ML17340B018

Affidavit in Support of Summary Disposition of Contention 2 Re Util Proposed Program for Controlling Occupational Exposure.Prof Qualifications Encl

ML17340B018
Person / Time
Site:	Turkey Point
Issue date:	04/09/1981
From:	Story H NUCLEAR POWER RESOURCES, INC.
To:
Shared Package
ML17340B017	List: ML17340B016 ML17340B018 ML17340B019
References
ISSUANCES-SP, NUDOCS 8104220555
Download: ML17340B018 (68)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE. ATOMIC SAFETY AND LICENSING. BOARD In the Matter of ) Docket Nos. 50-250-SP

)' 50-25 I-SP FLORIDA POWER & LIGHT COMPANY

) (Proposed Amendments to (Turkey Point Nuclear ) Facility Operating License to Generating Unit Nos. 3 and 4) ) Permit Steam Generator Repairs)

AFFIDAVITOF HARVEY F. STORY ON CONTENTION 2 My name is Harvey F. Story. My business address is 6040 S.W. 82 Avenue, Miami, Florida 33I43. I am a certified Health Physicist and President of Nuclear Power Resources, Inc. A statement of my professional backgraund and qualifications is attached.to this testimony.

I was employed by Florida Power Bc Light Company (FPL) from September, I 970 until March 3 I, l98 I. During the last five years, I was the Corporate Health Physicist. I am familiar with the programs and procedures to.be followed by FPL during the repairs in order to maintain occupational radiation exposures as low as is reasonably achievable and the measures which will be taken to limit individual exposures within regulatory limits.

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This affidavit addresses Contention 2 which states:

A. The programs and procedures proposed to be followed by the Licensee in making the steam generator repairs demonstrate that it will'not make every reasonable effort to maintain occupational radiation exposures as low as is reasonably achievable (ALARA)within the meaning of IO CFR Part 20 or that it will not comply with IO CFR 20. IOI, in that the Licensee'intends to. use transient workers with unknown radiation exposure histories.,

B. A sufficient work force, both skilled and unskilled cannot

'be obtained to perform the repairs without violating the lirriits on individual exposures contained in IO CFR 20. I 0 I.

This affidavit is divided.into"two parts. The'first part demonstrates. that FPLs proposed program for controlling occupational exposures to radiation satisfies the ALARAprinciple. The second part'emonstrates that FPL's procedures for transient workers complies with IO CFR Part 20.

Maintainin Ex osures ALARA IO'CFR 20. I(c) requires licensees to make every reasonable effort to maintain radiation exposures as low as is reasonably achievable (ALARA).

FPL is committed to the ALARAprincipl'e. Independently of the repairs, FPL has established an extensive Health Physics Program. The Florida Power &

Light Company Health Physics Manual contains the radiation protection policies of the Florida Power & Light Company Health Physics Program, The manual has been-prepared by the Power Resources Department Nuclear Staff of FPL to describe the requirements and procedures for implementing a program for maintaining occupational exposure to ionizing radiation as low as is reasonably achievable. The plant staffs, with support and review by the Corporate Health

.Physics Staff, have written over 50 detailed procedures-covering all aspects of the program. This Health Physics Program will be utilized during the repair.

IO 'I ,K The bases for the Health Physics Manual are the requirements and recommendations set forth by the following documents and/or agencies:

Title IO, Code of Federal Regulations (IO CFR Parts I9 & 20)

Chapter IOD-56, Control of Radiation Hazards, State of Florida National Council on Radiation Protection and Measurements (NCRP)

International Commission on Radiation Protection (ICRP)

International Commission on Radiation Units and-Measurements (ICRU) international Atomic Energy Agency (IAEA)

NRC Regulatory Guides 8.8 and 8. I 0 It should be stressed that the Steam Generator Repair Project (SGRP) does not involve any new concepts or problems from the standpoint of health physics.

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Additionally, it should be noted that the majority of the repair operations will'occur'n relatively low radiation areas, (IO-50 mrem/hr). However, the following represent the principal work operations which will require some people to work in high radiation areas

(~ IOO mrem/hr whole-body dose rate):

I) Removal of the existing steam generator manway covers, installation of the reactor coolant pipe nozzle inflatable seals, and installation of the temporary manway covers, all of which are required prior to decontamination of the steam generator channel heads.

2) Cutting of the steam generator in the transition cone area and fit-up of the tube bundle cover plates for the existing steam generators.

3) Cutting and welding of the existing steam generator at the

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channel head area just below the tubesheet.

4). Fit-up of the existing steam generator lower assembly tubesheet cover plates.

Although the dose rates estimated for .the above work operations are not insignificant, many FPL projects, such as replacing reactor coolant pump seals, have required work in areas of high radiation fields, and have been successfully performed frequently in the past.

In short, FPL's normal 'Health Physics Program will be adequate for the repairs.

Experience gained in past projects has been and will be used to ensure that all necessary precautions will be taken during the repairs to guarantee that. the purpose of ALARA is fully satisfied.

