ML20205K603

Affidavit of RW Fell,Supporting NRC Response to Aslab Question Re Conservation Council of North Carolina Contentions 16,17 & 18.Certificate of Svc Encl

ML20205K603
Person / Time
Site:	Harris
Issue date:	02/24/1986
From:	Fell R Office of Nuclear Reactor Regulation
To:
Shared Package
ML20205K595	List: ML20205K593 ML20205K603
References
OL, NUDOCS 8602270583
Download: ML20205K603 (12)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING APPEAL BOARD

, In the Matter of )

)

CAROLINA POWER AND LIGHT )

COMPANY AND NORTH CAROLINA ) Docket Nos. 50-400 OL i EASTERN MUNICIPAL POWER ) 50-401 OL ACENCY )

)

(Shearon I!arris Nuclear Power Plent, )

Unit 1) )

AFFIDAVIT OF ROBERT W. FELL IN SUPPORT OF NRC STAFF'S P.ESPONSE TO Tile APPEAL BOARD'S QUESTION CONCERNING CCNC CONTENTIONS 16,17 AND 18 I, Robert W. Fell, being duly sworn, do depose end state:

1. I am a Nuclear Engineer in the PWR-A division within the Office of Nuclear Reactor Regulation, NRC. A copy of my professional qualifi-cations is attached. I have knowledge of the matters set forth herein with respect to environmental sampling for radioisotopic determinations.

The statements made are true and correct to the best of my knowledge, information and belief.

2. This affidavit addresses the differences in sampling frequency between the environmental monitoring progran proposed at the CP stage and that proposed at the O.L. stage with re6pect to CCNC's Contentions 16,17 and 18.

of identified The sample locations concern are in CCNC Contentions 16, 17 and 18, as surface water sample 26, groundwater sample location 39, and drinking water sample point 40.

8602270583 860224 PDR ADOCK 05000400 0 PDR

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These matters are addressed individually in the following paragraphs.

3. The sampling frequencies and analysis methods reviewed in the Final Environmental Statement (FES-OL) are identical to those required by the NRC in the Branch Technical Position dated November 19, 1979, "An Acceptable Radiological Environmental Monitoring Program" . O These requirements are part of the licensing review and will be reflected in the Padiological Effluent Technical Specifications. A copy of the Branch Technical Position was sent to all power reactor licensees and holders of construction permits on November 27, 1979. This document was received by the applicant after the Environmental Report-Construction Permit (ER-CP) was issued. Therefore , it would not be unexpected if differences e:<ist between the ER-CP and the ER-OL. Even though dif-forences do exist, the Applicant does comply with current licensing crite-ria for sampling location, frequency, and analysis methodology.

4. A review of the sampling locations listed above revealed some differences in sampling frequencies for these locations between the ER-OL and the ER-CP. A description of the differences and my technical evalu-ation follow . In summary, however, it is judged that the sampling schemes listed in the ER-OL are better than those listed in the ER-CP.

-1/ The environmental monitoring program is summarized in Table 5-4 of the FES-OL. This is identical to Table 6.1.5-1 of the ER-OL in regard to CCNC's Contentions 16,17 and 18.

Surface Water, Sample Location 26, Spillway on Main Reservoir, '4.6 Miles, South Sector of Site

5. The ER-OL specifies a composite sample to be collected over a 31 day period. At the end of each period, a monthly gross beta analysis is performed and a gamma isotopic determination is performed. By combining part of these monthly composite samples, a quarterly composite sample is prepared for tritium determination.

The ER-CP specified weekly grab samples for this sample location . A portion of each weekly sample was utilized for gross beta anelysis each week; the belance of each weekly sample was saved for three months to provide a composite sample for quarterly gamma isotopic and tritium determinations.

The ER-OL specifies a better way for sampling by utilizing a composite sampler to collect small aliquots 2_/ over 31 days. Because small aligout size samples are taken at very small intervals (perhaps as small as every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />), the monthly composite sample , because of its higher sampling frequency of more than once per week, is a better representation of the average reservoir discharge than can be obtained by composite weekly grab samples. As a result , one monthly . composite sample for beta analysis , for example, would provide a more accurate representation of radioactive particles that were released over the spillway than the four weekly samples with gross beta analysis results (as specified in the ER-CP). In addition, there is a higher probability that a 2/ An aliquot is a small fixed volume container.

significant release of radioactivity could go undetected by weekly grab samples than for the composite samples with monthly analysis checks.

