ML19263H039
| ML19263H039 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/1980 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| References | |
| TASK-CC, TASK-SE SECY-80-153, NUDOCS 8007070598 | |
| Download: ML19263H039 (36) | |
Text
..,
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 55"-
-'S CONSENT CALENDAR ITEM March 19, 1980 For:
The Commissioners From:
Robert B. Minogue, Director r_
(~
Office of Standards Development s
,.,.x
=
Thru:
Executive Director for Operations 1
Subject:
ADVANCE NOTICE OF PROPOSED RULEMAKING ON REACTOR SITING Purcose:
To obtain Commission approval for publication of the subject Advance Notice.
Catecory:
This paper relates to major policy issues.
Discussion:
The attached Federal Register Notice for the Advance Notice of Pro-posed Rulemaking on Reactor Siting has been prepared in response to the Commission's discussions of siting issues.
In responding to the Commission's instructions (memorandum, Chilk to Dircks, dated February 27, 1980), the comments of the ACRS have been appended to each recommendation and additional questions have been incorporated where appropriate to solicit response to certain portions of the comments.
In two places, the wording of the recommendations (two and four) of the Siting Policy Task Force (Task Force) has been k
altered and the alterations have been clearly indicated to avoid confusion.
In order to clearly indicate how each of the Commission's requests was implemented, the material added to the Task Force recommendations in the advance notice (other than the inclusion of the ACRS comments) is identified below according to the number of the recomendation:
1.
The OPE alternative for Recommendation 1, Part 3 has been described on the basis of the September 4, 1979, memorandum rom OPE to the Commission (Enclosure "C").
f The numbers used as an example by the Task Force have been listed in supplemental questions.
The OPE alternative approach has also been related to those example numbers.
A request has beea made for any other reasonable set of limits and the rationale for their selection.
2.
The OPE alternative for a "three tier" approach to exclusion-ary distances has been added to the Section on Task Force Recommendation 2.
The wording of the recommendation has been altered by the addition of three items to the list of specific hazards.
A question has been presented on whether other nuclear facilities should be treated as hazardous by requiring standoff distances.
A question has been added request.ing additional candidates for this list.
800707o 5 9 #
Contact:
R. P. Grill, SD
The Commissioners 2
3.
No changes or additions.
4.
Recommendation 4 has been deferred with reference for further information to NUREG-0625.
5.
Questions have been added to focus the attention on specific aspects of the ACRS commer.ts.
A question has been added to focus comment on the circum-stances under which the Commission should require changes in operating procedures (including plant shutdown) or engineered design changes in order to accommodate the intrusion of hazardous activities within the appropriate standoff distance.
A question on Recommendation 2 asks if other nuclear facilities should be considered hazardous.
6.
The OPE alternative has been introduced as requiring considera-tion in the alternative site analysis of site deficiency com-pensating features which are undesirable but not unacceptable in an absolute sense.
7.
No changes or additions.
8.
Language developed by OGC has been added to the red mmendation to limit this to State agencies acting within their proper State authority.
9.
Recommendation 9 has been deferred.,ith an indication that it may be implemented at a later time For further information, readers are directed to NUREG-05' Comments on the extent to which the iaw criteria for future plants should apply to existing sites are requested by addition of a new item "K" to the ANPR.
Reference has been made to the proposed rulemaking on emergency planning and on alternative sites.
In addition, a statement has been added that ind: cates that the Commission is initiating a separate rulemaking to establish a standard set of engineered safety features which will be mandatory for all future plants (see Enclosure "A", page 5, subparagraph 2).
The staff has prepared a letter to PIRG for the signature of the Chairman (Enclosure "0") describing the current status of their petition on siting and the relationship of their petition to this rulemaking activity.
Since it is desirable to receive comments from a wide range public interest groups and individuals, NUREG-0625 will be made available at no charge to an appropriate mailing list and to any others who indicate an interest in commenting.
The Commissioners 3
Enclosure "B" presents a composite schedule for staff activities in the area of siting.
The composite schedule projects issuance of proposed rule changes by November 30, 1980.
The indicated effort by RES in a technical support role involves the same Probabilistic Analysis staff that is already heavily impacted by the Indian Point /
Zion efforts and the ongoing review of all existing plants.
Recommendation:
That the Commission approve the Federal Register Notice, letter to PIRG, and draft Congressional letter.
Coordination:
This paper has been concurred in by the Office of Nuclear Reactor Regulation, the Office of Policy Evaluation and the Office of State Frograms.
The Office of the Executive Legal Director has no legal objection.
%,h-
~
Robert B. Minogue, Director Office of Standards Development
Enclosures:
"A" - Federal Register Notice "B" - Schedule of Staff Siting Activities "C" - OPE Memo, 10/4/79 to Commissioners
" 0"
.s ;ter to PIRG "E" - Draft Congressional Letter Comissioners' comments or consent should be provided directly to the Office of the Secretary by c.o.b. Friday, April 4,1980.
Comission Staff Office coments, if any, should be submitted to the Comissioners NLT March 28, 1980, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical review and coment, the Comissioners and the Secretariat should be apprised of when coments may be expected.
This paper is tentatively scheduled for affirmation at an Open Meeting during the Week of April 14, 1980.
