ML20041A060
| ML20041A060 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/29/1981 |
| From: | Nossa C AFFILIATION NOT ASSIGNED |
| To: | Keppler C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20041A057 | List: |
| References | |
| RTR-NUREG-0813, RTR-NUREG-813 NUDOCS 8202190033 | |
| Download: ML20041A060 (2) | |
Text
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3311 Arsznal ~
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4 St. louis, MO 63118 r
Novembe" 29, 1981
_PRINCIPML STM7 PBIR E&IS Mr. James G. Keppler; Regional Director D/D pro Region III A/D do U.S. Nuclear Regulatory Commission DR&PI De' ar Mr. Keppler:
DE&TI' After reviewing the Callaway Nuclear Power Plant' Draft Egyos pile }{};-
Environmental Impact Statement (NUREG-0813), I would like-to s'ubmit the following comments:
- 1) The Callaway Draf t Environmental Impact Statement
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(DEIS) does not' appear to give information on the probable levels of emissions that would.come from this plant in case of the most probable accidents.
- 2) On page 5-20, radiciodines, carbon-14', and tritium are all specified for 15 millirems as.the maximum allowable dosage.per year.
All three have the. same estimated dose limit despite the fact that they have very different half-lives which. indicates significant differences in toxicity.
This sug-gests that the 15 millirems is more of an estimate than it is a figure derived f. rom real knowledge of; the physiological effect of each'.
No information is given in the EIS in how the 15 millirem. figure was arrived at:
3)' Page 5-21 refers to one group of data (on asounts of radioactivity released through vents and dis-charge points) reported in the Radioactive-Effluent-
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Release Reports.
What other safety-related informa-tion does this report give?
Will it be available to the public?
- 4) The EIS implies that nuclear plant emissions are equal to or less than normal background radiation.
However, the types of radiation' involved in back-ground vs. nuclear are somewhat different.
Those of the power plant may be more toxic.
- Further, the EIS does not deal with the disproportionately additive effect of power plant radiation on too of background radiation.
One addi.tional unit of radiation (such at that of a power plant-added to background radiation) produces more than one addi-tional unit of toxicity.
I.E.,
the majority of evidence indicates that the relationship between dose and effect is not linear:
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, assumption Ample evidence for this is provided in the bel-R Report ' (rsf. 28) referred to in the EIS on P. 5-29.
5)
The EIS does not specify whether'the Callaway emissions are intermittent or continuous.
If the exposure is continuous (and thus acting without let-up, no matter.how large or small the total dose), its dose.is more toxic 'than the same. total dose would be if received intermittently, since intermittent exposure gives the body's recuperative or compensating mechanisms a chance to " rest" or catch up.
Any textbook on the health effecta od pollutants will verify this.
6)
Vith regard to Table 5.2 on P. 5-25, " Underground metal miners" is redundant or overlapping with uranium miners.
It does not reveal whether a breakdown of types of metal min'ers would show a type with higher fatality than uranium miners, or lower.
If uranium miners are one of six types of under-ground metal miners, the 422 deaths / year for uranium miners could be the highest group among the 1275 deaths listed.
I hope these comments will be of interest to you as you prepare the final environmental impact statement.
V ry truly
- ours, Carey Hoss
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