FPL's Health Physics Program, together with dose-reduction measures planned for

'he repairs, 'is described in detail below.* .

A. -

Mana ement Commitment Current Pro ram One of the most important aspects of any health physics program is the commitment to the ALARA'principle by management. The following is a brief statement of the corporate radiation protection policy, quoted from the Health Physics Manual:

The operation and maintenance of a nuclear power plant requires that some personnel be exposed to an environment of ionizing radiation. Doses received under 'limits recommended'by the National Commission on, Radiation Protection (NCRP) and those adopted by the NRC involve a risk that is small as compared to every day hazards of life.

Nevertheless, every effort should be made to reduce the exposure from ionizing radiation to the lowest level that is reasonably achievable.

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The organization, practices, and procedures described below reflect the extent of that commitment.

Steam Generator Re air Pro am

.FPL personnel were assigned to the Surry steam, generator repair. Persons employed'by. FPL participated in, observed, and

'I analyzed the Surry Units I'nd 2 steam generator removal and replacement projects.. These individuals represented various FPL departments and have provided FPL with valyable information

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in such areas as Quality Assurance, Construction, Health Physics, Project Management, Engineering, Plant Operations for the Turkey Point steam generator replacement planning and scheduling effort.

FPL Plant Health Physics technicians and supervisors who will be responsible for health physics operations, training and administration at Turkey Point, spent more than a week at the Surry 2 repair. They made observations and received valuable information on such things as logistics of health physics processing and training,.

dosimetry control, man-rem evaluations, shielding requirements and decontaminating operations. Health Physics plant technicians, supervisors and Health Physics staff personnel also spent about a week at the Surry I repair project.

Another example of FPL Management's commitment to'the ALARAprogram is the use of an on-site mini-computer system to provide real-time accumulation of personnel exposures for more accurate and timely analysis and evaluation of man-rem data during the steam generator project. 1

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3. Conclusion.

In short, FPL Management is committed to the extensive Health Physics Program that is designed to meet the corporate radiation protection policy and to ensure full compliance with the intent of the applicable NRC regulations and guidelines, including the ALARAphilosophy..lt should be pointed out again that this is not a new or one time program set up for the steam generator repair project. The program, the commitment. to it, and all the requirements and reasons for it have existed since FPL entered the nuclear industry, and will be used to complete safely the steam generator repairs.,

B. Or anization I .. Current Pr'o ram The Corporate Health Physicist establishes the corporate radiation protection policy and program, and is also responsible for ensuring that the. ALARAprinciple is implemented., The Staff ALARA Specialists primary responsibility, under the direction of th'e Corporate Health Physicist, is to develop,~review, and upgrade the ALARA program in accordance with regulatory guidance. The Health Physics Supervisor at each plant is responsible for

,establishing detailed radiation protection procedures at the plant and is responsible for maintaining. exposures ALARA. The present complement of Plant Health Physics personnel is thirty-seven. The average health physics experience for health physics supervisors and health physics operational personnel is over ten years. The plant ALARA engineer s primary responsibility, under the direction. of the

i 0 Health Physics Supervisor, is to ensure that ALARApractices are I

implemented in all areas of plant operations and maintenance. Plant health physics personnel have the authority to stop a job in progress if they feel unsafe work practices are being followed.

The Health Physics Supervisor at. each,plant'has a direct line of communication to the Plant Manager and the Corporate Health Physicist, who in turn reports to the Manager'of Power Resources Nuclear Services. The Manager of Power Resources Nuclear Services reports to the Manager of Power Resources - Nuclear, who, is responsible for all matters concerning the-operation and maintenance of FPL's nuclear plants. Those who are responsible for FPL's Health Physics Program have sufficient, access to management, on both a corporate and plant. basis, to ensure that the ALARAprinciple is implemented.

Steam Generator Re air Pro ram

~ The individual responsible for supervising and coordinating the Health Physics Program for the repair project is the steam generator repair health physics supervisor (SGR-HPS). He reports to the Health Physics Supervisor and is assigned full-time to the project. He will have approximately seven supervisory and three technical personnel reporting to him for the project..ln addition, there will'e at least sixty Health Physics Technicians (contract Health Physi'cs Technicians) assigned to the project.

In addition to the Health Physics Shift, Supervisors assigned to him for the repair, the SGR-HPS will be supported by the ALARA Engineer, the ALARA Technician, and the Rad-Waste Supervisor.

He will also receive routine review and assistance from the Plant

i Health Physics Supervisor and the Corporate Health Physicist.

3. Conclusion The FPL health physics organization is designed to ensure that the Health Physics Program,.including the ALARAconcept, is properl'y implemented. FPL believes that its current policy and current organization, expanded for the project, are appropriate and sufficient for application to the steam generator repair project.

