ML20037B514

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Responds to to Chairman Schlesinger Re Statements Before Il Pollution Control Board.Cites Factors Helpful in Placing Computation in Perspective Re Dose of 680 Millirems Per Yr to People within 1-mile Radius of Plant
ML20037B514
Person / Time
Site: Dresden, 05000268  
Issue date: 03/21/1972
From: Rogers L
US ATOMIC ENERGY COMMISSION (AEC)
To: Dumelle J
ILLINOIS, STATE OF
Shared Package
ML20037B515 List:
References
NUDOCS 8010140590
Download: ML20037B514 (11)


Text

{{#Wiki_filter:* . N ,y t. .s [. .. =.. .CC:." Docket Nos. 50-10, 50-237, 50-268, 5 0 -2If f MAR g 1 1972 M Mr. Jacob D. Dumelle Board Member State of Illinois Pollution Control Board. m "-" 309 West Washington Street ..= Suite 300 Chicago, Illinois 60606 es _

Dear Mr. Dumelle:

M This is in reply to your letter of February 18, 1972, to Chairman Schlesinger regarding the statements before the Pollution =m 3.5 Control Board of the State of Illinois by Representative Katz and ^""" Dr. Radford. s.,._ With regard to Dr. Radford's estimate of a dose of 680 millirems per year to people at one mile to the northeast of the Dresden site, there are several factors that may be helpful in placing such a computation in persr. tive. 1. Dr. Radford's dose estimate does not refer to actual doses delivered. It is a projection, based on an estimate of the dose due to opera-tion of Dresden-1 alone, of what the dose might be from all three power reactors operating at 90% of capacity. He apparently has =n assumed that the dose to people wou'.d be linearly related to total power level. Dr. Radford indicates that his estimates are based on a USPHS survey of Dresden-1 done in 1968. We assume that he is referring to the survey reported in HEW publication BRH/ DER 70-1, ~; a copy of which is enclosed. Page 53 of the report states that the highest measured exposure rate, at station #110, adjusted foe annual wind-direction frequency and wind speed in the appropriate sector, and the annual average gaseous fission proMet release rate during 1963 was 14 5 millirems per year. 2. Technical specifications on release rates applicable to presently operating power reactors are based on 10 CFR Part 20, which is, in turn, based on the existing Federal Radiation Council (now the s.7 Environmental Protection Agency) guidance that doses received by .s:,. - the most highly exposed individuals in the general population should not exceed 500 millirems per year. It follows that, if the combinedj.

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Mr. Jacob D. Dumelle 2- ~ be expected to msult. Although this has been the technical ~~ =E =: basis for our operating limits, we have never permitted individual facilities or continations of facilities at a given site to .= 2F operate for any extended period of time at their maximum operating limi ts. Measurements have been obtained independently by our

== Cocpliance Division during subsequent operation of Dresden-1 and ~~" Dresden-2. In the one-year period fmm October 1970 to October 1971, the quarterly doses to a person continuously present at the measuring station nearest the location refemnmd by Dr. Radford y. would have been about: 4th quarter,1970 9 millirems / quarter ~ 1st quarter,1971 8 millirems / quarter 2nd quarter,1971 12 millirems / quarter 3rd quarter,1971 22 millirems / quarter

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,m: or an average of about 13 millirems / quarter, for an average annual rate of about 50 millirems / year.

== 3. In December 1970, the Consission promulgated amendments to 10 CFR Parts 20 and 50 (copy enclosed) which require that levels of radio-active material in effluents to unrestricted areas from light-water-cooled nuclear power plants be kept as low as practicable. We expect that for plants designed and operated in accordance with this requirement, resulting doses to menbers of the public would not be likely to exceed a small percentage of the FRC/ EPA guidance of 500 millirems per year. The amendments also require that equipment be installed capable of routinely controlling releases such that doses are this lo.v, and that this equipment be maintained and used. Technical specifications developed since that time requim that i licensees control effluents such that material mleased is kept as low as practicable. Sicilar provisions have been applied to Dresden-2 and Dresden-3. I 4. In June 1971, the Commission publishe'd a proposed amendment to 10 CFR Part 50 (copy enclosed) which would provide a numerical definition of the qualitative "as low as practicable" criterion stated in the amendment of December 1970. A new proposed Appendix I would estab-lish design objectives for effluent releases such that doses to members of the public would not exceed 5 millirems from liquid and 5 millirems from gaseous effluents. Following coupletion of the hearings presently being conducted on the proposed amendnents, we E expect to publish amendments to Part 50 in effective form that would '= specify numerical values for design objectives and limiting conditions -r OntCE > $URNAh4E> DATE > Form AEC-5tB (Rev.9-53) AECM 0240

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. =.. y .[. ^^ Mr. Jacob D. Dumelle. for operation of light-water-cooled power mactors. Under the TE proposed criteria extended operation of such plants at more than

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a few percent of the FRC/ EPA guidance level of 500 millirems per year to the most highly exposed individual would not be pennitted.