Please refer to the appropriate Weekly Comission Schedule, when published, for a specific date and time.
DISTRIBUTION Comissioners Commission Staff Offices Exec Dir for Operations Regional Offices ACRS Secretariat
NUCLEAR REGULATORY COMMISSION
[10 CFR Parts 50, 51 and 100]
MODIFICATION OF THE POLICY AND REGULATORY PRACTICE GOVERNING THE SITING OF NUCLEAR POWER REACTORS AGENCY:
U.S. Nuclear Regulatory Commission ACTION:
Advance Notice of Proposed Rulemaking:
Revision of Reactor Siting Criteria
SUMMARY
The Nuclear Regulatory Commission is considering the adoption of modified or additional repulations concerning the siting of nuclear power reactors.
The intent is to reflect the experience gained since the original regulations on siting were published in 1962.
The Cr amis-sion intends that this task be completed expeditiously.
In this Notice, the Commission requests comments on seven of the nine recommendations contained in the " Report of the Siting Policy Task Force," h REG-0625, August 1979.
Where appropriate, some of these recom-mendations are supplemented with comments from the Advisory Committee on Reactor Safeguards (ACRS) and with questions to focus comment in areas that will be particularly helpful in developing the rule.
DATES:
While comments and suggestions are welcome at any time, in order to be considered for this version of the proposed rule changes they must be received no later than ADDRESSES:
Written comments should be submitted to the Secretary of. the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention:
Docketing and Service Branch.
1 Enclosure "A"
[7590-01]
Copies of the complete text of the " Report of the Siting Policy Task Force," NUREG-0625, are being mailed, along with a copy of this Advance Notice, to a number of individuals, groups, and appropriate State offi-cials that may have a particular interest in commenting.
Those who do not receive this mailing may obtain single copies without charge by writ-ing to the Director, Division of Technical Information and Document Con-trol, U.S. Nuclear Regulatory Commission, Washington, D.C.,20555.
FOR FURTHER INFORMATION:
Contact Mr. Richard P. Grill, Office of Stana-ards Development, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, (301) 443-5966.
SUPPLEMENTARY INFORMATION:
Background
The essential elements of nuclear power plant siting policy are derived from the Atomic Energy Act of 1954 and the National Environmental Policy Act of 1969 and are contained in 10 CFR Part 50, " Domestic Licens-ing of Production and Utilization Facilities," 10 CFR Part 51, " Licensing and Regulatory Policy and Procedures for Environmental Protection," and in 10 CFR Part 100, " Reactor Site Criteria."
The regulations in Part 100 were promulgated by the Atomic Energy Commission in 1962 and have remained essentially unchanged since that time.
The site suitability criteria utilized by the staff in performing licensing reviews have been based upon the principles embodied in Parts 50, 51 and 100 as modified by experience gained over the years by both applicants and staff, contributions from the public during the public hearing process, decisions of Atomic Safety and Licensing Boards (ASLB) and Atomic Safety and Licensing Appeal Boards (ASLAB), consultations with the Advisory Committee on Reactor Safeguards 2
Enclosure "A"
[7590-01]
(ACRS), petitions for rulemaking received by the Commission research funded by NRC, interaction with other Federal and State agencies, new legislation such as the National Environmental Policy Act (NEPA), the Clean Air Act, and other environmental legislation, as well as consulta-tion with the Congressional Committees to which NRC is responsible.
All of these have been important factors contributing to the current license review practice.
In June 1975, the Commission directed the staff to draw the siting policy and practice that had been developed over the years into a single statement.
As a result, the staff undertook major efforts in a number of areas to provide a basis for revising Commission siting policy.
- Also, l were received on reactor during this period, petitions for rulemaking siting matters which were factored into the general staff effort.
As an outgrowth of these efforts, the Commission directed, in August of 1978, a task force of senior staff members to develop 1 general policy statement on nuclear power reactor siting.
From this, a number of recommendations emerged which are contained in the " Report of the Siting Policy Task Force,"
NUREG-0625, which has been considered by the Commission in developing this Advance Notice.
Events during the past year, including the events at the Three Mile Island Nuclear Station, have made the NRC, the Congress, and the public increasingly concerned that past siting practice may not afford sufficient protection to the public health and safety.
Considering revi-sion of NRC siting policy using the Task Force's recommendations is, therefore, particularly relevant at this time.
1 Note:
In particular, the rulemaking initiated by this Advance Notice will consider the detailed recommendations contained in a Petition for Rulemaking filed by the Public Interest Research Group, et al. (PRM-100-2, June 1,1976) and in part 4 of a Pc?.ition for Rulemaking7iTed by Free Environment, Inc., ej al. (PRM-50-20, April 28, 1977).
3 Erclosure "A"
[7590-01]
Parallel to this planned revision of the siting regulations, the Commission is embarked upon rulemaking to improve the protection of the public through upgrading emergency planning requirements for new and existing plants.
Another rulemaking which is related to but separate from this Advance Notice is the proposed rule on the consideration of alternative sites under NEPA (FR Notice Citation).
The effort in emer-gency planning is presently at the stage of a proposed rule for which public comments have been solicited (44 FR 75167, December 19, 1979).
