ML19261A260
| ML19261A260 | |
| Person / Time | |
|---|---|
| Site: | Atlantic Nuclear Power Plant  |
| Issue date: | 11/24/1978 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Brooks J, Dingell J, Hart G, Ribicoff A, Udall M HOUSE OF REP., GOVERNMENT OPERATIONS, HOUSE OF REP., INTERIOR & INSULAR AFFAIRS, HOUSE OF REP., INTERSTATE & FOREIGN COMMERCE, SENATE, ENVIRONMENT & PUBLIC WORKS, SENATE, GOVERNMENTAL AFFAIRS |
| Shared Package | |
| ML19261A261 | List: |
| References | |
| NUDOCS 7812050284 | |
| Download: ML19261A260 (23) | |
Text
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m Ccc:.ittc; cn G; verr.nnt Cparations
!nittd Statas i.ouse of Representatives
'.'tshing t.n, D. C.
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Ccar l'r. Chtirran:
Pur:uant to Section 23C of tl.e Legisictive D.orr c.nization Act of 1970, the ':uclear Ccculatory Cc ~.ission (i.~.C) 1.;r.15y subaits a state:.cnt on tha acticas that have, cre Leing, or i;ill be talen i;ith re;ard to the rcccr.: cndaticas. de by the Ccq i. roller Gcncral of the Unit;d States in a rtport entitled, "Cefora Licecing Floating !!aclecr Pu cr Plcnts, !' ny Ana.crs Arc ':.0;'ed."
The rcspe:.scs to thcsc r: en,_ndati:ns, uhich are cnclcsed, were gre.pred by the imC staff uith no price revicu or ccatnt by the Cc:. i s s i c;, a rs.
This c.;.proach to satisfying the ra.uirc. ants of the atsve-rcfarenced statute was decr.cd apprcpriate undcr the unusual circur. stances present in this.atter.
'bny of the raints raisSd in tLe GA0 report required an '2C response which involved 4
a discussion of issues that are presently being litigated in a centested on-the-record public hcaring en the application of the Gifthore Pouar Systccs for an IRC inanufacturing lictnse for float-ing nuciear power plants.
Cecause the rulings and decisions en those issues by the presiding Atcr.lic Sciety and Licensing Coard
- ill very likely cone before the Cccr.issiencrs for revicu in connection with their adjudicator.' respcnsibilities, it could not ba appropt l ate for the Co
- .nission to cormnt on thcs issu:s at this tir.o.
Sincerely, A C C *.
h,..u)t.av.t:mk 97l2*So2i'y Lce V. Cossick e-Executive Director for Operations
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Enclosures:
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t' 1.
IRC General ','icus on the GA0 Report I <,,J "r[) {
2 2.
IRC P.esponses to the Gl.0 Rccc:r:ndc tions D
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3.
Ltr. fn USCG datcd 10/13/78
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Ltr. fn Daker to Canfield b O(.5 v
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iWREG-0054 (Suppl. P.), 0055, 0127, O'40, 0
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3 E",iaogue HShapar ED] 4536 Identical letters to:
Chairman Abraham Ribicoff Senate Committee on Government Affairs cc: Sen. Charles A. Percy Chairman Gary Hart Senate Subcommittee on fuclear Rem;lation Comittee on Environment and Public '.-lorks cc: Sen. James A. McClure Chairman Morris K. Udall House Subcontnittee on Energy and the Environment Committae on Interior and Insular Affairs cc: Rep. Robert Bauman Chairman John D. Dingell House Subcommittee on Energy 5nd Power Comittee on Interstate and Foreign Ccmerce cc: Rep. Clarence J. Brown
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2158 143 11-14 Retyred in ECO to change to ED0's signature - Per SECY.
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20615 "ar :'.r. Ch:irecn:
Pursuant to Section 236 of t:.2 Le;i:htive.torg:nization Act of 1970, the Nucitar Replatory Co:c.ission (i.P.C) Lcrc5y nbmits a statcr.2nt on the actions that h:ve, are Laing, or will be taken with re;ard to the rccc r.snhtisas :S Ly the C;. 4rollcr Nnceal of the United Statcs in a report entitled, "Safera Licensing Ficating Eucitar Pcu:r Plents, "any Ansucrs Ar'. ceded."
The respens, to these recorr.cndations, which cre enclosed, e:-re pre-pared by t.ha NRC staff with no rior revicu or ccre.iant by the Ccrnissioners.
This approach to satisfying the requirc: cnts of the abov -referenced statute was desmad appropriate under the unususi circur: stances present in this matter.
I'.any of the points raised in the CAO report required an i!RC response which involved a discussion of issues that cre presently being litigated in a contested on-the-record public hearing on the application cf the Ofichore Pouer Systems for an !!?.C ranufacturing license for floating nucicar pouar plants.
Bccause the rulings and decisions on those issues by the. presiding Atomic Safety cnd Licensing i
Board uill very likely come before the Cc:til:sioners for ravicu in connection with their adjudicatory responsibilities, it '.ould not be cppropriate for the Cornission to cc T:.cnt cn these issues et this time.
Sinccrcly, I
s Joseph 11. hcadric Chairaan l
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Enclosures:
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1.
URC General Views on the GA0 Report
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2.
j'RC Responses to the GA0 Recorr.enStions 3.
Ltr. fn USCG dtd 10/13/73 4.