G. Based on the above facts, my conclusions for this sample loca-tion are a) The monthly composite sample provides a more accurate and reliable representation than the weekly grab samples; b) The monthly isotopic gamma analysis specified in the ER-OL is at a greater frequency than called for by the ER-CP and there-fore is more conservative.

c) The Quarterly determination for tritium specified-in the ER-OL is at the same frequency as in the ER-CP; but, the composite samples used to provide the data are more representative of the average reservoir discharge than called for in the ER-CP, Groundwater, sample location 39, Onsite Deep Well in The Proximity of The Diabase Dikes.

7. The EP-OL specifies taking a quarterly grab sample and per-forming each quarter a gamma isotopic and tritium determination.

The ER-CP specifies a monthly grab sample for gross beta par-ticulate analysis and to make up a composite sample for quarterly gamma isotopic and tritium determinations.

8. The above two sampling analysis schemes are equivalent. This conclusion is based on the following evaluation.

There are several factors that affect groundwater contamination by a underground leak from the plant. The velocity of groundwater in

the aquifer is very slow. 3_/ In addition, because of the filtering effects of the soil, any released radioactive particulates are readily retarded from migration by attaching themselves to soil particles; also, soluble elements

, may chemically react with soil ingredients which will remove them from solution . The overall result of the filtering effects by the soil and the slow ground water velocity is that changes in groundwater concentration due to a plant underground leak will be slow in detection. Another fact to consider is that seepage into the groundwater from postulated cracks in the concrete basemat , if any, and walls of a nuclear power plant is extremely unlikely. On consideration of these facts , the sampling frequercy of a deep water well on the site does not have to be as frequent as, for example, rivers or reservoirs where radioactive discharges do occur. Accordingly, there is no increase in safety for sampling a deep site well more often than once per quarter (which is the Bronch Technical Position). If the well after sampling is found to contain any significant concentration of radioisotopes, or if accidental spills do occur at the plant , the sampling frequency can then be increased to determine increasing or decreasing trends.

Unlike the ER-CP, the ER-OL does not specify a gross beta analysis on the sample. The soil will filter out most if not all the radioactive par-ticulates which would otherwise be detected by gross beta analysis.

-3/ See page 2-18 of the Revised Final Environmental Statement.

Frch 1974.

Therefore , performing a grors beta analysis on a deep well sample will not provide any meaningful information. A Drinking Water, Sample Point 40, 5/ Lillington's Water Municipality,15.0 Miles, SSE of Site

9. The ER-OL specifies a monthly composite sample to perform both the monthly gross beta and gamma isotopic determination and then later for a quarterly trituim determination. If from the plant discharge data, the projected dose for the drinking water pathway exceeds 1 mrem / year, then sample must be every 2 weeks for I-131.

The ER-CP specifies a weekly grab sample to perform a weekly gross beta analysis. The samples are also used to prepare a composite sample for the quarterly gamma isotopic and trituim determinations.

The sampling frequency and analysis scheme required by the ER-OL is better than that required by the ER-CP. This is based on the following facts:

a) a composite sampler is utilized to obtain a sample that al-most continuously represents the drinking water consumed over the sampling period of 1 nonth. As discussed in paragraph 5 above, this is a better sampling method than weekly grab samples.

4,/ The Branch Technical Position does not call for deep well gross beta analysis.

5_/ It is the Staff's understanding that in 1984 the sample location was moved to provide for a permanent sample station with access to elec-trical power. The new location is 1/3 of a mile downstream of the Lillington water intake (the old sample location).

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b) The analysis for gamma isotopic determinations are per-formed more often than required by the ER-CP. Even

. though the analysis for radioactive particulates (gross beta) is performed once each month, the sample is a better representation of the water consumed over that period than can be obtained by weekly grab samples.

c) A " flag signal" (i .e . the projected dose by plant monthly analysis for the drinking water pathway) is utilized to focus attention on potential problems by increasing sam-pling frequency and analysis for major dose contributors.

10. Essed on the above considerations, I conclude that the sampling methodology for the subject locations in the ER-OL is equal to or better than that specified in the ER-CP.

