ML20080U168

Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard on Joint Contention V.Related Correspondence

ML20080U168
Person / Time
Site:	Harris
Issue date:	02/27/1984
From:	Patricia Anderson CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20080U150	List: ML20080U147 ML20080U168 ML20080U179
References
NUDOCS 8403020188
Download: ML20080U168 (3)

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.. _ 1 pn Alio C? .u;DENCE CCtKETEF LN February 27, 1984

'84 IBR -1 A11 :47 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f 5

'gC ' '[ 4 BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' STATEMENT OF MATERIAL FACTS .

AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON JOINT CONTENTION V Pursuant to 10 C.F.R. S 2.749 (a) , Applicants state, in support of their Motion for Summary Disposition of Joint Con-tention V in this proceeding, that there is no genuine issue to be heard with respect to the following material facts:

1. Joint Contention V alleges that Applicants intend to inspect and calibrate their continuous air monitors (CAMS) and portable air samplers once" annually, that this frequency of

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inspection appears inadequate to assure that accurate monitor-ing can he performed in an emergency situation and that Appli-cants should be required to inspect the monitors and samplers frequently enough to ensure accuracy of + 5 percent.

2. Applicants intend to calibrate CAMS and portable air samplers once every six months. Affidavit of Dr. William H. Wilkie (hereinafter " Wilkie Affidavit") at 57.

8403020188 840227 PDR ADOCK 05000400 0 PDR

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3. Applicants' commitment to semi-annual calibration complies with the standards set forth in NRC Regulatory Guide 8.25.

4. Applicants' method of calibrating CAMS and portable air' samplers is in compliance with Regulatory Guide 8.25 and with " Air Sampling Instruments for Evaluation of Atmospheric Contaminants," 6th Edition, 1983, a publication of the American Conference of GovernmentalLIndustrial Hygienists. Wilkie Affidavit at 111.

5. Applicants inspect CAMS daily for proper operation -

during use'and perform response checks weekly using radioactive

~ sources. Wilkie. Affidavit at 118,

6. Applicants inspect portable air samplers used during routine operation each time the eculpment is used. Wilkie Affi-davit at 518.

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7. Emergency portable air samplers are inspected at the I time of semi-annual calibration and are stored in a controlled environment.- Wilkie Affidavit at M18.

8. CAMS are not used to determine accurately concentrations -

l of airborne radionuclides. Wilkie Affidavit at 16.

9. Portable air ' samplers may be used to collect samples for laboratory analysis of concentrations of airborne radionuclides.

Wilkie' Affidavit'at 16.

I' 10. Respiratory protection is implemented whenever con- ,

cent ations-of radioactivity exceed 25 percent of the MPC values

r, set forth in 10 C.F.R. Part 20, Appendix B, Table 1, Column 1.

Wilkie Affidavit at 516.

11. Regulatory Guide 8.25 suggests that CAMS and portable air samplers be calibrated.to an accuracy of 1 20 percent, which Applicants commit to do. Wilkie Affidavit at 511.

. 12 Calibration of CAMS and portable air samplers once a month to i 5 percent accuracy would not result in any improvement -

-in Applicants' ability to protect the health and safety of Plant personnel or.the public during an emergency situation. Wilkie Affidavit at 5515,19. -

Respectfully submitted,

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Thomas A. Baxter, P.C.

John H. O'Neill, Jr., P.C.

Pamela H. Anderson SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1148 and u Richard E. Jones i

Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh North Carolina 27602 (919) 856-7707 Counsel for Applicants February 27, 1984

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