While this particular advance notice is focused upon siting criteria, it should be recognized that the revised rules on emergency planning and the rule changes for consideration of alternative sites will be applied in the licensing of future plants and, thus, will become factors con-sidered in developing criteria that will be used in the selection of sites for future plants.
Although this rulemaking is intended for application to new sites, if it becomes apparent that significant improvement in safety will be achieved by use of the new criteria, the question will naturally arise as to whether additional engineered safety features and/or changed operating procedures, including plant shutdown, should be required for existing plants on sites that do not meet the new criteria.
One item (Item "K") has been added specifically to explore this question further.
Inclusion of this item is not intended to imply that the rule changes under consideration here will, or should, be directly applied to existing plants.
It should be noted that Conmission decisions on the rentinued operation of existing plants currently are being made on a case-by-case basis in light of policy developed for future site acceptability, upgraded emergency plans, improved operator training, additional engineered safety 4
Enclosure "A"
[7590-01]
feature requirements, and other related considerations.
Each of these aspects of improving existing plant safety is currently under separate but parallel NRC study and is bei q implemented as rapidly as practicable.
Becr.use this rulemaking is directed at siting criteria and attempts to separate those criteria from engineered reactor safety systems, the intent of the Commission with regard to several issues should be stated here:
1.
The original licensing policy for nuclear power plants permitted plant design features to compensate for unfavoraW.e site charac-teristics and thus, over the years the net effect has been an unforeseen de-emphasis of site isolation (remote siting, as the concept was originally used).
The Commission with these rules intends to re-emphasize the goal of site isolation inde-cendent of engineered features which can compensate for unfavor-able site characteristics.
Thus, siting for isolation is re-emphasized as a primary goal of the Commission.
2.
Although the Commission is interested in establishing s neric criteria for isolation which are independent of plant dec?gn, improved engineering design remains a valid, proven, and important way of reducing risk to the public from operation of a nuclear power plant.
To retain tho benefits of this sell-developed technology, portions of the Commission's regulations will be revised to establish a standard set of engineered safety features that will be required of all new plants.
This action is now being initiated and will be separate from the rulemaking being supported by this Advance Notice but will be accomplished 5
Enclosure "A"
[7590-01]
in parallel so that both rules can be implemented at approximately the same time.
3.
Dose assessment should not be used as a measure of site suitabil-ity because this approach tends to de-emphasize isolation as an independent safety feature and, accordingly, is counter to the Commission's intent to reassert the importance of isolation.
In other areas of the Commission's review of license applica-tions dose assessment will continue to play an important role.
In establishing an impact assessment which is as complete as possible the Commission's staff will continue to make calcula-
- tions of the potential radiological consequenris of releases which are specific to the plant under review.
In reviewing emergency plans these same release scenarios sill be used to improve the planning basis for emergency protective actions.
4.
The applicant for a plant with standard safety features on a site which meets all proposed siting criteria is not guaranteed issuance of a Construction Permit.
Although this is a necessary qualification of an acceptable site plant comaination, the Commission's rules implementing the National Environmental Policy Act of 1969 require that before a Construction Permit can be issued there must be a demonstration that, with regard to environmental considerations, there is no obviously superior alternative site.
All final alternative sites are required to be potentially licensable from the safety standpoint according to available information (i.e., no safety siting criteria are violated).
Under present practice, safety matters are only indirectly considered in the comp rison of alternatives (except 6
Enclosure "A"
[7590-01]
when population densities exceed 500 persons per square mile as described in Regulatory Guide 4.7) through plant cost estimates, but an alternate approach introduced later in this Advance Notice would change this practice.
Since the Report of the Siting Policy Task Force was first issued in August 1979, additional staff consideration has resulted in alternative approaches to several of the Task Force recommendations.
In addition, the Advisory Committee on Reactor Safeguards has submitted comments on each of the Task Force's recommendations and on the goals which guided their development.2 In order to present these matters clearly, the following format is utilized:
Item Task Force Recommendation:
Alternative Approach to Task Force Recommendation (if any):
ACRS comment on Task Force Recommendations (if any):
Additional Questions (if any):
Additional questions have been prepared, where appropriate, to help focus comment along directions that the staff believes will be most usefu'..
In particular, several questions focus on the substance of the ACRS comments.
Comments from all interested persons are requested on all of the entries under each item and will be considered on any aspect of improving the safety of nuclear power plant siting that the public perceives as important.
Priority for this rulemaking, however, will be given to those comments bearing on the goals established by the Task Force (Item "A");
seven of the nine Task Force recommendations, including alternative
" Letter to Chairman John F. Ahearne from Milton S. Plesset, Chairman, Advisory Committee on Ractor Safeguards, dated February 14, 1980.
7 Enclosure "A"
[7590-01]
approaches and additional questions (Items "B" through "I", except "E")
and the additional Item "K" on existing plants.
Item A The three conceptual goals developed and used by the Task Force in reaching their recommendations were (NUREG-0625, page lii);
"1.
To strengthen siting as a factor in defense in depth by estab-lishing requirements for site approval that are independent of plant design consideration.
