ML19323D215

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Presents,In Detail,Substance of Recent Discussions & Correspondence Re Certain Aspects of Intervenor Contentions. Defers Signature on Stipulations Until Matters Are Resolved
ML19323D215
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/18/1980
From: Ellis J
Citizens Association for Sound Energy
To: Chandler L
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML19323D198 List:
References
NUDOCS 8005210275
Download: ML19323D215 (2)
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ATTACHMENT B (CITIZENS ASSN. FOR SOUND ENERGY) ~ February 18, 1980 Mr. I4vrence J. Chandler Counsel for URC Staff U. S. Nuclear Regulatory Cc:::=ission e,, Washington, D. C. 20555

Dear Larry:

Subject:

In the Matter of , texas Utilities Generating Co., g al. ~ Comanche Peak Steam Electric Station, Unit's 1 and 2 'L Decket Nos. 50 M3 #s 50-u6 During our recent discussions and c'orrespondence, you have raised certain questions, and we're not sure.ve completely understand certain aspects of_several of our Contentions at this point; specifically: (1) What is the effect of the reference in the 1/25/80 Stipulations to "(FORMERLY Contention No. X )" Does this limit us to using ~ only that former contention in our M ses; or, as we had thought, does this simply mean that this was 5ur primary former contention and that it may also include scue Jortions-which are applicable 'but which were originally contained it'other contentionsi As you will. recau, we had exy.essed concefa e' specially about 'our former Contention 2(our10/30779 letter and following telephone conver-sations) in this regard. I think this may very well be the. root of part of the problem you ve're having with our wording on New Contention 7 (referred to in your Stipulations as "F01HERLY Contentions 9. and 17."); although the main parts of our Con-tention (or.at least the most lengthy).are contained in old Contentions 9 and 17, there are other portions of our 5/7/79 Contentions which also have a bearing on it and which we discussed at our 7/18/79 and which led you to agree that-thia was a good contention (see particularly 5/7/79 Conteitions, p.10 and 11, Old Contention 2, item 3 and p. 50 and'55, Old Contention 19, items 10 through 13). We want to be surb that we are not limited to using as our bases only "FORERLY Contentions 9. and 17." since this was never our intention. (2) We recall that you made a very big point early in our discussions that each contention should be tied in to some requirement in the 9

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..~, -. 2 . ' :.... ;. p <. s . se- .? ,~ ) '. 7, ..s...,'... g.. regulations, and we tried to improve this in our 5/7/79 Contentions. However, 'in light of subsequent conversations and correspondence since our 7/16/79 conference, we e.ro nov very much concerned that the present wording contained in the 1/25/80 Contentions may be deficient.in that regard and that our position may therefore be empromised or weakened. Do we need this tie-in to tpe regs, and what is the effect of not including it? (3) What is the effecti of deferring a contention? Does it mean that we may give up our option to pursue this contention at some point does it mean that we are sid,n6s, or (as has always been our intenti in time later in these heari ply postponing consideration of them pending resolution by the NRC of its position on them and that we vill still be able to pursue them for this'.*paiticular plant at sme later time.in the hearings, but before an operating license is issued? We have already discussed.'this somewhat regarding New Contention 10 (formerly 12, etc.) on 9/16/79,11/26/79 mi 1/31/80 by phone and in your 10/4/79 cover letter with Stipulations and our 10/30/79 letder, but we are still somewhat unsre exactly what the implications are of de' ferring a contention. ~ We'll appreciate your,gettin6 back with' us as joon as possible so that we can ~ get these matters resolved. In the meantime, tie are deferring signing the Sti'pulations. 1 ,. 'a. l -? . *a.. Thanks. c~". p ~ Sincerely,- CASE,(CITIZENS ASSOCIATION FOR. SOUND ENERGY) Mrs.) Juani.ta Ellis President cc: Nicholas Reynolds Dick Fouke Geoffrey Gay "~ , Rick.Ard Lowerra- ~ 4 e 9 9c_._.,...-. - - &C

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~ E' " 'r j %-i.f. " C A S E = JV 214/9k6-9hk6, Dallas M l I ( CITIZENS ASSN. FOR SOUND ENERGY) October 30, 1979 Ms. Marjorie B. Ulman and Mr. Larry Chandl er Counsels for NRC Staff U. S. Nuclear Regulatory Ccumission Washington, D. C. 20555

Dear Marjorie and I4rry:

