ML19289C186
| ML19289C186 | |
| Person / Time | |
|---|---|
| Issue date: | 12/04/1978 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | |
| References | |
| RTR-NUREG-0499, RTR-NUREG-499 7590-01, NUDOCS 7812140338 | |
| Download: ML19289C186 (24) | |
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NRC PUBLIC DOCUMENT ROOM
'CIMPTER I U.S. NUCLEAR REGULATORY COMMISSION INTERIM POLICY STATEMENT GENERIC RULEMAKING TO IMPROVE NUCLEAR POWER PLANT LICENSING AGENCY:
U.S. Nuclear Regulatory Cornission ACTION:
Interim Policy Statement SUMP.ARY:
An interim policy is presen'ted to govern the consideration of preliminary propesals and plans by the Nuclear Regulatory Commission to pursue rulemaking on generic licensing issues as one of several initiatives to improve the effectiveness and efficiency of licensing of nuclear power plants.
Although planning for expanded rulemaking of this nature was initiated with an NRC study group recommendation of June 1977, the present interim statement fully supports Executive Order 12044 of March 23, 1978, requesting improvement of existing and future government regulations so as to be as simple and clear as possible and avoid imposing unnecessary burdens on the economy, on individuals, on public and private organizations, or on State and local governments.
Comments received by February 12, 1979, will be considered before adopting and implementing the final policy and plan for such expanded rulemaking.
DATE:
Comments cue on or before February 12, 1979.
CDRESS:
Written comments or suggesticns for consideration in connection wi tn the proposed Interie Statement en Rulemaking Policy should be 7 81214 0 33 f
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s submitted to the Secretary of '.he Commission, U.S. Nuclear Regulatory Commission, Washington, DC, 20555, Attention-.
Docketing and Service Branch.
FOR FURTHER INFORMATION CONTACT:
Miller B. Spangler, Office of Nuclear Reactor Regulation, Division of Site Safety and Environmental Analysis, U.S. Nuclear Regulate y Commission, Washington, DC, 20555, telephone 301-492-7305.
SUPPLEMENTARY INFORMATION:
The Nuclear Regulatory Ccamission is proposing this interim policy statement as a means of receiving public and industry conment on the interim policy and plans for expanded rulemaking to improve and simplify the licensing process for nuclear power plants.
Ten individual proposals for rulemaking are selected for presentation to illustrate the kinds of generic licensing issues the Commission feels might be treated more effectively by. ulemaking.
The purpose of announcing this interim policy is to obtain comments that will:
help the Commission decice which, if any, of these ten issues should be considered further for ruiemaking; identify other issues suitable for ruiemaking; develop a better perscective as to the likely scope or nature of any proposed ruiemaking on any cf the identified issues; and assist in the development of an overall plan for proceeding with generic rulemakings, especially public comment which would assist in determining relative priorities for each candicate issue fcr rulemaking.
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The NRC recognizes that, in many instances, flexibility is required in the licensing process to accommodate changes in technology and analytical technioues as well as differences in specific design and site character-istics.
However, the NRC also foresees a gain in licensing efficie'ncy and simplification by placing, as appropriate, more of its analysis techniques and decision criteria into rules rather than Regulatory Guides and Standard Review Plans and relying on case-by-case analysis anc litigation.
By treating licensing issues generically, Federal, State, public, and applicant resources coulc be more effectively focused en site-specific and design-specific issues of importance and the NRC's licensing process would be more effective and better uncerstood.
The brief description of the ten potential candicates for rulemaking appended to the following Interim Policy Statement provides only the general character of the intent of the proposed rule.
Further informa-tion regarding these ten issues and procedures for their selection is presented in " Preliminary Statement on General Policy for Rulemaking to Improve Nuclear Power Plant Licensing," NUREG-Oc99.
Single copies are available by writing to the Distribution Services Brancn, Division of Technical Information and Document Control, U. S. Nuclear Regulatory Cermission, Washington, D. C.,
20555.
