ML20101E921

Affidavit of L Lewis Re Assertions of Palmetto Alliance & Carolina Environ Study Group That Operation Will Significantly Increase Costs & Exposures in Performing Maint & Repair Work & Releases to Environ

ML20101E921
Person / Time
Site:	Catawba
Issue date:	12/20/1984
From:	Lashawnna Lewis DUKE POWER CO.
To:
Shared Package
ML20101E837	List: ML20101E834 ML20101E842 ML20101E865 ML20101E879 ML20101E892 ML20101E898 ML20101E913 ML20101E921
References
OL, NUDOCS 8412260448
Download: ML20101E921 (3)

Text

.fv  %.

, (( **

4 1, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 'St! "

A A!O .34 In the Matter of ) ,$ $ a . -

DUKE POWER COMPANY, et al.

) ' ?;ll*Y!h$f';'

~

) Docket Nos. 50-413 ,

) 50-414 (Catawba Nuclear Station, )

Units I and 2) )

AFFIDAVIT OF LIONEL LEWIS My name is Lionel Lewis. I am employed by Duke Power Company as System Health Physicist. I have been employed in this position since 1967. I hold a MS in Biophysics as the result of an AEC Fellowship in Radiological Physics at the University of Rochester. My professional qualifications are contained in an attachment to this affidavit.

In the position that I hold, I am familiar with the radiation levels experienced by various systems within Duke's nuclear units, including those anticipated by Catawba, as a result of operation at various power levels, including full power. I am also familiar with costs, time, difficulty, and assessment of exposures to plant maintenance and operating personnel, resulting from maintenance and repair work to those systems. Those exposures are evaluated to assure compliance with 10 C.F.R. Part 20 and the As Low As Reasonable Achievable (ALARA) philosophy (which requires licensees to use their best efforts, on a cost-benefit basis, to keep exposures ALARA within Part 20 limits).

The purpose of this affidavit is to respond to the assertions of Palmetto Alliance and CESG that operation of Catawba Unit 1 will significantly increase the costs and exposures incurred in performing 8412260440 841221 PDR ADOCK 05000413 Q PDR

2

) -

(

-maintenance and repair work and increase releases to the environment beyond those anticipated in the FSAR and ER due to the repair of supposedly faulty welds.

Before full power operation is permitted by the NRC the reactor must undergo a successful period of escalation power testing and evaluation at many low and intermediate power levels. The testing and evaluation, among other things, ensures that operation at any and all  :

power levels will fully comply with NRC regulations and the technical specifications for the operation of the reactor. This testing and evaluation also considers radiation and contamination levels in the plant, occupational doses to plant personnel due to operation and maintenance work, and doses to the public due to planned releases of radioactive gaseous and liquid effluents.

Based on our experience with our other nuclear units and particularly with the McGuire Nuclear Station which is a twin of the Catawba Nuclear Station, we believe that radiation and contamination levels in the station as a result of reactor operation will be within regulatory limits as are radiation doses incurred by station personnel. Doses to the public resulting from the normal radioactive effluent releases will also be within regulatory limits.

The NRC often requires modifications to plants which have been operating for many years. Despite the presence of large quantities of fission and activation products, work on radioactive systems has been accomplished with minimal radiation exposure. This is possible

-2

b through compliance with the radiation protection standards of 10 CFR Part 20, viable Health Physics programs, and espousement of the ALARA philosophy. Our experience at our nuclear plants confirms this point.

l I, Lionel Lewis, of lawful age, being duly sworn, state that I have reviewed the foregoing affidavit, and that the statements contained therein are true and correct to the best of my knowledge and belief.

Lionel Lewis Subscribed and swop to before me this e?g_, day of Decemt/m 1984.

0W 0 bCW/? inn Nctary Public (f

My Coriaission Expires: 7-42 Jcf

__