ML19296D563
| ML19296D563 | |
| Person / Time | |
|---|---|
| Issue date: | 02/25/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8003050248 | |
| Download: ML19296D563 (53) | |
Text
_., - _ _ _.,
f "*%,
p
/
UNITED STATES N UCLE AR R EG UL ATORY COMMISSION in the m at te r of:
DISCUSSION OF SITING POLICY ISSUES C
PIaee:
Washington, D. C.
Date:
February 2s, 1980 Pages:
1 - 53 INTERNAT1CNAL VERBATIM REPCRTERS. INC.
499 SCUTH CAPITCL STREET. S. W. SUITE 107 WASHINGTON, D. C. 20002 202 484-3550 soouosoz.y.g
=
.A Y o av
,.cz se, I
UNITED STATES 1
2 NUCLEAR REGULATORY COMMISSION
______x A
In the Matter of:
DISCUSSION OF SITING I
5 POLICY ISSUES l
7
- - - - - - - - - - - - - - - -x 3
f 9
10 Room 1130, Eleventh Floor l
1717 H Street, N.W.
11 Washington, D.C.
February 25, 1980 13
- 2 The Commission met, pursuant to notice, for jy presentation of the above-entitled matter, at 10
- 04 a.m.,
j BEFORE:
14
- 7 JOHN F. AHEARNE, CHAIRMAN jg VICTOR GILINSKY, COMMISSIONER RICHARD T. KENNEDY, COMMISSIONER
- 9 PETER A. BRADFORD, C0
- 01ISSIONER
,.0 LEONARD BICKWIT, GENERAL COUNSEL 1
4
=
I 22
{
u
\\
~ -
~3 i
l
% nc v - ~ w rm :=
me $3JrM CAprret. STWs.ET 3. v. WMt '97 l
4
.W o
W 2
paGE N o.
_P _R _O _C.E.E.__D _I_.N _G.S._
2 CHAIRMAN AHEA?.NE:
We come this morning to discuss t
siting policy and the various aspects.
Before wt get started, !
i 4
I'd like to make a couple of comments.
3 First, I want to break at 11:30.
That doesn't mean 6
that I believe we will be finish by 11:30, but I would like to break at 11:30.
If fruitful and my colleagues are agreeable, 7
a we could continue this afternoon, because we have a free 9
spot on the Commission calendar.
10 We have a very major issue facing us, that is the siting policy.
We have two large staff papers on siting jj r
policy.
One on the results of a task force and the other n alternative sites.
We have comments from the Presidential 13 j3 l
Commission and our own special inquiry group.
We have a number 3
of comments over the past months from the staff and a l
8 g
variety of mechanisms indicating the need, the necessity of g
moving on and clarifying siting policy.
My own view was that I believe we have to put out g
for concent either proposed rule or at least a set of alternatives. I had asked Mr. Hsnrahan to put together a strnary of what are the issues before us and that led to a paper from
,1 4
OPE on January 31st.
But, I would like this morning to at least do is to service a =eans to discuss the alternatives 22 and hopefully to lead to an agreement on guidance to the j
,4 staff on the proposed rule.
I recognite that standards is l
I m % % m. % nn. x me SCRtrhe OF?t:2. N. L w. SutTE P i
AY c
^V 3
{
,,,,, c, I
close to ccmpleting an exercise to bring forward to us a proposed rule, but nevertheless, if the Ccmmission could I
reach some agreement on some of these alternative issues 1
we could clarify what we would put out for public comment I
which I think would be useful.
l 4
With that sort of opening remark, first I'll ask 7
my colleagues whether they wish to make any comments and then 3
I'd ask Ed.
?
I Peter?
10 COMMISSIONER BRADFORD:
No.
II CHAIRMAN AREAR'iE:
Ed, I would like to presume that i
I:
we've all read the summary.
I would also like to presume at 1:
least at some stage in the past we went through the various 14 reports, so what I'd like to do is perhaps if you could help i
l IJ us work through the recommendations.
l I4 MR. HANRAHAN:
That was our intention.
The members i
17 of both the Task Force that the Siting Policy Tasks Force as I
e i
18 well as the alternate sites are here to participate in the 19 discussion of each of those issues.
George Sege prepared 20 our memorandum on this and will lead you through that.
i i
II CHAIRMAN AHEAR'iE:
Okay, but rather than leading O
through the whole memorandum I'd rather just focus upon each i
U of the alternatives.
24 MR. HANRAHAN:
Right.
23 CHAIRMAN MIEARNE:
Yeah.
George?
% % vo.w % m x es 33tm GAN 2TutI*. E e. sunt rf e61 L J2EE
~
AY :
av 4
l' 4
ncz se.
f I
MR. SEGE:
Mr. Chairman, the Siting Policy Task I
Force report contains nine recommendations with respect to which Commission guidance in the draft in the proposed rule l
I I
4 would be useful.
I would suggest going down the list of each 3
of the recommendations to solicit your guidance with respect l
5 to each from the recommendations.
7 I guess you know that our significant definitive 3
viewpoints are available for the Co= mission to consider. In 9
addition to the nine recommendations of the task force, there 10 are two other issues which at the end I will suggest to the 11 Commission for consideration and that is the issue of how M:
conservative the siting policy should be and the issue of L:
the retroactive or partial retroactive application of any of 14 the various provisions of the changed siting policy.
IJ Let me turn to recommendation number one, which l
!4 deals with population limits.
The recommendation is in four i
I C'
parts.
The essence of the recommendation is that contrary to I 18 past practice there would be firm numerical limits established 19 for the siting parameters which relate to our population.
l i
l 30 These fira numerical limits would in some cases be uniquely I
1 determined with respect to minimum exclusion distance and t
2:
with respect to planning distance.
But, with respect to 21 population density in the environments of the plant they 24 work according to the Task Force recommendation.
That will U
be determined according to the average population density of l
mex %
- _ : c.
ase W:E4T'M C.AM ff*f2*.1 e. Nrft '87 I'
- a88*e61 &.gast
= AY
= av 5
l 3 ACc NC.
j l
l t
I each region of the country and that would presumably differ i
in different regions of country.
i It is this part of the recommendation of regional i
differences and that basis in overall comparison of nuclear l versus coal risks that is the subjecc of some controversy l
l 6
with different individuals in a Task Force in different 7
offices having different views from the Task Force majority.
3 The fourth part of the recommendation is not 9
independent.
That part cerely says that those calculations I
to as a basis of siting decisions, case-by-case siting decisions,j 11 i
no longer played a previous role, but that is implied by 12 the other three parts of the recommendations.
So, that i
13 decisions by the Commission on what guidance to give to the 14 staff can be concentrated on parts one, two and three.
IJ (Whereupon Commissioner Kennedy arrived at the l
l M
meeting at 10:07).
i 17 CHAIRMAN AHEARNE:
George, OPE's conclusion was to
'8 go for a mixture, isn't that correct?
19 MR. SEGE:
Well, we had obj ections to the -- well, i
20 we agreed with the Task Ebrce on part one and part two.
On i
Il part three we agreed with fixed limits.
We disagreed with i
the regional variation of those fixed limits as proposed by l
the Task ?brce principally on two grounds.
l 24 One is that arguing that these limits should be 2
predicated on the argument that every region of the country l
m % mn wem x
.e smerw cumm. rrasr. t e. sur-t es I
- JJL_: av i
6 l
nacz we.
I should be able to accommodate nuclear plants because otherwise l
coal would be used in those regions to greater detriment to l
i the public health.
We consider that argument to be quite i
i speculative because of the unknowns and the controversies i
surrounding these estimates of overall health and safety 6
risks.
We therefore feel that would be a rather weak and f
7 troublesome basis for establishing these limits.
I 3
There are also other problems that we have.
Principally, the other problem we have is that the establish-9 l
10 ment of different limits for different parts of the country 11 would have an objective of which we approve and which where the desired result is shared by the Task Force majority 13 and ourselves.
But, the practicalities of achieving that ta objective which is that once a finds numerical limit is estab-IJ lished we don't want to encourage proposed sites just barely l
I f4 meeting that limit.
We recognite that one wants to do 17 better where conditions permit doing better.
Of course, j
l 13 in vastly populated regions of the country one may be able j
19 to do better.
20 In our view, the way to test whether one can do Il better and how much better, is via the NEPA type process 2:
of alternative site comparisons.
If good alternatives are 2:
available that have an attractably low population density, i
24 even lower than the maximum acceptable population density 2
then certainly that sort of location should be sought.
- But, i
mrwne m,.m -
- MW "JN JTwEr, t e. gyrry g7
-- u -
I
= AY : av 7
l uca se, l
1 if one establishes limits on the basis of regional variation rather than looking individually frcm fixed regions too large, l one runs into the same problem as having a single limit for A
the country to a lesser excent.
l i
If a fixed region is too small, let's say one for l
l 5
each of the states, then one would have to establish what
{
7 a priori limits which could be more numerous than the number of applications for which case-by-case decisions could be 9
l made.
10 CHAIRMAN AHEARNE:
George, have you had a chance 11 to take a look at the ACRS letter which was written February 12 14th?
i l
13 MR. SEGE:
Yes, sir, I have.
14 CHAIRMAN AHEARNE:
The approach that you had been 13 recommending I thought in the letter in your paper had been l
l 14 to say here is a minimum distance, some sort of criteria that 17 you can't allow a plant to be sited closer than that.
Here's ta some type of envelope that outside of this there's no doubt j
!?
that a plant can be sited and that in the intermediate region i
- 0 that you do all of these calculations.
For example, you do l
- 1 those calculations, you do the alternative site.
22 ACRS seems to be saying that all that's well and 23 good, but what the agency really should do is to try to 24 establish some basic safety level on acceptable safety condition and that any decision we wou.'" make, and I guess this.
m w e.u r.
w, ~ n.e.
me 33tDe CapTCL. ITWTI* E e. Suf71 '87
= AY o av 8
,,c2 y e, 1
is consistent with their comments on the action plan also, f
I 2
any set of decisions, policy, that we do would always be l
^
tested against that.
That would be the fundamental objective.,'
I i
Do you share that? Does that modify your proposal?
MR. SEGE:
I share the view with some serious 6
reservations.
One of my reservations is this, that for 13 7
years now we have had siting policy on the books which has I
become increasingly obsolete and instead is preamble that we 9
don't have much experience in reviewing sites and after we 10 get scoe experience we'll have more definitive standards.
II i
Now, to crrive at some sort of numerical criteria i
for any sort of even approximate quantitative criteria of l
t what constitutes adequate safety and then arrive at apportion 14 ment of that goal among the ingredient decisions between IJ design, quality control, siting, and so on.
That is likely I4 to take quite some time to arrive at with a sole dependability i 17 that is needed.
I8 I don't think that the Commission should delay 19 for any substantial length of time the statement of a siting "O
policy.
If in the course of time after a siting policy is
'I arrived at.one can come closer to the ACRS goal of rationaliz- )
ing policy on the basis of overall risk assessment.
The C
Commission is going to 'oe here and there will be possibiHtiasod
.A making change.
I don't think it is going to be easy to i
'd arrive at quantitative goals let alone rational apportionment.
' wfu,,sa FCsaad. 'a cenaPes 4.-i 6 %
ee 3:3tPM CAN frittr*. L 8.
SWFTE T2 cm, 2 :==
AY
- av 0
..c=
.s c.
l l
l l
1 of those goals, f
i I
CHAI'U!AN AHEARNE:
So, you would continue with your recommendation that you, at least I interpret it as a I
I A
recommendation from OPE that two sets of nationwide numerical 3
limits, upper limit and lower limit and then the intermediate f
6 regions.
i 7
MR. SEGE:
That continues to be our suggestion for 1
the moment although we do attribute greater importance to 9
recognizing the practicalities represented by alternatives 10 inseekinglowerpopulationlevelsthanthemaximumacceptablel 11 one.
If it's practical to establish a diminimous (phonetically 12 spelled) threshold you would go _ iter that and that is l
l 13 desirable but not the e,sential part of what we're recommend-14 ing.
U i
CHAIRMAN AHEARNE:
Diminimous (phonetically spelled) {
M threshold being one beyond which you wouldn't concern yourself !
t U
with populations then.
i I
18 MR. SEGE:
Yes, beyond which we would say that when 19 a population is that low that it doesn't matter anymore what I
l
- 0 t'ae difference is in population level.
Philosophically i
11 we think that is a good approach, but one can.
But, in practice I don't think it's essential to establish the second U
set of limits if difficulties are encountered in establishing I'
it.
2 CHAIPS.AN AHEARNE:
Would someone from the Task Force
%% - v- %
l
-,. m.,n.o. s. m m
- i sn 1-
- w 10 l
= AY
,m %
I like to coccent on this OPE suggested approach which isn't I
really what the Task Force reccenended?
l 1
MR. MOORE:
Yes, I would.
