ML20197J504
| ML20197J504 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/09/1998 |
| From: | Craig C NRC (Affiliation Not Assigned) |
| To: | Samuels S AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9812150112 | |
| Download: ML20197J504 (7) | |
Text
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UNITED STATES e
3 NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666 4 001 s,
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g December 9, 1998
$> W Mr. Sheldon W. Samuels Vice President The Ramazzini institute P.O. Box 1570 Solomons Island, MD 20688
Dear Mr. Samuels,
Thank you for your letter dated November 2,1998, regarding our environmental scoping summary report you received and reviewed. In your letter, you stated that by omitting a discussion regarding the risks of radiation exposure, we seriously skewed the communication and unnecessarily distorted the public dialogue on issues related to nuclear power. In this letter, I will address public radiation dose and the work performed in support of license reriewal with regard to radiation exposure, and radiation dose limits.
The purpose of the scoping process under the National Environmental Policy Act (NEPA)is to identify issues that should be addressed further in the environmental impact statement being prepared in support of the review of the Calvert Cliffs Nuclear Power Plant license renewal application. The staff is focusing its evaluation in the environmental impact statement on the environmental impacts expected to occur as a result of any refurbishment activity for license renewal and the additional 20 years of operation.
The staff issued a Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Power Plants (NUREG-1437) that evaluated the impacts expected from license renewal. The document is available for purchase through the Government Printing Office, while j
copies are available for inspection at the Calvert County Public Library. In the GEIS, the staff examined public radiation doses for the petiod of license renewal.
For each year from 1975 to 1992, the NRC issued a report entitled " Population Dose Commitments Due to Radioactive Releases From Nuclear Power Plant Sites,"
I NUREG/CR-2850. In the 1975 through 1992 period, nuclear energy generation increased about 360 percent, but the associated collective dose to the public declined from 1,345 to 47 person-rem. That is, the average annual dose from effluents to people living in the vicinity of nuclear power plants dropped to about.0003 millirem (mrem). which is about the dose the average
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American receives from the earth every 5 minutes. The estimated cancer risk to the average individual due to plant operations is much less than 1 x 104 Radioactive effluents and doses have decreased over the years, and because of the improvements in reactor fuel and effluent control measures, evidence suggests that radioactive effluents and doses will continue to
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2 decrease. In fact, doses to the maximally exposed individual 11so demonstrated a decreasing trend. By the end of the 1975-92 period, seventy-nine percent of the sites reported doses to maximally exposed individuals that were less than.2 mrem. The two highest doses reported in 1992 were.93 mrem and.80 mrem. These doses are well within the 10 CFR Part 50, Appendix 1, design objectives, as explained below.
On the basis of the information presented above, radiation doses to members of the public can be projected into the license renewal period. The three areas that were evaluated in the GEIS are: the maximally exposed individual, the average exposed individual, and the collective exposure of the population. After examining radiation doses to members of the public from a variety of perspectives, the staff found that doses were well within design objectives and regulations. Radiation exposures of the average individual and collective doses to the population around a nuclear power plant are not anticipated to increase from present levels in the period after license renewal.
Based on this, the staff concluded that the significance of radiation exposure rates to the public attributable to operation after license renewal will be small at all sites. No further mitigation measures were identified. Thus, the staff identified radiation exposure to the public as a Category 1 issue. Category 1 issues need not be addressed by applicants unless new and significant information is ideatified. The conclusions in the GEIS regarding radiation exposure were adopted by Baltimore Gas and Electric in its license renewal application. The staff will summarize the GEIS conclusions, along with any new and significant information, regarding radiation exposure in its draft GEIS, Supplement 1, pertaining to the Calvert Cliffs license renewal.
