ML19224D152
| ML19224D152 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/16/1979 |
| From: | Nedzi L HOUSE OF REP., ARMED SERVICES |
| To: | |
| Shared Package | |
| ML19224D151 | List: |
| References | |
| ACRS-SM-0129, ACRS-SM-129, NUDOCS 7907110003 | |
| Download: ML19224D152 (21) | |
Text
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OPENING STATEMENT OF CHAIRMAN LUCIEN N.
NEDZI SUBCOMMITTEE ON MILITARY INSTALLATIONS AND FACILITIES Wednesday, May 16, 1979 This morning the Subcommittee on Military Installations and Facili ties begins hearings on the civil defense aspects of the Three Mile Island nuclear accident.
Specifically, the Subcomm' 'ee is examining the role of the Federal government in the development and execution of the crisis evacuation and relocation program, the status Of the program, 'he reie of states and the local governr 'ts in the program, and tne Three Mile Island experience with the program.
To assist the Subcommi ttee, wi tnes ses have been scneduled from various Federal agencies, State emergency preparedness offices and local civil def ense uni ts.
Today, the Subcommittee will receive tes timony from the General Accounting Office on its report en ti tl e d, " Areas Around Nuclear Facilities Should be Prcoared for Radiciogical Emergencies," and from the Nuclear Regulatory Commission.
The witnesses are:
J.
Dexter Peach, Director E r. e r gy and Mine,als Division General Accounting Office Josepn M-Hendrie, Chairman Nuclear Regulatory Commission 79071 lox 3 259 332
UNITED STATES GENERAL ACCOUNTING OFFICE WASHINGTON, D.C.
20548 FOR RELEASE ON DELIVERY EXPECTED AT 10 00 a.m.
Wednesday, May 16, 1979 STATEMENT OF J. DEXTER PEACH, DIRECTOR ENERGY AND MINERALS DIVISION BEFORE THE SUBCOMMITTEE ON MILITARY INSTALLATIONS AND FACILITIES HOUSE COMMITTEE ON ARMED SERVICES ON EMERGENCY PREPAREDNESS AROUND NUCLEAR FACILITIES Mr. Chairman and Members of the Subcommittee:
We welecme the opportunity to be here today to discuss emergency preparedness around nuclear facilities.
On March 30, 1979, we issued a report 1/ to the Congress in which we concluded that areas arcund nuclear facilities should be better prepared for emergencies.
The recent ac-cident at the Three Mile Island nuclear powerplant near Harrisburg, Penn.="lvania, underscores the.need for sound nuclear emergency preparedness at all governmental levels.
Since 1973 three Federal agencies have had primary planning and coordination responsibility for general civil emergency preparedness and response.
The agencies are:
--The Federal Preparedness Agency in the General Serv-ices Administration (GSA), which develops and coor-dinates civil preparedness policies and programs 1/" Areas Around Nuclear Facilities Should Be Better Prepared for Radiological Emergencies," EMD-78-110, March 30, 1979.
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and fosters State and local participation in preparedness activities.
--The Defense Civil Preparedness Agency in the Depart-ment of Defense (DOD), which administers a national civil defense program and provides assistance to State and local governments for military attack and, secondarily, natural disaster preparedness.
--The Federal Disaster Assistance Administration in the Department of Housing and Urban Development, which coordinates Federal natural disaster re'ief opera-tions and administers a small natural disaster pre-paredness State grant program.
Undir a planned executive order, these three agencies will be incorporated into the new Federal Emergenc, Manage-ment Agency (FEMA).
This new agency, established on April 1, 1979, is to serve as a single point of contact for State and local governments for Federal emergency planning and preparedner At present, FEMA is made up of the Federal Insurance Administration, which advinisters flood, crime, and riot-related insurance programs; the National Fire Provention and Ccatrol Administration, which fosters fire prevention and mitigation; and the Emergency Broadcast System.
Other spe-cialized Federal emergency pro ; rams which interf ace with State and local authorities may also be transferred to FEMA in the future.
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FEMA does not, however, automatically assume the primary policymaking and coordination role for radiological emergency response planning.
This role was asci.gned in I
December 1975 to the Nuclear Regulatory Commission (NRC),
l
.j which regulates the commercial nuclear industry, by GSA.
Forty-three States have sizable fixed nuclear facili-ties within their boundaries.