We considered this three l
tier approach that George is talking about and I think the I
thing that led us away from it is that we strongly suspect i
5 that even after we've studied the class nine accident
[
I consequences that when we get ready to sta.s setting popula-3 tion density limits it's going to require judgement.
It's 9
going to be very difficult to decide what the limit ought to 10 be.
But, we think we have to do that.
But, to establish j
II l
two limits such as the diminimous limit and you can't site II if it's above this limit and have the intermediate ground i
l i3 for alternatives.
We really think that will be parsing it i
I4 awfully fine, because it's going to be very difficult to establish one population density and to try to establish two IJ I
I4 it's going to be very difficult.
l I7 COMMISSIONER GILINSKY:
Well, let's see.
You were la going to establish several throughout the count:
, weren't 19 you?
i 20 MR. MOORE:
Yes, but it would be -- the thing we i
j 21 would establish for the regulation would be that a fraction 22 of the average population of the region.
So, it's that 22 number.In arriving at that number that's what we would 24 propose to put in the regulations.
2 CHAIRMAN AHEAR'!E:
What is the rationale that you
%e
- m. :_ < c me 334fbe Capr?'Or 1Tec* g e.
gum *t2
- ^^
3hm A L me
t AY av 11 i
,,c_
ye, i
use against those who say that what you're doing is recommendig 2
different acceptable icvels of safety depending upon the l
t region of the country?
i 1
MR. MOORE:
'4 ell, I think we accept that, that it f
I does provide different levels of risk.
But, aswesaidinthef i
6 report of people who drese to live in those areas for the
{
l 7
various advantages, already accept a higher level of risk.
l l
I 1
Now, that's not the rationale.
The real rationale is that 9
it becomes -- if you exclude nuclear and you do need energy 10 then the alternative which may be worse would be selected.
11 That's the real basis.
12 MR. NORRIS:
Jan Norris, the main thrush behin!
I 13 this --
14 CHAIRMAN AREARNE:
Could you tip that down a little 13 bit?
I4 MR. NORRIS:
The main thrush for these recommenda-i 17 tions was not in fact to assure that nuclear pcwer is 18 available throughout the country, but to assure that there is j
19 a uniform incentive throughout the country to alte nuclear l
t M
power plants in remote areas.
21 If you enly have one limit throughout the country, l
C you have different incentive for remote siting.
So, the i
U principal driving force was to assure that, that there was 24 a uniformity incentive for remote siting, even in the 13 scarcely populated regions of the country.
mnm v
- e. =-rm e.
nin. weu. sr tr. s... wn es
---u~-
.. ~... -. - ~
= AY
- av 12 s e, I
COMMISSIONER BRADFORD:
Let's see.
Is there any i
I argument that the OPE alternative would not preserve that incentive?
1 MR. MOORE:
Oh, can you answer that Jan?
Go l
l 5
ahead, Jan.
l 1
l I
4 MR. NORRIS:
Well, anytime you have a limit that l
l 7
is applicable to the whole country you vary the incentive.
l i
l 5
Whenever you set it you have to decide it would be some kind ofl l
9 an average.
So, the only real place where they would be j
l 10 applicable at some average population density region you l
li would have different incentive for the rest of it.
i We felt that the most fair way of reproaching i
i 10 it recognizing the fact that we do have varying population i
14 densities throughout the country, is to make it flexible.
IJ COMMISSIONER BRADFORD:
But, once you set the l
l 14 criteria for a particular region there's no incentive to i
17 site more remotely than that criterion would require --
18 CHAIRMAN AHEARNE:
In that region.
I I
19 COMMISSIONER BRADFORD:
-- in that region?
i i
20 MR. NORRIS:
That is correc~
l Il CHAIRMAN AHEARNE:
But, I think what Jan's point l
r is Peter, let's say that we set a criteria for New Jersey and i
U so that's a certain number of thousands of people per square 21 mile and if that's now a northeast criteria then that's in 2
an area where there's high density throughout.
t nrfewma rcs.44. V cosaPtas 4 m u :a. :,=C se 3:1m* M iT*G*. L e. sur t s7 e - --
1 a aruss
~.=..
.7
~^:~ ~ ~
AY ay 13 I
Now, if you translate that criteria and put it in I
well let's say Nevada, Arizona, then you could lead to i
bringing it up much closer to population sites.
I think what l
they're saying is that they would rather -- they were proposing that in each region of the country you'd look at 4
the population density so that you would end up being much 7
more restrictive in a lesser populated --
3 COMMISSIONER BRADFORD:
No, I understand that.
But, i 9
! as I understand the OPE proposal --
l CHAIRMAN AHEARNE:
It's nationwide.
10 II COMMISSIONER BRADFORD:
-- it's nationwide.
- But, I2 the upper limit, that is the one beyond which you could cite I:
without question.
It might be very hard to meet anywhere in I4 New Jersey and might have the same affect in remote regions i
13 as the staff proposal.
I l
I4 If I followed your point about NEPA correctly, i
945 you were saying that NEPA should be in any case be used --
j
'8 this is my phrase not yours -- but on a sort of ALARA (phonet-19 ically spelled) basis to urge the process toward the most 20 remote site in any case or it could be used that way?
l Il MR. SEGE:
That is a correct interpretation of our O
view.
i 22 CHAIRMAN AHEARNE:
George, wouldn't your proposal 2*
really in affect -- well let's assume, I think it's reasonable 2
there is a reasonable assumption you may not be able to find t nrftppreA PC,udh '/ C'SA f*as On, c. 'sec I
es e CA N STWEI*,t e.
SurTS '87 I
i samsesecTtue.1
- zumzt
=
AY c av 14 f
% ye, l
I that upper limit?
So there may really be no upper limit s
2 beyond which you would never take population into consideratiorf I
MR. SEGE:
That would be a lower limit.
1 CHAIRMAN AHEARNE:
A lower limit of population 3
and not for distance.
This --
l 6
MR. SEGE:
Yes, that is very possible.
7 CHAIRMAN AHEARNE:
The lower thresholds.
3 MR. SEGE:
We do not press the diminimous threshold.
9 CHAIRMAN AHEARNE:
So, what you would in effect 10
. would have is here is an upper limit of population density II in which you could never site.
For the remaining systems II you would take into account the dose calculations and the IU alternative site affects.
Id MR. SEGE:
In a very crude sort of way we would be IJ what we think primarily in terms of gross regularly apparent l
Id differences rather than calculations where the decision of i
C the calculation out stricks the accuracy of knowledge.
f I8 CHAIRMAN AHEARNE:
That's clearly one never wants I?
to do that, whether it's gross or fine.
.O l
MR. SEGE:
But, let's say just to pick scoe number i
l 21 out of the air, let's say 400 people per square mile becomes l
C f
the absolute national limit and in the particular region l
22 where we are looking there are sites available and 350 2'
people per square mile and 100 people per square mile, 2
differences of that magnitude would be taken into account in IsrTTP*ma h '/CP5AT?w 8N '%
ee En47W CAFTQi. ff*ET*, L e. SJffT :#7 i
t AY av 15 l
,a ye, I
a very real and significant way.
2 MR. ERNST:
I'd like to offer one comment if I might i
on this particular example.
It's my impression that the
+
I 1
T.ask Force and also the alternative sites paper embraces the I
same concept that with that example I think the lower limit 6
would be this hundred, for example.
The only difference 7
! between the two is that we would not accommodate any site 3
above the hundred.
In other words, if you reasonably have I
9 sites in that region of less than a hundred, then we're saying IO you should go there and you shouldn't debate whether you 11 should be at a higher value or not.
COMMISSIONER KENNEDY:
Even though other considera-i3 tions taken into account would perhaps suggest a different I4 balance? You simply wouldn't consider tnose other factors?
]
I!
MR. ERNST:
The numbers that one arrives at I4 would have to be reasonably based.
I think there are some i
i 17 numbers in the Task Force report that perhaps are being 18 keyed upon as too much.
If these are the proposed numbers, 19 I don't think the numbers have been established yet.
20 I guess a personal view and I think the Tisk Ibrce 21 view also is that it's fine to have two sets of criteria established.
But, our intent would be at the lower end and r
U not to argue about the gray area in the middle.
The feeling 24 is that one might be able to establish an upper limit where 2
you think the risk is so great that you should never have a mrm mr =_ t ~e es 2:xtru M JTWEI". L e. SJM '87
AY ay 16 I
=cz se.
i I
sited there.
But, it probably would take a lot of staff l
i I
time and a lot of controversy to establish them and in our i
view you'd never have sites proposed at that high limit.
j i
So, it would be sort of a perhaps a manpower sense in trying l
i I
J to establish them, because our inclination would still be 4
to site at the lower more reasonable limit.
7 COMMISSIONER GILINSKY:
What is the limit that i
I 3
you vary throughout the country or the values for it?
9 MR. MOORE:
It's the population density in different Id rings around the plant.
II COMMISSIONER GILINSKY:
But, that would be a 12 standard for what?
If you were below that you could site i
l C
without any further review?
I' MR. MOORE:
Without any further review of demo-I t!
graphy.
f i
Id COMMISSIONER GILINSKY:
That's what I mean.
l 17 MR. MOORE:
Yes.
Now, it's not just population l
13 density.
It's population density and clustering.
But, they i
19 would be both based on the average population of the region.
i 20 MR. ERNST:
I think the problem before the t
i Il Commission if I might try and express my view on --
l l
COMMISSIONER GILINSKY:
But, let me just pursue U
this point a little further.
How much would the standards vary from the lowest value to the highest value over these 13 four regions of the country?
How would you break that up?
I @ M A4.Y N IM
.O N
me sl3JTM QN ffWtT*, L e.
EJf71 '87
[
m., 2 :. _
4 AY o 4v 17 ucx sc.
I MR. MOORE:
We have really not -- well, we haven't i
looked into that too much.
But, as far as population density i
~
in different regions I think it proba'oly varies by a factor i
i l
of four or five.
Let me see if Len Soffer is here.
- Len, I
e can you answer that?
l l
6 MR. SOFFER:
Let me give you an idea.
I'm Len I
Soffer.
Population density for New Jersey, for example, 9
- is about 900 people per square mile.
New Jersey is the 10 densest populated state in the country.
Population density II i
for the Un:.ted States as an average for the 1970 census was 12 about 60 people per square mile.
In some states, I can't is recall them by name, but states like Nevada, Oregon, the Id population density is on the order of 10 to 20 people per I
'~
i square mile.
So you have variations of anywhere from about i
l 14 10 up to 900 people per square mile on a state-by-state I
region, state-by-state variation.
I8 COMMISSIONER GILINSKY:
So, possibly in variation I9 to areas of magnitude?
20 MR. SOFFER:
Yes.
II COMMISSIONER GILINSKY:
In your standards?
=
MR. MOORE:
Yeah, there could be that.
Yes.
l IU MR. HANRAHAN:
Both proposals here are attempting 2*
to drive at the lowest population densities around the plant.
I think that's what the argument or disagreement is, which
~~
- n m vm e.
w.
x es sottf9e OMTel. ff*Cr?. L *. SWfT1 W or _ i Gg..1. C. 2EEI4
c--.
- 21 : vr 18
,a ne, i
i is the best way to achieve that.
On one hand, you know, i
I i
our suggestion requires really determining some limit beyond I
which one would not site.
I think Mal characterized it as l
A a difficult thing to do.
On the other hand, it requires some compute know-i 4
ledge of future sites in that region as proposed.
We would 7
look at that region to see where future sites might be and then pick that as the criteria for that region.
So it entails 9
some difficulty in knowing what might be suggested as 10 future sites.
I COMMISSIONER GILINSKY-Let'n see, why do you say 11 12 it's difficult to pick a maximum?
f3 MR. ERNST:
I think it would be very -- the maximum 14 number of people now you're talking about, I think it would i.!
be difficult for two reasons.
One, technically you get into 14 a lot of differences of opinion of evacuabilic/ and things of that nature.
But, more importantly, perhaps from the 18 standpoint of a decision criteria is the controversiality of 19 it and the end use of it --
1 20 COMMISSIONEh GILINSKY:
Doesn't the staff apply 21 such a criterion in current reviews or recent reviews?
MR. ERNST:
We typically use the 500.
We say we're l
going to look at alternatives if you trio our 500 criterion.
i 24 I guess it's just a personal judgement perhaps what I think 2
the Task Force judgement that you j us t wouldn' t.
Even if l 6 fM N DM Ve r 4
l
- - ~... -,
.- u -
. AY av 19 I
- ace M C.
i I
you establish them you would still ce encouraging or essen-l I
2 tially demanding sites if reasonably available at areas of lower population.
So, you would never be approaching that I
upper limit.
Once you set the lower limits you'd be striving I
3 for sites at the lower limit.
I l
6 COMMISSIONER GILINSKY:
Well, let's see.
Now 7
! you're saying there's no need for it and it's unworkable.
3 MR. ERNST:
Well, it's not unworkable and against 9
a personal opinion.