Tne hRC has no prejucgment and precommitment to the exact nature cf any sucsecuent propose rule anc invites creative contricetive inputs by 6
-a-parties with a desire to aid in imoroving the licensing process through rulemaking.
To aid its decisions on which issues to take to rulemaking and the establishment of schedule priorities, the NRC invites quantitative estimates on cost savings (manpower and financial resources) anticipated to result from generic rulemaking rather than individual case treatment of the issue using examples, as appropriate, from licensing experience to provice hart data on avoidable costs.
These cost estimates should give consideration to the various types of proceedings which may be followed for individual rulemaking actions, namely:
adjudicatory hearings; opportunity for comment, or hybrid hearings (e.g., 5-2 table, GESMO, ACCESS rulemaking).
INTERIM STATEMENT OF POLICY AND PLANS A.
Statement of Purcose On April 20, 1977, the Commission directed that recently completed licensing actions be reviewed by the staff for tne purpose of identify-ing ays to improve the effectiveness of NRC nuclear power plant licens-ing activities.
The Study Group's report, Nuciear Pc-er Plant Licensino:
Goo'ortunities for Imorovement (NUREG-0292, June 1977) presented eleven recommended measures for improving licensing effectiveness.
Recommenda-tien No. 10 of this study (Increasec Use cf Rulemaking) providec the fciio.ing statement suggesting certain casic purpcses of uiemaking.
G "The Study Group recommends that rulemaking should be considered to resolve, or to assist in the resolution of, major issues, which are routinely litigated in individual licensing proceedings.
A system should be established for the continuing identification of major issues that are frequently raised in individual licensing cases, and for which, considering all relevant circumstances, the initiation of rulemaking would improve the overall licensing process."
The Commission, on October 28, 1977, requested the staff to prepare a cacer cefining the issues and the scope of the proposal to make increased use of rulemaking proceedings.
Pursuant to this request, a Steering Comrittee on Reactor Licensing Rulemaking was established with the initial function of developing definitive criteria fcr identifying issues amenable to rulemaking and to recommend issues that should be considered further for rulemaking.
The Commission recognizes that there are potential acvantages to the handling of certain safety and environmental issues by rulemaking, which depend on the specific issue being considered.
These advantages are:
(a) enhance stability and predictability of the licensing process by previding regulatory criteria and requirements in discrete generic areas on matters which are significant in the review anc approval of license app'lications; (b) enhance public understanding and confidence in the integrity of the licensing process by bringing out for public participation inro-tant generic issues which are of concern tc ine agency and to the
- u;1ic; (c) enhance acministrative efficiency in licensir.; oy removir.g.
i, wnole or in car, generic issues 'rce staf" edew anc acjecicatory resciuticn in indivicuai licensing proceedings anc/or oy establisning the importance (or lack of importance) of various safety and environmental issues to the decision process; (d) assist the Commission in resolving complex methodology and policy issues involved in recurring issues in the review and approval of individual licensing applications; and (e) yield an overall savings in the utilization of resources in the licensing process by the utility industry, those of the public whose interest may be affected by the rulemaking, the NRC, and other Feceral, State, and
'ocal governments with an expected improvement in the quality of the decision process.
Accordingly, rulemaking is perceived as an instrument for improving the effectiveness of the licensing process.
Rulemaking would appear to serve the societal purposes reflected in the above acvantages whenever inis precedure would lead to a dispositive generic treatment cf certain safety and environmental issues in a more cost effective manner than the cu* rent approach which treats these issues repetitively for each individual icensing action.
E.
Criteria for Ruiemakino Issues Certain preliminary criteria were develocec oy the Steering Ccmmittee a c utilirec cy ne staff in icentifying cancicate ensironnenta anc sa'ely issues anc evaluating their s / stility fcr rulerst'n; crocecure s.
