ML20041B942
| ML20041B942 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/22/1982 |
| From: | Villforth J FOOD & DRUG ADMINISTRATION |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20041B940 | List: |
| References | |
| RTR-NUREG-0848, RTR-NUREG-848 820112, NUDOCS 8202250426 | |
| Download: ML20041B942 (2) | |
Text
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DEPA RT31ENT OF IIEA LTii k IIUM AN 5ER VICES Public Health Se vice t
.' ' d Food and Dru;; Admin:stratu Rcovil;c MD 20857 d$U i 2 i.-D l
Mr. B. J. Youngblood Division of Licensing
'U.S. Nuclear Regulatory Carmiission Washington, D.C.
20555 Cear Mr. Youngblood:
We Bureau of Radiological Health staff have reviewed the Craft Environ: rental Statement (DES) for the Byron Station, Units 1 ard 2, NUREG-0848, Nove:rler 1981.
We note that (1) the application for construction of this staticn was received by the NRC in September 1973, (2) the NRC staff evaluation was issued as a Final Environmental Statement - Construction Phase (FES-CP) in July 1974, and (3) as of November 1,1981, the construction of Unit 1 was about 78 percent carplete, and Unit 2 was 63 percent complete. While the FES - CP is not included in this l
CES, the CES does include adecuate introductory resumes in appropriate sections which su.:rarire the extent of utdating the FES-CP.
W e Bureau of Radiological l
Health staff have evaluated the public health and safety aspects associated with the preposed operation of the plant, and have the follcwing cor: rents to offer:
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- 1. It appears that the design objectives of 10 CFR 50, Appendix I, the l
operating standards of EPA's 40 CFR 190, and the proposed operations plan of the Byron Station, Units 1 and 2, provide adequate assurance that the l
potential individual and population radiation doses meet current radiation G
l protection standards.
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- 2. We environmental cathways identified in Section 5.9.3.1 and shown schematically in Figure 5.4 cover all possible emission pathways that f
l could impact on the population in the environs of the facility. W e dose carputational methodology and models used in the estimation of radiation dose to individuals near the plant and to populations within 80 'ecn. of the plant have provided reasonable estimates of the doses resulting fran nor:ral cperations and accident situations.
Results of the environmental pathway i
dose calculations are shown in Appendix C, Tables C-6, C-7, C-8 and C-9, and confirm that the potential doses meet the design cbjectives.
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- 3. The discussien in Section 5.9.4 on the environmental impact of poten-i
- ial radiolocical accidents is considered to be an adecuate assessment of l
l the radiation exposure pathways and dose and health impacts of atmospheric releases. The evacuation model presented in Appendix F.1 is based on l
assumed conditions and capabilities to evacuate pecple to specified down-wind directions. Since evacuation involves early and expeditious movement of people to avoid exposure of the passing cloud and acute ground contami-nation followirg cloud passace, it would be helpful to include references to shcw that studies either have or have not been made to verify the model and to demonstrate that evacuaticn-is feasible for the specific facility ccvered by the EIS.
I 8202250426 820211 PDR ADOCK 05000454 D
Page 2 - Mr. B. J. Youngblood, NRC In our view Section 5.9.4.4(3) on e:rergency preparedness is not adecuate to meet planning needs.
However, we will forego further ca=ents on this aspect, realizing that the process of granting an operating license to the facility will include an adequate review of emergency preparedness (FD*.A-NRC Femorandum of UnderstaMing, Regional RAC's, criteria in NUPEG-0654). Na i
have representatives on the RAC's whose evaluation relative to Byron Station will speak for this Agency.
Ze accident risk and irpact assessment presented in Section 5.9.4.5 is considered to be an adecuate analysis of potential accidents in relation to
!y the dese and health inpact on the population fran at=cspheric releases.
It i:
is irportant that such an assessment provide the public with an understanding of risks involved and the measures the NRC is taking to mitigate the conse-ll cuences of potential accidents.
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- 4. We radiological monite-ing program, as presented in Section 5.9.3.4 and sum arized in Table 5.8, appears to provide an adecuate sampling frequency in expected critical exposure pathways. Se analyses for speci_fic radionuclides are considered sufficiently inclusive to (1) measure the extent of enissions I:
frce the facility, and (2) verify that such emissions meet aorlicable radia-I=
tien protection standards.
l In view of the monitoring problems that were identified during the Three j'
Mile Islam - Unit 2 accident, we suggest that the plan be modified to address the particular problers of monitoring radiohalogens (especially radiciodine) in the presence of radionoble gases. his could be accocplished by reference to FEMA REP-2, a document on instrumentation systers prepared with considerable j.
input from NRC.
Furthermore, it would be helpful to cite specific studies at operating plants that would verify that the instrument systems for making such ll measurements actually perform as expected and meet the technical requirements.
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- 5. Section 5.10 and Appendix G contain a description of the environmental impact assessment of the uranium fuel cycle. S e environmental effects presented are a reasonable assessment of the population dcse cocnitments and the health effects associated with the releases of radon-222 from the Uranium Fuel Cycle.
Thank you for the opportunity to review and comment on this draft document.
-Sincerely yours,
' '. C j\\
i
- ..' (.'
J
,-t John C. Villforth Director l
Bureau of Radiological Health a
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