ML17340B044
| ML17340B044 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/22/1981 |
| From: | Branagan E Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17340B043 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8104230618 | |
| Download: ML17340B044 (26) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING'OARD In the Matter of FLORIDA POWER 8
L'IGHT COMPANY (Turkey Point Nuclear Generating Units 3 and 4)
Docket Nos.
50-250-SP 50-251-SP (Proposed Amendments to Facility Operating License to Permit Steam Generator Repairs)
AFFIDAVIT OF EDWARD F.
BRANAGAN, JR.
ON CONTENTIONS 3
AND 6 I, Edward F. Branagan, Jr.,
being duly sworn, state as follows:
l.
I am employed by the U.S. Nuclear Regulatory Commission as an Environmental Scientist in the Division of Systems Integration, Office of Nuclear Reactor Regulation.
2.
Contention 3 states:
During the course of the repairs proposed by the Licensee, (a) the hardling, processing, storing or discharing 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 is reasonably achievable within the meaning, of 10 CFR Parts 20 and 50.
3.
Contention 6 states:
The cumulative o$fsite radiation releases as a result of the activity at Turkey Point, during the proposed repair, do not comply with 10 CFR Parts 20 and -50.
4.
I have reviewed the statements of facts accompanying the applicants April 8, 1981 motion for summary disposition of contentions 3 and 6, and concur with these facts.
ii
5.
I prepared Section 4.1.2.1'and accompanying Table 4.5) and Appendix A of the Final Environmental Statement (FES)
(Attachment 1) related to the Turkey Point steam generator repair (NUREG-0743) dated triarch, 1981,and the March 27, 1981 Staff Safety Evaluation Report regarding conformance with Appendix I to 10 CFR Part 50 (Appendix I SER), in whole or substantial part.
Their contents are true-and correct to the best of my knowledge and I hereby adopt them as my direct testimony on contentions 3 and 6.
6.
In regard to contention 3, Section 3.9 of the Technical Specifications contains specifications to assure that radioactive effluent releases to un-restricted areas from normal operations and the steam generator repair are within the limits referred to in 10 CFR Part 20.106.
Section 3.9 contains both quarterly and instantaneous release limits.
Our analysis, as presented in the FES, indicates that radioactive effluents from the steam generator repair sho"ld be well below the radiological technical specification release limits.
The estimated quantities of radioactive effluents from the repair are less than the quantities that were estimated at the time of initial plant licensing (see Table 4.5 of the FES).
The "as low as reasonably achievable" (ALARA) guidelines of 10 CFR Part 50 Appendix I apply only to normal reactor operations.
There are no quantitative limits placed on the ALARA guidance of 10 CFR 20.1(c) for the repair.
Nonethe-
- less, we di'd an independent determination to see whether these guidelines were met.,
In Appendix A of the. FES, we demonstrated that the anticipated radioactive
~i
. ~
~
i
effluent releases to unrestricted areas from the repair were ALARA by showing that the estimated doses from exposure to anticipated radioactive effluents from the repair are less than the Appendix I guidelines.
Radiological releases from the repair to unrestricted areas should result in radio-nuclide concentrations in air and water that are within the permissi b'.e levels referred to in 1'0 CFR Part 20.106.
7.
In regard to contention 6,
we demonstrated that cumulative releases Ko un-restricted areas from the site were ALARA by comparing the estimated doses from exposur e to radioactive effluents from the repair of one unit and normal operations of the other unit (see FES, 54.1.2,.1 and Appendix A) to the ALARA guidelines for normally operating plant si.tes given in the Annex to Appendix I to 10 CFR 50.
Edward F. Branagan, Jr.
Subscr ibex'nd sworn to before me thisgg "~day of cX, 1981 No arv Pu ic Ny Commission expires.
Attachment:
FES, Section 4.1.2.1 5 Appendix A
0 0!
