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DEPARTMENT OF ENVIRONMENTAL PROTECTION DIVISION OF ENVIRONMENTAL QUALITY JOHN FITCH PLAZA. P; O. BOX 1390. TRENTON. N. J. 08625 August 22, 1973 Director of Regulation U. S. Atomic Energy Commission Washington, D. C.
20545 Refer to: Docket No. 50-219 j
Dear Sir Attached are comments relating to the Draft Environmental Statement for Oyster Creek 1.
Very truly yours, xy l
John J Russo, Chief Bureau of Radiation Protection JJR:dg Encl.
4 G558 9604150134 960213 PDR FalA DEKOK95-258 PDR
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-t Com' ment's on Sections 5.3'through 5.4
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c'alcula tions The~ manner.inwh[ichthematerialanddose 1.
'have been presented in this section does not lend itself to an or the~ radiation independent verification of many parameters r
~ dose values.
No' reference as to'the critical radionuclides, other than airborne 7, -was mentioned within the presented 131 material.
2.
Certain portions of this section describing the radiological impact on the biota and man have been based on of radioactive j
-calculated estimates of the annual releases materials.
In addition, bioaccumulation factors taken from the open literature were utilized to evaluate the uptake of radionuclides f' rom the liquid effluents into the va'rious marine flora and fauna.
In view of the fact that detailed environmental data have been documented by several governmental agencies (the State of'New Jersey, the U.S. Environmental and the U.S.' Atomic Energy Commission),
Protection Agency, the State objects to the ommission of the documented data (and the interpretation) into this section of the report.
Since no actual environmental data were considered in the evaluation, some of the basic theoretical assumptions and parameters may be too conservative in some cases and may be grossly exaggerated in other cases._ For example,.the bioaccumulation factors stated for Mn in Table 5.1 for mollusk and algae,' appear to be two orders of magnitude greater than e
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4 the actual values based on-empirical data.
The'bioaccumu)ation-factors _for Co~and Mn for crustacea also appear to be several orders of; magnitude greater than the actual values.
Studies
. conducted by the State.of New Jersey and the U.S.. Environmental 60 o, 58 Protection Agency'ha,ve indicated that very little C
co, and 4Mn have been incorporated in crustacea from Barnegat Bay.
The' incorporation of these nuclides in crustacea was significantly
<1ess than that of shellfish.
Therefore, the stated dose estimates based-on the ingestion of these marine organisims would 'be greater t:
than the actual va1ues.
3.
Dose rate values to crustaceans and mollusks living on the bottom sediments in the cooling water outfall have been estimated without defining the acc'umulation factor of radioactive materials in sediments.
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4 No consideration has been given to the radiation e
i dose to be incurred from the dredging of the discharge canal.
Due to the severe sedimentation of Oyster Creek, the facility chall have to dredge the stream periodically in order to permit c
' access of small vessels to the commercial marinas.
Data t
collected by the State verifies radioactivity concentrations in 60 sediment of the order of 30 to 40 pci/g - dry for Co and 54Mn.
.If the~ dredged material was to be deposited on the banks of Oyster Creek, the resultant radiation dose to a fisherman on-the stream bank'would be-very significant.
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Since there is a great variation 1t the radioactive a
gaseous and aqueous effluents from the plant due to practices 1
in waste treatment and the dependence of leakage rates on a
operating time, the estimated dose values should be evaluated in terms.of a range.rather than some finite numerical value.
6.
H. Beck of the U.S. Atomic Energy Commission Health and Safety Laboratory has measured the offsite ' external radiation dose' contributions from the radioactive gaseous plume during 4
periods of operation in 1972.
The data accumulated and reported a
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Beck should be incorporated into the report.
131 7.
The report does not specify.whether the I thyroid dose calculations were based on the release of iodine in the l
form of 1 Studies conducted by C. Pelletier, Environmental 2
Protection Branch, Directorate of Regulatory Operations, U.S.
131 i
Atomic Energy Commission, indicate that over 80% of the I
i released from the steam-j et-air ej ector of Oyster Creek NGS vas organic iodide.
If this fact was not included in the Parameters utilized for the calculation of the thyroid dose of a child drinking milk, then the stated thyroid dose value of 5.6 mrem / year is overestimated.
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-Comments on'Section 6.2 The facility's current Environmental Radioactivity Monitoring Program, as outlined in Table 6.1, of the report, is very inadequate to assess the in terms of providing meaningful data in order radiological impact of the gaseous and aqueous discharges'from the plant.
This statement is based upon the State's knowledge of the current surveillance program maintained by the f.acility and upon independent measurements co. ducted by the State.
Basically, if governmental agencies, namely the U.S.E.P.A. and the State of New Jersey, had notimplemented detailed environmental surveillance l
programs of the facility, little or no data relative to the offsite abiotic and biotic accumulation of facility-related radionuclides would be available for evaluation.
The State finds the current radiation monitoring program "t
outlined by the Oyster Creek Nuclear Generating Station inadequate
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in the following areas:
1.
the use of film badges for the measurement of the external radiation dose due to the radioactive gaseous plume discharged from the facility.
The State recommends the use of sensitive thermo-luminescent dosimeters for measuring th'e integra ted or quarterly radiation dose and the use of sensitive pressurized ionization chambers for measuring the instantaneous plume dose.
2.
the positioning of the film badge dosimeters have not been predicated on theoretical data estimating the offsite locations of the maximum population dose.
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3.x the use'of low-volume' air samplers for the-measurement o f ? airborne :.radionuclid es'.
(4. ~theffailure'to position the' air sarplers at locations r
s of the predicted 1. maximum ground level concer ratins.
5.
the failure to incorporate a means'to evaluate the offsite airborne 7 tadiciodine' originating;from the plant.
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6..
the failure to analyze the air-particulate filter.ssmples,.
soil,. vegetation, and precipitation'for gamma-ray emitting radio-
- nuclides.
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7.
the' failure to analyze surface water from Barnegat Bay t
89 90
. and Oyster Creek for tritium, Sr, Sr,'and gamma-ray emitting i
radionuclides.
8.
the performance of-unrelated radioc'hemical analyses 228
) of surface water.
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zehe collection of a monthly grab sample of Oyster Creek rather than-having a continuous yater sampling system.
10.
the failure to analyze bottom sediment (silt) for gamma-
- 0 ray emitting' radionuclides.
11.
the performance of scmewhat meaningless gross alpha and beta analys es of clams taken from Barnegat Day.
89 12.
the failure to conduct a sr analysis on class.
.13.
-the f a '.lur e to sample and analyze (radiochemically) the~' common benthic algae, aquatic plants, fin fish and other i
' marine organism of' Oyster Creek and-Barnegat Bay.
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