Ltr. fm Caker to C;nfield 5.
NUREG-0054 (Suppl. 2),
0056, 0127, 0440, nna. v. g nona 6.
39FR2124 orrecr y seamawI MC1.$ep..[fCDk ' 50 f (Q lb. _..._..
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2-7.C rorJr 31s (9 76) hTsC4 c:40 W t>. 's. covt as p r.ur raisvis s arric ri inre - s ae. 24 2158 144
Encitsure 1 f.;C STAFF RF.!;EU'. C EUS C'; THE G;3 E! 5.T 16 is thu sta; f s consiuered jucy.. nt tnat Lhis CAO r.epos. will rais~.2ac its readers since it dces not pre cide :.a oby.ctive overview of fiRC licensing pelicies related to the ficating nuclear power plant (Flip) a; plication.
The Report includes several generalized criticisms with regard to I;RC review cractices associated with FiiPs.
He wish to comment on two of these findir.gs which we believe were in themselves developed in a
- bjective fashicn and as a result tend to leave the reader with a misleading everall view of the licensing process for the FI;P concept.
Firs c, the GAO Report finds that several nanagement decisions of the !iRC have complicated the licensing review of the F;P application and have contributed to a 3-year delay in the licensing process.
Secondly, the GA3 Repsrt finds that the Gcneric Environnental Statement prepared for Ft.Ps provided little assurance about the feasibility of the FI;P concept and that the Generic Environmental Statement added little to the licensing process.
With regard to the first E40 finding, tiRC management decisions during the course of tne staff review of this application were made to satisfy the recuirements of the I;ational Cnvironnental Policy Act of 1969 (tiEPA) as well as our mandate under the Atcmic Energy Act of 1954, as amended.
The staff has long recognized that due to the uniqueness of the Flip concept, the safety and environmental reviews of this application would be cf longer duration than that of a typical land-based plant.
The staff found that the complexity of the review dictated the secuential issuan:e of the various envirornental statements prepared for this appli-cation. Additionally, it allowed for the initiation of the hearings related to this case at an early point during the licensing process.
As discussed in the GA0 report, an environmental inpact statement was first prepared by !?RC rela:ive to the manuf acture of the eight F!iPs and, having.
ctncluded that the Fri?s could be manuf actured with acceptable impacts, t'.e staff developed the Generic Environmental Statement which addressed r
principally the issue of whether the eight Fr;Ps could be sited at proposed generalized sites.
Tre Gereric Environmental Impact Statement for this application differs c.arkedly from the environmental evaluations prepared by the staff for linc-bised power plan s at specific sites, since it considers the totality of i.'picts associated with the generalized siting and operation of ei g'r.: r.uclear power plants.
The staff believed that the Generic S:atement adecuately addressed the environmental considerations of all genera.ized Fl!P siting options, including riverine and estuarine siting b.:, at the insistence of the Council on Environmental Quality, decided 9 PP m
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'dith respect to the core-melt risk at FI;Ps, the staff has been studying the consequences of such an accident since 1973 prior to the formal acc,ptante of this c;plicatica by !;RC.
The Liquid Pathway Generic Study Report (LPGS) v.hich was published in final fcrm in early 1978 was an extensicn of earlier staff efforts to fully assess the differences in risk between an FiiP and a land-based plant regarding accidental radioactive releases to a water environment.
The LPGS was not an environ-mental statement, but was used by the staf f as a principal reference in It the development of Part III of the Generic Statement for FI;Ps.
shouid be emphasized that the ;RC r;ccgnized the naed for and, in fact, initiated the analyses related to a postulated core-melt at an FitP vcry car'.y in the review process for this application.
Relative to the safety review of this application, the I?RC management initiated a !iemorandum of Understanding Between the f?RC and the U. S.
Coast Guard so as to provide an additional vital review function of various related FilP design aspects regarding the seaworthiness of the FitP which is not ccamon to the review of typical land-based plants.
A unique design, as is the FftP, will always involve additional review effort which may not be representative of schedules routinely associated with established technology.
As a result of these factors, we agree that the !!RC licensing review of the FNP has been delayed apprcximately 3 years relative to a standardized schedule for a typical land-based plant, however, we find that the GA0 discussion of the fiRC schedule for the Fi;P licensing action fails to nake the reader aware of the importance of the various activities which resulted in the delay, the potential consequences of the delay to the public interest, and the loss had these activities not been conducted.
As to the second GA0 finding, it is our understanding that the GA0 believes, based upon its discussions with other agencies, that the Generic Environmental Statement added little to the licensing process because it did not address the cumulative impacts of nany (about 40) floating plants operating simultaneously and did not include an analysis of specific Fi;P sites.
This finding reflects a lack of understanding of the intent of the Generic Statement which is: given an application to manuf acture eight such plants, the staff must demcnstrate that there is reasonable assurance that the eight FilPs could be sited with acceptable environmental inpact at generalized locations.
It is not as GA0 implies meant to be a definitive statement on the siting or operation of all future Fi;Ps.
The staff will conduct further analyses of additional Flips shculd the applicant apply to manufacture such additional plants in the future.
2158 146 hie staff believes that a nore cc.grehensive statcmant v.hich addresses
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~mkr cf ;parat',ci.ai F ':P's < i d u a prograr71 tic statacnt ?.nd t-wid 7 '2ycrd the re:_i' l
mants of this application to manufacture only aight F';Ps.