1

Subject:

dockets 50.kh5and50hk6 / Application of.. Texas Utilities Generating Company' f'or an J Operating License for Comanche Peak Steam' Electric Station Units f1 and"#7 (CPSES) s In response to your letter dated October 4, 1979,.there are several items which need attention: 1. Contention No. 7 (old Contention Nos. 9.and 17), Radiation Effects. In reviewing our notes on the conference where we worked out the wording of the contentions, we believe we discussed thoroughly'st that, time exactly what we meant by this contention, and that the wording.fuially agreed upon af'ter much discussion reflects what wk vanted").o cover by this' contention. Further, the J Staff agreed at that time that this was a valid ' contention. In your 8/31/79 conference call, you indicated that you now feel tbat we are attempting to challenge Appendix I, vliich is not permissable. Frankly, we are at a loss to understand your change of stance at this point and would request an explanation. Further, if the Staff insists on changing its 'su'pport of this contention, we would like to revise our vording of the contention, for purposes of clarifi-cation only, to the following: "Neither the Applicant nor the Staff has adeq'uately considered the health effects of low level radiation on the population surrounding CPSIS as re-quired by 10 CFR 51.20 (c) and lo CFR 50 57 (a)(6)." This would not change the meaning as originally agreed upon and as outlined in our original bases but would clarify the exact meaning scmewhat. 2. Contention No. 5 (old Contention No. 7), Spent Fuel. As I recall, Larry, in our 8/31/79 conference call, you stated that a "second German report" repudiates German Report No. 290. In reviewing the information we have, this does not seem b 6L mns@O

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.i. to be the case. Please advise exactly what German report you are referring to, send us a copy of this second German report, and advise in which specific sreas it repudiates Report No. 290. Here again, we request an explanation for the Staff's change in position.. 3 Contention No.10 (old Contention Nos. 12, 13, 14 and LS), Evacuation. ~ We do not believe the wording in your October 4 Stipulation accurately reflects what I agreed to over-the phone on 9/18/79. We request that'the following wording be used to replace the wording of item 7, page 3, of your Stipulation: "'ihe parties stipulate to the cone,olidation of contentions 12, 13, 14, and.15 into the language of revised contention 10, as set forth in the Attachment, but agree to defer for the present, ponsideration of this contention in light of probable changes in Ccomi'dr '.on requirements regarding emergency planning, with the understanding that the Intervenor will be given the opportunity to pursue this contention in the operating license hearings at a latu date,before the operating license'.'if issued." v. k.. Item *k, page 2, of your Stipulation should read: "The Staff and Intervenor also agree that contentions 6 and 18 (ccambined) and 16....." etc. and "The Applicant does not agree that contentions 6 and 18 (combined) and,16....~." etc. , 5. I. tem 7, page 3, of your Stipulation should read "The parties stipulate to the consolidation 'of contentions 12,13,14 and 15 into the innguage of revised contention 10....." etc.. This contention, when huumb'ered, would become No.10 rather than No.12. 6. The wording regarding Contention 2 should more accurately read: "With-drawn; included in other contentions" or" simply " Included in other contentions." We would request new stipulations with corrected attachment referred to in the stipulations actually attached thereto and referenced as an exhibit before signing. Thanks for your help in working out these problems) Sincerely', CASE (CITI$ENSASSOCIATIONFORSOUNDE3ERGI) e (Mrs.)JuanitaEllis President 7 cc: Servi'ce List-e l i

\\ ~ }'2l,s f . } ... Q g3..::g ),..yy 9 ~ r.ased u.gi.etw 4 NdisMfars,aur,.Marck.mf msW 9Rufes 18823 G -it the market administrator ta$eldag" O eregr'adshannot apply to a pareci",;[spondi peedd44 with July of the ..z p p Mr. nests to predacere persuant to who was s'psodeoer under's Federal. y current yper. p (i) As seestae possible after the rate 11:ca.73 (s) and (c) shall deductJ,oeste. dedor underwhid the seam refund - Mnot!8catico period a ,p Mr nundredweight, or sech lasser - ' amount se the Secretary sterpreecribe, < :f person didaat appuppriately sahndt a,. p. writtagement prodacar currently o j mth respect to miIk of such producer.,, refund appacation daring noch period..,- m l _ 'euept a bandleve own farm. ' ; M'C Aled requent fortsfund of advestising,,.withholdingrate.This notf! cation ehal ! Y

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8' and promodon program asseeements on. 'be repeeled annomDy thereafter only if i deductions to the market ad=f at=trator ; 4 '5Ji 4,t later than the 17th day after the end" his marketings of milk under another there is any change in the rate from the j g% of the.nonth. Such money shaU be . Federal order.shall be ei!gible (on the, previous period. 7 8 by the market admirdstrator to vertfy or asts of his request !!!ed under the other ' Nets-nts recommended decision has establish weights, samples, and tests of r) for refund wLth roepect to his been rettewedender USDA cntena eetsbushed to hepiaraeot Execuuve Order gg Ptoducer mdk and to provida producers pr4rcar muk under this order agarnat uDat. "' Govemment Regulations." d Mv. with market information.The services w aseesament la wtthheld until A delansmat6on been made that this l 7 thall be performed by the markst. ' the o ty exists for such producer should de clasaM "s#canr" to be refund a t to, undemose cruariaAs decision consututes . p admirdstrator or an agrst engaged by' the Depanzeent's Draft Imact AssWe

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patagrep of thle (b)In the case of producers for whom 13.Zui the in uctory text Statseneet for this proceedtes. ,; a cooperative association is actuallY of paragraph hmd p ph (b}{2) Sissed at Weehington, DC. on Atarch 14 g fy Hrforming the services set forth in c and(3) are revi and ne etagraphs.- Igsr prapaph (e) of thne eaction and for (e) and (f) are a to re ' s follows: WSam 7*