The present policy of permitting plant design features to compensate for unfavorable site char-acteristics has resulted in improved designs but has tended to de-emphasize site isolation.
2.
To take into consideration in sitina the risk associated with accidents beyond the design basis (Class 9) by establishing population density and distribution criteria.
Plant design improvements have reduced the probability and consequences of design basis accidents, but there remains the residual risk from accidents not considered in the design basis.
Although this risk cannot be completely reduced to zero, it can be significantly reduced by selective siting.
3.
To require that sites selected will minimize the risk from energy generation.
The selected sites should be among the best available in the region where new generating capacity is needed.
Siting requirements should be stringent enough to limit the residual risk of reactor operation but not so stringent as'to eliminate the nuclear option from large regions of the country.
This is because energy generation from any source has its associated risk, with risks from some energy sources being greater than that of the nuclear option."
8 Enclosure "A"
[7590-01]
ACRS comments on the Siting Policy Task Force goals.
"With regard to the [three Task Force] goals discussed above, the ACRS agrees that siting, as a factor in the defense in depth philosophy, should be strengthened.
However, the ACRS believes that any minimum requirements for parameters such as the exclusion zone radius, surround-ing population density, or distance from population centers should be established, if possible, within the framework of an eserall Nuclear Regulatory Commissior. safety philosophy for future reactors.
Such a philosophy should be based on preestablished Co::nission objec-tives for acceptable risk both to individuals and society.
This will, of necessity, include consideration of matters such as the potential effects of a broad spectrum of reactor accidents, the identification of an ALARA
[(As Low as Reasonably Achievable)] criterion for the reccction of risk from accidents, and a general statement of policy concerning the objectives to be sought in reactor design with regard to the prevention and the mitigation of accidents.
The establishment of demographic-related site criteria will inevit-ably require a considerable a=ount of judgment.
However, the choice will be less arbitrary if made within the framework of an overall NRC safety policy.
The ACRS believes that an overall NRC safety philosophy is also needed in connection with the third objective of the Task Force, namely that of selecting sites to minimize the risk from the utilization of electricity generating sources.
The ACRS believes that well-founded nuclear power plant siting policy and practice are a national as well as a regional need.
The Committee suggests that as part of a broad approach to LWR [(Lignt Water Reactor)]
siting, the NRC should explore the possible development of a nationwide 9
Enclosure "A"
[7590-01]
program to identify a bank of near-optimal sites regionally distributed for various types of energy generating plants.
By combining considera-tions of acceptable risk, the risks from various energy sources, and the national needs for energy, together with other rele" ant factors, a better long-term basis for determining appropriate criteria for LWR siting should be possible.
In the absence of such a broad approach, the ACRS recommends that changes to past siting policy be interim in nature and be designed primarily to provide an acceptable basis for near-term decision making."
Item B Task Force Recommendation 1 (NUREG-0625, pages 46-50 and 64-65)
" Revise Part 100 to change the way protection is provided for acci-dents by incorporating a fixed exclusion and protective action distance and population density and distribution criteria.
1.
Specify a fixed minimum exclusion distance based on limiting the individual risk from design basis accidents.[3] Furthermore, the regulations should clarify the required control by the utility over activities taking place in land and water portions of the exclusion area.
2.
Specify a fixed minimum emergency planning distance of 10 miles.
The physical characteristics of the emergency planning zone should provide reasonable assurance that evacuation of persons, including transients, would be feasible if needed to mitigate the consequences of accidents.
" Note:
The Task Force Report also discusses accidents larger than " design basis" accidents (NUREG-0625, page 47) in regard to providing signif-icant additional protection by increasing the exclusion distance.
10 Enclosure "A"
[7590-01]
3.
Incorporate specific population density and distribution limits outside the exclusion area that are dependent on the average population of the region.
4.
Remove the requirement to calculate radia'.*on doses as a means of establishing minimum exclusion distances and low pepulation zones."
Alternative acoroach to Task Force Recommendation 1, Part 3.
Consideration should be given to provision of two thresholds for each parameter.
One would be the acceptance threshold.
On the side of that threshold which exceeds any criterion for acceptance the site would be disapproved regardless of other considerations.
On the acceptable side of the threshold, residual risks could be taken into account in site comparisons, except that another, lower threshold--a d_e minimis threshold--
would be established for population density.
For site parameters on the favorable side of tne d_e minimis thresholds the residual risks would not be included in site comparisons.
The thresholds would be nationwide, rather than varying with regions.
The rationale of such a "three-tier" approach rests on the view that even when the population density is not prohibitively high in any absolute sense, one should try to do better.
The alternative sites evaluation process is suited to determination of how well one can reasonably do in a particular area under consideration.
The process would illuminate specific alternatives.
A, priori judgments on a regional basis would be avoided.
In view of the inherent imprecision of the comparative evaluations, the comparative judgments would focus only on gross differences in the raw numbers (on population density and distribution, etc.):
detailed dose 11 Enclosure "A"
[7590-011, calculations would not serve a useful purpose in this context and are not intended.
ACRS comment on Task Force Recommendation 1.
"Part 1.
The ACRS believes that the specification of a minimum exclu-sion distance should include consideration of the risk from all accidents, not just design basis accidents.
It should include consideration of the number of reactors at the site.