~Trainin I. Current Pro ram All unescorted personnel working in the Radiation Controlled Area (RCA) are required to attend an approximately twenty-hour Radiation Protection Training Course which covers in detail, the basic theory and,practice of radiation protection principles, emergency planning, and FPL's radiological protection program. The course includes lectures, films, practical demonstrations, and other material. Additionally, all such personnel are. required to take a comprehensive written examination and to pass it with a grade of 70% or greater in order to receive an unescorted access badge,

'hich allows them to enter the RCA without an escort. Personnel who pass the examination must be reexamined; every two years (with .

a six month grace period) in order to retain their unescorted access badge. Individuals who score between 55% an'd 70% on the health physics exam are required to repeat the course and pass the exam prior to working in the. Radiation Controlled Area. Any individual who scores less than 55% is excluded from the',RCA and is not permitted to retake the exam until the Health,'Physics Supervisor has determined that a reasonable time has elapsed. Individuals with

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'9-prior nuclear experience may waive part or all of the twenty-hour course at the discretion of the Health Physics Supervisor but are required to pass the comprehensive examination.

In special cases. in which an individual with unique skills is required to work in the Radiation Controlled Area, the Health Physics Supervisor. may waive any of the above requirements if he establishes alternate contr'ol measures. These may include continuous escort control with a trained escort assigned to each individual or group of individuals. Similarly, visitors and non-radiation workers (personnel who normally work outside the RCA) are required to be escorted while in the Radiation Controlled Area.

A full-seal'e mock-up of the steam generator channel head has'een used for the past one and one-half years to train personnel for working on and in the channel head.

2. Steam Generator Re ai'r Pro ram Additional facilities are being prepared for essentially continuous training activities. The steam generator repair.

operations will be emphasized in the training program by pointing out special considerations in the repair'effort., The steam generator channel head mock-up and the various scale models (see description under D.2. below) will be used extensively for training.

3. Conclusion FPL has an extensive, proven radiation protectio'n,training program in operation which will be geared toward the steam

'generator repair to ensure that all personnel working in the Radiation Controlled Area will be adequately trained.

Oi i I Task Plannin I. Current Pro ram All activities in the Radiation Controlled Area are evaluated for dose-rates or estimated man-rem and are, performed pursuant to a Radiation Work Permit (RWP). Activities which entail significant exposure (e.g. 50'mr/hr whole body exposure. rates) are preplanned.

Activities for which whole-body exposure rates are expected to be 50 mr/hr will be analyzed for man-power planning and estimated man-rem. 50 mr/hr is a guideline number that, based on experience, may cause accumulation-of significant man-rem. Areas less than 50 mr/hr may be looked at if the activity requires a large expenditure of man-hours. If a particular activity is estimated to produce greater than I'-2 man-rem of exposure it will be evaluated further to determine if effective action can be taken to reduce the occupational exposure associated with that activity. 'Such action, if taken, may consist of any or all of the following:

Temporary Shielding Decontamination Mock-up Training Dry Runs Equipment Modification As part of the evalucition and implementation of necessary ALARA actions, a RWP is written which specifies the following:

a. Description of the Task

b. Radiological Conditions Radiation levels Contamination levels Airborne contamination levels

c. Protective Clothing Requirements Type and quantities

Qi Monitoring Requirements Any special personnel monitoring

.such as'extremity badges, neutron badges, etc.

Portable survey instruments required to'monitor general radiation levels Special or periodic surveys by Health Physics personnel.

e. Special Considerations Decontamination required Special shielding required Containment of radioactive materials Special notifications The RWP is posted at the entrance to the Radiation Controlled Area and at the entrace to the job location.

In addition to the use of Radiation Work Permits, it is FPL s practice to provide periodic coverage by health physics personnel for all work in the Radiation Controlled Area. Continuous health physics coverage is provided for those activiti'es which present the potential for significant radiation exposures. An example would be steam generator channel head entry.

Steam Generator Re air Pro am The majority of work activities associated with the repair effort will be accomplished by utilizing standard construction practices. Nevertheless, FPL will employ several planning aids to facilitate performance of the activities and to reduce occupational exposures.

The full-scale mock-up of the steam generator channel head will be utilized for the purpose of training personnel in removal of

Ql i the steam generator manway covers,, installation of temporary manway covers required for channel'head decontamination, and ~

cutting of the channel head divider plate.

Additionally, a 8' I '0" scale model of the Unit 4 containment and major component internals, and the Unit 3 containment in the area of the equipment hatch, and a O' I'0" scale model of the steam generator and internals have been constructed. The containment model is a yaluable.tool in determining occupational radiation exposure and'studying methods.

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- for reducing doses. For example, the model will serve the following purposes:,

a. ~Shieldin The model, in conjunction with actual field survey data, can be used to study radiation fields to assist in determining temporary shielding requirements.

b. Man-Rem Assessment The model has been an aid in predicting the expected man-rem doses for activities in high radiation areas. Decisions related to radiation exposure, such as employing local decontamination or determining the number of people required for an activity, can be made early in the design phase of the project in order to incorporate the most effective solutions to the reduction of exposures.