Furthermore, the cuestion of generic effects resulting from the deploment of large nur%rs of Ft;os has alr'ady tren discussed in a report prepared by tSe Council on Enviror. mental Quality.'
!!e firmly believe that the Generic Environmental Statenent, together with supplemsntal information developed during associated Atomic Safety and Licensing Board hearings regarding this application, provides assurance that eignt F::Ps could be sited with acceptable environmental inpacts along the Atlantic and Gulf coasts.
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2158 147 I 0ffshore iluclear Powerplants - A CEQ/ Interagency Task Force Study, February 1976
rc csure 15 5T Fe ??%,5:S T1 THE C'-0
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f.'t% ^ ra " of the "RC cermnts listed belcw have previously appeared in correspondence to the GAO, we recognue tr.; ina. us; 2nd u.c_...
7 thw r;3pnse;
..e tve n:de nery Congress and therefor e in prepar in s attempc to elaborste upcn Our prior coments to the GA0.
The GA0 recc= ended that the :GC, befcra ccncludir.g its revie?! cf tM manufacturing license for eight Fi!Ps, should implement the following three recccc.endations:
GA0 Reccmendation flo. I (c. 29)_
--astchlish an acceptable level of risk for a core-melt accident on a floating nuclear plant; f;RC Resconse The !!RC is in agreement in principle with this recommendation as evidenced by actions initiated in 1975 to study the problem.
The ilRC has not established a quantitative criterion for accident risks as suggested by the GA0.
The ?!RC reactor licensing criteria are in the main deterministic in nature and compliance with the IIRC regulations does constitute a measure of what is considered acceptable.
As noted in the Final Liquid Pathway Generic Study Report and the Revised Draf t Envirennental Statement, Part III, i;UREG-0440 and 11UREG-0127, respectively, scme quantitative risk analyses These analyses have shown that there have been performed.
are differences in the magnitude of risks betvieen the Fi!P design and land-based nucitar power plants and that the risks
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of core-melt accident are icw for both the Ft!P and lan0 based The risks of core-melt events at an ocean-sited power plants.
FriP fall within the upper cortion of the acceptable range of risks for existing land-based plants and the risks of core-melt accidents at estuarine sited Ft:Ps are greater than those for the ocean-sited F!iP.
The pctential for severe environmental impacts due to a large prompt release of radio-active material from an F:!P into the hydrosphere was the con-trolling factor which led to the placement of the Fi;P at the outer range of the spectrum of risks for existing land-based The staff believes plants (See p. xii and p. 4-3 of f1VREG-0127).
the level of risks for core-melt accidents at existing land-based plants is acceotable and that future land-based reactor, designs may provide lower risk levels.
Implicit in the analyses presented in fiUREG-0127 is the view that the risks associated with the Flip should be made comparable with current and/or future land-based designs.
The !!RC has recommended that certain 7 [ogg 2158 148 cMiges.a irurpar -tec i:.to vie.7P c...gn t-er ;re. at tL E. J. ; f '
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associated with current and f uture land-Lesec nuci_ar pcwer
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t c. _ t e.".' ' :; v ::w t'..t a 1 :v t l c ' a snt:51e ricF fcr a cere-nelt =ccident at an FN? has been cefined.
E' S 't-:ocr :r d a tion Mo. 2 (p. 29)
--identify those changes which cast be nade to the design of the ficating nuclear plant to achieve that level of risk:
IRC Resconse The staff agrees with this reconmendation and believes that the design and int cfaca charges recon 3nded by the staff in the Generic Statement (N'JREG-0127) serve to implement it.
The FMP contains design features that are largely identical to a land-based nuclear power plant.
As noted in NUREG-0127, certain FNP design ard interface changes have already been reccamended by the s aff (See p. xiv of MUREG-0127) to asrure that the FNP meets present NRC safety related criteria and, as well, provides an adequate level of protection for the envirorinent. Specifically, the staff believes that the concrete pad beneath the reactor vessel should be replaced with a material that provides increased resistance to a core-melt and that FN?s sited in estuaries and rivers should be enclosed in a structure to limit the introduction of radioactive material into the surrour. ding water body in the event of a core-melt accident.
Further, the Final Generic Statement will set forth additional criteria regarding the delay period before a melt-through could occur at an FNP.
It is our opinicn that there is reasonable assurance that these cesien conditions can be implemented and will provide a level cf core-melt risk for the FNP at all proposed siting environments that is ecuivalent to that of land-based nuclear power plants.
Ei.0 Recommendation No. 3 (c. 29)
--require that weight carameters be developed for the safe cpera: ion of the floating plant and insure that these paraneters are met.
'AC Resoonse For the reasons discussed belcw the NRC does not plan to inpose a requirement for the development of weight parameters.
F.owever, the na;ter of FNP weight will be discussed in a forthcoming Sup:lement to the Safety Evaluation Report for FNPs.
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The etaff has censiMred weight in rersnective with the-many other safety and environnental consideratiens and has found that no adoiticnal safety concerns mula be satisfied by considering weight, and that the iteight of the F!;P is implicity considered in the "no grounding" parameter. "!!o g rour.c i ng' is cc.e of several si ce envelope parancers that the Flip design must satisfy.
