ML19331D094

NRC Lessons Learned from TMI: Time for Action & New Directions in Safety Policy for Nuclear Power Plants, Presented at 800522 Conference on Radiation Control. Mb Spangler Article Encl

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Issue date:	05/22/1980
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NRC LESSONS LEARNED FROM THREE MILE ISLAND:

A TIME FOR ACTION AND NEW DIRECTIONS IN SAFETY POLICY FOR NUCLEAR POWER PLANTS

• Roger J. Mattson Director Division of Safety Technology Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, D.C.

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'A paper presented at the Twelfth Annual Conference on Radiation Control, Louisville, Kentucky, May 22, 1980.

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NRC LESSONS LEARNED FROM THREE MILE ISLAND:

A TIME FOR ACTION AND NEW DIRECTIONS IN SAFETY POLICY FOR NUCLEAR POWER PLANTS Roger J. Mattson U.S. Nuclear Regulatory Commission Investigation of the Accident at Three Mile Island The accident that occurred over a year ago at the Three Mile Island nuclear power plant was traumatic -- especially for the people living in the region of the facility near Harrisburg, Pennsylvania -- as well as for utilities; nuclear plant suppliers; and governmental authorities at the local, State and Federal levels.

The accident at TMI received extensive media coverage and also produced fear and anxiety among a wide segment of the public, especially people living near other nuclear power plants.

Indeed, it is now apparent that NRC's safety pelicies should be formulated so as to deal not only with safety and economic tradeoffs, as recommended by the Kemeny Commission (Ref. 1), but also to deal constructively with what Robert DuPont has characterized as " nuclear phobi

(Ref. 2).

In this light, this paper describes NRC's status on lessons learned from the accident at TMI and our continuing search for new directions in the formulation of safety policies for the siting, design, and operation of nuclear power reactors.

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Since the accicent at Three Mile Island on.Waren 2S,1979, tnere have ::een an acuncance of studies and investigations of the causes of tne accicent and recommencations for corrective actions.

Among these =no have investigated the acricant are committees of both houses of the Congress, tre President's Commitssion on the Accident at Three.$ tile Islanc, tne NRC Scecial Incuiry Gross, the MSC Advisory Conurittee on Reactor Safeguarcs, the Lessens-Learned Tass Forca and tne Salietins and Creers Task Force of :ne NRC Cffice Of Nuclear Reactor Regulation, and the Saecial Review Grous of the NRC Office of Inspection and Enforcement (Refs. 3-14).

Cthers *no have stucied ine accicent incluce a nuncer of State gnuns, incivicual utflities and new incustry organi-

=ations, suc:t as the Atomic Incustrial Forum Policy Committee on Follcw uc to the Three Mile Island Accicent, the Nuclear Safety Analysis Center ccerated for t.% electric utility industry t:y the Electric Dower Research Institute, and the Institute for Nuclear Power C erations (Refs.15 and 15).

The Conception of an Action Plan Althcugn t.wre is a never-ecding need to study anc learn sore accut nuclear safety and risk assessment, it is fair to say tnat the taneciate priorities related ta the accident at TMI have shifted free a learning to an actica pnase.

Indeed, in view of the troubled world cutlook for enemy sucoly, the Presioent on Cer==ner 7,1979 excressed a sense of urgency for the NRC to end the nuclear licensing pause following ::e TMI accicent within a sir-1renth

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period. The NRC had already initiated the development of an Action Plan to address the urgency of performing its regulatory and licensing functions on a timely basis, commensurate with the urgent need for deciding and implemer t-ing improved safety measures.

In developing an action plan to accomplish these objectives, the obvious starting point was the recommendations from the various external and internal investigative studies.

In the aggregate, the recommendations from these official studies numbered over a thousand.

Although the various groups, for the most part, reached simi'.ar conclusions, they organized and stated their recommendations in different ways in accordance with their particular per-spectives.

In order to pull all of these recommendations together in one place and develop specific plans for prioritizing and acting on them, the Nuclear Regulatory Commission called late last year for the development of an action plan to respond to the lessons learned from the accident at Three Mile Island. This TMI Action Plan is now more than five months old and the final draft is soon to be published (Ref. 17).

The plan contains approximately 175 discrete actions organized into five chapters, each covering a broad subject area: Operational Safety; Siting and Design; Emergency Preparedness and Radiation Effects; Regulatory Practices and Procedures; and NRC Policy, Organization and Management.

The Action Plan serves to consolidate and definitize the sany general recommen-dations from the official investigations into a set of discrete, scheduled tasks that specify enanges (or studies of possible future changes) in regulatory

o recuirernent.t and. the organistion ard crececures of NRC.

The actions in the Marr alscr nave teen systematically prioritized anc nave now been assigned to accrecriata-organintional elements of NRC.

