ML20054H911

Comments on Des (NUREG-0894) Re Project Const.Comments Address Health & Safety Aspects of Proposed Plant Operation,Including Radiological Monitoring Program & Emission Pathway Dose Computational Methodology

ML20054H911
Person / Time
Site:	Skagit
Issue date:	06/21/1982
From:	Villforth J HEALTH & HUMAN SERVICES, DEPT. OF
To:	Norris J NRC
References
RTR-NUREG-0894, RTR-NUREG-894 NUDOCS 8206250175
Download: ML20054H911 (3)

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g DEPARTMENT OF HEALTil & IlUM AN SERVICES Public Health Servica

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% Food and Drug Administration Rockville MD 20857 Mr. Jan A. Norris Environmental Project Regulations U.S. Nuclear Regulatory Comission Washington, D.C. 20555

Dear Mr. Norris:

'Ihe Bureau of Radiological Health staff has reviewed the Draft Environmental Statement (DES) related to the construction of the Skagit/Hanford Nuclear Project, Units 1 and 2, NUREG-0894, dated April 1982. Our review has been limited to the health and safety aspects associated with the proposed operations of the plant. We have the following comments to offer:

1. It appears that the design objectives of 10 CFR 50, Appendix I, the operating standards of 40 CFR 190, and the proposed operating plan of the Skagit/Hanford Nuclear Project, Unit 1 and 2, provide adequate assurance that the potential individual and population radiation doses I

will meet current radiation protection standards. However, Section 4.2.12.1, page 4-176, on regulatory requirements needs to be clarified in light cf the stated standards of 40 CFR 190. In paragraph one of this sectbn, it states that no member of the public in unrestricted areas shall receive a radiation dose, as a result of facility operations, of more than 500 mrem in one calendar year, as set forth in 10 CER 20. Wis seems to imply that there is a double standard in light of the requirements of 40 CFR 190, as stated in paragraph 3 on page 4-177. Wis regulation limits annual doses for members of the public to 25 mrem total body, 75 mrem thyroid, and 25 other organs from all fuel cycle facilities. Since the NRC has agreed to implement EPA's 40 CFR 190 regulation, this section should be modified to clearly state that the annual doses to members of the public will comply with this regulation. It should also be consistent with the discussion on radiological impact on humans, as presented on page 4-189, as it relates to the individual doses for members of the general public.

2. % e environmental pathways identified in Secton 4.2.12.3, and shown in Figure 4.41 cover all possible emission pathways that could impact on the population in the environs of the facility. We dose canputational methodology and models (Appendix B and D) used in the estimation of radiation dose to individuals and to populations within 80 km. of the plant have provided reasonable estimates of the doses resulting from normal operations at the facility. Results of these calculations are shown in Appendix D, Tables D.6, D.7, and D.8. Wese results confirm that the calculated doses meet the design objectives.

Further, the discussion in Section 3.4 of Appendix I, Environmental Analysis of the conditional sale and easement contract with Puget Sound Power and Light Company, provides an evaluation of radiation exposure for the reference site. The estimated doses are shown in Appendix I, Table 3, and are within the current radiation protection-standards 8206250175 820621 fd8 PDR D ADDCK 05000522 PDR

Mr. Jan A. Norris - Page 2

3. Discussions in Section 4.2.12.4, on the potential radiological impacts on the environment of possible accidents is considered to be an adequate assessment of the exposure pathways depicted in Figure 4.42. Two additional exposure pathways are identified in the text which could be significant. %ese are (1) fallout of radioactivity initially carried by the air into open bodies of water and (2) the

" China Syndrome" that creates the potential for release of radioactive material into the hydrosphere through contact with ground water. If possible, it would be helpful to quantify the health impact from these exposure pathways in sufficient detail to permit an understanding of the consequences of such events.

We will forego corrtents on the emergency preparedness section in light of the statements in Section 4.2.15, on emergency planning which indicate that the staff does not have sufficient information to assess any environmental impacts resulting from implementation of the upgraded emergency planning requirements in 10 CFR 50, Appendix E.

Moreover, the State and local emergency plans will be reviewed by the FEMA-chaired Regional Advisory Corrmittee (RAC) in which we and other agencies participate. Our Departmental representatives will thus address adequacy of the emergency planning separetly from the DES review.

4. The radiological monitoring program, as presented in Section 4.2.12.2, and Section 5.2 and sumarized in Table 5.1, appears to provide adequate sampling frequencies in expected critical exposure pathways. We analyses for specific radionuclides are sufficiently inclusive to (1) measure the extent of emissions from the plant, and (2) verify that such emissions meet applicable radiation protection standards. However, we suggest that the airborne radioiodine sampling and analysis program be examined to make certain that the system is adequate for monitoring radiohalogens (especially radioiodine) in the presence of radionoble gases in the unlikely event of an accident.

5. Section 4.2.13 and Appendix C contain descriptions of the environ-c mental impact of the Uranium Fuel Cycle (UFC) based on the value in Table 4.34 (Summary Table S-3, UK environmental data) . We environ-l mental effects presented are a reasonable assessment of the population dose commitments and health effects associated with the release of radon-222 from the UFC.

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

Sincerely-yours, L

/ )/BureauofRadiologicalHealth John C. Villforti Director 1

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