ML17340B278

Affidavit Supporting Contention 4B.Integrity of Loosely Stacked Drums of Low Level Radwaste Cannot Be Assured During Passage of Major Hurricane.Prof Qualifications Encl

ML17340B278
Person / Time
Site:	Turkey Point
Issue date:	05/11/1981
From:	Pardue L ONCAVAGE, M.
To:
Shared Package
ML17340B275	List: ML17340B274 ML17340B276 ML17340B277 ML17340B278 ML17340B279 ML17340B281
References
NUDOCS 8105290368
Download: ML17340B278 (10)

Text

~FFZDA iT OF L'OLLA Q.:~RDU"'XHlBlT D ON CONTi'ÃTj:ON 4 B

l. kQ name is Leonard Q. Pardue. address is I

641 Falcon a%venue, Miami Springs, Flor ida, 33166. statement of my prof'essional background and cualifications is attached to thi*s affidavit and made a part thereof.

2. This affidavit, addresses Conten ion 4 B which states:

There are likely to occur radioactive releases, (from the steam generator repair) to unrestricted areas which violate 10 CFR Part 20 or are not as low as reasonably achievable within the meaning of'0 CFR Part 50 as a result of' hurricane or tornado striking the site during the repairs.

3. The statistical probability of a major hurricane (categories 3, 4, or 5 on the Saffir/Simpson Eurricane Scale),. striking the

.Turkey Point area is 5 5 each year. This area is a 50 mile

'segment of the southeast Florida coast in which Turkey Point is located.

4. The Saifir/Simpson Hurricane Scale defines a category 3 hurricane as having a central pressure from 945 964:-millibars,

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winds from 111 130 mph, and a surge from 9 '12 feet; 4

a category 4 hurricane as having a central pressure from 920 944 millibars, winds from 131 155 mph, and a surge from 1S 18 feet; and 81 0 5 29 0 g

e category 5 hurricane as having a central pressure less than 920'illibars, winds greater than 155 mph, and a surge, greater than 18 5'eet.

5. Ninds generated during a category 5 hurricane can exceed 200 mph. The most recent category 5 hurricane to strike the

'United States was hurricane Camille in 1969.

6. Tornadoes can strike the Turkey Point plant as independant storms or they can be spawned from hurricanes.

7. On april 10, 1956, a tornado struck Florida Power and Light's Cutler power plant, located approximately 14 miles north of the Turkey Point plant. The reported estimated windspeed eras in excess of'00 mph.-

8 ~ 'sYinds generat ed during a tornado can exc e ed 300 mph, but

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the possibility of' tornado of'uch severity,'ccurring. in Southeast Florida, is remote.

9. A major hurricane can generate a storm surge 15 f'eet above mean sea level at the Turkey Point site.

10. Waves 6 - 8 Eeet high which are superimposed on the 15 foot storm surge can occur during a major hurricane at Turkey Point.

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11. Hurricane force winds will usually last t4, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at a location directly in the hurricane's path, but, if a hurricane were to stall over Turkey Point, the duration of burr'cane force winds would be extended.

12. On Sept, ember 5, 1950, Cedar Key, Florida experienced winds of 120 mph, intermittently, over a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. period.

13. For a location directly in the path of a hurricane, hurricane force winds can be expected to reverse airection 180 aegrees, as the storm passes.

14. Due to the flooding of the access roads and the isolated location of'e plant site, the National Hurricane Center would most likely advise that Turkey Point be evacuated at the approach of a major hurricane.

15. During the strike of a major hurricane, objects, such as loosely stacked drums, can be scattered by the hurricane and can receive mechanical shocks from collisions with other objects.

CONCLUSION During the passage of' major hurricane over the Turkey Point site, the integrity of'oosely stacked drums of low level radioactive waste cannot be assured. The scattering of these loosely stacked. drums can be expected.

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ZUBTE'H APZIANT SAY'"TH HOT Date:

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Leonard G. Fardue STAT'" 'OP FLORIDA )

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SPOBN t.o and subscribed before me this A day of May, 1981.

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STAT" Iv"""NT OF PROF'IONAL BACKGROUt'0 AND QUALIFICATIOfS ZZONARD G. PARD' am a f'ully oualified meteorologist. Following many years wi h the National:,Yeather Service, including 25 years in L>iami, Florida at the National Hurricane Center, I lef't the Government to enter private practice as a consultant. I have assisted many law f'irms and assistant state's attorneys and public defenders, appearing of'ten as an expert in Circuit Court and Federal District Court in Dade, Broward, Palm Beach, arid Lee Counties and '>'/ashington, D. C.

I entered the:leather Bureau at;montgomery, Alabama, serving also at other points in Alabama, Louisiana, and Florida.

Meanwhile I attended Spring Hill College at Mobile, Florida Southern College at Lakeland, Tu.lane University at New Orleans, and the University of Miami,. 2'ollowed by a year at the Graduate School of'eteorology at New York University, where I had been awarded a f'ull scholarship. Upon completing my I

year at NYU was assigned to Kiami. I have taught weather courses at, the 'University of'iami, FIorida 4 Zc Ef University, miami-Dade Community College, the Air Force Reserve, and adult evening high- school. For two years I was president of'he Museum of Science and Planetarium and now am president Friends of'hysics of'he University of'Miami. I have of'he been certif'ied as a consultant by the American Meteorological Society.

.During my private practice I have worked with attorneys in cases involving railroads, air lines, public utilities, aircraft manuf'acturers, municipalities, and the United States Government. I have been consulted by commodity traders, architects, engineers, and insurance companies.

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