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'gg '3hom the cooperative le not authorued N h oven.Wdang %m to collect payment for milk, each . t 1038.121 of 'a e ct 9 handler shall make la lite of the edannteerstor. .\\ w 0" "'8" " ** ** "I d.eductione specified in paragraph (a).of ' - k j' pin ' 81 %. yth:s section, such deducilons as asw (b) Set aside into authorized by such producers, and, on or " promotion fundiseparate( ' g a le b "rg before the 1ath day afterthe end of each for, an amount equal to the ' N RNTORY i-S 7 exmth. pay over such deductions to the. rate for the month as set /.,' COMMl884CM 5 1 u L,y association rendering such services. paragraph (e) of this secticadisfer'tbe (c)In the case ofprodubers lbr whosa. amount of producer milk int! h tha to CFR Part 20' .{. = M'fon ch : t coopers tive associetion is not -. ' uniform price==dt set a be' Standards forProtection Against i5' ) .Q.) {

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'c- 'r'n--t inn M1 maks & deduction and perform,..of mandatory checkoff for s ' prtising i1038.73(h) the mar $st administrator 88d8' Acticet Advance Notice of Proposed 4'- 'ap: ~- ud e- ~~ Pr'8r*84 r-j,T du services spedfled la parsgraph,(al.of f authorityof Statelaw appIl ble fu sedt, Rulemaking: Request for Public .b. 4

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12. In i 103e 120 paragraphs (b).tc);;. " producers, but not in amouraxceed h, sets per hundred t

gg,%, c e f and (d) are revised to road as !bBows:c- : determinedpossent in (e)of massanser:The Nuclear Regulatory ' 44

e. c this section on thevolume of C--'- '~ (NRC)is considering a:

.[fg rotunna. ..i.<.- ' pooled by anysuch producet Icr which major revision to 10 CFR Part 20 of its ' ltoss.12e procedwoperrepoeune

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+ e = /t deductions were made purst sht to this regulations.The primary purpose of ths revisionis to bring NRC radiation c.:; (b) Except as providad in paragra h peregraph. 7 (3) After the end of th maks protectice standanis into accord with Y, Ic)of this section, the request aNatt h ( 'h submitted within h !!rstis days of a refund to each producer inade developments in radiation psutection June. Septstaber. December, or March application for such refund truanfir that have ocx:urred since promulgetion for milk to be marketad from the Brst of. I 1036.130. Such refund shall mij of Part 20 in its pruent form in b !ste @'%the immediately following month computed by multiplying the iate ms. In a preHminary review of thia mattar, b NRC staff has identified a i throush the following June soth;.. ~ 'spedfied la paragraph (e) of ttisisection number of areas in which Part 20 might times the hundredweight of a ~ belmiproeed. Before proceeding further i f',' (c) A dairy farmer who 0 st ecquiru producer's milk pooled for w ' with spedfic structural and substantive d producer etatus under thu pari may, dednd== were made parstant to this ~ [M upon application filed witu 6 market ' proposed chang *= the NRC is seeking administratae pursuant to prograph (ab. Fe n el.Ihr sadtmenth.lessithe 'k of this section by the end of the month y amount of any rufund otherwiie'inadejo public comunent. Of partic e %'l != mediately followmg the month la the pi 4 -.= ---=* to paressaph.. arv publisviews on the areas so far. . Idaarmad by the staff as wvil as i which producer status is acquired. be (b)(2) of this anc*m 4 C t suggesttoos for further improvements -e Y' eligible for refund on all markatinge I' al.: and suggestions for altemative against which an aseeneawat la withheld - (e) As'soon as possible after 8pproaches for affecting needed for the period through the following Jane, each yens compute the rate of W !. !=e i. soth and if producer status is first withholding by amitiplying the hihrple DATsm Comment period expires June 18. {_ acquired !n Jun's such producer shall be average of the naffarm prices fdr 1;. eligible for a refund on all m@== month period andinst April 30by 1980. during June and the following 12 month ; and roundfag to b nearnt who cent. aaaa** =*-Written ecmments or pertod. Eligibility for re6ad under this,. This rate shall apply dmd.ng the suggestiana abou!d be submitted to 6 . j .. ~ " '.[ s. .) .~-L. . D. ,/. ,h ?s -[ ^* ..g J 3 .~. .n

