ML19330C192
| ML19330C192 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/25/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8008080051 | |
| Download: ML19330C192 (63) | |
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NUCLEAR REGULATORY COMMISSICN THIS DOCUMENT CONTAINS POOR QUALITY PAGES COMMISSION MEETING
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PUBLIC SEETING~
DISCUSSION ON INDIAN POINT s..
g July 25, 1980 pgggg 1 - 46 Washington, D.
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- 1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSICN
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- 4 PUBLIC HEETING 5
DISCUSSION ON INDIAN POINT 6
7 8
Nuclear Regulatory Commission 9
Room 1130 10 1717 H Street, N. W.
11 Washington, D.
C.
12 13 Friday, July 25, 1980
.I 14 The Commission met, pursuant to no tice, at 2:35 p.
a.
15 BEFOREs 16 JOHN F. AHEARNE, Chairman of the Commission 17 VICTOR GILINSKY, Commissioner 18 PETER A.
BRADFORD, Commissioner 19 JOSEPH M.
HENDRIE, Commissioner 20 NRC STAFF PRESENT:
21 LEON ARD BICKWIT, General Counsel 22 M. MALSCH 23 A.
KENNEKE
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24 25 ALCERSON REPORTING COMPANY, INC.
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This is an unofficial transcript of a =aeting of the United States Nuclear Regulatory Cc==ission held on July 25, 1980 in the Coum:ission's officas at 1717 E Street, N. W., Washington,
' D. C.
The meeting was open to public actandance and observation.
This transcript has not been reviewed, correccad, or adicad, and it may contain inaccuracias.
The transcript is intended solely for ganaral infor=aticual purposes.
As providad by 10 C7R 9.103, it is not par: of -de for=al or informal record of decision of the mattars discussed.
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Expressions of opinion in this transcript da not necessarily reflect final determinations or be11afs.
No pleading or other paper may be filed with the Commission in any precanding as the result of or addressed to any stacament or argn= ant contained herein, except as the Commission nay authorize.
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CHAIRMAN AHEARNE:
Ihis afternoon, the Commission 3 meets to continue its discussions on the matter of the 4 - Indian Point rea ct ors.
Some time ago, we did reach a 5 Commission decision to allow interim operation.
We are now 6 in the process of trying to come to grips with what specific 7 set'of directions we should give to the licensing board tha t 8 we also had previously agreed would be set up.
9 At the last meeting. we had agreed to reconvene 10 today to address specifically the questions that had been 11 given in the Ccamission 's order that had gone out on May 30, 12 and in particular to address any changes or modifications 13 that any of the Commissioners might suqqest, and we also i - /
14 were to have thought through whether we could establish a 15 set of criteria-that the boa rd might use for decision L6 criteria, or that we might use, and thereby instruct the 1
17 board to work off of that basis.
l 18 The memos that I received on July 22, Commissioner 19 Hendrie distributed some comments addressing that issue, and 20 a few minutes ago Mr. Bradford distributed a set.
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21 counsel, do you have any other information, or have you 22 thought of any additional medifications, or do you have any 23 more thoughts on the decision criteria?
24 MR. EICKWIT No, I have received no other g
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25 inf o rm a tion.
As f ar as decision criteria are concerned, I-
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'(s 1 think what was ;ut forward by our office at the last meeting 2 plus what was -- has been distributed constitute the various
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3 choices available to - the Commission 4
The only other thing I would say is that I think 5 the logical progression ought to be to deal with the 6 criteria before you deal virh the question, since the 7 criteria -- if you proceed logically, it will shape the 8 questions.
So, I would make that recommendation, even 9 though it may be easier to deal with the questions, and we 10 all have thoughts on th o se, whereas the criteria -- shaping 11 the criteria'is a harder task.
That is the order I think 12 you ought to proceed in.
13 CHAIRMAN AHEARNE:
I Tuess what I would first ask, 14 since I view this more or less as a discussion meeting, I 15 vill ask each of the other Commissioners if they have any 16 general or specific commen tr.
Vic?
17 COMMISSIONER GIIINSKY:
I don't have anything to 18 ay at this poin t.
19 CHAIRMAN AHEARNE:
Joo, do you want to address 20 your succestions?
21 COMMISSIONER HENDRIE:
Yes, I would like to.
22 Fi rst, however, I would like, in th e ealm of 23 related matters, to ask the general counsel, we havo
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24 received-recently, this morning, in my office, a motion from j
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25 the licensees involved at Indian Point for -- askinq for 1
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1 reconsideration of a portion of'our May 30 order that 2 directs an adjudicatory hearing on the Indian Poin t units,
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3 and raises various arguments as to why th'e y think that 4 proceeding, if there is to be one, ought to follow a generic 5 proceeding to establish general requirements of whatever 6 kind on hich' population density sites.
7 Nov, we have all been down to a Congressional 8 hearing thi s mo rnin g, and I ga ther by the blank locks at 9 your end of the table --
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10 (General laughter.;
11 COMMISSIONER HENDRIE:
-- that for a change I am 12 two minutes ahead of you on this subject, and the nature of 13 the questions that I had about this thing had tc do with, I f
14 quess I will say litigation risk, and by that, I am not sure 15 all of the things I mean -- you know, I picked up these 16 terms of art from another field and use them probably 17 indiscriminately, but in particular, we ought to have not 18 necessarily - - I don ' t think we need to have it here 19 particularly, because this discussion can go on, I think, 20 r ea so n ably anyway, some judgment as to whether -- what the 21 merits of-the motion for reconsideration are, and if we 22 reject it, I guess.
23 Does that provide opportunity for the licensees te 24 ask for review, judicial review, or do they have to sit out x
25 th e end -- to -he end of the whole adjudicatory proceedinc?
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That is, I am curious to know, A, is there 2 opportunity they have in your judgnent for judicial' review
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3 of what amounts to the - Commission 's decision --- what might
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4 be the Commission's decision to go ahead with the 5 adjudication, and then, of course, we are always interested 6 in your assessment of the likely outcome of those kinds of 7 reviews.
8 ER. BICKWIT:
I would pref er to read the motion.
9 COMMISSIONER HENDEII:
I would think so.
o 10 MR. BICKWIT:
I would be happy to get back to you 11 as scon as I can do that.
12 COMMISSIONER HEUDRIE:
I think it is a reasonable 13 thing to deal with the next time the Commission is able to
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14 gather on Indian Point.
In the meantime, I do not see that 15 ve are or ought to be precluded from going ahead and 16 exchanging thoughts on criteria and so on.
1:7 Gkay.
With regard to criteria, it seems to me
_18 that we come to-the Indian Point -matter, because it is a 19 high population density site, that the proposition before us 20 is whether the risks associated with the IP units are out of 21 line - with the range of risks that are there at the run of 22 operating sites.
23 It seems to me, then, that the primary - decisicn 24 criteria ought simply to be, and I would put it in terms of 3 individual risk, whether the risks tc sn individual who ALDERSON REPORTING CCMPANY, INC.
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y 1 - lives in.the IP -- Indian-Pcint. vicinity are substantially 2 greater than the range of. risk to individuals around other T
.3 - sites, taking into account, cbviously, the Indian Foint 4 designs, proposed-fixes, the emergency planning reasures
-5 presented and planned for the high population.
6 Now, we talked the last time, and Vic suggested --
7 I don't think he was against an individual risk criterion, 8 but suggested tha t there occht to be also some kind of 9 societal impact criteria.
10 One way to phrase it, I guess, would be in terms 11 of the population radiation exposure, and my view on that 12 is, while if I were writing the proposition all by myself, I 13 quess I would~ stick to individual risk, nevertheless, the 14 societal impact point is not an unreasonable one at all.
If 15 we included it, my inclination voud be to make it a 16 secondary criterion, since I think the individual risk 17 proposition is rather more in keeping with just the general 18 tradition of American practice.
19 And then there are some details about how you 20 would' frame that societal risk.
As I said last time, I have 21 an aversion to these integrations which go out over great 22 distances, and then result in adding up very small exposures a to very large numbers of pecple.
24 So, I would be inclined at first blush, at any 25 rate, to propose some sort of cutoff on that integration, l~
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7 1 but that would be a matter T would think that one would be 2 interested in hearing f rom staff who have thought about it a f
3 while as we went down the line and get a better sense of 4 what the ramifications of the cutof f on the integration 5 might be.
6 CHAIBMAN AHE'ARNS:
What, Joe, do you see'as being 7 the way you would get at t'ais?
I gather what you are saying 8 is that you do not basically disagree with having a double 9 set of criteria, one on individual risk and one on socie tal 10 risk.
11 COMMISSIONE3 HENDRIE.:
I don ' t basically disagree,
12 because there are perfectly good and respectable arguments 13 for the societal one, and I think the individual risk
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l 14 criterion is clear.'y -- you would not care to go with just 15 the societal one and say we don't care about the 16 in divid uals.
It is just whether the society as a whole 17 CHAIRMAN AHEARNE:
How would you get to where we 18 would reach a decision on what those criterion are?
.19 COMMISSIONER HENDRII:
As I said in my note, I j
20 thought I could rephrase the six questions in the May 30
. 21 order in much better shape, and the more I tried that, the 22 less satisfied I was with the results, and the more 23 impressed I was with the collective wisdom we managed te 24 manif est in the Ma y 30th order, and I would keep these basic
- 25 six questions.
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1 There are a ' couple of places where I think some 2 adjustment would be appropriate, and.also if we are able to
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3 ' agree on the general direction of some criteria to be 4 included, then probably some further elaboration of 5'Cuestions 4 and 5, particularly to give guidance on the sort 6 of measures to develop the societal impact data would be 7 appropiate.
8 CHAIRMAN AHEARNE:
Yes.
I recognize that is where 9 your memo came out.
How wocid you go about developing the 10 individual and societal criteria, or would you not need to --
11 COMMISSIONER HENDRIE:
I would not attempt to put 12 numbers in them, or -- for the individual risk one, I think 13 all that is needed is to say tha t the primary decision i
14 criterion will be rather the risk to an individual in Indian 15 -Point vicinity is substantially greater than the range of 16 risk to individuals who live around other sites, and I would I'7 not see a need to go beyond that.
18 The questions are already phrased. in a way to 19 develop the sort of information that would allow you to make 20 that judgment, and I would phrase, the societal one in-just 21 the same way, but I think 22 CHAIRMAN AHEARNE:
Whether the societal risk is 23 any greater.
24 COMEISSIONER HENDRIE:
I think there one has to 25 think, and we would have to develop some more information 1
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l'about whether -- about the integration question.