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y Robert W.' Fell Subscribed and sworn to before me this jh ' ' day of February,1986 Ccl. j[ .( f Noiary Public My Commission expires: f/

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PROFESSIONAL OUALIFICATIONS OF PORBERT W. FELL

. EDUCATION University of Maryland, Ph.D (A.B.D.), Energy Conversion (Mechanical Engineering),1978 University of Michigan, M.S. , Electrical Engicering,1967 University of Michigan, B.S.E., Electrical Engineering and Engineering Mathematics, 1966 Bettis (Westinghouse) Atomic Power Laboratory Engineering School, Nuclear Engineering Certificate,1969 REGISTRATION Professional Engineer - Electrical, Mechanical Engineering EXPERIENCE United States Nuclear Regulatory Commission,1981 - Present NUS Corporation, 1971 - 1981 Division of Naval Reactors (USAEC), 1967 - 1971 University of Michigan, 1966 - 1967 International Business Machines, 1963 - 1967 U.S. Nuclear Regulatory Commission (USNRC) - As a Nuclear Engineer, responsibile for design , review and evaluation of liquid, gaseous, and solid radioective waste management system; Developed guidelines for Solid Waste Process Control Programs (PCP); Responsible for radioactive effluent Technical Specifications , and associated radioactive effluent monitoring programs and effluent limits; Responsible for establishing requirements for airborne and reactor coolant radiation monitoring instrumentation. Manage subcontractors to evaluate nuclear plant solid waste process contral programs.

As a project manager, coordinated all activities required to evaluate the acceptability of older nuclear power plants compared to present NRC licensing criteria; evaluated desirability of backfit modifications to bring old nuclear plants in compliance with present criteria.

NUS - Responsible for the detail design and project managment of high radiation reactor coolant and containment sampling systems for the Zion Nuclear Power Plant.

Analyzed the technical feasibility to find lost isotope heat sources using infrared, gamma and neutron detection schemes for ERDA.

Set up NUFUEL computer code for demand, supply, and cost studies for various nuclear fuel cycles. Projected nuclear power growth and associated demands for uranium recycle. Responsible for the mechanical design and

manufacturing specifications for boron carbide neutorn absorber plates for spent fuel ' storage assemblies. Established and carried out seismic testing and electron beam irradiation testing on boron carbide material for spent

, fuel pool assemblies. Participated in all phases of design, licensing and procurement of components for gaseous and liquid radwaste systems.

Performed process and engineering design and analysis of gaseous radwaste treatment systems. Designed the gaseous waste treatment systen for the South Texas Units 1 and 2. Participated in startup tecting of the Monticello offgas system. Performed cost-benefit analysis i of varous cooling water systems for environmental reports. Developed methods, systems, ~ and equipment for testing IIEPA and charcoal filters.

Responsible for assessment and evaluation of industrial and institutional energy conversion and conservation systems; building energy audits; and designs effective energy management systems. Developed conceptual design and performed economic analyses for central coal-fired heating plant at Owens Technical College in Ohio. Performed a total energy systen analysis and optimization including computer code development to evaluate total energy-heating / cooling and electricity generation systems employing gas turbines, diesel generatorc, or coal-fired boilern; analyzed a 20-MWe coal-fired total energy s'j stem for the City of Independence, Missouri; performed cost estimates for boilers firing various coals and assessments of major oil-burning facilities (for process heat) to incorporate coal as an alternate fuel.

Other recent accomplishments in the area of energy conservatrion include the conduct of several energy audits and system evaluations for 1 Kimborough Army Hospital, I.ima Army-Tank Plant and Fairchild Space and riectronics complex . These assignments involved HVAC system review and modification; building insulation cost-benefit assessment, evaluation of a retrofit heating systen, computer room heat recovery systens , load leveling evaluation, and additional energy reduction control 1

systems for the HVAC and hot water heating systems. Provided several conceptual retrofit designs for utilizing reject waste heat from an electric

generating station to supply additional district heating and cooling for the

! City of Danville, Virginia. Two of the designs proposed involved the addition of a heat pump with a single hot water / chilled water distribution j loop and a turbine extraction steam retrofit with low temperature steam distribution system.

Division of Naval Reactors -

While U.S. liaval Reserve Officer (lieutenant ) , responsibilitien included the technical administration for fabrication and procurement of nuclear fuel assemblies for nuclear powered vessels; review of technical requirements and manufacturing techniques for nuclear units; review of the technical acceptability of products manu factured with defects; and review of design changes to simplify the manufacture of nuclear power units.