Yk g,;,",,, p *, - f[f. pM~ (y > [. [ E,..' + J3 .1 - . m., y;.g.. .2.,.;.,. g,sid J ~ ATSCIDG2fr D samme ?- Endosel Ragheer /* vel % Nei se;/ 'Desredayllfarch W2Ses [h- Rulee o 1.rm" Sometary of the P UA. partisipagesin therL ', ^ f dy poeteedse of seheahh and soferpeW e Nuclar Regulatory F-d=d== .. propoedrevisions, the NRClaseshkig.- workas mdMdalmembere dse Weata-mat n 20585 Attendom ~' Dockedagand pubBc ossement and seasesticos at this y aedes populanen la senerer. coms.ea. es ServloeGesamb.Copiseat "L, esegeln the pressoa In regeseting," 'o.,s.m..e Mc,== '-= v ,,,,e _Y,,**8 ew me,be e-mma a the fa==1= dam'sPolpheDocument' . that,thsKa'rthaan _ "3 for ,,,e a,,,,,. Room at 1717 H 9treet.N.Wi * - ea*=M8ahyPodesali Miadium Nd==== recessiend Nasonal and faternet:ans' ' / ' Washington DE edvisory orsammadone. m a t . and'3sesseEy agglicablesternimain for -.,: be ansceure.f to a meanersetis em pose puervosest semesseeness sourracn the preescelos of the savironment froar endarmeed and can be reeddy reviseest Robert A. Purple, AssistemtD! rector, rediados and radioactive meternale, and ecsemmoda a leenslauve and reA*dfm D. Radiological Health & Safeparde - is aware that EPA is actively developing chasses as necesseer.To essere Standarda.085ce of Standards nous y=tdaaea and standaada that would imelementaden of me standarde mgi Development. Nuclear Regulato,y effect sha provtalons on NRCa radiatiour m verissedan by es Commlulon.Wantagens.DA 20a55 protectica regula tione whieh ere dedeed - ,N,,,,,,,hle asd hina; I-(phone.-Clot)MS 6485). from EPA guidance and standasde. &m medy and efeedve adorcement eumauerrawmoomearioet & NRC th'".""dd**88" d " d'I*****' een be takes wtwomr the standardmas n radiation protection standanis were ita 're tion steadasde NRC gre,og, I8 N '" g developed in the lats 1960's. Sines-that ,,,t r ;, a"I - EDe list of sesential elemmate of -eem uve w.eas h> p nmabe r , rot.co... d be. r dawa. aeme dae-i. f,

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.,,, ow nwead.veio,,dw. w .uaow e reged-i.to.co.rd we e ,, a -- ese O e in mad. recommendations of vartaus scinati8e P'***'88** N,, a, e,, advisory orpa=t==Ma=a but none of isa.wayea M

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g, __."P8'8f,,DF 0*,g,, g,"Cos=enI==lon* f.DahlRC I**** A Protection sabodied in 4e molytaal liens thathave d""*d wLs it considers to be the$ Il publication.With the passagaaf tima there has been sa lacreeas in the ~ M ee ofsa n dcol eenendal alamanta that s.hou sophletication of thegameral sppranch to Hades tar hidiehhsald.asse. As part of. ~=hia-dia the MC re ation A I - b considertaaen d oerpeddame.R le regulations nelistalltest.' radiation protection, there have been i eeverallegislative meMane that affect the.andclpenden leerings este 8: N federal approach to radiation protection' newEPA guidance for

a. 3tadiological Protection Principises:.1 and there have been additional acoaWand Minbe Deee shouldInchade:

T informatios and =rs=n==adatione an dM EPA.MCmid ' identi8 cation olhasic assumption rediation protecdos frent naticeal and OSHA in the'near future Dime M m laned for tediation protsetica ' -{ in ternational bodies (e.g., Itatted 53785. umber 17.197a) and such aaq1) thers ta within the sease Natiene Scionetas Commiteesas the domidose Heing

  • aposure annditinna unmaBy E!! bete of Atomic Radianon,MeWamal ehmbaWE asiaises Md.. encountered la radiados work, a mesehand'ignJ N.'as a @d &a EPf 'duae and = way of st Counen airP===H -peeteselen and k;

==ap reviand nomasiesf ..a a. Measurements and theInessameinant and [2} the! severity of each type ofv g en==8 dan 'on Rsdialogical Protectica) <,gy,,g go,,,,,,,p,,ac,.., a ger, stochasticaffect la * - - Md D la addittour, there bee bear e souring q:g,.. er public laterest tr and sommern abeat the la &e above context,'pabhc comment's f powntialheelbe5kerdioWevel en to absolum manericalumna Gat Protoedon principles which are derived i. lonizing radiation. br Aegast 1979, the should be estabilahed in the radla tion frt>m the assumptions, such est 1, Secretary of Health. Eshacation and protecdon standards kr nucTear (1) No practice or operation Welfsee aest to the Phssident s empert of workers and the pubHc are not soRefted

    • Posures to radiation should be a g y as ' 1.- -; Task Paeseen the Heele as past dthiis modos.Howeves pubW.