Any long-term criterion concerning a minimum exclusion distance would best be established within the framework of a general NRC policy on LWR safety.
Interim guidance could be deter-mitied with the benefit of information developed from NRC Staff studies ard information submitted during a proposed rulemaking on interim changes in the site criteria.
Part 2.
The ACRS generally supports this recommendation with the understanding that appropriate attention would be given to potential problems at greater distances.
Part 3.
The ACRS believes the wording of this recommendation is vague and it could be interpreted to be excessively restrictive or very permissive with regard to demographic requirements.
Additional informa-tion is needed to establish interim criteria of this sort within the context of an NRC rule.
Among the factors which require consideration are the following:
(a)
If some regions of the country are permitted to employ higher maxi-mum population densities, should there be any additional require-ments for such plants in design, operation, or emergency planning?
If not, what basis will be provided for designating regionally dependent acceptable risks?
12 Enclosure "A"
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(b) Should the NRC place a simihr or a substantially greater emphasis on improbable, large accidents in its siting (and design) require-ments than is utilized for other new societal activities posing hazards similar in magnitude and probability?
(c) How should the effectiveness of emergency measures, such as evacua-tion, sheltering and decontamination, be ascertained and factored into a judgment concerning minimum exclusion and emerg,ency planning distances?
(d) Should meteorology not be given consideration in regard to the development of siting criteria?
Part 4.
The ACRS agrees with the Task Force that the approach used for the past two decades has not provided enough emphasis on site isola-tion.
The Committee believes that the emphasis on engineered safety fea-tures to meet Part 100 for the postulated accident without direct consid-eration of other, more serious possibilities has led to a less-than-optimum approach to safety.
However, if the recommendation of Part 4 is adopted, some alternative means of determining the need and adequacy of engineered safety features will be required.
In summary, although the ACRS agrees that the specification of mini-mum exclusion and emergency planning distances and population density and distribution limits is a commendable objective, and that interim criteria should be developed, the Committee believes that the adequacy of such parameters will depend on the safety related design and operational requirements and on the effectiveness of emergency measures.
Also, the ACRS believes the establishment of such parameters involves the assump-tion of some accepted band of risk which should be specified.
While the 13 Enclosure "A"
[7590-01]
ACRS is not opposed to removal of the Part 100 requirement for calcula-tion of radiation doses or to the specification of regionally dependent acceptable population densities, the Committee believes these matters need in-depth evaluation."
Additional Questions Relative to Recommendation 1:
1.
Should the exclusion distance also be based on limiting indi-vidual risk from accidents beyond those considered for design basis?
(
Reference:
discussion on pages 46 and 47 of the Task For;e Report.)
2.
Should there be a single population density / distribution limit set applicable to the entire country, or shculd such limits recognize different demographic characteristics of regions and be dependent upon those characteristics?
(
Reference:
discus-sion on page 49 of the Task Force Report.)
3.
Should the concept that projected population densities during the lifetime of the plant should remain below maximum criteria be dropped and replaced by requiring that population limits be considered only at the construction permit license phase?
(
Reference:
page 67 of the Task Force Report.)
4.
What other considerations should be examined and how should NRC proceed in order that public policy be established or the extent to which risk from nuclear power plants should be limited?
5.
NUREG-0625 gives examples of the following specific population density and distribution limits which would vary regionally:
the greater of 100 persons per square mile or the average population density of the region out to five miles; from five to ten miles, the greater of 150 persons per square mile or 14 Enclosure "A"
[7590-01]
three quarters of the average population density of the region and no more than one-half of the allowed total in any single 22 sector; from ten to twenty miles the greater of 400 per-sons per square mile or twice the average population density of the region and no more than one-half of the allowed number in any single 22
- sector.
Would this graduated, regionally dependent approach be desirable? What other sets,of values would be a more reasonable expression of population density and distribution limits?
6.
If a "three-tier" approach were utilized as set out in tha alternative staff approach, what values should be utilized for the upper (exclusionary) and lower (de minimis) thresholds?
(For example, the 100, 150 and 400 persons per square mile values cauld be considered de minimis thresholds.
The corres-ponding exclusionary limit could be set--for example--at 250, 375 and 1000 persons per square mile.
A more conservative approach might use 100, 150 and 400 as exclusionary limits and establish de minimis thresholds of 30, 50 and 100 persons per square mile.)
7.
Is the graduated approach with regionally differentiated limits (as recommended by the Task Force) or the alternative nation-wide "three-tier" approach a more reasonable way to proceed or would a combination of the two approaches be more appropriate?
8.
If criteria are to vary regionally, how should region be defined?
15 Enclosure "A" i
[7590-01]
Item C Task Force Recommendation 2 (NUREG-0625, pages 51-52)
" Revise Part 100 to require consideration of the potential hazards posed by man-made activities and natural characteristics of sites by estab-lishing minimum standoff distances for:
1.
Major or commercial airports, 2.
Liquified natural gas (LNG) terminals, 3.
Large propane pipelines, 4.
Large natural gas pipelines, 5.
Large quantities of explosive or toxic materials, 6.
Major cams, and 7.
Capable faults.[4]"
[8.
