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| {{#Wiki_filter:AFFIDAVIT OF DOUGLAS KING ON CONTENTION 4 B EXHIBIT C 1.My name is Douglas King.My business address is Palmer School, 7900 S.V/.176th Street, Miami, Florida, 33157.statement of agr professional background and aualifications is attached to this affidavit and made a part thereof.2.This affidavit addresses contention 4 B which.states: | | {{#Wiki_filter:EXHIBIT C AFFIDAVIT OF DOUGLAS KING ON CONTENTION 4 B |
| 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 10 CFR Part 50 as a result, of a hurricane or tornado, striking the site during repairs.3.I participated in the Turkey Point site'nspection on April, 19, 1981 as a member of Intervenor, Mark Oncavage's party-The inspection was authorized by the Atomic Safety and Licensing Board for the purpose of discovery. | | : 1. My name is Douglas King. My business address is Palmer School, 7900 S. V/. 176th Street, Miami, Florida, 33157. |
| 4.I observed several locations of loosely stacked, sealed drums, in roped off areas.These drums were identified as containing radioactive-material 5.I monitored a few of these locations of loosely stacked sealed drums with a geiger counter.The readings indicated radiation above the background level.82 052g Op@3 0 P 6.The drums were apparently sealed but were neither f'astened down nor covered.Zhe drums were subject to weathering and other natural forces.7.Zn all, several hundred drums were observed at these locations. | | statement of agr professional background and aualifications is attached to this affidavit and made a part thereof. |
| At some locations, drums were loosely stacked on top of each other.8.NUREG 0743, the inal mvironmenta1 Statement, states that the estimated amount of'adioactive solid waste generated f'rom the steam generator repair ranges f'rom 1100 cubic meters to 2300 cubic meters, per unit.This ,estimate excludes the lower assemblies and the normal amount of solid waste from operations of'75 cubic meters, per unit per year.9.MIRZA 0743, the Final environmental Statement, states that the waste limitation for Turkey Foint wastes at the Barnwell disposal.site is 57 cubic meters, per month, starting October 1981.No other site for the final disposition of these wastes is mentioned in the Final Environmental Statement. | | : 2. This affidavit addresses contention 4 B which.states: |
| 10.I am professionally concerned that the ability of the sealed drums to completely contain the radioactive wastes II 41 I will diminish, due to long term outdoor storage where natural weathering forces such as high rainfall, high humidity, high temperatur e, sunshine, salt spray, and storms can environmentally degrade the sealed drums.CONCLUSION'f a=hurricane or tornado, with the ability to breach and flood the drums of radioacti've wastes, were to strike Turkey Point, a contaminating accident will occur.The magnitude oZ the contamination would increase es the the numbers of breached drums increases. | | 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 10 CFR Part 50 as a result, of a hurricane or tornado, striking the site during repairs. |
| The vast amounts of wastes discussed and the degradation of the drums increases the potential of the contaminating accident.The present practice of outdoor storage of, radioactive wastes in a hurricane prone area (see Leonard G.Pardue affidavit, paragraph 3)is an abandonment of the ALAM principle. | | : 3. I participated in the Turkey Point site'nspection on April, 19, 1981 as a member of Intervenor, Mark Oncavage's party- The inspection was authorized by the Atomic Safety and Licensing Board for the purpose of discovery. |
| In view of the vast amounts of radioactive wastes that will be generated by the" repairs and.stored on site, the present practice of loose, outdoor storage is unreasonable. | | : 4. I observed several locations of loosely stacked, sealed drums, in roped off areas. These drums were identified as containing radioactive -material |
| 0 0 FURThr R AFFIANT SAYZTH NOT Date: 2 lB2 Doug1as ng STATi OP FLORIDA))ss.COUNTY OF DADZ)SWOBN to and subscribed bef'ore me this day 02 May, 1981.ox a Zu zc)tWt~g 4 4~4'u s~~>~=-~W)1581~ | | : 5. I monitored a few of these locations of loosely stacked sealed drums with a geiger counter. The readings indicated radiation above the background level. |