. adopted unless lie hatroduceen predeems g Effects oflisching Radation. Hit e='i====trarsrequesendon de, a posieve net beneat: report, amongother tidnes, med* appropriateness of the spec Scitems (2) AB exposures sha8 be kept es le recomewndesses for reducing redietion lieted forindteldnaldoses and on the as reasonsbhe schlecebia, econo,sde and@* =_t - o of eresa identtned for sociallectore beingtakenintssamount g -;. exposures and r======ad=d the estab4A==at of a Federal Radiatfou f.nrth'er heprovement by the NRC stafE and "k . (3) De dose equivaleet le indleidseie'4" Policy Counce r==t===nt* kr Function of y-a.m pg n d'* formaleting breed redation protectiour Standmio shaR not exce ed the Ibnite selected fba ' J I I the approprinta circumetances. policy.DePresidentheew J Teaidkrdeveloping thehomework (47 Ftrooms occupetionaDy espoesd-ter '//A theseiscemowendaeses.. As part of its on whichto strustere thenew redietion redetten shoekt be infernsed'aiits - A p.n! 4 tisar as &ieTheirPbseeeSert repfaelana ittehelpfefit - - potematal risk of that esposure. radiation preesomen seesdards. . tobe nut by the L ew standards.To that Theseehemidimefudu-_ -[J t!w NRC 4e desirelWRIy el ve t

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h. Standasde for Indivtduas reev==ida-odequeaycrittsidstlog charevotistics Mor J,;ose C=y

'LF m4 For these seassee6 theMRCle- - endithe NRCatonhaei Olse p) Niemorical dose limite (hrearresif Init!ating a estemskingpressedhgfor following staammeta ofpoposefeeNRC tw*m==d andla combinoden)for A'{ the purpose d modamistag fu malatica. radiaelan pe=*= d== ctandarde-. ~ pecific theeperiods. T s p.a6 standards itto e-t-re=d that this rulemaking p will be - WMitCesem forprmecuou (2) Checideration of special previsione 7 asetanr=a=w badhaft specate for Intflag exposaree of susceptible complex and ces To provida p..ma-w and peuesdare6 requaeseente, groups (ets, enrbryo/feten womseim j o i for theearliaet peeseble ambas y ;, and thstr Ibesse(that wel gassess edequem seassel. Aprtue womes and =iname) ,,[. '9' 'E. a

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Federal Register /'Vol. 48. No. 55 / Thuredey.. March 20.'19e0 /4 Proposed Rules (2) Deelved limits for concentrat[ons '. 'd applicable laws being taken into (10) Procedures for responding to. air and water should be '* updated" or Q' L. secount. emergency s&fustions replamd by annual limf to for intake. (3) Controls foe tranelent workers. (11) Procedures for radiation (3) Standards appucable tn emergency 1; -Q contract workars, and " moonlighters". protection oe owerexposura situations should be hteI]h'( I4) Dettved standards. 84t. maximum (12) Procedures for==naging permisatble concentration (MPC), overexposures prescated. .4 (4) Spedalprovisions to Ilmit _. 3 (13) Procedures for radioective waste collective doses should be considered. b ^ rw sarfact contamtnatica in restdcted. disposal' (5) Special provisions for timf ting h'df?' ' erposures and overexposure situatiorm (1)!ndividuaf doses (internal and embryo / fetus, women in general fertile steas. annual limita of intakes ( All). - M (5) Proviasons for piaaaad special

e. Record Keeping Requirements :

Wee should teclude: exposures of susceptible groups (e.g. d M s8b.d (8) Provisions for emer13ency external) and bases for estimates women and minors) should be i (2)!dentity and quantity of -Sd under appucable law. a 'M'r f General Public contract workers, and transtant workers exposures.

c. Standards for Exposures of the radioactive matedals reisesed to the (6) Contzels for " moonlighters",
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Dese should include: (3) Survey and monitoring results should be stnngthened. (1) Numerical dose liraits (laternak (4) Disposal oflicensed material

c. Standards for Exposure of the

-Q external. and in combinati.m) for (5) Receipt, transfer, and inventory of GeneralPublic M specific time periods'lacluding radioactive material (1) Additional consideration should be %y consideratton of spedal population L Reportmg Requirements given to exposure pathways to man d 'pp, These abould other than by air and water intake. 4' ) Ef!!uent release limits including (1) Raan=a ofoccupational (2) Derived lizalts for concentrations in 1' 4] doses (!Maa bothinternal and ' air and water should be ** updated" or replaced by annual umits kr Intake. c. ble) and

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-(3)Spedal peovielons for limiting ( considerstion of specialpopulation (2) Ovevexpoeure reports (3) Reports of afDuents re!.ased to the exposures of susceptible groups (e.g. i.j c y,.m wassen in generaLfertile 4' 3 dved stedaada, taking inta envir oment .r s account major exposure mde d (4) Reports of then or toes of' women and minors) should be

  • g, pathways, e.g. MPC air. MPC water, ndiscun mdd MW & a lk a ls W.