If the bottom line of it is going to be 10 l
such that it would never be useful in the decisional process II that you'd be keying on the lower limit anyway, I'm j ust End Tape 1 II wondering about the usefulness of trying to establish it.
i l
rape 2 13 CHAIRMAN AHEARNE:
I guess I'd probably be interested I
14 in putting both as a proposal, both approaches. But, neither of M
them are so clearly good that theyleadtoaneasyapplicationf I
M of something that is clearly right.
They both have problems, l
i i
L-both have advantages.
is MR. HANRAHAN:
I think you need in either case 19 the comparison of alternative sitc.a not just, you know, 20 because it meets a certain criteria that that site is there-I 1
fore fine.
In order to get at the point that both are l
i U
making here about the lower population density, the NEPA U
process should ensure that is brought out and the comparisons 24 made.
MR. MOO RE :
That's the essential difference between
~
t' f orfDNeafMllpasa. VC*eaf*he Ere i va Per.
me p CaN ITwgg*, t e. surft '97 l
t AY av nac
.y e.
20 I
I the two approches.
One is it doesn't involve considering I
f I
alternative sites.
i MR. ERNST.-
Is that really true if you're belcw
(
1 this lower limit?
If the icwer limits were both the same in both their viewpoints, then anything below that limit we f
6 would not consider an alternative.
So, I don't think that I
is the differences in them.
MR. SEGE:
We're not emphasizing the diminimous 9
threshold because that would be so low that there would pre-10 sumably no controversy concerning sites that met that, but 11 CRAIRMAN AHEARNE:
Probably in no sites in the II United States.
!~
I MR. SEGE:
It would have to be exclusionary or --
j 14 i
COMMISSIONER KENNEDY:
Excuse me, George.
I was l!
going to come back to that, because you said something like 14 that much earlier.
I guess I'd like to hear more about why i
II that's so.
18 MR. SEGE:
Why one would not need to consider 19 alternatives if the proposed site has a surrounding population I
20 level below some diminimous level?
Il COMMISSIONER KENNEDY:
I know, we're talking about i
1 on population grounds I assume.
l MR. SEGE:
Yes, en population grounds.
24 COMMISSIONER KENNEDY:
When we say diminimous what 2
does that mean?
I
{ ph / OlFSASta OareaMa N me nw C.AW'CI. ST*EIT.18. surft 'e7 l
e _T Y
t
, AY
- av 21 l
,,,_ 32 I
MR. SEGE:
Well, that the population can be I
considered to be so low that the further safety advantages to be gained by looking for sites with even lower population f
1 A
would be too small to matter in relation to other considera-l 3
tions, if one might take into account in selecting a site.
I 4
We have not really thought that much in terms of specific 7
numbers or diminimous thresholds.
But, that would be the I
i basis for establishing it.
9 In the absence of a formalized threshold presumably i
10 in case-by-case comparisons of alternatives, one could argue 11 in a case that the pcpulation from a poor site is so low that even through an alternative as a still lower population 10 that the difference is too small to have any appreciable 14 significant impact on the comparison.
l COMMISSIONER KENNEDY:
Well, that doesn't quite l
14 get to my question, uhich is if one has arrived at some level 17 in your three tiered notion below which population is no 18 longer an issue whatever that level is, I'm not sure why it 19 follows that whatever there is there would be so few cases l
lC which would arise there that it',s really not a question.
That 21 was the point you made earlier I thought.
It would almost f
2:
never occur anyway.
MR. SEGE:
No, I don't think --
24 COMMISSIONER KENNEDY:
That was the answer to a 2
question that you made.
enwo.or-u,_ x l
es it2tm C.AFP:3.37WEI*,& e.
Sufft '87 I
AY av 22
(
,,,,, c, i
1 CHAIPSUI AREARNE:
That was the same impression I i
l got too.
1 COMMISSIONER KENNEDY:
Yes, I thought that's what i
you answered.
You answered Mr. Bradford's question much f
A I
earlier and I thought that's what you said.
I was trying to i
6 figure out why that was true.
7 MR. SEGE:
No.
The only reservations that I have 3
about formalizing the diminimous threshold is that it could j
I 9
be rather difficult to arrive at the concensus on what that 10 lower level of population would be below which a population j
t 11 difference no longer matters.
In actual cases, that 12 determination could be made on a case-by-case basis.
While 13 it could be helpful to have that threshold and we do advocate I
l t
14
. some attempt to look at the possibility of establishing it.
l 13 While it would be helpful, the essential part of our disagree-l i
I4 ment in connection with part threetheTaskForce'srecommenda-!
17 tion is as Ed put it that we look at alternatives so we can 18 determine how much better than the exclusionary limit it is i
19 practical to do in a particular area on the particular j
i 20 circumstances that you should not say that the exclusionary I
6 21 limit is met then we no longer make an attempt to do substan-l i
22 tially better where circumstances permit.
l It's simply philosophically on this, I think all of 24 us are agreed that they seek the result where people will not 2
try to come in under the wire when exclusionary threshold
( arTUt9aAPCMM. VO'EAPes Os.v r n ! **C l
l es 33tf58 CAN 2TWC. L e.
surft 27 e _^_
Tw a & zassa
=
AY -
av 23 I
nca sc.
i that would then be accrued that we are looking for ways to I
encourage doing better than exclusionary thresholds.
f We submit that a good practical way of doing it is by a NEPA I
type comparison in which population, substantial difference i
3 population density in a role.
l l
5 COMMISSIONER BRADEORD:
Let me ask y u about that.
7 In assuming that a diminimous level could be established, j
doesn't it mean in practice, that is population I take it is 9
sort of a shorthand for an acceptable dose calculation and 10 for a presumed ease in emergency response in an evacuation.
II If somebody came in with a population less than the upper limit, II would you be saying in affect that emergency planning around i
that site could not be a subject of litigation in the 14 hearing?
That is it would be presumed that a population that small was evacuable within whatever limits we wind up setting. !
I' r
I I4 MR. SEGE:
For the diminimous threshold if one is 17 established, that would be the case.
I3 CHAIRMAN AHEARNE:
Easically what your diminimous 19 is, is that population could then no longer be an issue.
l 20 MR. SEGE:
That would be the idea of establishing 21 it.
O COMMISSIONER BRADFORD:
But, not just population f
I C
but the things it stands for, yeah.
24 COMMISSIONER KENNEDY:
Karl, you --
2 MR. GOLLER:
Yes, I'd like to make an observation ene
< mon. %r= x f
de 23stW CAN TTu2I* i e. SW871 '87 h
u
= AY
- av 24 uc2 ye l
I on this three tier approach.
Aside from being very difficult l
2 to accept the two value which has already benn brought out, I would be very concerned that in the end the two values l
would be set at such levels that for the majority l
of cases would be business as usual.
It would be an ad hoc l
I i
case-by-case decision application of accident scenarios, i
I 7
calculation of doses andso on.
That's just what we' re trying l
3 to get away from.
We're trying to make a generic decision 9
that would avoid that.
10 I would also like to suggest focusing on the high li number.
Th. t t is the high density number where actually both 1
proposals, that is the Task Force's and the three tiered 13 approach have the same inherited problem in it.
It would I4 be very useful if the Commission could give some guidance as j
l to whether the intent would be to have that number high IJ i
to enough or low enough or whatever so as not to preclude any i
regions, whatever regions are from the country.
That is l
e l
18 a rather basic policy issue that I think it would very useful i
i 19 to focus on.
COMMISSIONER BRADFORD:
Now, what is really entailed l 0
i II in precluding a region of the country? That is New York C
City is now buying power from northern Canada, obviously U
there are transmission costs in that, but when you talk about f
3 precluding a region of the cour.try you have to be going 2
pretty far to say that ther. was an area so densely populated arrDraia f*CoeA6 # CTSA f'ad 4.-. i n G.
es e CAFTts. ff"urgI*, L g.
surft 's?
e
AY :
av f
y 25
..cz sc I
for so many square miles that one couldn't imaginably site I
a reactor from which power could be transmitted into it.
I
~
MR. GOLLER:
Yes, I think one can imagine that if l
1 you take a region as being the entire northeast of the United 3
States and if you set the population density figure low 6
enough, low enough in this case being of a magnitude that I T
don't think anycne would dismiss, but again it's not that low.
You i
could preclude siting a nuclear plant to the entire northeasterb l
9 United States.
Now the Task Force suggests that not be --
10 COMMISSIONER BRADFORD:
Karl, nobody lives in i
11
- northern Maine, not that I'm advocating making thac the I2 regional.
But, there are a lot of square miles up there with nobody in it.
l I4 MR MOORE:
I think one of the things that we t.!
considered was that if you push as a nuclear plant out so far I
I4 that economics will dictate that the choice would be coal or i
i U
some alternative and we wanted to leave the alternative 18 available.
19 COMMISSIONER BRADFORD:
So, that somewhere in here t
20 I
one is going to have to get into. transmission costs and how t
21 i
they tip the balance between nuclear and coal this year -- of i
20 co ur s e, that will change with coal prices next year and the year atter -- would the standard then have to vary with the 22 price of coal --
13 MR. MOORE:
No, no, sir.
I don't think so.
I think m enine.=~
re j
es s:iuTw curft:n. 3T812*.1 e. sur71 's?
8 eameana*os.1. masa
f
= AY c av 26 l
ycg ye, t
I by tying it to a fraction or percentage of the regional population you take care of that problem.
We did consider i
~
that sort of balance and then we realized that it was such A
a moving target if we tried to do it economically.
It'd l
3 be so complicated that we really felt we should do it on the i
5 basis of --
7 CHAIRMAN AREARNE:
But, your underlying goal is an 3
economic balance goal?
7 MR. MOORE :
I think the underlying goal is a safety to goal that economics certainly would affect.
I 11 DR. SPANGLER:
When you get into trade-offs between i
safety and economic and environmental values, this is a very it complex type of analysis.
When you have long transmission I4 lines you are disturbing the environmental land use to build i'
those transmission lines for one thing.
When you have remote id locations you have a higher capital cost to build the plant 17 because it's harder to attract pecple to commute long la distances to site and delays in building it as well while 19 you're training people af ter you've found you can' t recruit l0 adequate skills.
l i
s There are questions of systems reliability because f
Il the longer you have transmission lines the more down time l
you're going to have in the access of the population centers
[
24 to the transmission.
That is an overwhelming percentage of 2
system reliability outages are due to transmission and not I
-nc ec ~ =
a.c.
ee 23tT%e C.M*TCR. JTRET? E *. WITT '87
I
=_.11 _.:
ncz sc.
27 l
i i
the reactor or the coal fire plant itself.
With regard to 2
hydro (?) this then involves the uncertainties of future international relations in the long-termed guaranteed l
i i
supply.
We explored that very question and we pressed i
Consolidated Edison why didn't they go to that and they gave l
\\
6 us -- I thought some very sobering insights of the complexi-l l
7 ties of dependency on electricity from Canada.
3 The hydropower is going to be very large initially 9
and they won't need as much of that energy in the first 10 place, you know, early on.
Then later on they're going to II as growth occurs they're going to need it.
But, the negotia-tions of long-term contracts is a very problemmatic question.
I I realize that's i
la COMMISSIONER BRADFORD:
I didn't mean to get us into !
l i
i 13 Canadian hydropower, I was just stating that it's possible l
I4 to bring power a great distance --
17 DR. SPANGLER:
It is possible but it has all these 18 other disadvantages that I wanted to bring out at any rate.
19 CHAIRMAN AHEARNE:
I still feel that e.he issues 20 are such that I' d j ust feel a lot more ccafortah'.e with going 21 out with both alternative approaches rather than --
i C
COMMISSIONER KENNEDY:
You mean you're pursuing the i
U rulemaking notion --
l IA CHAIRMAN AHEARNE:
Yes.
l 2
COMMISSIONER KENNEDY:
-- with a different range of
{
t,,er, r - <o or
=xr =, m ' c se sarew eum:n. rrwcx?. s.. surrt of
.ao aarcos, a mm
_.A L :
3v 28 I
alternatives?
I CHAIRMAN AHEARNE:
Yes.
i i
COMMISSIONER KENNEDY:
It seems sensible to me.
l t
I 1
CHAIRMAN AREARNE:
Yeah, I just don't see myself l
J coalescing on that.
I 4
COMMISSIONER BPaDFORD:
John, would you -- I agree 7
with that, but I think it would be important to at least put 3
a range of possible numbers in for comment, because otherwise 9
we're going to be in a situation where we're going to have to 10 turn right back there again for comment on what the numbers li ought to be.
12 CHAIRMAN AREARNE:
Yes.
I3 COMMISSIONER BRADFORD:
So, that it would -- I 14 would agree with taking that step.
But, I think I'd try to 13 develop at least a range of something.
l I
14 CHAIRMAN AREARNE:
Yes.
i I
i 17 MR. ERNST:
Can I offer a philosophical base 18 for numbers?
Maybe one might not have the numbers developed, 19 at least on a philosophical basis.
