ML19329F413
| ML19329F413 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island, Big Rock Point, Midland File:Consumers Energy icon.png |
| Issue date: | 01/28/1976 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Mondale W SENATE |
| Shared Package | |
| ML19329F414 | List: |
| References | |
| NUDOCS 8006270459 | |
| Download: ML19329F413 (8) | |
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- g 2 0 Q THIS DOCUMENT CONTAINS POOR QUAUTY PAGES Honorable Ualter F. Fondale United States Senate c.
Dear Senator Mondale:
This is in reply to your request of December 10, 1975, for our comments on a December 1, 1975 letter you received from Mr. Steve J. Gadler, Saint Paul, Minnesota.
Mr. Gadler expressed concern over the release of some radioactive mat;erial from the Prairie Island :fuclear Generating Plant und some other matters relating to this agency.
In order to provide seme information on the recent event referenced by Mr. Cadler, we are enclosing a copy of the Northern States Power Company's November 14, 1975 report on this event and a rap 1y sent by NRC to Mr. Peter L. Gove, Executive Director of the Minnesota Pollution Control Agency, in response to his letter of December 1. 19/5. u!.ich Mr. Cadler enclosed with his letter to you. Ue believe that these letters adequately describe the details of this event and the letter to Mr. Cove indicates that IEC believes that any possible dose associated with this release to an individual offsite is extremely low.
The unusual event report, which should have been submitted to the Commission by September 9,1975, was not submitted until November 14.
The licensee has indicated that the late reporting resulted from oversight. Because of the minor nature of the reported event and Northern States Power Company's favorable reporting history, we have no reason to believe at this time that the report was intentionally withheld. All aspects of the matter, including the late reporting, will be reviewed during a future inspection. Enforcement action vill be taken wherever warranted.
The amount of radioactive releases from Prairie Island is extremely low and it is not increasing at an alarming rate as P.r. Cadler alleges in his letter. Increasing, low-level releases during a plant's initial years of operation are normal. Italogen and particulate radionuclides with half-lives greater than eight days have been released at the following rates:
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Honorable 'talter F. "ondale -
Period Curies Released Annually, 1974 0.00045 1975 0.018 These release rates correspond to two percent and ninety-tuo percent, respectively, of the extremely conservative annuc1 design objective.
In order to put these values in perspective wo bava compared the possible individual annual thyroid dosco resulting fron the reported releason for,1974 and 1975 with the thyroid dose allouable under NRC regulatory limits. This comparison shows that for 1974, these releases were 0.007% of the Comnission regulatory limits and 0.3% for '975.
We believe from our review of Mr. Cadler's lotter that he does not clearly understand the relationship between NRC regulatory limits and "as lov as reasonably achievable" design objectives.
"e would like to clarify this catter by providing a summary discussion of the basis for the NRC regulations and standards for radiation protection. This is encitsure 1 to this letter.
We believa the discussion in enclosure I will also provide the basis for cur conclusion that the reported radioactive emissivas fron the trairie islana plant, are being maintained at very lov icvels and well within reg 21 story limits. No deleterious effcets to the health and safety of the public have been observed and none are expected as a result of routine emissions from nuclear plants in Minnesota or any ot1er state.
We would like to comment on Mr. Cadler's inference that the former AEC should have taken enforcement action when NSP exceeded a commitnant it made to the "innesota Pollution Control Authority.
The basis we utilize for evaluating the operation of a particular facility is the AEC (now NRC) regulations and commitments made to the regulatory authority in support of the license application.
The NRC (and the former AEC) cnforces its own regulations and does not take official notice of commitments which an NRC licensee might have made to the Minnesota Pollution Control Authority.
Mr. Cadler alleges that the NRC stresses the promotion of nucicar reactors an did the forner AEC. The NRC does not have the responsi-bility for promoting the nuclear industry. The Energy Reorganization Act of 1974, which created the URC and ERDA, gave the responsibilities for encouraging and neveloping all forms of energy to ERDA. The responsibilities of NRC were linited to regulating and licensing activities formerly covered under the Atomic Energy Act of 1954, as anonded, review of safety and safenuards of such activities and raco:"r.ending rcucarch necessary for the daie.harge of those functions.
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- 1 Certain questions were also raised in Mr. Cadler's letter relating to the uso of plutonium at Big Rock Point in Michigan and plans for use of plutonium at Midland, Michigan. Tite questions asked and our reply to each follows in enclosure 2.
Uc hope that this information vill be helpful in your response to Mr. Cadler.