E Mand a fo censee acdon (4) siderations. including opplicable to emergency or bi spectal popuistion groups for licensed Atees In Part 30 mt Need re situations should be o .j facilities and activities other than LWR tropro w nset Bdeed partly on the NRC staffs wiewe (5) Standards for environmental e.g power stations. - oo the necessary alements of a revised - monitorms for either routine or accident (5) Emergency dose limits refketinS f<;g Federalguidelines. Part :u) as presented above, and also on conditions should be presented. il y>.y .g (6) Limits of contamination for the a critical =a==alkon af the present d.Raquirements for a Radiation '. I gl,.4 release of material for unrestricted use. Part 2E the following het of amas whase Protecnoa Program pa j ' (7) Litnits for burial of radioactive Part;u)couldbe knprovedhasbeen. D) h basic slaments of an I weste in other than licensed burial identined, ft would be the latent of the ble fediation protection program -N di5 grounds (Le 10 CFK Part 20,20.304). staN toensure that these areas'em be presented. ..j (8) Umits of coclamination. In terms neolved la a proposed twelalon le Part , e.Rapoetins Requirements g) Reporting of routine internal of concentretion and total activ6ty, for 20. L

.$g;l disposal of material as non-codioactin
a. RadiologicalProtectionTrindples exposures should be required.

waste. (1) N anderlying radiation (4 Reporting of the rupture or failure 'l protection principles adopted by NRC .of*malad radiation sources.

d. Requiremente for a Radiatio.n f Mea =Maneous -

4L Protectien Program should be prnented la terma Tbese should indude: understandable to laymen. (1)The adopdan of SJ (Syetame (1) Traimag mquirements (2)h ALARA principle and Internstlanala) units with related. h (2) Management audits and controle requirements for both afDnants and ooseersion formulas should be -9 (3) Designation and marking of occupational exposures should be

  • MM(forexample radiation rsdistion amas strengthened. Quantitative occupational doses in units of grays and sieverts and

.. m (4) ALARAprogramrequirements ALAllA guidelines should be activity in units of becquerels). including guidance on hfettme estabushed wherever possible for NRC (2) Performance standards (accursey %' j lie==aad facilities. Collective doses and rollebility) for health physics . t.. accumulative dosee measurements should be presented. (5) Access controls.Inc!uding alarms should be addressed. ~ (6) Personnel doelmetry requirements.

b. Standards for!ndividual (3)b technical bases for numerical

' N',C (for both in arnal and external 0--*aA Exposum limits should be readily identifiable. W exposures) Was performance (1) Consideration should be given to It must be emphasized that the items standards for heelth physics. dopting the ICRP rs====adations on listed above do not represent decisions ,d.' -]; the use of "eNective does equivalents" or commitmenta. Rather, as stated measurements (7) On. site radiation and and dou limitations for combined previously, they are the result of a ey contamination measurements internal and external exposures. Present preH=tnary rvview by the NRC staff and (Instruments, performance standards. part 20 does not preclude radiation are pnhBahad at this time to solicit exposure as high as a total of 17 rem of views ofinterested persons not only on t 2 etc.) (8) Environmental radiation combined internal and external. dose to the appropriatenen of the specific items momtonng (off. site) the whole body in a single year. Ls 5 listed but also to fac:litate idennfication (9) Procedures for transportaticn of rem internal plus (3 rem per qtr. X 4 qtr. of further improvements or revisions to radioactive material' =)12 rem external doses. Part 20 not yet identified by the staff. a 6

l ATTACHMENT D a 18028 Federal Register / Vel 45. N:. Se / ThurMay. Marcli 20.1980 / Proposed Rules (Sec.181b. Pah. L 8340s, he Stat, ese (42

unav tilability of that element of the engagement between the meting book UAC. 2aot(b)Dec. 201 as ameded. Pub. !-

evacuation syster2. and pile panels of the device. To establish a consistent breakaway 93-434. se Stet.1242 as essended by Pub. I. .sAtast Centments must be received on d 96-79 se Beat. 413 (42 UAC. seet)l. or before May 26,1980. for the trackingdevice and thus aesese $ Deted at Betheeds. Maryland, tide 7th day e..., Sad connects on th proper tracking of the ramp during ?. of Much teen. - prop sal t,.x Department of deployment of the evacuation system.M For the Nuclear itsgulatory Codadaa Transportaticr Federal Aviation now tracking device has been developed which stiliza a frangible link anem waam J. Dercke. Adriinistration. Wastern Region, t which sepenta consistently et a A ctins t.ucucir, anctorfbr operetions. Att6ntion: Regional Counsel. truo.as iru.s m e g Airhorthiness Rule Docket. P.O. Box. pmdetermined force within a tighter q eu,e coes r e,.m 92007. Worldwey Postal Center los tolerance range than the velcro 9 l Ankeles. California 90009. conaguration. r.I J jThe ap Since this condition is likely to exist - ? rney be oglicable service informationa hh on & aW & sans j ) tained hm Air Cmisers SMA1.1. BUSINESS ADMINISTRATION Company. Post OiB:e Box 180. Belmar. type design the proposed AD would g 13 CFR Part 121 New Jersey 07719. require modification of the trackin8 i restraint device on the affected g ,,, m ,,,,,,,,y,,,,ee,,m. _- ~ M'_. iv seiemod EstabNehing StM Jerry Preeba. Executive Secretary, evacuation systems on McDonnell .c Standards and Definitions of Smed Airworthiness Directive Review Board. Douglas DC-10 Settes Airplanee. 1 Busino.a; Correction Federal Aviation Administration. Proposed Amendment "ld assocyt Small Businses Administration. W*e torn Region. P.O. Box 92007. World ^ Ac7tosc Advance Nodce of Proposed Way Postal Center. Ioe Angeles. Accordingly, the Federal Aviation Administration proposes to amend 3 Rulemaking--Cornetion. 90009.(213) 536-4351. 8 30.13 of Part 39 of the Federal Aviaticed surnassesTAfMlesposetA7 tost Regulations (14 CFR 3913) by adding the i suesssasm On March 10,1980, there Interested persons are invited to following new Aftworthinese Directive: U appeared in the Federal Register (Vol participate in the==hing of the 4