University of Michigan - Conducted research on microwave antennas, antenna couplings, and high-speed switches.

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IBM - Performed circuit design and development; conducted research experiments on high-frequency pulse transmission; and participated in devising circuit testing systems.

Iyfessi nal Memberships ANS committee member on ANS Standard N 6.8, Selection for Design Criteria for Continuous Procoam and Effluent Radiation Monitors For Light Water Nuclear Reactors.

PI'DLICATIONS

" Multi-Ilundred Watt Radioisotope Thermoelectric Generator Program:

Detection . and Retrieval of Lost Radioisotope Ileat Sources of the NHW/MJS-RTG Design," prepare'! for ERDA, September 1976.

"Uorldwide Separative Work Supply / Demand" (conuthor), Atomic Industrial Forum International Conference on Uranium Enrichment, New York, June 30, 1976.

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DOCHETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING APPEAL BOARD 9 26 Af0:9

. QFFICE : g ,, ,

' In the Matter of ) u0CMETING .. $[yyg[

) BRANCH CAROLINA POWER AND LIGIIT )

COMPANY AND NORTil CAROLINA ) Docket No. 50-400 OL EASTERN MUNICIPAL POWER )

AGENCY )

)

(Shearon Ilarris Nuclear Power Plant) )

CERTmICATE OF SERVICE I hereby certify that copies of ""NRC STAFF RESPONSE TO TIIE APPEAL BOARD'S QUESTION CONCERNING CCNC CONTE!!TIONS 16,17, AND 18" in the above-captioned proceeding have been served on the following by deposit in the United States mail first class, or (*) through deposit in the !!ucicar Regulatory Commission's internal mail system, this 24th day of February,1986:

James L. Kelley, Chairman

• Richard D. Wilson, M.D.

Administrative Judge 720 I!unter Street Atomic Safety and Licensing Board Apex, NC 27502 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Glenn O. Bright

• Travis Payne, Esq.

Administrative Judge 723 W. Johnson Street Atomic Safety and Licensing Board P.O. Box 12043 U.S. Nuclear Regulatory Commission Raleigh , NC 27605 Washington, DC 20555 Dr. James II'. Carpenter

• Dr. Linda Little Administrative Judge Governor's Waste fianagement Building Atomic Safety and Licensing Board 513 Albermarle Building U.S. Nuclear Regulatory Commission 325 North Salisbury Street Washington, DC 20555 Raleigh, NC 27611 Daniel F. Read John Runkle, Esq. Executive Coordinator CIIANGE C< iservation Counsel of North Carolina P.O. Box 2151 30.' Granville Rd.

Raleigh, NC 27602 Chapel 11111, NC 27514

Steven Rochlis, Esq. II. Joseph Flynn, Esq.

Regional Counsel Associate General Counsel FEMA Office of General Counsel 1371 Peachtree Street, N.E. FEMA Atlanta, GA 30309 500 C Street, S.W. Rm 840 Washington, DC 20472

/.tomic Safety and Licensing Appeal Bradley W. Jones, Esq.

Board Panel

• Regional Counsel, USNRC, Region II U.S. Nuclear Pegulatory Commission 101 Marietta St. , N.W. Suite 2900 Washington, DC 20555 Atlanta, GA 30323 Robert P. Gruber E::ecutive Director Thomas A. Baxter, Esq.

Public Staff - NCUC John H. O'Neill, Jr. , Esq.

-P.O. Box 991 Shaw, Pittman, Potts a Trowbridge Raleigh, NC 27602 1800 M Street, N.W.

Washington, DC 2003G Wells Eddleman Atomic Safety and Licensing Board 806 Parker Street Panel

• Durham, NC 27701 U.S. Nuclear Regulatory Commission Washington, DC 20555 Richard E. Jones, Esq. II. A . Cole, Jr. , Esq.

Associate General Counsel Special Deputy Attorney General Carolina Power a Light Company Antitrust Division P.O. Box 1551 Office of Attorney General Raleigh, NC 27602 200 New Bern Avenue Raleigh, NC 27601 3 DL/LKD t. NLLTao -

^ Janice E. tioore Counsel for NRC Staff

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