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Sincerely, W.lliam I. Dircks Assistant Executive Director for Operations
Enclosures:
1.
NRC Regulatory Linits and "As Low As Ecssenchly Achiavable" T,w=Iv,u 6ajectives 2.
Plutoniu:2 Use at Big Rock Point and Midland 3.
Ltr fm S. J. Gadler to Senator Mondale, dtd 12/1/75 i
4.
Ltr fm L. O. Mayer to-R. S. Boyd 6td 11/14/75 5.
Ltr fa D. L. Ziemann to P. L. Gove itd 12/24/75 i
Distribution:
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PDR (50-282, 306, 155, 329, 330)
IE Files (5)
LPDR (50-282, 306,155, 329, 330)
SECY (3) (76-0907)
OCA (3) v/o ine'- w/enci B. C. Rusche, NRR G. Ertter (9561)
IE Reading K. R. Chapman, NMSS EDO Reading H. K. Shapar, ELD D & SS MID Reading OGC SEB Reading B. H. Weiss, SEB:IE l
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Honorable tialter T. Mondale These release rates correspond to two percent and ninety-four percent, respectively, of the extreaaly conservative annual design objective.
Durinr, the three-conth period ending in nid-December, the release rate averaged si::ty percent of the design objective. Ile do not e<pect the annual design objective, which as Mr. Gadler's letter points out is not an operating limit, to be exceeded during 1975.
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We conclude from our review of Mr. Gadler's letter that he is socewhat confused about NRC re3ulatory limits and "as low as reasonably achievable" design objectives.
'Te would like to clarify this natter by providing a s
su:::=ary discussion of the basis for the ERC regulations and atandards for radiation protection. This is enclosure 1 to this letter.
We believe the discussion i enclosure 1 vill also provide the basis for our conclusion that the reported radioactivo eniesions from the Prairie Island plant, are bein;; unintdined et very low icvels and well within regulatory linits. No deleteribus effects to the health and safety of thepublichavebeenobservedorhreexpectedasaresultofroutine emissions fron nuclear plants in Minnesota or eny other state.
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Certain questions were also raised i:rgr. Cadler's letter relating to the use of plutoniun at Big Rock PointNin Michigan and plans for use of plutonium at !!idland, Michigan. The questions ashed and our reply to each follows in enclosure 2.
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l We hope that this inforcation will be helpful in your response to Mr. Gadler.
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I Sincerely.
Enclosures:
1.
NRC Regulatory Limits and
- 4. Ltr fm L. O. Mayer to R. S. Boyd "As Low As Reasonably Achievable" dtd 11/14/75 Design Objectives
- 5. Ltr fm D. L. Ziemann to P. L. Gove 2.
Plutonium Use at Big Rock Point and Midland dtd 12/24/75 3.
Ltr fm S. J. Gadler to Senator Mondale, dtd 12/1/75 Distribution w/inc & w/ encl w/o inc & w/ encl L. N. Underwood, IE PDR (50-282,306,155,329,330) t Central Files (5)
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i NRC Regulatory Limits and l'
"As Low As Reasonably Achievable" Design Objectives The official guidance to NRC and other Federal agencies for control of exposures to radiation has been provided through recommendations of the Federal Radiation Council (FRC) and approved by amendment to the Atomic Energy Act of 1954 (420s.C.2021(h)). The functions of the FRC_were transferred to the Environmental Protection Agency under Reorganization Plan No. 3 of 1970.
The radiation protection guides of the FRC are generally consistent with the recommendations of the National Council on Radiation Protection and Measurements (NCRP) and the International Commission on Radiological Protection (ICRP). These guides and recommendations form the basis for the Commission's regulation,10 CFR Part 20, " Standards for Protection Against Radiation". 'The radiation protection guides established by the FRC for individual members of the public are 500 millirems per year to the total body and bone marrow and 1500 millirems per year to the thyroid and bone.
The FRC radiation protection guides and the recommendations of the NCRP-ICRP give appropriate consideration to the overall requirements of health protection and the beneficial use of radiation and atomic energy. Any biological effects that may occur at the low levels of the FRC guides 4
occur so infrequently that they have not been detected with existing techniques. The FRC, however, has added to its recommendations of the provision that every effort should be made to maintain radiation doses as far below the numerical radiation protection guides as practicable.
The NRC subscribes to the general principle that, within established radiation protection guides, radiation exposure should be kept as low as reasonably achievable.
