ML20106D839

Forwards Affidavits in Support of Applicant 850130,0201 & 05 Motions for Summary Disposition of Contentions A,B,C,G,H,I,J,M,O,P,Q,U,Z,BB,CC,DD,GG,JJ,15 & 16

ML20106D839
Person / Time
Site:	Perry
Issue date:	02/07/1985
From:	Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20106D844	List: ML20106D839 ML20106E181 ML20106E340
References
CON-#185-525 OL, NUDOCS 8502130168
Download: ML20106D839 (2)

Text

n 5 06 SHAW, PITTMAN, PoTTs & TROWBRIDGE A PARTNERSMep OF PROFESS.ONAL CORPORATIONS ISCO M STRL ET. N. W.

WASHINGTON. D. C. 20036 TELEcopiER

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February 7, 1985" castr y-u -

JAY E. SIL8ERO. P.C. as . a

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Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 The Cleveland Electric Illuminating Company (Perry Nuclear Power Plant, Units 1 and 2)

Docket Nos. 50-440 and 50-441 Gentlemen:

On January 30, February 1 and February 5, 1985 Applicants filed motions for summary disposition on contentions A, B, C, G,-H, I, J, M, O, P, Q, U, Z , BB, CC, DD, GG, JJ, 15 and 16.

Some of these motions included affidavits with telecopied signature pages. Enclosed are the originals of these p affidavits:

1. Affidavit of Richard R. Bowers on Contention B;

2. Affidavit of Gary Winters on Contention B;

3. Affidavit of Gary Winters on Contention H;

4. Affidavit of Daniel D. Hulbert on Contention I;

5. Affidavit of Daniel D. Hulbert on Contention J;

6. Affidavit of Richard R. Bowers on Contention Mr

7. Affidavit of Ronald W. Smith on Contention M; fb f s

. SHAW PITTMAN, PoTTs & TROWBRIDGE A PARTNERSdl# OF PROFESSIONAL CORPOSAflONS

8. Affidavit of Roger E. Linnemann on Contention P;

9. Affidavit of Gary Winters on Contention Q;

10. Affidavit of John Baer on Contention BB;

11. Affidavit of Daniel D. Hulbert on Contention CC;

12. Affidavit of Janet E. Dugan on Contention GG; and

13. Affidavit of David R. Green on Contention JJ.

Sincerely, x ,.,

J . ILBERG Enclosures V cc: Service List (w/o encs.)

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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 )

50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF RICHARD R. BOWERS ON CONTENTION B County of Lake t

) 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 B.

'2. Contention B states in part that a low. power or no power operation at Perry during extreme conditions of inclement

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weather has not been included in the emergency plans. The logic implicit in this part of the contention appears to be that (1) evacuation is the only appropriate protective action in the event of an accident at the Perry plant with significant off-site consequences; (2) evacuation would be impossible during an " immobilizing period of inclement weather" (Sunflower Alliance's August 20, 1984 Particularized Objections, p. 3);

f therefore (3) such an accident must be avoided by requiring low power or no power during such weather conditions. My affidavit addresses the first of these arguments. The Affidavit of Gary Winters on Contention B addresses the second issue and the Affidavit of Kevin Holtzclaw on Contention B the third.

3. Initially, it should be pointed out that the kind of blizzard conditions postulated by the contention are typically associated with high winds. Such high winds would certainly be characterized as Pasquill-type A or B meteorological conditions, the most favdrable conditions for rapid dispersion

. of a radioactive plume. Rapid dispersion would greatly reduce any doses to the public. The dose reduction would range anywhere from factors of 45 to several hundred, as compared to doses calculated using standard NRC design basis licensing

. methodology.

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4. As for the argument implicit in the contention on evacuation as the only protective action, this position is

- inconsistent with NRC regulations, NRC/ FEMA regulatory guidance, and with studies that have been done on protective t

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_acti on measures. NRC regulations talk about a " range of protective actions," not only of evacuation. 10 C.F.R.

S 50.47(b)(10). NRC/ FEMA guidance also recognizes a range of protective actions, NUREG-0654, p. 59, and specifically identifies sheltering as an appropriate off-site protecti.ve'

-action, NUREG-0654, p. 9, 20, 1-12, 1-16.