Liquified propane gas (LPG) terminals]5
[9.
Navigable water ways which are used for the transportation of hazardous materials.]s
[10. Other nuclear power plants]5 Alternative accroach to Task Force Recommendation 2.
Consideration should be given to provision of two thresholds for each parameter.
One would be the acceptance threshold.
On the side of that threshold which does not meet any criterion for acceptance the site would be disapproved regardless of other considerations.
On the acceptable 4 Note:
Althougn comments are requested here with respect to standoff distances for capable faults and will be corsidered in a later action, the complexity of this topic and the commitment of the cognizant staff to other activities of pressing importance require that consideration of this topic be deferred for two to three years (see Item "E").
5 Note: Added at the suggestion of the Advisory Committee on Reactor Safeguards.
16 Enclosure "A"
[7590-01]
side of the threshold, residual risks could be taken into account in site comparisons, except that another threshold--a g minimis threshold--would be established for specific parameters.
For site parameters on the favorable side of the g minimis thresholds the residual risk considera-tions would not be included in site comparisons.
ACRS comments on Task Force Recommendation 2.
"This recommendation proposes minimum standoff distances for potential hazards posed by man-made activities and natural characteristics.
The Committee believes that such a recommendation is appropriate but the list is incomplete.
For example, LNG terminals are included but not LPG.
Similarly, hazardous cargo on rivers is not mentioned.[8]
In addition, the proposed approach lacks an adequate rationale for specific numbers suggested.
distance of at least 12.5 miles from all
.4 cabable faults, with no distinction as to fault size, is proposed, as is a specification that no reactor sites located on a flood plain should be closer than five miles downstream of a major dam.
The reason why either of these two proposed numbers is suitable is not clear to the ACRS.
For example, dams many miles away could be equally or more dangerous to a nuclear plant; on the other hand, small capable faults nearer than 12.5 miles might not pose significant design problems.
It is noted that the recommendation does not provide standoff dis-tances between nuclear plants.[8] The potential adverse influence of one plant on its neighbors in the event of a serious accident requires con-sideration in design."
6 Note:
Added to list in Task Force Reconsendation 2.
See footnote 5.
17 Enclosure "A"
[7590-01]
Additional Ouestions Relative to Reccmendation 2:
g 1.
hhat man-=ade activities or natural characteristics, other than those discussed above, might require that sini=um standoff dis-tances be established? Should other nuclear facilities be con-sidered in setting criteria for standoff distances?
2.
khat specific distances night be appropriate?
3.
What would be an appropriate basis for specifying standoff distances?
Item 0 Task Force Recomendation 3
" Revise Part 100 by requiring a reasonable assurance that interdic-tive ceasures are possible to limit groundwater contamination resulting from Class 9 accidents within the ime:ediate vicinity of the site."
ACRS Cc=ent on Task Force Recc=endation 3 "The ACRS supports the reccc=endation.
However, the Cccaittee notes that the current wording is subject to a range of interpretations which could include, for exa=ple, the necessity for developing interdictive measures for particulate fallout or rainout that could result in ground-water contaminaticn.
The Co.mittee recemends that the wording of the recommendation be made core explicit."
Item E Task Force Reccenendation 4 (Deferred; text is included for cc=pleteness.)
" Revise Appendix A to 10 CFR 100 to better reflect the evolving technology in assessing seissic hazarcs."
It is planned to icplement this recce=endation in a separate action in two or three years.
Cements are not solicited at this ti=e on the 18 Enclosure "A"
[7590-01) revision of Appendix A to Part 100.
For additional information on this recommendation consult the Report of the Siting Policy Task Force (NUREG-0625, page 54).
Item F Task Force Reccmmendation 5 (NUREG-0625, pages 55-56)
" Revise Part 100 to include consideration of post-licensing changes in offsite activities:
1.
The NRC staff shall inform local authorities (planning commis-sion, county commissions, etc.) that control activities within the emergency planning zone (EPZ) of the basis for determining the acceptability of a site.
2.
The NRC staff shall nu a fy those Federal agencies as in Item 1 above that may reasonably initiate a future Federal action that may influence the nuclear power plant.
3.
The NRC staff shall require applicants to monitor and report potentially adverse offsite developments.
4.
If, in spite of the actions described in Items 1 through 3, there are offsite developments that have the potential for significantly increasing the risk to the public, the NRC staff will consider restrictions on a case-by-case basis.7 ACRS comments on Task Force Recommendation 5 "This recommendation relates to post-licensing changes in offsite activities but does not specify what population / time period would be used.
For example, would it be the present population, that at the projected 7 Note:
The upgraded emergency planning requirements now being implemented should reveal information about such projects.
If any such developments are noted by any means the Commission will take whatever action it deems appropriate including possible shutdown of the plant in question.
19 Enclosure "A"
[7590-01]
end of life of the plant, or an average over the time period during which the plant will be operated? This should be clarified.
The recommendation also does not specify what is considered to be a "significant increase in ri s k. " Another consideration that might be taken into account is the nature and use of the land surrounding a site.
Whether neighboring land is used for residential or industrial purposes, and whether it is fertile land or a desert, could also be important."
Additional Questions Relative to Recommendation 5:
1.