These facilities include 70 commercial nuclear powerplants, and a number of Federal mili-tary and nuclear materials production and research reserva-tions.
Another 165 nuclear powerplants are being built or planned.
The greatest danger from a nuclear accident at one of these facilities is the release of radioactive material into the environment.
In the event of an offsite release, public health is threatened in two ways; first, ptople near the f acility can receive unsafe levels of radiatic a either externally or by breathing-in radioactive materia), and sec-ondly, radioactive fallout can contaminate food and water supplies.
Of course, many factors, including weather conditions, wind direction, and the geography of the area, would deter-mine the path of the release and extent of the health hazard.
If the analysis indicates a hazard exists, prompt actions are necessary to protect the public from overexposure.
These actions may include evacuating and sheltering the pub-lic as well as administering medical help and curtailing access to contaminated areas.
Actions to prevent or 259 335 3
minimize indirect exposure may include controlling access t) contaminated foodstuffs and decontaminating foods.
Choosing the response that provides maximum hoaith protection for an endangered public is not un easy tar'..
Generally, a number of decisions must be made la a short time with, of ten times,
limited information.
As one part of regulating commercial nuclear power-plants, NRC requires utilities to develop, and test at least annually, onsite emergency plans.
Likewise, DOD and the Department of Energy (DOE) require nuclear facility opera-tors to develop and periodically test emergency plans.
These plans must include measures for carrying out the emer-gency phase of a potential offsite release.
The emergency phase involves assessing the situation and initiating the appropriate protective action.
Promptly notifying respon-sible State and local officials is the most important step.
NRC, DOE, and DOD consider the protection phase--evacuation and sheltering--the responsibility of State and local au-thorities.
In the event of an emergency, therefore, the level of protection af forded people living around a nuclear facility largely depends on (1) the facility operator's promptness in notifying State and local authorities, and (2) these authorities' response capabilities.
We believe this is where emergency preparedness begins to break down.
For example, State and local cfficials we talked to were 259 336 4
not confident they would receive prompt notice or be prepared to respond.
We share this lack of confidence.
At all nuclear fa-cilities we visited, the operator's appeared prepared to re-spond to releases of radioactive materials contained within plant boundaries; although we did find a lack of facility-wide coordination of onsite emergency drills at DOE nuclear facilities.
However, existing levels of State and local government planning and preparedness cast doubt on whether effective actions would be taken to protect the public should a significant release extend offsite.
The remainder of my testimony will concentrate on three major areas.
--First, too little attention has been given to insur-ing that State and local governments develop and periodically test comprehensive nuclear emergency plans.
--Second, emergency planning zones around nuclear power-plants are too small..
--Third, people living near nuclear powerplants are not well informed of f.3tential hazards or emergency procedures.
TOO LITTLE ATTENTION GIVEN TO DEVELOPING -
AND TESTING EMERGENCY PLANS Forty-one States have some tra of peacetime nuclear emergency plan and five States are developing or planning 259 33I'
i to develop plans.
Of the 41 States with nuclear emergency plans
--only 9 have tested plans in full-scale drills;
--sixteen have had drills involving some, but not all, people who would be expected to respond to an emer-gency; and
--the remaining 16 have not tested their plans.
Problems found with plans that were tested indicate that an untested plan would probably be ineffective in handling an emergency situation.
NRC has the primary responsibility for assisting State and local governments in developing nuclear emergency re-sponse plans.
NRC provides guidance and assistance and for-mally reviews State plans.
NFC's guidance is intended for use in emergency planning for all types of nuclear facili-ties, but it has been primarily used in connection with nu-clear powerplants.
When NRC is satisfied that a plan meets its criteria, a formal letter of concurrence with the plan is issued.
This is a cooperative process; NRC has no direct authority to either require States to develop plans or dis-approve State plans.
At the time we prepared our report, NRC had given its concurrence to 10 State nuclear emergency plans and was.eviewing another 10 plan's.'
Recently NRC con-curred in 2 more States' plans.
NRC does not make concur-rence in, or indeed the existence of, a State nuclear 6
259 338
emergency, plan a prerequisite for permitting operation of a commerc:el nuclear powerplant.
To obtain a comprehensive picture of State-level nu-clear emergency preparedness we sent questionnaires tc each State, the District of Columbia, and Puerto Rico and asked them to assess their preparedness.
Forty-one respondents said they have some type of nuclear emergency response plan, five said they are developing or planning to develop such plans, and the remaining six said they did not need plans because there were no sizable nucles facilities within or near their borders.