5. Sheltering is an effective protection method. . EPA studies conclude that sheltering is recommended in at least two types of situations:

1. If the projected dose exceeds the (Protective Action Guide] by more than a few-fold, and ... timely evacuation is not feasible (i.e., the time available before cloud arrival is short compared with.the required mobilization, warning, and transit i

time for evacuation), then sheltering is recommended.

2. If the projected dose does not exceed the PAG by more than a few-fold, then sheltering will probably be adequate and economical.

EPA 520/1-78-001, Protective Action Evaluation -- Evacuation and Sheltering as Protective Actions Against Nuclear Accidents Involving Gaseous Releases, Pt. II, 53.

6. Studiesl/ show that the average home will reduce whole~ body dose by a factor of 2.5 to 3. The degree of whole body dose protection afforded by homes as a function-of cloud

, exposure time tends to remain relatively constant for cloud I

i 1/ PSR Report 515, Pacific-Sierra Research Corp., The Effectiveness of Sheltering as a Protective Measuro Against Nuclear Accidents Involving Gaseous Releases, p.

85 ff.

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4 exposure periods up to several hours because the main source of whole body dose will be gamma radiation from the cloud through 1

the structure. The protection that homes offer from exposure )

i l to particulates and iodines will tend to decrease with time (if the cloud is still present), as the cloud concentrations infiltrate into the home.

7. For radiciodines and particulates, the typical home will provide a protection factor from 4 to 10 for representative air change rates and a factor of from 20 to 70 for low air change rates for at least three hours. In the tir.ter time when people have their houses reasonably tightly clos 2d, both the protection factor for particulates and iodines and the length of time sheltering will be effective will be higher because infiltration will be reduced. When houses are tight, as is common in the northern part of the United States, such as the area around Perry, particulates and iodines are partially filtered as they pass through the relatively small cracks which allow outside air to enter the home.

8. Respiratory protection is another protective action N

- which could further reduce doses for sheltered individuals from inhaled particulates during extremely adverse weather that made l-evacuation unadvisable. This would involve covering the nose and mouth with such common items as-towels, handkerchiefs or toilet paper. Such simple measures can reduce doses from-such a release by a factor of about 10. EPA 520/1-78-001, Pt. II at 55.

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9 For these reasons, sheltering and respiratory protection are protective actions which can provide substantial dose savings in the event of a radiological release.

W cq fo%L Richard R. Bowers Subscribed and sworn before me this ~4 day of February, 1985.

YAA'A'Yb ~

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~ Notary Publig

. My Comission -Expires:

' BETHANY J. REESE Notary Public. STATE OF OHIO My Commission espires 3/11/88 Secorded in t.ake Countv)

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Name: Richard R. Bewers, Cceporate Health physicist Formal Education:

Sachelor of Science in chemistry, he 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 methodologies, 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 management and technical direction / review of radiation protectton consulting projects for utility clients. Projects included develop- -

ment of operaticnal radiation protection programs, health physics procedures, radiological emergency plans, health physics training, and decemnissioning prograns as well as plant /systen ALARA reviews.

radiation protection equipnent evaluations, and reviews of health physics programs.

1963-1970: Niagara Mohawk Power C rp: ration As Health Physics and Chemistry Supervisor, resper.sible for setup and management of the radiation protection program at Nine Mile Point 1. Trained and supervised technicians, administered enviren-mental monitoring program, developed radiologi' cal emergency plan.

. wrote health physics and chemistry procedures, and purchased and set up health physics /enemistry equipment.

As Radiolosical Engineer, assisted in the design of !!ine Mile Point 1. Assisted with general plant layout and designed plant shielding. Designed health physics and. chemistry facilities.

Designed installation details of process and effluent mentters.

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

As Health Physics Engineer at the Savannah River P; ant, supervised technicians in separations plants, fuel fabrication facilities, and production reactors.

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, ' Professional Memberships:

Health Physics Society Certification:

Comprehensive Health Physics-American Board of Health Physics-1963

Pcwer Reacter Health Physics-American Board of Health Physics-1980 e=..,. ce=e. .r.,, =e,

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