Your letter outiines two issues: 1) the general standards for dose limits cover all populations equally without distinguishing variable susceptibilities of any one population, except for occupationallimitations, and 2) the epidemiologic and experimental data argue against the likelihood of a threshold for every type of cancer With respect to the first issue, Part 20 of Title 10 of the Code of Federal Regulations (10 CFR Part 20) identifies dose limits, including occupational, dose limits for adults, occupational dose limits for minors, dose limits to an embryo / fetus, and dose limits for individual members of the public. The total effective dose limit for individual members of the public from license operation is 100 mrem in a year. As stated in the environmental impact statement scoping process summary report, these limits are carefully consdered and are conservative to protect chiidren as well as adults. The licensee must demonstrate continued compliance with these limits. These limits are based on the Fundamental Radiation Protection Principles published in the Federal Register on May 21,1991 (56 FR 23360). With respect to your concern regarding threshold limits for every type of cancer, in promulgating the protection pnnciples, the Commission assumed the following: a linear nonthreshold relationship between dose and probability of stochastic health effects, such as latent cancer and genetic effects; the severity of each type of stochastic health effect is independent of dose; and that certain nonstochastic health effects. such as radiation induced cataracts of the eyes, can be prevented Dy limiting exposures so that doses are below the thresholds for their induction. The Commission also recognized that the dose limits combined with the principle of keep ~ng all radiation exposures "as low as reasonably achievable" (ALARA) provided a significantly greater degree of protection than relying on the dose limits alone. The ALARA principle has been formalized in Appendix 1 to 10 CFR Part 50, " Numerical Guides for L
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P Design Objectives and Limiting Conditions for Operation to Meet the Criterion 'As Low As Reasonably Achievable' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents." The appendix provides numerical guides for various radiation effluents so that the dose to any member of the public does not exceed the design objectives. Alllicensees strive to maintain doses as low as reasonably achievable.
We do not intend to issue changes to the scoping summary report, however, we did consider the issues you raised and determined no new and significant information beyond the GEIS conc'osions was identified. The draft GEIS, Supplement 1, pertaining to the Calvert Cliffs license renewal is scheduled to be issued in March 1999, and we plan to hold a public meeting in the local area in April 1999, to solicit comments on the draft document. I appreciate your continued interest in these issues and encourage you to review the draft document and provide comments.
Please notify me of the time and place of your pres?ntation at the county-wide meeting you referenced in your letter. If schedules permit, members of the staff may be interested in attending the meeting to hear your presentation. I can be reached at 1-800-368-5642, extension 415-1053 or via the Internet at: cceis@nrc. gov.
Sincerely, 1
64 Claudia M. Craig, Senior Project Manapr Generic Issues and Environmental Project Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-317,50-318 cc: See next page l
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Design Objectives and Limiting Conditions for Operation to Meet the Criterion 'As Low As Reasonably Achievable' for Radioactive Materialin Light Water-Cooled Nuclear Power Reactor Effluents." The appendix provides numerical guides for various radiation effluents so that the i
dose to any member of the public does not exceed the design objectives. Alllicensees strive to maintain doses as low as reasonably achievable.
We do not intend to issue changes to the scoping summary report, however, we did consider the
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issues you raised and determined no new and significant information beyond the GEIS 1
conclusions was ider lified. The draft GEIS, Supplement 1, pertaining to the Calvert Cliffs l
license renewalis scheduled to be issued in March 1999, and we plan to hold a public meeting in the local area in April 1999, to solicit comments on the draft document. I appreciate your continued interest in these issues and encourage you to review the draft document and provide comments.
l Please notify me of the time and place of your presentation at the county-wide meeting you l
referenced in your letter. If schedules permit, members of the staff may be interested in attending the meeting to hear your presentation. I can be reached at 1-800-368-5642, extension 415-1053 or via the Internet at: cceis@nic. gov.