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4l 4i co Craft Trainin The model can be used for the orientation and training of supervisory-and key craf t personnel .to supplement construction work plans, to achieve the most, efficient utilization of manpower in high radiation areas, and. to.reduce overall'man-rem doses by minimizing the time spent in these high radiatiori areas.

The containment model, the steam generator channel head mock-up, and the steam. generator internals model have been used.to develop construction work plans. For example, these plans consist

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of. the organization of task activities, methods of movement and .

operation of equipment, and other procedural steps to provide efficient use of manpower and to ensure that occupational exposures are maintained ALARA. Mast of the activities associated with the repair have been preplanned with ALARA considerations taken into account. This includes projecting man-hours-and man-rem for each task. FPL Health Physics preplanning has been, underway since 1977. For example, the steam generators will be filled with water on the secondary side and will not be drained until immediately before the channel head cut. The water in the filled steam generator will provide shielding for the workers from the radiation inside the steam generator. Finally, when beneficial, post-

~i operational debriefings will be used for activities involving major radiation exposure'to utilize the experience gained during the activities for planning future tasks.

3. Conclusion Preplanning for routine and special activities has always been an FPL operating philosophy and is necessary to provide for an efficient, organized, and safe operation. This necessary planning is expanded and emphasized for the steam generator repair project.

Administrative Controls Current Pro ram

a. Access Control Security personnel and Health Physics technicians control access to the Radiation Controlled Area (RCA) and to the containment, where individuals are checked for access requirements. Daily pocket dosimeter readouts of individual radiation exposures and compliance with existing plant health physics administrative procedures are used to limit access to the Radiation Controlled Area and containment building only to those individuals who have little potential for exceeding their weekly, quarterly, or yearly FPL radiation exposure guidelines. Those guidelines are themselves more stringent than the NRC established radiation exposure limits. A computer output indicates individuals that are very near or at administrative exposure limits. Additionally, individuals are checked for accumulated dose on pocket dosimeters when leaving the containment, and when leaving the RCA.

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b. Protective Clothing

'he fundamental purpose of radiological protective clothing is to provide.a barrier between contamination existing in a work area and personnel who enter the area'. All persons working with radioactive material where contamination of the person is possible are required to wear protective clothing appropriate to the work involved, as stated in the Radiation Work Permit. Such clothing provides protection against loose contamination. 'dditional protective clothing may be required for highly contaminated areas. In order to reduce the spread of contamination, the outer set-of protective clothing will be removed when leaving the work area:and deposited in a container. The final set will be removed in a designated area outside the containment and also deposited in a container.

co Respiratory Protection Equipment Under normal working conditions, airborne radioactive material concentrations are controlled by engineering measures, such. as enclosures or confinement and the ventilation and filtering of work areas. Respiratory

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protection equipment is used when effective engineering control measures are not feasible or cannot be applied.

All activitie's in the Radiation Controlled Area are evaluated for potential or existing radioactive airborne contamination. Respiratory protection. equipment is individually assigned to qualified persons by Health Physics as needed and is specified on the Radiation Work Permit.

Individuals who wear respirators are trained in their use and fitted in a test atmosphere to ensure a proper seal prior to working in a.radiological atmosphere requiring such controls. They must also pass a physical before they are considered qualified to wear a respirator.

Low Background Waiting Areas Proper planning and scheduling of work activities in relatively high radiation areas is required to ensure that workers in these areas receive prompt support in order to accomplish their tasks in the least amount of time possible and t'o maintain occupational exposures as low as is reasonably achievable. Since these tasks involve work in relatively high radiation areas, it is not, desirable to allow support personnel to remain in these areas for appreciable lengths of time. Consequently, support personnel will remain in low background waiting'areas, or relatively low radiation.

areas, until needed.

, The low background waiting area is based upon the criterion that the radiation field within the area is no.greater than a designated Zone III (equal to or less than I5 mr/hr).

Low background waiting areas are not established outside of the containment because of the requirement that workers remove their protective clothing when leaving the containment.

Low background waiting areas are established by the Turkey Point Health Physics staff based on radiation surveys taken periodically by Health Physics personnel. Signs are

posted in various, areas of the containment buildings t'o specify those areas designated as low backgrourid waiting areas. Signs are-also used to warn personnel of high radiation areas in the containment, as required by FPL's health physics procedures. Health physics'personnel work with the job supervisors so that personnel not required immediately in the work area remain in a.low background waiting area.

Steam Generator Re air Pro ram

a. 'ccess Control The following is'a brief description of the access control pathway currently contemplated for entering and exiting the containment:

I Personnel will enter the locker area, disrobe, and, after proceeding through the radiation control point, pick up their protective clothing in a connecting area and dress before entering the equipment hatch into the containment.

Personnel leaving the containment will remove their rubber shoe covers and rubber gloves at an access control, point. just outside, the equipment hatch before stepping onto the step-off pad.

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These personnel will immediately proceed to

..the undressing area to undress and be frisked for residual contamination. They will then exit through the radiation contr'ol point and return to the locker area for their street clothes.

