ML19275A059

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Forwards Comments Re Review of Draft Eis.Statement of Compliance W/Epa U Fuel Cycle Std Needed.Transportation Section Requires Inclusion of Measures to Insure Public Safety During Shipment
ML19275A059
Person / Time
Site: New England Power
Issue date: 08/08/1979
From: Custard C
HEALTH & HUMAN SERVICES, DEPT. OF
To: Ballalrd R
Office of Nuclear Reactor Regulation
References
NUDOCS 7908300676
Download: ML19275A059 (3)


Text

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k' 1. ] DEPARTMENT CF HEALTH. EDUCATION. AND WELFARE

CFFICE OF THE SECRETARY 9

W ASHINGTON. O C. 2C20' August 8, 1979 Mr. Ibnald L. Ballard, Chief Envisuaild.al Projects Branch 1 Division of Site Safety and Environme:1tal Analysis Nuclear Ibgulatory Ctanission Washington, D.C. 20555

Dear Mr. Mllard:

h Departrent has reviewed the draft envitessital impact statanent on the New England Power Units 1 and 2 (NEP 1 & 2),

Block Island Sound, Charlestown, Ihode Island. Our m ".ts are attached.

Sincerely yours,

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Charles Custard Director office of Envu m tal Affairs Attachment 2032 ro lh00 I tM\ l 7908300676

MMORANDUM EPARTMENT OF HEALTH, EDUCATION, AND WELFARE PUBLIC HEALTH SERVICE FOOD AND DRUG ADNtINISTRATION TO Charles Custard DATE: July 20,1979 Director, OEA Consultant FROh! Bureau of Radiological Health (HFX-4) sUafEcT: Comments on DEIS - New England Units 1 and 2 (NEP 1 & 2)

The Bureau of Radiological Health as reviewed the health aspects of the subject DEIS and has the fcilowing comments to offer.

Section 5.4.1 Radiological impact on man The predicted dose commitments to the maximum individual from radioiodine and particulate releases are listed in Tables 5.12 and 5.13. The individual doses for units 1 and 2 are within Appendix I, 10 CFR 50 design objectives. However, in view of EPA's Uranium Fuel Cycle Standard (40 CFR 190) which becomes effective December 1,1979 a statement should be added indicating that NEP 1 and 2 will meet this standard. Since the plant is expected to come on line after the effec-tive data of the EPA Standard a footnote should be added to Table 6.12 citing the numerical standard and total quantity limitations for normal operations. Recognition of this standard should also be acknowledged in Section 5.4.1.6 since it appears that the actual radiological im-pact of plant operations may result in doses close to the design ob-jective. That is, the 40 CFR 190 Uranium Fuel Cycle Standard will be the appropriate radiation protection standard after December 1,1979.

The transportation of radf oactive material dircussed in Section 5.4.1.4 is not considered to be adequate with respect to the transport of low level radioactive waste to the burial ground. The section should be expanded to indicate that adequate measures exist to insure public safety during shipment. For example, the Governor of the State of Nevada closed the Beaty site for a period of time because accidental leakage of radioactive material could cause a public health problem.

It should also provide an assessment of the facilities that could be expected to be available for receiving the waste. Further, footnote (a) for Table 5.17 cites the Federal Radiation Council guidar.ce of 500 millirem per year for individuals in the general population. As stated previously, effective December 1,1979, 40 CFR 190 will be the appropriate standard and the maximum individual whole body dose will be 25 millirem. (Page A-10, 40 CFR 190) 2032 3rn RECElVED JUL 3 01979 Ctly of (nugnmemat ,wan

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Directer, OEA 2 6.1. 3 Radiological The operational offsite radiological monitoring program should be reexamined to determine if the modifications are required in the type of sampling ana sampling location and collection frequency to assure that timely population exposure data would be available in the event of an accident.

Section 7 Environmental Impact of Postulated Accidents The experience from the Three Mile Island accident shows the need for the addition of a section on emergency response plans. Such a section should include a summary of the critical aspects of the detached emer-gency response plan which will provide assurance that adequate plans exist and have been tested. We believe that including such a discussion in the DEIS would serve to point out the key actions that would be taken to protect public health and safety in the event of an accident.

The monitors located at critical points in the plant should be reexamin-ed to assure that adequate data would be available for making timely decisions in the event of an accident. Further, provisions should be made so that post accident samples of reacto.a coolant water in the containment atmosphere can be made to provide an early indication of any potential public health problems.

2.9 Attitudes Toward NEP 1 and 2 It is noted from the discussion in this section that there is opposition in the town of Charlestown for the use of the abandoned Navy Auxiliary Landing Field (NALF) as the site for NEP 1 and 2. Since publication of the DEIS, it is my understanding from reading Nuclionics Week that this site has not been approved and that the New England Power Company is looking for an alternate site.

- < W Charles L. Weaver )

cc:

Dr. Taylor (HFV-2) 2032 91