== 5. Pending promulgation of the above described amendment to Part 50, ~ we have been inosing related requimments on particular pcwer plants. Specifically, for the Dmsden-1 facility, the licensee has proposed an instantaneous action level, based on a dose rate of 75 millirems / year at the boundary of the site, above which action would be requimd to reduce levels. Specifically for Umsden-2 ~ and Dresden-3, AEC requested the licensee on Decenber 4,1970, to submit plans for installation and operation of additional gaseous holdup systems. The licensee agreed by letter dated June 1,1971, and now is in the process of procuring these augmented systems. =. In addition, for the Dresden-1 reactor, AEC requested the licensee on July 22, 1971, to propose technical specifications that would = reduce allowable rates of leakage to the lowest practicable level. 6. In sumary, public doses as high as Dr. Radford's 680 millimms could occur only if the Comission were to permit licensees to operate such that cembers of the general public would receive dose rates of 500 or more millirems per year for a period of as long as a full year. The record shows that short tenn dose rates this high have not occurred, and the Commission does not propose to permit annual doses to individual members of the public to exceed a few percent of this guidance level. We received the Applicant's Environmental Report for the Midwest Fuel Recovery Plant from General Electric in July and have completed prepara-tion of the environmental igact statement, a copy of which accompanies this letter. We will be happy to discuss any aspect of this statement with you, should you so desire. Dis tribution: Sincerely, Distri bution (cont'd) LRogers, REP JBecker, OGC PDR PMorris, DRL CGamertsfelder, REP MFitzPatrick, REP SSmiley, DML JNehemias, REP AJackson, OCM LDLow, C0 GErtter, DR (DR-4228 @fER ROGERS ^Giambusso, REP and DR-4268) Lester Rogers, Dimctor LKornblith, C0 REG Docket Files Division of Radiological and DSkcvolt, DRL REP Docket Files Environmental Protection

Enclosures:

1. BRH/ DER 70-1 2. 12/73 Anundments to Parts 20 & 50 3. S/7' orcpc:cd f.=ntent to." art 50 om&.- Environmen tal. Imp.act..Stak! en.t.for DA QGC RFPtDIR Midwest Fuel Recovery Plant su-c .. REP.:.RPS. REP.:ADRP CO _.QSko.vnl.t.........JBecker I a r.s_... our L.JNehemias:sf CGamertsfe ider LKornbli g.-. _.,.... _3.-l.4 -12......NNZ.b cb h t -s t e$ s's Fom MC ps gRev.9 53) 2

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Mr. Jacob D. Dumelle. .a be expected to result. Although this has.been the technical basis for our 6 erating limits, it has beep our practice not to permit ~ ~ ~ ~ ~ =L..? individua facilities or combinations of facilities at a given site to operate for any extended period f time at their maximum operating = limits, and e have never actua11 permitted such operation. E~ Measurements ave ban obtained i ependently by our Compliance Division durin subsequent opera)' ion of Dresden-1 and Dresden-2. In the one-year eriod from October 1970 to October 1971, the fi

s a person cor3 nuously present at the measuring quarterly doses station nearest th location r ferenced by Dr. Radford would have 4 ;; -

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== 4th quart, 1 97 9 millirems / quarter 1st quarte 1971 8 millirems / quarter 2nd quarter,1971 12 millirems / quarter 3rd quarter, 671 22 millirems / quarter

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or an average of about 13 m 111 rems / quarter, for an average annual rate of about 50 millir.s/ r. ~ 3. In December 1970, the Cpmissi promulgated amendments to 10 CFR _...~~ Parts 20 and 50 (copy enclosed) which require that levels of radio-activematerialineffnuentsto nrestricted areas from light-water-cooled nuclear power plants be ke t as low as practicable. We expectthatforplanysdesignedan operated in accordance with this

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r requirement, resultipg doses to m i ers of the public would not be likely to exceed a all percentage f the FRC/ EPA guidance of 500 i

millirems per year The amendments a so require that equipment be installed capable f routinely contro ing releases such that doses are this low, and that this equipment maintained and used. Technical specif ations developed sine that time require that licensees contro effluents such that ma erial released is kept as low as practica e. Similar provisions h ve been applied to Dresden '2 and Dresden 3 .e 4. In June 1971, he Commission published a p posed amendment to 10 CFR Part50(co enclosed) which would provide numerical definition of the quali. tive as low as practicable" c iterion stated in the =.J amendment of' December 1970. A new proposed pendix I would estab-

== lish design / objectives for effluent releases uch that doses to

== members of/the public would not exceed 5 mill rems from liquid and .7 5 millirems from gaseous effluents. Following completion of the

