ML20207B641

Affidavit of Jl Minns Re Contention 4 Concerning Personnel Exposures.Related Info,Including Prof Qualifications,Encl. W/Certificate of Svc

ML20207B641
Person / Time
Site:	Turkey Point
Issue date:	07/14/1986
From:	Minns J Office of Nuclear Reactor Regulation
To:
Shared Package
ML20207B627	List: ML20207B623 ML20207B631 ML20207B641
References
OLA-2, NUDOCS 8607180140
Download: ML20207B641 (14)

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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

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

AFFIDAVIT OF JOHN L. MINNS REGARDING THE PERSONNEL EXPOSURE PORTION OF CONTENTION 4 I, John L. Minns, being duly sworn, state as follows:

1. I am a Health Physicist in the Plant, Electrical Instrumentation  ;

and Control Systems Branch, Division of PWR Licensing-B in the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. Prior to Ncvember 24, 1985, I was a Health Physicist in the Radiological As-sesr. ment Branch, Division of Systems Integration in the Office of Nuclear Reactor Regulation. A summary of my professional qualifications and ex-perience is attached hereto.

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 allow-ing the pool to boil with makeup water from only seismic Category 1 sources.

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

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8607180140 860714 0 PDR ADOCK 05000250 0 PDR

4 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.

4. Intervenor's general concern about onsite personnel safety in the event of spent fuel pool boiling poses two issues: (1) whether acceptable protective measures can be taken in advance of pool boiling to protect personnel safety, and (2) whether, in the event boiling occurs, worker safety can be adequately protected from the releases associated with pool boiling should re-entry be required to manually initiate makeup water.

As described in detail below, the Staff believes that worker exposures will be minimized in both instances through a combination of controls, radiation monitoring, water level / temperature monitoring, and emergency procedures.

5. Turkey Point, as well as other nuclear plants, employs a defense in depth concept for early warning of, and subsequent protective actions in response to, any accident or abnormal occurrence, including a loss of cooling to the spent fuel pool. Early warning via monitoring systems and precautions according to the plant's health physics program assure mini-mum radiation exposure to workers during both normal and abnormal con-ditions. The spent fuel pools have temperature indicators, water level indicators, vent radiation monitors, airborne radioactivity monitoring sys-tems and area radiation monitoring systems. The water temperature and level indicators provide redundant and diverse means of detecting loss of cooling to the spent fuel pools. The temperature indicators have an alarm setpoint of 125 F which is well below boiling and the level indicators have high/ low alarm setpoints which are activated at 2" from the normal wa-ter level in the spent fuel pools. These indicators and setpoints can

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provide early warning to alert workers in the spent fuel pool buildings as 1 to the need for protective measures with respect to personnel and to allow .

for corrective actions necessary to restore cooling before the water level in the spent fuel pool would decrease due to boiling. There is also a  !

i local pool temperature readout in each spent fuel pool area, a normal wa- ,

ter level line painted on each pool and a control room readout to remotely I monitor the water level in the spent fuel pools.

! 6. The Turkey Point plant is also equipped with systems that mon-i itor airborne radioactivity which could endanger personnel at the facility, including those working in the spent fuel pool buildings. There are area l

radiation monitors set just above normal operating levels in accordance i

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! with the limits in Table 11.2-7a of the Final Safety Analysis Report.

I These area radiation monitors will assure that exposure to workers occu-py:ng plant areas, including the spent fuel pool buildings, are maintained as low as is reasonably achievable (ALARA) during normal operation as per 10 CFR Part 20. In addition, the Unit 3 spent fuel pool building i vent monitor and the plant's vent monitoring system (which includes the Unit 4 spent fuel pool building vent output) monitor airborne radioactiv-ity released in accordance with the requirements of Technical Specifica-tions Section 3.9 and Tabic 3.9.3 for each unit. The area monitors directly , and the vent monitors indirectly through the control room operators, serve to warn workers and thus minimize radiation exposures

! to workers in the event of spent fuel pool boiling or other abnormal j conditions which might exist in the spent fuel pool areas.

7. The Licensee's area radiation monitoring systems are to ,

(1) monitor the radiation levels in areas where radiation levels could rise

4 above normal and where personnel may be present, (2) alarm when the radiation levels exceed normal operating levels to provide warning of in-creasing radiation levels, (3) assure prompt evacuation, and (4) provide a continuous record of radiation levels in the monitored areas. In order to meet these objectives, the Licensee has four spent fuel pool area moni-tors and one spent fuel pool vent monitor for each spent fuel pool. The area monitors consist of similar channels which monitor radiation levels at different locations in the spent fuel pool buildings. Each radiation moni-toring channel consists of a sensor, convertor unit (the local radiation sensor), an indicator and a trip unit. All channels, additionally, feature a locally mounted audio alarm and its controlling auxiliary unit. If the radiation level within the monitored area exceeds normal operating levels, the alarm will sound and a local high radiation indicator lamp will illumi-nate. In addition, each monitor provides input to a central readout in the control room which also has audio and visual alarms.

