ML19303A294
| ML19303A294 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/24/1981 |
| From: | Bolef D WASHINGTON UNIV., ST. LOUIS, MO |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0813, RTR-NUREG-813 NUDOCS 8111300205 | |
| Download: ML19303A294 (2) | |
Text
,
e g-UNIvERSITT WA5HINGTON Q
s T. Louis, utssocat essao
,3 :1-s November 24, 1981
' &( )
1 m o r m t o, m v.,p.
Nuclear Resulatory.Commissione Office of Nuclear Reactor Regulations
(:.
- d. OV3 01981> e 1717 H Street, N.W.
% "" w"' N Washingotn, D.C. 20555 e
s r
- Gentlemen / Ladies:
tt
,g
=
I subrait belcw several comments relative to Draft Environmental-Statement
'(NUREG-0813)
. related,-to the oper: tion of - ~
T CalIaway Plant,
' Unit'- No t 1
=,
Docket No. 50-483 s
Page 5-34, Paragraph beginning,. " Radioactive forms of iodine....". ' The implications are that rainfall during an iodine release, or the presence of water (e.g. dew),. decreases the ha:ards to humans and animal.s.
(Note the misuse of the word "also" in thi tllowing ser.tenc-e). The converse may in fact be true; concentration of radioactive iodir.& on nearbye pastures or built-up areas may expose humans and animals to much higher c,oncen-grations then if the iodine tadeb'een dispersed over larger areas.
9,_.
I
.?
Page 5-35, Paregnph beginning, "All of these radicactive materials...".
It is mis-leading to cnaracterize the half - lives of the radionuclides in Table 5.5 as " ranging frca fisctions of a s'econd to rany days or years." An accurate statement woul.d sur read
. t,
. " ranging from less than an hour (I-134, 0.0266 day's} to over 2000 years (Pu-239; 8 3,900,000 days)." The inrcssion is left with the reacer, further, that it is the i life which is a correct ceasure of time during which the radionuclide is dangerous, whereas in practice one uses apprcxirately ten i lives, l
\\
Page,5-37, Paragraph under "Healt'. Effects Avoidance." This paragraph is grossly mis-leading and the last two sentences snoulo ra completely rew~ itten. The "possible (!)
r cons'equential environmental societal impact of severe accidents" is indeed'the resulting health hazard and not, as the authors tortuously write, "the avoEnce of the nealth nazard" or the "poTeiitial (!) economic impacts". The emchasis on " economic" effects l'
rathat than on actuc1 health effects indeed permeates - and distorts - this entire 3 ' fore, tha [See, for another example, the sentence on page 5-54, third paragrap "There-document.
consequences would be largely economic or social rather than radiological."
This is gratuitous nonsense, and the sentence should be eliminated or reworded to rake
, sense..).-
'4 goo 911130C205 811f24 p
PDR f, o PDR ADOCK 05000483 7.
s.
4 Nuclear Reguldtery Comissio.n, Nov. 24,1981 2'
page S-6_2, Section 5.11 DecomIssioning.
Every sentence. in t!ris haragraph, with possible exception of the last, is fallbcious.
Taking these misleading sentences one at a time:
(1) -This is a-non; sentence, 'since it avoids the main point, which is that decomissioning involtres substantial and extensive environmental impact, affecting (potentially) large nu bers of people. _These.arerlisted in any number of well-known references, a rather recent one being the article by J. A. Sefeik in Technology Reviews, June / July 1979.
.. Especially noteworthy - and' unique to this specific activity - is the generation, during dismantling, of radioactive dust, as well as the intensive exposure of workers, and the high public exposure to radioactivity during transportation.
'~~
(ii) f NOT' Nwell in hand..",
"The technology for deco ~ aissioning nuclear facilities is n
A g
since no large-ccamercial-nuclear reactor has ever been decommissioned, and the current
-hsretofor suspe! experience witt TPI ihdi. gates that the task is muchy.one compicx anc difficult.t k.-
cteo.
... can.be performed... at reasonable cost"is entirely misleading, since in several instances %e' cost of cicanup/decomissioning has equaled or exceeded the cost of building the fa.cility --- e.g. Elk River, Dresden, THI, West Valley (projected).
(iii) " Radiation doses'... shculd be very small..." Actually, they should be very large comoared to the radiation' release during normal operation of the plantQ6e sources of radiation art 1istEd in many sources; I list only three in Paragraph (41) a e.
3 div)
Radiation doses to decomissioning workers...." Both porttions of tttis i.entence are incorrect. From the experipnces at TMI, West Valley, etc. we know ~(d.)~ thatyhe ~
(
nazards to workers are so extreme that only a few minutes exposure are enough toaive D
a yearly allowed use, and (b) that in many instances the regulatcry guideline (have
~
teen exceeded.
Sincerely /ours, Q
"7.
V y
Dan I. Bolef -
}
Professor of Physics DIB fmh
-o
~,
J l
l
.)
1
,