ML20148T584

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Testimony of Wa Rodger,R Shropshire & CA Mazzola on Radiological & Exclusion Area Contentions
ML20148T584
Person / Time
Site: Green County Power Authority of the State of New York icon.png
Issue date: 11/01/1978
From: Mazzola C, Rodger W, Shropshire R
NUCLEAR SAFETY ASSOCIATES, POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK, STONE & WEBSTER, INC.
To:
Shared Package
ML20148T573 List:
References
NUDOCS 7812050354
Download: ML20148T584 (17)


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! PROCEEDINGS IN UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s

i In the Matter of: )

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POWER AUTHORITY OF THE STATE ) Docket No. 50-549 1 OF NEW YORK ) l

) l (Greene County Nuclear Power Plant) ) l

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TESTIMONY OF WALTON A. RODGER, ROBERT SHROPSHIRE AND CARL A. MAZZOLA ON

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RADIOLOGICAL AND EXCLUSION AREA CONTENTIONS July 22, 1977 (Revised November 1, 1978) 78120503fT [

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l 4 1 PROFESSIONAL QUALIFICATIONS i

2 WALTON A. RODGER 1 3 PARTNER 4

4 NUCLEAR SAFETY ASSOCIATES 5

6 My name is Walton A. Rodger. My business address is 5101 Ri.ver 7 Road, Bethesda, Maryland 20016. I am a partner in the nuclear f 8 consulting firm Nuclear Safety Associates, Bethesda, Maryland, l l

9 and have held this position for the past eleven years. The i

10 four years prior to that I was Vice President of Nuclear 11 Fuel Services, Inc. , serving as its Technical Director and 12 later as General Manager of its West Valley Plant. In the 13 latter position I was responsible for the construction, 14 startup, and licensing of the world's first privately owned 15 nuclear fuel reprocessing plant.

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l l 17 From 1960 to 1962, I was a Partner in the nuclear consulting 18 firm of McLain Rodger Associates. Before entering the 19 consulting field, I spent 13 years at Argonne National

! 20 Laboratory, four years et Oak Ridge National Laboratory, i

21 and one year at the Metallurgical Laboratory of the 22 University of Chicago. At Argonne I was Associate Director l

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WALTON A. RODGER 1 of the Chemical Engineering Division.

2 My total experience in the nuclear field has covered 35 years. ,

3 4 I received Bachelor of Science Degrees in Chemical Engineering

. l 5 and Meta 11ugical Engineering from the University of Michigan 6 in 1939. I obtained my Master's Degree in Chemical Engineeringj 7 from the same institution in 1940. My Doctorate in Chemical j

' 1 8 Engineering was awarded by the Illinois Institute of Technology' 9 in 1956.

i 10 j 11 I am the author of sections of several nuclear handbooks and 12 have published more than two dozen papers in the nuclear field, l 13 largely on reprocessing and waste disposal. I am a Fellow of l l

14 the American Institute of Chemical Engineers, and in 1960 l 15 was Chairman of the Nuclear Engineering Division of the 16 Institute. I am also a member of the American Nuclear Society

, 17 and the Atomic Industrial Forum. I am past chairman of the 18 ANSI Committee N-48 which is developing standards for the 19 disposal of solid nuclear waste. In 1959, I served as Technical 20 Consultant to the Joint Committee on Atomic Energy of the 86th 21 Congress at the Bearings on Industrial Radioactive Waste 22 Disposal. During 1972 and 1973, I served as a principal witnes

WALTON A. RODGER 1 for the Consolidated Utility Group in the As Low as Practicable 2 rule Making Hearing (RM 50-2). In this capacity I have done 3 extensive cost-benefit studies on LWR radwaste systems. I have 4 made detailed studies of releases from the radwaste systems 5 of more than fifteen reactors.

6 7 On this project, I have conducted an independent evaluation 8 of the radiological releases to be expected from the operation 1

9 of the proposed Greene County Nuclear Power Plant and the dosesj 10 which might result to maximum exposed individuals from those 11 releases.  !

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1 PROFESSIONAL QUALIFICATIONS 2 ROBERT SHROPSHIRI 3 SENIOR RADIOLOGICAL ENGINEER 4 POWER OPERATIONS DIVISION 5 POWER AUTHORITY OF THE STATE 6 OF NEW YORK 7

8 My name is Robert Shropshire. My business address is Power 9 Authority of the State of New York, 10 Columbus Circle, New Yo:

10 New York 10019. I am employed as the Senior Radiological 11 Engineer by the Power Authority of the State of New York.

12 13 I have worked in various phases of the nuclear fuel cycle 14 for approximately fifteen years, to include: obtaining 15 Nuclear Reactor Operator Licenses on U.S. Navy Reactors, 16 A1W and S5W, the Brookhaven National Laboratory Graphite 17 Research Reactor, and the Cornell University TRIGA Reactor; 18 decontamination and decommissioning of " Hot Cell" facilities 19 and the Walter Reed Army Institute of Research Reactor 20 Facility; radiation shielding design; preparation of 21 applicable sections of safety analysis and environmental i

22 reports; participating as an expert witness on radiological

ROBERT SHROPSEIRE s ,

1 issues before the Atomic, Safety & Licensing Board and the 2 Advisory Committee on Reactor Safeguards for pressurized 3 water nuclear power plants (Dockets No. 50-434 and 435).