As noted in Table 1.2 of Supplement l!o. 2 to the Scfety Evaluaticn Report, i:UREG-0054, the " Plant must not ground under the influence of environmental loads."
It should be emphasize; that inplicit in the NRC "no grounding" criterion is consideration of weight and loading effects.
For each specific site, this requirenent dictates a minimum low water depth to insure that the Fi!P does not grcund during normal and extreme envircnmantal conditions. The effect of weight on seaworthiness during tow will be reviewed by the Coast Guard as part of its permit review process for the F: P.
Further, the spent fuel pool located on the FNP and referred to in the GA0 Report has undergone a redesign to expand its capacity and the additional weight associated with this change has been considered in the "no grcunding" criterion.
Since the inception of the FI;P safety review, the applicant has included site envelope limitations based on the requirement that the plant not contact the basin floor as the result of plant motions produced by severe environmental canditions.
The specific quirement flo. (2), Table 1-2 (page 2) plant-site interface re-site envelope limits are found under of SER Supplement tio. 2.
Equations defining the minimum acceptable basin water depth (at the reference, MLW, conditions) are given for four different comoinations of environmenta'. events, and each equation must be satisfied at an F!iP site.
When these four equations are satisfied, clearance will exist between the bottom of the platform and the basin ficor, i.e.,
there is no contact.
Clearance to the basin ficor depends on (1) still water depth, (2) plant draft and (3) plant motion.
Plant draft is not a limiting parameter in itself with respect to the requirement that contact with the basin floor be avoided.
Rather it is the ccabination of several parameters v;hich is limiting.
Note that for any given water density (salt vs. fresh water),
plant weight and plant draft are uniquely related and that plant weight is therefore an input to the site envelope relationships establishing minimum acceptable basin water depth.
Plant weight will, like nany other Ft:P parameters, be essentially fixed and relatively inflexible at the time of specific site licensing.
This is precisely the reason for a site envelope, i.e.,
to state what range of site parameters is compatible with the as-designed M pg'g" 2158 150
t, F..P.
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c..ner can, end will, alter the elevation of the 'casin floor as n_;m. j M ;r; /: _%
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Ouite 7 cart frcm plant safety, plant weight is an important
,co= ercial consideration related to Fi;P manufacture and delivery.
The Fi;P manufacturing facility is 12 miles upstrun frca the imuth of the St. John's River at Jacksonville, F'.orida.
The depth of the river channel between the nanufacturing facility and the ocean limits the draf t of vessels traversing the channel to a r.aximum of about 36 feet.
The applicant, Offshore Power Systems, (OPS) has therefore established a design limit of 34 feet on plant draf t (with an associated weight limit of i60,000 tons).
As the FriP design progressed, the weight and associated draft cf the F'lP tare found in 1975 to be approaching the towing draf t limit for the St. John's River.
This led to a compre-hensive review of the plant design by OPS resulting in signi-ficant design alterations to reduce weight.
This is the weight "prcblem" referred to in the first paragraph of page 19 of the GA0 report.
The inportant safety issue alleged by the former CPS employee was in fact a non-issue because, regardless of plant draft (weight),the site envelope (and hence plant safety requirements) would have to be satisfied by an owner's site.
The allegation that OPS management was (in 1976) "ccapletely in the dark" concerning plant weight appears incorrect in light of our finding that in 1975 OPS management po'ssessed sufficient awareness to institute a weight reduction program. As a further note, it is not uncommon in ship design to periodically discover undesirable weight buildup and to react in essentially the same manner as the applicant did.
On page 19 of the report, GA0 notes a U. S. Coast Guard (USCG) interest in plant waight.
The FtP is a " vessel" under USCG regulations and is therefore subject to USCG regulation.
Division of regulatory responsibilities between USCG and USt'RC is delineated in a Memorandum of Understanding published January 17, 1974 (39FR2124).
The Memorandum of Understanding states in part respecting plant weight (draft):
"All barges admeasuring to greater than 150 gross tons are required to obtain a load line certificate issued by the /cerican Bureau of Shipping for the U.S.C.G. under 46 U.S.C., 88 et. seq., prior to proceeding from a port or place in the United States D *
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2158 151
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r but r.ot limited to, procceding fror.i a fabrication site
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Loadline regulaticns basically set the maximum draft limits for e vesrel.
The purpose of establishing a loadline is to assure vessel stability and the ability of the hull structure to resist applied loads.
Pursuant to USCG regulations and the Memorandum of Understanding, Offshore Power Systems has contracted with the American Bureau of Shipping to class the Fl!P and assign a loadline to the FMP to that agency's highest classification for Nuclear Power Barges, i.e., Class A-1 f.arge.
Ir conclusion, plant weight (or equivalently, plant draft) is irportant for the following reasons having safety significar.:e:
1.
Potential grounding under severe environmental conditions.
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Vessel stability and hull loadings.
1.'e have adequately considered Item (1) in the site envelope wherein the owner's site is required to satisfy conditions imposed by the existing design of the FNP.
Item (2) is satisfied by USCG approval of the loadline assigned by the Anerican Bureau of Shipping.
Plant weight is important commercially in that the channel from the OPS manufacturing facility to the open ocean will acccmmodate a maximum draft of approximately 36 feet.
It was for this reason and in response to this problem that OPS undertook a weight re-duction program in 1975.