Do you 2~want'to~1nteq ate sort of all.the way around the globe, er Jf' 3 would you'vant to cut it off so tha t the doses were mo re 4 meaningful on a site specific basis and then --
5 CHAIRMAN AHEARNE:
In other words --
I would not feel the 6
COMMISSIONE3 HENDEIEs 7 need to write the criterion out in great and excruciating i
8 detail, because I think 9
CHAIRMAN AHEARNE:
A qualitative description of 10 the integration and cutoff -- you might not need to do that, 11 once you do it with comparison to other sites.
12 COMMISSIONER HENDRIEs I think that is right.
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- 13. would like to hear from the staff -- some best judgment from l
14 people who have recently done this. kind of calculation.
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15 much the tail effects are.
Cne of the questions I have, if 16 you carry the integration out to arbitrarily low doses, l'7 carry the integration over a distance around the globe, it 1
18 seems to me there is a good possibility that sites become 19 indistiquishable, and that you lose the meaningfulness cf 1 the societal impact.
11 I think -- you know -- but I do not know that to
!n be a fact, and tha t is what I would like to hear before one 23 -decided on that what some of the experts think.
24 MR. KENNEKE:
- he draft addressed that a little
.s. bit.
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CHAIENAN AHEARNE:
Your basic poin't is, it is a 2 comparison rather than an absolute.
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3 COMMISSIONER HENDRIE:
I think at this stage it 4-has tc~be a comparison.
The Commission has enunciated no 5 absolute standard.
The Congress has enunciated no absolute 6 standard we have set for ourselves as one of the tasks 7 resulting f rom our re-examination, the things af ter Three 8 Mile Island, trying to enunciate a standard, and I think to 1
9 try to incorporate that very dif ficult sort of proposition 10 into this adjudication is just beyond the reasonable scope 11 of the adjudication, and so I would make it on a relative 12 basis, and so what that means is that ul tina tel y, with the 13 hearing record before us, the board summaries and 14 recommendations, we would have to try to decide what we mean 15 by risk either to individuals or a societal risk, 16 substantially greater than the run of corresonding risks at 17 other plants.
18 CHAIRMAN AHEARNE:
Peter?
19 COM MISSIONER GIIINSKY:
If I could make a comment, 20 Joe, if you look at the environmental reports and look at 21 the Man Rem calculations out to 50 miles, nost of them
- 22. converge to that distance, like Calvert Cliffs.
Ycu pass 23 '4a s h ing t o n.
The number is still increasing, but I think if 24 you go helond' that, they dc decrease.
You do not get into 25 th e problems --
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COMMISSIONER HENDFII:
You do not think ~the tail 2 dominates that?
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3 COMMISSIONER GILINSKY:
I don't think so.
4 COMMISSIONER.HENDRIE:
That could very well be the 5 case.
The dose is dropping
.6 MR. KENNEKEs Page 6 of the draft addresses that.
7-COMMISSIONER HENDRIE:
Page 6 of what draf t?
8 MR. KENNEKE:
Of'the ceder, the bottom of Page 6, 9 the top of Page 7, talking about latent cancers doeinated by 10 the population within a 200-mile radius of the plant.
11 Because of this, the individual site risk curves for latent 12 cancers reflect the character of the region.
The latent 13~ cancer risk f or these sites and probably all other sites is 14 ap p ro xim a tely the same.
15 COMMISSIONER HENDRIE:
That does not exactly 16 correspond to Vic's remark.
17 COMMISSIONER GILINSKY:
I was talking a bout no rmal 18 releases.
19
. COMMISSIONER dENDRIE:
And primarily whole body 20 doses, _I would think.
21 COMMISSIONER GILINSKY:
I was not talking about 22 routine releases.
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- D CHAIRMAN AHEARNE
Peter?
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COMMISSIONER 3RADFCHD:
On which type of risk ve i
25 are interested in, I think I come out not too differently ALCERSCN REPORTING COMPANY, INC, j
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12 1 from Joe, but that depends on my having understood him 2 correctly.
I think both standards are applicable.
I think
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3 that if you ask yourself whether, for example, you had a 4 core melt accident and significant fission products were 5. released and everyone around every site could be assured of 6 being successfully moved away from it, night there still not 7 be societal consequences in terms of areas left 8 uninhabitable.
9 There might easily be some areas that that would 10 mean an awful lot more to the country than o thers, so I 11 think.there is a societal risk component that goes out 12 beyond just the numbers of people exposed in the first 13 rounds-that you might get by adding up or multiplying the 14 exposure times to'the number of people.-
15 So, I do think there is a legitimate question on 16 societal risk to be asked.
I have choppad a wa y at it a 17 little bit in my meno that I sent around rather late in th e 18 game.
19 CHAIRMAN AHEARNE:
I guess without any 20 em ba.rrassmen t I can say I really have not had a chance to 21 read the memo.
22 COMMISSIONER ERADFORD:
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23 ' emba rrassed to say that, including me.
I 24 (General laughter.)
s CHAIRMAN AHEARNE:
So -- but are you saying that ALCERSoN REPCATING COMPANY, INC.
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1 ~ tou would not disagree vith Joe 's approach of a qualitative 2 standard which is by comparison to other sites?
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3 COMMISSIONER BRADFORD:
That is certainly true 4'with' regard to individual risk.
5 CHAIRMAN AHEARNEs And if you,tc the asterisk
-6 caveat on the potential property issued --
7' COHEISSIONER BRADFORD:
It is also true with 8 respect to societal risk. The comparison to other sites i
9 gives ycu at least this much comfort.
If it turns out that j
10 Indian Point is no worse than other sites on either societal 11 or individual risk, then it seems to me that in moso 12 respects th e proceeding is decided, putting aside the 13 question of compliance with the regulation and other points 14 outside of the risk calculation that would get broucht up.
15 It does enclose it at the other end, that is, if it is
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16 some wha t more risky, you hafe not therefore decided I'7 automatically that continued operation is out of the 18 question.
It z.ay help you make some decisions about 19 specific techn,1 cal fixes.
20 COM?fISSIONER HENDRIE:
It is clear -- I think it 21 is clear enough, at least it is clear enough to me that 22 there is a range of risks from the operating plants, and 23 that means some facility vill be at the top end of the 24 range, and I am interested in knowing whether Indian Point 25 is up here and the range is down here, or whether Indian l
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~1 Point is down here or like that or maybe just the top one, 21 and you.know, some sense of what that difference is would
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3 then' be what I would use in forming a judgment about whether 4 the risk was unacceptable or not.
5 Now, if we decide tha t it is within the band of 6 risks of other plants, then it simply gets thrown into the 7 basket of all ether plants, and at some time, as we try to 8 formulate what we think is a -- you know, is the best 9 enunciation we can give of the safety goal, what adequate 10 protection under the statute means, at least in principle, 11 you know, it is possible for us to decide that the whole set 12 of operation plants needs improvement by some f actor, and 13 this one along with the others would have to improve.
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14 CHAIRMAN AHEARNE.
Vic, you were sort of the 15 principal initiator of this concept of - the decision 16 criteria, so now Joe has proposed a concept which Peter, at 17 least, is tentatively moving towards.
18 COMMISSIONER BRACFORD:
I think we would both 19 agree that there is a limit to it.
Even if you knew that 20 Indian Point was four times riskier than other sites, we are 21 no t sure what that means.
There still has to be some 22 absolute concept of how much is too much.
23 CHAIRMAN AHEARNE:
How would you propose to get
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24 th a t 25 COMMISSIO!iER BRADFORD:
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.1 thing I have not been'able to -- I have not been able to 2 answer 'the question.
What specific showing would it take I
3 for me to. decide that the plant had to be shut down?
It 4 ~goes scmething like -- you know, for one thing you have to
- 5. state it partially in terms of ability to fix, and so it is 6 really what unfixable maximum is too much, and~I have not 7 got a neat formula in terms of blatant cancers, immediate 8 deaths, and property damage for you to consider as being the 9 absolute cutoff.
10 CHAIRMAN AHEARNE:
Do you believe that such would 1
11 be necessary before the board begins?
12 COMMISSIONER BRADFORD:
I would rather have it i
13 before the board begins, but I don't think it is absolutely 14 necessary. If we can propound clearly the quest' ions we want 15 the board to take evidence on and the areas that we want 16 tentative findings in, then it is not necessary, because ve 17 are -not asking the board to develop the standard itself, but 18 'it is necessary for us to be specific in the duty that we do
- 19. assign to the board.
20 If we were to assion them the ultimate decisicn in 21 the. case, then it would be necessary.
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CHAIRMAN AHEARNE:. Do you disagree with that 23 : direction ?
A 24 COMMISSIONER GIIINSKY:
No, I think this is a 25 usef ul direction, and I think that -- I do think that we i
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16 1 need to give the b.Tard some guidance on what our concerns 2 are and what might cause us to go one way or the other
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3 before this proceeding gets going.
4 I don't think these are going to be numerical, or 5 they maylhe as general as Joe has-proposed, saying we might 6 act one way or the other if the individual or collective 7 risks were significantly greater in this case than the 8 typical case.
9 So, do think we are heading in the right 10 direction th ere.
I don 't have a specific proposal, but I 11 think the whole proceeding vill be a very much better one if 12 ve have made clear what our concerns are and why we are 13 having this proceeding, and what even if only qualitative 14 criteria ve have in mind.
15 CHAIRMAN AHEARNE:
I have no difficulty with Joe's 16 qualitative decision criteria proposed -- the comparison --
17 as I said last time.
I don 't see how we are going to get 18 the specific set of criteria, and I really am concerned that 19 if we try to get numeric values, for example, in order to 20 generate those in any way th.at I think would be a reasonable 21 approach, it would significantly postpone getting on with 22 the hearing.
In fact, the more I thought about it, the more 23 I began to conclude that if we really had vanted tc develop 24 any. kind of nunerical criteria, it is not unlik e the generic 25 high population density rulemaking.
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1 COMMISSIONER GIIINSKY:
It is not clear that that 2 is even feasible.
I mean, it does also suggest a degree of f'
3 precision in all this risk assessment, which I think is not 4 th er e.
5 CHAIRMAN AHEARNE:
I am glad to hear you say that.
6 COMMISSIONER HENDRIE:
I think that is righ t.
7 CHAIRMAN AREARNE:
That is three of us.
8 COMMISSIONER BRADFORD:
I was not disagreeing.
o.
9 COMMISSIONER GIIINSKYs When we talk about the 10 risk being greater or less than or significantly creater 11 th a n the risk a t a typical plant, we are talking about 12 rances, particularly when one is talking about the product 13-of large consequences, very small probabilities.