What, if any, legislative authority should or could be given to NRC in order to:
a.
assure population densities or groupings around nuclear plants remain within acts.ptable criteria?
b.
preclude installation of activities or facilities that might be hazardous to the plant during its lifetime?
(
Reference:
discussion on pages 55 and 56 of the Task Force Report.)
2.
Should an approach which specifies population density levels that should not be exceeded at start-up and projected end of plant life be used or should a different approach (please be specific) which daes not include a limit with respect to post-licensing population growth be adopted?
(See Item 8, Question 3.)
3.
What actions should be considered by the Commission and under what circumstances should they be applied in the event that post licensing demographic criteria are no longer satisfied?
4.
Under what circumstances should the Commi sion require chinges in operating procedures (including plant shutdown) or engineered 20 Enclosure "A"
[7590-01]
design changes to accommodate the construction of facilities (including other nuclear power plants) or changes in existina hazardous offsite activities which might compromise plant safety?
Item G Task Force Recommendation 6 (NUREG-0625, page 57-50)
" Continue the current approach relative to site select, ion from a safety viewpoint, but select sites so that there are no unfavorable characteristics requiring unique or unusual design to compensate for site inadequacies."
Alte native approach to Task Force Recommendation 6.
Staff practice under this recommendation of the Task Force would change to preclude consideration of sites which have a characteristic that does not meet safety criteria but is amenable to unique or unusual compensating engineering design or feature which would offset the undesirable site characteristic.
On the other hand, no further con-sideration of marginal differences in safety between sites which meet all of these criteria would be contemplated even though they may involve engineered designs or features to offset undesirable site characteristics that are not so unique or unusual as to require rejection.
An alternative approach would recognize the possibility that some compensating p aineered designs or features may not be so unusual, unique, or involve uncertainties significant enough to be rejected on an absolute standard, but nevertheless should be accepted only if there is no ctherwise comparably attractive alternative site withe.at the characteristics requiring the compensatory engineered designs or features of concern.
In such cases, the alternative site review under NEPA should permit consideration of these matters.
21 Enclosure "A"
[7590-01]
ACRS Coments on Recommendation 6 "The Committee suggests that the phrase, " unfavorable characteristics requiring unique or unusual design," be clarified.
Many characteristics that are " unfavorable" can be readily compensated for by design, includ-ing some of an " unusual" nature.
Design features to provide permanent site improvements should be permissiF,e when suitably reliable.
Perhaps these problems could be solved by deleting the word, " unfavorable," and substituting the word, " unproven," for " unique or unusual"."
Item H Task Force Recommendation 7 (NUREG-0625, page 60)
" Revise Part 100 to specify that site approval be established at the earliest decision point in the review and to provide criteria that would have to be satisfied for this approach to be subsequently reopened in the licensing process."
ACRS Comment on Task Force Recommendation 7 "The ACRS suggests that this recommendation could be improved by substituting the word " decision" for " approach"."
It:m I Task Force Recommendation 8 (NUREG-0625, page 61-62)
" Revise Part 51 to provide that a final decision disapproving a pro-posed site by a State agency [ acting within proper State authority]s whose approval is fundamental to the prcject would be a sufficient basis for NRC to terminate review.
Such termination of a review would then be reviewed by the Commission."
- Note:
Language added to the recommendation of the Siting Policy Task Force on the advice of the NRC's Office of the General Council.
22 Enclosure "A"
[7590-01]
Item J Task Force Recomendation 9 (Deferred; text is included for completeness.)
" Develop comon bases for comparing the risks for all external events."
This recomendation may be implecented by the NRC at a future time.
No coments are solicited at this time.
For additional infor=ation on this recomendatf ort consult the Report of the Siting Policy Task Force (NUREG-0625, page 63).
Item K Evaluation of Existino Plants with Resoect to New Sitino Criteria As discussed earlier in this Advance Notice, the Coxaission is aware that cocparison of existing sites with the criteria that result from this siting rulemaking is inevitable.
The Commission also recognizes that the ability to modify the characteristics around existing sites is limited by physical, legal and economic constraints.
With this in mind, the Commission would welcoce cocments on whether and to what extent existing plants should be corpared against the new criteria, i.e., whether and to what extent engineering design and operating procedures should be modified for plants at existing sites which exceed the new siting criteria.
Coments on the relationship between any addi-tional levels of safety-afforded by new siting criteria and any additional levels of safety afforded by compensatory design or operating changes (including plant shutdown) for existing plants also would be useful.
23 Enclosure "A"
[7590-01]
All coments received will be evaluated by the NRC staff.
The staff will utilize the coments in preparation of recomendations and proposed rule changes for consideration by the Comission.
Dated at Washington, D.C., this day of 1980.
For the Nuclear Regulatory Comission.
