ML19264C329

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Comments on Des for Facilities.Fes Should Indicate Levels of Radiation Which Individual Could Expect to Receive to Substantiate Negligible Impact
ML19264C329
Person / Time
Site: Byron  Constellation icon.png
Issue date: 01/18/1982
From: Backley B
ENVIRONMENTAL PROTECTION AGENCY
To: Youngblood B
Office of Nuclear Reactor Regulation
References
NUDOCS 8201250220
Download: ML19264C329 (3)


Text

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5ED 8 UNITED STATES fgg ENVIRONMENTAL PROTECTICN AGENCY R E GION.V W

230 sOU,TH oEARBORN ST.

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CHICAGO. ILUNO'S 60004 k payW C3 REPLY TO ATTENTION 05:

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f JAN 2 21982> di Mr. B. J. Youndblood, Chief gim m sem I c Ja IIE2

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Licensing Branch e=nx ucum n 9

Division of Licensing U.S. Atomic Energy Commission g

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Washington, D.C.

20555 ro RE: NEPA-D-NRC-F060ll-IL (81150)

Dear Mr. Youndblood:

We have completed our review of the Draf t Environmental Impact Statement (EIS) related to the Operation of the Byron Station Units 1 and 2 near Byron, in Olge County, Illinois. Construction of Unit 1 is approximately 80% complete and fuel loading will begin in April 1983, and construction of Unit 2 is approximately 60% and fuel loading will begin in April 1984.

Impacts related to construction of the station have already been addressed in the past draft and final environmental impact statements related to the construction permit. Our attached comments on this environmental impact statement concern the radiolog; cal impacts to man and his environment due to operation of the facility and our major concern is related to the need to complete tne Radiation Emergency Response Plan.

We appreciate the opportunity to review this environmental impact statement.

In accordance with our responsibility to inform the public of our views on other agencies projects, the date and classification of our comments will be published in the Federal Register. We have rated our attached comments re-lated to the facility as ER (Environmental Reservations) and classified the environmental impact state ient as Category 2 (Additional. formation Necessary).

We will continue to have environmental reservations on the issuance of an operating permit for this station until the Radiation Emergency Response Plan has been completed. When the Final Environmental Impact Statement and the Safety Evaluation Report are published, please forward three copies to us.

Sincerely yours, f

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Bar bara Taylor Ba kley, Actinglhief Environmental Review Bramh Planning and Manacement ! vision

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Amaurevr P nttachment f0 8201250220 820118 f

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Environmental Protection Agency, Region V Comments. on the Draft Environmental Impact Statement Related to the Operatioin~ of the Byron Station, Units 1 and 2 Radiological Impacts Exposure Pathways:

The environmental impact statement indicated there were seven public water supplies, within ten miles of the Byron Station, which use groundwater sources.

However, it is also indicated it was not necessary to evaluate the drinking water pathway to the determine the exposure of persons outside the site boundries.

It is unclear how there can be seven public water supplies within ten miles of the station, and no consideration of the drinking water pathway. The final environmental impact statement should discuss the reasoning for not assessing the drinking water pathway.

Radiological Impacts cn Man:

This station will have to limit radioactive releases to the environment to those specified in 40 CFR 190. Since this station is not an operating station, infor-mation on how other similar stations operated by the Commonwealth Edison Company have complied with these regulations should be provided. The final environmental impact statement should indicate under what, if any, circumstances compliance with the regulations will not be achieved.

The environmental impact statement indicated the natural background radiation levels are approximately 100 millirems per year and releases from the Byron Station will be so minute in comparison as to have no measurLble radiological impact on members of the public. The final environmental impact statement should indicate the levels of radiation which an individual could expect to re-ceive from the Byron Station to substantiate negligible impact.

General Characteristic of Accidents:

We suggest that the environmental impact statement include a map which shows the Exclusion Area, Low Population Zone, Emergency Planning Zones, etc. This would provid_ an indication to the general public where these areas are in relation to their town, homes, schools, etc.

A full review of the Radiction Emergency Response Plan for the. Byron Station has not been completed, tested or reviewed by the Federal Emergency Management Agency (FEMA) and the Regional Advisory Committee. We note that a thorough evaluation of the ability of all parties to handle accidents is not possible at this time, and will have to await future actions by FEMA.

Accident Risk and Impact Assessment:

Section 5.9.4.5, part 5 discusses the potential releases to the groundwater if an accident occurred at the Byron Station. This section compares the explosure doses from the Byron Station to the Liquid Pathway Generic Study (LPGS) for floating nuclear power stations. Comparison of exposure doses for drinking water pathway, shoreline exposure and fish ingestion were made between the Byron Station and the LPGS small river site; i.e., (1) the drinking water population dose would be about 130 percent of the LPGS small river site, (2) the shoreline exposure dose would be a factor of three higher than the LPGS small river site, and (3) the fish ingestion pathway would be a

factor of 24 times greater than that of the LPGS small river site. The direct addition of these three pathways for the Byron Station, provides a factor which is almost 30 times greater than the LPGS small river site.

The Final Environmental Impact Statement should discuss why the staff believes "a factor of about three times higher than those of the LPGS small river site", in light of the above figures, was selected and determined to be conservative.

Radiological Monitoring:

The environmental impact statement indicated that once the final monitoring programs go into effect, some adjustments of sampling frequences and the deletion of some types of samples will occur. One of the programs to be discontinued is vegetable sampling. We assume the reason for stopping this monitoring program is because there are no vegetable farms near the Byron Station,but the final environmental impact should indicate the reason why vegetable monitoring will cease.

Decommissionino:

A statement should be made here thac decommissioning of a commercial nuclear power plant has not yet occurred in this country, even though the technology may be available to handle it. Therefore, this section should reflect this as a judgement of the Nuclear Regulatory Commission staff, not as an accom-plished event.