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Further, we have asked the USC3 to review this specific GA0 reccamendation, and have enclosed for your information their letter to the fiRC which ccaments on the question of the weight monitoring program for FNPs. (See Enclosure 3. )
Both vie and the USCG have exercised adequate concern over FMP weight to assure plant safety.
Beyond the weight limit which will be established by the assigned loadline, we conclude that there is no increase in safety to be gained by additional limitations on or study of, plant weight.
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2158 152 Th2 GT h23 t>'io cencled2d tht te'ere mic+ irg its review of e operating license for two FNPs off the coast of i;ew Jersey, the tGC should implement the five following reccnendations:
GA0 Recommendation No. 4 (p. 10)
--identify speci ic methods for handling the loading and offloading of radioactive material and the recovery of such material in case of an accident; NRC Response The NRC staff is in agreement with this recomendation As p ev 9usly stated to the GAO, the NRC favors the development of specific handling methods and procedures for the loading and offloading of spent fuel casks and other radioactive materials from Flips.
Such procedures will be subject to the review and approval of the NRC prior to issuance of any operating license for a plant off the New Jersey coast or for that matter at any approved Ft'P site.
At present, the utility / owner of an Flip would have to conform to regulations established by the t1RC (10 CFR Part 71), the Department of Transportation - U.S. Coast Guard (49 CFR Parts 170-189 and 46 CFR Part 146) and affected states regard-ing the packaging and shipping of nuclear materials.
This will insure that adequate consideration is given to the protection of the health and safety of the public as well as to the minimization of potential environmental impacts due to the transfer of such materials.
Additionally, it should be noted that Sections 6.13 and 12.6.9 of the Generic Environmental Statecent (FES-Part II, NUREG-0056) related to the OPS application and Section 5.6 of the Draft Environmental Statement (NUREG-0058) related to the Atlantic Generating Station (AGS) application describe in some detail the activities associated with the transportation of nuclear materials to and from FNPs.
We wish, however, to clarify the NRC position with regard to the GA0 finding related to accidents involving spent fuel casks and the transport of radioactive materials given respectively on page 21 and on pages 28-29 of the report.
The NRC believes that the potential environmental consequences of a sunken spent fuel cask would be minimal.
However, recovery of a sunken cask nay not be a routine matter.
Recovery of a cask would be both expensive and difficult but could probably be accompiirned with the use of salvage procedures normally used in recovery operations for materials frcm ocean waters.
It should be noted that the retrieval of a spent fuel cask should be considered in terms of the potential environmental consequences as well as the specifics of the particular site.
O As ta the C;0 conclorien coprding the shipvnt of nuclear f"el and associated wastes, transoortation and handling of nuclear fuel and radioactive waste has been conducted without adverse environmentei itpact for n:ry years.
Packaging for these materials has been developed and authorized so that they may be introduced into t.he transportation system with minimal regard for their radioactivities.
The main feature of spent fuel packaging which requires special consideration in transportation is its weight.
Heavy cargoes have been transoorted at sea for centuries.
Recovery of sunken heavy objects at sea has been accomplished many times.
In sum, procedures fcr transportation end recovery are available.
GAO Recommendation No. c (p. 30)
--require specific procedures be developed for mitigating the consequac.ces of a core-melt accident; NRC Response The NRC staff is in basic agreemett with this recommendation.
We believe that plans and procedures for coping with this type of incident should be developed and that NRC should assume the lead responsibility in assuring that such plans and procedures are adequately developed.
It should be noted that other mitigation procedures that might be utilized 1 the event of a core-melt accident are discussed in the Draf t Generic Environmental Statement, Part III (llUREG-0127).
- Further, it is our plan to specify in the Final Generic Statement specific criteria related to mitigation techniques.
These general procedures tocether with procedures germane to a specific FNP site such as that proposed for the New Jersey coast will be considered in staff analyses prior to the issuance of an operating license for any FNP.
GA0 Recommendation No. 6 (p. 30)
--require that a specific decommissioning plan be prepared for the floating plant and the breakwater, including a funding mechanism to assure that the facility owner pays the cost of decommissioning; NRC Response The NRC staff agrees in principle with the recommendation and is taking a number of steps to develop its policy on decommissioning but does not believe a specific decommissioning plan for the FNP and its associated structures should be required at this time.
The staff certainly agrees that plans for decommissioning must be included in the decision-making process at the time of the review for the initial operating license for all nuclear facilities.
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tS imeiHor cf s p eific finnci'l M ans end/or technical pP,s at the time of licensing may not be warranted.
It is the present tiRC policy to determine during the licensing process that there are fexible and acceptable cathods for deccmmissioning nuclear power plants (land-based or floating) rather than to require, before licensing, the specification of a particular plan.
As 14RC under-standing increases, and as the technology is further developed, NRC will be in a better position to. determine how best to make specific plans for final disposition of the facility.
This allows for changes in regulations and improvements in technology as well as consideration of future alternative use; of the pcwcr picnt sii.e in 30 or 40 3,. u s between licensing and decommissioning.
The decommissioning of nuclear reactor facilities have been relatively well developed and is routinely considered in the licensing pcocess.
Since 1960, over 50 reactor facilities have been successfully decom-missioned, including five licensed power reactors.
!;RC does believe, however, that an orderly effort to further refine its approach to and definition of decommissioning of reactors and fuel cycle facilities is appropriate.