Interestingly er.ough, some of these latter respondents actually have classified military nuclear facilities within their borders.
Twenty-seven of the 41 respondents with plans said they were prepared, 5 said they were not, and 9 rated their preparedness as borderline.
Only about one-half believed they had adequate resources in the areas of equipment, communications facilities, and trained personnel; while about three-fourths stated that a
they had satisfactory emergency operations centers.
Al-though 41 respendents said they had nuclear emergency plans, only 9 have tested them in full-scale drills,,+ile 16 have had partial tests.
States may play a li:aited role during the initial emer~
gency because their resources and personnel are generally located too far away to start immediate protective measures.
Thus, loccl authorities around nuclear facilitiec are 259 339 7
initially. responsible for protecting public health and safety within their jurisdictions.
They are not, however, always prepared to handle nuclear emergencies.
Although local authorities are generally expected to be the first to respond to a nuclear accident with an offsite release, they usually do not have the expertito or capabili-ties to determine whether any health hazards might exist.
Basically, local authorities depend on NRC, DOD, and DOE to provide them with such information.
These Federal agen-
.vays advise'd local authorities of cies have not, however, t the potential health hazards or of the roles local authori-ties would be expected to play in responding to a nuclear emergency at a nuclear facility.
We noted that while some local aut'horities in the vicinity of commercial nuclear p.
lants were prepared for
_e handlire nuclear emergencies, others were not.
Furthermore, we found that local authorities around DOD and DOE nuclear facilities were generally less informed of potential radio-logical hazards--and, therefore, less prepared to respond to emergencies--than around commercial nuclear powerplants.
DOD and DOE officials told us that there is little or no potential hazard to local communities around their nuclear facilities.
DOD officials also pointed out that security policies prohibit either confirmation or denial of the pres-ence of nuclear materials on military installations.
For example, neither the State nor local authority near one 8
259 340
powerplant had evacuation plans even though the utility considered evacuation to be the primary offsite emergency protective measure.
In other cases, local governments with nuclear emergency plans had not tested them.
Testing their plans would, we believe, improve emergency preparedness.
Where tests have been made areas identified as needing improvement included
--inadequate communication between t.e various agencies participating in the test,
--confusion regarding respo.nsibility and authority for coordinating and implementing emergency mesaures, and
--inadequate offsite radiological monitoring procedures.
We believe it prudent to resolve all aspects of emer-gency preparedness before nuclear powerplants begin operat-ing.
We recommended that NRC
--allow nuclear powerplants to begin operating only where State and local emergency response plans meet all of NRC's' planning criteria, and
--require license applicants to make agre,ements rith State and local agencies assuring their full parti-cipation in annual emergency drills.
We also recommended that DOD and DOE require facility commanders to (1) develop agreements with' State and local authorities delineating the responsibilities and capabili-ties of each party during a radiological emergency and (2) 259 34:
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encourage State and local authority participation in annual emergency drills.
In commenting on our draft report, NRC disagreed, stating its belief that State and local nuclear emergency plans are not essential in determining whether nuclear pow-erplants can be operated without undue risk to public health and safety.
Public. statements by NRC Commissioners since the Three Mile Island nuclear accident indicate that NRC's position on the issue may be changing.
Neither DOD nor DOE provided specific comments on our recommendation.
EMERGENCY PLANNING ZONES AROUND CCMMERCIAL NUCLEAR POWERPLANTS ARE TOO SMALL Emergency planning zones around nuclear powerplants are much smaller than the area that couId be affected by a large radiological release.
The zones are usually areas within 5 miles or less of poverplants and are not based on carrying out emergency actions to protect the public.
As a result; nuclear emergency. plans and procedures developed on the ba-sis of such criteria are not adequate in overall coverage to comply with Environmental Protection Agency (F A) recom-mendation for taking nuclear emergency protection actions.
In November 1978, a joint EPA and NRC task force recom-mended that emergency planning zones around nuclear power-plants be increased to about 10 miles.
Basea on a review of potential accidents at nuclear reactors, the task force be-lieved this to be the most like_y area where immediate 10 2bh 3N2
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emergency actions, such.as evacuation, might have to be taken for large accidental releases.
We believe NRC should l
adopt this recommendation as a minimum.
NRC's staff told us that the recommendation is currently out for public comment.