- Ihere, 14 those numbers are very soft.
15 CHAIRMAN AREA RNE :
Right.
16 COMMISSIONER GILINSKY:
And for that reason, I 17 vonder whether -- well, I think one wants to phrase even the 18 criteria such as Joe laid out, the risk being greater than 19 or significantly greater than -- phrase those pre tty 20 ca re f ully, in that these risks will be really rances of 1
21 numbers.
They are not goino to be precise numbers.
22 CHAIRMAN AHEARNE:
They won't be believable if 23 they are.
24 COMMISSIONER GIIINSKY:
And l
1 25 CHAIRMAN AHEARNE:
Well, let's -- I guess the I
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1 assumpt.'on I will make is that we seem to be going in the 2 direction of establishing that qualitative description as a
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- 3. set of criteria. I imagine they would still have tc get 4 something in writing.
5 COMMISSIONER GILINSKY:
I also think that Peter 6 raised an important point in speaking not only of people 7 getting irradiated, but property in the areas getting 8 irradiated.
From what we heard from Bob Bernero, the 9 estimates for the economic damage have been understa ted in 10 most of the studies that have been done.
And the ability to 11 carry out clean-up operations seems to assume it to be 12 easier than in f act it would he, and that is something I 13 think one wants to take into account.
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14 When we talk about societal risks, I think we had 15 better talk about economic risks, too.
16 CHAIRMAN AHEARNE:
I guess we really oucht to move l'7 to at least some discussion of the questions, because I 18 think I will at least ask Commissioner Hendrie to take a 19.cr ac k a t putting decision criteria down, and I would guess 20 there will be a lot of additional comments from us on how tc 21 get to that.
22 -
But I do not see any fundamental disagreement with r that.
24 COMMISSIONER 3RADEORD:
You said two criteria, 25 John.
I am sorry.I had not drawn two criteria out of what s
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2 CHAIRMAN AHEARNE:
The individual and the societal.
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3 COMMISSIONER BRADFORD:
Okay.
4 CHAIRMAN AHEARNEs And as you and Victor are 5' leaning toward the societal, I guess mine include the 6 property aspect also.
7 COMMISSIONER HEEDRIE.
When I talk about -- I 8 quess when I talk about individual risk, why, it is strictly 9 a health risk.
It ru :s through, you know, these estima tes 10 derive, starting with WASH 1400 types have been separated 11 out into early fatalaties, early in j u ries, and latent cancer 12 likelihoods, and I guess these are as good a set of 13 cateocries as anything else.
14 So, when I talk about individual risks, I have in 15 mind that sort of catecor12ation under the term " individual 16 risk."
Societal risk, property damage has been included.
l 1'7 When I talk about societal risk, I guess I am willing to 18 look at property damage, although it would be an interesting 19. -- l e t me pose a hypothetical and not too likely case to try 20 the ccunsel.
21 I am enec7 raged, because we deal in unlikely 22 things here.
In fact, we used to have a convention.
23 Whenever we talked about loss of coolant accidents, why, 24 -there was a boilerplate phrase, "unlikely hypothetical."
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20 1 whenever you talked about lesing the water out of the 2 system.
Suppose a set of results came back and within the
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3 sort of-precision that one gets in these things by the time 4 they are shaken down and everyone has had their crack at 5 them and so on, that the health neasures for the unit 6 units came out not to be -- lie probably toward the upper 7 edge of the band, but not perceptably out of the band of 8 other plants, but that the property damage, you know, was 9'well above the band.
Okay?
10 Now, is that an Atomic Energy Act basis for an 11.enfo rcement action against the plant either in terms of 12 requirement for further mitigation measures or more 13 obviously in the limit pulling the license?
14 MR. BICXWIT Yes.
15 COMMISSIONER HENDEIE:
How does it come out --
16 MR. BICKWITs You have the authority to issue 17 orders to minimize and _ pro tect property and minimize damage, 18 minimize danger to life or property 19 CHAIRMAN AHEARNE:
All right.
20 COMMISSIONER HENDRIE God, we have talked abcut 21 -- o ve r th e ye a rs, you know, reasonable risk, and ad eq ua te 22 : protection,. and so on.
I guess I never much thought about 23 th e property side'of it, but it is in the statute.
24
' COMMISSIONER BRADF0ED:
It would stand to reason
.3 to ontinue to talk in terms of the highly unlikely ALCERSON REPORTING COMPANY. INC.
- 400 VIRGINIA AVE; S.W., WASHINCTON, O.C. 20024 (202) 554.-.2345; 4't.
4 21 1 hypo thetical.
Even if you could assure the evacuation cf 2 ?.anhattan, you would note site a-reactor in Central Park if f
3 there were a possibility that you could not then use the 4 place until 10 or 20 years afterwards.
5 COMMISSIONER HENDRIE:
Couldn't use Manhattan 6 again?
Well, gee, I --
7 (General laughter.)
8 COMMISSIONER HENDRIE:
I' vent to school and wo rked 9 in "anhattan for a number of years and lived in Cueens and 10 so on, and have considerable affection for the place, but in 11 another time and at another place, one might debate whether 12 the abandonment of Manhattan would necessarily be an 13 unacceptable societal impact.
t 14 (General laughter.)
15 COMMISSIONER BRADFORD:
I guess I think it would.
16 (Ceneral laughter.)
17 COMMISSIONER BRADFORD:
Having been raised there, 18 but even if I hadn ' t been --
19 CHAIRMAN AH EA RNE :
' Peter, could you review some of 20 the points that you had hoped to make in your memo?
21 COMMISSIONER BRADFORD:
It has two parts.
The 22 first ; age basically has to do with the questions and some 23 underlying assumptions about the criteria.
The second page 24 is just modifications to the order.
The elenen ts tha t we 25 have not touched on that are on the first page, one is, it ALDERSON REPORTING COMPANY, INC.
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22 1 seems to me that as I ask myself what are the requisites for 2 continued opera tion, you not only have whatever the criteria 3 come out to be on risk, but also there has to be compliance 4 with the basic regulations.
1 5
That remains the clearest agency criteria for 6 operation.
We do have specific allegations by a party in 7 the case that there is non-compliance with a t least some of 8 the reos in one of the plants, and -- so it seems to me 9 there ought to be a definitive finding on that question at 10 the end of the proceeding, and the other element that is in 11 my items that is not in any way implicit in the questions in 12 the draf t order is the business of ascertaining the official 13 position of the State of New York, which seems to me to be 14 important in my own efforts at defining adequate protection 15 for the public health and safety.
16 I would at least like th e inpu t of the elected 17 officials most responsible for the governmental aff airs of 18 the impacted area.
We have it from Governor Carey in the 19 context of the interim order, and I think I would like to 20 have it in this proceeding as well.
Obviously, there are 21 limits to our ability to extract if they don't choose to 22 fu rnish i t.
23 CHAIRMAN AHEARNE:
What would you see them doing?
24 COMMISSIONER BEABFCRD:
Again, if the plants meet 25 th e regulations and are within what Joe has said is the band ALDERSON REPORTING CCMPANY. INC.
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23 1 of risk f or other plants, then I don't think it is of grea t 2 weight.
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3 CHAIRMAN AHEARNE:
Either way?
4 COMMISSIONER BRADFORD:
Either way.
That is, I 5 don't think we would shut a plan t down if it meant all our 6 regulations and was -- there were 10 or 20' plants riskier 7 operating around the country.
8 CHAIRMAN AHEARNE:
Even if the Governor came in 9 and said, I am very uncomfortable about it?
10 COMMISSIONER BRADFORD:
I think he would have to 11 gie us reasons beyond tha t.
I felt somewhat differently in 12 the Rancho Seco context, even af ter the TMI aspect, and the 13 question of PCW reactors, but as a normal matter, I do not
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14 think that we would shut the plant down.
I have a separate 15 set of questions about whether the Governor oucht to have 16 the owner to do it himself, but I think if he wants us to do 17 it, there has to be a showing of specific reason.
18 But if what came out of the proceeding were 19 instead an indication that Indian Point were somewhat more 20 risky, either sccietal, individual, or both, and leave aside 21 the question of meeting th e regulations, because that is one 22 ve have to decide ourselves, then my feeling, at least at 23 the moment, is, I would like the State of New York 's views 24 on what adequate protection to the public health and safety 25 meant.
ALCERSCN REPORTING COMPANY, INC.
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CHAIRMAN AHEARNE:
Would you then see asking for 2 that opinion af ter the board made its finding?
I' 3
COHHISSIONER BRADFORD:
That might be a reasonable 4 var to do it.
I had not thought that through.
Certainly 5 there are some contexts in which it vculd not matter, so 6 maybe the most efficient thing to do is to wait un til i t h a s.
7 CHAIRMAN AHEARNEs Certainly, if it is not going 8 to matter, then you would not want to go to an extraordinary 9 effort to get it, but I was thinking more from the way you 10 just described it, if this had greater risk, that that would 11 not. become clear before the board made its finding, and so 12 if you are ask5ng the state to address, given tha t the plant 13 has greater risk, what is ycur position?
It would be kind a
14 of-hard to get them to take a clear position on a nebulous 15 set of circumstances.
It is much easier on the concrete.
16 COMMISSIONER BRADFORD:
I think that is right.
I'7 What I really veuld be after is some way to do all that we 18 reasonably can to assure state participation in the 19 proceeding.With a view toward just th at, getting an 20 articulation of the stat.e position in whatever form a brief 21 to us or testimony at the appropriate time 'in th e proceeding Z! as to what the state's position on adequate protection would
.zi be.
'24 CHAIRMAN AHEARNE s When you say 25 COMMISSIONER BRADFORD:
I know where you are l
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I don 't know the answer.
My first preference is 2 obviously -- from my own days in state government, it always 3 seemed better vnen you had the Governor being represented by 4 the Attorney General.
Then there were still difficulties 5 with the legislature, but there are states and situations 6 where you get an Attorney General going one way and th e 7 Governor the other.
8 CHAIRMAN AHEARNE:
And the state goes the other 9 way.
Who represents the state?
10 COMMISSIONER BRADFORD:
I like to think the 11 Governor does, but that seems to be one that is somewhat 12 beyond our con trol.
I would like to get the clearest 13 articulation we can of the state position in the proceeding.
J 14 CHAIRMAN AHEARNE:
Or a variety of state 15 po sitions.
I see.
16 COMMISSIONER BRADFORD:
The other questions, I 17 think -- Well, there is the property damage, clearly set 18 forth in Item 6 -- are 'cariance of questions that are 19 already in the draft order, and they really are the result 20 of my just sitting down and listing the things that seem to 21 me to matter for this proceeding, and they are no t really 22 urged on you as being any better or worse worded than what 23 ve s1 ready have.
