ML19290E261

Forwards Radiological Monitoring Info in Response to 800125 Suggestion Re Radiological Monitoring Program.Program Cost Unjustified.Annual Repts on Results of Radiological Environ Monitoring Program Available in Lpdr

ML19290E261
Person / Time
Site:	Diablo Canyon
Issue date:	02/20/1980
From:	Harold Denton Office of Nuclear Reactor Regulation
To:	Forbes B AFFILIATION NOT ASSIGNED
Shared Package
ML16340A826	List: ML16340A825 ML19290E261
References
NUDOCS 8003100030
Download: ML19290E261 (6)

Text

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UNITED STATES j

NUCLEAR REGULM CRY CO.*/o.*iSMON c

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FEB 2 0 1980 Mr. Bert E.. Forbes 2415 Leona Avenue San Luis Obispo, California 93401

Dear Mr. Forbes:

Your letter of January 25, 1980, to Chainnan Ahearne, and others, has been directed to me for reply.

The plan described in ycur. letter shows considerable thought and creativity on your part, and you are to be commended for your effort.

The type of monitoring program you sugcest is certainly more rigorous than the one approved by the Nuclear Regulatory Commission (NRC) and pursued by Pacific Gas & Electric Company (PG&E). However, we do not agree that the costs of such an effort can be justified.

In our judgment, your entire proposed program cannot be justified by balancing of public costs and benefits.

However, we strongly endorse most of parts 1, 2 and 3 of your proposed plan, and indeed already have received commitments fran PG&E for them as a condition of granting a license to operate the Diablo station.

Howeve r, we take exception with "high altitude air radiation counts" and samples of

" mother's milk". While it is not clear now high in altitude you would like to measure radioactivity in air, we do not feel it is justifiable to make measurements where radioactivity released fran the plant cannot physically be present, nor where any member of the public does not reside. Howeve r, recognizing that atmospheric releases fran the Diablo station are below the elevation of the surrounding hills, PG&E will monitor airborne radioactivity by various means at the existing 28 stations, and add several additional stations prior to issuance of an operating license.

A copy of the existing radiological environmental monitoring network is enclosed for your i nfo rmation.

In the case of food crops and cow's milk, every close-in site which produces edible crops will be sampled.

In most cases these locations have a baseline of data going back to about 1970. Annual surveys are required as a condition of licensing so that ned locations can be added if it appears desirable.

The same is true for c:w's milk, altho"gh the nearest dairy cow is presently over 10 miles fran the plant.

For that reason, it is extremely doubtful that routine releases will ever be detected in cow's milk.

In the case of mother's milk, it is doubtful a meaningful sampling program could ever be established for a number of reasons including a lack of lactating women who would volunteer to provide significant amounts of milk on a regular schedule.

N any case, other environmental samples such as airborne iodine and #,odcrop analysis will provide an ea.rly indication of potential human exposure.

8003100030

"c. ?ert E. Forbes 2

Finally, in the very unlikely event of a serious accidental release of radioactivity, additional monitoring stations would be set up and samples would be collected and analyzed by numerous agencies in addi-tion to PG&E samples. Whole body counting of a significant number of people fran the public (e.g., similar to the program at Three Mile Island after the accident) is also very likely if a serious accident at Diablo did occur. However, we do not believe it would be cost effective to require a utility to carry out a preoperational whole body counting program at an annual cost in excess of $100,000 when sampling of the human food chain (e.g., milk, crops, etc.) are a more sensitive means of assuring that no buildup of radioactivity is occurring in the environment.

In the case of monitoring cancer-related disease and death in the county, such infomation is already being collected by local, state, and federal agencies and has been for many years.

In addition, there is no scientifically valid reason to believe that the small radiation doses expected to be received by the public could possibly result in any measurable effect on current or future cancer statistics.

In the unlikely event of a serious accident, such studies could be carried out starting with the baseline data already being collected.

All of the preceding discussion is supported by the fact that nomal variations in naturally occurring background radiation are many times greater than the anticipated average doses to the population around the pl a nt.

It should be understood that PG&E is free to have an independent labora-tory analyze their environmental samples. However, the Nuclear Regulatory Commission does not have the legal right to make such demands as long as PG&E maintains their own analytical capability at a level conparable to those of other state-of-the-art independent laboratories.

At the present time, the PG&E laboratory facilitie.s:

(1) meet the NRC requirements for sensitivity and precision, (2) participate in a federal quality assurance program sponsored by the Environmental Protection Agency, and (3) are frequently checked by NRC and State inspectors. We are, therefore, confident that the PG&E program is adequate to assure the protection of the public. However, to provide backup and confimation for the PG&E program, it is probable that additional radiation monitors will be deployed by the NRC around the Diablo Canyon site sometime soon.

"r. ?ert E. rcrbes 3

The annual reports on the results of the Diablo Canyon radiological environmental monitoring program are provided to, in addition to the NRC, your local public document room (LPOR) at California Polytechnic State University Library, Documents and Maps Department, San Luis Obispo, California 93407. They may be reviewed there by any member of the public.

Thank you for your suggestions.

Sincerely, Cr& si-m,

L ;'l, J. wn j Harold R. Denton, Director Office of Nuclear Reactor Regulation Enc'osure:

Diablo Canyon Radiological Environmental Monitoring Mstwork

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Site, i; orth of Station 19 290 0.3 3

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Site, N.E. Batch Plant 125 0.6 7

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Morro Bay Power Plant 358 11.2 10 Sunnyside School 10 6.9 11 Los Osos School 36 7.6 f.

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