| II STAT"~NT OF PROFZSSIONAL BACKGROUND'6) | | 82 052g Op@3 |
| AND QUALIFICATIONS-'OUGM~S KING ZDUCATION: | | |
| Bachelor of'cience, Physics, 1971 The Cooper Union, New York City, New York GR"DUATE STUDIFS: Physics Department, Radiation Biophysics Department, 1971-1977 University of Florida, Geinesville, Florida RZSZARCH ARZAS: Nuclear Magnetic Resonance, Radiation Biophysics, Biological Action of'onizing Radiation, Cell Membrane Physiology, and TLD Dosimetry ZLPLO K"'NT: 1975-1977 Teaching Assistant, Physics Dept-Univ.of Florida 10/77-1/78 Biomedical Engineer, Univ.of hami, Medical School 2/78-10/78 Radiation Health Physics Supervisor, Kedi+Physics Inc.11/78-5/81 Physics and Advanced Mathematics Teacher, The Palmer School~~RSHIPS AND HONORS: Member of'igma Pi Sigma, Physics National Eonor Society President of Sigma Pi Signa, Univ.of'lorida Chapter, 1976-1977 member of United States Chess Federation, 1964-1980 0 J3 I}} | | 0 P |
| | : 6. The drums were apparently sealed but were neither f'astened down nor covered. Zhe drums were subject to weathering and other natural forces. |
| | : 7. Zn all, several hundred drums were observed at these locations. At some locations, drums were loosely stacked on top of each other. |
| | : 8. NUREG 0743, the inal mvironmenta1 Statement, states that the estimated amount of'adioactive solid waste generated f'rom the steam generator repair ranges f'rom 1100 cubic meters to 2300 cubic meters, per unit. This |
| | ,estimate excludes the lower assemblies and the normal amount of solid waste from operations of'75 cubic meters, per unit per year. |
| | : 9. MIRZA 0743, the Final environmental Statement, states that the waste limitation for Turkey Foint wastes at the Barnwell disposal .site is 57 cubic meters, per month, starting October 1981. No other site for the final disposition of these wastes is mentioned in the Final Environmental Statement. |
| | : 10. I am professionally concerned that the ability of the sealed drums to completely contain the radioactive wastes |
| | |
| | II 41 I |
| | |
| | will diminish, due to long term outdoor storage where natural weathering forces such as high rainfall, high humidity, high temperatur e, sunshine, salt spray, and storms can environmentally degrade the sealed drums. |
| | CONCLUSION'f a =hurricane or tornado, with the ability to breach and flood the drums of radioacti've wastes, were to strike Turkey Point, a contaminating accident will occur. The magnitude oZ the contamination would increase es the the numbers of breached drums increases. The vast amounts of wastes discussed and the degradation of the drums increases the potential of the contaminating accident. The present practice of outdoor storage of, radioactive wastes in a hurricane prone area (see Leonard G. |
| | Pardue affidavit, paragraph 3) is an abandonment of the ALAM principle. In view of the vast amounts of radioactive wastes that will be generated by the" repairs and. stored on site, the present practice of loose, outdoor storage is unreasonable. |
| | |
| | 0 0 FURThr R AFFIANT SAYZTH NOT Date: 2 lB2 Doug1as ng STATi OP FLORIDA ) |
| | ) ss. |
| | COUNTY OF DADZ ) |
| | SWOBN to and subscribed bef'ore me this day 02 May, 1981. |
| | )tWt~g ox a Zu zc 4 4~4'u s~~>~ =- |
| | ~ |
| | W)1581~ |
| | |
| | II STAT" ~NT OF PROFZSSIONAL BACKGROUND'6) AND QUALIFICATIONS-'OUGM~S KING ZDUCATION: |
| | Bachelor of'cience, Physics, 1971 The Cooper Union, New York City, New York GR"DUATE STUDIFS: |
| | Physics Department, Radiation Biophysics Department, 1971 - 1977 University of Florida, Geinesville, Florida RZSZARCH ARZAS: |
| | Nuclear Magnetic Resonance, Radiation Biophysics, Biological Action of'onizing Radiation, Cell Membrane Physiology, and TLD Dosimetry ZLPLO K"'NT: |
| | 1975 - 1977 Teaching Assistant, Physics Dept- Univ. of Florida 10/77 1/78 Biomedical Engineer, Univ. of hami, Medical School 2/78 10/78 Radiation Health Physics Supervisor, Kedi + Physics Inc. |
| | 11/78 5/81 Physics and Advanced Mathematics Teacher, The Palmer School |