Sincerely, Original Signed By:
Claudia M. Craig, Senior Project Manager Generic issues and Environmental Project Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-317,50-318 cc: See next page DISTRIBUTION: See next page DOCUMENT NAME: g:/ cmc 1/ramazz.itr
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I Calvert Cliffs Nuclear Power Plant Baltimore Gas & Electric Company Unit Nos.1 and 2 cc:
President Mr. Joseph H. Walter, Chief Engineer Calvert County Board of Public Service Commission of Commissioners Maryland 175 Main Stree' Engineering Division Prince Frederick, Md 20678 6 St Paul Centre Baltimore, MD 21202-6806 James P. Bennett, Esquire Counsel Kristen A. Burger, Esquire Baltimore Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre Baltimore, MD 21203 Suite 2101 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire Shaw, Pittman, Potts and Trowbridge Patricia T. Birnie, Esquire 2300 N Street NW Co-Director Washington, DC 20037 Maryland Safe Energy Coalition P.O. Box 33111 Mr. Thomas N. Pntchett, Director Baltimore. MD 21218 NRM Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell 1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattwooga, TN 37411-4017 Resident inspector clo U.S. Nuclear Regulatory Mr. Char!2s H. Cruse Commission Vice President - Nuclear Energy P.O. Box 287 Baltimore Gas and Electric Company St. Leonard, MD 20685 Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Mr. Richard I. McLean, Manager Lusby, MD 20657-4702 Nuclear Programs Power Plant Research Prograrn Mr. Roy Denmark Maryland Dept. of Natural Resources Federal Activities Office Tawes State Office Building,83 U.S. Environmental Protection Agency Annapolis, MD 21401 Region 111 841 Chestnut Budding Regional Administrator, Region l Philadelphia, PA 19107 U.S. Nuclear Regulatory Commission 475 Allendale Road Mr. J. Rodney Little King of Prussia, PA 19406 Director and State Historic Preservation Officer 100 Community Place Crownsville, MD 21032
Calvert Cliffs Nuclear Power Plant Baltimore Gas & Electric Company Unit Nos.1 and 2 cc:
Mr. John Wolfin Mr. Daniel L. Larcamp Supervisor - Chesapeake Bay Field Office Assisant General Counsel U.S. Fish & Wildlife Service Electric Rates and Corporate Regulation 177 Admiral Cochrane Drive Federal Energy Regulatory Commission Annapolis, MD 21401 888 First St., NE Washington, DC 20426 Ms. Barbara Schroeder National Marine Fisheries Service Mr. Roland G. Fletcher, Manager Office of Protected Resources Radiological Health Program 1315 East-West Highway Air and Radiation Management Silver Spring, MD 20901 Adminsitration Maryland Department of the Environment Merrilyn Zaw-Mon, Director 2500 Broening Highway Air and Radiation Management Baltimore, MD 21244 Administration Maryland Department of the Environment Doug Walters 2500 Broening Highway Nuclear Energy institute Baltimore, MD 21244 1776 i Street, N.W.
Su;te 300 H. Russell Frisbey, Jr., Chairman Washington, DC 20006 i
Maryland Public Service Commission 16th Floor Badh Doroshuk 6 St. Paul Street Baltimore Gas and Electric Baltimore, MD 21202-6806 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 Dorchester County Commissioners County Office Building National Whistleblower Center P.O. Box 26 3233 P Street, N.W.
Cambridge, MD 20650 Washington, DC 20007 St. Mary's County Commissioners P.O. Box 653 Leonardtown, MD 20650 l
Charles County Board of County Commissioners P.O. Box B Government Building La Plata, MD 20646 Mr. David Lewis l
Shaw, Pittman, Potts, and Trowbridge 2300 N Street, NW Washington, DC 20037
' Letter to Sheldon Samuels dated December 9. 1998 Distribution:
Hard Conv Docket File PGEB R/F' l
iCentral Files PDR LPDR i
MEl-Zeftawy, ACRS CCraig E-Mad FMiraglia/RZimmerman JRoe DMatthews CGrimes TEssig THiltz JMoore i
l RWeisman MZobler DMartin WMcDowell SDroggitis
' DSolorio ADromerick-LDoerflein BBores JStewart, Senior Resident inspector GMeyer.
RArchitzel CCraig CSochor RJolly.
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