45. No. 48) posal to amend the SBA proposed rule by submitting such ggytoMcDoanst,

g j size atand la i 121.2. on page 15450, written data, views, or arguments as middle column. under the Meding Major they may desire. Interested persons are 30.-30F and -40 Series AirP anes '3 I Croup 78--Motion Pictures, the also invited to comment on the certAcateOn au cakgwin uWng Airg proposed size ' standard for SIC-7819 economic. environmental and ene Cmisen Pam 261 sedu .-) anger avecuadon systems we the Services A#/ed to Afotion Pleture frapact that might result because - foHowing suial12umbem g ,i Production, was erroneously printed as adoption of the proposed rule. Left NondDoorr Air Cruisers Company P/ 5 employees. %e proposal is corrected Commimications should identify the to reed 50 employees. ~ tory docket number and be 2afwnat udes, aD serial nambero prior to - S/N 1531. except 150s 1514 tsit 1515. pon rusmeen neronesavton coeryAcT1 s tted in duplicate to the addrese tats,15:1.1s.:3 and 1sas. Kaleel C. Skelrik. (202) 853-4373. 8pecified above. Allcosununications AlgbrHandDoorr Air Cruisers Compa Deted: Meech 11.tasa received on or before the closing date asD3cos eartw. au =dai numbers prior to l Oleta F. Waugh, for conunents wu! be considered by the S/N 1830. exwpt teos,1811.1813.1815 'i federu/4/sterLidm@m Ariministrator before taking action on 1819.1821. and 18 3. 2 Comp ance required withis next elshteen N the proposed rule.The proposal U ^ "* "" '""".ew"* ** "I contained in this notice may be changed (ts) calendar months after the e5ective date. meAme coes me e in light of conuments received. All 'I8hi* AD *"3**e already accomplished. To prevent improper deployment of the Air ) comments submitted willbe a.vailable. Cruisere Company emergency evecuatloa g yore and after the clooms date system due to deby in u no a for comments.in the Rules Docket for volcro tracking ruwaint Nee, n of the DEPARTMENT OF TRANSPORTATION accompush 4 Federed Avletion Adtninistregon exarninstion byl'nterested persons. A the fonowtng: report summarising each FAA-public

s. Modify the a5ected evacuation system 14 CPR Poet 3p contact, concerned with tee s'ubstance.

asumblies in accordence with Part ?. of the proposed AD. will be Eled in the Accompliaha==et Instructicos. of Alt Crufears (Decket No. 9 J-Ws-4-AD] Rules Docket. Company Service feu11 erin No. 25-75 deted During production test deployments of Nuery an 1 sea Altwortf**essee Otractives; McDonnell Air Cruisers Com slide / reft asht persuts may be land la % Model DC-10 Sortes Airplarwe evacuation syst a installed ~at the No. opers a for he 7 Ac esev: Federal Aviation-3 door on the McDonnell Douglas Model accomplishment of modiacenons required by ' Adminletration (FAA) DOT. DC-10 aircraft three units deployed thie AD. Actiosc Notice of proposed rulemaW s. I'nproperly over the leading edge of the

c. Alternat4ve modifications or other i

wing between the engine naceDe and the actions which provide an equivalent level of safe may be need whe1 approved by the sussesAsrvt This notice proposes to adopt fuselage, renderir.g the escape device Cue { Alrean Enstawnns Dension an airworthiness directive (AD) that unusable. Upon investigation it.was would require modification of the ramp determined that the mistracking was-assembly on certain A!r Cruisers due to e deley in the seperation of the (Sees. 313(a), ect, eG3. Federal Avtetfos Act Company evecuation systems Installed valero tracking restraint device which is ((,,'[e7o $8;fTr Is on McDonnell Douglas Model DC-10 designed to provide proper tracking of Act (se U.S.C. toss (c)): to CFR 11.ast Series Airplanes.De ADis prompted the ramp along the wing surface. It was Neee-The Federal Aviation by reports of titree instances of. further determined that the force Admuustration ha determined that this overwing slide /reftimproper, required to disengage the velcro can document involves the proposed regulation deployment which could result in vary depending upon t])e degree of which is not considered to be sientacant u -.