=== ~ hearingshresently being conducted on the proposed amendments, we expect to publish amendments to Part 50 in effective form that would specify' numerical values for design objectives' and limiting conditions .jjp' OFFICE > c.= n= $URNAME> DATE > Form AEC-31s (Rev.9 53) AECM 4240 tr. S. GOVUtWENT WNTDIG OFFICE : 1,70 O. 405 34s J

/ DISTRIBUTION:~ CCGamertsfelder, REP LRogers, REf PMorris, DRL-- JNehemias, REP SSmiley, DML DR-4228 (2) LDLow, C0 DR-4268 (2) Mr. Jacob D. Dumelle AGiambusso, REP REG Docket Files (3) LKornblith, C0 REP Docket Files (3) DSkovolt, DRL PDR JBecker, OGC MFitzPatrick, REP for operation o light-water-cooled power reactors. Under the proposed criter a extended aperation of such plants at more than a few percent of the FRC/ EPA guidance ldvel of 500 millirems per = year to the most ighly exposed individual wo'ild not be pemitted. 5. Pending promulgatio of the above de cribed amendment to Part 50, we have been imposin related requirjments on particular power plants. Specifically, for the Dresdgn-1 facility, the licensee has proposed in instan neous actior level, based on a dose rate of 75 milli ems / year at he boundary of the site, above which action would be required to redu e levels. Specifically for Dresden-2 and Drenden-3, AEC request the li ensee on December 4,1970, to submit plans for install tion an i operation of additional gaseous holdup systems. The icens ee agreed by letter dated June 1, 1971, and now is in the proce of{procuringtheseaugmentedsystems. In addition. for the Drasden-1 eagtor, AEC requested the licensee on July 22, 1971, to. propose te n-cal specifications that would reduce allowable rates of leakag m the lowest practicable level. occur only if the Cornission were ) Dr. Radford's 680 millirems could In summary, public doses as high a 6. permit licensees to operate such that members of the general publid uld receive dose races of 500 or more millirems per year for a peri d of as long as a full year. The record shows that short term dose ates this high are very unlikely, and that the Commission l does ot propose to ::ernit annual ~ doses to individual members of the publ to exceed a few percent of this guidance level. /' Ue received the Applicant's Environmental Report for the Midwest Fuel Recovery Plant from General Electric in July and have completed prepara-tion of the environmental impact statement, a copy of which accompanies this letter. We will be happy to discuss any aspec.t of this statement with you, should you so desire. Sincerely, t Lester Rogers, Director Division of Radiological and Environmental Protection l

Enclosures:

1. BRH/DEP 70-1 2. 12/70 Amendments tn Pts 20 & 50 3. 6/71 Proposed Amendment to Pt 50 4. qnvironmental I. pact Statement for l 4 dwesg fuel-grg-P t-7-gg;;C Rg.g.g. C REP:DIR mc4 u $URNAME3 Me s:.sg..C CGamer.tsfeldfr..LXQrnbli.th...D.S.ko.vol t........ JBecker LRog_ers _ ono. ..l. 3/ /f /72 3/ /1/72 3/ / 4 /72 3//9772 37~ /72 3 /72 1 l Form AtC-318 (Rev. 9-53) AECM 0240 r s. covrancT rnsTsc orrscE : 1,10 o. en.s.s J

\\ sr:. Docket Nos. 50-10, 50-237, 50- 8 n=p"" gijm s. j Mr. Jacob D. Dumelle Board Member ~~~. State of Illinois Pollution Control Board s== 309 West liashington Street [...... Suite 300 61 Chicago, Illinois 60606 ~~

Dear Mr. Dumelle:

. 5 This is in reply to your letterf of ebruary 12,1972, to = Chairman Schlesinger regarding Ithe tatements before the Pollution Control Board of the State of ',11tno s by Representative Katz and Dr. Radford. E I With regard to Dr. Radford's estimate f a dose of 680 millirems per year to people at one mile to the north ast of the Dresden site. l there are several factors than may be he pful in placing such a != = computation in perspective. 1. Dr. Radford's dose estim te does not gfer to actual doses delivered. It is a projection,. based on an estimate of the dose due to operation ,.= of Dresden-1 alone, of what the dose mi t be from all three power reactors operating at 9 of capacity. le apparently has assumed that the dose to people uld be linearl related to total power =- level. 2. Technical specification,s on release rates applicable to presently operating power reactor,s are based on 10 CER Part 20, which is, in F turn, based on the existing Federal Radiation Council (now the L Environmental Protection Agency) guidance that doses received by the most highly exposed individuals in the general population should not p exceed 500 millirems per year. It follows that, if the combined effluents from all of the plants at a particular site, for example the Dresden site, were permitted to operate for a full year at the operating limit, doses to individual members of the public of the m order of 500 millirems per year might be expected to result. Although this has been the technical basis for our operating limits, it has of facilities at agiven site to operate for any extended period of been our practice not to pemit individual facilities or combinations . :.L,..i... .-~....:.... ' ^ ^ m,_... -,.

