ML20027C563

Comments on Des (NUREG-0921) & Public Health & Safety Impacts of Proposed Plant Operation

ML20027C563
Person / Time
Site:	Catawba
Issue date:	10/12/1982
From:	Villforth J FOOD & DRUG ADMINISTRATION
To:	Jabbour K Office of Nuclear Reactor Regulation
References
RTR-NUREG-0921, RTR-NUREG-921 NUDOCS 8210180169
Download: ML20027C563 (2)

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DEPARTM ENT OF If EALTil & IIUM AN SfRVICES Public Health Servica Y ~

• % Food and Drug Administration Rockville MD 20857 OCT 1 2 1982 Dr.,Kahtan N. Jabbour Project Manager p L/ l 3 Division of Licensing Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Dr. Jabbour:

The Bureau of Radiological Health staff has reviewed the Draft Environmental Statment (DES) related to the operation of the Catawba Nuclear Station, Units 1 and 2, NUREG-0921, dated August 1982.

In reviewing the DES, we note that (1) the application for a construction permit is dated July 1972, (2) the Final Environmental Statement-Construction Phase (FES-CP) was issued in December 1973, (3) after a safety review, evalu-ation by the ACRS, and a public hearing, the construction permits were issued in August 1975, and (4) as of May 1982, the construction of Unit 1 was about 90 percent omplete. The Bureau of RadioJogical Health staff has evaluated the public health and safety impacts ascociated with the proposed operation of the plant and has the following conments to offer:

1. The numerical guidance on dose-design objectives of 10 CFR 50, Appendix I to meet ALARA requirements, the Uranium Fuel Cycle standards of EPA's 40 CFR 190, and the applicant's proposed radioactive waste management system (Section 4.2.5) provide adequate assurance that the effluents will be maintained as low as reasonably achievable (ALARA) .

It appears that the calculated doses to individuals and to populations resulting frm effluent releases are within current radiation protec-tion standards.

2. The environmental pathways identified in Section 5.9.3, and shown schmatically in Figure 5.1, cover all possible mission pathways that could impact on the population in the environs of the facility. The dose conputational methodology and models (Appendir. D arx3 E) used in the estimation of radiation doses to individuals and populations within 80 km. of the plant have provided the means to make reasonable estimates of the doses resulting from normal operations and accident situations at the plant. Results of the calculations are shown in Appendix D, Tables D.6, D.7, D.8 and D.9 and confirm that the calculated doses meet the

! design objectives.

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Dr. Kahtan N. Jabbour - Page 2 ,

3. Discussion in Section 5.9.4 on the environmental impact of postulated accidents is considered to be an adequate assessment of the radiation ex-posure pathways depicted in Figure 5.1 and the dose and health impacts of atmospheric releases. However, in Section 5.9.4.2(2) , two additional possible pathways are mentioned. These are (1) radioactive fallout onto

, open bodies of water, and (2) the "Gina Syndrome" that creates the poten-tial for release of radioactive materials into the hydrosphere throtgh contact with ground water. A discussion of this latter pathway has been included in Section 5.9.4.5(5) . It would be helpful in understanding the consequences of the former, if some discussion of that pathway could also be included in an appropriate section, possibly in Section 5.9.4.5(5) .

No mention is made in Section 5.9.4(3) of an Emergency Operation Facility (EOF) being planned for location cn-site to coordinate activities needed to mitigate the consequences of serious accidents. Designation of such a facility would indicate one of the positive steps taken since the TMI-2 accident to improve reactor safety.

4. The radiological monitoring progra as presented in Section 5.9.3.4, and sumarized in Table 5.7, appears to provide adequate sapling fre-quency in critical exposure pathways. The analyses for specific radio-nuclides are considered sufficiently inclusive to (1) measure the extent of missions from the plant, and (2) verify that such emissions meet applicable radiation protection standards.

It is noted that the NRC is considering propoJais to require real time monitors that can provide useful, timely information to implement the off-site protection actions following an accident. In view of some of the monitoring problems identified during the 'IMI-2 accident, we suggest that the system, which is being studied by a consultant, include reevaluation of the airborne radioiodine sanpling and analysis program, and, if appro-priate, include the finding in the proposed systs. We are particularly concerned about the problem of monitoring radiohalogens (specifically radiciodine) in the presence of radionoble gases.

5. Section 5.10 and Appendix C contain descriptions of the environmental inpact of the Uranium Fuel Cycle (UFC) . The population dose comitments and health effects presented are a reasonable assessment of the environ-mental effects from liquid and gaseous radioactive effluent releases fra the UFC (excluding reactors, but including radon-222 and technicium-99) .

'Ihank you for the opportunity to review and cmment on this Draft Enviromental Statement.

Sincerely yours, John C. Villforth Djrector Dureau of Radiological Ikalth

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