ML20071H610

Comments on DES,NUREG-0878 Re Operation of Facility & Evaluation of Public Health & Safety Impacts

ML20071H610
Person / Time
Site:	Wolf Creek
Issue date:	03/02/1982
From:	Villforth J HEALTH & HUMAN SERVICES, DEPT. OF
To:	Hopkins J Office of Nuclear Reactor Regulation
References
RTR-NUREG-0878, RTR-NUREG-878 NUDOCS 8203080472
Download: ML20071H610 (2)

Text

(""%

{

's DEPA RTM ENT OF IIEA LTII & ilUM AN S ER VICES Public H2dth S;rvics

'% 4 Food and Drug Administration Rockville MD 20857 E2 1982 p

b RECSIVC0 Mr. Jon Hopkins -

S Licensirg Project Manager ~4

,,% 0 3 $82)n. ;

Office of Nuclear Reactor Regulations -i 8 8m Wunw en,ap  %

U.S. Nuclear Regulatory Cmmission .[* 7 4' U Washington, D.C. 20555

Dear Mr. Hopkins:

O The Bureau of Radiological Health staff have reviewed the Draft Environmental Statement (DES) related to the operation of the Wolf Creek Generating Station, Unit No.1, NUREG-0878, dated January 1982.

In reviewing the DFS, we note that (1) the application for a construction permit is dated April 1974, (2) the Final Environmental Statment - Construction Phase was issued in October 1975, (3) the construction permit was not issued until May 1977, ard (4) as of September 1981, the construction of Unit 1 was about 75 per-cent complete. We Bureau of Radiological Health staff have evaluated the public health and safety impacts associated with the proposed rperation of the plant and have the following comments to offer:

1. %e dose design objectives of 10 CFR 50, Appendix I, the Uranium Fuel Cycle Standards of EPA's 40 CFR 190, and the applicant's proposed radio-active waste managment system provide adequate assurance that radioactive materials in the effluents will be maintained as low as reasonably achiev-able (AIARA) . It appears that the calculated doses to individuals and to the population resulting from effluent releases are within currene radia-tion protection standards.

2. The environmental pathways identified in Section 5.9.3 and in Figure 5.3 cover all possible mission pathways that could impact on the population in the environs of the facility. 'Ihe dose computational methodology and models (Appendix C 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 C, Tables C.5, C.6, C.7 and C.8. % ese results confirm the doses meet the design objectives, pp. > ko de P 8203080472 820302 gDRADOCK05000g

+.. A Page 2 - Mr. Jon Hopkins, USNRC

3. Discussion in Section 5.9.4 on the environmental inpact of postulated radiological accidents is considered to be an adequate assessment of the radiation exposure pathways depicted in Figure 5.3 and the dose and health impacts of atmospheric releases. However, in Section 5.9.4.2 (2), two additional possible exposure pathways are mentioned. nese are (1) radio-active fallout onto open bodies of water and (2) the " China Syndrome" that creates the potential for release of radioactive materials into the hydro-sphere through contact with ground water. If possible, it would be helpful to quantify the environmental and health inpacts from these exposure path-

-ways in sufficient detail to permit an understandity of the consequences of such events. We will forego coments on the mergency preparedness section (5.9.4.4(3)) since we realize the process of granting an operating license to the facility will include an adequate review of emergency plants (FENA-NRC Memorandum of Understanding, Regional RAC's criteria in NUREG-0654).

? We have representation on the RAC's whose evaluation relative to the Wolf Creek Generating Station will speak for this agency.

It is noted in Section 4.2.1 that an Emergency Operation Facility has been located on-site to coordinate activities needed to mitigate the conse-quences of accidents. Sme mention of this facility could be included in this section to indicate one of the positive steps the NRC has taken to improve reactor safety as a result of the 'IMI-2 accident.

4. he radiological monitoring program, as presented in Section 5.9.3.4 and summarized in Table 5.5, appears to provide adecuate sampling fre-quency in expected critical exposure pathways. %e analyses for specific radionuclides are considered sufficiently inclusive to (1) measure the extent of emissions from the plant, and (2) verify that such missions meet applicable radiation protection standards.

In view of some of the monitoring problems that were identified during the Three Mile Island, Unit-2 accident, we suggest reevaluation of the airborne radioiodine sampling and analysis program. In particular, it should be modified to address the problem of monitoring radiohalogens (especially radiololine) in the presence of radionoble_ gasm. B is could be accmplished by reference to FENA-REP-2, a document on instrumentation systems prepared with considerable input from NRC.

5. Section 5.10 and Appendix G contain descriptions of the environmental impact of the Uranium Fuel Cycle (UFC). W e environmental effects presented are a reasonable assessment of the population dose commitments and health effects associated with the release of radon-222 from the'UFC.

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

Sincerely yours, M

J hn C. Villfor th

! I)1 rector s Bureau of Radiological Health l

J