Eacr candicate issue wili remain uncer consiceration fcr uiemaking if
- *easenably reets each rf !ne IcllO-ing 52ncalcr) Crite*ia
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The issue must be ceneric.
This means ina; the topic.Tust arise f requent.ly in case review and/or at licensing hearings (not necessarily all heacings), with little adced to the state-of-the art and no significant differences in outcome in each instance.
In other worcs, repetitive administrative litigation of the subject appears unproductive.
Such issues might involve broad policy matters which are really not most efficiently adcressed in specific plant licensing procedures, or might involve the establishment of criteria with wnich to mea.sure the acceptability of an analytical or forecasting procedure or the importance of an issue in specific plant licensing procedures.
2.
There must be a likelihood of a useful, cefinitive ruie.
This means that the final rule should reasonably be expected to co one or more of the following:
Arrive at a dispositive finding regarding the generic a.
issue so that the issue would not be addressed at all or in a simplified way in subsequent incivicual licensing cases where threshold or other generic criteria established by rulemaking are met.
Estaciish generic acceptance crite-ia enicr can ther De c.
applied to the issue in suosecuent incivicual licensing cases.
-e-Establish the relative importance cf the generic issue to c.
the decisional process for subsequent individual licensing cases; i.e., criteria to determine the relative signifi-cance of the issue.
d.
Establish analytical criteria or methodology to be utilized in sucsequent individual licensing cases.
While many criteria and methodologies are alreacy in Regulatory Guides and Standard Review Plans, in some instances it might be use#ul to incorporate these in NRC's rules in a more specific form.
If culmination of rulemaking would likely result in ene or more of the above, then this would reduce subsequent controversy, strengthen the bases for NRC licensing cecisions, and im; rove the quality and efficiency of staff review.
3.
There must be a likelihood of a stable rule.
This means that the information base and analytical cr forecasting procedures should be sufficient to reach a reasonatie generic conclusion and should be expected to remain relatively unchanged for some reasonable period of time after implementation of the rule.
These cancidates fcr ulemaking which teet the atete criteria shall have the fellowing value-impact criteria a;;11ec in their evaluation. /
'- :n NRC usage, the meaning of " values" and "imoacts" {nc'.cces external anc intangicle effects as well as internal and cuenti'iacie enes.
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Ineir beneficial values, on balance, shoulc outaeign cne acditional impacts or costs of the licensing process in order to be considered further for rulemaking.
Near-term priorities for the scheduling of action for the accepted candidates for rulemaking will be made principally in accordance with the degree of favorability of benefits over costs anc the level and availability of NRC resources including contract, si e,ervices.
Value Criteria Achievement cf more effective public input and improved public a.
understanding of NRC's analytical procedures and decision criteria i
in treating potential environmental and safety issues in the licensing process for nuclear power plants.
Improvement of the stability and predictability of the licensing b.
process, including the provision of orderly and clear procedures for State-Federal cocperation in treating generic licensing issues.
Accomplishment of an overall savings of manpower and financial re-c.
sources of the NRC, the public, the utility industry, and other local, State, and Federal agencies involved in the nuclear licensing I
process.
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I :act Criteria The short-term increase in dollar costs of the various participants a.
in the rulemaking action, including contractual support.
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The additional impacts (i.e., opportunity costs) of diverting' man-po<-er and other resources to the rulemaking process and away from other productive uses for a temporary period.
C.
Plan for the Develcoment of Rulemakina on Soecific Issues The plan for the development and implementation of rulemaking on specific generic issues involves the following steps:
1.
Identification and description by the NRC staff of candicate issues for generic rulemaking.
Erief descriptions of candidate issues for rulemaking as proposed by the staff are set forth in the Appendix.
2.
Invitation and receipt of ccmments by the utility industry, the public, and other governmental agencies on staff proposed rulemaking issues, including additional sugcestions for rule-making as well as information useful in assessing the scope, benefits, and costs of specific rulemaking issues.
3.
