ML20214S105

Affidavit of SA Brown Re 860728 Affidavit of Ps Miriello Concerning Radiation Exposure,Filed in Support of Motion to Reopen Record.Allegations Re Exposure to High Levels of Radiation Unsupported

ML20214S105
Person / Time
Site:	Harris
Issue date:	09/25/1986
From:	Brown S CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20214S087	List: ML20214S083 ML20214S105 ML20214S127
References
NUDOCS 8609290395
Download: ML20214S105 (7)

Text

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,y ENCLOSURE 3

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD l

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In the Matter of )

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CAROLINA POWER & LIGIIT COMPANY )

and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL j MUNICIPAL POWER AGENCY )

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1 (Shearon Harris Nuclear Power )

l Plant) )

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! AFFIDAVIT OF STEPHEN A. BROWNE l

] County of Wake )

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1 State of North Carolina )

l Stephen A. Browne, being duly sworn according to law, de-poses and says as follows:

1. I am employed by Carolina Power & Light Company j ("CP&L") at the Shearon Harris Energy & Environmental Center as a l

Project Specialist-Health Physics. In this position I am respon-l sible for the technical direction of the personnel dosimetry pro-gram for all CP&L nuclear plants. I testified before the Licens-

! ing Board on November 1, 1984. See " Applicants' Testimony of Stephen A. Browne in Response to Joint Contention IV i (Thermoluminescent Dosimeters)," ff. Tr. 6407. A description of my professional experience and qualifications is provided in that testimony.

2. I previously prepared an affidavit, dated May 6, 1986, which was filed with the Licensing Board in support of AD P fDR G

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" Applicants' Response to Request by CCNC and Wells Eddleman for Admission of New Contention WB-4 (Falsification of Exposure Records)," dated May 8, 1986. The same affidavit was filed with the Director, Office of Nuclear Reactor Regulation, in support of

" Applicants' Response to CASH's Show Cause Petition," dated August 15, 1986. I also prepared an affidavit, dated January 4, 1984, which was filed in support of Applicants' Motion for Sum-mary Disposition of Joint Intervenors' Contention IV.

3. In my May 6, 1986 affidavit I addressed Ms. Miriello's affidavit dated April 3, 1986, in which Ms. Miriello described her exposure to radiation at Brunswick on or about August 9, 1985. Ms. Miriello's April 3, 1986 affidavit was filed in sup-port of " Request by CCNC and Wells Eddleman for Admission of New Contention WB-4 (Falsification of Exposure Records)," dated April 22, 1986. My January 4, 1984 affidavit contains a detailed dis-cussion of the accuracy of thermoluminescent dosimeter ("TLD")

systems. These affidavits and their attachments fully describe the methods by which the exposure records of Ms. Miriello and all other CP&L personnel are generated and maintained, and the basis for having confidence in their accuracy. As stated in my May 6, 1986 affidavit, Ms. Miriello's exposure records indicate that 1

during the week of August 5 through August 9, 1985, Ms. Miriello -

l received a dose of 29 mrem as measured by her TLD. See May 6, 1986 Affidavit, 1 6, p. 4.

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4. The purpose of this affidavit is to report the results of my review of the Affidavit of Patty S. Miriello concerning ra-diation exposure, dated July 28, 1986 ("Miriello Rad. Exp. Affi-davit"), which has been filed with the Appeal Board in support of

" Motion to Reopen the Record Pursuant to 10 CFR 2.734 by Coali-tion for Alternatives to Shearon Harris, Wells Eddleman and Con-servation Council of North Carolina," dated September 15, 1986.

Nothing in the Miriello Rad. Exp. Affidavit gives me any reason to doubt the accuracy of the testimony I had submitted previous-ly. I therefore shall not readdress those issues presented in Ms. Miriello's July 28, 1986 affidavit that have already been addressed in my earlier affidavits.

5. Ms. Miriello discusses work at Brunswick with another technician in cleaning up spills (apparently on August 8, 1985),

and visitation of an unspecified area of the Brunswick plant with that technician the next day. It is noteworthy that the Miriello Rad. Exp. Affidavit does not specify: (1) the identity of the technician with whom she worked with the radioactive liquid and with whom she toured the allegedly unmarked area of high radia-tion; (2) the identity of the "CP&L health physics technician in charge"; (3) the location of the alleged spill; (4) the source or cause of the alleged spill; (5) the size of the alleged spill; and (6) the location of the unmarked area where she allegedly was exposed to high levels of radiation. With the notable exception of the dialogue between Ms. Miriello and the anonymous

V technician, Ms. Miriello's discussion of the events upon which her allegations are based is vague. Nevertheless, I have at-tempted to investigate available information in order to respond to Ms. Miriello's allegations.