~
1
FES, March,1981
- 4. l. 2. 1 Doses from Eff1 uents Public radiation exposure from the Turkey Point steam generator repair can be estimated by comparing the estimated quantities of radioactive effluents from the steam generator repair with annual average releases and dose estimates from nor.mal operations at Turkey Point.
Estimates of the gaseous releases
.and liquid releases" of radioactivity from the steam generator repair at Turkey Point can be obtained from three sources:
. (1) the generic report (Ref. 5)'repared by PNL for NRC, (2) estimates made by FPL (Ref.
- 1) for the steam generator repair, and (3) measured releases from the steam generator repair at Surry Unit 2 (Ref.
16).
Estimates of annual average releases and doses are documented in the Turkey Point FES (Ref. ll).
Radioactive effluent releases from the steam generator repair and normal reactor operations are given in Table 4.5.
In general, the estimated quantities of radioactive effluents from the repair from three sources of information (Refs.
1, 5,
- 16) are less than the releases from one year of noir,al operations at Turkey Point.
The Turkey Point FES (Ref. ll) did not contain separate estimates of the quantities of airborne particulates and tritium.
However, the present review of the dose estimates in the FES (see Table Y-6) indicates that airborne effluents contributed a small fraction of the.estimated total dose to individuals '(i.e.,
less
- than, 5% of the total body dose for the highest dose pathways of exposure to individuals in the general public).
Therefore, the total cumulative doses to maximum individuals from the steam generator repair at Turkey Point will be no greater than, the doses estimated in the Turkey Point FES resulting from one year of operation.,
The Turkey Point FES estimated an annual total body dose of about 6
mi em, and a highest annual'ose to any organ of about 16 mrem (thyroid) fromm the operation of Units 3 and 4.
Consequently, the.total cummulative dose to the "maximum 'individual" from radioactive effluents released during the steam genei ator i epair of one unit should be less than about 3 mrem and 8 mrem to the total body and thyroid, respectively.
Since the estimated dose to the
~The pr>mary sources of liquid releases during the ste=-e generator repair are the possible release of the primary reactor coolant and the laundry waste water (Ref. 5).
These souices of liquid releases have been included in the liquid release estimates fi om steam generator repairs in Table 4.5 (e.g.,
see Ref.
1).
4-8
0
Figure 4.1 Exposure Pathways to t1an GASEOUS EFFLUENT NUCLEAR POWER PLANT 0
50
/
'P.
o O
0 Q
, 0C O
O O'o O
0 Igat')on gage
~o O
C hll s ll(g~ggge/Pp e/g eQQo idge%
<~Q~~
c c9 eh6%W Direct Irradiation Shoreline p"Poru W
0 LIQUID EFFLUENT 0
,V 0',
e e &
)
4-9
Table 4.5 Radioactive effluents from steam generator repairs and normal operations Radioactive effluents Steam generator repairs (Ci/unit)*
Normal operations (Ci/yr/unit)4 Estimates Measured FES estimates Type of radioactive effluent FPL NUREG/
CR-1595 Surry Unit 2 Annual average Measured Parti cul ates Tritium 0.0428 Negligible Airborne Noble gases Negligible Hal ogens (iodines)
- 0. 0105 100 Included in 0.0000069 particulates 0.00021 4.3 3650 0.80 8700 0.3
- 0. 025 2.1 Li<iuid Mixed fission and activation products Tritium
- 0. 55 185
- 0. 23 190 0.5 8.5 2&
1000 3.4 415 "Values for radioactive effluents from steam generator repairs ar'e taken from References 1
(Section 5.2.2),
4 and 5.
tValues for radioactive effluents from normal operations are taken from References ll, 17, and 18.
The measured effluents from normal operations are average values based on effluent monitoring for the years 1975-1977.
O'The FES (Ref.
- 11) value includes both iodines and particulates.
r.;>ximum individual from the repair work is a small fraction of both the annual do.'e (about 80 mi.em, including internal emitters, Ref.
