ML20207B631

Affidavit of ML Wohl Re Contention 4 Concerning Personnel Exposures.Related Info,Including Prof Qualifications,Encl

ML20207B631
Person / Time
Site:	Turkey Point
Issue date:	07/14/1986
From:	Wohl M Office of Nuclear Reactor Regulation
To:
Shared Package
ML20207B627	List: ML20207B623 ML20207B631 ML20207B641
References
OLA-2, NUDOCS 8607180137
Download: ML20207B631 (15)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket Nos. 50-250 OLA-2 FLORIDA POWER & LIGHT COMPANY ) 50-251 OLA-2

)

(Turkey Point Plant, Units 3 and 4) ) (SFP Expansion)

AFFIDAVIT OF MILLARD L. WOllL ON THE PERSONNEL EXPOSURE PORTION OF CONTENTION 4

1. My name is Millard L. Wohl. I am a Reactor Engineer in the Technical Specifications Coordination Branch, Division of Human Factors Technology, U.S. Nuclear Regulatory Commission. Prior to November 24, 1985, I was a Nuclear Engineer in the Accident Evaluation Branch, Divi-sion of Systems Integrations where I performed radiological consequence evaluations for the NRC Safety Evaluation (SE), dated November 21, 1984, on the expansion of the spent fuel storage capacity at Turkey Point Units 3 and 4. A statement of my professional qualifications is attached.

2. The purpose of this affidavit is to address Contention 4 with respect to personnel exposures. Contention 4 states:

Contention 4:

That FPL has not provided a site specific radiological analysis of a spent fuel boiling event that proves that offsite dose limits and personal (sic] exposure limits will not be exceeded in allowing the pool to boil with makeup water from only sels-mic Category 1 sources.

In response to Licensee's .dotion for Summary Disposition of Contention 4, Intervenors allege that neither the affidavit of i

8607100137 860714 M PDR ADOCK 00000250 G PDR

Rebecca Carr, affiant for the Licensee , nor that of Millard Wohl, NRC Staff, address onsite dose to personnel .in the event of spent fuel pool boiling.

3. The Staff analyzes the offsite radiological consequences due to accidental radionuclide releases using the dose guideline values of 10 CFR Part 100. Part 100 states that doses to an individual at the site exclusion area boundary shall be within 25 rem to the whole body or 300 rem to the thyroid during the two hour period immediately following onset of the postulated radionuclide release. These guidelines are not applied to acci-dental radiation exposures to personnel onsite. Likewise,10 CFR Part 20 limits are not used by the Staff as accidental exposure occupational limits, but as limits applicable to radiological exposures acquired during routine plant operational and maintenance duties. Thus, the NRC does not im-pose onsite personnel exposure limits for accidental releases.

4. Based on an analysis performed by the Staff, the accident-related radiation exposure consequences to plant personnel in the spent fuel pool buildings would be negligible during the pre-boiling spent fuel pom heatup phase, since the estimated activity in the pool at the initia-tion of boiling (the end of the pool pre-boiling heatup period) is essen-tially zero. Memorandum from R. II. Vollmer to L. S. Tong, " Verification of Fission Product Release Rate Assumed for Spent Fuel Pool Boiling Event ," November 30, 1976 (attached) . During the boiling phase, the doses would be 5.4 rem thyroid and 35 mrem whole body assuming a twenty second occupancy time for personnel in the spent fuel pool build-ing. These dose estimates are within the dose guidelines of both 10 CFR Parts 20 and 100, even though neither section is applicable to

, occupational exposures obtained during an accident. These dose estimates are based on the conservative assumption that all airborne volatile radio-activity remains within the spent fuel pool building and the building air is inhaled at a rate of 19 liters per minute.