24 CHAIRMAN AHEARNE:
Now, why should the order 25 mention the fact that the Governor recommended th e plants l-ALDERSCN REPORTING CCMPANY, INC.
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1 26 I continue?
2 COMMISSIONER RRADFORD:
To me, at least, tha t is,
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3 while not a sine qua non, an important point in all this, 4 and that given the fact questions have been raised about th e 5 safety of Indian Point, we have a specific petition on it 6 that there is a good deal.of uncertainty acknowledged by 7 everyone in the task force report on the risk assessment 8 calculations.
9 The fact is that the state has -- at least the 10 Governor of the state has put it about as strongly as he 11 could.
I think that a,s the chief executive officer of New 12 York State he - wants the energy f rom those plants, and 13 considers the public health implica tions to be acceptable.
t 14 It seemed significant to se in my thinking, and therefore to 15 the extent. tha t I have a say in the order, I would urge you 18 to include'it.
r7 CHAIRMAN AHEARNE:
And the New York 18 COMMISSIONER BRADFORD:
I think the point is that 19 when you put out an order settling a stage of a proceeding, 20 you ought just as a matter of art to deal with the -- all of 21 the cententions tha t you have that have been made to you and 22 your reasons for rejecting them.
23 The same with regard to the licensee request on 24 reconsideration.
3.
CHAIRMAN AHEARNE:
A may turn out to be true.
ALDERSON REPORTING COMPANY, INC.
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1 (General laughter.)
2 CHAIRMAN AHEARNE:
Modify Question 2 --
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3 COMMISSIONER BRADFORD:
Actually, that would be 4 true whether you used Question 2 out of the draft order or 5 Question 2 off of my own list.
6 CHAIRMAN AHEARNE:
Y<.u are adding, I guess -- at 7 the moment I am having a 11ttir difficulty seeing why 8 specific off-site emergency procedures are not part of the 9 emergency plan.
10 COMMISSIONER BRADFORD:
It is more in the nature 11 of, if in the course of the proceeding the plans seem to be 12 inadequa te, it is in the same context of saying that the 13 plan t itself, what can be done to improve it.
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14 CHAIRMAN AHEARNE:
So you are saying that it has 15 the same -- Number 2 at least was what improvements can be 16 expected in the near future, and I guess you are adding on l'7 not only what could be expected, but what could be taken.
18 COMMISSIONER BR ADFORD:
That is the way it would 19 wo rk. Yes, that is the way it 9euld work in the context of 20 that question.
You would introduce just a different element i
21 in to mine.
22 Also, there is some difference in urgency between Z3 that which. can be reasonably expected and tha t which can be l
24 specifica117 mandated.
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CHAIRMAN AHEABWZ:
Yes.
Now, do you have in mind ALDERSON REPCRTING COMPANY, INC.
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28 1 -- Ycur Question Number 10 at least raises the possibility 2 of you having in mind the board perhaps trying to address
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3 interim operation.
i-4 COHNISSIONER BRADFORD:
Nc, I am sorry, this is 5 just for purposes of this order, the one tha t we would be 6 putting out at this point.
It ought to include a brief 7 discussion of our understanding of the current situacion.
8 CHAIRMAN AHEARNE:
I see.
Well, that is -- those 9 are sort of -- my initial reading, I have to, at least f o;r 10 arself, think more caref ully.
11 COMMISSIONER BRADFORD:
Okay.
12 CHAIRMAN AHEABNE:
Vic, any questions or comments?
13 COMMISSIONER GIIINSKY No.
14 CHAIRMAN AHEARNE:
Joe?
15 COMMISSIONER GILINSKY:
Let me understand a little 16 more what people mean by criteria.
When you say that we l
l'7 would use as a criterion whether or not this plant or 18 another plant departs significnatly in one or another form 19 of. risk from the band that applies to other plants, we are 20 in effect saying that we do not think that they should, and 21 that if it does -- it leaves open t he question of what 22 significan t is.
23 So, there is a certain amount of flexibility 24 th e r e.
Whether that is a factor of two or a factor of 20 or 25 100 or whatever it is, that if it does, it ought to come 4
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1 12 9 1 back into some reasonable range, or it ought not to continue 2 to operate.
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3 COMMISSIONER HENDRIE:
Well, I guess, yes.
I 4 think there.is that implication in the way I framed things.
5 Ge sort of depends on the way you come at it. - Suppose your 6 view was that the least risky -- that the most risky 7 operating plant by whatever measure you care to propose was 8 already substantially below any reasonable safety goal level 9 that society might inpose.
So, here is some kind of safety 10 goal, and in a risk sense is obviously the righ t dir'ection.
11 You have a batch of data points down here, and you are 12 convinced that even the worst of those is well below.
13 Well, in that case, I don 't care if Indian Point i
14 is here and all of th e re s t of the plants are grouped in a 15 band down like this, because they are all below.
16 Now, it is my sense tha t that is not exactly the l'7 case.
On no grounds other than sort of intiution and 18 judgmental grounds of our deliberations, calculations, and 19 so on.
I think that the I conclude for myself that the 20 run of operating plants are probably overall at an 21 acceptable level, as I would judge it, at any rate, but as n we look -- begin to look in some detail on these risk 23 assessment bases at particular plants, I think we may very 24 :vell find some tha t need some cures to-get them back down 25 into that group, and what I suspect is that if I find one ALDERSON REPORTING COMPANY, INC.
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1 that is well above the group, that I might. very well 2 conclude that that is getting a little too much for me, and 3 that I want some way to get it back down in th e re, and if 4 Indian Point turned out to be one of those, then, you know, 5 what could we do about'it.
6 So, I think there is, in terms of the way I 7 fo rm ula ted the criteria, the sort of implicit assumption 8 that the band, the general band is at an approximately 9 acceptable level on an absolute scale, but that as ycu get, 10 you know, very perceptably above it, why, it becomes -
you 11 either have or may have gone above the absolute -- an 12 ubsolute acceptable band.
13 At such time as we are able to enumerate for I
14 ourselves wha t we think that absolute level is, then we have 15 a much better handle on this proposition.
In the meantime, 16. wh y, my judgment on IP would be where it stands versus where 17 the band of plants stand.
18 Now, this adjudication is not likely to proceed so 19 capidly that we have back before es for decision the record 20 of the proceeding before we have an opportunity for any 21 further thought about the general standard.
22 You know, I for myself, as I look around at the 23 thinor that are going on in terms of the general standard, !
24 see initiatives in various industry groups and academic 25 f gr ou ps, and there is an initiative in the staff, and we are ALDERSON REPORT:NG CCMP ANY, INC.
400 VIRGINIA AVE, S.W., WASHINGTON. O.CC0024 (2021554-2345 m. g.- -
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1 not without input materials to discussion of such a subject, 2 one..
3 Two, it seems to me that we are simply attempting 4 to take the first step on a very long road, and that you 5 know, several years of studies and analyses and arguments 6 and hypotheses -- proposals which are'then critiqued and so 7 on, is going to be an appropriate course, but I am not sure 8 that we have to say absolutely nothing until we have gone 9 all the way down that line.
10 I begin to sense that I think I could frame a that the Commission could 11 safety objective that sould be 12 discuss, and conceivably put tentatively on the table as an 13 interim basis inviting comment and providing some limited
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14 amount of guidance over an interim period, and it seems to 15 me that that is worth trying, and I hope to be able to try 16 it and encourage discussion, and indeed, by the time the 17 record of this proceeding came back, we might out of that 18 kind and other intiatives have a considerably better idea of 19 where we think we are and where we think we are going to go.
20 So, maybe we sort of start on one basis, but by 21 the time we'get to look at the results, why, we have a 22 better idea where this whole f ramework lies on some absolute 23 scale.
24 COMMISSIONEH GIIINSKY:
You said something earlier i
3 about putting the collective risk as sort of a secondary ALDERSON REPORTING COMPANY, INC.
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32 1 criterion.
-I am not sure what weight I would attach to 2
COMMISSIONER HENDRIE:
I think that is very much a 3 matter of individual point of view, and
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4 COMMISSIONER GILINSKY:
I guess I would be 5 inclined to two sets of criteria.
6 CHAIRMAN AHEARNE:
As long as we are keeping them 7 qualitative, I would have great difficulty with reading them 8 primary or secondary.
9 COMMISSIONER HENDRII:
Well, that might be<an 10 unfortunate phrasing down the line.
I will say for myself 11 that if we discovered that the IP societal impact was either 12 within or not substantially above the band, but the 13 individual risk was.
I would regard that as a more i
1-4 difficult situation than the reverse.
15 CHAIRMAN AHEARNE:
I would find it sort of tb 16 opposite.
17 COMMISSIONER GILINSKY:
It would be hard to 18 achieve.
What you probably would be doing is, if you brinn 19 the societal risk down into the band, you will be driving 20 the individual risk.vay down, and somebody else may be 21 (General laught.er.)
22 COMMISSIONER HENDSIE:
I think that is probably 23 right.
.In fact, you might even be able to make a ;rcof of a 24 theory 25 COMMISSIONER GILINSKYs A possibility --
I i
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COMMISSIONER HENDRIE On the other hand, you 2 know, occasionally, it is interesting to see how you feel
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3 about these pathological cases by way of sort of exercising 4 a point.
5 CHAIRMAN AHEARNE:
Anything else?
6 COHNISSIONER GIIINSKY:
No.
7 CH AIRM AN AHEAR NE :
Well, we have, unless general 8 counsel or OPE has any other comments --
9 MR. 3ICKWIT:
Just one more on the subject.
You 10 mentioned at the last meeting tha t many of the comments 11 vanted to emphasi=e consequences of a probability in your 12 analysis.
If you are putting together crite ria, I think nov 13 would be an appropriate time to decide whether you want to 14 go that way or whether you want to stick wi th the normal 15 definition of risk.
16 CHAIRMAN AHEA RNE :
That is one of the issues l'7 COMMISSIONER GIIINSKY:
Well it seems to me that, 18 you know, just dealing with conseq' nces in order of 19 probatilities probably does not make any sense, but the fact 20 is, when you talk about some of the p robabilities we regard i
l 21 as highly unlikely evoets, those probability estimates are 22 pretty uncertain in themselves, and I guess in those 23 circumstances -- well, f or e xample, before the Brown's Ferry 24 Event _the other day, people would have calculated pretty i
25 small numbers for the chance tha t it might ha ppen.
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1 COMMISSIONER HENDRIE:
About one part in 10,000.