- 19) and lifetime doses (about 5200 mrem) from exposure to background radiation in the Florida area, we conclude that the dose to individual's offsite due to radioactive effluents from the repair work will not be environmentally significant.
The FES (Ref. ll) for Turkey Point (Table Y-7) estimated an annual total body dose to the population within 50 miles (about 2. 1 million) of about 12 person-rem from operation of Units 3 and 4.
Since the effluent releases from the steam generator repair for each unit are less than those estimated in the FES for normal operation of one unit, and even allowing for a 50X increase in population, the population dose from the repair effort should be less than about 9 person-rem to the total body.
Since the population dose from the repair work is a small fraction of both the, annual population dose (about 240,000 person-rem) and'he lifetime population dose (about 16,000,000 person-rem) from exposure to back-ground radiation, the staff concludes that the dose to the offsite population within 50 miles due to radioactive effluents from the repair work will not be environmentally significant.
Since the publication of the Draft Environmental Statement (Ref. 20), the staff has compared the estimated doses from normal operations at Turkey Point Units 3 and 4 with the 10 CFR 50 Appendix I dose design objectives (Ref. 21). 'n
- addition, the NRC staff has made detailed calculations of doses to the maximum individual and the population from radioactive effluents from the steam generator repair (see Appendix A).
The detailed calculations confirm that the doses from the steam generator repair are very small fractions of background radiation.
In addition, the estimated doses from the steam generator repair are below the dose design objectives of 10 CFR 50 Appendix I.
Risk due to radiation exposure of the general public at the dose design objectives of 10 CFR 50 Appendix I are discussed in more detail in Appendix B.
J
APPENDIX A COh1PARI SON OF OFFSITE ESTIMATED DOSES FROM THE STEAM GENERATOR REPAIR WITH 10 CFR 50 APPENDIX I DESIGN OBJECTIVES This appendix (Tables A-l, A-.2, and A-3) contains estimates of cumulative doses to offsite individuals and offsite populations from exposure. to radioactive effluents released from the proposed steam generator repair at Turkey Point Units 3 and 4.
Doses were estimated using the GASPAR and LADTAP II computer codes (Refs.
1 and 2).
Estimates of the quantities of radioactive effluents from the steam generator repair were taken from Tables 5.2-2 and 5.2-6 of Reference 3.
Estimates of the risk due to radiation exposure of the general public are given in Appendix B.
The cumulative dose to'the maximum individual from exposure to radioactive effluents from the steam generator repairs is compared with the 10 CFR Part 50 Appendix I annual dose design objectives for one reactor unit in Table A-2.
The estimated cumulative dose to the maximum individual from exposure to radioactive effluents from the steam generator repair is less than the 10 CFR Part 50 Appendix I annual dose design objectives for one reactor.
The dose to the maximum individual from exposure to radioactive eff'luents from the repair of one.reactor unit while the second reactor unit is operating for the entire year is compared with the -RM-50-2 annual dose design objectives for a reactor site in Table A-3.
The estimated cumulative dose to the maximum individual from exposure to radioactive effluents from the repair of one reactor unit while the second reactor -unit is operating for the entire year 15 less than the RM-50-2 annual dose design objectives for a reactor site.
0
Table A-1 Dose commitments to a maximum individual near the Turkey Point Station Location Pathway Dose commitment from steam generator repair Noble gases in gaseous effluents*
Total body Skin Gamma air dose Beta air dose (mrem/uni t)
(mrem/uni t)
(mrad/uni t)
(mrad/uni t)
Nearestt s ite boundary Direct radi ation (0.36 mi, SE)¹ from plume
<0. Ol
<0. 01
<0. 01
<0. 01 Iodine and particulates in gaseous effluents Total body Thyroid (mrem/unit)
(mrem/unit)
Other organ (if >10X of dose,'mrem/unit)
Nearestg residence (5.0 mi, W)¹ Ground deposit**
Inhalation Vegetation Milk (infant)
Heat
- 0. 03
<0.01
<0.01
<0.01
<0. 01
- 0. 03
<0. 01
- 0. 02
- 0. 43
<0. 01 Liquid effluents Total body Other organ (if >>10K (mrem/unit) of dose, mrem/unit)
Recirculating water canal Fish ingestion Invertebrate ingestion Shoreline
- 0. 10
- 0. 14
- 0. 04
- 0. 03 0.27 0.27 "The doses for gaseous effluents presented in this table and Tables A-2 and A-3 are corrected for radio-active decay and cloud depletion from deposition, where appropriate, in accordance with Regulatory Guide 1 ~ 111, Rev.