| | ~~RSHIPS AND HONORS: |
| | Member of'igma Pi Sigma, Physics National Eonor Society President of Sigma Pi Signa, Univ. of'lorida Chapter, 1976 1977 member of United States Chess Federation, 1964 1980 |
| | |
| | 0 J3 I}} |
Affidavit Supporting Contention 4B.If Hurricane Had Enough Force to Breach & Flood Drums of Radwaste,Contamination Accident Would Occur.Practice of Loose Outdoor Storage Unreasonable.Prof Qualifications EnclML17340B277 |
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Turkey Point ![NextEra Energy icon.png](/w/images/9/9b/NextEra_Energy_icon.png) |
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Issue date: |
05/11/1981 |
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From: |
King D ONCAVAGE, M. |
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To: |
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Shared Package |
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ML17340B275 |
List: |
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References |
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NUDOCS 8105290363 |
Download: ML17340B277 (10) |
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Category:AFFIDAVITS
MONTHYEARML20141F5711997-06-13013 June 1997 Supplemental Affidavit of B Hughes & Ta Peebles.* Affidavit Re Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam.W/Certificate of Svc ML20138J2331997-05-0202 May 1997 Affidavit.* Affidavit of B Hughes Re Denial of Application for SRO License for Rl Tetrick.W/Certificate of Svc ML20136F2721997-03-0606 March 1997 Supplemental Affidavit of B Hughes.* Supports Staff Motion for Reconsideration of Presiding Officer Initial Decision of 970228.W/Certificate of Svc ML20134A6661997-01-23023 January 1997 Affidavit of B Hughes & Ta Peebles Re Denial of Application for SRO License.W/Certificate of Svc.Served on 970124 ML19325E0111989-10-20020 October 1989 Affidavit of J Lorion on Contention 2.* ML20247F2461989-09-11011 September 1989 Affidavit of SA Collard on Contentions 2 & 3.* Collard Prof Qualifications,Supporting Info & Certificate of Svc Encl ML20247A3081989-09-0505 September 1989 Affidavit of Bj Elliot.* Advises That Author Responded to Interrogatories 1,3,4,6-10,12,13,16 & 17.Related Correspondence ML20246F6651989-08-28028 August 1989 Affidavit of GE Edison.* Advises That Author Provided Response to Interrogatory 5.Supporting Documentation Encl. W/Certificate of Svc ML20246J7161989-08-28028 August 1989 Affidavit of GE Edison.* Advises That Author Provided Response to Interrogatory 5.Certificate of Svc Encl.Related Correspondence ML20207B6311986-07-14014 July 1986 Affidavit of ML Wohl Re Contention 4 Concerning Personnel Exposures.Related Info,Including Prof Qualifications,Encl ML20207B6411986-07-14014 July 1986 Affidavit of Jl Minns Re Contention 4 Concerning Personnel Exposures.Related Info,Including Prof Qualifications,Encl. W/Certificate of Svc ML20140D7781986-03-19019 March 1986 Affidavit of J Lorion Re Contentions 3,4,5,6,7,8 & 10 ML20140D5491986-03-19019 March 1986 Affidavit of J Lorion Supporting Intervenor Contention 3 Concerning Util Motions for Summary Disposition.Certificate of Svc Encl ML20205K5501986-02-21021 February 1986 Supplemental Affidavit of Jl Danek Correcting 860121 Affidavit on Contention 7 to Indicate That Actual Exposure Incurred During Reracking Is 13.20 Not 13.17 person-rem. Notice of Appearance & Certificate of Svc Encl ML20153D2441986-02-18018 February 1986 Affidavit of Jn Ridgely Supporting Util 860123 Motion for Summary Disposition of Contention 8 Re High Density Design of Fuel Racks ML20153D2521986-02-18018 February 1986 Affidavit of LI Kopp Supporting Util 860123 Motion for Summary Disposition of Contention 10 Re Spent Fuel Pool Capacity.W/Certificate of Svc & Two Notices of Appearance ML20153D2041986-02-18018 February 1986 Affidavit of B Turovlin Supporting Util 860123 Motion for Summary Disposition of Contention 6 Re Matls Integrity ML20153D1721986-02-18018 February 1986 Affidavit of SB Kim Supporting Util 860123 Motion for Summary Disposition of Contention 5 Re Main Safety Function of Spent Fuel Pool ML20137W8501986-02-18018 February 1986 Affidavit of LI Kopp Supporting Licensee 860123 Motion