6. During the week of August 5 through August 9, 1985, Ms.

Miriello was assigned to work with three other Health Physics Technicians at Brunswick. None of Ms. Miriello's coworkers re-ceived significant radiation exposure during that week. The pocket dosimeter c'ecdings (which are typically higher than the TLD readings) for the Health Physics Technicians who were on the same Radiation Work Permits ("RWPs") as Ms. Miriello for August 8, 1985 ranged from 0 to 30 mrem. Their pocket dosimeter readings for August 9, 1986 ranged from 0 to 10 mrem. CP&L main-tains spill tracking forms which are filed in the event of sig-nificant spills of radioactive liquids. There is no record of any such spills during the week of August 5, 1985. Moreover, there is no record of any reports of high radiation levels in any unmarked areas during the period in question. Finally, there is no evidence of any personnel exposure records, including those of Ms. Miriello, that would corroborate the high levels of radiation allegedly monitored by Ms. Miriello. Based on my investigation I find no evidence supporting Ms. Miriello's allegations.

7. Ms. Miriello states: "For about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> I and the other technician were within 1 to 3 feet of the spills of this radioactive liquid.... Near the end of the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> my throat was l

V burning." Miriello Rad. Exp. Affidavit, 1 4(A), p. 2. As stated above, there is no record of a spill during the week of August 5-9, 1985. Ms. Miriello was assigned to work in the Radwaste Drumming Room where there have been occasional periods during which water may be on the floor due to the processing of wet materials. However, cleaning up this water is a safe and simple task and exposure to such low level radioactivity would not cause one to experience a burning sensation in one's throat.

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8. Ms. Miriello states that she and another technician went "into an unposted high radiation area" where she and her coworker monitored radiation levels ranging from "several hundred millirem / hour" to "3000 to 5000 millirem / hour" for "15 to 30 minutes." Miriello Rad. Exp. Affidavit, 1 4 (B), pp. 3-4. The most plausible explanation for Ms. Miriello's allegation is that she and her coworker may have wandered into the lead shielded storage area of the Radwaste Drumming Room. The entire Radwaste Drumming Room is posted an a locked high radiation area. The shielded storage area of that room contained radioactive materi-als emitting 1 1/2 r/hr. general area to 7 r/hr. on contact based upon detailed daily surveys. If Ms. Miriello and her coworker wandered into that area they might monitor radioactive dose rates approaching those stated in the Miriello Rad. Exp. Affidavit, however, if they had remained in close proximity to the stored materials as long as she claims they did, their dosimeter readings would have been much higher than they were. I cannot be i

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4 certain that Ms. Miriello was in the Radwaste Drumming Room stor-age area; however, if she was, her allegation that she had entered an unmarked high radiation area was false as the Radwaste Drumming Room is a posted area. If, however, Ms. Miriello and her coworker were in an area other than that postulated above, then they may have been outside of their assigned RWP area in vi-olation of CP&L's procedures. In any event, if they had discov-ered an unmarked high radiation area as alleged, then they should have notified CP&L immediately. Their failure to do so would constitute a violation of CP&L's health physics practices.

9. As noted above, none of the individuals working under the same RWP's as Ms. Miriello experienced significant exposure to high levels of radiation. Indeed, the pocket dosimeter of the individual whom Ms. Miriello indicated as the person who had re-ceived similar levels of radiation exposure on August 9, 1985, only read 5 mrem on the morning of the 9th when the investigation of Ms. Miriello's exposure took place. If one were actually sub-jected to the levels of radiation alleged for the length of time alleged, that person would have a TLD readout exceeding 250 mrem.

Ms. Miriello only received 29 mrem during the time that she al-leges that she was in the unmarked high radiation area. It is therefore doubtful that Ms. Miriello's recollection of the event is accurate.

10. Finally, Ms. Miriello states: "I never saw the com-pleted form (attachment 1) until CP&L made it public." Miriello l

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Rad. Exp. Affidavit, 1 4(C), p. 4. The form to which Ms.

Miriello refers is the Personnel Exposure Investigation form which shows that Ms. Miriello's TLD readi.ng for the period from August 5 to August 9, 1985 was 29 ares. Alice Thompson recalls that the investigation form had been oospleted before Ms.

Miriello signed it in accordance with CP&L procedures. The form thus included the assigned dosimetry results when Ms. Miriello signed it. Nevertheless, CP&L se.nt Ms. Miriello her f ull expo-sure history on s+ptember 10, 1995, which included har TLD reading for the week of August 5-9, 1985. Agg May 6, 1986 Affi-davit, 1 10, p. 7. Hence, Ms. Miriello cannot claim that she was only recently apprised of her exposure history.

11. In conclusion, Ms. Miriello essentially alleges that she was exposed to high levels of radiation at the Brunswick Plant on or about Angust 9, 1995 and that CP&L altered her dosimetry records concerning that exposure. Based upon the facta presented above, I conclude that there is no basis supporting her allegations.

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Stirphen A. Browne and sworn to before me . . . . .

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