The 11RC requires all reactor licensees to present various decommissioning plans prior to the issuance of an operating license for a commercial power reactor or test reactcr.
These decommissioning plans may include mothballing, entombment, dismantle-ment or a combination of these modes, all of which have been used in decommissioning in past.
liothballing or entombment permits termination of the license to operate the reactor.
A materials license is issued for possession of the residual rc.tioactive material in the reactor ccmponents.
Either procedure permits greatly reduced surveillance requirements for protection of the public health and safety.
During the licensing process, tidC examines the costs and environmental impacts of the various decommissioning plans.
In each case llRC must be satisfied that feasible decommissioning alternatives do exist and that the applicant possesses or has the capability of obtaining the necessary funds.
One of the alternatives examined routinely is complete dismantlement.
Requiring a specific plan for decommissioning at the time of licensing may foreclose other more desirable methods which may be developed in the future.
In summary, NRC's current practice of assuring that various alternatives have been considered provides for the necessary assurance that economically viable alternatives will be available when needed.
It should be noted that Sections 9.5 and 12.4 of the Generic Environ-mental Statement (FES-Part II, NUREG-0056) and Section 10.2.3 of the AGS Draf t Environmental Statement (NUREG-0058) discuss various alterna-tive decommissioning techniques for both the Flip itself, the breakwater and associated transmission lines and shore facilities.
Relative to the decommissioning of the breakwater for a floating reactor, tha reactions of State governments to the need for Federal regulation b
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.g-thereof rw ba similar to that concerning the croling tov er at a land-based reactor.
At three regional St2ta Workshops on decommis-sioning held in September 19/8, the States generally agreed that F veral acencies should not involve themsleves with the requir m.nt for decommissioning nonradioactive structures such as cooling towers since that was an area for State prerogative.
14RC has developed a detailed plan, tUREG-0436, " Plan for Reevaluation of tiRC Policy on Decommissioning of fluclear Facilities," March 1978.
Inis plan was approved by the Ccmmissioners and is currently being implemantad.
Tt.3 plan includes tha davelcpment of a comp d.ar.sive information base on the technology, safety and costs of decommissioning LWRs to guide the policy reevaluation.
A very cetailed report o1 a land-based PWR was is3ued in June 1978, fiUREG/CR-0130.
A similar report on BWRs is scheduled for March 1979.
While these reports will provide valuable information on the decommissionir.g of LWRs, some of the specific characteristics of floating plants are not discussed.
A specific study on the deccmmissioning of ficating LWRs is planned to be initiated in October 1980 and completed in March 1982.
GA0 Recommendation flo. 7 (p. 30)
--reanalyze the effect on tourism.
f4RC Response The tiRC staff does not plan to implement this recommendation because the GA0 criticism of the flP,C tourism analysis related to Fl4Ps is directed only at the study conducted by Dr. E. J. Baker and his team
~
of researchers from Florida State University.
This study, entitled
" Impact of Offshore t!uclear Generating Stations on Recreational Behavior at Adjacent Coastal Sites" (flUREG-0394), was a major element used by the staff in preparation of testimony before the Atcmic Safety and Licensing Board in July 1978 regarding a contention that Fl:Ps located near a tourist area could cause economic injury to the area.
GA0 believes that the survey instrument deveic, ped by Bcker
(!1UREG-0394) was biased and should not be utilized as a basis for any decisionmaking.
With respect to the question of bias, we believe the study conducted by Dr. Baker to be objective and free from bias, in that the questionnaire for the study was designed so that the direct question on avoidance was asked immediately after the initial questions concerning demographic characteristics and beachgoing behavior and prior to any questions concerning attitudes about nuclear power.
Therefore, the latter questions could not influence the initial avoidance responsa.
The assumption of initial overestimate is not associated with the sequencing of questions but rather is based on well documented research (see pp. 132-134 of 14UREG-0394).
The adjustments made to the initial estimates of itended avoidance and the rationale for modifying verbal responses en predicting actual behavior are described on pp. 95-97 of t;UREG s.J94.
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. In addiuu, at thc.uLE Larings reg.rding the t;uri:= cent;nt' at FNPs, the que:tica of up w d bias in the questionmire design was pursued in some detail in cross examination of Ors. Baker and West.
Dr. Eaker wrote to the GA0 on August 30, 1978 providing his personal retort to the GA0 criticism cf his study.
Dr. Baker's letter is included as Encicsure 4 for ycur review.
Althnugh the CAC report acknowledges that the Baker study is one of several ccmponents of the NRC analysis dealing with the effects of FNPs on the tourist econcmy, no GA0 critique was offered on the other staff components.
The analysis conducted by the NRC is in agreement with Dr. Baker in that the staff concludes that the siting of ar, FNP would result in a relatively small level of tourist avoidance.
GA0 Recommendation No. 8 (p. 30)
--further the GA0 recommends "that if the licensing review starts again, the Chairman should determine as early as possible if the State of New Jersey is willing to provide a grant for siting of two floating power plants off that State's coast.
This may involve establishing a milestone date in the licensing review process by which time the applicant should have obtained the necessary grant.
Otherwise, the Chairman should once again suspend the licensing review."
NRC Resconse The NRC staff is in agreement with this recommendation.
The staff policy regarding the review of applications for nuclear power plants prior to acquisition of the associated site is2unless other events render a Commission proceeding moot, the Commission's review process will not be stayed based on what might or might not happen at some future date.