Formalization of rulemaking plans upon receiet of comments and further oevelcoment of it.;iementation strategies and schecules.
Precaration of toecific oroposec ruiemaking on :ne selectec issues in acccrcance with :ne fcrma'.izec cia-
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,2 Preiiri..ary Acoroaches for Treatina RulemaKinc Di'ficulties There would appear to be three basic problems in achieving an effective implementation of rulemaking on generic issues:
(i) achieving effective input from public and industry sources; (ii) schedule conflicts with other NRC staff assignments; and (iii) developing rulec for treating a number of the generic issues that will improve, rather than hinder, cooperative relations with those State accacies performing parallel functions.
In achieving effective input to rulemaking from public and industry sources, particularly on complex issues about which there are a diversity of views, the normal Federal Register Notice procedure of proposed rulemaking will be appropriately supplemented by ?.he use of workshops or conferences.
The preparation of staff papers before and after such workshops could serve as a useful basis for structuring the assimilation of comments and expertise in the development of generic methodological procedures and decision criteria.
In minimizing schedule conflicts with other staff assignments, it is contemolated that only a few of the more comolex and difficult rulemaking actiens would be scheduled in a given calencar year.
The use cf consultants to aic in :ne preparation of background stucies for ruiemating woulc als: be cf assistance in easing schecule conflicts ith staff e#ferts.
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One of the greatest difficulties, however, is ceveio:ing rules for treating a number of the generic issues that will icprove, rather than hinder, cooperative relations with those State agencies performing parallel functions.
Some States have been quite active in assessing the need for and siting of nuclear power plants, while other States are just beginning to get deeply involved.
In addition to varying levels of experience among State agencies are problems arising from differences between States in the form of legal authorities, administrative structures, and olicies and procedures affecting the treatment of licensing issues.
These do not appear to be insurmountable difficulties, however, and the NRC has already begun to develop cooperative agreements in review and hearing efforts with several States in the areas of water-related impacts and neec-for-baseload facility methodology.
Rules ano guidelines can be developed that provide an appropriate blend of flexibility and specific protecural receirements.
State officials can be involved in workshops and conferences to aid in formulating the rules.
Inceed, this rulemaking process concutted at an early date could have a substantial impact on tnose States which are just beginning to formulate licensing review programs, thus making State-Federal cooperation easier to accomplish anc more effective.
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_ APPENDIX DESCRIPTION OF CANDIDATE ISSUES FOR GENERIC RULEMAKING NRC staff efforts have produced the following preliminary identification of candidate issues for generic rulemaking upon which public comment is i nvited: 1/
Future availability and price of uranium - Forecasting the avail-e ability anc price of uranium is a complex, uncertain, and contro-versial issue that often arises in comparing the costs and benefits of preposed nuclear power plants with alternative energy sources.
The subject is highly generic since the future cuticok in the availability and price of uranium is both national and interna-ticnal in analytical content with insignificant variations for case-by-case treatment.
The sources of informaticn are outside the (4RC.
The principal output of rulemaking would be to accept the uncertainties as a given (i.e., not attempt to narrow them) and establish:
(i) criteria regarding availability and costs to 4'~ne termission nas not arrived at any final ;osition as ;c :ne r.a:cre cf ary subsecuent proposed ruie(s) or even as te wnetrer, after receict cf rutlic comment anc further staff develo; ment, any of the ;rc;csec ca,dicates will De pursuec furtne-
- i. -. ce used in reactor facility licensing decisions, and (ii) tnres-holds for review of the rule at a later time to update the criteria for decision making, when warranted by substantial changes in.the information base.
Alternative enerov sources to the nuclear cotion - Alternatives for e
central station electric power generation dealt with in hearings include coal, oil, geothermal, solar, wind, tidal, biomass, and municipal waste.
Their administrative litigation in reactor licens-ing cases is largely generic with repetitive outcomes, making these suitable candidates for rulemaking.