I don't think we're far i
20 apart at all between OPE and ourselves.
We're saying that 21 NEPA this is a NEPA question.
I think we're j ust talking C
about the mechanics of how one addresses the NEPA question.
.l I
22 One method is to address it generically and 24 establish criteria such that these kinds of impacts do not I
2 weigh heavily on the NEPA scales.
That's basically I think mwn~ w1 e f
me 220te W STwtI*. L e. surft's,
- am.u=ovea.1 :. meia
=r Av c av 99 i
ucz se.
i 1
I the issue.
i i
I think the question is whether or not nuclear plants are sufficiently safe to be sited in major regions of A
the country and we get off on a little bit on the track of l
I talking about criteria rather than the basic policy question.
f I
i 5
COMMISSIONER GILINSKY:
What do you mean by maj or i
7 regions of the country?
i i
3 MR. ERNST:
Well, let's say electric reliability i
9 counselor is if one wants to pick a region.
10 COMMISSIONER BRADFORD:
Maybe I misunderstood this j
i 11 regional approach.
You would be saying that if the density 12 in a particular region taken as a whole exceeded the standard j l
l~
that no plants could be built in that region?
I assume not.
I 14 I assume that you're saying that within -- that you'd want I
l M
to go to various l
i
'4 MR. MOORE:
No, within that region we want to pick l
!7 one that is fractionally lower than the average.
18 MR. ERNST:
There are proposed numbers in the Task 19 Force report and I guess what I'm saying philosophically the 20 basis for it, at least in my view, is that let's first make 21 the decision whether or not it is sufficiently safe to site reactors in a major region of the country.
If that answer is yes, then I would submit that the policy question or policy 24 should be to site as far as reasonably away from people.
'3 COMMISSIONER GILINSKY:
How are you going to e e
- m. =c.: m :,.c
== mum c.wm:n. sr=trr. s.. marrt es
- ae>***G7Cai.1 a 2,ma
= AY c av 30 l
,t I
decide the first question?
f 2
MR. ERNST:
I would work from the outside in.
Take l
t the region you're worried about come in towards pecple until l
}
A you have sufficient other kinds of resources which is water, i
3 land use, sequatic interest, things like that that you have I
5 enough siting options from a resource standpoint that you say 7
I have no need to come in closer to people, because I have 3
enough --
9 COMMISSIONER GILINSKY:
Now, how are going to 10 decide the first question?
11 MR. ERNST:
How safe is safe enough?
Is that the 12 question?
l That is one I don't think we're going to decide i'
through this rulemaking.
That is a different question, really.
IJ COMMISSIONER GILINSKY:
Well, I know, what is it?
I i
'd I mean you're saying if they're safe enouFh to site in a
{
i 17 particular region of the country, how are you going to make l
ta that decision? I mean isn't it a population criterion implied 19 in that?
- o FEL. ERNST-There could be a population question.
l 21 I guess my feeling is that if one from a siting standpoint it 2:
would be nice for everyone to know the ground rules so that 2
you decide the issues generically as to whether or not it's 2A safe enough and then --
^1 CHAIRMAN AHEARNE:
Yes, we11 we're trying to focus
}
,,vo r= vo.w. u., ' c.
.:ue= e.u ma. n. m. s.. u o i
.m-
- - ~ -
= AY av 31 l
8 I
on that.
I MR. ERNST:
Yes.
COMMISSIONER GILINSKY:
Let me ask you something l
?
else.
Is it really the average density in some region of l
I the country that matters here or the -- or let me put it this way, it seems to me it makes a lot of difference what the f
6 I
variability of population densities throughout a region.
You I
3 2ay have a region fairly high average density but that may be j
9 distributed uniformly or it can distributed in a very non-10 uniform manner so that you still have many areas of low II population density which are too far from --
i 12 CHAIRMAN AHEARNE:
Or, you can take a section of IU Arizona and that includes Phoenix and you get a fairly high I4 population density.
IJ COMMISSIOliER GILINSKY:
I'm wondering how that id affects in arriving at these various standards for various I7 parts of the country.
In other words, suppose you pick one I3 standard will you have important affects on siting?
19 MR. MOORE:
Well, it certainly affects us in that l
i 20 picking the fractional population we're going to have to look :
II at what it does to availab 'i y of sites.
Very often you t
I tentioned that there will be,ome variability in population, l
i
~2 but very of ten that population will be clustered along 2*
war.crways where the water is essential for an adequate site.
So, there's really not even though you find a part of a
~
men n r.
_ x
- M "M N.1 e. surf't '87 e m. :.==
^V "V
32 l
pacs sc region has very low population, it just may not be suitable 1
i tor a power plant.
4 i
COMMISSIONER GILINSKY:
So, what you're saying is j
that these average density figures do in scme way tell you I
I roughly what the availability of sites is in the area.
l l
5 MR. MOORE:
I think so, yes.
7 l
CHAIRMAN AHEARNE:
Jan?
3 MR. NORRIS:
I think that the concept of looking 9
at alternatives is fine.
We're not trying to get away frca 10 it.
What we're trying to do is to do it on a generic basis 11 i
rather than to do it on a case-by-case basis.
What the difficulty is on a case-by-case basis on a NEPA process trying If to trading off population density versus other things that i
i I4 fall into NEPA process.
t ~e On a case-by-case basis this is not going to make l
14 f
the siting any bit easier, any better.
The idea that we have I7 was we were trying to incorporate the various things on a la generic basis.
The consequence of Class 9 accidents 19 availability of sites we can look at all of those things in M
a generic fashion in the process of establishing those
(
~I limits.
We're not trying to preclude thoseelementsoh i
E decision-making, but leave it out of the case-by-case process,j r
3 t
because we simply do not have any criteria or any means or any basis for diocriminating among one parameter like dollars for instance against the population which is strictly
~
mwn-r :
- ,.c
=1m. wma. srm.1 a. wm m
.. ~. - _. =. - -
_ _ =. _.
t.AY av 33 l
=*cz sc i
i safety on a case-by-case basis.
i I
CHAIIO!AN AHEAPSE:
Any other cocments?
i l
Karl?
l f
1 MR. GOLLER:
I'd like to point out that the Task I
3 Force approach has inherited a way, a reasonable way to solve 1
i this problem.
The three tier approach I think would be I
7 l
extremely difficult to set that higher limit and the lower 3
limit, extremely difficult.
Those would have to be set up.
9 on the basis of decisions of how many people you would be 10 willing to expose to this risk and how many would not.
11 Whereas with the Task Force approach, you take a i:
region of the country and that is the decision that we made 10 what would constitute a region. Ym'd take a region of the l
14 country, you would start out with the premise that you would l
iJ not preclude a siting of a nuclear power plant in that area.
i I4 Therefore, you set things in exclusionary population limit i
17 on the basis that it would allow with that region some sites. j i
IS That would then force an applicant to pick those sites that 19 would not meet that limit or that region.
Then beyond that,
[
i 20 you would have an additional rule in the alternative sites i
Oi rule that would force him and ourselves then to pick the 2:
best site within that region.
Taking into consider other l
20 matters other than demography in addition to demography.
24 My point is that you have inherent in this a way 2
of solving this problem and the approach being of coming up f
& $WTH wp s 6%
me Sta/TM cap *t:n. ITwitt". S. e. suW '87
.- u
~
..~
AY av 34 I
o maCZ NC.
I with the best possible sites.
You are accepting and again I I
have to come back to the same question I tried to ask before.
)
You are starting with the premise that you will accept the I
siting of nuclear power plants in any region of the country, f
A Therfore, the premise and basis that this whole thing is based.
6 on is that you must set your numbers in such a way that you 7
will permit siting in any region of the country.
t l
COMMISSIONER KENNEDY:
Depending on how one defines 9
the word region that has different implications, Karl.
If I
- o you get a region big enough and the bigger it is in some f
11 areas the more likely you are to be able to make that stick.
MR. GOLLER:
- Yes, i:2 COMMISSIONER KENNEDY:
But, manifestly as you 14 shrink the region if there're going to be a whole lot of 1
i t.!
them you're going to have to have some pretty big numbers.
l l
14 MR. GOLLER:
Yes, sir, very true.
The decision of 1
17 what constitutes a region is all important and this gets
!a back to questions such as the regional director raised I
19 perhaps it should be based on the basis of what is reasonable I i
- c transmission line distances.
i 21 The ACRS also raised this point that the region C
must define O
CHAIRMAN AHEARNE:
Well, the ACRS's point is that l
24 we ought to first try to figure out what the safety require-ment is and then the rest of the data.
'T *.&*A'.W "u n ?
am
~ ~'
AY =
av 4
35 I
ncz sc I
i I
I COMMISSIONER KENNEDY-ACRS is essentially saying I
I they're not separable questions, isn't that correct?
~
CHAIRMAN AHEARNE:
Yeah.
i I
4 DR. SPANGLER:
Now, there's another lying philoso-ohy here that I think needs to be sharpened.
Mr. Denton at i
6 a meeting of the risk assessment symposium we had suggest 7
that a criterion of how safe is safe enough for nuclear might 3
be that it should be some X margin or X ratio safer than 9
coal.
If we don't start with that basis on the social 10 acceptability of risk and we look at decision criteria one II at a time which in the siting policy seems to do but, on the overall this was debated in terms of a whole pattern of k
C distant related variables.
I4 But, taking them up one at a time you say let's j
IJ put the utility under pressure to either define sites in 16 less populated areas.
We say let's define regionality in I7 a broad sense.
The upshot of all of these kinds ot pressures i i
I ta could very well be if we don't keep our eye on the goal of t
I?
some criteria such as Mr. Denton suggested for how safe is j
20 safe enough.
The upshot of it is is that the utilities
- t will just not offer nuclear.
l i
U Now, that in the eyes of many people will not be U
bad.
I mean they will cheer that.
On the hand, realisticall'.
2' the imminent danger to safety and health of both the 2
coal and the nuclear cycle risk are in the vacinity of the P
W PM O@c 5%
n aut M CAMTTE. N. L e. Wr?"C '77
.=
ams.
. =... ~
=:- ~ ~
AY -
av t
36 i
~
asaz nc.
i t
plants.
A high percentage of coal are close by.
I don't l
think people commonly appreciate this, but one might ought to i
t have a remote siting policy for coal as well.
But, we don't i
I 1
have the symmetry of approaches in how safe is safe enough l
3 and the decisionmaking criteria if you really want l
tc serve l
6 the public interest, I think you have to take that kind of 7
systems view.
The Report particularly recommended or 3
made the statement I should say first of all that the ultimate 9
responsibility for deciding how safe is safe enough with the 10 social acceptability of risk should lie with the Congress 11 and the President.
I wholeheartedly agree with that.
- But, 12 then it went on to make I think additional sensible statement C
that NRC should facilitate this kind of analysis.
i 14 I think~'these kind of siting policy deliberations 15 are one of the key instruments in elevating to public -- you I
M know we talk about things being very difficult and they are l
17 and very controversal.
We're not going to have any solution 18 to process at all if we don't accept the challenge of getting 19 into the difficult and controversial things.
20 I don't know that we at this time have to decide U
how the outccme of the debate will be.
I think we need to i
get this sensibly in front of the public and start to debate so we can get on with what the Commission i
recommended that we do about this social acceptability of 2
2 risk.
I stTUHu.*acruk (Ursaf=es be s
- a. M ape 9JuTM f. AFT"l2. sTuc*.1 e. s#Tt 'O gaswomcTCus J. - man
AY.:
37 I
- *c=
.w e.
^'
I COMMISSIONER GILINSKY:
Where do we take our estimates of the risks of electricity generation for coal?
l DR. SPANGLER:
We take them frca the literature i
i broadly.
Rather than generate all of the information in-house j 3
the BEIR Committee and of course now we have the National i
l i
4 Academy of Science Study of energy and transition and they 7
have taken some of the rasma and data and multiplied it by i
3 a leve-1 fact.
I think it was 500.
They used the upper i
9 limit of comparison, you know, since there is a range of 10 uncertainty of safety and health impacts for coal and nuclear II they have taken the upper bound of this uncertainty and I2 compared the two and they concluded that nuclear looked l
l 0
better than coal.
But, I would like to point attention to going t'
beyond just safety and health again.
The State of New l
1 I4 York, Governor Carey as we know was very negative about I
nuclear and still is in many ways.
But, there was a recent I3 newspaper announcement --
I9 CHAIRMAN AHEARNE:
Yeah, let's not get too far.
20 DR. SPANGLER:
I want to call attention to the 21 acid rain problem of nuclear which is a big political issue O
CHAIRMAN AHEARNE:
A pull.
[
2d DR. SPANGLER:
-- in New York.
-a COMMISSIONER KENNEDY:
Also has scmething to do
~
m % vo.m 3 _ _ :c, M 23JTM M IT*EI?, i e, sterft c e:
m1 ma
AY av
=
38 l
= ace sc.
j t
I with how much of that power we're going to get from Quebec.
