! 3. Measurements of average radioactive material per 100 cm a og

' surface area can be determined by scanning the area at a uniform rate with an appropriate instrument of known efficiency. If the average activity is greater than those values shown in the first column the surface should be decontaminated. For objects of less surface area, the average should be derived for each such object.

E-2-1 Campbell County - Change 0, June 1982 I

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Attachment 3 Page 3 of 3

4. Measurements of maximum radioactive material per 100 cma can be determined by scanning the area for the point of highest radioactivity. If the maximum activity at this point is greater than those values shown in the second column, the surface should be decontaminated.

5. The kmount of removable radioactive material per 100 cm 2 of' surface area should be determined by wiping that area with dry filter er soft absorbent paper applying moderate ,'

pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency.

If the removable activity is greater than those values shown i in the third column, the surface should be decontaminated.

When removal of contamination on objects of less surface area is determined, the pertinent levels should ba reduced proportionally and the entire surface should be wiped.

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Reference:

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors", June 1974.

t E-2-2 Campbell County - Change 0, June 1982

Attachment 4

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Delaware State Radiological Emergency Plan I] (Division of Emergency Planning and

,! ' Operations), Section 3: Concept of Operations j (Salem Generating Station-New Jersey) (April 1983) .

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Attachment 4 3 Page 2 of 3 SURFACE CONTAMINATION LEVEL 51 Average (2,21/ Maximum 2,4s/ Removable'2,s>f 100 cm2 100 cm2 100 cm2 Nuclide 18 8

~

U-nat, U-235, U-238, 5,000 dpm 15,000 dpm 1,000 dpm and associated decay alpha alpha alpha l products Transuranics, R-226, 100 dpm 300 dpm 20 dpm Ra-228, Th-230, Pa-231, Ac-227, I-125, I-129 Th-nat, Th-232, 1,000 dpm 3,000 dpa 200 dpm Sr-90, Ra-223, Ra-224, U-232, I-126, I-131, I-133 Beta-gamna emitters 5,000 dpm 15,000 dpa 1,000 dpm (nuelides with decay beta-gamma beta-gamma beta-gamma modes other than alpha emission or spontaneous fission) except Sr-90 and others noted above.

1 of 2 Rev. 1 April 1983 c - _ - - - -

I Attachraent 4 Page 3 of 3 TABLE 3-4 (Cont)

NOTES:

1. Where surface contamination by both alpha- and beta gamma-emitting nuclides exists, the limits established for alpha- and beta-gamma-emitting nuclides l shculd apply independently.

i

2. As used in this table, dpm (disintegrations per . ) means the rate of emission by radioactive material as determined by c: .ing the ccunts per j

minute observed by an appropriate detector for background, efficiency, and geometric factors associated witn the instrumentation.

3. Measurements of average contaminant should not be averaged over more than 1 square meter. For objects of less surface area, the average shoulo be derived for each such object.

i l 4. The maximum contamination level applies to an area of not more than 100 cua ,

l

~

5. The amount of removabli radioactive material per 100 car of surface area should be determined by wiping that area with dry filter or soft absorbent paper applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency.

When removable contamination on obje~ cts of less surface area is det' ermined, l

the pertinent levels should be reduced proportionally'~and the entire surface should be wiped. 1.

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! Source: U.S. Nuefea'r Regulatory Commission,s Regulatery Guide 1.86,

! Termination of Operation, Licenses for Nuclear Reactors.

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2 of 2 - Sept. 1981 - Rev. 0

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Attechmsnt 5 Page 1 of 3 1

Maryland State Radiological Emergency Plan (Civil Defense and Disaster Preparedness Agency), Disaster Assistance Plan Annex Q, Section 3: Planning Basis (Calvert Cliffs Nuclear Power Plant-Maryland) (May 1981) l i

- _ . _ . . . . - - - . _ - - ~ - . . _ _ _ _

l l

Attachment 5 Page 2 of 3 ANNEX Q REVISION O MAY 1981 TABLE 3-8 ALLOWABLE EURFACE CONTAMINATION LEVELS i

A'verage b,c/ Maximumb,d/ Removableb,e/ f Nuclide a 100 cm* 100 cm 8 100 cm 8 l j

U-nat, U-235, U-238, 5,000 dpa 15,000 dpm 1,000 dpa and associated decay alpha alpha alpha products Transuranics, R-226, 100 dpa 300 dpa 20 dpa Ra-228, Th-230, 1

Pa-231, Ac-227, 1-125, I-129 l Th-nat, Th-232, 1,000 dpa 3,000 dpa 200 dpm Sr-90, Ra-223, l, Ra-224, U-232, l

I-126, I-131, I-133 Beta-gamms emitters 5,000 dpa 15,000 dpm 1,000 dpa (nuclides with decay beta-gamma beta-gamma beta-gamma i modes other than .

alpha emission or spontaneous fission) except Sr-90 and -

others noted above.

NOTES:

a. Where surface contamination by both alpha- and beta-gamuna-emitting nuclides exists, the limits established for alpha- I and beta-gamma-emitting nucludes should apply independently. .

b. As used in this table, dpa (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate

.. detector for background, efficiency, and geometric factors associated with the instrumentation.

c. Measurements of average contaminant should not be averaged over more than I square meter.

d. The maximum contamination level applies to an area of not l more than 100 cm*.

