ML17340B042

Response Supporting Applicant 810408 Motion for Summary Disposition of Contentions 3,6 & 8.No Genuine Issue of Matl Fact Remains to Be Resolved

ML17340B042
Person / Time
Site:	Turkey Point
Issue date:	04/22/1981
From:	Goldberg S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML17340B043	List: ML17340B042 ML17340B044 ML17340B045 ML17340B046 ML17340B047
References
NUDOCS 8104230614
Download: ML17340B042 (6)

Text

04/22/81

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Docket Hos.

50-250 50-251 (Proposed Amendments to Facile Operating Licenses to Permit Steam Generator Repair)

FLORIDA POWER AHD LIG'rlT COl4PAiVY (Turkey Point Nuclear Generating Unit Nos.

3 and 4)

UNITED STATES OF AMERICA NUCLEAR REGULATORY Colll1ISS ION

/PPj BEFORE THE ATOl1IC SAFETY AHD LICENSING, BOARD L ~

/g In the 11atter of NRC STAFF

RESPONSE

TO APPLICANT'S NOTION FQR SUHI'1ARY DISPOSITION OF CONTENTIONS 3

.6 AND 8 INTRODUCTION On April 8, 1981, the Applicant filed a motion for summary

'I disposition of contentions 3+

and 6-j and separate motion for summary disposition of contention 8

pursuant to 10 CFR 5 2.749.

On. the basis 3/

of the HRC Staff Final Environmental Statement (FES)

(NUREG-0743),

dated'arch

1981, December, 1980 Safety Evaluation Report (NUREG-0756), triarch, 1981 Safety Evaluation Report regarding conformance with Appendix I to 10 CFR Part 50, (Appendix ISER),

and the attached affidavits, the Staff supports the present motions.

i Contention 3 states:

During the course of the repai.rs proposed by the

Licensee, (a) the handling, processing, storing or discharging of primary coolant or (b) the discharging of laundry waste water is likely to result in the release of radioactive material to unrestricted areas in quantities which will not be as low as i's reasonably achievable within the meaning of 10 CFR Parts 20 and 50.

Contention 6 states:

The cumulative offsite radiation releases as a

2l result of all activity at Turkey Point, during the proposed

repairs, do not comply with 10 CFR Parts 20 and 50.

Q3 Contention 8 states:

The proposed method of radiation monitoring during repair of the steam generators will not provide accurate informati'on to comply with 10 CFR Part 20 and 50.

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l" DISCUSS IOH Contentions 3 and 6

The statement of material facts accompanying the Applicant's motion for summary disposition of contentions 3 and 6 accurately summarize the material facts not open to dispute.

Staff affidavit of Edward F.

Branagan on Contentions 3 and 6,

FES,

54. 1.2. 1.

With regard'o contention 3, the potential release of primary reactor coolant and laundry waste water constitutes the primary source of liquid effluent releases from the proposed repair.

Id.

This potential source of liquid releases was specifically considered i n Staff estimates of total li'quid.releases from the repair.

Id.; FES, Table 4.5.

Radioactive effluent releases to unrestricted areas from all sources during the repair are a small fraction of those from normal operation ~Id.),

a small fraction of both the annual and lifetime dose from background radiation ~Id.), and a.small fraction of the numerical guidance and design dose objectives for unrestricted areas in Appendix I to Part 50.

FES, Appendix A.

Conformance to the guidelines of Appendix

-I is deemed a conclusive showing of compliance.with the Commission's ALARA requirements relative to releases to unrestricted areas 10 CFR Part 50, Appendix A, Section I.

,With regard to contention 6, the radioactive effluent releases to unrestricted areas during normal operation are well within the numerical guidelines and design objectives in Appendix I.

Appendix I Safety Evaluation Report, dated Harch 27, 1981.

The estimated radiological releases to unrestricted areas during the proposed repair alone, or in combination with existing operational

releases, have been similarly demonstrated to be well within the Appendix I objectives.

FES, 5 4. 1.2. 1, Appendix A.

lI Og Contention 8

The statement of material facts accompanying the Applicant's motion for summary. disposition of contention 8 accurately summarize the material facts not open to dispute.

Staff affidavits of Edward F. Branagan, Chandu P. Patel, and John L. Hinns on Contention 8.

Contention 8 alleges that the readiation monitoring during the repair will not provide accurate information.

The Staff has reviewed the Applicant's personnel monitoring

program, and related equipment and instrumentation, as well as the 4/

monitoring program.+ governing radiological releases to the environment, and related'quipment and instrumentation. +

These.programs and processes will combine to provide accurate information during the proposed repairs to assure compliance with 10 CFR Parts 20 and 50 values. +

CONCLUSION As demonstrated

above, no genuine issues of material fact remain to be resolved with respect to contentions 3,

6 and 8.

Accordingly, the Board. should grant summary disposition and dismiss Contentions 3,

6 and 8

from this proceeding.

Respectfully submitted,

~h,MQ/

Steven C. Goldberg Counsel for HRC Staff Dated at Bethesda, Maryland this 22nd day of April, 1981.

Q4 tlinn's affidavit.

g5 Branagan affidavit.

g6 Patel affidavit.

j7'd.,

n. 4-6.

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