2 CHAIRMAN AREARNE:
Yeah.
What I'd like to get l
l t
back to though is --
r r
A COMMISSIONER GILINSKY:
No, but let me just pursue 3
that one question for a minute.
Is there some set of numbers l
6 or range of numbers that you have fixed on as being one that l
7 you would accept for the risks of coal use?
3 DR. SPANGLER:
Well, we have not accepted this.
9 COMMISSIONER GILINSKY:
Or that it's implicit in to l
your approach.
l DR. SPANGLER:
We have not settled upon a specific 11 i
I:
number.
We j ust generically compared the two and conclude I:
that nuclear is much safer than coal.
We can have a la qualitative standard or judgement as well as a quantitative In fact, when the numbers are so diverse the quantitative 13 one.
te numbers that appear in the literature scientific values l
17 are so broad, a qualitative statement I think is just about ta as good as a quantitative statement in many respects.
19 COMh1SSIONER GILINSKY:
You base that qualitative
- o judgement specifically on the studies that you've mentioned?
21 Is that something that the Task Force agrees on?
MR. MOORE:
Yes, we looked at a number of studies l
22 on coal and the comparisons and while it's a broad range I
i 2A it looked like that either nuclear was safer or they were 2
about the same.
Most of the indicate nuclear was safer.
%% vo T.
- c.
se 1CEtm CAFTQt. 37ptr, 3, s.
surft :47 e-u -
AY e av
=
39 i
,am COMMISSIONER GILISSKY:
Does it matter to you i
whether they're about the same or safer?
l' i
MR. MOORE:
Well, when there's that muchuncertaintyj t
COMMISSIONER GILINSKY:
What I'm trying to under-6 stand is what underlies your recommendations?
What are the I
I 7
assumptions that you're making.
I MR. MOORE:
Oh, okay.
9 COMMISSIONER BRADFORD:
One other question.
Are to these studies that you take you back into the coal mine on 11 the one hand and the uranium mill on the other?
Or, do they focus just on the two plants?
12 MR. MOORE:
I believe they cover the full cycle.
ta DR. SPANGLER:
Only cover the full spectrum --
IJ CHAIRMAN AREARNE.
Full cycle.
id DR. SPANGLER:
Full spectrum and transportation l
17 included and waste management and all of that.
13 COMMISSIONER BRADFORD:
Well, for siting purposes 19 though is that -- okay.
It's useful for some but not all 20 of what we're talking about.
21 DR. SPANGLER:
Yeah.
1:
MR. MOORE:
It's useful when you --
l I
DR. SPANGLER:
The bulk of it is really close 24 into the place where the electrity generates, both for 2
nuclear cycle and the high percentage as you look at the D
U V7 IW ee 23JTD. f. AFT"2. STM1*. t e. RJf71 '87
AY
- av nacz sc.
'A I
r smas (phonetically spelled) and data and other data on i
this subject.
The highest proportion of nuclear risk is l
l in close to the plant site, not the waste management storage A
or the mining and all and transportation.
The same is true j
fer coal.
6 COMMISSIONER GILINSKY:
Is that true for coal, too?
I l
7 DR. SPANGLER:
What's that?
3 COMMISSIONER GILINSKY:
The mining accidents 9
being a small fraction of the total.
I 10 DR. SPANGLER:
Yes, for both coal and nuclear, 11 Although, mining accidents for coal because of the large 10 volume of material are certainly much alike.
1:
But, there's one other aspect of this,is the forward 14 looking.
We're not stuck with any of the numbers for coal 15 and nuclear.
Using historical data, you know, of social 14 acceptability of risk is one thing, but looking ahead toward i
I 17 improvements is quite another thing.
That's particularly 13 important because of Three Mile Island for nuclear.
19 MR. MOORE:
Commissioner Gilinsky let me -- your 20 question was is it critical whether you think nuclear is Il considerably safe or about the same.
I think it's not when O
you're considering siting decisions and the avoidance of O
avoiding precluding nuclear.
I think if the average or tne IA reports you read indicate they're about the same level of 2
safety but there's a broad range of uncertainty, I think that m g;stTW Cw"tA ITWC*, L 8 EM '87
t AY av 41 l
,,c=
y e, that would still lead you to the dacision that you don't want j
to preclude it from the large region.
j
'MISSIONER GILINSKY:
But, underlying your recommendation is the assumption or conclusion that nuclear A
energy is at least as safe or approximately safe as coal?
l 6
MR. MOORE:
Yes, sir.
l 7
COMMISSIONER GILINSKY:
In other words, just in terms of the affects in the vacinity of the plant itself?
9 MR. MOORE:
Correct, sir.
10 MR. ERNST:
That is a consideration I think.
- But,
[
11 I don't think it is extremely important.
CHAIRMAN AHEARNE:
Well, ithastobeafundamental--l I
13 COMMMISSIONER GILINSKY:
I would think --
14 MR. ERNST:
I think one has to determine whether t!
or not reactors can be safely safe reasonably sited so --
14 CHAIRMAN AHEARNE:
Well, but that's a different 17 approach and there's one approach that says which I thought 13 was the.ACRS approach, which says let us establish what is i
19 a fundamental level of acceptabla safety.
Once having estab-i
- 0 lished that, then you look in any region and say is that l
or I
21 is that not met.
That's one approach.
The other approach is what Dr. Karl Goller was describing is the belief that you do not want to exclude 24 from any region of the country the ability to site a nuclear
'J plant in comparison to a coal plant.
There clearly has their i
lse.W1'*Creas. 4 DPRa f'*ee O, -e i m.r-a l **C.
s me SOWne M STmEI*. L W.
Surft it!
42 I
AY av
=
,,a m
I fundamental assumption of the relative risk of coal and I
- nuclear, I
MR. ERNST:
Yes.
f i
CHAIRMAN AHEARNE:
Those are really too different.
f I
I I
COMMISSIONER GILINSKY-Beyond that is the con-t t
i 4
clusion that a reasonable standard for nuclear safety is j
i 7
that it be no worse than the alternative which you take to j
l 3
be coal.
I think in most cases would be.
Now, that's not
?
the only standard one can pick.
10 MR. ERNST:
I think that's what I was driving i
li at.
C MR. SOFFER: It's a practical matter one has to O
arrive at some limit and some people on the staff have suggested a definition of how safe is safe enough by saying f
I4 I!
that a nuclear option should be scoe factor X as safe as the i
14 next best alternative.
I 17 COMMISSIONER KENNEDY-As safe or safer than?
l 13 MR. NORRIS:
Safer than.
19 MR. sopyggi As safe or safer than my has l
20 to be safer than the next best alternative, whatever that 21 alternative may be.
In some area it may be hydro, in some i
C area it maybe oil and some areas may be coal.
O CHAIREUI AHEAR'IE :
Well, I still believe we ought 24 to go after both approaches.
2 MR. BICKWIT-In the advance notice?
-r-wr-wrm %
scimee.4em a fr*tr. t e. wrr e7
t
. av 3
,v 43 i
,,cz se, CHAIRMAN AHEARNE:
Yes, because I don't see any way of resolving and I would agree with Peter.
We ought to try
[
i l
to put in some numbers because otherwise it tends to be to A
theoretical discussion without any practical application.
What people are going to be most concerned with they start 4
looking at this is what does it mean?
What does it end up I
T meaning in practice?
3 Practically speaking, what regions of the country 9
are now foreclosed from siting plants or what regions of i
to the country are not acceptable to teeting it in siting l
11 plants?
i:
MR. SEGE:
Mr. Chairman, it might be appropriate l
l 1:1 to ask Karl as a representative of standards whether it would 14 be practical to have any sort of numbers in the advance l
i 13 notice as distinguished from the proposed rule which is l
!4 still maybe six months.
The advance notice would merely i
17 ask for public comment on the Siting Policy Task Force's i
ta report and possibly alternative recommendations have been 19 made.
But, the development of numbers my understanding is l
- o not so close that they could be put into the advance notice i
- 1 without substantially delaying it.
You may wish to ask f
Karl Goller what the timing element is.
l CHAIRMAN AREARNE:
Karl?
f
- A MR. GOLLER:
George has put his finger on a very
'J valid point to enlarge the advance notice even to this extent m ec,.n1-uv n nrws x ase p =!.AN ffWEE*. L 4.
9JffE 87
r
= Av c '-
44 3.cz se.
n I
would be difficult.
I'm not prepared to say what additional time it's going to add, but it would certainly lie in the j
t scope of the advance notice.
There remains to be seen what j
A other points like this might come out of this at the Commission meeting this morning.
I i
4 I would suggest that we keep the advance notice 7
relatively simple limiting it to the Task Force recommenda-j 3
tions which of course any comment you could open the scope to 9
whatever extent you deem appropriate.
l 10 CHAIRMAN AREARNE:
Well, at least from my point 11 of view I w,uld suggest that we put off the advance notice whatever we conclude, the Commission concludes in the theory 1:
that we have been hearing for the last many months the la Commission ought to involve itself mure heavily in policy i.!
making.
I I4 MR. GOLLER: Splendid.
j i
!7 CRAIRMAN AHEARSE:
Yes, thank you.
l
!3 But, to get to George's specific point though is l
19 the time that it would take you to develop numbers to put 20 in.
21 MR. MOORE :
Well, it depends on how much you want I
these numbers to mean.
Certainly our intent was to study i
a range of numbers with regard to risks and with regard to i
24 how the siting options got narrowed down.
Now to do that l
15 will take some time.
Now, one could threw a range of numbers
- %om.--x l
om, mmx. n ut.
.. =m 4, I
m h.
Ne i
, AY
- av 45
,,,; y e, m
I and ask for sort o f a vo ting, but I'm not sure how much the i
numbers by themselves would mean.
I think you'd like to l
know a number and how that restricts siting and some idea of l
A what that number compared to another has to do with risks.
l 3
MR. ERNST:
There are some things in the public 4
record right now and I don't know how much we could draw on 7
it.
For example, the site survey that was completed four 3
years ago had the entire country mapped out down to I think 9
200 people, affectively 200 people per square mile, and showed to the regions of country left over.
n 11 The big problem with numerical numbers I think was l
10 what Ross was aiming at is it's fine to develop numbers and 10 come up with areas where you have less people in that but 14 you don't have other half of the equation.
Namely, the l
l I'
reasonable sites left over from a resource standpoint.
Now I4 the site survey has done that.
So, there's something in the 17 record at least in a general way of resources and population IS
. density.
I 19 CHAIRMAN AHEARNE:
Anyone have any thoughts about j
20 the use of numbers?
11 COMMISSIONER BRADFORD:
Numbers versus other kinds?
2:
I would be inclined I think to try and get at least some O
rough response in terms of numbers whether we put them in l
- A or whether we just ask commenters to suggest numerical U
standards, because it seems to me that the exercises in some
!strtposarm Vowsaf'ne 41.F:, gruel ImmC me s:t.rfbe wa'*ts. N. L e. strt a, easessa.m a
- AY t
- ay 46 l
,,a w,
F.
I ways is a fairly empty one if that isn't done.
Let me understand, though, what is the date assuming that obviously it won't happen this morning, but assuming enat l
sometime pretty soon we work our way through the recommenda-i J
tions and authorize you go out with an advance notice, when I
I 4
would you anticipate the rule being in place?
i I
T MR. MOORE:
Jan will get the schedule on that.
3 MR. GOLLER:
By October the way it looks right now.
9 ComIISSIONER BRADFORD:
Wait a minute I proposed I
'O those rules I mean the --
i 11 MR. GOLLER:
Those rules that are formed.
I:
COMMISSIONER BRADFORD: What does that leave you l
1 M
for having the rule in place ?
14 COMMISSIONER KENNEDY.
A year or more.
j 15 MR. GOLLER:
It might depend on what kind of a 14 hearing situation you got in but, probably a year following 17 that.
IS CHAIRMAN AHEARNE:
So, something like fall of '81?
I 19 MR. GOLLER:
right.
l 20 COMMISSIONER KENNEDY:
That would be an optimistic 21 l
guess I would think, Karl, maybe.
l O
MR. GOLLER:
Also the question we must be sure i
O we're talking about the same thing.
These estimates are I
24 based on following up on most of the recommendations of the
~5 Task Force which are aimed primarily at demographic
(@
[ h N OG b7 YW N
se e car *CI fTwcr" 3. e sur?T '97 I
= AY : av 47
..cz sc n
t considerations with a few exceptiens.
The distance for
~
certain hazardous activities being also included this would i
~
I not not get into the question of grandfathering, application j
of these new requirements to existing sites which could l
3 considerably extend the time.
6 CHAIRMAN AREARNE:
Those are some of the points I
that I expected we're going to get to if not -- we'recertainlyl 3
not this morning but maybe this afternoon which our OPE 9
has raised that specific issue about the application to 10 either both existing sites, sites under construction, that II sort of thing.
I2 MR. GOLLER:
The advance notice -- well, when it I3 comes to the Commission will have inherent in affect questions I4 that you could focus on.
