ML19260E097

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Comments on Presidents Commission Recommended Conditions for CP or OL Issuance.Supports Need for New Safety Improvements,Review of Licensee Competency & Conditioning Licensing Upon Approval of State & Local Emergency Plans
ML19260E097
Person / Time
Issue date: 12/11/1979
From: Carbon M
Advisory Committee on Reactor Safeguards
To: Ahearne J
NRC COMMISSION (OCM)
References
ACRS-R-0853, ACRS-R-853, NUDOCS 8002130354
Download: ML19260E097 (3)


Text

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'o UNITED STATES

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[ j "g.,f[ g NUCLEAR REGULATORY COMMISSION p/

c ADVISORY COMMITTEE ON REACTOR SAFEGUARDS

- cp /j WASHINGTON, D. C. 20555 i;,

December 11, 1979 Dr. John F. Ahearne Chairman U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

CCMMENTS ON 'nIE PAUSE IN LICENSItG

Dear Dr. Ahearne:

The President's Commission on the Accident at Three Mile Island has recommended that:

"Because safety measures to afford better protection for the affected population can be drawn from the high standards for plant safety recommended in this report, the NRC or its suc-cessor should, on a case-by-case basis, before issuing a new construction permit or operating license:

(a) assess the need to introduce new safety improvements recommended in this report and in NRC and industry studies; (b) review, considering the recommendations set forth in this report, the competencp of the prcspective operating licensee to manage the plant and the adequacy of its training program for operating personnel; and (c) condition licensing upan review and approval of the state and local emergency plans".

Since issuance of this report, the Nuclear Regulatory Commission has stated that there will be a pause of many months before the NRC will li-cense any of the reactors now nearing readiness for operation while safety improvements are worked out for the reactors already in operation. Longer delays are anticipated for new construction permits.

The ACRS agrees with most of the recommendations made by the President's Commission. 'Ihe ACRS supports the basic recommendation of the President's Commission which is quoted above, but with some qualifications which are discussed below.

The ACRS believes that the risk to the oublic health and safety which is posed by the operating nuclear power plants is comparable to or probably smaller than the risk posed by other existing methods of generating the same quantity of electricity. The ACRS also believes that this risk is comparable to or less than that posed by many other technological activi-ties of society.

8002130 35 9

Dr. John F. Ahearne December 11, 1979 The ACRS has, in the past and again since the Three Mile Island accident, recomended that the NRC and the nuclear industry take major steps to im-prove the safety of nuclear power reactors. We ACRS believes that it is proper that nuclear power be safer than other comparable technologies.

The Comittee has sought this goal.

It believes that the country wants a higher level of safety for nuclear reactors and is willing to pay for it.

The ACRS also believes that the country wanta a higher degree of assurance as to the level of safety which is being attained.

While the ACRS believes that interim licensing of the next six to twelve nuclear power reactors for operation on tne same basis as is now being accepted for currently operating reactors would not pose undue risk to the public health and safety, the ACRS favors the consideration of additional improvements in their safety on a case-by-case basis, as ucommended by the President's Commission. Nevertheless, the following additional considera-tions can and should have a strong bearing on the specific NRC approach and actions in this regard:

1)

For those reactors which are ready for power operation, there exists the possibility that a considerable body of experimental information having either a plant-specific or a general safety significance can be ob-tained by performing app ~oriate tests on systems or the entire plant at powers up to about 5% of full power. Rese are tests which are not usually run because of the time they consume. They would afford essentially no risk to the public health and safety. There also exists the possibility of providing trore than the normal training of operators.

2)

If the NRC pause becomes relatively extended, there taay arise a more severe national need for additional electric power. The ACRS recom-mends that consideration be given to permittirg newly completed nuclear power plants which meet the requirements of NUREG-0578 to start up and undergo testing at power levels up to 50% or 75% of full power, after which they could be placed in a shutdown condition, available for call in the event of national need, while the NRC reaches a resolution as to the addi-tional safety requirements it will impose before permitting normal commer-cial operation,

3) The ACRS believes that the safety improvements recommended by the President's Commission, the various NRC Task Forces and the ACRS itself, should be < valuated and acted upon expeditiously. However, the ACRS believes 1. hat a judicious choice is required as to which recommendations require implementation promptly, which reluire implementation on a speci-fied time scale during which reactors are permitted to operate, and which warrant study and resolution on some specified and achievable time scale.

The ACRS supports the rapid steps being taken by the NRC to develop an action plan and will expedite its review of the plan.

Dr. John F. Ahearne December 11, 1979 4.

Although the ACRS believes that operating reactors should receive priority, and that reactors under construction also require emphasis from the NRC Staff, the Comittee recommends that the NRC Staff take steps in timely fashion to redirect, as appropriate, the design of reactors for which a construction permit has not been granted or for which construction has not been initiated. General guidance, as well as requests for studies of design alternatives could be useful in this regard. 'Ihe Committee be-lieves that the initiation of possible design changes need not await the complete developnent of a final NRC position on changed or additional re-quirements for reactors which have not yet received a construction permit.

The ACRS is available to work with the NRC Staff to help achieve these actions.

Si cerely, Max W. Carbon Chairman