for Summary Disposition of Contention 3 Re Increased Fuel Enrichment ML20153D1501986-02-18018 February 1986 Affidavit of ML Wohl Rejecting Util 860123 Motion for Summary Disposition of Contention 4 Re Radiological Analysis of Spent Fuel Boiling Event ML20153D1081986-02-18018 February 1986 Affidavit of ML Wohl Supporting Util 860123 Motion for Summary Disposition of Contention 3 Re Calculation of Radiological Consequences Resulting from Cask Drop Accident ML20140C8661986-01-23023 January 1986 Affidavit of He Flanders Re Contention 5.New Spent Fuel Storage Racks Designed in Accordance W/Seismic Category 1 Requirements.Design Conforms W/Srp Section 9.1.2.Summary of Prof Qualifications Encl ML20140C8441986-01-22022 January 1986 Affidavit of Rk Carr Re Contention 3.Offsite Doses for Postulated Cask Drop Accident Calculated Conservatively Using Appropriate Peaking Factors & Resultant Radiation Doses within Guidelines.Qualifications Encl ML20140C8581986-01-22022 January 1986 Affidavit of Rk Carr Re Contention 4.Assumptions Re Saturation Noble Gas & Iodine Inventories,Percent Fuel Failure & Gap Activity Used for Analysis of Spent Fuel Pool Boiling Appropriate & Doses Calculated Acceptable ML20140D1551986-01-22022 January 1986 Affidavit of Ew Thomas Re Contention 6.Analysis Shows That Pool Maintains Structural Integrity Even Under Severe Conditions of Postulated Boiling Water Combined W/Effects of Design Earthquake.Summary of Prof Experience Encl ML20140D1301986-01-22022 January 1986 Affidavit of Rk Carr Re Contention 6.Spent Fuel Pool Liner & Pool Structure Consists of Matls Commonly Used in Nuclear Applications & Have Proven Ability to Withstand Radiation Exposure.Qualifications Encl ML20140D1811986-01-22022 January 1986 Affidavit of Rk Carr Re Contention 7.Occupational Exposure from Reracking Spent Fuel Pool at Plant Was Substantially Lower than Original & Revised Estimates,Thereby Demonstrating Conservatism.Prof Experience Encl ML20140D2331986-01-22022 January 1986 Affidavit of DC Patton Addressing Contentions 6 & 8.Util Committed to Upgrade Spent Fuel Pool Cooling Loop to Ensure Adequate Cooling of Spent Fuel Pool in Event of SSE ML20140D2241986-01-22022 January 1986 Affidavit of Jl Danek Addressing Contention 7.Radiation Protection Policies of Util Require Establishment & Implementation of Formal ALARA Program.Prof Experience Encl ML20140C8781986-01-21021 January 1986 Affidavit of Lt Gesinski Re Contention 5 Concerning Seismic Loads on Fuel Assemblies.Methodology Used in Analysis Appropriate & Results Obtained from Analysis Accurate. Summary of Experience Encl ML20140D1371986-01-20020 January 1986 Affidavit of Gr Kilp Re Contention 6.Spent Assemblies & Cladding of Fuel Rods Designed to Withstand Very High Radiation Levels Present in Reactor.Summary of Experience Encl ML20140D2531986-01-20020 January 1986 Affidavit of Wa Boyd Addressing Contention 10.Critical Analyses Performed for Spent Fuel Pool Expansion Amends Conform W/Applicable Stds & Criteria.Certificate of Svc Encl ML20140C6231986-01-17017 January 1986 Affidavit of SE Turner Re Contention 3 Concerning Increased Fuel Enrichment.Certificate of Svc Encl ML20198E4311985-11-0606 November 1985 Affidavit of G Edwards Re Intervenor Contention (D).Dnbr of 1.17 for Optimized Fuel Assembly Fuel in Transitional Mixed Core Unwarranted Unless Detailed Studies Done.Adoption of Lower DNBR Value Would Allow Operation at Hotter Temp ML20198E4351985-11-0606 November 1985 Affidavit of J Lorion Re Contention (D).Change in DNBR Limit from 1.3 to 1.17 Reduces Margin of Safety.Board Should Conduct Hearing Previously Ordered to Investigate Margin of Safety ML20133J2511985-10-15015 October 1985 Affidavit of Yi-Hsiung Hsii Addressing Contention (D) Re Three Issues Stated in ASLB 850816 Order Denying Licensee Motion for Summary Disposition ML20135H8831985-09-20020 September 1985 Affidavit of EA Dzenis Re Vessel Flux Reduction at Facilities ML20096F3971984-09-0404 September 1984 Affidavit of J Lorion Refuting Contentions (B) & (D) That There Is No Genuine Issue of Matl Fact to Be Heard ML20096F4291984-09-0404 September 1984 Affidavit of Gd Edwards Refuting Licensee Contentions (B) & (D) That There Is No