4 5 From 1959 to 1964, I served in the U.S. Navy which incluc'ed 6

service aboard the nuclear submarine U.S.S. Sam Houston SSB (N) 60 7 in the capacity of reactor operator / reactor technician.

8 9 From December, 1964 to June, 1966, I was employed by Brookhaven 10 National Laboratory as a nuclear reactor operator. I participate 11 in the startup, operation, maintenance and shutdown of the 12 Brookhaven Graphite-Moderated ur-Cooled Research Reactor.

13 14 From July,1966 to July,1969, I was employed by Columbia l I'

15 University in the City of New York as assistant reactor 16 supervisor. In that capacity, I was responsible for 47 designing in-plant systems to comply with the Hazards 18 Survey Report writing of procedures, technical specifications, 19 and corrections and amendments to the Hazards Survey Report, 20 and installation and relection of Radiation Monitors for the 21 facility, working with the Health Physicist.

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ROBERT SEROPSEIRE

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.1 I also had the responsibility for establishing a maintenance 2 program, and ensuring that all conditions of applicable i 3 government licenses and regulations would be fulfilled. l 4 i 5 From December, 1968 to December, 1972, I was employed as a I

6 consultant to Atcor Inc. I participated in decontamination '

7 efforts at various nuclear installations, including Pratt 8 and Whitney's Middletown Connecticut facilities. My 9 responsibilities included those of the Health Physicist for thi l 10 project as well as supervisor of the decontard. nation of " Hot Cell. l l 11 and packaging and removal of radioactive material to a 12 licensed burial site.

13 14 I also supervised the decommissioning of Lockheed Georgia's 15 - Nuclear Facility at Dawnsonville, Georgia, and assisted in the 16 decontamination efforts of Commonwealth Edison's Dresden 17 Station. The latter job involved the decontamination of a i i

18 highly radioactive auxiliary system at the Dresden BWR, l 19 Plant I. My responsibility was to ensure that tr.e decontamina- ;

i 20 tion was carried out safely with minimum exposure to personnel, 21 and that the radioactive waste was packaged and shipped in  !

22 accordance with both local and AEC regulations. l 1

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4 ROBERT SEROPSEIRE -

1 I was also Field Manager, responsible for the overall 2 operation of the decontamination efforts for the U.S. Radium 3 Corporation plant in Danville, Pa. I was initially 4 responsible for bidding the job, and when the contract was 5 awarded, supervised both technicians and laborers until the 6 . licensed area was " released" by AEC authorities, 7

8 From January 1973 to April 1976 I was employed by Stone &

4 9 Webster Engineering Corporation. I was responsible for 10 reviewing licensing material and client and vendor correspondenc 11 for completeness, technical accuracy and conformance with 12 Company policies and Regulatory requirements.

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14 I was also responsible for the radiction protection effort 15 on Virginia Electric and Pcwer Company's (VEPCO) nuclear 16 units Surry 3& 4. As Radiation Protection Engineer, my l

17 duties included: shielding studies, accident analysis, i 18 contributing to the writing of the Preliminary Safety 19 Analysis (PSAR) and Environmental Report (ER) , responding to 20 NRC staff questions, interpreting the applicability of NRC 21 Regulatory Guides, insuring that the release of radioactive 22

ROBERT SEROPSHIRE 1 material to the environment met the "as low as reasonably 2 achievable" (ALARA) objectives promulgated by regulatory 3 agencies, responding to Advisory Committee on Reactor 4 Safeguards, Atomic Safety and Licensing Board and Radiological 5 Hearings for the Surry Power Station Units 3 & 4. I also 6 administrated and directed the overall operation of the 7 Radiation Protection Group, assisted in the hiring and the 8 training of personnel to ultimately accept responsibility for 9 a given nuclear project, maintained and implemented 10 State-of-the-Art knowledge within the Group, interfaced 11 with other offices to make use of the expertise within all 12 Radiation Protection Groups, and entertained and supported 13 generic studies in the field of radiation protection. I 14 directed the radiation protection efforts for the Jamesport 15 Nuclear Power Station, and had final radiation protection 16 responsibility for the Greene County Nuclear Power Plant.

