ML20102A841

Affidavit of RR Bowers Supporting Motion for Summary Disposition of Contention B Re Potential Evacuation Route Impediments

ML20102A841
Person / Time
Site:	Perry
Issue date:	02/04/1985
From:	Bowers R CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20102A776	List: ML20102A774 ML20102A784 ML20102A809 ML20102A818 ML20102A832 ML20102A841 ML20102A858
References
OL, NUDOCS 8502080590
Download: ML20102A841 (6)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION E BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 035

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In the Matter of )

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. THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING. COMPANY ) ~50-441

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~ (Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF RICHARD R. BOWERS ON CONTENTION B County of Lake )

) as:

State of Ohio )

Richard R. Bowers, having duly sworn, deposes and says:

. 1. I am presently Corporate Health Physicist, The

. Cleveland Electric Illuminating Company (CEI). My business address-is 10 Center Road, Perry,-Ohio 44081. In my position,

- I have technical overview responsibilities for both the-operational health physics program and the engineering' health physics program. In this position I provide consulting assistance to these two groups as well as perform reviews of' their programs. A current statement of my professional and technical ~ qualifications is attached. hereto. I have_ personal

- knowledge oi-the matters stated herein and believe them to be true and-correct. I make this affidavit in support of

. Applicants' Motion for Summary Disposition of Contention B.

- !2. Contention B states in part that-a low power or no power'operatis>n at Perry during extreme conditions.of inclement-w.gs h

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k weather has not been included in the emergency plans. The s logic implicit in this part of the contention appears to be

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that (1) evacuation is the only appropriate protective action h in the event of an accident at the Perry plant with significant h B

off-site consequences; (2) evacuation would be impossible during an " immobilizing period of inclement weather" (Sunflower Alliance's August 20, 1984 Particularized Objections, p. 3); [

therefore (3) such an accident must be avoided by requiring low r 5

power or no power during such weather conditions. My affidavit r

addresses the first of these arguments. The Affidavit of Gary a

Winters on Contention B addresses the second issue and the ;_

Affida/it of Kevin Holtzclaw on Contention B the third. ,

3. Initially, it should be pointed out that the kind of L i

blizzard conditions postulated by the contention are typically  ;

associated with high winds. Such high winds would certainly be  !

characterized as Pasquill-type A or B meteorological h conditions, the most favdrable conditions for rapid dispersion -

of a radioactive plume. Rapid dispersion would greatly reduce

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any doses to the public. The dose reduction would range ,

anywhere from factors of 45 to several hundred, as compared to doses calculated using standard NRC design basis licensing f methodology. _

4. As for the argument implicit in the contention on _

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evacuation as the only protective action, this position is inconsistent with NRC regulations, NRC/ FEMA regulatory guidance, and with studies that have been done on protective

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action measures. NRC regulations talk about a " range of prc:.ocive actions," not only of evacuation. 10 C.F.R. -

S 50.47(b)(10). NRC/ FEMA guidance also recognizes a range of protective actions, NUREG-0654, p. 59, and specifically identifies sheltering as an appropriate off-site protective action, NUREG-0654, p. 9, 20, 1-12, 1-16.

5. Sheltering is an effective protection method. EPA studies conclude that sheltering is recommended in at least two types of situations:

1. If the projected dose exceeds the

[ Protective Action Guide] by more than a few-fold, and ... timely evacuation is not feasible (i.e., the time available before cloud arrival is short compared with the required mobilization, warning, and transit time for evacuation), then sheltering is recommended.

2. If the projected dose does not exceed the PAG by more than a few-fold, then sheltering will probably be adequate and economical.

EPA 520/1-78-001, Protective Action Evaluation -- Evacuation and Sheltering as Protective Actions Against Nuclear Accidents Involving Gaseous Releases, Pt. II, 53.

6. Studiesl/ show that the average home will reduce whole body dose by a factor of 2.5 to 3. The degree of whole body dose protection afforded by homes as a function of cloud exposure time tends-to remain relatively constant for cloud 1/ PSR Report 5.15, Pacific-Sierra Research Corp., The Effectiveness of Sheltering as a Protective Measure Against Nuclear Accidents Involving Gaseous Releases, p.

85 ff.

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exposure periods up to several hours because the main source of whole body dose will be gamma radiation from the cloud through the structure. The protection that homes offer from exposure to particulates and iodines will tend to decrease with time (if the cloud is still present), as the cloud concentrations infiltrate into the home.

7. For radiciodines and particulates, the typical home will provide a protection factor from 4 to 10 for representative air change rates and a factor of from 20 to 70 for low air change rates for at least three hours. In the winter time when people have their houses reasonably tightly closed, both the protection factor for particulates and iodines and the length of time sheltering will be effective will be higher because infiltration will be reduced. When houses are tight, as is common in the northern part of the United States, such as the area around Perry, particulates and iodines are partially filtered as they pass through the relatively small cracks which allow outside air to enter the home.

8. Respiratory protection-is another protective action which could further reduce doses for sheltered individuals from inhaled particulates during extremely adverse weather that made evacuation unadvisable. This would involve covering the nose and mouth with such common items as towels, handkerchiefs or toilet paper. Such simple measures can reduce doses from such a release by a factor of about 10. EPA 520/1-78-001, Pt. II at 55.

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'9 For these reasons, sheltering and respiratcry protection are protective acticns which can pecvide substantial dose savinE8 in the event of a radiological release.

$s Richard R. Bowers Subscribed and sworn before ce this 4 day of February, 1985.

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!l Name: Richard R. Bowers, Corporate Health Physicist l

4 Formal Education:

Sachelor of Science in chemistry, The Pennsylvania State Cniversity, 1955

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Experience:

1984-Present: Cleveland Electric Illuminating Company I ~

As Corporate Health Physicist, responsible for overview of operational, engineering, and environmental radiological control programs. Responsible to provide policy, criteria, standards,

1. measurement methodologies, and evaluations for radiological and radiological environmental protection programs and practices.

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1970-1984: NUS Corporation As Manager of the Health Physics Services Department, responsible for management and technical direction / review of radiation protection

' consulting projects for utility clients. Projects included develop-ment of operational radiation protection programs, health ph) sics procedures, radiological emer6cncy plans, health physics training, and decommissioning programs as well as plant /systen ALARA reviews, radiation protection equipnent evaluations, and reviews of health

, physics progchms.

. '1963-1970

Niagara Mohawk Power Ccrporation 4

As Health Physics and Chemistry Supervisor, respcr.sible for setup i  :

and management of the radiation protection program at Nine Mile Point 1. Trained and supervised technicians, administered environ-mental monitoring program, developed radiologi' cal emergency plan, wrote health physica and chemistry procedures, and purchased and n

set up health physics /chenistry equipment.

As Radiological Engineer, assisted in the design of. Nine Mile Point 1. Assisted with general plant layout and designed plant

, shielding. Designed health phycles and chemistry facilities.

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Designed installation details of process and effluent monitcrs.

F 1955-19632. E. I. duPont de Nertours and Co.

As Health Physics Engineer at the Savannah River Plant,-supervised

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technicians in' separations plants,' fuel fabrication facilities, and production reactors.

Professional Memberships Health Physics Society Certification: .

Comprehensive: Health Physics-American Board of Health Physics-1963 Power Reactor Health Physics-American Board of Health Physics-1980

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