Genuine Issue of Matl Fact to Be Heard. Prof Qualifications & Certificate of Svc Encl ML20094J2261984-08-0808 August 1984 Affidavit of EA Dzenis in Support of Licensee 840810 Motion for Summary Disposition of Intervenor Contention (D). Realted Correspondence ML20094J0881984-08-0303 August 1984 Affidavit of Mj Parvin in Support of Applicant 840810 Motion for Summary Dispositon of Intervenor Contention (B).Related Correspondence ML20087F6211984-03-0909 March 1984 Affidavit of DC Poteralski on Petitioners 840303 Brief Re Conflict Posed by Legal Requirement of Timeliness & Equitable Considerations.Util 830720 Amends Not Part of Pressurized Thermal Shock Program.W/Certificate of Svc ML17341A4301981-08-0505 August 1981 Affidavit Responding to ASLB 810728 Order Re Void Found in Area Adjoining & Beneath Equipment Hatch.No Breach of Structural Integrity of Unit 3 Containment Pressure Boundary Occurred ML17341A3241981-07-10010 July 1981 Affidavit Re Intervenor Oncavage 810627 Application for Stay of Final Order ML17341A3251981-07-10010 July 1981 Affidavit Re Intervenor Oncavage 810627 Application for Stay of Final Order ML18008A0181981-06-27027 June 1981 Affidavit Re Lack of Adequate Precautions in Storing Wastes Resulting from Steam Generator Repair.Prof Qualifications Encl ML17341A2461981-06-12012 June 1981 Affidavit Addressing ASLB 810528 Memorandum & Order Re Filing of Detailed Info on Low Level Solid Waste Resulting from Repairs.Prof Qualifications & Certificate of Svc Encl ML17340B2761981-05-12012 May 1981 Affidavit Supporting Contention 1 on Alternatives to Repairing Facility Steam Generators.Conservation Potential from Several Approaches Could Cut Energy Consumption by 50-70%.Prof Qualifications Encl ML17341A2871981-05-11011 May 1981 Affidavit Re Probability & Result of Hurricane Damage to Containers in Which Low Specific Activity Waste Resulting from Steam Generator Repair Would Be Stored.Prof Qualifications Encl ML17340B2781981-05-11011 May 1981 Affidavit Supporting Contention 4B.Integrity of Loosely Stacked Drums of Low Level Radwaste Cannot Be Assured During Passage of Major Hurricane.Prof Qualifications Encl 1997-06-13
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEAR3F0999-05, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines1999-09-14014 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines L-99-201, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments1999-09-0707 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments ML20206H4441999-05-0303 May 1999 Comment Opposing Proposed Rules 10CFR170 & 10CFR171 Re Rev of Fy 1999 Fee Schedules ML20205J0461999-04-0101 April 1999 Comment Supporting Proposed Draft Std Review Plan on Foreign Ownership,Control & Domination.Util Supports Approach Set Forth in SRP Toward Reviewing Whether Applicant for NRC License Owned by Foreign Corp.Endorses NEI Comments ML20205B3771999-03-16016 March 1999 Comment Opposing PRM 50-64 Re Liability of Joint Owners of Npps.Util Endorses Comments of NEI & Urges Commission to Deny Petition for Rulemaking ML17355A2511999-03-0909 March 1999 Comment Supporting Amend to Policy & Procedure for NRC Enforcement Actions Re Treatment of Severity Level IV Violations at Power Reactors.Util Also Endorses Comments of NEI on Revs L-98-306, Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP1998-12-10010 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP L-98-272, Comment on Draft Reg Guide DG-4005, Preparation of Suppl Environ Repts for Applications to Renew Nuclear Power Plant Operating Licenses1998-10-28028 October 1998 Comment on Draft Reg Guide DG-4005, Preparation of Suppl Environ Repts for Applications to Renew Nuclear Power Plant Operating Licenses L-98-252, Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule1998-10-0606 October 1998 Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule L-98-248, Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement1998-10-0505 October 1998 Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement ML17354A8741998-03-27027 March 1998 Comment Opposing Proposed Generic Communication,Lab Testing of nuclear-grade Activated Charcoal (M97978) ML17354B1061998-02-26026 February 1998 Submits Listed Requests for NRC EA Per 10CFR2.206 to Modify OLs for All FPL NPPs Until Licensee Can Demonstrate Open Communication Channels Exist Between NRC & Licensee.Also Requests EA to Address Alleged Discriminatory Practices ML20217M0751997-08-13013 August 1997 Licensee Response to Supplemental 10CFR2.206 Petitions Filed by Tj Saporito & National Litigation Consultants.Petition Provides No Basis for Extraordinary Relief Requested. Petition Should Be Denied.W/Certificate of Svc ML20217J4321997-08-0707 August 1997 Memorandum & Order.