It would be presented as an i
IJ option whether you want to limit this additional effort Id to the area encompassed by the Task Force recommendations I
t, or whether you want to include in it these other broader I8 questions of siting.
19 COMMISSIONER KENNEDY:
Do you think the grand-I
.C fathering question be it as to s.ites under construction or i
i I
.I operating sites can be avoided?
It would seem to me that i
C you would be hard pressed to develop a rationale for not U
somehow contemplating whatever the rule said in respect to i
3 the real world as it now exists.
MR. COLLER:
It can not be avoided ultimately, t
i nfTTRmafth /UPSAT*3A O{r e s km -N I
ao scn/Tse Cur *Ca. :T71*U*, L e.
Suf71 "37
aLc nr naz sc.
69 I
Dr. Kennedy, buc you could go ahead and establish siting I
criteria for new sites.
Setting aside the question of how those will be applied to existing sites.
I i
i CHAIRMAN AHEARNE:
I suspect that if we have to I
set aside ene versus the other we would end up having to l
l 6
set aside siting criteria for sites.
In any event I would 7
propose that we incorporate in the advance notice the OPE l
1 1
3 alternative.
If we can't put any numbers in it at least 7
pick up Commissioner Bradford's proposal to ask for comments l
10 on numbers.
II I
MR. GOLLER:
We could certainly incorporate l'
typical numbers or example numbers provided that we don't I
i i
I2 have to provide any great basis for those paricular numbers.
14 I think that would be quite appropriate and --
i M
l COMMISSIONER KENNEDY:
Yeah, so long as the tenta-I'6 l
tive or provisional nature of those numbers was clearly noted, I
U it would seem to me that that would at least give commenters 18 some sort of ball park within which to focus.
It would be 19 help ful.
20 MR. GOLLER:
I would go even further not even call 11 a tentative or~ provisional rather numbers as examples or
~.
possible --
l COMMISSIONER KENNEDY:
Yeah, without status, i
MR. GOLLER:
Yes, exactly.
COMMISSIONER 3RADFORD:
Let's see, one of the points
{ 6 FC54et 7 OPEA 5 Sd ' as-r i m 4 as SOUTW CAMP 3. 2TecT, L e. zJrTE :g7 f
e%.
4 r
= AY o av 49 ucg y e, I
i 6
i in the separate staff used earlier as the possibility of
{
i having numbers of that sort without having them become the I
numbers which everyone takes to be serious.
You're saying f
I A
then that you feel that as long as one puts the right words l
I around the numbers you can avoid their becoming a distraction l
4 of that sort?
I 7
MR. GOLLER:
That would be the intent.
Perhaps I
we would go even a step further rather than a particular 9
i number indicate a range of numbers for the high and the low l
10 numbers.
I think we could certainly bracket both numbers.
j i
II CHAIRMAN AHEARNE:
All right.
George, why don't 12 you try to at least briefly get into recommendation two.
!3 MR. SEGE:
I assume that parts one and two the 14 Ccemission didn't have any problem with under recommendation 13 one.
14 CHAIRMAN AHEAR'iE:
Pardon me.
17 MR. SEGE:
I assume that the Commission didn't have la any problem with parts one and two of recommendation one.
19 CHAIRMAN AHEARNE:
I think that's correct.
t 20 MR. SEGE:
Okay, well recommendation two would I
21 establish fixed minimum stand off distancas for various i
12 types of natural and man-made hazards.
Seven specific hazards are identified as candidates for establishing those 24 minimum stand off distances.
Unlike with recommendation one the stand off l
~
- r w -m.= - x l
me e CAFTCI. fres27. L 4. EurTE '87
.= = +, > - -
, AY o av 50 2.cz se, l
~
i distance recommendation is accompanied by some specific numbers that t,he Task Force suggest for consideration as i,
those stand off distances.
So, here the Ccamission has the j
4 option of deciding if priniple that stand off distances are 3
a good idea as part of the siting rule and you could also 6
decide whether the seven particular hacards are appropriately 7
selected as the right things to a stand off distance frcm a
and further you could decide whether the particular numbers l
9 that the Task Force report includes are the numbers that you g
feel comfortable with.
i Hereto, there is a differing view on a part of 11 the recommendation that is that OPE has expressed the view i
g i
that after these minimum stand off distarces are met that g
could quite often still be incentive for not being right on g
~
the verge of those distances and that consideration of what g
alternatives are available could play a role in connection g
l.
with cne of the specific hacards which is dams, state programs,'
g, and OPE raised the issue that establishing a single minimum
,3 i
stand off distance maybe programmatic in the case of dams because one has to consider such things as televasion differences, intervening topography and much larger of
,1 A
smaller distance is made depending on the factors be I
appropriate.
CHAIRMAN AEEAR'iE:
The impression I had on this 24 i
that is was -- that at least, for example, raising the issue i
3 i
t INTEMpeAMoreA4. '/E*WADhe Ear e i n lhC
AY av pacz.sc.
E' 1
on the dam these are points that similarly you would expect l
i 2
to come back in the public comment cycle.
- But, you're also I
l however, raising the two or three tiered approach to plot here as you had in the previous population.
i 5
MR. SEGE:
That is correct 3
CHAIRMAN AHEAFlIE:
So, I assume that many of the 1
7 similar arguments come back on this cycle also.
The diffi-i l
culty of establishing a diminimous and how you set 3
up 9
requirements, et cetera.
9 MR. SEGE:
But, principally that is the issue of whether a single number can provide an adequate policy 3;
g whether if an airport of a certain description has to be a certain number of miles away whether one wants to disregard g
the merit of having a site that is even further away than g
that.
COMMISSIONER KENNEDY:
Well, I thought that the views that the ACRS expressed here were sensible additions.
l They suggested adding L figi (phonetically spelled) terminals as there's cargo on rivers.
I'm not sure where this would t
apply, but it might well because there's increased interest
,0 in navigation on rivers.
That navigation is probably to a i
large extent, certainly in a maj or extent, would be oil.
i MR. MOORE:
Well, Commissioner Kennedy, the Task i
l Force did consider that and didn't believe that we could set
- 4 i
stand off distances.
We felt that that was one we would i
t rc, 6 vo um acoerm x 3
= AY :
a'i 5?
P ACZ NC.
probably have to continue considering on an ad hoc basis because you've got to be near water and putting a stand off I
distance just didn't seem to be a practical way,n A
transportation.
5 COMMISSIONER KENNEDY:
How about the stand off 6
distances between nuclear plants which the aCRS recommended?
7 MR. MOORE:
I think that's one we'll want to 3
consider.
CHAIRMAN AHEARNE:
By consider do you mean adding?
9 i
10 COMMISSIONER KENNEDY:
Add to the list for j
r purposes of comment?
1 CHAIRMAN AHEt.RNE:
I would think so.
2 i
i
- 3 MR. MOORE
Yes, yes, absolutely.
14 MR. CRILL:
Dick Grill of Standards Development.
g I think I can explain to the Ccmaission the format which currently the advance notice proposed rulemaking has.
That is to put off for public comments seven of the nine recommendations in the Task Force report and then appended to those are additional questions.
For example, on this reccmmer.dation two an l
,c additional question would be is the list inclusive enough.
,1 Also appended will be some of those of questions that will be raised the ACRS.
But, that will be the format as you 22 I
will see when it goes rotten, i
CHAIRMAN AREARNE:
I would suggest that perhaps l
tenm vmsana. Mocartm. %
er
, AY : av l
7$cz NC-
}
t you could incorporate those a little bit more directly.
I MR. GRILL:
Except, sir, that the Task Force report that the advance notice is directed at the recommenda-i tions of the Task Force.
Those are included in here.
Additions I
would be, you know --
t 5
CHAIRMMI AHEARNE:
But, I think it would feasible.
i 7
MR. ERNST:
I have one question, sir.
I don't s
know how much we'll get involved in the alternative site i
paper itself, but my understanding of the format of the 9
i 10 proposed rulemaking, the proposal for comment does not it address alternative sites --
CHAIRMAN AHEARNE:
It may by the time I
I 13 this arternoon.
i 14 MR. ERNST:
Fine.
I 33 CHAIRMAN AREARNE:
I've proposed that we stop now 16 as we will cover from 3 to 4:30 this subject again.
77 (Whereupon the hearing adjourned at 11:28 a.m.)
la 19 20 I
- 1 l
4 Il I
t
- 1 enc. vo n- %,
- c
'o UNITED STATES
[ h,, [~',i NUCLEAR REGULATORY COMMISSION
- c4
- E WASHlfdCTOPJ, D. C. 20555 s.
E
...../
January 31,1980 (Revised February 7,1980)
MEMORANDUM FOR:
Chairman Ahearne Commissioner Gilinsky Commissioner Kennedy Commissioner Hendrie Commissioner Bradford FROM:
Edward J. Hanraha
SUBJECT:
DECISION MEMORANDUM ON SITING POLICY ISSUES (SECY-79-493 AND SECY-}9-431)
CONTENTS:
Pace 1.
INTRODUCTION 2
1.1 Purpose and Scope
of this Memorandum 2
1.2 Where Things Stand 2
2.
SITING POLICY (SECY-79-493) 3 2.1 General 3
2.2 The Nine Reconrnendations 4
2.3 Other Needed Guidance 10 2.4 Procedural Considerations 13 3.
ALTERNATIVE SITES RULE (SECY-79-481) 15 3.1 Relation to General Siting Policy 15 3.2 Safety Issues in Site Comparisons 15 3.3 Disposition of the Proposed Rule 16 4.
NEXT STEPS 16
'~
Contact:
George Sege, CPE 63-43302
Commissien -
1.
INTRODUCTION
1.1 Purpose and Scope
of this Memorandum This memorandum was prepared in response to the Chairman's request for a summary of the principal siting policy issues that are now before the Commission for decision, in order to provide a framework for Commission action.
The memorandum recapitulates the major issues and key options and arguments, and includes dacision checklists.
This memo is intended for use in conjunction with the referenced documents, wnicn contain fuller exposition and alscussion of,tne issues.
1.2 Where Things Stand Two Commissioner Action papers on siting are new before you:
SECY-79-493, Report of the Siting Policy Task Force, 8/16/79 SECY-79-481, Proposed Amendments to 10 CFR Part 51, " Licensing and Regulatory Policy and Procedures for Envire, mental Protection,"
Evaluation of Alternative Sites for Nuclear 3enerating Stations Under NEPA, 8/10/79.
You have been briefed on SECY-79-493.
You also had a preliminary briefing on the alternative.ites issues, in connection with a precursor document (Supplement I to NU' :.G-0499) that led to SECY-79-481.
SECY-79-493 includes nine policy recommendations.
Your decisions concerning those recommendations are to be reflected in a proposed rule to be drafted by the staff for your consideration.
SECY-79-493 also includes differing opinions within the Task Force and its Working Group, and some office comments.
After submittal of SECY-79-493, you received additional comments on it by separate memoranda from OPE, OGC, SD (two memos), ELD, NRR, NMSS, and RES.
Commissioner Hendrie stated his views on the Siting Policy Task Force's recommendations in a Response Sheet dated November 5,1979.
On January 3,1980, you received a memo from the Director, SD, advising you of a staff intent to submit for your approval (in February 1980) an Advance Notice of Proposed Rulemaking which would solicit public comment on the Sit.ing Policy Task Force's report.
SECY-79-481 contains a draft proposed rule on alternative sites, recom-mended by the staff for your approval for publication for public ccmment.
SECY-79-481 includes comments frem OPE, together with staff response to those ccaments.
lev. 2/5/SO
Comaission -
On the related issue of emergency planning, a proposed rule was published for public comcent in Federal Register on December 17, 1979.
Other recent and current developments bear on siting policy issues:
The President has endorsed the Kemeny Commission's recommendation calling for remote siting of new plants (Recommendation A.6).
The Rogovin task force's report also called for more remote siting.
You commented on a proposed amendment to NRC's authorization bill for FY '80 that would require an effective rule on siting to be pro-mulgated within six months.
In your comments you agreed that a new rule is desirable, but recommended nine months to a proposed rule as a more realistic schedule.
The ACRS discussed the Siting Policy Task Force report on January 11, 1980, and plans to continue deliberation on it at its next meeting (February 7 to 9).
As an outgrowth of an earlier staff paper on Class 9 accidents, SECY-78-137, you asked the staff (through a memorandum from the Secretary dated September 14, 1979) to discuss how they intend to define Class 9 and design basis accidents and how these accidents are to be used in reviews, including siting.
We understand that the staff expects to respond in February 1980, and that current staff thinking is in terms of replacing current accident classifications with a continuum of accidents of increasing severity and decreasing probability.
On June 1, 1976, Public Interest Research Group (PIRG) et al. submitted a petition for rulemaking concerning population density around reactor sites (Docket No. PRM-100-2).
The Siting Policy Task Force has, as requested by the Commission, included with its report a review of the issues in the petition.
