ML20054B596

Comments on NUREG-0537,DES for Facilities.Problems of Monitoring Radiohalogens in Presence of Radionoble Gases Should Be Addressed

ML20054B596
Person / Time
Site:	Midland
Issue date:	04/12/1982
From:	Villforth J FOOD & DRUG ADMINISTRATION
To:	Hernan R Office of Nuclear Reactor Regulation
References
RTR-NUREG-0537, RTR-NUREG-537 NUDOCS 8204160628
Download: ML20054B596 (2)

Text

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[ DEPA RTM ENT OF llEALTil & IIUM AN SERVICES Public Hrlth Servics i

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[ (h ' Q U Office of Nuclear Reactor Regulation g N /

U.S. Nuclear Regulatory Commission , +

Washington, D.C. 20555

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Dear Mr. Hernan:

he Bureau of Radiclogical Health staff have reviewed the Draft Environmental Statement (DES) for the Midland Plant, Units 1 and 2, NURD3-0537, dated February 1982.

In reviewing the DES, we note that (1) the application for a construction permit is dated January 13, 1959, (2) the NRC staff evaluation was issued as a Final Environmental Statement - Construction Phase in December 1972, and (3) as of December 1981, Unit No. I was about 73 percent complete. W e Bureau of Radiological Health staff have assessed the public health and safety impact associated with the proposed operation of the plant and have the following comments to offer:

1. It appears that the design objectives of 10 CFR 50, Appendix I, the operating standards of EPA's 40 CFR 190, and the applicant's radioactive waste treatment system and effluent control measures provide adequate assurance that the radioactive materials in the effluents will be main-tained as low as reasonably achievable (ALARA). W e calculated doses to individuals and to populations from effluent releases are within the current radiation protection standards.

2. %e environmental pathways identified in Section 5.9.3 and Figure 5.2, and discussed in Section 5.9.3.1, cover all possible emission pathways that could impact on the population in the environs of the facility. %e dose computational methodology and models (Appendix C 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 and accident situations at the facility. Results of these calculations are shown in Appert11x C, Tables C.6, C.7, C.8 and C.9. %ese results confirm that the doses meet the design objectives.

3. %e discussion in Section 5.9.4 on the environmental impact of postu-lated accidents is considered to be an adequate assessment of the radi-ation exposure pathways and the dose and health impacts of atmospheric releases. We evacuation model presented in Appendix F.1 is based on assumed conditions and capabilities for evacuation in specified downwind directions. Since evacuation involves early and expeditious movement of people to avoid exposure from the passing radioactive cloud and any acute ground contamination following cloud passage, it would be helpful to include some references to show that sttxlies either have been made or are planned to verify the model and to demonstrate that evacuation is feasible at the specific facility covered by the DES.

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Mr. Honald W. Hernan - 2 We will forego commenting on the emergency preparedness discussion in Section 5.9.4.4(3), since we realize that the process of granting an operating license to the facility will include an adequate review of emer-gency preparedness (FD4A-NRC Memorandum of Understanding, Regional RAC's, criteria in NURE-0654). We have representatives on the RAC's whose eval-uation relative to the Midland Plant will speak for this agency. It is noted in Section 4.2.1 that an Dnergency Operation Facility (EOF) will be constructed which will be the focal point for directing responses aM coordinating activities to mitigate the consequences of accidents.

4. We radiological monitoring program, as presented in Section 5.9.3.4, and stunmarized in Table 5.3, appears to provide an adequate environmental monitoring program for the critical exposure pathways. However, it is indicated that milk will be sampled at five locations, but it does not include information on frequency of analysis and required sensitivity.

(Required analytical sensitivity is given in NURE 0492.) In our view, it is important to establish a well-planned program as part of the operational monitoring program. Such a program is needed in the event of a radiological accident to provide a source of data on radioiodine in milk for use in the event protective actions are necessary.

Also, we suggest that the plan be modified to address the particular problems of monitoring radiohalogens (especially radioiodine) in the presence of radionoble gases. Wis could be accomplished by reference to FD4A REP-2, a document on instrinnentation with considerable input from NRC. Flirthermore, it would be helpful to cite specific studies at operating plants that would verify that the instrument systems for making such measurements actually perform as expected and meet the technical specifications.

5. Section 5.10 and AppeMix G contain a description of the environmental impact of the uranitzn fuel cycle. % e environmental effects presented are reasonable assessnents of the population dose commitments and health effects associated with the release of radon-222 from the Uranium Fuel Cycle.

Thank you for the opportunity to review and comment on this Draft Environmental Statenent.

Sincerely yours, M9&(ohn C. Villf$rt h Director pureau of Radiological Health

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