ML20101S921

Affidavit of RR Bowers on Contention M.Fixed Offsite Independent Radiation Monitoring Sys Less Desirable than Flexible,Mobile Sys Available.Certificate of Svc Encl

ML20101S921
Person / Time
Site:	Perry
Issue date:	01/31/1985
From:	Bowers R CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20101S871	List: ML20101S869 ML20101S892 ML20101S904 ML20101S921
References
OL, NUDOCS 8502050714
Download: ML20101S921 (6)

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4 4-La t UNITED STATEF ' AMERICA NUCLEAR REGUL7' COMMISSION COMETEc BEFORE THE ATOMIC SAFET. AND LICENSING BOARD E3 FE3 -5 A9 :49 In the Matter of )

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THE' CLEVELAND ELECTRIC ) Docket Nos. 50f440$9f"jEN >

ILLUMINATING COMPANY ) 50-441

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF RICHARD R. BOWERS ON CONTENTION M County of Lake )

) ss:

State of Ohio )

Richard R. Bowers, having duly sworn, deposes and says:

1. I am presently Corporate Health Physicist, The Cleveland Electric Illuminating Company (CEI). My business address'is 10 Center Road, Perry, Ohio 44081. In my position, I have technical overview responsibilities for both the operational health physics program and the engineering health physics program. In this position I provide consulting assistance to these two groups.as well as perform reviews of their. programs'. - A current statement of my professional and technical qualifications is attached hereto. I have personal knowledge'of the matters stated herein and believe them to be-true and correct. I make this affidavit in support of Applicants' Motion for Summary Disposition of Contention M.

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f 7.c 2. There is no regulatory' requirement or guidance requiring fixed, independent off-site monitoring systems around a nuclear power plant. To assure that every possible accidental release would be monitored, a very large and complex system would be required. For-Perry, approximately 103 fixed monitoring locations would be needed to be sure that the plume

.would be tracked. The cost for installation and operation of such a system would be substantial. Guidance from the Federal Emergency Management Agency indicates that fixed monitoring systems are not recommended. As stated in in FEMA-REP-2, Guidance on Off-Site Emergency Radiation Measurement Systems (September 1980), page 4-15:i "The Task Force considered the concept of j making field measurements of the distribution of radionuclide concentrations I

in the plume with a system of fixed monitoring locations as a method of estimating the dispersal of the plume and for projecting exposure patterns. This concept was rejected because of=the large number of sophisticated detectors and the 4 telemetry necessary for such a system. At least 150 detector locations would be required out to a distance of approximately 8 miles from the site for good spatial distribution. Both radiciodine and direct gamma measurements would have to be made and telemetered to the EOC in order to get the necessary information for making a dose projection. The maintenance, repair and calibration of such systems would be very costly and hard to justify in view of the accident probability."

3. A more effective method for-evaluating accidential releases,is to use mobile survey teams. These teams can move

.to the area where meterological conditions (both wind speed and t

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a- Ldirection) indicate the plume is located, and make measurements to' define.the precise plume location and the radiation levels associated with it.- The mobile survey teams can use instrume'.ts to measure the whole body dose directly, and can take special air samples to evaluate radioiodine concentrations. As the plume moves, the survey teams can follow it. Data from these actual field measurements are fed

.back into the dose projection models to make the projections more accurate.

4. In addition to the mobile survey teams used by CEI, the State of Ohio also fields mobile survey teams to monitor the actual conditions downwind. See Affidavit of Ronald W.

Smith on Contention M. These State monitoring teams, and any monitoring personnel supplied by the Counties, provide an independent monitoring assessment. The reference in NUREG-0654, p. 58 which discusses assessment of radiological hazards, includes:.

"This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times,"

thus indicating the use of mobile monitoring teams to perform the assessment. FEMA-REP-2, page 4-17 also states:

" Portable instrumentation is expected to be the most cost-effective category of instrumentation for measuring exposure rate patterns from an airborne release from a nuclear incident. The plume from such a release may cover a large area and its

-shape may be continuously changing with the prevailing' meteorology. .Therefore, a l

o flexible. system using a limited number of

'a measuring devices is much more cost Teffective than the large number of fixed detectors with their associated telemetry required to obtain the same information."

5. The use of mobile monitoring teams provides the most effective, as well as: efficient, method to track and measure offsite. doses during an accidental release. A fixed radiation monitoring system is not logical from a technical viewpoint, ,

and is not called for by any regulation or regulatory guidance.

6. In any event, there currently are two' fixed-independent radiation monitoring systems in place around Perry.

In addition to the 25 thermoluminescent dosimeters (TLD) monitors placed and maintained by CEI throughout the plume exposure pathway Emergency Planning Zone (EPZ), the State of.

, Ohio and the NRC have 27 and 25 TLD monitors respectively, arranged in rings within'the plume exposure pathway EPZ, to

, measure the doses from accidents as well as any doses from normal plant operation, if any measurable doses are produced.

