ML17266A537

Comments on Des.Radiological Monitoring Program Provides Adequate Sampling Frequency for Critical Exposure Pathways, But Could Be Modified to Address Problems of Monitoring Radiohalogens in Presence of Radionoble Gases

ML17266A537
Person / Time
Site:	Saint Lucie
Issue date:	12/21/1981
From:	VILLFORTH J C FOOD & DRUG ADMINISTRATION
To:	MIRAGLIA F J Office of Nuclear Reactor Regulation
References
RTR-NUREG-0842, RTR-NUREG-842 NUDOCS 8112280444
Download: ML17266A537 (6)

Text

REGULATV Y INFORMA'7 ION P ISTR I BUTION SYSTEbi (~R IDS)AOCESSION NBR:8112280944 DOC~DATE: '81/12/21 NOTARIZED; NO FAOIL:50 389 St~Lucie Pl antE Uniit 2E F l or ida Power 8 Light Co~'AUTH~NAME,.AUTHOR AFFILIATION YILLFORTHi J,G.HEis'<Dept0of i Food 8 Drug Administr ation IRBC I'P, NA/hE'RECIPIENT AFF ILI AT ION MIRAGLIAi F~J~Licensing Branch'

SUBJECT:

Comments on DES,Radiological moni,toring program'provides adequate sampling frequency-for'cri,tical Iexposure ipathwaysE but.'coulid

'be modi fied to address problems of moniltorin'g radiohalogens"in ipresence of radionoble

'gases.l OISTRIBUTIOR)COBE: C00'2B COPIES iRECEIVEO:LTiR

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DOCKET 05000389 RECIPIENT ID CODE/NANE ACTION: LIC BR N3 BC 06 NERSES E Y~01-INTERNAL; ELD NRR/DE/AEAB 20 NRR/DE/HGEB 21 NRR/DS I/AEB 19.NRR/DSI/RAB 17'COPIES LTTR ENCL 7 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAVE NL IE 13 NRR/DE/EEB 16 NRR/DE/SAB 18 EiTSB 1'5 04 COPIES LTiTR ENCL 1'2 1 1 1 1 EXTERNAL;ACRS NATL LAB NSIC 21 05 1 0 5'5 1 1 LPDR NRC PDR~NTIS 03 02[TOTAL NUMBER OF COPIES REQUIRED: UTTR 30 ENCL 1 4'L s Ei ll t o DEPARTMENT OF TH 84 HUMAN SERVICES Public Health Service Food and Drug Administration Rockville MD 20857 Mr.Frank J.Miraglia Licensing Branch No.3 Division of Licensing U.S.Nuclear Regulatory Commission Washington, D.C.20555 6~ca~ll)@6~gF9 o~cs4~9$Q~iggj%g@",gal<@,~~@@

Dear Mr.Miraglia:

The Bureau of Radiological Health staff have reviewed the Draft Environmental Statement (DES)related to the operation of St.Lucie Plant Unit No.2, NUREG-0842, dated October 1981.The proposed action covered by this DES is issuance of an operating license to the Florida Power and Light Company for the startup and operation of St.Lucie, Unit No.2.Comments on the Draft Environmental Statement-Construction Phase were provided by this agency in March 1974 (Appendix A-10, page B-121)prior to issuance of the construction permit in May 1974.We note that as of August 1981, the construction of Unit No.2 was approximately 80 percent complete.Bureau of Radiological Health staff have reevaluated the public health and safety impacts associated with the proposed operati,on of the plant and have the following comments to offer: 1.The 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 treatment system provide adequate assurance that the radio-active materials in the effluents will be maintained as low as reasonably achievable (ALARA).It appears that the calculated doses to individuals and to the population resulting from effluent releases are within the current radiation protection standards.

2.The environmental pathways identified in Section 5.10.3 and Figure 5.2, and discussed in Section 5.4, Appendix B-64 of the Final Environmental Statement-Construction Phase cover all possible emission pathways that could impact on the population in the environs of the facility.The dose computational methodology and models (Appendix E and P)used in the esti-mation of radiation doses to individuals and to populations within 80 km.of the plant have provided the means to make a reasonable estimate of the doses resulting from normal operations and accident situations at the facility.Results of these calculations are shown in Appendix P, Tables F-4.a, F-4.b, F-4.c, F-5, F-6 and P-7.These results confirm that the doses meet the design objectives.

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Mr.Frank J.Miraglia, NRC-Page 2 3.Discussion in Section 5.10.4 on the environmental impact of postulated radiological accidents is considered to be an adequate assessment of the radiation exposure pathways and the dose and health impacts of atmospheric releases.We will forego comments on the emergency preparedness section, since we realize that the process of granting an operating license to the facility will include an adequate review of emergency plans (FEMA-NRC Memorandum of Understanding, Regional RAC's criteria in NUREG-0654).

We have representation on the RAC's whose evaluation relative to the St.Lucie Plant will speak for this Agency.It is noted that an emergency operation facility (EOF)will be constructed (Section 5.13.2)which will be a focal point for directing responses and coordinating activities to mitigate the consequences of accidents.

4.The radiological monitoring program, as presented in Section 5.10.3.4 and summarized in Table 5.5, appears to provide adequate sampling frequency in expected critical'exposure pathways.The analyses for specific radio-nuclides are considered s'ufficiently inclusive to (1)measure the extent of emissions from the" plant, and (2)verify that such emissions 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 that the program might be modified to address'in paiticular the problems of monitoring radiohalogens (especially radioiodines) in the presence of radionoble gases.This could be accomplished by, reference to FEMA-REP-2, a document on instrumentation systems prepared with considerable input from NRC.5.Section 5.11 and Appendix I of this DES contain a description of the environmental impact of the Uranium Fuel Cycle (UFC).The environmental effects,prese'nted are a reasonable assessment of the populati.on dose com-mitment and the health effects associated with release of radon-222 from the UFC.There is no mention in Appendix I of the DES in EPA's Uranium Fuel Cycle standard, as promulgated in 40 CFR 190, and cited in Section 5.10.1, paragraph 1, on page 5-14.A statement should be included in the Appendix that the environmental dose commitment from all fuel cycle oper-ations meets the annual dose limits established by EPA.-Thank you for the opportunity to review and comment on this Draft Environmental Statement.

Sincerely yours, hn C.Villforth irector Bureau of Radiological Health

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