However, the application for a riparian grant was filed in June 1972 by Public Service Electric and Gas Company (PSEG) to site two FNPs off the New Jersey coast and is still pending before the New Jersey Department of Environmental Protection and, furthermore, PSEG has delayed the delivery of the FNPs by three years.
Thus, the staff has decided to reinstitute its review of this project only after receipt of assurances from the State of New Jersey regarding the granting of riparian rights to PSEG.
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.U. S. Nuclear Regulatory Conn.ission Attn:
Mr. Domenic 3. Vassr.llo Acsistant Director for Light
'.?ater Reactcrs Wasitina ;cn, D.C.
20535 Gentleten:
The Ccast Guard has reviewed GA0 Report E!D-78-36 "3efore Licensing Floating Su lear Tour Plsnts, l'any A.swers ar e " ceded" at the rcquest of the Commission. The folicwing cc=ents resulting from this review are being forwarded to you.
In accordance with the Memorandum of Understanding between the United States Coast Guard and the Suclear Regulatory Commission on Floating 5uclear Power Plants we do not intend to respond directly to the Governcent Accounting Of fice (GAO) concerning this report.
The Coast Guard takes issue with the statement on page 18 that the
" weight" of the floating nuclear plant represents a problem, and with the discussienc concerning this item which are presented on pages 18 - 20 and 28.
We also disagree with the recomendation on page 29 that the Nuclear Regulatory Cornission or any agency should " require that weight parameters be developed for the safe operation of the floating plant and insure that these parameters are cet".
Vhen the Coast Guard was contacted by 'GAO during the research phase of this re;.or t, the concern expressed for plant weight, with regard to safety, war brought up by GA0 and discussed at scne length. We indicated to the investi-gator that plant ueight is not vicwed as a saf ety problem but rather as a design related parameter.
The plant will be designed and built to accomodata its own 'teight and the weight of the systems and all materials on it.
The established rules of the American Sureau of Shipping, U.S. Coast Guard regulations and the International Leadline requirenents will be used as a basis for the design, review, classification, construction and certification of the vessel.
The standards expressed by the aforementioned rules and regulations will not be lowered to accommodate this plant.
The Coast Guard has studied the preliminary design and has found the structure to be appropriate for this type of vessel and service. We further indicated to the investigator that the Coast Guard will conduct an independent finite element analysis of the structure in addition to the one conducted by Offshore Power Systems, to assure that the structure is adequate for the loadings determined by the final design.
'IsucaI l LIMIT 15 o90 "o
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It is " -$rt ant to place plant "vcight" or rote properly, displacement in it; proper prospective.
There is no absolute "weisar
.n.ich ce r.cr M "h-cor. mucw of exceedinc, the expected design " weight" is the cr:*e h!,
nececsity to re-cvaluate and rc-site the structural nen'oers to acco:2odate the higher " weight".
It is co=on to allow a cargin of 5 tc 1C,J. vf
.c.e mal weight of a vessel for atute add vas.
It is :.crof cu und:rstandc512 that the engineers at OPS would follow connen practice and be vary cautious of addcd weights which would use up this rarsin cr require a r 2--evalua tic a c.f J..s.
structure.
It was pointed out that weight esti:2tes in the shipbuilding industry are quite accurate by the final design stage.
It is not unusual that the supertankers being built today (which are much larger than this bar,a) till ficat at their predicted decip water line uhen launehm! and put into service. Thus with modern techniques available and the economic incentive of this project, it is unlikely that OPS is " completely in the dark" about plant weight.
Following construction, the Ccast Guard will determine that the plant will meet its design requirements.
Based on the design, s tability calculations, and on an inclining experiment, the plant will be issued a Loadline Certificate indicating the maxinua draf t at which the plant may be towed and operated.
Both the desis;n of the plant and the Loadline issued will be based on unrestricted ocean service and will therefore be conservative for the sheltered breakwater environnent and the planned fair weather towing conditions.
A deviation from the design displacement is irrediately apparent in cbserving the plant draf t.
The loadline requir< cent will be in effect throughout the life of the plant and any weights added in the future cust not result in the plant draft exceeding the assigned loadline.
Based on the preceeding brief arguments, the Coast Guard sees the development of " weight parameters" as meaningless. The concern for grounding is a function of the waterdepth at the site with regard to the draft.
This aspect is adequately identified and accounted for by the Nuclear Regulatory Commission "no grounding" criteria.
With regard to the statement on page 19 that "it is important to control plans weight therefore the Coast Guard plans to inspect the floating plant and barge before it departs...", the Coast Guard inspects all certifi-cated vessels including passenger vessels, tankers, tugs and teubcats, drilling rigs and other co=ercial vessels as well as canned and unnanned oceangoing barges.
The inspection of the floating nuclear power plant is based on statutory requirenent and is not due to a weight consideration, as implied by the report.
Inspection starts with the approval of construction drawings, specifications, and stability calculations; and continues with physical inspection during construction, witnessing of the inclining experiment, and periodic inspections throughout its life.
In this regard, the floating naclear power plant is not unique.
These inspections are necessary for the initial and continued certification of any vessel.
2158 159 9{
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':- r a. n r e 30 is to " Identify :pecf fic tethd3 fer hand]ing the 1-dine ;.i of fleading of radiesetive r.aterial and the cccovery c: such r_terial in case of an acc:. dent.'