Although these devices cannot give instantaneous indications, they would be valuable to measure the doses during an. accident.-

They could be (and typically are) changed during an accident to evaluate doses during various stages of an accident.

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7.- In'surmry, there is no re6ulatory requiremer.t ,r gildance (cr t'xed, cfr-site ~ independent radiati:n ::nitorir.g syster.s. Fixed systens wculd be mu:h less: desirable than the flexiele, met,ile systens available at Ferry.

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6 Name: Richard R. Sowers, Ccrporate Health Physicist Fornal Education:

Sachelor of Science in chemistry, Tr.e Pennsylvania State University, 1955 Experience:

1984-Present: Cleveland Electric Illuminating Company

.As Corporate Health Physicist, responsible for overview of operational, engineering, and environmental radiological control programs. Respcnsible to provide policy, criteria, standards, measurement methodolo61es, and evaluations for radiolegical and radiological environmental protection programs and practices.

1970-1984: NUS Corporation

• As Manager of the Health Physics Services Department, responsible for manage =ent and technical direction / review of radiation protection consultin5 projects for utility clients. Projects included develop-ment of operational radiation protection pro 6 cams, health physics procedures, radiological emer6cncy plans, health physics training, and decennissioning prograns as well as plant /systen ALARA revleus, radiation protection equipnent evaluations, and reviews of health physics programs. '

1963-1970: Niagara Mchawk Power Ccrporation As Health Physics and Chemistry Supervisor, resper.sible for setup and management of the radiation protection program at Nine Mile Point 1. Trained and hupervised technicians, administered enviren-l mental monitoring progra.m., developed radiolo61 cal energency plan, wrote health physics and chemistry procedures, and purchased and set up health physics / chemistry equipment.

i l As Radiological Engineer, assisted ir. the design of Nine Mile Point 1. Assisted with genera.' plant layout and designed plant shielding. Designed health physics and chemistry facilities.

l Designed installation details of process and effluent men:tcrs.

1955-1963: E. I. duPont de Nemours.and Co.

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' As Health Physics Engineer at the Savannah River Plant, supervised technicians in separations plants, fuel fabrication facilities, and 1 production reactors.

Professional Memberships:

Health Physics Society Certifications Ccmprehensive Health Physics-American Board of Health Physics-1963 Pcwer Reacter Health Physics-American Board of Health Physics-1380 c c. .r, c::c. . , r,r, et, .,, ,na m.~ - --. - -

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' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD-sihTC" In the Matter of )

) CFrfce -

THE CLEVELAND ELECTRIC -) Docket N"df0E5"ddd UMj{':

ILLUMINATING COMPANY ) -

5044 1

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(Perry Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion For Summary Disposition of Contention M," " Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard on Contention M," " Affidavit of Richard R. Bowers on Contention M," and " Affidavit of Ronald W. Smith on Contention M," were served this first day of February, 1985, by deposit in the U.S. mail, first class, postage prepaid, upon the parties listed on the attached Service List, except for those parties identified by asterisk who were served by express mail.

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E. Silberg Dated: February 1, 1985 l

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' UNITED-STATES OF AMERICA

-NUCLEAR. REGULATORY. COMMISSION ,

BEFORE THE ATOMIC ^ SAFETY AND LICENSING BOARD In.the Matter of' )

)

.THE' CLEVELAND ELECTRIC ) ' Docket Nos. 50-440

' ILLUMINATING COMPANY, ET'.AL.

) 50-441

)

'(Perry Nuclear Power Plant, )

Units-11 and 2)- .)

SERVICE LIST James P.'Gleason,' Chairman Atomic Safety and Licensing 513 Gilmoure Drive .

Appeal Board Panel Silver Spring,' Maryland 20901 U.S. Nuclear Regulatory Commission

. Washington, D.C. 20555 Mr. Jerry R.'Kline Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington,RD.C. 20555 Mr. Glenn O.-Bright Colleen P.-Woodhead, Esquire Atomic Safety and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C.J 20555 Alan S. Rosenthal, Chairman Atomic Safety and Licensing

• Terry Lodge, Esquire Appeal Board Suite 105 U.S. Nuclear Regulatory Commission 618 N. MichiganJStreet Washington, D.C. 20555 Toledo, Ohio 43624 Dr. W. Reed Johnson Donald T. Ezzone, Esquire Atomic Safety and Licensing Assistant Prosecuting Attorney Appeal Board Lake. County Administration U.S. Nuclear Re'gulatory Commission Center Washington, D.C. 20555 105 center Street Painesville, Ohio :44077 Gary J..Edles, Esquire Atomic Safety.and' Licensing Atomic Safety.and Licensing Appeal Board .

. Board Panel U.S. Nuclear. Regulatory' Commission RU.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C.' 20555

~

John G. Cardinal, Esquire

• Ms. Sue . Hiatt Prosecuting Attorney 8275 Munson Avenue Ashtabula County Courthouse Mentor, Ohio 44060 Jefferson, Ohio 44047

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