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Access control by Health Physics personnel will be provided at the radiation control point and the. equipment hatch. Additionally, access will be,restricted'to "contaminated areas" and high radiation areas. The contaminated area is defined as that area where transferable.

beta-gamma contamination is greater .than or equal to l000 dpm/l00 cm2 averaged over a major portion of the area. A" high radiation area is defined as any. area accessible to

.personnel, in which there exists radiation at such levels that a major portion of the body could receive in any one hour a dose in. excess of l00 mrem.- Entry into contaminated areas or high radiation areas is subject to control procedures established by Health Physics and the Nuclear Plant Supervisor. Those areas are either barricaded or posted and an.RWP is. required for entry.

b. Protective Clothing The requirements for protective clothing during the steam generator repair will be the same as the existing program. The-containment will be decontaminated (see

'ection I.H.2 of this affidavit) resulting in decreased need for protective clothing in some areas.

co Respiratory Protection Equipment Personnel in the containment during the repair will

~ 'wear respiratory protection equipment. when necessary.

However, most of the workers inside the containment during the repair will have no need to wear respiratory protection equipment, since the airborne concentrations to which they

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will'be exposed are expected to'be insignificant. Only one activity during the repairs,'utting of the channel head, is anticipated to produce significant levels of airborne concentrations. Airbor'ne activity generated by cutting of the head will be contained within the contamination 'hannel control envelopes, as described in Section I.i ~infra and

,workers inside these envelopes during these operations will wear respiratory protection equipment: commensurate with airborne concentrations as determined'by. sampling and monitoring. Similarly, workers involved in removing contaminated nonmetallic insulation will also wear respiratory protection equipment. Since experience at the plant indicates that containment airborne radioactivity does not show a measurable increase, except locally, during insulation removal, other workers in the containment will not

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need to wear respirators to protect against the airborne activity produced by removal of the insulation. It is normal practice to wet this insulation just prior to removal which reduces the amount of material becoming airborne.

Other activities in the containment during the repair, such as cutting and removal. of concrete, are not expected to produce significant levels of airborne activity. Nevertheless, airborne radioactivity inside containment during the steam generator repair effort will be controlled, monitored and ultimately released via the plant vent stack.

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d. Low Background Waiting Areas Low background areas already established for previous shutdowns will be used for the steam generator repair.

Additional low background areas may be established as needed during the progress of the repair project.

F. Monitorin Relevant to Maintainin Occu ational Ex osures ALARA Current Pro ram In order to implement the Health Physics program and maintain exposures ALARA, the presence of radiation and contamination levels must be detected and measured.

The personnel monitoring program tracks both external and internal exposures. For internal exposures, airborne activity is monitored to ensure that proper respiratory protection is provided when needed and to account for potential inhalation of radioacti'vity. Additionally, a bioassay program, including whole body counts, is used to audit internal doses to personnel. The Respiratory Protection Manual and implementing procedures further amplify the instructions in the Health Physics Manual.

For external monitoring, Thermo-Luminescent Dosimeters (TLDs) are used and processed at least monthly. or whenever an administrative limit is approached. The program provides for special neutron TLDs whenever the possibility of neutron exposure exists. (Due to the removal of all fuel from the reactor vessel and containment, neutron exposure will not be a factor in the Steam Generator Repair Project.) The Health Physics Manual specifically discusses the use of additional TLDs to provide backup monitoring of

4k the extremities. For instance,.depending on dose rates, wrist TLDs are utilized to ensure that exposures to the extremeties (hand and forearms) are properly monitored.

tn addition to the TLDs worn by all personnel entering the Radiation Controlled Area, all personnel will also carry self reading pocket ionization chambers (pocket dosimeters). These devices can be quickly and easily read by the individual simply by looking into the-device while pointing it at a light. This allows the individual, his supervisor, or Health Physics personnel to determine his exposure at any given time. These devices are read and the individuals exposures recorded'at the completion of a work period, or at least daily, to provide assurance that applicable limits are not exceeded.

FPL's Health Physics Program specifically provides for using, the total of the latest TLD reading and the recorded pocket dosimeter readings to track accumulated exposure for the period of interest (day, week, quarter and year) to ensure that no exposure limits are exceeded. Pocket dosimeter readings are recorded at the exit to the Radiation Controlled Area for specific jobs. These numbers can then be used to determine if total exposures on a task are excessive and ensure that the ALARA concept is met for both individual and total man-rem. It is an'NRC and corporate 'xposure requirement that detailed records of all these monitoring'programs be maintained and that all personnel receive cumulative exposure information upon termihation of employment.