8. The plant's vent monitors detect radiation passing through the spent fuel pool ventilation systems. Indications and alarms from these systems are provided in a console in the cable spreading room. The Li-censee also has an airborne radioactivity monitoring system (1) to check on the integrity of systems containing radioactivity, (2) to warn of unex-pected release of airborne radioactivity to prevent inadvertent overexpo-sure of personnel, and (3) to assist in monitoring occupational exposure of workers to airborne contaminants. This system has both local and remote readouts and alarms.

9. All monitoring systems and portable radiation detection equipment are state-of-the-art to insure that in-plant personnel receive timely and

accurate information. The number and types of equipment used are con-sistent wi-th Regulatory Guide 1.97, " Instrumentation for Light Water-Cooled Nuclear Power Plant to Assess Plant and Environs Conditions During and Following An Accident," as it relates to compliance with Gen-eral Design Criteria (GDC) 63, " Monitoring fuel and waste storage," and 64, " Monitoring radioactivity releases," of 10 C.F.R. Part 50, Appendix A. GDC 63 and 64 require that instrumentation to monitor plant variables, systems and associated areas during normal operation, anticipated operational occurrences and postulated accidents be provided.

10. Personnel are also protected by shielding and operating proce-dures in accordance with the overall health physics program. As stated in Section 5.2.4.1 of the Licensee's FSAR, continuous evaluation and re-view of the radiological status of the plant will be carried out by health physics personnel so that levels of radiation will be known at all times in areas where personnel are working. Each area is classified according to the dose rate allowable in the area. The allowable dose rate is based on the expected frequency and duration of occupancy. In addition, there is portable shielding available and permanent shielding in the spent fuel pool area to protect personnel from radiation exposure during refueling, other normal work activities or emergency conditions.

11. In addition to the monitoring systems and the plant's overall health phyeics program, the effects of any accident or abnormal condition on personnel, including spent fuel pool boiling, can be mitigated by im-plementation of the Licensee's emergency plans. Licensee has a " Radio-logical Emergency Plan For Turkey Point," Rev.15, December 12, 1985, and " Emergency Plan Implementing Procedures," October 10, 1984,

particularly Emergency Proceduro No. 20110 " Criteria for Conduct of Owner Controlled Area Evacuation." Section 5.3 of the Turkey Point Ra-diological Emergency Plan outlines a program for " Radiological Exposure Control." The objective of the radiation protection program is to minimize radiation exposure to individuals both onsite and offsite during emergency conditions.

12. The Emergency Radiation Protection Program guidelines are as follows:

1) Efforts should be made to limit radiation exposures to the quarterly exposure limits established for routine opera-tions. Shorter stay times and portable shielding should be used when possible to minimize personnel exposures.

2) Where exposures to personnel are expected to exceed those permitted by 10 C.F.R. 20, the following guidelines will be met :

a) This exposure must - be explicitly authorized in advance by the Emergency Coordinator (or Re-covery Manager) or one of his recognized superiors.

b) Any volunteer authorized (by the EC or RM) to receive greater than regulatory exposure limits should be a healthy male. No women of child bearing age will be selected to perform these emergency actions.

c) Whole body exposure received by emergency workers is to be considered occupational expo-sure and retained as part of the individual's dose history. Whole body exposure limits have been established as follows:

• Under emergency conditions not re-quiring action to prevent serious inju-ry or a catastrophic incident, personnel exposure should not exceed 5 rem to the whole body or 25 rem to the thyroid.

• A planned emergency exposure to pre-vent destruction of equipment which l

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l could result in serious injury or to assess a potentially critical situation i should not exceed 12 rem to the whole

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body or 60 rem to the thyroid, a When immediate action is necessary to prevent serious injury, dose to the whole body should not exceed 25 rem and dose to the thyroid should not exceed 125 rem.

o For lifesaving actions , an individual may receive a whole body dose of 75 rem. "No specific upper limit is given for thyroid exposure since in the ex-treme case complete thyroid loss might be an acceptable penalty for a life saved. Hovever, this should not be 4

necessary if respirators and/or thyroid protection for rescue personnel are available as the result of adequate planning." [ footnote omitted] Be-cause of the health risks associated with the dose limit, lifesaving missions should be undertaken by volunteers (healthy males above the age of 45) who have an understanding of the health risks and preferentially by those whor,e normal duties have trained them for such missions.

d) Frequent checking of radiation survey instru-ments and self reading dosimeters is required during emergency operations.

e) Whenever it is likely that an area has the poten-tial for airborne radioactivity greater than limits specified in plant Health Physics procedures, appropriate protection will be prescribed.