17 18 From April, 1976 to the present I have been employed by the 19 Power Authority as the radiological engineer responsible 20 for establishing, administering, and maintaining State-of-the-21 Art knowledge within the disciplines of Radiochemistry, 1 22 Meteorology, Environmental, Radiation Protection and 4

ROBERT SHROPSHIRE 1 , Nuclear Safety. I assure that the operation of the ndclear 2 facilities and contractors under the jurisdiction of the 3 Power Authority of the State of New York conform to the 4 highest standards of radiation protection and nuclear 5 safety within criteria established by applicable regulatory 6 bodies.

7 8 I received a Bachelor of Science Degree in Nuclear Engineering 9 from Columbia University in 1975. I have also taken advanced 10 courses in nuclear engineering at Columbia University, 11 participated in the Health Physics Certification Course 12 sponsored by the American Health Physics Society in 1974, 13 the Senior Reactor Operator Training Course, Cornell 14 University,1966, the Nuclear Power Reactor Safety Course 15 at M.I.T. Boston, Massachusetts, 1973, and Environmental 16 Surveillance Course, Harvard School of Public Health; 17 Boston, Massachusetts, 1974. I am a member of the American 18 Nuclear Society, the Health Physics Society, and the 19 Standards Committee, ANS 18.1.

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1 PROFESSIONAL QUALIFICATIONS 2 CARL A. MAZZOLA  !

3 SENIOR METEOROLOGIST f

4 STONE & WEBSTER ENGINEERING CORPORATION 5 l l

l 6 My name is Carl A. Mazzola. My business address is 7 Stone & Webster Engineering Corporation, 245 Summer Street, 8 Boston, Massachusetts, where I am employed as a senior 9 Meteorologist in the Environmental Engineering Division.

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11 Since joining Stone & Webster in 1973, I have been l 12 responsible for the evaluation of all environmental impact 13 aspects, within my discipline, regarding several operating 14 and proposed nuclear and fossil-fueled power facilities.

15 These aspects have included management of accurate onsite 16 data acquisition programs, evaluations of the regional l 17 climatology fer specific plant design purposes, and I 18 mathematical model predictions of the potential impact of 19 the radiological and non-radiological gaseous releases from 20 various plant structures on the local air quality and 21 meteorology in the vicinity of the facility site. In 22 addition, I have performed studies on toxic chemical

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CARL A. MAZZOIA l 1 dispersion and LNG spill vaporization, and have also provided 2 general consultant suppcrt in these specialty study areas.

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4 My responsibilities on the Greene County Nuclear Power 5 Plant project include participation in the evaluation of l l

4 6 regional climatology and site meteorology, acquisition and i

7 analysis of onsite data, the prediction of the dispersion of 8 radiological and non-radiological plant effluents relative to i 9 air quality and radiological impacts, and assessment of the 10 impact of the proposed facility on the meteorology at the 11 Athens and Cementon sites.

12 13 Prior to joining Stone & Webster, I was employed by 14 Scott Research Laboratories., Plumsteadville, Pennsylvania, 4

15 where I was involved in a highway diffusion modeling study 16 at the Bronx-Whitestone Bridge for the Triborough Bridge 17 and Tunnel Authority. I was also responsible for all 1

i 18 serometric monitoring and diffusion modeling for an 1

19 Environmental Impact Study of proposed Route I-78 near 20 Allentown, Pennsylvania. In addition, I was also responsible 21 for the gathering of meteorological data, and the subsequent 22 analysis, concerning a large-se' ale aeromatic photochemical 1

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CARL A. MAZZOLA i 1 smog monitoring program in the New York City area.

2 3 I received a Bachelor of Science degree in Meteorology 4 in 1968 from the City College of New York and a Master of 5 Science . degree in Meteorology in 1970 from the Pennsylvania 6 State University.

7 8 I have published and/or co-authored papers such as 9 "Veriances and Spectra of Vertical Velocity Just Above the 10 Surface Layer" in Boundary Layer Meteorology, and " Atmospheric ;

I 11 Interactions, Diffusion Meteorology", a chapter in the 12 Environmental Engineers Handbook, Volume 2, Air Pollution 13 Section. My Masters Thesis is entitled " Properties of 14 Vertical Motion oyer Heterogeneous Terrain."

15 16 _I am a member of the American Meteorological Society 17 and the Air Pollution Control Association, and I belong 18 to the societies of Mu Alpha Theta and Chi Epsilon Pi, the 19 latter being a National Meteorological Honorary Society.

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. WALTON A. RODGER ROBERT SHROPSHIRE CARL A. MAZZOLA i

i 1 CONTENTION l

2 l 3 Stipulated contention I.A. of Citizens to Preserve the l l

4 Budson Valley questions the adequacy of the Applicant's controll 5 over land within the Exclusion Area Boundary and compliance 6 with radiation dose standards required by 10CFR100. Specif-7 ically, this contention states:  !