1, "Methods for Estimating Transport and Dispersion of Gaseous Effluents in Routine Releases from Light Water Reactors,"
July 1977.
t"Nearest" refers to that site boundary location where the highest radiation doses due to gaseous effluents have been estimated to occur.
¹To convert mi to km, multiply by 1.6093.
$ "Nearest" refers to the location where the highest radiation dose to an individual from all applicable pathways has been estimated.
""To a receptor.
4>>
i
Table A-2 Calculated dose commitments to a maximum individual and the population from the steam generator repair at the Turkey Point Station Dose per reactor unit repaired (maximum individual dose)
Source of exposure Appendix I Calculated design objectives*
dosesg Liquid effluents Dose to total body from all pathways Dose to any organ from all pathways (1 iver)
Noble gas effluents (at site boundary)
Gamma dose in air Beta dose in air Dose to total body of an individual Dose to skin of an individual Radioiodines and particulates¹ Dose to any organ from all pathways (infant thyroid) 3 mrem/yr
10 mrem/yr 10 mr ad/yr 20 mrad/yr 5.mrem/yr 15 mrem/yr 15 mrem 0.37 mrem 0.44 mrem
<0.01 mrad
<0. 01 mrad
<0. Ol mrem
<0.01 mrem 0.5 mr'em Population doses within 80 km (person-rem)
Natural radiation background) one year Liquid effluents Nobel gas effluents Radioiodines and particulates Total body 240,000 1.1 1.2 Thyroid 0.3
<0. 1 2.5
- Appendix I design objectives from Sections II.A, II.B, II.C, and II.D of 'Appendix I, 10 CFR Part 50, considers doses to maximum individuals and populations per reactor unit.
From Fed.
Reg.
V. 40, p.
- 19442, May 5, 1975.
tSee footnote" of Table A-l.
¹Carbon-14 and tritium have been added to this category.
5"Natural Radiation Exposure in the United States,"
U.S.
Environmental Protection Agency, ORP-SID-72-1, June 1972; using the average Florida state background dose (about 80 mrem/yr) and year 2000 projected population of 3,030,000.
A-3
4~
Table A-3 Calculated dose commitments to a maximum individual from operation of one reactor unit and steam generator repair at the second reactor unit An'nual dose per site Calculated doseg Source of exposure RM-50-2 Unit operating design objective*
for one year¹ Unit repair Total Liquid effluents Dose to total body or any organ from all pathways, mrem Noble gas effluents (at site boundary)
Gamma dose in air, mrad 8eta dose in air, mrad Dose to total body of an individual, mrem Dose to skin 'of an individual, mrem Radioiodine and particulatesg Dose to any organ from all pathways, mrem 10 20 5
15 15 2.5 5
10.
2.5 7.5 7.5
- 0. 44
<0. 01
<0. 01
<0. 01
<0.01 0.5 2.9 5
10 2.5 7.5 "Guides on Design Objectives proposed by the NRC staff on February 20, 1974, consider doses to individ-uals from all units on site.
From "Concluding Statement of Posi.tion of the Regulatory Staff," Docket No.
RN-50-2, February 20, 1974, pp.25-30, U.S.