3) The radiation exposure of individuals providing ambulance service and medical treatment service will be kept as low as reasonably achievable. Proper precautions will be taken to assure that these individual's exposure will remain with-in the limits of 10 C.F.R. 20.

The Licensee's emergency procedures also provide for the monitoring of emergency response personnel by the continuous plant radiation expo-sure monitoring program; the maintenance of dose records for all

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individuals exposed to ionizing radiation; contamination control and decon- i l

tamination procedures; training of site personnel in radiological emergency response (i.e. technical training and emergency drills); and accident miti-gation , recovery and re-entry procedures for onsite and offsite person-nel. The Licensee's onsite exposure guidelines are consistent with Environmental Protection Agency emergency worker and lifesaving activity protective action guides (Manual of Protective Action Guides and Protec-tive Actions for Nuclear Incidents, EPA-520/1-75-001, Rev. June 1980).

The Licensee's radiation protection program described above is in accor-dance with NUREG-0654, " Criteria for Preparation and Evaluation of Radi-ological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."

13. Emergency Procedure 20110 of the " Emergency Plan Implement-ing Procedures" provides criteria for determining if evacuation is neces-sary, instructions for rapid and safe evacuation in order to prevent or minimize radiation exposure to personnel, and instructions for personnel accountability. In the event that there is a loss of spent fuel pool cool-ing, the protective measures taken (such as sheltering, limited stay times or evacuation, if necessary) would be based on the potential radiological hazard posed to the workers as determined by health physics personnel and emergency teams.

14. Guidelines concerning re-entry into an evacuated area prior to commencing the recovery phase once the hazard potential has passed are contained in Section 5.4.1 of the Turkey Point Emergency Plan. The guidelines provide that re-entry into an evacuated area will be made by i I

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- the Emergency Teams when required for one or more of the following reasons:

1) To ascertain that all personnel who were in the affected area '

have been evacuated, or to search for unaccounted personnel.

2) To assist in evacuating injured or incapacitated personnel from the affected area.

3) To perform operations which may mitigate the effect of the emergency or hazardous condition [for example, manual connec-  ;

tion or provision of makeup water, if necessary, by hoses or piping] .

4) To determine the nature and extent of the emergency and/or radiological conditions.

5) To establish personnel exclusion area boundaries.

15. According to the emergency plan, re-entry may take place only under the authority of the Emergency Coordinator or the Recovery Man-ager and emergency conditions are evaluated by the leader of the Radia-tion Team, among others, as to the advisability of re-entry. For emergencies inside the radiation control area, the Radiation Team leader  ;

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must supervise the initial entry of the Emergency Teams and all subse-quent entries until radiation areas have been properly marked. These procedures will protect workers from unsafe exposures should it be nec-essary to re-enter pool areas to manually provide makeup water.

16. On page 4 of the " Affidavit of John N. Ridgely Regarding Contention 8," February 18, 1986, the Staff concludes that 7.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (the time required for the spent fuel pool to commence boiling assuming the normal heat load) is adequate time to initiate make-up water before a spent fuel pool would commence boiling. Based on this estimate of the time required for boiling to occur, there is ample time for the various monitoring systems and health physics personnel to notify workers in the l

area of the potential hazard. In case of emergency conditions such as loss of cooling to the spent fuel pools, the Station Health Physicist will take immediate action to ensure the safety of all affected personnel, eval-unte the total radiological situation and, if necessary, notify all persons to evacuate the affected area and proceed to the nearest safe location.

These emergency procedures are more than adequate to minimize personnel exposures resulting from a loss of cooling which could lead to spent fuel pool boiling. Morever, in the unlikely event that the various radiation and temperature monitoring systems and alarms--as well as the visual pool temperature and water level indicators--fall to alert workers to abnormal pool conditions and boiling were to occur, the emergency plan radiation protection program and re-entry guidelines would be sufficient to minimize exposures to workers responding to the emergency.