8 9 1. The Prel'iminary Safety Analysis Report ("PSAR") j 10 prepared by the Applicant does not provide reasonable 11 assurance, as required by 10CRF Section 50.35 and Section 12 50.40, that (a) the health and safety of the public will not 13 be endangered, and (b) the Applicant is financially qualified l 14 to engage in the proposed activities in accordance with the 15 Commission's regulations in the following respects: ,

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l 17 A. The PSAR does not include sufficient information '

18 to insure that the Applicant can control all land 19 within the exclusion area as required by 10CFR Part 100.

20 (Furthermore, the Applicant's subsequent request to 21 decrease the size of exclusion area will cause the dose 22 standards of 10CFR Part.100 to be exceeded unless j 13

- * , WALTON A. RODGER . ,

i ROBERT SHROPSHIRE CARL A. MAZZOLA 1 unapproved meteorological models are to be employed, or 2 plant design changed) .

3 4 RESPONSE i

5 6 Title 10 to the Code of Federal Regulations Part 100 (10CFR100 ;

7 Section 100.3 defines Exclusion Area as:

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l 9 " Exclusion Area" means that area surrounding the reactor, in I 10 which the reactor licensee has the authority to determine 11 all activities including exclusion or removal of personnel 12 and property from the area. This area may be traversed by a 13 highway, railroad, or waterway, provided these are not so l 14 close to the facility as to interfere with normal operations j 15 of the facility and provided appropriate and effective 16 arrangements are made to control traffic on the highway, 17 railroad, or waterway, in case of emergency, to protect the 18 public health and safety. Residence within the exclusion 19 area shall normally be prohibited. In any event, residents 20 shall be subject to ready removal in case of necessity.

21 Activities unrelated to operation of the reactor may be 22 permitted in an exclusion area under appropriate limitations l

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WALTON A. RODGER

'- ROBERT SHROPSHIRE '

CARL A. MAZZOLA 1 provided that no significant hazards to the public health 2 and safety will result.

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4 The exclusion area for the Greene County Nuclear Power Plant J 5 (GCNPP) is shown in PSAR Figure 1.2-3. The land portion of 6 this area will be entirely owned and controlled by the 7 Applicant with neither public highways nor main railroad lines 8 traversing its boundary. All onshore activities within the i l

9 exclusion area will be under direct Applicant control with l

10 the exception of periodic maintenance of the U.S. Coast Guard l l

11 beacons located near the shoreline. Coast Guard use of this

] 12 land is presently granted by lease, which permit practicable 13 right of way. It is the Applicant's intention to continue 14 such a leasing arrangement with the stipulation that proper l 15 notification be made when Coast Guard personnel intend to 16 perform inspections or maintenance at the beacons. The 4 17 arrangements also provide for timely notification and 18 evacuation of Coast Guard personnel as required by the 19 Applicant. Additionally, the Coast Guard has assured the 20 Applicant that they will respond when required to control 21 access to the waters within the exclusion area boundary to 22 mitigate the consequences of an accident. The Applicant will  !

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WALTON A. RODGER ROBERT SHROPSHIRE .  :

CARL A. MAZZOLA 1 install a public address system capable of notifying personnel

, 2 on the water within the area as the need may arise.

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1 4 The direction dependent meteorological diffusion model l 5 employed by the Authority to determine radiation doses at the 6 outer boundary of the exclusion area following Design Basis 7 Accidents is specified in Section 2.3.4.2 of the GCNPP-PSAR.

8 An.. independent evaluation by the NRC Staff using a direction ,

1 9 dependent meteorological diffusion model was performed. This j

10 model is described in Appendix D of the GCNPP Safety Evaluatio; 11 Report (NUREG 0283, September,1977) (SER) . As indicated in 12 Appendix D, the NRC Staff concludes that "the direction 13 dependent diffusion model provides a realistic, yet conserva-14 tive estimate of the dispersion for use in evaluating the 15 short-term accidental releases at this site". Their analysis 16 of the radiation doses at the exclusion area boundary resultin; 17 from the Design Basis Accidents as shown in SER Table 15.2 18 indicates that these doses are well within the 10CFR100 19 guidelines. This confirms the acceptability of the proposed 20 exclu'sion area.

21 i 22 Modifications were made to the GCNPP Containment Spray System l 16

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WALTON A. RODG"R -

ROBERT SEROPSH; RE .

CARL A. MAZZOLA 1

, in order to provide enhanced airborne iodine removal )

2 effectiveness during a Design Basis Accident. These 3 l modifications were necessary in order to utilize the reduced l 4

exclusion area. A detailed description of the current 5

4 Containment Spray System is provided in Section 6.2.3.2.2 6 and Appendix 6A.2 of the GCNPP-PSAR.

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