Additional. protection for the workers will be provided by the plant monitoring system. Plant monitoring refers to detection and measurement. of radiation and contamination in and around the

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plant. Part of the plant monitoring is performed automatically by the Area Radiation Monitoring Syst'ems (ARMS). The ARMS consists of radiation monitors with indication and alarm capabilities located strategically throughout the plant. The ARMS provides continuous monitoring with alarms to give early indication of changes in local radiation levels. Additional radiation, contamination, and airborne activity surveys are performed throughout the plant. The frequency of these surveys depends on the potential for changes in radiological conditions and the personnel occupancy. Finally, continuous Health Physics monitoring of areas with a high potential for changing radiological conditions is provided.

ln addition to various regularly scheduled surveys within the

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Radiation Control Area (RCA), surveys are regularly performed in areas outside the RCA to verify the effectiveness of the Health Physics Program designed to control and contain radiation and contamination. TLDs are strategically located both inside and outside the generating station area and are periodically replaced and measured dose determined to ensure the program is working properly.

It should be stressed that the monitoring procedures described above are normal practices required by regulations, and they are not special programs implemented just for the Steam Generator Repair Project. This monitoring program has been in existence and tested for effectiveness over a period of years, and FPL believes the monitoring program is satisfactory.

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2. Steam Generator Re air Pro am An adequate number of TLD reading machines, TLDs, and pocket dosimeters will be available for the repair project; additionally one or two whole-body counters will be used. As indicated above, a new computer will provide real-time exposure tracking capability.

Use of Automatic Toolin Current Pro am Automatic tooling is continuously evaluated, improved and implemented where applicable. For example the positioning tool for steam generator tube testing has.been modified to require fewer steam generator entries for manuvering. In addition, the electronic monitoring equipment has been moved outside the containment to a remote trailer for remote test monitoring, using closed circuit television.

2. Steam Generator Re ir Pro am Automatic tooling will be utilized to the maximum extent practicable to:

a. Reduce the manhours required to perform a special task, and/or b.'llow the workers to be further away from the radiation source, and/or

c. Allow the workers to remain behind a shield while the task is being performed by an automatic device.

The state-of-the-art for remote cutting and welding apparatus is continuously changing throughout the industry. The

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developments in the field will be followed, and selection of such tools for use during the steam generator repair project will be made at a time consistent with supporting the repair outage. These tools and techniques will be evaluated using the following,considerations:

Manhours required to set up the equipment.

b. Manhours-required to perform the task

c. Experience with the use of the proposed equipment.

d. Cost and schedule impact associated with development of the equipment.

e. Space limitations within the steam generator cubicles inside the containment building.

For example, an automatic, track-mounted oxy-acetylene torch assembly may be utili'zed for making the steam generator channel head and upper girth cuts. Track-mounted, automatic milling machines may be utilized for making the channel head and upper girth cut end-weld preparations. Track-mounted, automatic/combination. cutting/weld prep machines may be utilized for removing sections of the main steam and feedwater piping~

track-mounted, automatic welding machines may be utilized for re-welding these previously removed portions of main steam and feedwater piping.

All of the above techniques and tooling devices, which are currently available in the industry, will be evaluated using the above mentioned considerations. Any new developments in the field will be followed and selected at a time consistent with:supporting the repair outage.

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-4 Decontamination Current Pro am II Decontamination of local or general areas and equipment is a current and continual practice. Decontamination processes are used,

.primarily to reduce transferable contamination levels but also are used in removing fixed contamination to reduce radiation levels.

The frequency of decontamination is highly dependent on the accessibility and use of the area and/or the specific work to be

'erformed. Several reasons. for decontamination are:

a. mihimize the potential for personnel contamination

b. reduce the need to use additional protective clothing co reduce the potential of airborne contamination

d. reduce the amount of radioactive waste generated

e. lower and/or control contamination and radiation levels to confined areas release or reuse tools arid equipment which have been contaminated The need to decontaminate is. reviewed on the basis of ALARA effectiveness.

2. Steam Generator Re ir Pro am To.lessen the total man-rem accumulated,,a general decontamination of the containment'is planned during the initial phases of the steam generator, repair. This operation consists of cleaning most of the exposed surfaces of the containment in the areas where work tasks in support of the steam generator repair are

4> 4i scheduled. The removal of a significant portion of the slightly radioactive surface dust and dirt from such areas has two beneficial effects: I) the overall background radiation level. is lowered in those areas due to removal of a significant contributing source; hence exposure of the work force during the remainder of the outage is reduced; and 2) the spread of transferable surface contamination is significantly reduced, so clean areas remain clean and the incidence of contamination of workers in such areas is greatly lessened.

In the channel cut approach, some decontamination of the channel head region of the steam generators would be advantageous in maintaining exposures to a minimum. Consequently, interior surfaces of the channel head and divider plate will probably be decontaminated.

Finally, local work areas will be monitored for contamination on a periodic basis and will'be decontaminated as necessary. It may be necessary to stop work activities to decontaminate areas for reasons stated under Section H.l., above.

Use of Contamination Control Envelo s Current Pro am When specific activities dictate, localized envelopes or enclosures are utilized to contain airborne particulates generated during cutting, weld preparation, welding activities, and any other activities that generate radioactive airborne contamination.