(SECY-79-493, Appentix A) 2.
SITING POLICY (SECY-79-493) 2.1 General The Siting Policy Task Force report includes nine recommendations of changes from present practice.
In most cases you have significant options available beside simple approval or disapproval.
Disapproval would in effect be a decision to continue present practice.
Modifications and alternatives are possible in a number of cases -- and some have been advocated by various commenting offices and Task Force minorities.
Commission. - -
You may also wish to provide guidance on matters not within the scope of the specific recommendations, such as (a) the degree of conservativeness that the policy should embody and (b) what the effect of the policy changes should be on existing plants and on plants at various stages of licensing and construction.
Several of the reccmmendations suggest a degree of conservativeness in siting that is somewhat greater than that reflected in some previously licensed facilities, though the report cautions against excessively stringent requirements.
However, none of the nine specific recommenda-tions call for any specific degree of conservativeness.
The recomendations are silent on the "grandf athering" issue.
Another issue not covered directly by the nine recommendations --
though it is implicitly involved in some of them -- is the question of what role, if any, safety aspects should play in comparative evaluation of alternative sites.
This is inevitably a cross-cutting issue involving both general siting policy and the proposed alternative sites rule.
Our summary addresses the issue mainly in Section 3, in the alternative-sites context.
But the issue is also directly involved in some options with respect to Recommendations 1, 2, and 6, addressed here under 2.2.1, 2.2.2, and 2.2.6.
2.2 The Nine Recommendations 2.2.1 Recommendation 1:
Population Limits This recommendation calls for abandoning the practice of dose calcula-tions from stylized accidents as a basis for siting decisions.
- Instead, there would be fixed numerical limits, including a minimum exclusion distance, minimum emergency planning distances, maximum nearby population densities and maximum population distribution into any octant (22.5*
sector).
The Task Force requests approval of the approach in principle only:
specific numerical limits would be proposed later.
Though the approach involves no site-specific accident-consequence calculations, accidents of all possible severities, including Class 9, would receive generic consideration in establishing the quantitative limits.
Notes:
For complete statement of Recommendation I see page 46 of SECY-79-493.
Recomendation 1 is stated in four parts.
Options:
Disapprove entire Recommendation 1 (i.e., no change from present practice).
Commission -.
Part 1 -- Fixed Minimum Exclusion Distance.
Part 2 -- Emergency Planning Distance.
Part 3 -- Population Limits, Varying with Region.
(Alternatively, you could approve fixed limits but not regional variation.
See discussion below.)
Part 4 -- No Dese Calculations as Basis for Siting Decisions.
(Note:
Approval of Parts 1, 2, and 3 implies approval of Part 4.
Disapproval of one or more of the first three parts would require retention of present dose-calculation-based practices in the affected respects.
Hence, no separate vote on this part is required.)
The fixed limits in Parts 1, 2, and 3 would, for future sites, supplant the practice of using extra engineered safeguards (usually added con-tainment features) to compensate for high nearby population density.
Efficacy of siting decisions would be less sensitive to accidents varying from stylized scenarios used in case-by-case dose calculations.
The numerical limits on population (Part 3) would vary by region according to regional population density.
(" Region" is not defined.) The reason for less stringent standards in densely populated regions would be to avoid driving out nuclear power in favor of coal, thereby exposing the public to putatively worse health effects.
OPE, OGC, and ELD disagree with this regional differentiation approach.
OPE (in its September 4, 1979 memo) has suggested an alternative approach, which could be described as a "three-tier" approach.
There would be two sets of nationwide numerical limits on population:
an upper limit, above which a site would never be approved, and a lower threshold, below which population could never be a factor in site rejection.
In the middle tier, between the two thresholds, a site would be approved or rejected depending on what alternatives exist:
population would be a factor in site comparisons.
The emergency planning distance part of Recommendation 1 is consistent with the published proposed rule on emergency planning.
Inclusion of this provision as part of a siting rule, rather than acting on the issue entirely in the context of the emergency planning rule, would have the effect of requiring that the emergents Conning zone's characteristics (such as population distribution in relation w tepography and transpor-tation routes) be such as to permit reasonably prompt evacuation.
. ~.
Commission 2.2.2 Recommendation 2:
Standoff Distances This recommendation would establish minimum distances to seven types of natural and man-made hazards (seismic faults, airports, etc.).
These distances would have to be exceeded regardless of mitigation.
The recommendation includes approximate numerical limits as well as the principle of fixed minimum distances.
Notes:
See page 51 of SECY-79-493 for full statement of the recom-mendation.
You have decision options on the broad principle and on each of the seven parts of Recommendation 2.
Options on Broad Principle:
You coult approve the concept of single-value fixed minimum standoff distances, as proposed by the Task Force.
Alternatively, you could approve the concept of fixed standoff distances, but with provision for these to vary (in simple ways) with size and specific features of the hazard where appropriate.
Or, you could disapprove concept of fixed standoff distances, continuing to rely entirely, as now, on case-by-case judgment.
Parts 1 to 7 -- Specific Hazards:
Here you could approve in principle inclusion of the specific items as hazards for which minimum standoff distances should be specified without necessarily endorsing the specific approximate distances proposed by the Task Force.
Approve Approve Principle; Principle Defer en Part Hazard
& Values Values Disapprove 1
Airports 2
LNG terminals 3
Propane pipelines 4
Natural gas pipelines 5
Explosive or toxic material depots 6
Dams 7
Capable faults *
"See note acout staff's 1/3/80 memo under 2.2.4, below.
Commission n Although the task force addresses only single-value minimum distances for each type of hazard, consideration could be given to a more complex approach in which more than one minimum distance would be specified in some cases, according to characteristics of the feature in question.
For example, for airports required standoff distances could be subject to modification according to airport size and parhaps flight patterns; for gas pipelines, there could be differentiation according to size; for explosive or toxic material depots, distances could distinguish among types and quantities of materials involved.
SP and OPE note a special difficulty in setting fixed standoff distances for dams, because of the importance of elevation differences and intervening topography.
OPE (in its 9/4/79 memo) has suggested consideration of a three-tier approach similar to its suggestion in connectinn with Recorrmendation 1, i.e., exclusionary minimum distances, larger threshold distances beyond which the hazard would not be a factor at all, and a middle tier in which alternative sites and mitigating circumstances would be considered.
2.2.3 Recommendation 3:
Groundwater Safety (Ref.:
Page 53 of SECY-79-493)
Radioactive materials could reach groundwater beneath the reactor in event of core melt and melting through the bottom of the containment.
At typical sites, the groundwater moves slowly enough to permit taking interdictive measures after an accident, to confine contanimation to the plant's imediate vicinity.
This recommendation is intended to assure that such interdictive measures are possible at a proposed site, as a condition of site approval.
2.2.4 Recommendation 4:
Seismic Analysis (Ref.:
Page 54 of SECY-79-493)
Options:
Approve for immediate action.
Approve for deferred action.
Disapprove.
Commission m This would update the specification of techniques for assessing seismic hazards (in Appendix A to 10 CFR 100).
It would, in additien, make the guidance in the regulation itself more general, moving specifics into the more flexible instrument of Regulatory Guides.
The staff now recommends deferring this effort by several years.
(Memo-randum to the Commission from Robert Minogue, " Proposed Rulemaking on Reactor. Siting," 1/3/80).
The recommendation is based partly on the fact that the staff geologists who would be needed for the update effort are also required for work on waste programs.
The staff does not say that work on the capable-f ault standoff distance (part of Recommendation 2) should also be deferred.
2.2.5 Recommendation 5:
Post-Licensing Changes in Offsite Activities (Ref.:
Page 55 of SECY-79-493)
This would provide for NRC communication to other agencies and for applicants and licensees to monitor and report on potentially adverse offsite develop-ments (such as new hazardous activities or significant population increases).
Problem resolution would be aj! hoc.
OPE (9/4/79 memo, page 4) suggested the possibility of recommending legislation that would compel disclosure to NRC of plans for specified activities out to specified distances from nuclear plants, in order to enhance the effectiveness of the measures proposed by the Task Force.
One task force member urged seeking legislation to orevent creation of man-made hazards closer than the minimum standoff distances of Recommendation 2 (SECY-79-493, p. 56, second paragraph).
2.2.6 Recommendation 6:
Avoidance of Sites with Unfavorable Characteristics Recu1 ring Compensating Design Features (Ref.:
Pages 57-59 of SECY-79-493)
Options:
Approve.
Approve, but call for consideration in comparison with alternative sites.
Disapprove.
Under this recommendation, sites would ordinarily be approved as safe enough or rejected as too unfavorable.
In some exceptional cases, com-pensatory design features could be considered to make up for some site weaknesses (other than population or standoff-distance problems dealt
~ Rev. 2/6/80
Commission m with by Reco=endations 1 and 2).
However, even in such cases, comparison with alternative sites with respect to safety-relevant site characteristics would not be permitted:
the site and compensating features together would be evaluated as acceptably safe or not, regardless of what alternative sites are available.
A Task Force minority (page SS of SECY-79-493),
OPE, and OGC disagree with the prohibition against consideration of alternative sites in such evaluations.
In their view, residual risks at different sites could clearly differ, though admittedly quantification of such risks may be subject to very large uncertainties (as pointed out by the Task Force majority -- page 59).
2.2.7 Recomendation 7:
Early Site Accroval (Ref.:
Page 60 of SECY-79-493)
This recommendation would call for site approval decisions to be made early in the licensing process.
Relatively high new information thresholds for reopening would impart a measure of finality to the decision.
The intent is to improve efficiency and avoid delay in the licensing process.
2.2.8 Recommendation 8:
Termination of NRC Review if State Disacoroves (Ref.:
Page 61 of SECY-79-493)
NRC review would be terminated if there is "a final decision disapproving the site by a state agency whose approval is fundamental to the project."
Termination would be subject to Comission review.
An argument against this recomendaticn is that a State decision that appears final may be subject to politicci or judicial reversal.
Under such circumstances, termination and resumption of NRC review could be costly in terms of both project delay and resources.
2.2.9 Reconmendation 9:
Risk Study for External Events (Ref.:
Page 63 of SECY-79-493)
The risks of natural and man-made hazards would be systematically studied, with probabilistic analyses included, in order to provide improved rational bases for comparison and management of risks.
4 Commission. s The Task Force does not conditicn the setting of standoff distances (Recommendation 2) on completion of the Reccmmendation 9 risk study, though it does not address this question explicitly.
OPE (9/4/79 memo, page 4) argues that Recommendation 2 should not be delayed to await the study outcome, though study results could perhaps lead to later changes.
2.3 Other Needed Guidance 2.3.1 Degree of Conservativeness The degree of conservativeness with which a policy favoring remote siting is to be interpreted is left as an open issue by the absence of specific numerical limits on population density and distribution in Recommendation 1.
You could address this issue when the staff comes back with specific numbers for your approval.
Alternatively, you could at this tire provide some indication of your preliminary views, to aid the staff in developing specific limits that will be reasonably in line with your sense of values and policy judgment.
Guidance options on approximate degree of conservativeness in remote siting:
Note: More than one item may be checked where not conflicting.
No guidance at this tire as to degree of conservativeness.
Keep present degree of conservativeness.
Base on risk ccmparison with coal.
(See discussion at Recommendation 1 above; anc SECY-79-493, second paragraph on p. 44, and last paragraph on p. 45.)
Reject sites ccmparable'to approximately:
the 5% least remote sites licensed in the past.
the least remote 20%.
the least remote 50%.
the least remote
Commission m Keep at least the following distances away from substantial towns (over 25,000 populatien) and cities, depenu 'ry; on their si:e:
5 to 20 miles 10 to 30 miles 10 to 50 miles to miles Do not establish limits so st-ingent as tc eliminate from reasonable prospect of nuclear-plant site approval *:
any entire state any entire state together with all adjacent states in the same Reliability Region any entire Reliability Region any region defined as follows:
2.3.2 "Grandfathering" Any revised rule on siting will need to specify to what extent, if any, the changed requirements apply to sitas of operating plants and of plants in various stages of licensing and construction.
You could defer consideration of this issue to await staff recommendations.
Alternatively, ycu could express current general views on the subject as guidance to the staff in development of specific recommendations.
0GC and SD have advecated review of existing plants in relation to new requirements. notably the groundwater protection requirements that would be entailed by Recommendation 3.
NRR is, we understand, considering imposition of additional requirements on existing plants near large cities, such as a " core ladle" to facilitate evacuation by delay of radioactive material release in event of a core melt.
(In SECY-79-493 the grandfathering issue is touched on in the last paragraph on p. 45.)
-Ref. SECY-79-493, p. 45, last paragraph.
Commission.,
Guidance cptions on grandfathering:
No guidance at this time.
New requirements should apply to:
new applications only all CP's issued after effective date all CP applications after 1/1/80 all CP applications after Plants with OL's cr CP's should:
be required to take mitigating measures only to the minimum extent that substantial safety considerations
- demand, be required to take mitigating measures to the maximum practical extent.
be subject to a policy to be developed after case-by-case review.