2 If ycu lock in WASH 1270, why, that is what I calculated the 3 unreliabilty of the scram systems to be, and th a t was on the 4 basis of -- I have forgotten whether -- whether it was one 5 or two scram failures.
6 COMMISSIONER GIIINSKY:
I remember there was just 7 a very small --
8 COMMISSIONER HENDRIE:
Yes.
9 COMMISSIONER GILINSKY:
-- number in one of the 10 tests.
11 COMMISSIONER HENDRIE:
The one that was not a 12 - failure, but would have been a failure if somebcdy pushed 13 the button or it had tripped, and then it was the in reactor 14 thing, and what I suspect is that that number vould not 15 ' change greatly if you added in the Brown 's Ferry experience.
16 COMMISSIONER GIIINSKY:
Nevertheless, I still l'7 think that a lot of those estima tes are highly uncertain.
I 18 think in those circumstances it is not unreasonable to play 19 it sale, in other words, take the upper rance of the 20 probability estimates and throw in'a factor of safety on 21 those.beyond what the risk estimate -- so I think it is not 22 an either or question here.
I think -- I nean, how do you 23 end up 24 COMMISSIONER HENDRIE:
No, I agree.
If you say, I 25 vill just look at probabilities, then what you end up dcing l
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1 is giving no weight to the big accidents which tend so have 2 low - probabilities, an1 tha t does not make sense, because
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3 even though they hopefully have low probabilities, if ther 4 happen to be substantial consequences -- on the other hand, 5 if you look just at consequences, then what you in effect 6 conclude is that the worst that can happen will happen, and 7 all that is going to lead you to is nightmares, and not only 8 in this field.
You know, it is not a basis on which you can 9 make a rational public policy decision.
I think you need 10 I think you need both of them.
I think it is -- I think it 11 is not unreasonable to ask to see what the probabilities are 1:2 snd the consequences are and the product rather than just 13 the product alone maybe.
14 So, you know, if you have a yen for one or the 15 other, why, you can look and see how it goes.
16 CHAIRMAN AHEARNE:
The issue that is -- and I do 17 not think -- because of the uncertainties in the 18 calculations and the methodology, I don't think you vill 19 ever get to doing-a mathematical analysis, but if one could, 20 it is whether there is a weighting factor, a non-zero 21 veighting factor that increases the consequences such that Z2 in that product, as the consequence gets very large, that 23 the significance of that product is larger than the 24 unweighted product, 25 That is really wha t the issue turns out to be, and ALDERSoN REPORTING COMPANY, INC.
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1 I would guess it is again going to be a subject cf 2 qualitative description.
That is really what Vic was saying
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3 when he talked about perhaps a safety factor at the upper 4 end.
5 Any other --
6 COMMISSIONER HENDRIE:
In order to Know where we 7 go from here, we may have to scratch a little bit more at 8 some of these thrusts on the questions.
9 CHAIRMAN AHEARNE:
I think what we have to.do is you nodded your head when I asked whether you would 10 first 11 take a crack at trying to draft th e decision criteria.
12 COMMISSIONER HENDRIE4 No, no.
13 (Ceneral laughter. )
i 14 COMMISSIONER HENDRIE:
I was recoiling in horror.
15 You just took that to be an upwerd mo tion.
16 (General laughter.)
17 MR. BICKWIT There were a lot of nods over here.
18 CHAIRMAN AHEARNE:
Perhaps you can use th e 19 services over there, but --
20 COMMISSIONER HENDRIEs All righ t, I will take it.
21 CHAIRMAN AHEARNE:
And then Peter has really 22 proposed a number of alternatives on the questions, and I 23 think we have just got to try to see what we can --
24 COMMISSIONER BR ADFORD s Why don't I undertake to 25 circulate a version of the order that incorporated those ALDERSON AE?ORTING COMPANY, INC.
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1 points.specifically, and do it through'the Secretary?
2 CHAIRMAN AHEARNE:
Fine, fine.
I would guess it E['
3 vill not be straight up and down.
It undoubtedly will be a 4 modification.
5 COMMISSIONER BRACFORD:
That is fine.
It seems 6 Aor? efficient to comment in terms of a written draft going 7 out for ccaments than to come back here again on it right 8 away.
9-CHAIRMAN AHEARNE:
Fine.
10 COMMISSIONER HENDRIE:
Before you go away 11 CHAIRMAN AHEARNE:
Today or next week?
12 COMMISSIONER HENDRIE:
Today.
P 13 MR. 3ICKWIT:
How about next week?
14 (General laughter.)
15 CHAIRMAN AHEARNE:
Yes.
16 COMMISSIGNER HENDRII:
The isst time we were at 1:7 the table on this subject, the counsel aided us ' grea tly wi th 18 a discussion of things like burden of proof, the burden of 19 going forward.
20 CHAIRMAN AHEARNE:
Ycu committed him to discussing 21 that.
22 COMMISSIONER HENDRIE:
A discussion which I found 23 to tally impene trable.
24 CHAIRMAN AHEARNE:
At this table, the word is 25 inscrutable.
ALDERSON REPORTING COMPANY, INC.
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1 COMMISSIONER HENDRIEs I don't know whether that 2 is the counsel's frailty or mine, but I asked if he could 3
MR. BICKWIT:
I know who is going to pay fcr it.
j 4
(General laughter.)
5 COMMISSIONER HENDRIE:
I asked if he would try it 6 again from a different direction.
7 CONHISSIONER BRADFORD:
Since then, we have given 8 you a new tool, the rebuttable presumption.
9 (General laughter.)
10 C05MISSIONER HENDRIE:
Yes, but what I can't 11 CHAIR 5AN AHEARNE:
Blunt arrows --
12 COHNISSIONER HENDRIE I keep forgetting whether 13 "rehuttable" is the important word or " presumption" is the 14 important word.
15 MR. BICKWITs All righ t.
I am not really clear 16 where I went wrong last time.
17 COMMISSIONER RENDRIE:
Neither am I.
18 COMMISSIONER BRADFORDs But just let me try to 19 COMMISSIONER GILINSKY:
This is the burden in this 20 proceeding?
21 MR. BICKWIT:
You want a general discussion of 22 what is the burden of proof.
23 COMMISSIONER HENDRIE:
In particular, what does it 24 mean -in this case?
25 MR. BICXWIT:- All richt.
ALCERSON REPORTING COMPANY, INC.
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COMMISSIONER HENDRIE:
I think in a normal 2 licensing hearing, it seems to me that th e people who have
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3 the burden of proof are the people who are trying to make 4 the case.
In order for them to be successful, they must 5 convince people that their propositions are supportable and 6 are supported, and folk who are adainst it don't have to 7 advance some different course of action.
They just attack 8 the guy 's basic proposition.
9 So, it seems to me clear enough there.
In this 10 one,-who is proving what against whom?
And it seems to me 11 that is the kind of thing that the commenters said.
Would 12 you please give instruction when you got around to it?
13 MR. BICKWITs It strikes me that whenever a 14 question is asked logically there can be a burden of proof 15 assigned.
It need not be in the context of an enforcement 16 proceeding.
It can be in the context of a discussion.
The 17 questien that involves burden of proof is always, what 18 happens when the decision maker on a question is undecided 19 af te r hearing all the evidence, and it seems to me that that 20 from
- a. logical standpoint -- you can apply tha t concept to a 21 question having nothing to do with enforcement.
22 You and I are having a conversation, and it 23 involves a given question, and Peter is making the ultinate 24 judgment on the basis of our discussicn.
It is seldom done, 25 but it is perfectly logical to assign to one of us the ALOu. SON REPORTING COMPANY, INC.
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3 on who had that burden, s.d would decide against the person 4 who had that burden, and that is really all we are talking 5 about here.
You could in this instance not assign a burden.
6 CHAIRMAN AHEARNE:.
What you are saying is, in tha t 7 kind of a context, you do an assignment, and if nobody makes 8 the case, th e person who had the burden of proof loses.
9 MR. BICKWITs That is right.
Now, in this kind of 10 a proceeding, ycu could say, if nobody makes the case, a 11 given party loses, or you could say, if nobody makes the 12 case, that will simply be reported up to the Commission.
13 COMMISSIONER BR A3 FORD:
With consequences unknown.
14 MR. BICKWIT That is right.
I mean, it would be 15 perf ectly reasonable to say on the question, what would be 16 the energy consequences of a shutdown, to say the board was 17 totally undecided as between the positions of Party A and 18 Party 3.
It would not be possible if you had assigned a 19 burden.
You would not get that kind of a report.
If you m had assigned a burden --
21 CHAIRMAN AREARNE:
Does the term have meaning in 22 the kind of questions just asked if it is a strictly factual 23 question that is being asked?
24 MR. BICKWIT Yes.
Eurden of proof is used --
25 CHAIRMAN AHEARNE:
What are the economic ALDERSON RE3cRTING COMPANY, INC.
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2 MR. BICKWIT Different people will take different
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3 positions.
4 CHAIRMAN AHEARNE:
The board would be responsible 5 for making a recommendation or reaching its conclusion on, 6 here are the economic consequences.
7 MR. BICKWITs One party will say, here are the 8 economic consequences.
Another will disagree.
If you 9 assign a burden --
10 CH AIR M AN AHEARNE:
But you described this last 11 time as an investioatory hearing.
The board is trying to 12 investigate something, find something out.
It is trying to 13 make its best judgment.
I 14 COMMISSIONER GILINSKY:
It is more than that.
If 15 you decided to 16 CHAIRMAN AHEARNE:
I am just askinq in this 17 particular -- I can see some issues of the burden of proof 18 being.something that would come into play.
I am having 19 difficulty with a strictly factual question.
The board is 20 trying to find out what is the situation.
l 21 MR. BICKWIT:
Different people will take different 22 positions on that.
23 CHAIRMAN AHEARNE:
Certainly, but it is not trying j
24 t o s a y, your position is right or your position is right.
1 25 You are asking the board to reach the conclusion, what do i
ALCERSON REPCRTING. COMPANY, INC.
stia m _,
42 1 th e y think-is the correct answer.
2 MR. BICKWITs That is true.
You are also deciding
('
3 what the board.should do in the event that it is undecided 4 as between the positions put forward.
5 That is what burden of proof is about.
6 CONHISSIONER BR ADFORD:
To give it a concept 7 make it a concept that has a clear meaning for any given 8 hypothetical, you have to be a ble -- th e decision -m ak e r h a s 9 to be able to articulate the result that will flow from 10 either unclear evidence or the absence of evidence.