* Grants Staff Petition for Review & Reverses Presiding Officer Decision Requiring Staff to Issue Tetrick SRO License.Order Disapproved by Commissioner Diaz. W/Certificate of Svc.Served on 970807 ML20148P8461997-06-25025 June 1997 Memorandum & Order (Determination of Remand Question).* Concludes That Presiding Officer Reaffirms Determination That Response of Rl Tetrick to Question 63 of Exam to Be SRO Was Incorrect.W/Certificate of Svc.Served on 970626 ML17354A5521997-06-18018 June 1997 Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems. ML20141F5441997-06-13013 June 1997 NRC Staff Response to Presiding Officer Memorandum & Order (Questions Relevant to Remand).* Staff Submits That Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam Should Be Denied ML20141F5711997-06-13013 June 1997 Supplemental Affidavit of B Hughes & Ta Peebles.* Affidavit Re Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam.W/Certificate of Svc ML17354A5181997-05-27027 May 1997 Licensee Response to 10CFR2.206 Petition Filed by Tj Saporito & National Litigation Consultants.Petition Should Be Denied,Based on Listed Info.W/Certificate of Svc ML20148G6531997-05-27027 May 1997 Notice.* Forwards Documents Received & Read by Author from Rl Tetrick on 970317 W/O Being Served as Required Under Procedural Rules.W/Certificate of Svc.Served on 970527 ML20148G7071997-05-27027 May 1997 Memorandum & Order (Questions Relevant to Remand).* Rl Tetrick May Respond to Questions W/Filing Served Pursuant to Procedural Regulations W/Notarized Statement to Be Received by 970617.Certificate of Svc Encl.Served on 970527 ML20148G7501997-05-20020 May 1997 Memorandum & Order CLI-97-05.* Staff May Withhold Issuance of SRO License to Rl Tetrick Pending Further Order of Commission.W/Certificate of Svc.Served on 970520 ML17354A5631997-05-17017 May 1997 Second Suppl to 970423 Petition Requesting Enforcement Against Listed Util Employees by Imposing Civil Penalties, Restricting Employees from Licensed Activities & Revoking Unescorted Access ML20141C7331997-05-16016 May 1997 Order Extending Until 970616,time within Which Commission May Rule on NRC Staff 970416 Petition for Review of Presiding Officer Initial Decision.W/Certificate of Svc. Served on 970516 ML17354A5611997-05-11011 May 1997 Suppl to 970423 Petition Requesting Enforcement Action Against Util Former Executive Vice President,Site Vice President & Maint Superintendent by Imposing Civil Monetary Penalty ML20138J2331997-05-0202 May 1997 Affidavit.* Affidavit of B Hughes Re Denial of Application for SRO License for Rl Tetrick.W/Certificate of Svc ML20138J2271997-05-0202 May 1997 NRC Staff Response to Questions Posed in Commission Order of 970425.* Staff Respectfully Submits That Commission Should Undertake Review of Presiding Officer Decisions in Proceedings LBP-97-2 & LBP-97-6 ML20138J2241997-05-0202 May 1997 Line (Providing Omitted Citation).* Informs That Submitted Citation Inadvertently Omitted from Response to Questions Posed in Commission Order of 970425.W/Certificate of Svc ML20138J2401997-04-25025 April 1997 Scheduling Order.* Staff Instructed to File W/Commission,By COB 970502,response to Tetrick Argument Re Question 63 & Discussion of Legal Significance of Consistent Staff Practices.W/Certificate of Svc.Served on 970425 ML17354A5651997-04-23023 April 1997 Requests That NRC Take EA to Modify,Suspend or Revoke FPL Operating Licenses for All Four Nuclear Reactors Until Licensee Can Sufficiently Demonstrate to NRC & Public That Employees Encouraged to Freely Raise Safety Concerns ML20137X5921997-04-16016 April 1997 NRC Staff Petition for Commission Review of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Undertake Review of Presiding Officer Decisions in Proceeding.W/Certificate of Svc ML20137X5511997-04-11011 April 1997 NRC Request for Issuance of Order Staying Effectiveness of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Stay Effectiveness of Decision in Subj Proceeding.W/Certificate of Svc ML20137R3531997-03-27027 March 1997 Correct Copy of Memorandum & Order (Denial of Reconsideration,Stay).