5. Paragraph 11 of the Affidavit of John L. Minns Regarding Contention 4 sets forth the guidelines of the Licensee's Emergency Radia-tion Protection Program. The most stringent of the plant dose guidelines listed therein is that personnel exposures by emergency workers respond-ing to accidental releases not exceed 25 rem to the thyroid or 5 rem to the whole body for emergency conditions not requiring action to prevent serious injury or a catastrophic incident. Based on a conservative esti-mate of the doses resulting from spent fuel pool boiling, I conclude that a worker could remain in the building and/or re-enter the pool building for a cumulative elapsed time of 92 seconds, and possibly longer through the use of respirators containing inhalation filters, without exceeding the 25 rem thyroid dose limit. If additional time inside the building is necessary to provide makeup water to t!:2 spent fuel pool, multiple workers could be used in order not to exceed this lowest dose guideline or any of the higher emergency prcgram dose guidelines that may be applied to a spent fuel pool _ oiling event.

6. In m 9ction 2.7 of the Turkey Point Safety Evaluation dated November 21, 1984, the Staff stated that:

Multiple means of makeup water are available until [the cooling systems for the spent fuel pools are) seismically upgraded.

Temporary connections can be provided from the fire water sys-tem or from the primary water storage tank. Additionally, there are two firehouses nearby such that, should a safe shut-down occur before the upgraded cooling system is operational, fire engines could be available in less than an hour and provide

i 4

. makup water to the pools. Thus, adequate time is available to provide the necessary makeup water.

Actions necessary for providing any of the above mentioned alterna-tive sources of makeup water, with the exception of putting . hose or pipe over the edge of the pool, could be accomplished in areas external to the spent fuel pool buildings. Since the edge of each spent fuel pool is approximately 5 feet from a doorway an individual could enter a pool building, drop a hose into the pool and exit in under 15 seconds. Thus, if boiling occurred, actions to provide makeup water which require entry into a spent fuel pool building could be performed by a single individual without exceeding the Licensee's lowest emergency exposure guideline.

1

7. In summary, the NRC does not apply either 10 CFR Parts 20 or 100 to onsite personnel exposures resulting from accidental releases, nor

! any other limits on worker exposure during or following an accident.

The Licensee does have, however, guideMnes on doses received by emer-gency workers responding to emergency conditions such as spent fuel pool boiling. Based on the Staff's conservative estimate of the doses as-sociated with spent fuel pool boiling and of the time necessary to perform actions in the building, these guidelines can be met by using a single worker, or multiple workers if necessary, to manually provide makeup water to the spent fuel pool.

i

. The foregoing and the attached statement of professional qualifica-tions are tfue and correct to the best of my knowledge and belief.

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h dad k. Yk rd L. WoM E NOTARY g j cNed an sworn to before me t% qa' of July,1986

$Notary Public "

aly commission expires: 7///9d

I MILLARD L. WOHL

~

. PROFESSIONAL QUALIFICATIONS _ .

~

TECHNICAL SPECIFICATIONS COORDINATION BRANCH

.~.

DIVISION OF HUMAN FACTORS TECHNOLOGY I am presently employed as a Reactor Engineer in the Technical Specifications Coordination Branch, Division of Human Factors Technology.

Until November 24, 1985, I was employed as a Nuclear Engineer in the Accident Evaluation Branch, Division of Systems Integration, U.S. Nuclear Regulatory Commission, Washington, D.C. My duties in this position were to conduct site and accident analyses, Emergency Response Facility Appraisals, and various other safety-related studies for nuclear power, test, and research reactor facilities. This includes probabilistic risk assessment (PRA) analyses for power reactor environmental impact statements as well as evaluation of .

applicant / licensee PPA's.

I attended Case Western Reserve University (formerly Case Institute of Technology) and received a B.S. degree in Physics in 1956. I received a M.S. [

I degree in Physics from Indiana University in 1958. I did additional graduate  !

l work as a special student in Nuclear Engineering Science at Columbia l l

University and in Nuclear Engineering at Case Western Reserve University from  !

1962 through 1964. I have had short courses in Reactor Safety,' Emergency i

Preparedness, Probabilistic Risk Assessment, and Human Reliabil Ry. l l

l

I was a teaching assistant in Physics at Indiana University from 1956 - 1958.

I have taught physics, physical science, mathematics, and statistics in the evening divisions of Baldwin-Wallace College, the Ohio State University and Cuyahoga Coccunity College from 1958 - 1973.

In 1957. I participated in the Special Power Excursion Reactor Tests at the SPERT-II Facility, National Reactor Testing Station Arco, Idaho.