Many of these alternative energy sources have substantial uncertainty regarding their technology, future cost, and market acceptance.
The DOE, NRC, EPRI and other institutions have prepared studies with additional research under-way on alternative energy sources which collectively provide an adequate basis for NRC decisions.
The rulemaking would seek to establish:
(i) criteria to determine wnen new energy sources sn'ould be considered as viable alternatives to a baseload nuclear po-er plant; (ii) criteria to judge when a viable alternative should be judged superior to the proposed nuclear power plant; and (iii) the criteria for any revie. cf the rule at a iater time.
s Need for accine baseioad ceneratinc cacacits - Power systems :ia--irg cy uti'ities, inciucing 'ntra poci sales, invcives anaiysis cf
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. numerous factors to determine the optimal mix by fuel type anc size as well as the timing of baseload generating additions to system capacity.
A wide variety of demand forecasting methodologies are employed whose accuracy is impracticable to demonstrate.
A legion of conservation, co generation, and energy substitution options exist that are often highly speculative as to timing of implementa-tion and their contributive importance.
Experience has demonstrated that economic advantages and benefits of improved fuel mix, in some instances, can be even more persuasive criteria for justifying additional baseicad capacity than need for power analysis which matches demand growth projections and plannet unit additions anc retirements against system reliability requirements.
The possible asymmetry of cost penalties due to overforecasting or underforecast-ing demand appears a fruitful line of research being sponsored by the NRC that would aid in developing generic decision criteria and procedures for dealing with need for baseload facility analysis.
Rulemaking would seek to establish:
(i) criteria by which the a Clicant's demonstration of need can be judged including criteria regarding demand forecasting methodologies, optimal fuel mix, and system econcmics; (ii) generic decision criteria regarding the extent to which the aDplicant's evaluation of need must agree sitt tne NRC's evaluaticn of neec, which inherently consicers forecast-
'r; error and the asymmetry of cost penalties; (i ii) :ne criteria,
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nearings relative to the adequacy of need for baseload accition analyses; and (iv) the degree to which the NRC could utilize previous reviews of State or Federal agencies.
Alternative sitinc metodolecy and information recuirements - Con-e siderations important to the analysis of nuclear power plant siting alternatives vary between regions and even between certain site options within a region.
Moreover, there are a variety of site screening and assessment methodologies in use among utilities which ciffer in their fundamental approach, the types of factors considered, anc the level of information supplied to support the analyses.
The cost of acditional information for the siting analyses must be weighed against expected benefits.
That is to say, a jucgment needs to be made as to whether the cost of the extra information would likely be compensated for by its social value in signifi-cantly recucing the probability that a superior site will not have been~ identified in the screening process or ultimately rejected in the cor.parative analysis because of inacequate or inaccurate sopraisal of acverse or beneficial impacts.
The cnief output of rulemaking would; (i) clarify the rules regarding the concept of "obviously superior'.' as set forth by the Commission in the Seabrook case:1/
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(ii) prescribe rules for establishing criteria regarcing the imple-mentation of the "obviously superior" concept and the kinds and extent of information required so as to achieve an appropriate blend of flexibility and specificity which would be cost effective for different types of licensing / siting situations; and (iii) cevelop a record regarding variations and the relative merits of different site screening and evaluation methodologies and their associated costs, benefits, and uncertainties focusing on a spectrum of historical cases wherein controversial issues arose.
Criteria for assessment of nuclear plant imoacts and miticative measures - Early Site Review (ESR) procedures have increasec atten-tion to site suitability concepts involving the acceptability of environmental anc socioeconomic impacts of nuclear power plants.
Regulatory Guides and Standard Review Plans developed by the NRC as they now exist are often too general in form to estabiish appro-priate specific procedures and decision criteria to make a clear determination that a plant cesign/ siting alternative is acceptable in regarc to certain types of environmen al anc socio-economic impacts without additional mitigative measures, or that certain minor or major citigative modifications are cf reasonable cost when ccr;Ered to the averted or recuce: imoacts.