If you 11 are doing it with something like the economic ccsts, I 12 suppose you could say, well, the Commission will assume that 13 the costs are A, 3, C, and D, in the absence of a convincing
-i 1-4 showing to the contrary.
15 CHAIRMAN AHEARNE:
I suspect what I am wrestling 16 with is my problem with using this kind of format to get at 17 an answer.
18 MR. hALSCH:
I can say usually the way boards 19 vould approach the question.
First o f all, they would look 20 at the logic of the various parties ' positions for logical 21 flaws.
Obviously, if they find a logical flaw, that 22 position drops out.
If you find there are two positions 23 equally logical, and th en they look at things like tine 24 spent-in investigation thoroughness.
If that fails, you 25 look at things like who is the be tter expert.
If everything ALDERSON REPORTING COMPANY, INC.
L: :
&ANTMn/Mk RE THNERreiTEN,RAKM4 iM G1PSMM.
4d 1
1 fails --
2 CHAIRMAN AHEARNE:
I think -- I am not sure
(~
3 wehther Commissioner Hendrie's questions are resolved.
I am 4 co mf or table.
I have a very clear picture of it.
I am not 5 very happy with it, and it certainly vonid relieve me to 6 conclude on many of these questions it is better to reserve 7 them to the Commission because it is a subjective judgment 8 that has to be reached.
9 MR. MA1SCH:
Not usually.
I have never seen 10 CHAIRMAN AHEABNEs I am not saying usually.
I am 11 saying in this case.
12 MR. MA1SCH:
Usually my experience has been before 13 licensing boards -- most decisions get solved on a logical i
14 basis.
15 CHAIRMAN AHEARNE:
In which case, the burden cf 16 proof issue is not a driving factor.
- 17 COMMISSIONER GILINSKY:
Isn 't the question really 18 whether someone has to show risks attached to the activity 19 that he is conducting are not significantly greater than 20 thoce attached to a typical f acilities operation, or whether 21 -- and if he does not show it, he cannot operate, or if 22 someone else has to show that the risk succeeds at a level 23 of significance, then --
24 MR. BICKWIT As I said last time 25.
CHAIRMAN AHEARNE:
That is right.
ALCERSON REPORTING COMPANY, INC.
hs.
44 1
MR. BICKWITa There are three different kinds of
- 2. questions.
f' 3
CHAIREAN AHEARNE:
When you break it into a whole 4 bunch of questions, as the people who raised this said last 5 time, when you have a string of questions, there are 6 different people who are participating in the examination, 7 on each one of those different questions, and the burden of 8 proof issue came up with respect to some of those note 9 narrow questions.
10 MR. BICKWIT4 I think there are three different 11 categories of questions, the natrov ones, th e decision on 12 whether a given criterion is met, and the decision on what 13 to do, what action to take, and you can assign a burden, a 14 different kind of burden on each one of those kinds of 15 questions, or you could choose to assign no burden on any of 16 them.
17 CHAIRMAN AHEARNE:
I am sorry, Joe.
I jumped in, 18 and they were trying to answer your question.
13 (General laughter.)
20 MR. BICKWIT:
I would suggest that if the concept i
21 is ill-fitting to this proceeding, in your view, then th e 22 appropriate position to take is that there should be no 23 burdens assigned.
24 CHAIRMAN AHEARNE:
Which is one of the 25 MR. BICKWIO4 That is right.
s ALDERSON REPORTING CCMPANY, INC.
45 1
CHAIRMAN AHEAFNE:
But th e petitioner basically 2 did net say, assign here, assign there.
He was raising the f
3 question to be clear on where the burden of proof was.
4 MR. BICKWITs That is right.
5 COMMISSIONER BRADFORD:
I want to think about that 6 some more, Len.
I as troubled by it, because it seems to me 7 that in fact, whether or not we assign a burden, there 8 certainly is one.
That is, there vill be consequences 9 attaching to either a completely unclear record or a record 10 on which no one has sought to go forward on a particular 11 subject.
12 That is as true whether you put it in the 13 fo rmulation of saying we should reserve these decisions to 14 the Commission as it is.
If we somehov formally tell a 15 licensing board to make a finding in the absence of a clear 16 record, there are consequences that a ttach to the f ailure to 17 have convincing evidence on one side or the other.-
18 CHAIRMAN AHEARNE:
When I said, reserve it to us,
,19 it was more -- and some of those, if they are really going 20 to turn out to be that kind of balancing that Earty was 21 describing, that you reach deep down, and there is a lot of 22 balancing judgment, then I would be more comfortable at that 23 stage in us trying to do that.
24 COMMISSIONER BRADF0FD:
That is right, and I think j
25 what was troubling me is just that I do agree to the extent i
i ALDERSON REPCRTING COMPANY, INC.
I
]
L
46
~ _
1 we can.
It is better to be clear at the beginning what the 2 consequences of a failure to persuade on any given point 3 would be.
In some cases, it is obvious.
4 MR. BICKWITs We will have ether meetings.
'5 CHAIRMAN AHEARNE.
Do you understand --
6 COMMISSIONER HENDRIEs I think the sensible thing 7 to do is go home and go for a long swim and have a stiff 8 drink.
9 (General laughter.)-
10 CHAIRMAN AHEARNE:
Well, hopefully, at the end of 11 _that you will then take a crack at the criteria, and Peter, 12 you will try and draft an order.
13 (Whereupon, at 3:52 p.
a.,
the mee ting was 14 ad jo urned. )
15 16 17 18 19 20 21 22 23 24 25 ALDERSON REPORTING COMPANY, INC.
-]
m.
NUCLEAR REGULATORY CO.*G1ISSION 1
This is to certify that the attached proceedings before the N
COMMISSION MEETING in the matter of:
PUBLIC MEETING - DISCUSSION OF INDIAN POINT Date of Proceeding:
July 25, 1980 Docket liumber:
Washincton, D. C.
Place of Proceeding:
were held as herein appears, and that this is the original transcript thereof for the file of the Ccamission.,
David S. Parker Official Reporter (Typed)
O G
p
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(SIGUATUPI OF ?I?CR"rR)
~
0 C tJt $ lit h b,
UNITED STATES OF AMERICA f
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NUCLEAR REGUMTORY COMMISSION C /U' h.
Comissioners:
(~
John F. Ahearne, Chairman Yictor Gilinsky-Joseph M. Hendrie-Petar A. Bradford CONSOLIDATED EDISON COMPANY OF NEW YORK (Indian Point,
)
Unit No. 2)
)
)
Docket Nos. 50-247 POWER AUTHORITY OF THE STATE 50-286 0F NEW YORK (Indian Point, Unit No. 3)
)
MEMORANDUM AND ORDER
(
A.
SACKGROUND*
On May 30,1980, the Commission issued an order establishing a four-pronged approach for resolving the issues raised by the Union of Concerned Scientists' petition regarding the Indian Point nuclear facilities, and by the decision of.
the Director, Office of Nuclear Reactor Regulation (NRR), gnnting in part and denying in part that petition.
The order announced the Commission's intention to hold a discretionary adjudication for the resolution of safety issues con-cerning the _ plants; initiated an informal proceeding for the purpose of defining The Con.;::ission has received a motion from the Union of Concerned Scientists, dated June - 23,1980, requesting the disqualification of Commissioner Hendrie from participation in this matter.
In its Diablo Canvon decision (In the Matt 6e of Pacific Gas and Electric,11 NRC 411 0980)), the Ccmmis-sion stated t. sat requests for the disqualification of a Commissioner would not be entertained by the Commission as a whole, but would be referred to the Catamissioner whose disqualification was recuested.
By memorandum of April 23,1980, Commissioner Hendrie has denied the request for his disqualification.
Attachment i t_
~ --~ -
-~
the questions to be answered in that adjudication, as well as the criteria to be applied; announced thti Commission's plan to address the generic question of the-([
operation of nuclear reactors.in areas of high population density through a generic proceeding, to be decided at a later date; and directed the Comission's General Counsel and Director, Office of Policy Evaluation, to establish a Task Force i.o ' address the question of the status of the reactors during the pendency of the pkanned adjudication.
The Task Force has now presented its report to the Comission.
On the basis of its findings, we conclude that the risks posed by the operation of the Indian Point facilities during the pendency of the adjudi-cation are not such as to warrant the extraordinary remedy of an interim shutdown in that period.
B.
THE TASK FORCE ON INTERIM GPERATION The Task Force was asked to examine the following specific questions:
1.
A description of the Indian Point site demography as compared to other U.S. reactor sites.
2.
A comparison of reactor accident risks (spectrum of probabilities and consequences for health impacts and property damage) at the Indian Point site to reactor accident risks at other sites.
i
.3.
The effects of potential public emergency response systems (evacuation, sheltering, etc.) on reactor accident risks at Indian Point. The area studied should be large enough to include New York City.
This evaluation 1
~
3.
a should include an. assessment of the effects of uncertainties associated with'successfbily completing such actions.
~T 4.
A comparison of the reliability or accident probabilities of the Indian Point 2 a'nd 3: reactors to each other and to other reactor designs which
~ have been analyzed. This should-include consideratio$ of th'e changes-
~
ordered by the Director, NRR; technical design comments received in response-to the Commission's February 15 solicitation of comments; and the effects of partial reductions in power level.
5.
An assessment of the economic, social, and other "non-safety" effects of shutting down or reducing the output of either or both reactors.
The Commission directed that the Task Force develop the information necessary for a Commission ' decision en interim operation, consider the comments
,J
'that had been filed with the Ccmmission in the matter of interim operation, and present that information to the Commission.
C.
TASK FORCE FINDINGS On June 12, the Task Force presented its report to the Ccmmission, and on June 26, it briefed the Commission as to its findings in a public meeting.
The Task Force found the following with respect to the first four items of its c harter :
1.
Site Democrachy With New York City within less than 50 miles to the south, the Indian Point site has the highest or one of the highest surrounding population
4 densities of all U.S. nuclear power plant sites, as shown by the various
'populat' ion density criteria examined by the Task Force. The data for total population levels out to 10, 30, and 50 miles show Indian Point
.b figures as highest for the U.S.
Total estimated populations to these distances -are appbximately 218,000, 3g8,000, and 17 million, respectiveTy,
~
3.L.s.
o....
s.,
as compared with corresponding median popula. tion levels for all U.S. power-
~
reactors of 24,000, "334,000, and 1 million.
..,.;.s When considering reactor accident risk, the population in a given direction, (i.e., in one 22-1/2 cegree sector), is often more significant than population density averaged over all directions.
Here too, Indian Point ranks among the highest:
eighth with respect to the highest-population' sector at 10 miles, ar.d highest at 30 and 50 miles.
2.