The NationalLJnderwriter Mo'ch 2I,1980 Prom rY & CA5UALTY IN5URANCE EDITION 84th Year, No.12 4 proach the Price-Anderson programa's industry that is subject to auch a po- $MO million ceiling on liabality." ientian catastrophic loss," he told re-He cited as major concerns of the [ y g g Of porters, adding that "the risk is great industry about the Udall bill, which and extremely remote" By MARY JANE FISHER In addition, he said that ANI win 'Mr. Proom proposed an increase in he suud "goes much too far in several increase individual plant ratings for the' Federal government's share of respects," such as: w.as.ss c.n 4,,,

  • **Ihe elimination of the extra-nuclear insurance on Jan.1,194t.

liability risk under the Act from the current $80 million to $500 million, ordinary nuclear occurrence thres-WASHINGTON-The average prtp-he property insurance rate in. crease will mean that the average which would bring the total liability hold in connection with the concept , erty maurance premium paid by nu- = clear power plants will increase about prem'um wl rise from the current protection la $.1.5 billion from the of absolute liability fo. the nuclear. 3 $3% this year as a result of the nree $900,000 to f; million, according to Act's current $540 million. industry;

  • "ne extension of the statute of g

Mile Island nuclear accident, Burt C. Mr. Proom. The property insurance ne nuclear power industry pro-limitations for all nucleer claims to -a ? Proom, president of American Nu-Increase included a decrease in the Posed increasing the retroactive as-clear Insurers, said here Tuesday. annual premium refund from 1979's sessment of $5 snillion per reactor 40 years! At a press brieAng to discuss cur-23.5% reduction to 14% in 1980.

  • **The increase in the retrospec-rent developments in nuclear insur-
    • The major contributing factor to

( under current law to $10 million at ance, such as " lessons learned

  • from the reduction in credit, effective Rep. Udall's Energy Subcommittee tive premium payable for each large hearing on his proposed amendments scale nuclear power reactor frogra a to the Act. With 88 reactors slue to maximum of $5 million ti $20 mil-TMI, factors affecting future growth March I,1980, is the hree Mile Is.

of the nuclear insurance pool, and land property loss of anh 28,1979 = come on line, the increased retroac-tion for each nuclear incident; and tive assessment per reactor would

  • "The exclusion of claims adjust-ongoing hearings by Congress on pro-the ANI said in a back $hnd briefing posed legislation to modify the 1951 paper.

amount to $720 milliog pdding to ment costs from the amounts of S-Price-Anderson Act, Mr. Proom said The 1979 premium refund amounted the total liability protech6n under nancial protection required and the to $11 million. Total refunds since - limitation of liability." liability rates for nuclear power plants also rose 10% on Jan.1. Cont'd on Page fo - the Act, Speaking for ' ANI, MAERP, the Predicts Nudear Rate Rise Of 63Y ^ -- ' -- ^

  • ^= ional American Insurers, and the Nat

, Assn. of ladependent Insurers, Rich-Cont'd fron Page 1 year and liability premitana, $17 mll ' ard: A. Schmalz, general counsel of l 1972, when the reduction program be-tion. Total insurance! avellability is Hartford Accident Is Indemnity, told San, have been more tha'n $$4 million. $300 million for property insurance the subcommittee that "the nuclear Depending on generating capacity, and $30 million for liability 'insur-pools rem &ln coAndent that nuclear single-unit nuclear power plant fa-ance, per insured, plus an additional. Power can be developed safely." cilities pay between $750,000 and $1.5 contingent liability of $30 million. The insurers earlier advised the 1 million in annual property insurance ANI has set asidc $200 million in subcommittee that'the Three Mile It-premium to the nuclear insurance reserves to pay for TMI property land accident "would ultimately con-1 pools-ANI, and the mutual pools, damage, the estima&d amount cf Arm the soundness of the Price-An-h Mutual Atomic Energy Liability Un-claima payable, with a total exposure . derson program." Mr. Schmalz. was .7 ae ompanied by Joseph Marrone, vice + 4 i derwriters (MAELU), and the Mu-of $300 million, accordi9g to Mr. president of ANI, and Ambrose B. l tual Atomic Energy Reinsurance Pool Proom. c He reiterated the nuclear insurers

  • Kelly of the MAERP.

(M AERP). ANI "is in the process of beefing testimony at a hearing on a bill in- "The pools can report today that - up our nuclear engineering program," troduced by Rep. Morris K. Udall despite the very large on-site loss at g Mr. Proom told reporters. "We now (D.-Ariz.) House Interior Committee Three Mile Island and the claims have some 18 nuclear engineers and Chairman, to raise the liability limits filed for off-site injuries and damage, we expect to increase that number to of the Price-Anderson Act that the they have been able to ntaintain their p PJ a complement of 40 on our nuclear Federal government should share re-capacity for 1980 at $180 million for engineering staff." sponsibility for indemnification for third-party liability claims and $300 Another premium increase this year nuclear power plant accidents. million for property damage," Mr. d i-cited by Mr. Proom was for builders' "We feel the government should be Schmalz sud. j t=3 risk coverage which will rise about a partner in this program-with the "We believe that the funds needed 41% as a result of experience rating, insurance industry and power com-to tutty compensate all injury or he said. panies." he said. damage to persona or property re-I ANI annual property insurance pre- "There should be some kind of sulting from the incident wall not ap-miums amounted to $34 million last government protection scheme for an l ,}}

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