THE PUBLIC SHOULD BE BETTER INFORMED OF EMERGENCY PROCEDURES The success of all emergency planning depends on public reaction to the information and directions provided if a ra-diological release at a fixed nuclear facility threatened public health and safety.
It can be expected that the pub lic's response will be no better than its understanding of the hazards and its preparedness to take recommended protec-tive actions. We found that people living in areas near nu-clear facilities could be better informed of the potential hazards or the actions that might be necessary to avoid or minimize exposure.
While some-local emergency agencies have attempted to encoarage dispencing this type of information, public interest has nct been great.
In addition, utilities, DO0, and DOE facility operators could do more to distribute information to the public.
We believe a serious weakness in assuring the overall preparedness of nuclear emergency response planning result from the absence of some requirement for public.information about the (1) potential hazards present at nuclear facili-ties, (2) emergency response required to rope with a nuclear emergency, and (3) protective measures that can be taken to 259 34; 11
minimize or avoid public health effects.
Without sore prior knowledge of wh.t to expect and what to do, the public may not react quickly or as cooperatively as the situation de-mands.
Dissemination of such information would require a coordinated e f for t on the par t of Federal, Sta' and local authorities, and perhaps utilities.
In our report, we recommended that NhC DOE, and, to the extent national security is not jeopardized, DOD require that the people living near nuclear facilities be provided with information about the potential hazard, the emergency actions planned, and what to do in the event of an accidental radiological release.
We also recommended that DOD develop methuis of interacting with States in peacetime nuclear emergency response planning where the classification of nu-clear facilities is justified on national security grounds.
For example, DOD could deal with a few key State or local officials on a classified basis.
CONCLUSION FEMA brings toget;..r the Federal responsibilities for peacetime and wartime emergency planning.
However, NRC will retain its responsibility for assisting State and local gov-ernments to develop plans for responding to emergencies around nuclear facilities unless FEMA assumes this respon-sibility through administrative action.
While we recognize that NFC has an important role in emergency response planning around commercial nuclear 259 34g 12
powerplants, we believe that as the focal point for Federal emergency planning and preparedness activities, FEMA--not NRC--should make policy and coordinate radiological emerg-ency reuponse planning as a part of its overall emergency planning and preparedness activitics.
Thus, in our report we recom.nended that FEMA:
--Assume the responsibility for making policy and coordinating radiological emergency response plan-ning around all nuclear facilities.
--Broaden radiological emergency planning assistance
+
to State and local governments artund Department of Defense and Department of Energy nuclear facilities.
We understand that PEMA is now considering our recommendations.
Mr. Chairman, this concludes my testimony.
I would be pleased to respond to your questions.
/
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ga arcw 8
UfJITED STATt:S o,
!?3 q 1'
'n NUCLEAR REGULATORY COMMISSION 3
ADVlsORY COMMnT2E OfJ REACTOR SAFEGUARDS A )l[k [#
g W ASHINGTON, D. C. 20555 o,
May 30, 1979 ACRS f1E!!BERS ACRS TECHNICAL STAFF ACRS FELLOWS CIVIL DEFENSE ASPECTS OF THE THREE MILE ISLA'!D NUCLEAR ACCIDENT; THE GA0 REPOP.T ON EMERGENLY PREPAREDNESS AROUND NUCLEAR FACILITIES Observations made at the hearing of the House Committee on Armed Services, Subcommittee on Military Installations ar.d Facilities,16 May 1979.
Congressmer. Dresent:
Nedzi (Chairrlan)
Whitehurst Mitchell Won Pat Beard Byron Fazio Witness List:
J. Dexter Peach - Director, Energy and Minerals Divisien, GA0 JosephM.Hendrie-@arimahNRC C FM "
I.
Opening Statement of Mr. Nedzi (statement attached) purpose is to investigate role of Federal government in development and execution of emergency planning future witnesses will include representatives from local and state civil defense units II.
Peach (joined by James Douglas and Duane White, both of G'J) reference GA0 report, EMD-78-110, 30 March 1979.
- read opening statement (attached)
- highlights of statement a) he 1973 three Federal agencies have had primary planning and coordination responsibility for general civil emergency preparedness aid response:
The Federal Preparedness Agency (GSA), The Defense Civil Preparedness Agency (r00), and the Federal Disaster Assistance Administration (HUD)
A planned executive order will combine th.se three agencies to form the Federal Emergency Management,qency (FEMA), tne purpose 259 346
~
of which is to serve as a single point of contact for State and local governments for Federal programs.