Comoarison of Accident Risks Accident risk, in the sense of the product of accident probabilities and consequences, is partly a function of population density and distribution around the plant.
In addition, it is a function of design and operational characteristics of the reactor plant, local meteorology, and ceasures --
such as sheltering or evacuation -- which could be taken to reduce the effect of a reactor accident on the public.
The Task Force compared Indian Point risks with those of other reactor sites and designs, dis-tinguishing among effects of population densities and of design and other l
f actors, a.
. Site Ascects,-
l
- To discern.the risk effects of site considerations alone, the Task Force calculated risk. measures for various sites for a " benchmark" l
3;
~
l
. 5L reactor, whose design remained constant regardless of site.
(The Surry pressurized water reactor was used as the benchmark design, but with a power ievel increased to 3025 thermal megawatts, the rating of Indian Point. 3.) Six sites were analyzed for this comparison.
Four --- Indian Point,' Zion, Limerick, and Fermi - represent sites of relatively hig.h population.
One, Pa.lisades, represents what the Task Force. believed is a site with typical or average population distribution.
The last, Diablo Canyon, represents a remote site, that is, one with relatively low population density.
The comparison was made in terms of four principal risk measures:
early fatalities, early (radiatien) illnesses, latent cancer fatal-ities, and' public property damage costs.
For each of these measures, the Task Force considered both accident consequences and, using the w
)
benchmark reactor, the probability of their being exceeded.
Integration of consequences of accidents for all probabilities represents the overall risk.
j Risk estimates of this sort necessarily involve wide uncertainties, as the Task Force emphasized.
The large uncertainties in absolute values of risk estimates generally introduce wide uncertainty bands in comparisons.
Subject to those uncertainties, and subject to the assumed conditions, including unshielded exposure during the entire radioactive cloud passage, the Task Ferce found that Indian Point risks attributable to site (i.e., surrounding population) factors alone ccmpared with risks of other sites as follows:
S
_~
(1)
Early fatalities:
. Indian Point risks are essentially the same as those of the other sites with dense local population.
The less densely popu-.
. k_..
lated sites showed progressively much lower risk levels.
Early fatalities ~are dominated by tiie-population within-10 miles of the plant, so-the large population of New-York City is not a factor here. At very low probabilities, up to thousands to tens of thousands can occur, according to the estimates.
(2) Early illness from radiation:
These risks are dcminated by the population within 50 miles.
Thus, New York City is important here.
Indian Point risks were comparable to those of the other high-population sites.
The
(
Palisades and Diablo Canyon sites were not very different from each other but were found to be substantially lower than the o thers.
At very low probabilities, up to hundreds of thousands of persons could suffer radiation illness, according to the estimates.
(3) Latent cancers (i.e., delayed cancers, occurring possibly a number of years after radiation exposure, which are statistically expected in excess of those that would otherwise have occurred):
These are dominated by the population within about a 200-mile radius of the plant.
Because of this, the individual site risk curves for latent cancers reflect the character of the region.
The latent cancer risk for these sites, and probably all other
j
.c.,
1.
e 7
i
. sites, is approximately ths.same.
The number of latent cancer
~
deaths projected is on the order of hundreds per year or thousands per accident for the lower probability events (on the order of 3
10-9 per year).
~~ ~
~
u (4) Property damage,. excluding damage to the plant itself, was estimated as proportional to population density.
Accordingly, Indian Point was at or near-the high end of property damage estimates, differing only coderately from the other high-density sites, but sharply higher than Palisades and, especially, Diablo Canyon.
Damage can reach up to tens of billions of dollars at very low probability levels for the high-density -- and even intermediate density -- sites.
The worst of the accident consequences -- those that result in fatal doses or severe ground contamination -- would ensue only from certain accident scenarios entailing core meltdown and gross containment failure, coincident with particularly adverse weather conditions.
Expected consequences, i.e., consequences statistically expected, taking annual accident probabilities and magnitudes of consequences into account, compare as follows, as summarized in Table 5 of the Task Force report, which follows.
1 4
--.w--
r
_w-
. - ~ - - -
- 5. _
~
. TASLE'5
~
EXPECTED ANNUAL CONSEQUENCES.(RISX) FRO'4 5 SITES WITH THE SURRY RESASELINED ?WR DESIGN Probability of Early Early latent Property Consequence. Oc
' Fatalities Injuries cancer /Yr*
Damage 5" Site currence nor vr
. Diablo Canyon
- 1.5x10-S 2.Sx10 1.8x10~4 1290'
-4 Palisades *
~2.9xid-4 1.2x50 2.7x10-f 2570
' Ferai 2.Zx10~4.
6.3x10-3' 3.6x10-4 4785 Limerick 3.Sx10-3 T.1 x10-2 4.7x10-4 5980
-2 '
Zion 4.7x10-3 1.2x10 4.3x10-4 5030 Indian ?oint 6.1x10-3 1.Sx10-2 5.4x10'#
o350
- Total Latent Cancers Would Be 30 Times Higher
- 5ased on 1974 Dallars
' NOTE:
T.'ERE ARE L5.RGE UNCERTAINTIES WITH tie ASSOLUTE VALUES PRESENTED IN TiIS TABLE.
. ASSUMPTION,5:
1.
SU?.RY DESIGN.
2.
I.P. UNIT 3 ?OWER LEVEL (30E5 MWT).
3.
WITHIH 10 MILES - ENTIRE CLOUD EX?OSU:.E + 4 HOURS GROUND EX?OSURE NO SHIELDING BEYOND 10 MILES - ENTIRE CLOUD EX?OSURE + 7 OAY GRCUND EX?05URE SHIEL0 LNG EASED ON NORMAL ACTIVITY.
4.
WIND ROSE WEIGHTED 1970 CENSUS ?O?ULATION DISTRIBUT10'!.
S.
IDENTICAL 31 WEATHER SEQUENCES FOR ALL SITES.
9 1
\\
g.
s
e'a l
9..
.j b.
Desion Effects The Task Force perfonned an analysis to estimate the extent to which the impact of the relatively unfavorable site demographic character-3 istics on the' relative risk at Indian Point would be modified by 1
design characteristics of the Indian Point plants. The analytical 1
' approach was to consider accident sequences that, based on previous studies,. could reasonably be viewed as dominating.overall risk. The sequences examined included reactor-transient accidents and loss-o'f-coolant accidents. The design-effects comparison was done by comparing what the risks of plants of the Indian Point and other designs would be were they all located at the Indian Point site and operated at the
.same power level.
The Task Force points out that large uncertainties surround the
)
results -- uncertainties believed larger than those surroundi,g estimates for site-dependent differences alone.
Subject to those uncertainties, the Indian Point reactors were estimated to have a 1 in 100,000 annual probability of suffering severe core damage, as compared with probabilities some 3 to 20 times higher for six other representative U.S. pressurized-water and boiling-water reactors.
The risk of the Indian Point reactors appeared from the Task :'orce analysis to be even lower compared to the other reactors examined than the ratio of their estimated core damage accident probabilities would suggest.
Tne changes completed and in progress at Indian Point
- s
=
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.~
as a result of the decision of the Director of Nuclear Reactor Regulation concerning the petition of the Union of Concerned Scientists produce a further risk reduction estimated by the Task L
Force at a factor of three.
The risks, in terms of statistically expected annuT1 consequences for the Indian Point and three other-plant designs, were. they all located at the Indian Point site, would compare as follows, as su=narized in Table 8 of the Task Force report, reproduced below.
r ^
o 4
4 r
7
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. g' 1. i.. :J.q*%y, ;a:e f. '.%
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..?: J.,. :
- , :'5 :>x :*;. _;l]p Q :.,.a y :.. 5.. L'. ~ '...
m.....'..-
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p(. - 4%,;',G.:.ti
- :. T t.:~t *.
- -1.m.s..
.f,t :;.::~,,,.::. r.&..^
.:m:-:s~;. u.: :...
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w.m.: ws :..:.
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TABLE. 8
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..:.:1::,:. ;f:. :::: ::.: --~.: :: c. --?.:.w 1
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.a EXPECTED ANNUAL CONSEQUENCES (RISK) FRCM 5 LWR DESIGNS' I'
~:'.!?.'. '
t
.AT THE INDIAN POINT SITE Yrob* o'* Conse.
Early Early Latent
- Property '
quenca Occur Fatalities
' Injttries Cancer /Yr*
' Damage S**
3 Desien r.nce oer vr 2.2x10-4
.Z.7x10 1.6x10-5 199 4
IP After Fix..
IP Before Fix.
6.3xib4 9.Sx10 4.4x10-5 700 3
Surry Rebase.1ined
.6.1x10-1.Sx10-2 5.4x107"-
9550 Sequoyah Ice; 2.7x10-3 2.2x10-2 1.2x103 14E00 Condenser'
?sach Bottom 5WR-1.7x10-2
.3.1x10-2 1.1x10 13500 3
Rebaselined
- Total Latent Cancers Would Se 30 Tin:es Higher
- Based on 1974 Dollars NOTE:
THERE ARE LARGE UNCERTAINTIES WITH ME ASSOLUTE VALUES ? RESENTED IN THIS TAELE.
'.)
ASSUMPTIONS:
1.
INDIAN POINT SITE METEOROLOGY - 91 WEATHER SEQUENCES WIND ROSE WE'3HTED 1970 CENSUS POPULATION DISTRIBUTION UNIT 3 POWER LEVEL (3025 MWT) 2.
WITHIN 10 MILES - ENTIRE CLOU0 EX?OSURE + 4 HOUP.S GROUND EXPOSURE NO SHIELOING BEYOND 10 MILES - ENTIRE CLOUD EXPOSURE + 7 OAY GROUND EXPOSURE SHIELDING EASED ON NORMAL ACTIVITY O
4 e
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^
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2.
v.- :.,._
q c-
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c.
Overview
~
After separately examining the risk of the Indian Point site and of
.C the Indian Point design, the Task Force summed up its findings as followsi i
[T]he-site is about an. order of magnitude more risky tt an' l
a typical site and the design about as much less risky than a typical design.
There is much more certainty in "our comparison of the relative site risks: than there is in the comparison of the design risks.. It is reasonable to conclude that the two about cancel, that is, the over-all risk of the Indian Point reactor is about the same as a typical reactor on a typical site.
We recognize that such a comparison makes no explicit compensation for the Indian Point risk entailing notably higher consequences even if at lower probability than is typical.
It is not unusual in risk aversion to demand lower risk as the potential consequences increase -- as the stakes get higher. Accordingly, one might argue that the probability should be more than a magnitude lower if the consequences can be a magnitude higher.
3.
