ML20077G192
| ML20077G192 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/29/1983 |
| From: | Villforth J FOOD & DRUG ADMINISTRATION |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0974, RTR-NUREG-974 NUDOCS 8308030406 | |
| Download: ML20077G192 (2) | |
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DEPARTMENT OF HEALTH & HUM AN SERVICES Public Health Service P
Food and Drug Administration Rockville MD 20857 JUL 2 91983 Mr. A. Schwencer Licensing Branch No. 2 Division of Licensing US Nuclear Regulatory Commission Washington, DC 20230
Dear Mr. Schwencer:
We National Center for Devices and Radiological Health (NCDRH) staff has reviewed the Draft Environmental Statement (DES) related to the operation of Limerick Generating Station, Units 1 and 2, NUREG-0974 dated June 1983.
In reviewing the DES, w note that (1) the application for the construction permit was filed on February 26, 1970, (2) the Final Environmental Statement
- Construction Phase (FES-CP) was issued in November 1973, and (3) construc-tion permits for Units 1 and 2 were issued on June 19, 1974. We Radiolog-ical Health staff of the NCDRH has evaluated the public health and safety impacts associated with the proposed operation of the plant and has the following comments to offer:
1.
We design objectives contained in Appendix I of 10 CFR 50 and in the EPA Uranium Fuel Cycle Standards, 40 CFR 190, as well as the applicant's proposed radioactive waste management systs, provide adequate assurance that radioactive materials in the effluent will be maintained as low as reasonably achievable (AIARA). It appears that calculated doses to individuals and to the population resulting from effluent releases are within current radiation protection standards.
2.
We environmental pathways identified in Section 5.9.3 and Figure 5.4 cover all possible emission pathways that could impact on the population in the environs of the facility. We cbse computational methodology and nodels (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 at the facility. Results of the calculations are shown in Appendix D, Tables D-6, D-7, D-8 and D-9.
Wese results confirm that the calculated doses meet the design objectives.
3.
It is noted that the environmental impacts of postulated accidents will be published in a supplement to this DES. We will forego any coments until we have had an opportunity to review the alpplement.
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Page -2 Mr. A. Schwencer
- 4. -%e radiological monitoring program, as presented in Section 5.9.3.4 and suromarized in %bles 5.8, appears to provide adequate sampling frequencies in critical _ exposure pathways. We understand that the
_ operational monitoring program will be a continuance of the preoper-ational radiological monitoring program outlined in Table 5.8.
We analysis for specific radionuclides are considered sufficiently inclusive to measure the extent of anission from the plant, as well as to verify that such anissions meet applicable radiation protection standards.
As stated above, the monitoring program is considered adequate for routine operations. However, it would be helpful if a paragraph could be added to Section 5.9.3.4 that indicated the capabilities of the nonitoring instrumentation to measure releases from the facility in the unlikely event of an accident. We are concerned about some of the monitoring problems that were identified during the Wree Mile Island, thit 2 accident.
In particular, the problem of monitoring radiohalo-gens (especially radiciodine) _in the presence of radionoble gas. Wis could be accomplished by reference to FDIA-REP-2, a doctanent on instru-mentation prepared with considerable input from NRC.
5.
Section 5.10 and Appendix C contain descriptions of the environmental impact of the Uranium Fuel Cycle (UFC). We environmental effects presented are a reasonable assessment of the population dose conunit-ments and health effects associated with the release of radon-222 from the UFC.
Sank you for the opportunity to review and comment on this Draft Environ-mental Statement.
Sincerely purs, p@
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John C. Villforth
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National Center for Devices and Padiological Health