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UNITED STATES OF AMERICA

MUCLEAR REGULATORY COMMISSION

In the Matter of .))

DAIRYLAND POWER COOPERATIVE ) Docket No. 50-409) (FTOL Proceeding)

(La Crosse Boiling Water )Reactor) )

AFFIDAVIT OFREGARDING

CONTENTION HO. 8

My name is Thomas A. Steele. I am employed by

Dairyland Power Cooperative (Dairyland) as Director of Environmental

Affairs. I have been employed in this position since 1971. My

professional qualifications are attached as Appendix A to this af-

fidavit.

The purpose of this affidavit is to present written

testimony in support of Dairyland's Motion for Summary Disposition

and the NRC Staff's Amended Motion for Summary Disposition.

Contention No. 8 reads as follows:

CREC Contention No. 8

CREC contends that LACBWR's radiologicalenvironmental monitoring program is in-adequate in terms of

(a) the metilodology of the testing

(b) the size and distribution ofthe sample, and

(c) the frequency of the sampling, inlight of the off-gas levels, the geo-graphy of the area to the east of theplant, and the fact that the area isprimarily a dairy region.

8202040316 920202PDR ADOCK 050004090 PDR

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1. As described in the Table attached as Exhibit 1

to this affidavit, Dairyland's radiological environmental monitor-

ing program for LACBWR complies with requirements of the NRC Staff

Regulatory Guide 4-1, and the practices approved by the U. S.

Environmental Protection Agency.

2. Dairyland's radiological environmental monitoring

program employs standard sampling and testing methodologies for

detection of radioactivity, including gamma isotopic analysis,

gross beta analysis and I-131 analysis. Testing for these elements

is conducted comprehensively and accounts for site specific con-

ditions in the vicinity of the LACBWR area. Dairyland monitors

for radioactivity in the air, surface water, ground water, drinking

water, milk, river sediment, fish, and food. Dairyland's monitor-

ing program has been operated over the past ten years and is

tailored to the local meteorology, growing seasons, topography,

population distribution and agricultural and human activities in

the area.

3 The operation of LACBWR over the past ten years

accompanied by a comprehensive radiological environmental monitor-

ing program, indicates that the size, frequency and distribution

requirements for monitoring established by the NRC have been met

and that exposure pathways are being monitored adequately.9

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4 I have read the foregoing affidavit and swear that

it is true and correct to the best of my knowledge and belief.

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J/ V'~ Lu | w'#

Sworn to and subscribed before me this /4/' day of ,%, da j ,1981.

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Appendix A

Thomas A. SteeleProfessional Qualifications

I am Director of Environmental Affairs for DairylandPower Cooperative.

My formal education consists of a B.S. from the Univer-sity of Wisconsin-River Falls in 1961, and an M.S. from theUniversity of Washington, Seattle, in 1963.

Before joining Dairyland Power Cooperative in 1968, Iwas employed as a Health Physicist for Argonne NationalLaboratory, Argonne, Illinois from 1963 - 1968. At ArgonneI was responsible for radiation protection at various facil-ities including the CP-5 Reactor, Zero Power Plutonium Reac-Lors, Plutonium Fuel Fabrication facility and Zero GradientSynochron. While at Argonne, I published papers on person-nel dosimetry and radiation protection associated withplutonium fuel fabrication.

| Since joining Dairyland Power Cooperative in 1968, Iwas Health & Safety Engineer at LACBWR until 1971, wherethe LACBNR radiation protection program and environmentalsurvey program were developed under my supervision. Since1971, I have been Director of Environmental Affairs for

}Dairyland Power Cooperative. I organized and developed theEnvironmental Department for Dairyland, which is responsiblefor environmental and regulatory functions associated withDairyland Power Cooperative's generation and transmissionsysten.

I am certified by the American Board of Health Physicsand have served on various industry and power pool commit-tees.

Thomas A. Steele

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Eshibit 1 SENSITIVITYSMtPLING SAMPLING ANALYSIS ANALYTICAL DETECTION

SAMPLE SITES METIOD DURATION FREQUENCY PERFORMED PROCEDURES LIMIT *j

Airborne

a. Radio- 7 . samples Constant Flow Continuous Charcoal Isotopic Count Immediately 3sl0'3 pC1/mlodine & !) la Crosse Sampler and Canister Analysim for

Particulates 2) Farm on Ridge to No. Flater Analyzed 1-1313) lock & Das #8 Weekly4) Crib House Continuous Particulate Cross Beta Count After 24-5) Farm on Ridge to Ea. 3Class Faber Filter Activity Hour Decay 2s10' pC1/m6) Trailer Ct. to So.,

g y7) Farm on Ridge to So.

' Direct bosation38 locations Themoluminescent Continuous At least once Camma Vendor I mR/ Quarter

Dosimeter Every 92 Days'

Waterborne

a. Surface 3 Sites Rinse Bucket With Crab Monthly Cross Beta Evaporation And Isl0' pC1/1I) lock & Dan #8 River Water Pull Analysis

f., 2) Boat Launch Area in Sample Making8 3) Victory Sure Bucket Doesn't

Scrape Bottom

b. Drinking Cenoa Flush Line For One Crab At Least Quarterly Cross Dried and Counted Isl0' pC1/11ACBWR Minute. Collect BetaTrailer Court SampleCenoa Fish Hatchery

~Ic. Rain lock & Dam #8 Collec t ion Continuous Monthly Cross Beta Dried and Counted IsIO pC1/1Pedretti F.a r m Container

P. Malin Fara *

Soil

a. River Silt / Plant Intake Sc rape Sediment crab Two Times /Yr. Camma Isotopic Dried and Counted Is10'I PC1/gShoreline Boat launch From Shoreline * Analysis

Sediment Plant outfall Drop Dredge orScoop In River

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Eahibit I (Continued).

SENSITIVITY

SAMPLING SAMPl.1NC ANALYSIS ANALYTICAL DETECTION

SAMPLF. SITES HETHOD DURATION ETEQUENCY PERfDRMED PROCEDURES LIMIT.

Ingestion

a. Milk P. Malin From Proprietor Crab At least Sr-90 Radiocheetcal ! pC1/1

A. Malin B1 Weekly 1-131 Separation

When CousP. PedrettiAre On Pasture

-2b. Fish Mississippi Commercial Crab 81-Monthly Camma c - Isotopic 3 10 pC1/3

River Fish Analysis OnEdible Portions

Dried and Counted

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At Time Of Camuna Dried and Counted 1 10' pC1/3 ;

c. Food Products 3 locations Tsom Propriator CrabHa rve s t . Isotopic AnalysisCiano11 Farm Carden Vegetables ,y

f,da P. Malin Farmi

Broadleaf Vegetation' Pedretti Farm

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