ML19303A293

Comments on Facility DES,NUREG-0813.Environ Pathways Identified in Sections 5.9.3.1,5.9.4.1 & Figure 5.2 Cover All Possible Emission Pathways That Could Impact on Population

ML19303A293
Person / Time
Site:	Callaway
Issue date:	11/12/1981
From:	Villforth J FOOD & DRUG ADMINISTRATION
To:	Youngblood B Office of Nuclear Reactor Regulation
References
RTR-NUREG-0813, RTR-NUREG-813 NUDOCS 8111170337
Download: ML19303A293 (2)

Text

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• lA*g DEPARTM ENT OF HEALTH k HUMAN SERVICES we w g,ng,

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                                                                                                      "!#h            CJ Food and Drug A6 ministration Rockwine MD 20857
                                                              .                                               ;r e                                             #0V121 set Mr. 3. J. Youngblood                         -                            "

Licens~in.g Branch II; lm-I NOV2 O ISSb'-l t Division of Licensing

                                              .U.S. Nuclear Regulatory Commission h     "      Q    gg         ~    ,
 ;                                             Washington D.C.20y55                             c,y                    h}/
                 ..                            Dest Mr. YoungblooN                                        M      #
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The Bureau of Radiological Health staff have reviewed the Draft Environmantal Statement (DES) related to the operation of the Union Electric Co. Callaway Flant, tinit lg NUREC-0813, September 19t!1 (Docket No. 50-483). In our review tit -1s' recognized that. the DES is an administrative action for issu'ance of an operating license. We not ~ Eat (1) the application for con-

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struction of this, plint was received by the NRC on April 30, 1974, (2) the NRC staff evaluation was issued as a Final Environmental Statement - 1 x Construction Phase 13 March 1975, and (3) as of July 1, 1981, construction of Unit 1 wai 7 percent complete. Tha sureau reevaluated the health aspects associated with tha proposed operation of the plant and offers the fo-llwing connents: _7.n 2-

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1. It appears that the design objectives of 10 CFR 50, Appendix I,-Ehe 1 operating standays of,40 CFR 190, and the proposed operat u:. plan ofQ;!Te - l Callaway Plant provide adequcte assurance that the" potential individuaf..; '

and population radiation doses identified 'in the DES meet- current radia- l tion protection standards. ~

                 ,                                  2. The environnental pathway. identified in Sectic'n 5.9.3.1,~Section 5.9.4.1 and Figure 5.2, cover all possible g=ission pathways that could inpact on the population in the environs of the. facility. The dose                                                            ~

l conputational niethodology and node 3s used in the estination of radiation

                                             ._ dose to individuals near the plant and populptions within 80 km. of the plant have provided reasonable artimates of doses resulting from normal
                            , ;. .             operations and accidents. Results of the environmental pathway analysis
                               ,               dose calculations are shown in Appendix C, Tables C.6, C.7. C.8 and C.9, and confirm that the doses neet the design objectives.-                     .                                                      i l

, 3. The Jiscussion in Section 5.9.4 on the environmental impact of por-tulated radiological accidents is considered to be an adequate assessment of the exposure pathways and dose and health impacts of atmospheric and ground vater releases. Section 5.9.4.3 (Emergency Preparedness) indicates that the Callaway Plant, Unit 1, emergency preparedness plan, including j

                                           ~ protective action measures for the plant and environs, is in an advanced, but not fully completed, stage. We vill forego further comment on the                                                               l

emergency plans, realining the process of granting an operating' license

{ to the facility vill include an adequate review of emergency preparedness ) (FEMA - NRC Memorandum of Understanding; Regional RAC's criteria in NCREG-

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i 0654). We have representation on the RAC's, whose evaluation of the emergency planning relevant to the Callaway Plant vill speak fpr this Agency. . 8121170337 B'!!!!2 '

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f Mr. B. J. Youngblood - F.je 2 ,

4. The radio'logtcal monitoring program as presented in Section 5.9.2.4 and summarized in table 5,4 a; pears to provide an adequate sampling fre-quency in. expected ' critical exposure pathways. The parameters measured

, are c6nsidered sufficiently inclusive to (1) measure the extent of emis-sionsfromtheplash,and(2)verifythatsuchemissionsmeetspplicable

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g adiation protection standards. In view of some of the monitoring l

   ~ .;                                 problems during the.Three Mile Island - 2 accident, we suggest that the                                              i operational monitor $,ng plan be modified to address the particular problems p' f                      of socitoring radiolialogens (especially radiciodine) in the presence of radionoble gases. This seuld be acccmplished by reference to FEMA-REP-2,                                        ,
        .                               a document on instrumentation sys*.sms prepared with considerable input                                              '

from NRC.

5. Section 5.10 a^d Appendix G of this DES contain a description of the environmental impact of the Uranium' Fuel cycle (UTC). The environmental 1 -

effects presented are._4 reasonable assessment of the population dose com-I -- - T mitment and health ef.fects associated .with~tlie releae of Raden-222 from r Jhe UTC. There 13 nq mention in Appendix G of EPA's Uranium Fuel Cycle i Standard (40 CFR 190) and cited in paragraph 2, oo page 5-21 of this DES. u A statement shoul'd be # included in this Appendix that the annual dose figuret to membert of the population from allefuel gele operations are within the lints of the EPA standard since it can be supported by the--data

contained in Appendix C and Appendix D. _7..

                                                                                                          ,                                     c Thark. you for the opportunity to review and comment en this Draft Enviionments.1
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Statement. , ,, ~ }-{,_~ . -

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                                                                                                              , Sin:erely yours ,
                                                                                                                                             - {P

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                                                                                                        J.phs,C. Villforth Director Eureau of Radiological Health 9                                                                                                                            .

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