The Commission amended its regulations on June 4, 1975, to give appropriate regulatory effect to the qualitative guidance of the FRC for as low as reasonably achievable radiation doses. The amendment adds an Appendix I to Part 50 of Title 10 of the Code of Federal Regulations._
The Appendix.contains numerical guides for design objectives and limiting i
conditions for operation to meet -the criterion "as low as reasonably achievable" for radioactive material in light-water-cooled nuclear power i
reactors..
The exposures to the public living in the immediate vicinity of operating i-power reactors have been cmall percentages of Federal radiation protection guides.
It is expected that conformance with the Appendix I guides on i
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. design objectives and limiting ~ conditions of operation will provide reasonable _ assurance that annual total-body doses to individuals living x
near the boundary of a site will'be generally less than five percent of
- average doses from natural background radiation (which is usually about i
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2-100 millirems per year) and one percent of Federal Radiation protection guides for individual members of the public.
It should be emphasized that the numerical guides are design objectives.
Licensees will be and are permitted flexibility in operation which may temporarily result in releases higher than such numerical guides for design objectives to assure that the public is provided a dependable source of power even under unusual operating conditions. However, these-higher releases will be compatible with considerations of health and safety and still within levels that assure that doses to the public are equivalent to small fractions of doses from natural background radiation.
The NRC includes in each license to operate a nuclear power plant a set of " technical specifications" which must be met by the plant. The general contents of technical specifications and their enforcement are described in the NRC regulations,10 CFR Part 50.
The specifications prescribe limits on the release of radioactive effluents. Originally the limits were based on the radiation protection standards of the Commission's regulations,10 CFR Part 20, which we mentioned earlier.
During the three years the NRC was considering Appendix I, all new licensees of nuclear power plants adopted radioactivity release limits more restrictive than 10 CFR Part 20, which were based on proposed "as low as practicable" design objectives. In the case of Prairie Island, their technical specifications for halogens in gaseous effluents were based on an early proposal which considered the design objective for an individual's thyroid to be 1/6 of the value in the final rule.
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e Plutonium Use at Big Rock Point and Midland 4
1.
Is this a decision the company is allowed to make?
Reply:
No. Consumers Power Compcny did not and cannot use plutonium without review and approval of the NRC.
In fact, each licensee or applicant for a license change relating to the reactor core is required to submit details of the reactor core design or design modifications to NRC for review. The review process and approval or disapproval actions are governed by the Code of Federal Regulations, Title 10, Chapter I, Parts 2 and 50.
2.
How can they do this without a public hearing?
Reply: They cannot. The Midland case is still in the licensing review 4
I stage. An opportunity for public participation is afforded by the independent Atomic Safety and Licensing Board (ASLB).
Both the radiological health and' safety matters and the environmental matters will be discussed at a location near the proposed site. The use of increased amounts of plutonium at Big Rock Point are subject to conpletion of a public hearing as discussed in Reply No. 4 below.
3.
How can the NRC allow it?
Reply: Our replies No. 1, 2 and 4 should also answer this query.
4.
Isn't it a violation of NEPA?
Reply:
No.
In 1969, Congress passed the National Environmental Policy Act (NEPA). Our regulations implementing NEPA require preparation of draft detailed environmental statements of the impact of our licensing actions; their review by appropriate Federal, state and local agencies; and preparation and submittal to the President's Council on Environmental Quality of Pinal Environmental Statements. The review process by the Commission's staff includes an evaluation of the potential environmental impact of proposed plants and includes a comparison.of the benefits derived against the possible riske to the environment.
The Big Rock Point case involves a request to increase the amot:nt of mixed exide (plutonium) tuel from amounts of less than 50 kilograms to 150 kilograms. Consumers Power Company has operated safely with test assemblies of plutonium in Big Rock Point since 1969 with AEC approval.
In 1972, Consumers requested approval for the increase in the amount of plutonium.
l The increase was approved by the AEC, but has not been implemented g
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. in the reactor because of an ASLB hearing on the subject.
The hearing was temporarily suspended by order of the NRC Commissioners for certain genericl/ considerations relating to wide scale use of plutonium.
In August, 1975 the Commissioners ordered that NEPA's requirements for Big Rock Point can be met through a discrete environmental review.
Therefore, increased use of plutonium at Big Rock Point will only be allowed when a positive decision results from the present hearing process. A necessary premise for any positive decision would be full compliance with all NEPA requirements, as noted above.
1/ WASH-1327 August 1974 Draft Generic Environmental Statement Mixed Oxide Fuel (GESMO).
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