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c..,.. j 21 ;.J._3 a:ent of the fuel cask transport barse or the f alling everbehd
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of a fuelcask f rom the transport barje should be intestigated vita re<*ard to feel recevery.
This subject. c a c:.s inap; cap;;atc foi rcycrt u,..[...ing O.: licensin; of the plart as it is '.nvo', ' with naither plant safet; er plant operation.
We agree that leading of a sp:nt fuel cask onto a transport vcssel is a legicizate concern, h;.:ever, t acsi;r
.e tion of prope. ly p..J.:ged and stored spent nuclear fuel c1ccents by barge is controlled and regulated by separately established statutes and has routinely taken place in the past and will probably continue to take place in the future. F.equiring analysis during the licensin; procedure of events which are unrelated to safety is uncalled for and will result in further um,arrented delays.
These cot ents su-arize those problea areas in the report identifiad by us as itecs of Coast Guarl congnizance or interest.
The co==ents have been brief in order to coaply with subnission tine restraints requested by the Com:1csion. Ple::e cer. tact =c if you equire -ore inferentien concerning this matter.
Sincerely,
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John Deck III Commander, U.S. Coast Guard Nuclear Coordinator of fice of Merchant Marine Saf ety T
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Pr. Monte Canfield, Jr.
Energy and Mats _ials Division h
U.S. Ce..eral Accounting Office D
9 441 C Strcet, N.W.
D Washington, D.C.
20448
Dear Mr. Canfield:
I have recently received cc =ents your staff made on our study for the URC entitled Incact of Of fshore Nuclear Generatinc Stations on Recreational Eehavior at Adjacent Coastal Sites.
The criticisms reflect ignorance of well established generalizaticns in behavioral science and a lack of cenpre-hension of the report;itself.
Your surrary of our study creates an impression that only the " avoidance per-centages" were derived thrcugh original data collection, and that the 7 r2asons given for adjusting the " avoidance" figures downward are little core than conjecture on our part.
In f act certain of the reasons are documented by evidence consistently produced by other investigations (which we cited elsewhere in the report), and other reasons for adjusting the " avoidance" data were mandated by data collected as part of. the study itself. The nethods and results are discussed in detail in the report.
It is commen kncwledge among behavioral scientists that simplistic verbal responses, eten " intention-to-behave" responses, are unreliable when taken at face value.
Such data must be interpreted and adjusted in light of other factors.
Your staff seems unaware of such factors.
Again, this literature is cited in the report.
You object to our adjustments of the data on two general grounds: the adjust-nents are arbitrary and asyumetric.
Clearly the adjustments are not arbitrary >
For every adjustnent a justification is provided.
Some of the adjustments were dictated by facts established by previcusly published studies which we c ited.
Others were dictated by our own data collected with other sectiens of the qu.estionnaires employed.
To have neglected to take these findings into consideration in interpreting the " avoidance" data would have been irre.onsible.
If other criteria for adjustnent were not employed it was because we eim..er had no theoretical motivation for suspecting the criterien to have an effect (and therefore collected no data on it) or were unaware of any literature indicating the criterion's significance.
Your other point -- that no adjustments were made to increase the avoidence figure -- scens to suggest that such adjustments should have been cade even if they were not supported by data.
You of f er two rcore reasons for adjust-0 2158 161
2 August 30, 1978
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The first is that "aew" or "first ti-.e" tourists r:y be deterred in c rca.er prop 0r ti s.s than ct.:.lunt
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for such. cenrir'eratien vauld be + hat people who had not previously visited i.he beach area wnuld r.ot be " captured" by the habitual nature of beach choice.
Th e "habin" adj u _ -.....'. i s a.a r c. e, ar.d eve-withcut it cur rciction You will note that the information-integration tasks (which figure would stand.
cho. ed other beach attributes to be overwhelr.ingly nere i=,cortant than pro.v.inity to a F::i) crplcyed hypothetical beaches.
T~ms, the habitual visitation phe-nemen was nc. a factor at all in beach choice:
people were responding to a hypotheti.:al b:ach as if it would be their first trip.
It is possible -- even likely -- that a rizable portion of people cons tering eisiting a beach area for the first tire wculd be unaware of a F;
.rby.
Thus, they n:y be less affected than current visitors.
The fact is that there is no evidence that first tir2 visitors would be af f ected more tha:1 current visitor s;
!.at litt*.e d ta exists suggests that th2y will be af fe.ted in about the cm.c way as current visitors.
The only other factor you mentioned was che tourica ef fect sterming frca a mjer accident at a D P.
We ourselves point out in the conclusions that an accident at any nuclear plant could have an impact on tourism at beaches near an WP.
Cur conclusions clearly state that they apply to present circunstances and that it is unknown what changes will occur over time.
In any case, the only way to take into account such an accident would be to construct an avoidance figure for a totally separate scenario.
It would in no way af fect the situation to which our figures pertain.
k representative of your of fice telephoned me in the course of reviewing our study and asked several questions to clarify uncertainties and reservations he had.
- ene e,f *he criticisms included in your report were inquired about in the tele,chone conversation.
I would have been more than happy to discuss the natters in graat depth and offer our point of view.
Sincerely, CL kJA Earl J. Eaker Assistant Professor s
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