In the explora;icr cf inese concepts rulemaking wouic:
fi) o ovice a re'.iew cf the tyces
- f issues enctunteret in the iicensir; : : cess ' ct',ing acce;;ac;
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cf impacts with and without mitigative measures in relation to neir importance to the overall licensing decision process; (ii) cevelop acceptance criteria for various kinds of impacts in the construction and operation of nuclear power plants; and (iii) establish the acceptability of costs of mitigative measures to meet these or related criteria.
Generic procedural criteria to define more concretely NRC resconsi-e bility in assessments and decisions recardinc certain water-related imoacts in relation to the statutory authorities of EPA and certittinc States - NRC responsibility in assessments and cecisions regarding water quality and resultant ecological impacts of nuclear power piant construction and operation derives principally from the NEPA of 1969 (PL 91-190) as modified by the Federal Water Pollution Cor. trol Act Amendments of 1972 (PL 92-500) and the Clean Water Act of 1977 (PL 95-217).
The 1975 agreement between EPA and NRC entitled "Second Memorandum of Understanding Regarding Implementation of Certain Nuclear Regulatory Commission and Envircimental Prctection Agency Responsibilities under the Federal Water Pollution Centrol Act and the National Environmental Policy Act of 1959" serves t Orcvide mechanisms for coordinating the res;ective responsit"'ities cf the two agencies.
Des:ite these efforts, suDstantial civersity in interpretation of these rescettive rc'es has teer ce : s: siec a*0T.g a numOer of EPA Regici.S anc among NEC 'icensing Ocarcs in
. their initial cecisions affecting certain water-related issues.
While NRC has no authority to establish in specific terms the roles of the EPA or permitting States in these cooperative licensing review efforts on certain water-related impacts, a greater specificity of NRC's procedures could lead to a substantial improvement in the effectiveness of nuclear power plant licensing actions.
The output of rulemaking would:
(i) develop dispositive rules on procedural criteria for the NRC role in assessments and decisionmaking involving certain water-related impacts of nuclear power plants; and (ii) provice a record through a review of licensing problems in multi-agency cocrdination in dealing with water-related impact issues to establish clearer NRC responsibilities and insights useful to other coccerating agencies to improve the effectiveness cf their cwn regulatory procedures.
NRC would need to maintain cicse coordina-tion with the EPA in the develcpment of any procesed rule.
NEPA cecisien criteria for coeratino license (CL) reviews - Current e
NRC regulations regarding OL licensing review procecures (10 CFR 51.23 e) declare that "a draf t environmental imoact statement prepared in connection with the issuance cf an operating license will cover only matters which ciffer frem or abict reflect new "rfc-r.ation in acditien to tnose matters discusse: in :ne final environmental imoact statement cretare: in cornect".cr with the "sscancE cf the ccrStructicn cer-il
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differentiation in the relevance of incividual ccst-benefit con-siderations to licensing decisions at the OL versus the Construc-tion Permit (CP) stage.
For example, the staff believes the need for constructing new baseload generating capacity, a factor con-sidered in a CP decision, normally is no longer a significant factor in the OL decision because the plant has already been constructed.
The staff believes that in order to be forward-looking, the OL decision should ignore investment costs and the controlling cost-benefit criterion at this stage is whether the operation of a nuclear plant once constructed is a less expensive option for society in terms of incremental system and environmental costs than the use of any ecuivalent baseload capacity available withir the system or the purchase of energy from other utilities in the power pool.
Likewise, construction of new alternative enercy sources and construction of the piant proposed in the application on an alternative site do not appear to be significant to an OL decision.
Also, external and irretrievable impacts on the environment or comT. unity-level socioeconomic effects that have alreacy occurred after having been found acceptable at the time of the CP cecision co not appear to be relevant to an OL decision.