(This order not yet issued.)
b)
FEMA does not automatically assume primary policy makine Tnd coordination for radiological emergency response planni4 3 This is continued role of NRC.
c) with regards to emergency preparedness of civilian and military nuclear facilities,.GA0 report feels weaknesses in existing plans are:
- 1) the facility operator's promptness in notifying state and local authorities
- 2) these authorities' response capabilities d) areas of major concern are:
- 1) too little attention given to developing and testing emergency plans 41 states have some type of peacetime nuclear emergancy plan and 5 additional states have plans in the development stage, of the 41..
9 have had full-scale tests,16 have had drills involving some, but net all people expected to respond in an emergency, and 16 have not tested plans; also of the 41..
27 rated themselves as " prepared," 5 as not prepared and 9 as borderline.
Evidence indicates that an untested plan vruld probably be ineffective. Where testing had been conducted, problems were revealed in communication, identification of authority, and off-site radiological monitoring procedurcs.
Some of the 6 s'ates with no current plans and no plans being developed have classified military nuclear facilities within their borders.
2)
Emergency planning zones around nuclear power plants are too small.
- 3) People living near nuclear power plants are not well informed of potential hazards or emergency procedures, e) Because of remote location of facilit es, it is the local i
authorities (not, state) upon whom the
.itial responsibility falls in the event of an emergency.
Those authorities around 000 and DOE nuclear facilities are less likely to be prepared than corresponding authorities around commercial nuclear power plants.
f) GA0 reconcends that NRC
- 1) allow nuclear power plants to begin operating only where state and local emergency resconse plans meet all of NRC's planning criteria, and
- 2) require license applicants to make agreements with state and local agencies assuring their full participadon in annual emergency drills.
259 347
. Questions and Answers Whitehurst:
What other Committees have you appeared before?
Peach:
Energy and Power (Dingell) and Environment, Energy and Natural Resources (Moffett).
Mitchell:
Are areas around facilities watch store nuclear weapons in danger?
Peach:
Potential for accident to occur exists; cons'lted with Lawrence Liver 111 ore Laboratary (LLL) on this.
Mi tchell :
Can a nuclear plant explode?
Peach refers to hydrogen bubble at TMI; danger at nuclear plant not explosion but breach of containment.
Mitchell:
Why establish a constant 10 mile radius emergency around all facilities; shouldn't wind patterns be taken into account?
Peach:
10 mile radius is a minimum; notes that at one point a 50 mile evacuation radies was considered at TMI; establishment of zone will involve site by site evaluation.
Mitchell.
People (including self) are basically ignorant of facts concerning radiation; must include education of people around facilities in any plan.
Beard:
Should a moritorium be declared on new licenses until evacuation plans are developed?
Peach:
doesn't have to get to "moritorium" stage; feels tnt goal is not difficult to accc7Diish, should only add 2 or 3 nionths to licensing process.
Beard:
Concerned about localities with part time local authorities. Why not incorporate the National Guard (especially around D00 sites) into,lan?
Peach:
Possible, not considered in G',0 report.
Beard:
No further licenses should be issued until problem of waste is settled.
Peach:
This is the key issue for the '.'uture of nuclear power.
Beard:
Why not incorporate emergenct planning in a new Civil Defense program?
259 34e Peach:
Possible.
~
. Nedzi:
..nat is accident scenario at military nuclear facilities ;
how could weapon detonate?
Peach:
In scenario presented to LLL, weapor. assumed to explode during movement.
Nedzi:
Is this scieritifically feasible?
Peach:
Yes; not known if LLL agrees; neither LLL. nor D00 commented on scenario.
Mitchell:
Weapons seem to be more of a threat to the public than power plants; what are the p,robabilities involved in the two cases?... "if we are concerned about nuclear power plants, we should be terri fied of weapons" Peach:
GA0 will review this question in more detail; probabilities not known to GA0.
Nedzi:
Were specific faults found in individual emergency plans?
Peach:
Procedures at individual plants were not. reviewed in detail; portion of research done by questionaire... interested in how states felt about their own plans.
Nedzi:
H3w can a state with nuclear weapons (but no nuclear power plants) have no plans't Peach:
5 tate may not be aware specific weapons are at a facility.
Nedzi:
What would be the essential parts to a good plan?