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operating 'imits, and we have never actually ~ permitted such opera ion. Meas rements have been obtained - ~ ~ m independently by our omplianc Division during subsequent opera- ..=. e tion of Dresden-1 and Dresden. In the one-year neriod from October 1970 to Octobe 1971, he quarterly doses i.o a person continuously present a the e asuring station nearest the location referenced by Dr. Radfo d wo d have been about: h 4th quarter,197 9 millirems / quarter 1st quarter, 91 8 millirems / quarter 2nd quarter, L 1 12 millirems / quarter 3rd quarter,171 22 millirems / quarter 2 \\ or an average of about 13.1111 rems / quarter, for an average annual rate of about 50 millirem /y ar. 3. In December 1970, the .iss n promulgated amendments to 10 CFR Parts 20 and 50 (copy en losed which require that levels of i radioactive material in fflue s to unrestricted areas from light-a water-cooled nuclear po er plan be kept as low as practicable. k'e expect that for plan s design and operated in accordance with this requirement, resulhing doses to members of the public would not be likely to exceed a mall percentage of the FRC/ EPA guidance of e.. _ 500 millirems per yea. The amendhents also require that equipment be installed capable f routinely chntrolling releases such that doses are this low, a that this e ipment be maintained and used. Formal requirements lation, maintenance, and use of such equipment ha,or design, inst e e been incorpora,ed in technical specifications developed since tha time. Also, specifically for Dresden-2 and Dresden-3, the licer see has been reque'ted to install additional gaseous holdep syst as before the proma tation of these amendments. 4. In June 1971, the omission published a. proposed amendment to 10 CFR Part 50 (copy enclosed) which would provide a numerical definition of the qualitative "fs low as practicable" c terion stated in the amendment of December 1970. In a proposed.ppendix I we proposed design objectiv for effluent releases suc. that doses to members of i the public not ceed 5 millfrems from liquid and 5 millfrems from gaseous effluen s. Following completion of he hearings presently i being conducted on the proposed amendments, % expect to publish amendments to part 50 in effective form that would specify numerical values for de ign objectives and limiting condigons for operation ~~_ .7 l

U Mr. Jacob D. Dumelle of light-water-cool \\ power reactors. er the proposed criteria extended operation of such plants at mofe than a few percent of the FRC/ EPA guidance level \\pf 500 millirer% per year to the most highly exposed individual would not be permitted. 5. Pending promulgation of he above de cribed amendment to Part 50, we have been imposing related Specifically, for the Dresd, requirements on particular power plants.en-1 fa6111ty an instantaneous action levhl, ba ed on a dose rate of 75 millirems / year, above which action would b required to reduce levels. In addition, for all three Dresden eactors, we have requested the licensee to submit plans thativ. uld implement the criteria or pro-visions of the proposed Append x I. l \\ l 6. In summary, public doses as I) gh as Dr. Radford's 680 millirems could occur only if the' Commission were to permit licensees to operate such that members of the gep'eral 'public would receive dose rates of 500 or more millirems per year foi, a period of as long as a full year. The record shows that exp9tures this high are very unlikely, and that l the Comiission does not propose to permit annual doses to individual l members of the public to exceed a few percent of this guidance level. p We received the Applicant' Environmental \\ Report for the Midwest Fuel Recovery Plant from Gener 1 Electric in July and have completed prepara- ' tion of the environmenta impactstatementiacopyofwhichaccompanies this letter. We will b happy to discuss any aspect of this statement with you, should you so desire. Sincerely, i- / Lester Rogers, irector L i / Division of Radiological and i Environmental protection l

Enclosures:

/ DISTRIBUsION: 1. 12/70 Ameridments to Pts 20 & 50 L. Rogers \\ REP C. Gamertsfelder, REl).: 2. 6/71 Proposed Amendment to Pt 50 P. Morris, DRL J. Nehemtas, REP [y 3. Environmental Impact Statement for S. Smiley, ML DR-4228(2) M Midwes't Fuel Recovery Plant L. Low, C0 DR-4268 (2) I A. Giambussoj REP REG Docket Files L. Kornblith, C0 REP Docket Files D. Skovolt, DRL PDR J. Becker, OGC M. FitzPatrick C 0 :........... D C '"' REP:DIR REP:RPB REP:ADRP omet > q... ~ l JVNeh iss:segCCG rtsfelderLkrn'b1ith DSko t JB c er LRogers j sumut > 3/ { /72 3/,iy72 3/,, /72 3/ lL) /72,, 3/ /72 i 3/14/72, f Form AEC-Sts (Rev. 9-53) AECM 0240

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