* Denies NRC Staff Motion for Reconsideration.W/Certificate of Svc.Served on 970327 ML20137F5551997-03-25025 March 1997 NRC Staff Response to Memorandum & Order of 970321.* Presiding Officer Should Grant Staff 970310 Motion for Reconsideration.W/Certificate of Svc ML20137F8251997-03-21021 March 1997 Memorandum & Order (Grant of Housekeeping Stay).* Orders That Effect of Initial Decision Postponed Until Close of Business on 970326.W/Certificate of Svc.Served on 970321 ML20137F5081997-03-17017 March 1997 NRC Staff Motion for Issuance of Stay.* Requests That Presiding Officer Deny NRC Staff Request for Issuance of Stay in Matter of Issuance of SRO License ML20137F5371997-03-17017 March 1997 NRC Staff Motion for Reconsideration in Matter of Rl Tetrick.* Requests That Presiding Officer Deny NRC Staff Request for Reconsideration ML20136F2981997-03-12012 March 1997 Memorandum & Order (Grant of Housekeeping Stay).* Informs That Initial Decision Issued by Presiding Officer on 970228 Postponed Until 970321 & Rl Tetrick May File Response by 970318.W/Certificate of Svc.Served on 970312 ML20136F2351997-03-10010 March 1997 NRC Staff Motion for Reconsideration Introduction.* Requests That Presiding Officer Reconsider Determination That Tetrick Passed Written Exam & Find,Instead,That Tetrick Failed Written Exam ML20136F3411997-03-10010 March 1997 NRC Staff Request for Issuance of Order Staying Effectiveness of Presiding Officers Initial Decision LBP-97-2.* Staff Submits That Presiding Officer Should Stay Effectiveness of Initial Decision.W/Certificate of Svc ML20136F2721997-03-0606 March 1997 Supplemental Affidavit of B Hughes.* Supports Staff Motion for Reconsideration of Presiding Officer Initial Decision of 970228.W/Certificate of Svc ML20138Q0191997-02-28028 February 1997 Initial Decision.* Concludes That Rl Tetrick Had Passing Score of 80% & Should Be Granted License as Sro. W/Certificate of Svc.Served on 970228 ML20134A6551997-01-23023 January 1997 Written Presentation of NRC Staff.* Staff Concludes That SE Turk Failed Written Exam & Did Not Establish Sufficient Cause to Change Grading of Answers to Listed Questions. Denial of Application for SRO License Should Be Sustained ML20134A6661997-01-23023 January 1997 Affidavit of B Hughes & Ta Peebles Re Denial of Application for SRO License.W/Certificate of Svc.Served on 970124 ML20129J5681996-10-23023 October 1996 Memorandum & Order (Error).* Informs of Incorrect Caption Identified in Order .W/Certificate of Svc.Served on 961023 ML20129D4981996-10-21021 October 1996 Memorandum & Order (Grant of Request for Hearing Scheduling).* Requests for Hearing Hereby Granted. W/Certificate of Svc.Served on 961021 ML20129D6681996-10-18018 October 1996 NRC Staff Answer to Rl Tetrick Request for Hearing.* Staff Does Not Oppose Request & Will Be Prepared to Submit Hearing File.W/Certificate of Svc & Notice of Appearance ML20129D4401996-10-0909 October 1996 Designating of Presiding Officer.* Pb Bloch Designated to Serve as Presiding Officer to Conduct Informal Adjudicatory Hearing in Proceeding of Rl Tetrick Re Denial of SRO License.W/Certificate of Svc.Served on 961010 ML17353A6311996-01-19019 January 1996 Decision & Remand Order Re FPL Discrimination Against RR Diaz-Robainas.FPL Ordered to Offer Reinstatement to RR Diaz-Robainas W/Comparable Pay & Benefits,To Pay Him Back Pay W/Interest & to Pay His Costs & Expenses Re Complaint ML17353A2471995-06-27027 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style. 1999-09-07
[Table view] |
Text
EXHIBIT C AFFIDAVIT OF DOUGLAS KING ON CONTENTION 4 B
- 1. My name is Douglas King. My business address is Palmer School, 7900 S. V/. 176th Street, Miami, Florida, 33157.
statement of agr professional background and aualifications is attached to this affidavit and made a part thereof.