Peach:
Key elements would include
- 1) reliable communications link between the utility and designated local and state officials.
- 2) Acequate resources to draw cn to implement plan (e.g.,
radiological monitoring equipment, dedi.cated vehicles,
access to highway patrol to define road blocks, etc.).
- 3) feedback; method to integrate acquired information during event, channel to correct individuals, etc.
Nedzi:
Were the roles of Civil Defense agencies on the federal and state levels reviewed?
Peach:
No.
259 349
III.
Hendrie (joined by Robert Ryan and Harold Collins, both of NRC, Office of State Programs) reads statement (virtually identical to testimony before Moffett Committee on 14 May 1979, please see notes of 16 "ay 1978) highlights:
a) relationships between authorities and federal agencies not as clear as might be, b) d es that plants have features to minimize
- eleases.
c) notes that evacuation is not only response possibility (shelter, compounds to block radio-iodine uptake, etc.)
d)
NRC has no legal authority to require plans or testing of plans off-site.
Policy is to use cooperation and persuasion... refers to NRC
" Guidelines" e) very small amount of federal funds historically used specifically for radiological emergency planninc.
f) most facilities will have dedicated telephone lines to NRC b3 end of June.
Questions and Answers Won Pat:
notes NRC's lack of authority.
Hendrie:
NRC offers a wiJe range of assistance to the states.
Don't have authority to require plans or to offer funds or equipment.
If actual emergency occurs, NRC does in fact provide assistance.
Mitchel : :
Why was there no monitoring for two days following accident at TMI?
Hendrie:
There was monitoring during first three days... I&E team, inplace Met Ed dosimeters, 00E team, and 00E airborne monitoring survey.
Mi tchell :
Was Califano therefore wrong?
Hendrie:
Impossible to enaw dose to each individual. Refers to DOE / HEW /NRC estimate of doses.
Mitchell:
Is FEPA the logical organization to take over in such an emergency... very similar to natural disasters... why not have a good Civil Defense program?
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_ Hendrie:
Civil Defense v auld make a lot of sense... could provide disaster response for all areas, not just those arourf nuclear facilities... CD has radiological experience.
Mi tchell :
Cost estimates for good plan?
Ryan:
NRC Staff draft report... cost to local governments for equipment, training, testing, updating... over the text 20 years... would be $150,000,000 for all plants.
Cost should be responsibility of licensees.
Byron:
Why is it that NRC must wait to be called before going into action?
Hendrie:
In theory NRC has authority to go to site at any tire.
In practice NRC depend on licensee to inform them of event.
Bryon:
How has TMI affected the transportation of waste?
Hendrie:
There have been four shipments of low level material from the TMI site since the accident.
A " good part if not the bulk" has been from normal operation cf units 1 and 2.
One shipment rent to Barnwell, three to Richland.
Fazio:
What v
'd be role of FEMA in radiologice' ergency planninh Hendrie:
NRC, which is most knowledgeable regarding specifics of of plans.
00A does not want part of licuising process outside of NRC.
Fazio:
Requests public hearing before Fancho Seco is allcwed to come back on line to " inform people to realities of situation" (expressed this request formally in le :ter to Hendrie on 16 May - coauthored by Rep. Matsui).
Nedzi :
What is organization within NRC for state planning, hnw l>rge?
Ryan:
Three professionals before yesterday (four added t hen),
and two state liaison officers (part time, ore eac1 in Regions I and V).
Hent -i e :
Staff not adequate, licensing also involved in pla inina, I&E involved in drills.
Total staff approximately 15-20 equivalent full time people.
Nedri:
Satisfied with distinctions made by licensee in ce ermining magnitude of emergency?
25a
?r-i s.>.
. Hendrie:
NRC reviewing this.
NRC should have been called before 7 a.m. on 28 March regarding Ti11... no detection of activity, but serious transient.
Nedzi:
Should plan be required prior to licensing?
Hendrie:
Will rethink present position. As for existing plaate question is one of timing... is this
.,o important as to require shutdown... personal view is that shutdown would be excessive, should phase in new regulations.
No fundamental objections for planning of future plants, however, more requirements in general tend to obstruct critical path.., likes coo ~pei ative basis.
Ryan:
One argument (not personal feeling) against requirement...
Why should utility be penalized because of state's inaction?
(w& 'E yumb David Heywood Johnson k
ACRS Fellow Attcchments as indicated 259 352