Emeroency Plannino Considerations The Task Force analyzed the sensitivity of the Indian Point risks to the effects of evacuation and sheltering.
The Task Force reported analyses which assumed that all persons who would be evacuated from the vicinity of the plant in an accident would suffer cloud exposure from the radionuclides released.
As a result of this pessimistic assumption, the analyses presented showed little difference in public risk for the alternatives of different radii of evacuation, sheltaring, or even no evacuation for one day after the accident.
Under the same assumption the Task Force analyses showed somewhat higher risk of early fatalities' for the no evacaation alternative, and some reduction of the early illness risk for the sheltering and 50-mile evacuation
_._ Z ~ Z _ i T_zzz-33
~
alternatives, but the calculated differences are small in relation to the uncertainties of the analysis. The Task Force did some nJrther analyses which were reported to the Commission in the briefing at the June 25, 1980 -)
open Commission meeting, which indicated that prompt notification and
~
evacuation out to 10 miles could substantially reduce the early fatality risk.
4.
Soectal Desion and Ooerational Provisions a.
Difference Between Units 2 and 3 The Task Force found no risk significant differences between the Indian Point 2 and 3 designs.
It made this finding in its examina-tion of the two designs in relation to the seven accident sequence scenarios that it judged to dominate overall risk.
.)
b.
Effects of Desion and Ooerational Chances The design and operational fixes completed or icminent at Indian Point in accordance with the decision of the Director of Nuclear Reactor Regulation in connection with the petition of the Union of Concerned Scientists reduce risk by a factor of three, in the Task Force's estimation.
1 c.
Effects of Power level Reduction Reduction of power level would reduce risk primarily through two mechanisms:
(1) proportionate reduction in the longer-lived radioactive fission-product inventory, which would produce a less-than-proportionate decrease in accident consequences; and
1,.
.,,, ~ ~
, w
.~
..it (2) reduction in accident probabilities thro' ugh lowered fuel'
- temperatures and rduced rate of decay heat after shutdown, both
.of whica would improve the reactor core's tolerance for poor cool ing..
Though the Task Force perfomed no ~ detailed study, it concluded from its consideration of these mechanisms that it appeared reasonable to
. -say 'that risk would: be reduced in proportion to the. reduction in power level.
D.
CONCLOSION The Director of Nuclear Reactor Regulation acted on the petition to shut down these reactors on February 11, 1980, finding that the interim risk of their continued operation while the matter was being considered did not warrant their shutdown.
Now the Task Force has conducted a separate evaluation of the ccmparative risk of interim operation.
We have reviewed the report of the Task Force with great care.
It should be enphasized that our review has been directed not to the question which is the subject of the adjudicatory proceeding which will be initiated -- that is, the long-tem acceptability of the Indian Point Unit 2 and 3 facilities -- but rather to the issue of whether the two plants should or should not be allowed
'to operate. during the. pendency of that adjudication.
Our conclusion is that the evidence now before us indicates that the risks posed by operation of the two plants is not so great, or so dissimilar to the risks posed by other facilities licensed to operate by the Commission, as to warrant the extraordinary remedy of an interim shutdown or reduction in power level.
The gist of the Task Force
.-m v
w 33 report is that although the Indian Point site is considerably less desirable than the average riuclear power plant site, in terms of the density of the sur-rounding population, special' design features not found in the average nuclear
]
power plant reduce the accident risk from Indian Point by a comparable factor.
We are conscious as well that operation of the two facilities, during this interim period, is subject to the various safety improvements ordered by the Director, Offica of Nuclear Reactor-Regulation, in his February confirmatory o rder.
In so finding, we are not prejudging the outcome of the adjudicatory proceeding, but-rather are addressing only the narrow question of whether interim relief is appropriate during the period in which the adjudication will be arriving at a decision, based on the evidence submitted to it.
In the event that the Licensing Board conducting the adjudication determines that new evidence warrants interim relief, it can at any-time reccmmend that course of action to j
the Ccmmission.
For the present, however, we find no basis in the record to support the extraordinary measure of an interim shutdown in advance of completion of the hearing and Commission decision.
It should be emphasized that our decision is based on grounds of safety, and the actual risks posed by the plant.
Though we have sought out informatio1 as to the economic and other non-safety issues involved in the decision whether to shut down the two plants, those factors do not play a part in this decision today. 'Je need not decide today the extent to which such factors may be taken into account, in circumstances in which safety considerations militate in favor
)
of one course of action, while economic considerations argue for a contrary resul t.
s -.
UNITED STATES OF AMERICA NUCEEAR REGULATORY COMMISSION BEFORE THE COMMISSION m
i
/
-)
In the Matter of
)
.)
CONSOLIDATED EDISON COMPANY
)
OF NEW YORK, INC. (Indian Point,
)
Docket Nos. 50-247 Unit. No. 2)
)
50-286
)
POWER. AUTHORITT OF THE STATE OF
)
YORK (Indian Point, Unit No. 3)
)
)
t UNION OF CONCERNED SCIENTISTS' MOTION TO DISQUALIFY COMMISSIONER HINDRIE The Union of Concerned Scientists (UCS) moves that the Commission disqualify Cor:lissioner Hendrie from further participation in any deliberations or decisions by the Commission concerning UCS' Petition for Decommissioning of Indian Point Unit 1 and suspension of Operation of Units 2 &
3.
This Motion is based on the likelihood of actual prejudice and the inescapable appearance of prejudice and unfair treatment that stems from Commissioner Hendrie's previous extensive involvement in the consideration of the Indian Point reactors as a mer--
.4-.,
... --- e,. c.,.
Reactor Safeguards ( ACF[x..
s.,,,.
1 pq DUPLICATE DOCUMENT j-Division of Technical y 1
c k
Entire document previously j
UCS first requeste[71 entered into system under:
ANO 3Obd bO \\ D Paragraph 69 of its pet l~O by the Director of Nucit No. of pages:
- .w a a.a=.= a
na =
Att3Ch..ent 2 7
14:
l The request for an interim. shutdown of Indian Point Units 2 and 3 is therefore denied. By a s'absequent Or6. we shall prescribe the questions to be resolved. in the adjt dicatory proceeding, and the criteria to be applied.
1 It is so ORDEREU'.
~.
~~
For the Comissi.on-SAMUEL. J. CHILK Secretary of the Comission Dated at Washington, D.C.
this day of July,1980.
I I
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-88 '
APPENDII 3 ADVISORY COMMi i t==. ON REACTOR sac ~. GUARDS UN!'C.D STATES ATch-ilC ENERGY CC)dMIS'510N
-wAsNiNGTon, e acus SEP 2 3. E70
~
Honorabia Glenn T. Seaborg ChW-m v.c
--1 U. S. Acc=ic Energy Co-
- asion -
Washington,. D. C..
20545
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Subject:
RI?OET CU NIDIAN ?O12iT NUCI2i? W"'h.~I".O VNIT EC. 2 j
Daar-Dr.. Sea.borg:
' At its 125th caeti=g, Septa *"er 17-19, 1970, the Advis'ory Coc=itree en '
Reec:or Safeguards c. eleted its review of the appliccf.ica-by Censo11-deced Edisnu Corp,a=7 'of New York,' Inc., fc ac:horization to operate
~
~'
.ghe Indian 'oint Nucicar Generating Uni:: No. 2.
This project had pre-vicucly been cen=idered at ths Co
':: tee's 95ti, 9sch,.122nd, and 124th
, meetings, and at Subec
' tee =ectings on August 23,1969, March.13, 1970, ' April 25,1970, Eay 28,1970, July 25-29,1970, and. Septe.=ber 15, 1970.
Subec:=ni:::ees also =et at the site on December 25, 1967 and May 11,.1970.
The Cs-
- ttee last reported on 09. project to you on l
August 16, 1966.
During the revieu, the Cc-#::ee had the benefit of
-}
j discussions with represen:ctives of the Consiolidatad Edison Ce:peny and their centrac c:s and ccusult.tn::s, cad wi::h repr:ccr.:atives of the AEC Regulacory Stsff.
Iha C
=#t:ce else had the becafi: of tha dec
-n:s lis::ed.
The Indias Point s.4.t:e is located in Westchester Ceune,,, New Yc k, approx.
ir.acaly 24 milec north cf the Neu York Ci:y licies.
Tbc min a radius e
,cf the excincica araa for Unit no. 2 is 520 =t crs cad Peekskill, the nearact population cen::er, is app c:d.=ately en:-h:.15 nila f::da the uni::.
Also at.this site cre Indien ?cint Unit I 615 L't, and Unit 3, in wc mn%which is,liccused.fo.m.o.r, era.7 r c
--m-~
w cien s.:
t y M e g e t W V~& g i g irp 2 S +'
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7 1~cs applicant bcs re-evaluate DUPLICATE DOCUMENT d
,the event of the pr.Labla nnn
=cra recent infor: action, and Entire document previously i
c::iste f::: vital ec..:penen::a entered into system under:
I
}
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ANO ROo G.% c) l 9 O Ads e cnn* _,cis 4 -
u.
t Un': !!o. 1 =perbacts: buildi uupsrhacte.: stacfc will ens.bh.
No. of pages:
1g of 300-260 uph cc :: pending 5e
.3._
,_J
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appeal to the-Court of Appeals, if that should be necessary, before the Commission reaches any substantive decisions concerning UCS' Petition.
Respectfully submitted, 9
E4% ~X.ww
,. -.. c EllN R. Weiss /4eM'A
/
General Counsel to UCS
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William S!' Jordan, III Harmon & Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006 (202) 833-9070 4
Dated :[-1) -f>>
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- Da.puty Di' rector for Tcchnical Review Directorate or. l 1cansang1 GS-18 7a9e 4
~ RESPONSIBILITY FOR' DECISION 55. -
Syervision Received:
Director, Directorate of Licensinal GS-18.
Work is reviewed'for over-nil adequacy.
Indeoendent Action:
Reviews. the overaTT 'per ormance o-th'ese organizational units repor to him foi accuracy and completeness.
. Review incoming correspondence, documents and technical assignments dete.rmines order.of priorities, and issues assignments.
Prepares important correspondence not recuiring a mafer policy decision 'for the signature of the Director, Directorate of Licensin or the Director of Regulation, as appropriate.-
Makes appointments, schedules meetings and conferences.
....... Performs res.,ea,rch a.s needed to present. compl eted staff work and-
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supervises,the.preparati.on. of major policy. document
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.r Supervises' the Assistant Director for Reactor Safety, Assistint '
Director for. Containment Safety, 'and Assistant Director for Site Safety.
WORKING CONDITIONS:-
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