CP's should not be revoked except on the basis of one or both of the following two criteria:
(a) the site is substantially and irreparably in conflict with new requirerents and (b) con-struction is not too far along.
In making revocation judgments:
Criterion (a) should weigh:
heavily moderately not at all
Commitsion.m Criterion (b) should weigh:
heavily moderately not at all.
Possible CP revocation should be subject to a policy to be developed after case-by-case review.
2.4 Procedural Considerations Options:
Schedule for publication of prcposed rule:
Approve October 15, 1980 Approve date of:
Request progress briefing.
Briefing should take place:
in April 1980 not later than 6/20/80 Complete draft of proposed rule should reach Commission not later than:
August 29, 1950 Proposal to seek public ccament en Task Force report by Advance Notice of Proposed Rulemaking:
Approve Approve, but Commissioners' current views on Task Force recom-mendations should be indicated in the Advance Notice Disapprove.
Commission,
PIRG petition:
Staff to draft response to PIRG, for Chairman's signature; sub-mit at the same time as the proposed rule.
In addition, staff should now (within 30 days) draft, for Chair-man's signature a brief letter to petitioners describing status.
At the time of this writing it was not clear whetner the FY '80 NRC authori.:ation act would mandate a set.dule for rulemaking on siting.
The staif, we understand, is procecding with drafting a proposed rule based on SECY-79-493 with a September or OctoLer 1980 target date for publication in mind (which should be consistent with a legislated requirerent for a proposed rule nine months from enactment).
You may wish to have a progress briefing, with an opportunity for mid-course guidance on significant issues in the drafting (e.g., specific numerical limits), as well as a reasonable amount of time for review of the proposed rule when drafted.
Meanwhile you could elect to approve Mr. Minogue's proposal (of 1/3/30) to issue an Advance Notice of Proposed Rulemaking which would_ solicit comments on the Siting Policy Task Force's report.
That proposal was made with a view to assisting without delaying the October 1980 completion of the proposed rule.
You should, however, recognize that if extensive public comment should call for substantial staff efforts to analyze the comments, pressures could arise to reconsider the schedule.
Should you approve the Minogue proposal, you could direct that your current views concerning the Task Force recommendations be indicated in the Advance Notice.
Commissioner Kennedy has indicated his concurrence with Mr. Minogue's proposal.
As for the PIRG petition on population density, the proposed revised siting rule expected to result frcm these efforts should constitute disposition of it, and you could direct the staff to draft a letter to the petitioners to that effect, to be sent at the time the proposed rule is published.
In addition, the petitioners could now be sent a brief letter about current status.
- i Commission 3.
ALTERNATIVE SITES RULE (SECY-79-481) 3.1 Relation to General Sitina Policy To be approved, a site must survive both (a) suitability review from a safety standpoint and (b) environmental-impact review, in which comparison with alternatives plays a critical role.
Thus, a comprehensive siting policy must address both sets of requirements.
However, if one assumes that environmental and safety aspects can be sharply separated, then the two parts of the overall policy can be formulated separately, independently of each other.
That assumption underlies SECY-79-493 and SECY-79-481.
The Siting Policy Task Force (in SECY-79-493) has refrained from addressing site-comparison issues, leaving this for independent treatment in SECY 4 8 '..
The soundness of ex,cluding safety issues from site comparisons has been questiened by OPE, ELD, and OGC, as well as a Siting Policy Task Force minority.
However, even if safety matters were admitted as issues in alternative sites review, the alternative sites rule lends itself to separate promulgation.
3.2 Safety Issues in Site Comoarisons SECY-79-481 is written on the basis that safety-related issues need not enter alternative-site comparisons because safety acceptance standards could be sufficiently conservative to result in a negligibly small environmental impact:
with respect to safety issues, a site is either acceptable (possibly on condition of specific design features) or unacceptable.
OPE, ELD, and OGC have in various ways questioned that approach, and have indicated an alternative view that would recognize differences in residual risks among sites that are not absolutely unacceptable.
For example, in popula-tion density, or seismic or aircraft-collision hazards, conditions not adverse enough to rule out a site may nevertheless involve enough residual risk to suggest avoiding approval of the site if clearly better alterna-tives are available.
(
References:
OPE Comment 1 and staff response in to SECY-74-481; Ccmment 2 in OGC Comments on SECY-79-493, dated 9/12/79; second comment by ELD, page 70 of SECY-79-493; minority and majority views, page 58 of SECY-79-493.)
Approval of fixed maximum population densities and distributions and fixed minimum standoff distances in connection with Recommendations 1 and 2 of SECY-79-493 is not inconsistent with allowing afety-related aspects to enter site comparisons.
Election of the "three-tier" approach in con-nection with those recommendations (sections 2.2.1 and 2.2.2 of this memo) would recuire allowing comparisons to include safety-related aspects.
Rev. 2/6/80
Commission.
3.3 Discostion of the Proposed Rule Though the safety-issue comparison question is an unusually important one, there are a number of other aspects of the proposed rule on alternative sites on which there could be useful public comment.
You could authorize publication for comment without awaiting any revision of the rule's language to reflect your views.
Options on proposed alternative-sites rule:
Approve Revise to reflect Commission views on safety-issues comparison and resubmit Add note on current Commicsion views concerning safety-issues comparison; then, after Commission approval of the added language, publish for comment.
Add note specifically asking for public comment on safety-issues comparison question; tnen, after Commission approvai of tne acced ianguage, publish for comment.
Defer cction, pending resolution of related issues in connection with general siting policy.
Then revise and resubmit.
Disapprove.
4.
NEXT STEPS In view of the number and complexity of issues and options involved, we suggest a Commission meeting, with appropriate staff officials invited to attend.
Then the staff would be directed to prcceed in accordance with your de-cisions with:
(a)
Drafting a proposed rule en general siting policy.
(b)
Disposition of the PIRG petition on population density.
(c)
Disposition of the draft proposed rule on alternative sites.
~.. ~ -
Commission,
Note:
You may later wish to modify or supplemert your guidance to the staff, should your evaluation of the Rogovin report or the expected ACRS advice warrant.
cc:
Leonard Bickwit Samuel Chilk William Dircks Harold Denton Robert Minogue Daniel Muller Howard Shapar Malcolm Ernst
'S
[h
- \\
UNITED STATES
^
NUCLEAR REGULATORY COMMISSION 3 NM)[li ADVISORY COMMITTEE ON REACTOR SAFEGUARCS
$ 3gg J
WASHINGTON, D. C. 20555
%{' ~ -;l} n
+..<
February 14, 1980 Honorable John F. Ahearne Chairman U. S. Nuclear Regulatory Ccemission Washington, D.C. 20555
Subject:
NUREG-0625, "REPCRT CF 'mE SITDIG PCLICY TASK FCRCE"
Dear Dr. Ahearne:
te purpose of this letter is to provide you with AC9S ccccents on the
" Report of the Siting Policy Task Force" (NURC-0625).
In preparing these ecmments, the Cecmittee had the benefit of discussions with the NRC Staff at a Subcocmittee meeting on Cetober 17, 1979 and at the full Ccmmittee meetire on January 10-12, 1980.
Sitino Goals In the abstract of the Report it is stated that a vnber of changes in siting colicy have been recccmended in order to accccp11sh the following goals:
1.
'Ib strengthen siting as a factor in defense in depth by establishing requirements for site approval that are in-dependent of plant design considerations.
2.
'Ib take into consideration in siting the risk associated with accidents bepnd the design basis (Class 9) by estab-lishing population density and distribution criteria.
3.
W require that sites selected will minimize the risk from energy generation.
In connection with the third goal, the Siting Policy Task Force states that, "Be selected sites should be amorg the best available in the region where new generating capacity is needed. Siting requirements should be stringent enot.qh to limit the residual c2sk of reactor operation but not so stringent as to eliminate the nuclear cption frem large regions of the ccentry. mis is because energy generation from any source has its asscciated risk, with risks frem seme energy sources being greater than that of the nuclear option."
Honorable John F. Ahearne February 14, 1980 Such a philosophy should be based on preestablished Cxmission objectives for acceptable risk both to individuals and society.
This will, of neces-sity, include consideration of matters such as the potential effects of a broad spectrum of reactor accidents, the identification of an AIARA cri-terion for the reduction of risk frca accidents, and a general statement of policy concerning the cbjectives to be sought in reactor design with regard to the prevention and the mitigation of accidents.
Re establishment of demographic-related site criteria will inevitably re-quire a considerable amount of judgment. Ibwever, the choice will be less arbitrary if made within the framework of an overall SRC safety policy.
We ACRS believes that an overall hBC safety philosophy is also needed in connection with the third objective of the Task Force, namely that of se-lecting sites to minimize the risk from the utilization of electricity generating sources.
We ACRS believes that well-founded nuclear powr plant siting policy and practice are a national as w il as a regional need. The Committee suggests that as part of a broad approach to DR siting, the NRC should explore the possible developncnt of a nationwide program to identify a bank of near-opti-mal sites regionally distributed for various types of energy-generating plants.
By cocbining considerations or' acceptable risk, the risks from various energy sources, and the national needs for eNrgy, together with other relevant factors, a better long-term basis for Jetermining appropriate criteria for mR siting should be possible.
In the absence of such a broad approach, the ACFS 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.
Task Force Recocrendations te Siting Policy Task Force has made nine recccmendations, each of hich is followd by a discussion which elaborates on the reccomendation, frecuently suggesting specific parameters and occasionally a significant additional recommendation.
In this repart the ACRS will deal primarily with the reccc-mendations themselves, unless otherwise stated.
Recommendation 1 mis is the principal recommendation of the Report.
It proposes that Part 100 be revised to change the way in which protection is provided for accidents, he recce=endation is very general in form and requires the addition of speci-fics to be meaningful.
Honorable John F. Ahearne February 14, 1980 Part 4 reccmmends removal of the requirement to calculate radiation doses as a means of establishing minimum exclusion distances and low population zones. We ACRS agrees with the Task Force that the approach used for the past tw decades has not provided enough emchasis on site isolatian. The Committee believes that the emphasis on engineered safety features to meet Part 100 for the postulated accident without direct consideration of other, more serious passibilities has led to a less-than-optimum approach to safety.
However, if the recccendation 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 minimum ex-clusion and energency plannirs distances and population density and distri-bution 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 establish-ment of such parameters involves the assumption of some accepted band of risk ahich should be specified. %hile the ACES is not opposed to removal of the Part 100 requirement for calculation of radiation doses or to the specification of regionally dependent acceptable population densities, the Committee believes the e matters need in-depth evaluation.
Recomendation 2 I
This recommendation proposes minimum standoff distances for potential haz-ards posed by man-made activities and natural characteristics.
te Com-mittee believes that such a recommendation is appropriate but the list is incomplete.
For example, WG terminals are inclu:!ed but not LP3.
Similarly, hazardous cargo on rivers,is not mentioned.
In addition, the proposed approach lacks an adequate rationale for specific numbers suggested. A distance of at least 12.5 miles from all capable 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 ntm-bers is suitable is not clear to the ACRS.
Ebr 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 paso significant de-sign problems.
It is noted that the recomendation does not provide standoff distances be-tween nuclear plants.
The patential adverse influence of one plant on its neighbors in the event of a serious accident requires consideration in de-sign.
..,s Honorable John F. Ahearne February 14, 1980 Reccanendation 6 This recocmendation pertains to methods for ccmpensating for unfavorable site characteristics. te Cermittee suggests that the phrase, " unfavorable characteristics requiring unique or unusual design," be clarified. Many characteristics that are " unfavorable" can be readily empensated for by de-sign, including some of an " unusual" nature. Design features to provide permanent site improvenents should ce permissible when suitably reliable.
Perhaps these problems could be solved by deleting the word, " unfavorable,"
and substituting the word, " unproven," for " unique or unusual".
Recerrrondation 7 This recccmendation relates to the timing of site reviews. Se MRS sug -
gests that this recommendation could be improved by substituting the ward
" decision" for " approach" (in the third line).
Recccr.endation 8
. This reccamendation relates to the role of a state agency in acproving a site for a nuclear power plant. Re ACRS has no cccments on this item.
Recomendation 9 This recccmendation 1.3 to develop ccmmon bases for cecparing the risks frca all external events. he ACRS supports the general cencept and would, if practical, extend it to internal events as well. Re Committee believes that this concept represents a good long range goal; however, recognizing the emplexity of the task, the Ccemittee recommends that priority be given to those areas thought either to introduce the greatest risk or to provide the best opportunities for improvenents in safety.
We Coccittee will be pleased to discuss the above items with you if you de-cire.
In the meantime, wu trust these cecments will be helpful to you and the NRC Staff.
Sincerely,
/
/
Milton S. Plesset Chairman t
_ _ _ _... _. - -.. -.. T ~. ~~~
~ ' ' ' ~ ~
~
..