- 2. This affidavit addresses contention 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 10 CFR Part 50 as a result, of a hurricane or tornado, striking the site during repairs.
- 3. I participated in the Turkey Point site'nspection on April, 19, 1981 as a member of Intervenor, Mark Oncavage's party- The inspection was authorized by the Atomic Safety and Licensing Board for the purpose of discovery.
- 4. I observed several locations of loosely stacked, sealed drums, in roped off areas. These drums were identified as containing radioactive -material
- 5. I monitored a few of these locations of loosely stacked sealed drums with a geiger counter. The readings indicated radiation above the background level.
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- 6. The drums were apparently sealed but were neither f'astened down nor covered. Zhe drums were subject to weathering and other natural forces.
- 7. Zn all, several hundred drums were observed at these locations. At some locations, drums were loosely stacked on top of each other.
- 8. NUREG 0743, the inal mvironmenta1 Statement, states that the estimated amount of'adioactive solid waste generated f'rom the steam generator repair ranges f'rom 1100 cubic meters to 2300 cubic meters, per unit. This
,estimate excludes the lower assemblies and the normal amount of solid waste from operations of'75 cubic meters, per unit per year.
- 9. MIRZA 0743, the Final environmental Statement, states that the waste limitation for Turkey Foint wastes at the Barnwell disposal .site is 57 cubic meters, per month, starting October 1981. No other site for the final disposition of these wastes is mentioned in the Final Environmental Statement.
- 10. I am professionally concerned that the ability of the sealed drums to completely contain the radioactive wastes
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will diminish, due to long term outdoor storage where natural weathering forces such as high rainfall, high humidity, high temperatur e, sunshine, salt spray, and storms can environmentally degrade the sealed drums.
CONCLUSION'f a =hurricane or tornado, with the ability to breach and flood the drums of radioacti've wastes, were to strike Turkey Point, a contaminating accident will occur. The magnitude oZ the contamination would increase es the the numbers of breached drums increases. The vast amounts of wastes discussed and the degradation of the drums increases the potential of the contaminating accident. The present practice of outdoor storage of, radioactive wastes in a hurricane prone area (see Leonard G.
Pardue affidavit, paragraph 3) is an abandonment of the ALAM principle. In view of the vast amounts of radioactive wastes that will be generated by the" repairs and. stored on site, the present practice of loose, outdoor storage is unreasonable.
0 0 FURThr R AFFIANT SAYZTH NOT Date: 2 lB2 Doug1as ng STATi OP FLORIDA )
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COUNTY OF DADZ )
SWOBN to and subscribed bef'ore me this day 02 May, 1981.
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II STAT" ~NT OF PROFZSSIONAL BACKGROUND'6) AND QUALIFICATIONS-'OUGM~S KING ZDUCATION:
Bachelor of'cience, Physics, 1971 The Cooper Union, New York City, New York GR"DUATE STUDIFS:
Physics Department, Radiation Biophysics Department, 1971 - 1977 University of Florida, Geinesville, Florida RZSZARCH ARZAS:
Nuclear Magnetic Resonance, Radiation Biophysics, Biological Action of'onizing Radiation, Cell Membrane Physiology, and TLD Dosimetry ZLPLO K"'NT:
1975 - 1977 Teaching Assistant, Physics Dept- Univ. of Florida 10/77 1/78 Biomedical Engineer, Univ. of hami, Medical School 2/78 10/78 Radiation Health Physics Supervisor, Kedi + Physics Inc.
11/78 5/81 Physics and Advanced Mathematics Teacher, The Palmer School
~~RSHIPS AND HONORS:
Member of'igma Pi Sigma, Physics National Eonor Society President of Sigma Pi Signa, Univ. of'lorida Chapter, 1976 1977 member of United States Chess Federation, 1964 1980
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