Samuel J. Chilk Secretary of the Comission -
24 Enclosure "A"
k Proposed Schedule for Staff Siting Activities 3/30 7/,15 1/15/82 7/15/82 Ye llearl'ngs llea Ings Final Comment Coment a
begin end rule Period Period 1/7/80 4/14 6/14 7/14 10/15 11/30 1/31/81 2/28/81 e
t I
I Degin issuc Connent Proposed Publish Comment Recommendation analysis rule to proposed anal sis to Consission preparation ANPR complete Consission rule camp ete on public hearings of ANPR I
ho l 6/30/81 Final rule NRR/Research Technical Support for 7{l7 HRR/Research Technical Support for Final Rule V
Proposed Rule CompIete 3/15 Develop RFP for Tech 9/31 2/2R/81 6/30/81 7/lp/82 I
I I
support for [IS Award contract Draft EIS Final Els EIS Begin tech complete Supplement 7
support work (ifnecessary)
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/I'5,a h U'JITE D STAT Es t}y*qf)y h TJUCLEAR REGULATORY COf.*f.*lSSION
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September 4, 1979 MEMORANDUM FOR:
Chairman Hendrie Comissioner Gilinsky Comissioner Kennedy Comissioner Bradford Comi
'r Ahearne FROM:
Al H
, eke, Acting Director, OPE
SUBJECT:
C0FJ4EN15 ON SECY-79-498, REPORT OF THE SITING POLICY TASK FORCE This is an excellent, useful paper. The Task Force's fine explanation and critique of current siting policy and practice provide valuable background. -
The recomendations are presented and discussed in the report in a manner that should help you focus on the major issues.
We agree with most but not all of the recomendations.
PRINCIPAL COFJ4ENT 1.
We differ with the Task Force on one major point, which has ramifications reflected in their Recomendations 1, 2 and 6.
In conformity with the alternative-sites paper (SECY-79-481), the Task Force would exclude safety aspects (such as' population density) from site comparisons.
This leads to substantial difficulties in some aspects of the three Task Force recomendations cited.
Our differing view on the role of safety aspects in site comparisons has already come before you in Enclosure 7 to SECY-79-481, which also contains the staff's response (copy enclosed with this memo).
The Task Force addresses the issue primarily in the discussion of Recomendation 6 (in connection with policy on design features to compensate for unfavorable site characteristics).
OPE's views are consistent with the Task Force minority view, sumarized on page 58 (third full paragraph).
The appended coments by El.D and State Programs also tend to' support the minority's views.
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Mr. L. J. Sirico, Jr.
Public Interest Researen Group 1832 M Street, NW.
Washington, D.C.
20036
Dear Mr. Sirico:
This letter is in reference to petition for rulemaking PRM-50-20, Part 4, which you submitted for Free Environment, Inc., et al. (April 28, 1977) and petition for rulemaking PRM 100-2 which you submitted for the Public Interest Research Group, et al. (June 1, 1976).
The subject of these petitions, reac-tor siting criteria on population density and distribution, has been under staff review for some time.
In August of 1979, the staff published NUREG-0625 which presents recommendations to the Commission from the Siting Policy Task Force, a group of staff members specifically charged with developing recom-mendations for revision of existing NRC reactor siting criteria.
Appendix A of that report addressed the recommendations of PRM-100-2 and how they related to the recommendations of the Task Force.
The Commission has decided to embark on rulemaking on reactor siting criteria.
As a first step in this rulemaking, the Commission has issued in the Federal Register the attached Advance Notice of Proposed Rulemaking and supporting materials.
While the material presented in the Advance Notice focuses on staff recommendations and thus does not directly reference the specific values recommended in your petitions, the material in those petitions will be given careful consideration as a part of the record for this rulemaking.
Enclosure "D"
Mr. L. J. Sirico, Jr.
2 The Commission intends that this rulemaking establish clear siting policy and thus should properly dispose of any related issues such as those in petitions PRM-50-20, Part 4, and PRM-100-2.
The Commission does not therefore intend to take any further action on these two petitions until completion of this rulemaking.
We recognize the interest of your clients in satisfactory completion of this rulemaking.
Although, as noted above, their views will be given careful con-sideration in this rulemaking, the Commission urges them to submit any addi-tional comments on the material in the Advance Notice.
We will continue to keep you informed on significant developments in the course of this rulemaking.
Thank you for your continuing interest in improving the safety of nuclear power.
Sincerely, John F. Ahearne Chai rman Enclosure "D"
DRAFT CONGRESSIONAL LETTER Enclosed fcr the information of the Subcommittee on are copias of an Advance Notice of Proposed Rulemaking to be published in the Federal Register.
Also enclosed is a copy of an NRC publication " Report of the Siting Policy Task Force," NUREG-0625.
The Nuclear Regulatory Commission is considering amending its regulations, on " Reactor Site Criteria," 10 CFR Part 100.
Any amendments will reflect the experience gained in evaluation of nuclear power plant sites since the original regulations on siting were published in 1962.
As the first step in this process, the Advance Notice requests comments on seven of the nine recommenda-tions of the Task Force report.
Where appropriate, some of these recommenda-tions are supplemented with comments from the Advisory Committee on Reactor Safeguards (ACRS), with alternative approaches to the recommendations and with questions to focus comment in regulations and in the involvement of the public in this important subject area.
The Commission intends that this rulemaking will be completed expeditiously and in close coordination with other related rulemaking efforts including those involving emergency planning and alternative sites.
Sincerely, Robert 8. Minogue, Director Office of Standards Development
Enclosures:
1.
Advance Notice 2.
Enclosure "E"