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Attachment 5 Page 3 of 3 ANNEX Q REVISION O MAY 1981 l TABLE 3-8 (Cont) -

)

amount of removable radioactive ma.terialthat per 100 cm* of area,with

e. The surface area should be determined by wiping absorbent paper applying moderate dry filter or soft pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. area When removable contamination on objects of less levels should be surface reduced is determined, the pertinent proportionally and the entire surface should be wiped.

SOURCE:

for Nuclear Reactors, Termination of Operating Licenses U.S. Nuclear Regulatory June 1974, Regulatory Guide 1.86 Commission.

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l 3-36

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P Attachment 6 1

Attachment 6 Pagn 1 of 2 i

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i New Jersey State Radiological _ Emergency Response Plan .

(Office of Emergency Management),

Emergency and Disaster Operations Plan, Attachment D, Section II: Planning Basis

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(Salem Generating Station-New Jersey) (December 19.81)

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Attachment 7 1

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Attachment 7 Page 1 of 3 I

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New Jersey State Radiological Emergency Response Plan (Office of Emergency 3

Management), Annex B Ocean County, Section II: Planning Basis (Oyster Creek ~~~

Nuclear Generating Station-New Jersey) (January 1983) i l

l i

• Attacrunent 7 Page 2 of 3' TABLE B-II-4 ALLOWABLE SURFACE CONTAMINATION LIMITS 1

1 l Averagesz,38/ Maximum'2,98/ Removableta,s /

Nuclide(1) 100 em2 100 cm2 100 cm2 U-nat, U-235,.U-238, 5,000 dpm 15,000 dpm 1,000 dpm and associated decay alpha alpha alpha products -

Trarsuranics, R-226, 100 dpm 300 dpm 20 dpm l Ra-228, Th-230, l

Pa-231, Ac-227, I-125, I-129 Th-nat, Th-232, 1,000 dpm 3,000 dpm 200 dpm Sr-90, Ra-223, Ra-224, U-232, I-126, I-131, I-133 Beta-gamma emitters 5,000 dpm 15,000 dpm 1,000 dpm (nuclides with decay beta-gamma beta-gamma beta-gamma modes otner that.

j alpha e. mission or j spontaneous fission) except Sr-90 and I

others noted above.

NOTES:

1. Where surface contamination by both alpha- and beta-gamma-emitting nuclides exists, the limits established for alpha- and beta-gamma-emitting nucludes should apply independently,

2. As used in this table, dpm (disintegrations per minute) means the rate of f emission by radioactive material as determined by correcting the counts per j minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.

l 3. Measurements of average contaminant should not be averaged over more than l 1 square meter. For objects of less surface area, the average should be derived for each such object.

a 4.,,The maximum contamination level applies to an area of not more than 100 cu ,

1 of 2 Rev. O, Jan. 1983 l

l -

Attaciunent 7 Page 3 of 3 TABLE B-II-4 (Cnnt) l r of surface area

5. The amount of removable radioactive material per 100 ca soft absorbent l should be determined by wiping that area with dry filter or l paper applying moderate pressure, and assessing the amount of radioactive instrument of Known efficiency. ,

material on the wipe with an appropriate When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire surface ,

should be wiped.

t l

l l

l l

Source: U.S. Nuclear Regulatory Commission, Regulatory Guide 1.86, Termination f of Operation Licenses for Nuclear Reactors, Revision 0, June 1974.

2 of 2 Rev. O, Jan. 1983 e

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Attechmsnt 8 B 06/13/83 WCB Nc 2501E Disk 00000 Job 21896 Proof 2 _ __

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TABLE 1. SURFACE RADI0 ACTIVITY GUIDES b

Activity Guide (dis / min - 100 cm )

Group -

Description Removable Fixed plus Removable 1 Alpha emitters except 20 300 U I '**d nat and Thnat' d'P uranium, 23SU and 232 Th d 90sr, 125g, 129I, 2 200 5000 131g, 223Ra 3 All radionuclides not in 1000 5000 groups 1 or 2 except' beta emitters with d

E,,x < 150 kev

'. a. A rationale for these surface activity guides is presented in Appendix 8.

b. The levels may be averaged over one square meter provided the maximum surface activity in any area of 100 cm2 is less than three times the guide values. For purposes of averaging, any square meter of surface shall be considered to be above the activity guide G if: (1) from measurements of a representative number n of sections it is determined that.1/n n 2

S, 2 G, where S4 is the dis / min - 100 cm determined from measurement of section i.

c. These are the radionuclides undergoing beta or electron capture decay 228 that present the greatest hazards as surface radioactivity. Ra is included even though it emits beta particles below the 150 kev minimum energy covered by the standard because it is readily detectable through its short-lived decay products.

I

d. The beta emitters with maximum energy less than 150 kev are excluded because detection by direct methods is not practical and they must be treated on a case-by-case basis. However, radionuclides that are detectable

by direct measurement with appropriate instrum'entation through emission of l

low-energy x and gamma rays (as in electron capture) or through the presence of short-lived decay products are included in this-category.

I I

Draft ANSI 13.12 29

.