ML20098A995

Comments on Des (NUREG-1074).Dose-design Objectives of 10CFR50 Concerning Operating Stds of EPA 40CFR190 & Radwaste Mgt Sys Provide Adequate Assurance That Radiation Doses Meet Protection Stds

ML20098A995
Person / Time
Site:	Hope Creek
Issue date:	09/14/1984
From:	Rosenstein M FOOD & DRUG ADMINISTRATION
To:	Schwencer A Office of Nuclear Reactor Regulation
References
RTR-NUREG-1074 NUDOCS 8409250356
Download: ML20098A995 (2)

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2 I* DEPAR FMENT Of HEALTil & IIUMAN SERVICES Pubhc Health Service i

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%L Food and Drug Administration

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t Mr. A. Schwencer

! Chief, Licensing Branch No. 2 Division of Licensing

, U..i. Nuclear Regulatory Cmmission Washington, D.C. 29555

Daar Mr. Schwencer:

The Center for Devices and Radiological Health staff has reviewed the Draf t Envirormental Statement (DES) related to the operation of the Hope Creek Generating Station, NUREG-1074, dated June 1984. We have the following i cmments to offer:

1. It appears that the dose-design objectives of 10 CFR 50, the operating standatxis of EPA's 40 CFR 190, and the facility's radioactive waste manage-t ment system (Section 4.2.5) provide adequate assurance that the potential individual and population radiation doses meet current radiation orotection g standards. ,

2. The environmental pathways identified in Section 5.9 and shown schemati- n cally in Figurc 5.3, page 5-71, cover all possible emission pathways that r could impact on the population in the environs of the facility. The dose canputational methodology and nodels ( Appendix B and D) used in the esti- '

mation of radiation doses to individuals near the plant and to populations '

within 80 km of the plant have provided the means to make reasonable esti- .

mates of the doses resulting from normal operations and accident situations at the facility. Results of the calculations are shown in Appendix D, = ,

Tables D-6, D-7 and D-8 and confirm that the calculated doses meet the design objectives.

3. The discussion in Section 5.9.4 on the environmental impacts of postu- E?

lated accidents is considered to be an adequate assessnent of the radio- .

logical exposure pathways and the doses and health impacts of atmospheric release. The incltsion of Section 5.9.4.5 (7) on the uncertainties associ-ated with the assessment of potential environmenta! impacts and errergency =

response ef fectiveness should prove to be helpful in understanding the  !

E analysis of potential accidents. The discussion in Section 5.9.4.4(3' on i emetxjency preparedness does not include a statement on the location and function of an emergency operations facility (EOF) for mitigating the +

consequences of an accident that was identified in tne NRC's " Lessons Icarned" report following the '1MI accident on March 28, 1979.

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-, 4 Mr. A. Schwencer - Page 2 4.-The radiological environmental monitoring program outlined in-Section 5.9.3.4 and stamarized in Table 5.11 provides adequate sampling and analysis of environmental media for specific radionuclides to (1) verify the effec-tiveness of in-plant systems used to control releases of radioactive material, (2) ensure that unanticipated buildups of radioactivity will not occur in the envirorinent, and (3) verify that such emissions meet the applicable radiation protection standards. Since radiological monitoring is an important program in protecting the public health, we would appreciate being informed about the specifics of the final operational monitoring program that will be incorporated into the operating license Radiological Technical Specifications.

5. Section 5.10 and Appendix C contain a description of the environnental inpact assessment of the uranitzn fuel cycle related to the Hope Creek facility. The envirorsnental effects presented are a reasonable assessment of the population dose cm mitments and health effects associated with the release of radon-222 frcm the uranium fuel cycle.

Thank you for the opportunity to review and connent on this draft envirorsnental

! statement.

l Sincerely yours, tp d-Marvin Rosenstein, Ph.D.

Director l Office of Health Physics Center for Devices and Radiological Health I

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