In 1958, I joined the NASA Lewis Research Center staff in Cleveland, Ohio.

. My initial duties involved the writing of Monte Carlo computer codes for the determination of radiation shielding requirements and propellant radiation heating for prcposed nuclear-powered rocket designs. Other assignments

. involved methods development and shielding and nuclear safety analyses for numerous proposed mobile nuclear vehicle applications including the -

Multi-purpose Nuclear A'irplane. I was co-author of a study on disposal of radwaste in space, performed for the USAEC. Numerous other technical publications evolved in the course of the NASA work, some presented at ANS meetings. Additionally, during the period 1958 - 1973 I had substantial research contract management responsibilities.

In 1973. I joined the General Atomic Company in La Jolla, California, as a nuclear engineer. At General Atomic I performed a variety of nu'elear safety-related analyses for the High-Temperature Gas-Cooled Reactor (HTGR).

These included the analysis of Design Basis Depressurization Accidents (DBDA) and containment integrity stuties, as well as computer code upgrading and modification.

i . _

~

. -1 In 1975, I joined the Accident Analysis Branch in the Division of Technical ,

Review, U.S. Nuclear Regulatory Commission. My responsibilities. involved site characteristic studies and accident analyses. More recently I have had ,

expanded responsibilities, including Design Basis and Severe Accident (PRA)

Analyses for staff Safety Evaluations and Environmental Impact Statements.

These analyses include reactor core and piping system radiological accident analyses, steam generator repair accident analyses, core reload accident l evaluations, spent fuel pool rerack accident evcluations, containment

. enclosure shielding analyses, and severe accider.0 consequence and risk f.

I analyses. Additionally, I have participated in operating plant Emergency Response Facility (ERF) appraisal. Also, I have had substantial contract management and expert hearing witness responsibilities.

i .

Presently, I am involved in the upgrading of nuclear power plant Technical Specifications in the newly formed Technical Specifications Coordination Branch, Division of Human Factors Technology.

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]* Spent Fuel Pool Boiling Model

. The boiling., spent fuel pool model has been developed to determine:

, (1) Dose due to direct release of activity to environment from failed '

fuel rods.

(2) Dose due to release of activity from pool boiling. _

a (3) Spent fuel pool concentration during course of accident.

The following assumptions are made:

(1) Spent fuel pool cooling system failure initiates pool heatup due to decay heat.

. (2) The activity released from the failed rods is deposited into the pool

, during heatup phase (no direct release to environment from failed rods

.- during this phase) and no releases from pool during this phase.

i (3) As a result of pool heatup, the activity release rate is increased

[ significantly and can be represented by a spiking factor. The spiked release from failed rods is assumed constant during the course of accident.

(4) The activity released from the failed rods during boiling is assumed to be contained in steam bubbles.

(5) The steam bubble releases some fraction of its activity into the pool

, (through condensation) as the bubble migrates to the surface.

(6) The fraction of activity released from the steam tubble to the pool is released from the pool to the environment at a rate equal to the (boiling rate)<(mass of pool water) during boiling phase.

(7) There is no plateout of activity on pool enclosure walls.

(8) The pool boiling rate remains constant during boiling phase, i

These assumptions are considered to be conservative. -

1. Terms Tj - Time at which spent fuel cooling system fails and initiation of pool neatup (relative to prior reactor shutdown time for refueling.

T2 - Time at which pool starts to boil and initiates activity releases to environment (relative to prior reactor shutdown time for re-fueling).

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G ,s

.. , . p.' . .

.'t h T - Start time of time interval for which dose is to be calculated 3

(reiative to prior reactor shutdown time for refueling).

T 4

- End time of time interval for which dose is to be calculated (relative to prior reactor shutdown time for refueling).

G j - Percent of failed fuel rods in core during prior, refueling outage.

G 2 - Percent of failed fuel rods in core that were unloaded during prior refueling cutage.

G

- Percent of activity in failed rods available for release to pool.