Atomic Energy Commission, Washington, D.C.; also pub-lished as Annex to Appendix I to 10 CFR Part 50.
tSee footnote* of Table A-l.
¹Oose estimates from normal operations are taken as one-half of the RH-50-2 annual dose design objective.
)Carbon-14 and tritium have been added to this category.
'l
'I(
References 1.
K.
F.
- Eckerman, F. J.
- Congel, A.
K. Roecklein, W. J.
- Pasciak, "User's Guide to GASPAR Code,"
USNRC Report NUREG-0597, June 1980."
2.
D.
B. Simpson, B.
L. McGill, "User's Manual for LAOTAP II-A Computer Program for Calculating Radiation Exposure to Man from Routine Release of Nuclear Reactor Liquid Effluents,"
USNRC Report NUREG/CR-1276, May 1980. "
3.
Florida Power and Light Company, "Steam Generator Repair Report--Turkey Point Units 3 and 4," Docket Nos.
50-280 and 50-281, September 20,
- 1977, and Revisions 1 through 7, dated December 20, 1977;, March 7, April 25, June 20, August 4, 1978, January 26,
- 1979, and March 28, 1980, respectively. **
- Avail'able for purchase from the NRC/GPO Sales
- Program, U.S. Nuclear Regulatory Commission, Washington, DC
- 20555, and the National Technical Information Service, Springfield, VA 22161.
"*Available in NRC Public Document Room for inspection and copying for a fee, 1717 H Street, NW, Washington, DC 20555.
A-5
~ ~
EDWARD F.
BRANAGAN PROFESSIONAL UALIFICATIONS I
am an Environmental Scientist with the Radiological Assessment Branch in the Office of Nuclear Reactor Regulation.
Presently, I am responsible for evaluating the environmental radiological impacts from nuclear power reactors.
In particular, I
am responsible for evaluating radioecological models and health effect models for use in reactor licensing.
I have been with the Radiological Assessment Branch for about 2 years.
I received a B.A. in Physics from Catholic University in 1969, an H.A. in Science Teaching from Catholic University in 1970, and a Ph.0.
in Radiation Biophysics from Kansas University in 1976.
While completing my course work for my Ph.D., I was an instructor of Radiation Technology at Haskell Junior College.
My research work was in the area of DNA base
- damage, and was supported by a U.S. Public Health Service traineeship.
Hy dissertation was entitled "Nuclear Magnetic Resonance Spectroscopy of Gamma-Irradiated DNA Bases."
Since joining the NRC in 1976 I have been with both the Office of Nuclear tiaterial Safety and Safeguards (NNSS),
and with the Office of Nuclear Reactor Regulation (NRR).
In NHSS I was involved in project management and technical work.
I was the project manager for two contracts that the NRC had with Oak Ridge National Laboratory.
These contracts were concerned with estimating radiation doses from radon-222 and radium-226 releases from uranium mills.
As part of my work on NRC's Draft Generic Environmental Impact Statement on Uranium tlilling (DGEIS), I calculated health effects from uranium mill tailings.
Upon publication of the
- DGEIS, I presented a paper entitled "Health Effects of Uranium Mining and Milling for Commercial Nuclear Power" at a Conference on Health Implications of New Energy Technologies.
Since joining NRR, I have worked on several projects:
(I) managed and main author of a report entitled "Staff Review of
'Radioecological Assessment of the Whyl Nuclear Power Plant'"
(NUREG-0668),
(2) served as a technical contact on an NRC contract with Argonne National Laboratory involving development of a computer program to calculate health effects from radiation, (3) served as a technical monitor on an NRC contract with Idaho National Engineering Laboratory involving estimated and measured concentrations of radionuclides in the environment; (4) served as a technical monitor on an NRC.contract with Lawrence Livermore Laboratory concerning a
literature review of values for parameters in terrestrial radionuclide transport models; and (5) served as a technical monitor with Oak Ridge National Laboratory concerning a statistical analysis of dose estimates via food pathways.
4i