2. Steam Generator Re air Pro am It is anticipated that localized envelopes will be required for the steam generator channel head w'ork. Enclosures have been designed to

accomodate the work operations'in these areas. However, it is not anticipated at. this time that I'ocalized envelopes will be required for cutting, weld preparation, and welding on the steam:generator 'upper assemblies, because the contamination levels are so low that they should I

not present an airborne contamination problem.

The design of the contamination control envelopes consists of galvanized steel enclosure structures (one for each steam generator channel head area) which makes.use of existing concrete walls where practicable. Each enclosure structure has two (2) windows, a ventilation inl'et with roughing filer, and a double door access area. The structures will be joined to the concrete walls and steam generators by angle irons and sealed with an air setting sealing compound for relative air tightness.

Each enclosure has a roughing air inlet filter.which will provide make-up air to satisfy the exhausted air flow requirements. This inlet air will be ambient air coming in from. the equipment and. personnel hatches.

The first of.'both doors associated with each enclosure allows personnel entrance into a vestibule area. The second door allows entrance into the enclosure itself. Each enclosure has been designed to operate at, a continuous negative air pressure. Therefore, any momentary opening of either door allows air to rush into the enclosure assuring that there is no release of enclosure.air except through the designed, filter exhaust system.

Each enclosure is exhausted in parallel to the filter exhaust unit.

This unit is a combined. base-mounted unit, will be located in an area adjacent to the three steam generators, and consistsIbasically of pre-filters (30-60 per cent efficient),, HEPA filters (99.97 per cent efficient), and'an exhaust fan.'ischarge of the filtered air will be to the existi'ng plant purge exhause system which will be operating continuously.

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4l The filt'er exhaust unit has been designed so that isolation of one enclosure does not defeat exhaust capabilities of the others. Pressure drops across the pre-filters and accross the HEPA filters will be separately monitored to determine replacement needs.

Finally, it should be noted that the contamination control envelopes will be monitored.

Use of Shieldin Current Pro am Temporary shielding is used in FPL's Health Physics Program. However, the use of, such shielding involves trade-offs.

For example, installing two inches of temporary lead ~

shielding around component "X" will generally reduce the dose rate at adjacent work location "Y'rom I rem/hour to only O.l Thus, for a 2 man, 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> job at "Y', the exposure could

'em/hour.

be cut from 6 man-rem to .6 man-rem. However, it should also be noted that one 4" by 8" by 2" thick lead brick weighs about 30 pounds. Installing and removing lead bricks requires the expenditure of both man-hours and man-rem. Obviously, installing a dozen bricks on a small hot spot would probably be ALARA effective.. Just as'obviously, installing several thousand bricks probably would not, since the man-rem incurred by installing and removing the lead brick shield would probably exceed the man rem savings which result from the lower radiation fields. Most cases involving temporary shielding fall.somewhere between these two extremes.

Lead brick, lead sheet and various sizes of iron plate are available and have been used frequently'n the existing program to reduce dose rates. For example, during a previous modification of

the steam generator internals, lead blankets were placed around the tube bundle to reduce dose rates.

2. Steam Generator Re air Pro am For the activities associated with the repair, the need for temporary shielding will be determined on a case by case basis. This determination will include a consideration of the estimated exposure that would be received by personnel performing the installation and the removal of the shielding and the estimated exposure to be received for the job to be performed without the use of shielding.

Also taken into account in evaluating the need for temporary shielding will be the dose rate, the time required to install and remove the temporary shielding, and weight and space limitations.

If it is determined that installation of temporary shielding is ALARA, the type and amount of shielding will be, determined by Health Physics personnel.

ln general during the repairs, temporary shielding will be used, as necessary, to reduce the dose rates from components such as the reactor coolant pumps and reactor coolant piping. Although the steam generator shell, cover plates, and secondary coolant will provide some shielding for activities performed outside the steam generators, temporary shielding will also be used, as necessary, inside the channel-head while it is being prepared for fit-up to the new steam generator section.

K. Conclusion FPL's Health Physics Program embodies all of the principles

.inherent in a good radiation protection program. Administrative controls

41 ~,

will be combined with training, the proper equipment and facilities, dose reduction techniques such as shielding and decontamination, and competent and qualified Health'Physics personnel for the purpose of maintaining occupational exposures ALARA during the repairs.

Transient Workers Contention 2 also questions whether FPL's procedures regarding transient workers will comply with IO CFR Part 20..

The concern expressed in this part of the contention arose from the I

promulgation of a rule regarding occupational exposures of transient workers at 44 Fed. Reg. 32349 (June 6, I 979). See Dr. Paris opinion, Ordering Ruling on the Petition, of Mark P. Oncavage (August 3, .I 979), pp. 46-47. This rule establishes the foll'owing relevant requirements:

A licensee may not allow a transient worker to enter into a restricted area in which the individual is likely to receive an 0

occupational exposure in excess of 25% of the standards of IO CFR

20. IOI(a), unless the individual first supplies a written statement disclosing his prior occupational exposure for the current calendar quarter.