3 n - Filter efficiency of SGTS in percent DF- Decontamination factor for rising steam bubble P - Reactor Power 5,- TID Source ,

M - Mass of pool water B - Rate of boiling S)- Spiking factor A - Decay constant I- Release rate coefficient (unspiked) 4.6x15 10 sec-1 A)- Spiked release rate coefficient g-Releaserateofactivityfrompoolduringboilingphase A - Release rate of activity from steam bubble to pool 3 -

Ag - Activity available for release in failed rods during heatup phase Ap - Activity in pool during heatup phase Ago

- Available activity for release in failed rods at initiation of ,

l boiling  ;

A pg - Activity in pool at initiation of boiling )

A g - Activity available for release in failed rods during boiling phase A'p - Activity in pool during boiling phase

. ., .. (G' . (' '., .

AEP = Activity released to environment from pool due to boiling in time interval T3 1t 1 T 4where T 3 1 T2

' AER = Activity released to environment from failed rods via_ steam bubbles during pool boiling in time interval T T3 1 T 2 3 1 t i T 4where (X/Q)) - X/Q for site boundary -t (X/Q)2 - X/Q for LPZ BR - Breathing rate DCF - Dose conversion factor

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2. Ecuations

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The activity available for release from the failed fuel rods in the pool at any time between initiation of pool heatup and pool boiling is AR = PS g G)G 230 10 e#1 e 4+A l M ) 1 I

f where T) i t 12 T 2

The differential equation that describes the rate of change of activity in the pool at any time between initiation of pool heatup and pool boiling is p =

dT

-A Ap+A j AR 3 where

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t

=t-T) 4

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4 The solution to equation (3), using as an initial condition that there is no activity in the pool at initiation of pool heatup, is '

Ap = PSgj23G G 0 10 e d {1- e-h MI ( -5 l The activity in the failed fuel' rods and in the pool at . initiation of

. boiling is '

Ago = PSgG G Gj23 e 1e bA + 1)b 2-Tl j Apg = PS Gj23 G 0 10 e -e - h 2%h 6 2)

where 7 -

Aj=Sj I The activity available for release in the failed fuel rods anytime after initiation of pool boiling is A'R = Ap0 e S+A I M ) 2 8

i where t>T 2 9 The differential equation that describes the rate of change of activity in the pool at anytime after initiation of pool boiling is -

dA'

= - (A + A2 ) A'p + A A'R 10 9

. em

e i)

-.e . _ _ _ . . _ _ _ _ . . _ . _ _ . _ ., ,

• . D o a 1 - -> s -

'j  ;

where ,

t =t-T 2 Il l

j The solution to equation (101 is _

"I -(A+A 2 )(t-T2 )

m

.A S3 Ro ( ' bA 2 1 2

-A )(t-T )}J 12

.j A,p =j_ Ap0 A -A 2 l b-

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i where s'

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i j A2 = B/M 13a i A3 = A j(1-1/DF) 13b

, j The activity released to the environment from the pool due to boiling in e

.j the time interval T 3 1 t1 T4 where T 3 1 T2 is pT4 A dt 14 EP

= ]T (1-n/100)A 2 A'p 3

Upon substitution of equation (12) into equation (14) and integrating we get A

EP =

(I""/ ) A Po e -b+A21 3-T 21Tl- e"(A+ A 1(T 2 4-T31 A+A 2

- l i

U - N34 2 2 MN4) 2 3 2

- (1-n/100).%2 AA 3 go [ j ,, ,

L A +A 2 * *A l # -

A2~A1 ,

(A2 " A1 )(T4 -T2 ) 1 "(A + A2 )(T4-T2)

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A+ A A+A j

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-1 The activity released to the environment from the failed rods via the

.I steam bubbles is

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j (T4 16 j A ' (1-n/100)A j A'R dt ,, ,

.t ER " A M '

T

.j 3 Upon substitution of equation (8) into equation (16) and integrating we

! get I

~l e O+A l 3 2)

] A ER = O-n/100{jh A go PdA+A j,

1

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,-(A4 aj)(T 4-T3) , 17

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The dose at the site boundary is IO Dj = JXi x BR x DCF x (AER + AEP)

A1 and that for the LPZ is

= 'X l9

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D 2 x BR x DCF x ( AER + AEP) d2 ..

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