17. The NRC Staff concludes that the Licensee % emergency proce-dures, operating controls in accordance with the health physics program, and radioactivity, water level and water temperature monitoring systems will minimize the radiological consequences of a postulated spent fuel pool boiling event. As described above, due to the extended period of time necessary for boiling to occur and the existence of acceptable plant pro-tective systems (including radiation and water temperature level monitors and alarms) , health physics controls , and emergency plan and proce-dures, worker safety can be adequately protected by a variety a mea-sures including evacuation, if necessary, before boiling occurs. In addition, the plant's emergency plan and procedures, health physics pro-gram and monitoring systems are adequate to protect personnel safety in the event of spent fuel pool boiling and re-entry into the pool area is necessary to manually provide makeup water.

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_ 11 The foregoing and the attached statement of professional qualifica-tions are true and correct to the best of my knowledge and belief.

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/k l J ( L. Minns Subscribed and sworn to before me day of July,1986.

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.l PROFESSIONAL QUALIFICATIONS JOHN L. MINNS Plant, Electrical, Instrumentation, Control Fystems Branch, PWR-B I am a Health Physicist in the Plant, Electrical, Instrumentation, Control Systems Branch, Division of PWR Licensing -B, Office of Nuclear Reactor Regulation , U.S. Nue: ear Regulatory Commission, Washington, D.C. I attended Columbia University and received a Bachelor of Science Degree in Chemistry in 1964. I also attended Rutgers University, Graduate School of Chemistry, and Catholic University Graduate School of Nuclear Engineering. I am currently enrolled at the University of Southern California at Crystal City, Va. for a Mester of Science in Safety.

After graduation from Columbia University, I worked for E.I. Dupont de Nemours & Company, as an Emulsion Chemist , Process Control Chemist and as a Quality Control Chemist. My duties included Instrumentation Analysis, Process Research and Development, and Asst. Supervisor of the Control Laboratory Ins.trument Section.

In 1971, I joined the Atomic Energy Commission as a Plutonium Chemist (for the New Brunswick Health and Safety Laboratory). I was responsible for performing general analysis on complex plutonium and other radioactive materials and improving present methods of analysis for elements such as Plutonium, Uranium and Americum. I was also a Quality Control Chemist in the Uranium Chemistry Section.

In 1974, I joined the Nuclear Regulatory Commission (formerly AEC) as a Nuclear Chemist in the Effluent Treatment Systems B ranch . In this position, I was responsible for acquiring and evaluating source term data and effluent measurements from operating nuclear facilities and from inplant measurement programs , investigating problems relating to radioactive waste treatment systems and assisting in the development of analytical model parameters and calculational methods for evaluating the effectiveness of proposed radioactive waste treatment systems. I alco reviewed and evaluated radwaste systems and the calculation of release of radioactivity from nuclear power plants. Prior to transfer, I was a Nuclear Engineer for 21 years in the Effluent Treatment Systems Branch.

In 1978, I was transferred to the Radiological Assessment Branch as a Radiological Engineer. In November 1979, my title was changed to Health Physicist. My principal function is the review of power reactor appli-cations, both at the construction permit and operating license stage, to determine the adequacy of proposed occupational radiation protection programs and the related efforts proposed to assure that occupational radiation exposure will be maintained as low as is reasonably achievable.

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,. I participate in the preparation and processing of NRC Safety Evaluation

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Reports in support of NRC licensing functions, pursuant to requirements of the Federal Regulations.

I am a member of the American Health Physics Society (National Chapter) and of the Baltimore-Washington Chapter (Local Chapter).

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

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

)

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

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF MOTION FOR

SUMMARY

DISPOSITION OF TIIE PERSONNEL EXPOSURE PORTION OF CONTEN-TION 4" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk, by deposit in the Nuclear Regulatory Com-mission's internal mail system, this 14th day of July,1986:

• Dr. Robert M. Lazo, Chairman Norman A. Coll, Esq.

Administrative Judge Steel, Hector & Davis Atomic Safety and Licensing Board 4000 Southeast Financial Center U.S. Nuclear Regulatory Commission Miami, FL 33131-2398 Washington, DC 20555

• Dr. Emmeth A. Luebke Administrative Judge

• Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555

• Dr. Richard F. Cole

• Atomic Safety and Licensing Administrative Judge Appeal Board Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555

• Docketing & Service Section Michael A. Bauser, Esq. Office of the Secretary Newman & lioltzinger, P.C. U.S. Nuclear Regulatory Commission 1615 L St. , NW Washington, DC 20555 Washington, DC 20036 Joette Lorion 7269 SW 54th Avenue Miami, FL 33143 L /

MitilLA/ Younir f g Counsel for NRC Staff v