P.ulemakir.; would improve licensing ef fect" enars a: the OL stage througn:
(i) establishing for some cases a clear cif ferer. iation bet-eer i cac issues acmissacle for u ee a; :.e CF a.c :. stages
of licensing decision; and (ii) developing fcr others acceptance criteria as to whether new information on impacts germane to an OL decision are sufficiently significant to sccietal interests to require re review at the OL stage.
Currently, there is under review a petition for rulemaking in this area (PRM-51-4).
While the staff believes that rulemaking in this general area would be productive, this Interim Policy Statement should not be considered as impacting the Ccmmissien's decision relative to the legal and technical merits of the petition.
Occupational radiation excosure control - Analysis cf occupational e
radiaticn exposure data has identified activatec corrosion products (crud) as the principal source of worker exposures at nuclear power plants.
Man-rem exposure, plant down-time, and operating and
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maintenance costs may be substantially increasec without appropriate exposure control of these depositional processes.
The incustry has been exploring methods of reducing occusational radiation exposures due to these sources.
At such time in the future as infermaticn becomes sufficient to justify specific regulatory recuirements in this area, rulemaking could achieve a scecific annual radiation expcsure cesign ocjective for contrei cf occupational radiation ex:cseres ' rom crud builcup, anaitgcus :c 50.3'a for ef'iaent c P.!r:l
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rulemaking surrounding the development cf accitional cesign criteria in Appendix A of Part 5 involving two separate considerations:
(i) crud formation, solution, and deposition, including design criteria for the primary coolant system for decontamination of crud; and (ii) aspects of plant layout and design to reduce occupational radiation exposure from this source in keeping with ALARA criteria in Regulatory Guide 8.8.
Generic radiolooical imoact for normal LWR radionuclice releases -
e Radiological impact estimates are currently preparec through an engineering evaluation of the radioactive waste treatment system that produces an inventory of radionuclides released to the envi-ronment, a calculation of the available atmospheric and hydrologic dilution, and a calculation of the dose to individual receptors in the immediate site environs and to the population within 50 miles of the site and the total United States.
A generic treatment cf these radiological impacts would be appropriate because:
(1) there is a regulatory requirement that ra'dioactive ef fluents result in caiculated doses within 10 CFR Part 50, Appendix I, design coiective values, and (2) technical specifications are imposed on nuclear plants which hold them to or below nese values.
This results in operating criteria that always limit the incact to a value below a specified value.
Tne prc00 sed ruietaking woulc te casec, in ps-t,
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cn a survey of the calculated impacts in environmental statements to determine appropriate ranges of doses for categorizing radio-logical impacts from radionuclide releases.
The upper end of this range of doses would be the Appendix I design objective values.
An empirical study of the relation between observed and calculated impacts would establish a more reliable lower bound for radiological impacts tha'1 that presently calculated and would obviate the need for calculating radiological impacts of normal radionuclide releases for each individual licensing case, Thrr.shold limits for ceneric discositen of cooling tower effects -
e ine potential environmental end socioeconomic effects of cooling to-er operation have raisec contentions at a substantial number of case hearings.
These issues include weather mocification (increased rain, snow, fog, tornadoes and floods), deocsition, interactions of cooling tower operation with other plant effluents (radiciogical and chemical), noise, and aesthetics.
In a sizeable fraction of these cases a detailed examination of these issues in supplemental testimonies supcorts the conclusion that the impacts are of negligible societal importance.
Accordingly, a useful objective of rulemaking wculd be to seek to establish threshoic limits for each octertisi effect cf cociing tower caeration for E -ide variety cf cesigns anc site-speci#ic conditions which, if not exceecec, would be ceemec :
- e '.ccnsecuential to societa; interests
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limits were exceeded, then more detailed assessment would be required for the individual licensing action in lieu of generic disposition.
Dated at Washington, D.C., this 4th day of December 1978.
For the Nuclear Pegulatory Comission l
L-amue' J. Chi.
Secretary of t.
Ccmmission.