ML20206D708

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Comments on Apr 1986 Des for Decommissioning Facility (NUREG-1166).Section 1.3 Provides Reasonable Justification for Selecting Safstor Decommissioning Method.Storage of Spent Fuel Will Provide Adequate Protection & Safety
ML20206D708
Person / Time
Site: Humboldt Bay
Issue date: 06/16/1986
From: Villforth J
HEALTH & HUMAN SERVICES, DEPT. OF, U.S. PUBLIC HEALTH
To: Berkow H
Office of Nuclear Reactor Regulation
References
FRN-51FR15853, RTR-NUREG-1166 NUDOCS 8606200164
Download: ML20206D708 (2)


Text

es.

DEPA RTM ENT OF IIEA LTil & IlUM A N SER VICES Public Hulth SIrvica

\%. W Food and Drug Adrninistration Rockville MD 20857 JUN 161986 gy 33 Herbert N. Berkow Director Standardization and Special Projects Directorate Division of PWR Licensing-B U.S. Nuclear Regulatory Comnission Washington, DC 20555

Dear Mr. Berkow:

The Staff of the Center for Devices and Radiological Health have reviewed the Draft Envirormental Statemant (DES) for decmmissioning the Hunboldt Bay Ibwer Plant, Unit No. 3, NUREG-1166, dated April 1986. Primarily our effort has been directed to an evaluation of the public health and safety impacts associated with the decmmissioning alternatives. We have the following camnents to offer:

1. The discussion of decmmissioning alternatives in Section 1.3 provides a reasonable justification for selecting the safe storage alternative (SAFSTOR) . Further, storage of the spent fuel assemblies of the Hunboldt Bay Unit 3 spent fuel storage pool is considered to be the most effective alternative and will provide adequate measures to protect public health and safety.
2. It is expected that small quantities of radioactivity will be released to the environment during normal SAFSTOR operations. The source of such radioactivity will result frm decontamination of systems and camponents, the operation and maintenance of the spent fuel storage pool, and the processirn of waste managment operations which have continued since the plant ceased operation in July 1976. Thus, the source tenn for estimating population dose over the 30-year SAFSTOR period is based on data gathered for the years 1977 through 1983. The calculated annual release rate of radioactive material in liquid effluents and in gaseous and particulate i effluents are shown in Table 3.1 and 3.2, respectively. Even though the releases are in the low nCi/yr range we believe that a measurement program should be conducted m verify that the releases are maintained as low as

, reasonably achievable (ALARA). The results of such a program should be made available to state and local health officials responsble for evaluating po-j tential population dose from the decmmissioning operation.

3. The discussion in Sectio. 3.2 on the radiological impact covers the possible sources of occupational and population exposure. The dose cmputa-
tion methodology and models (Appendix B) used in the estimation of the dose l

cmmitments to individual members of the public and to the general population within 80 kilmeters of the plant have provided reasonable estimates of the l

doses resulting frm decmmissioning operations. Results of these calcula-tions are shown in Appendix B, Table B.3 and B.4, and confirm that the calcu-lated doses are minimal and meet current radiation protection standanis.

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Herbert N. Berkow - Page 2

4. '1he potential accident scenarios and offsite radiological consequences of such accidents is considered to be an adequate assessment of the exposure .

pathways and the dose and health impacts resulting frm accident situations.

5. 'Ihe DES does not contain any specific information on emergency planning and coordination with the State of California in the unlikely event of an accident.

In our judgment, a section should be added to Chapter 3 that briefly presents 4

the plans and coordination that would be in place during the-30-year decmmis-sioning period. This action is particularly important at this time in view of the increased concern of the public relating to emergency response and pro-tective actions.

Thank you for the opportunity to review end coment on this Draft Environmental Statement.

Si rs,

%ncerelyyL/A

/ John C. Villfor

/' Director

/ Center for Devices and Radiological Health

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