ML20052G913

Comments on NUREG-0884,DES Re Operation of Facilities.Design Specs of 10CFR50,App 1,EPA 40CFR190 & Util Proposed Radwaste Mgt Sys Provide Adequate Assurance That Radioactive Matls in Effluents Will Be Maintained ALARA

ML20052G913
Person / Time
Site:	Perry
Issue date:	05/14/1982
From:	Villforth J FOOD & DRUG ADMINISTRATION
To:	Stefano J Office of Nuclear Reactor Regulation
References
RTR-NUREG-0884, RTR-NUREG-884 NUDOCS 8205190149
Download: ML20052G913 (2)

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[ DEPARTMENT OF EALTil & IIUM AN SERVICES Public Hrlth Servica

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% Food and Drug Administration Flockville MD 20857 MAY I 4 1982 Mr. John J. Stefano Licensing Project Manager Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Comission Washington, D.C. 20555

Dear Mr. Stefano:

The Bureau of ladiological Health staff have reviewed the Draft Environmental Statement (DES) related to the operation of Perry Nuclear Power Plant, Unit 1 and 2, NUREG-0884, dated March 1982.

In reviewing the DES, we note that (1) the application for a construction permit was received in 1973, (2) the Final Environmental Statement - Construction Phase was issued in April 1974, (3) the construction permit was not issued until May 1977, and (4) as of January 1982, the construction of Unit 1 was 82 percent complete and Unit 2 was 41 percent complete. The Bureau of Radiological Health staff have reevaluated the public health and safety impacts associated with the proposed operation of the plant and have the following coments to offer:

1. The design specifications of 10 CFR 50, Appendix 1, EPA's 40 CFR 190, and the applicant's proposed radioactive waste management system (Section 4.2.5), provide adequate assurance that radioactive materials in the effluents will be maintained as low as reasonably achievable (ALARA). It appears that the calculated doses to individuals and to the population resulting frcm effluent releases are within current radiation protection standards.

2. The environmental pathways identified in Section 5.9.3 and Figure 5.2, cover all possible emission pathways that could impact on the popu-lation in the environs of the facility. The dose computational methodology and models (Appendix B and D) used in the estimation of radiation doses to individuals and to 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 facility.

Results of the calculations are shown in Appendix D, Tables D-6, D-7, D-8 and D-9. These results confirm that the doses meet the design objectives.

3. The discussions in Section 5.9.4 on the environmental impact of postu-lated accidents la considered to be an adequate assessment of the radi-ation exposure pathways depicted in Figure 5.2 and the dose and health impacts cf atmospheric releases. We will forego coments on the emergency preparedness aspects (Section 5.9.4.1. 3. 3) since we realize the process of granting an operating license to the facility will include review of emergency preparedness to include the adequacy of State and local government emergency response plans (FEMA-NRC Memorandum (C)C of Understanding, Regions RAC's criteria in NUREG-0654). We have I representation on the RAC's whose evaluation relative to the Perry Nuclear Power Plant will speak for this agency. iO 8205190149 820514 PDR ADDCK 05000440 D PDR _

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Mr. John J. Stafano - Page 2 It is noted in Section 5.12, that a Technical Support Center (TSC) and an Emergency Operation Facility (EOF) have been located on-site to coordinate activities needed to mitigate the consequences of accidents. Some mention of these facilites should be included in Section 5.9.4 to indicate one of the positive steps that the NRC has taken to improve reactor safety as a result of the mI-2 accident.

4. The radiological monitoring program, as presented in Section 5.9.3.4 and summarized in Table 5.5, appears to provide adequate sampling frequency in expected critical exposure pathways.

Analyses for specific radionuclides are considered sufficiently inclusive to (1) measure the extent of emissions from the plant, and (2) verify that such emissions meet applicable radiation protection standards.

Although adequate for operational monitoring, the program should be assessed to determine if it is adequate to meet the needs imposed on it in the event of an accident. In particular, we suggest reevaluation of the airborne radioiodine sampling analysis program. Possibly, it should be modified to address the problem of monitoring radiohalogens (especially radioiodine) in the presence of radionoble gases. This could be accomplished by reference to FEMA-REP-2, a document on instrumentation systems prepared with considerable input from NRC. A paragraph could be added at the end of Section 5.9.3.4.2 that addresses this issue.

Such a discussion would provide assurance that the nunitoring problems identified during the TMI-2 accident are recognized, and that positive steps have been taken to provide the instrumentation needed to adequately detect releases of radiohalogens under accident conditions.

5. Section 5.10 and Appendix C contain descriptions of the environmental impact of the Uranium Fuel Cycle (UFC) . The environmental effects presented are a reasonable assessment of the population dose comit-ments and health effects associated with the release of radon-222 from the UFC.

Thank you for the opportunity to review and comment on this Draft Environmental Statement.

Sincerely yours,

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f ohn C. Villforth director sureau of Radiological Health

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