ML20005B196

Provides Comments Re Health Aspects of Des NUREG-0769. App I to 10CFR50 & Operating Plan Provide Adequate Assurance That Radiation Exposures Meet Current Radiation Protection Stds

ML20005B196
Person / Time
Site:	Waterford
Issue date:	06/29/1981
From:	Villforth J FOOD & DRUG ADMINISTRATION
To:	Miraglia F Office of Nuclear Reactor Regulation
References
RTR-NUREG-0769, RTR-NUREG-769 NUDOCS 8107060453
Download: ML20005B196 (2)

Text

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, :s g DEPARTMENT OF HEALTH 8t HUMAN SERVICES 80282 Public Health Servi 5 Food cnd Drug Administration ,

% Food and Drug Administranon Rockville MD 20557 JUN 2 91981

$r. Frank J. Miraglia, Acting Chief Licensing Branch No. 3 Division of Licensing - NRR U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Miraglia:

Staff of the Bureau of Radiological Health of the Food and Drug Adminstration have reviewed the health aspects of the Draft Environmental Statement (DES) relating to operations of the Waterford Stream Electric Station, Unit 3, NUREG-0779, April 1981.

In reviewing the DES for Waterford-3, it .is recognized th tt a DES is an administrative action for the eventual issuance of an operating license. DHHS comments were provided on the Draf t DES - Construction Phase in January 1973 (Appendix B-13 and B-14, pages B-120-121), prior to issuance of the construction permit in November 1974. We note that as of February 1981, the construction of Waterford-3 was 83 percent complete. Bureau of Radiological Health staff have reevaluated the health aspects associated with the proposed operation of the plant and have the following comments to of fer:

1. It appears that the design objectives of 10 CFR 50, Appendix I, and the proposed operating plan of Waterford-3 provide adequate assurance that the potential individual and population radiation exposures meet current radiation protection standards.

2. The environmental pathways identified in Section 5.9.1 and Figure 5.7 on page 5-27, and discussed in Appendix D, as well as pages B-61-65 of Appendix B of the . Final Environmental Statement - Construction Phase, give all the possible emission pathways that could impact on the population in the environs of the facility. The dose computational methodology and models used in the estimation of the radiation doses to individuals near the plant and to populations within 80 km. of the plant have provided a reasonable estimate of the projected doses resulting from normal operating conditions as we)1 as hypothetical accident situations at the facility. Results of these calculations have been given in Tables 5.9, 5.10, 5.11, 5-12, and 5-14. They confirm our assessment.

3. The discussion in Section 5.9.2 on the environmental impact of postulated radiological accidents at Waterford-3 is considered to be en adequate assessment of the radiological exposure pathways and dose and health impacts of atmospheric releases.

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o Mr. Frank J. Miraglia, NRC - Page 2 However, we believe that, by itself, the emergency preparedness section (5.9.2.1.3(3)) is not adequate. We will forego further comment on this aspect, realizing that the process of granting an operating license to the facility will include an adequate review of emergency preparedness (FEMA-NRC Memorandum of Understanding, Regional RAC's, criteria in NUREG-0654).

In view of some of the monitoring problems during the Three Mile Island-2 accident, we suggest the preparedness plan might be modified to address in parti-cular the problems af monitoring gaseous radioiodines in the presence of radio-noble gasses. This could be accomplished by reference to FD4A-REP-2, a document on instrumeatation systems prepared with input from NRC.

Considering the extensive lessons learned f rom the accident at IMI-2, it would bo helpful to expand Section 5 (Emergency Preparedness) to include a brief presentation of the critical public health and safety actions that NRC has taken since TMI-2, or plans to take in the near future, to improve nuclear reactor safety and to mitigate the consequences of potential accidents at commercial nuclear power plants. The discussion in paragraph 4, page 5-57, is a possible introduction to the proposed modified section.

4. The operational monitoring program is planned to be a continuation of the preoperational program. It appears that the program vill provide adequate sampling and analysis for measuring the extent of emissions from the plant, and to verify that such emissions meet applicable radiation protection standards.

5. The Section 5.9.3 discussion of the environmental effects of the Uranium Fuel Cycle is a reasonable assessment of population dose commitment and health effects associated with the UFC.

Thank you for the opportunity to review and comment on this draf t document.

Sincerely yours,

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John C. Villforth Director Bureau of Radiological Health

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