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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}}

Latest revision as of 10:50, 22 October 2019

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 Encl
ML17340B277
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 05/11/1981
From: King D
ONCAVAGE, M.
To:
Shared Package
ML17340B275 List:
References
NUDOCS 8105290363
Download: ML17340B277 (10)
v • d • e


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.

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. 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

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