2) A licensee may not, allow a transient worker .to receive an occupational exposure in excess of the standards of IO CFR

20. I0 I(a), unless a licensee first obtains a certificate on Form NRC-4,.

3) A licensee may not allow a transient worker to exceed the standards in IO CFR 20.IOI(a) for all sources of occupational exposure, including sources other than the licensee's.

The wording of IO'CFR 20.IOI, before its amendment at 44 Fed. Reg.

4i

-3.1'-

32349, left a possibility that a worker employed by two or more companies in the same quarter could receive the dose limit of l.25 rem (3 rem if certain conditions are met) from each. of the companies involved. Thus, an individual could, consistent with the wording of the regulation, receive more than the prescribed limiting exposure. The regulation has now been reworded to eliminate the possibility.

FPL would expect to be use some transient workers for the repairs.

Consequently, the. new. rule on transient workers will undoubtedly apply to at least som'e of the manual workers employed during the repairs. However, the new rule is academic as far as FPL's practices are concerned. It has long been the policy of FPL to ensure that total occupational exposure, whether received at FPL or

'elsewhere, is maintained at or below the applicable limits.

It is FPL's practice to limit all radiation workers to a maximum exposure of 250 mrem/quarter until their current radiation exposure history for the quarter is known., tn addition to the quarterly history, every reasonable effort is expended to assure that the information projected in the individuals completed NRC Form 4 document is complete and accurate. No worker is allowed to receive more than I I 00 mrem/quarter until his lifetime exposure history is known. The maximum accumulated quarterly exposure that FPL allows any individual has always been less than established federal limits.

III. Conclusion As demonstrated above, FPL's Heal th Physics Program for the repairs complies with the ALARAprinciple and FPL's procedures for handling transient workers satisfies IO CFR Part 20.

Ql 0

FURTHER AFFIANT SAYETH NOT.

Dafe tory STATE OF FLORIDA )

) SS.

COUNTY OF DADE )

SWORN to and subscribed before.me this day-I 98 I.

otary blic My Commission Expires:

f<otery Public. Stats of riorfds t Lergo My Commission Expires October 30, 1983 Bonded thru Maynerd Bonding Agency

0 0 1 STATEMENT OF PROFESSIONAL, QUALIFICATIONS Harvey F. Story Present Certified Health Physicist President, Nuclear Power Resources, Inc.

6040 S. W, 82 Avenue Miami, Florida 33143

~

Professional Ex erience 1976-198i FPL Power Resources Nuclear Staff-Corporate Health Physicist, Responsible for all staff activities in the areas of Radiation Protection, Emergency Planning, Radiolo'gical Environmental Monitoring, Radiochemistry, and Waste Management:.

Directly supervised six staff personnel. The entire company program was implemented by a-

.total plant staff of about seventy Health Physics and Radiochemistry permanent personnel plus various consultant and service personnel."

1974-3.976 -

FPL Power Resources Nuclear Staff Health Physicist-.

Developed and administered 1'PL corporate r~rdiation.

pxotection program. Established. centralized in-house pexsonnel monitoring system.'Spent several days each montlr at plant sites during shutdown and operation..

l9 73-19 74 Assigned'o St. Lucie Plaht" as Health Physicist,."...

Responsible for establishing .and implementing complete Radiation Protection'rogram, including decontaroination, wast:e rnrrnagement, envixonmental monitoring, and eroergency planning, 1971-1973 Health Physics =dept., Turkey Point Plant (PTP) -.

Acted a Assistant Health Physicist in organizing and developing Health Physics pxogram. Wrote the majority of all health physics procedures.

Responsible for t: he Health Physics night crew during fuel loading of Units .3&4 at PTP. Directly supervised rrrany activities such as calibration of area monitors, changing reactor coolant: filters, decontamination, etc. Assumed all of the llealth Physicist's xesponsibil'ities during his absence.

1970-1971 FPL Turkey Point Plant, Assigned to procedures group. Wrote preoperational and operational procedures on primary systems such as process and area monitoring systems, reactor coolant system, and auxiliary systems.

Oi 1969-1970 Attended graduate school at Texas A&M University on a teaching assistantship. Gained limited experience in radiochemistry, xeactor engineering, and health physics.

1967-1969 Freshman Chemistry Instructor; taught laboratory courses in General Chemistry & Qualitative Analysis, Education s

B.S., Chemical Engineering, Georgia Institute of Technology M.S., Nuclear Engineering, Texas A&M University Additional Course Work:

Nucl.ear Reactor Engineexing, University of Missouri Ilealth Physics, Roclcwell In terna tional klealth Physics, University of Michigan Various industry business and management courses.

professional Reco~irion d Health Physics Society EEI Heal th Phys ics Task 1"o rce EEI Technical Committee on Low Leve3; Exposure AIF Working Group on Occupational F~posure AIE Horking Group on Append:iw I Technical Specifications Member of American Board of: Health Physics Examining Board for Power Reactor Health Physics Certification.

Certified by American Board of Heal'th Physics in both General and Power Reactor Ilealth Physics

t.

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