The varicus offices-have est.isatec t:w rescarces: nd: senecules-for NRC anc tae incustry to accerolisn eac:r af thee actf ons. M1 of tais-inforeatiert is ;:revicae in-the final version of' the-Actiest N arr..

The Action Plan is. r enamar. far :::st r sacre anc. icnger range actions.

It caralcgs, ast = ell',. taae many. cecisiens-ane d ens. alreacy taken ty the NRC in

e. year since the ac=ident.. For exapele, tna NRC t cc a nuacer :f :amedia:e stacr ::r inornve: tte safety of coarsting nuclear ;::s.er ;11 ants in the first few cays. anc waaks. after tua ac=f eent.. Thess &c were-wibed in a series of bulletinsi uxc creers ::r. ::e 1icenseet af cesrating p1 ants that previced co-to-the-minute f ai.n,.u+tariens of tre: secuence c' eventr leading u: to tne 'I ac=f cent. anc recnirec. sceci ?!c. cnangas ar. al1. ccara:.ing ::.1 ants to guarc agai nst: rumstd tions. af' sucir eventss A-few santas 1ater, accreximately tnirty-snart:-tare W resents;were isttm+ by tae NRC.en the basis, of lessons learned t

from t,:- scrht. Thece are nm being i:mlemented. irr t e stages, between m

January.1. IS8K ana:Jamsary 1,.1am by. alI coerating alant 1icensees. Al1 af tam-imesista asuc se ac=funs; wara documentat in the Action F1an so taat-ther, c:malm bee ensram=rser ane ac=mntee for cutiv tne-develcoment of

m longer tarw recuf m-tnat are alsa. reff end in the al an.

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In developing the TMI Action Plan, the recommendations of the various investi-gations and studies were assessed and either adopted, modified, or rejected.

These assessments and decisions were made under the direction of a Steering Group, which served to integrate and coordinate the development of the Action Plan by the NRC staff.

The Commission, the Executive Director for Operations, and the directors of the program offices within NRC reviewed and commented on the various drafts of the plan, and their decisions and directions were followed in refining subsequent drafts.

The regulated industry has also undertaken intensive study of the plan in order to provide its assessment of the priorities and resources for implementation of the actions which affect licensees.

The decisions on whether to include specific action items in the plan were based primarily on whether they were necessary to respond to the recommenda-tions of the principal investigations of the accident.

This was consistent with the NRC decision made in November 1979 to implement changes so as to conform with the recommendations of the President's Commission and with subsequent findings by the NRC and its staff that the principal investigations reached consistent conclusions. However, decisions on the priority and resources to be afforded the various actions in the plan have been based primarily on assessments of their relative risk reduction potential, i.e., their contribution to overall safety.

Throughout the decision-making process, there has been general agreement as to basic causes of the accident and universal opinion that improvements are necessary in ceder to restore the confidence of government regulators, reactor owners, and the puolic that

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operating plants are acceptably safe.

It is recognized, of course, that acceptadie levels of safety cannot be viewed as static concepts.

Not only is this because of changtng sectal values (Ref.18), but also because of new options 1sade available by advances, irr science and technology and other world deveTopments affecttng the energy supply outlook tither favorably or unfavoratriy.

Irv adattfort te the acove, there ts, aTso a wide consensus among experts as to whictr technologicar and human factors in reactor safety need improvement.

This corisensus stems front the aforementioned general agreement among the various fnvestigations as toe the causes of the ac=tdant. This includes fatTures that occurred before and during the. event,. both in the equipment. and trr the organtzattons that designed, operated and regulated the plant.

For the most part, any differences of optriiert that did exist among the investigating groups were over the degree of imprtmement. requ. ired, and the specific choice of methods and ttsfng of thetr imprTementatforr_

We iTeve new reached a' point where we are doing something; about all the major weakness fdentiffed by the acctdent. But, there is a need for Tonger ters 1

respanse, and it fs refTected frr the TMI Action Plan. Certain elements. of the piarr have bew scheduTed for the future,. so as to provide far:

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L A reartstfc amount of time far Ticensed ut.i.11ttes, t:r perfcrm the engineering desigrr, fabrfcation, fnstallatfort and testing of technoiogical modtffca-tions once they are decided to be necessary.

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Additional studies by the government, the industry, and the public that are necessary, in some instances, to establish the desirability of specific changes that have been suggested for siting, design, or operation of reactors.

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Effective public input as a means of exploring the diversity of societal impacts of candidate safety measures having controversial aspects or wide scientific disagreement. This includes the need to ensure against hasty decisions on behalf of certain safety measures which, in the absence of careful study and review, might have yielded an actual reduction in overall system safety instead of the hoped for gains.

An Overview of the TMI Action Plan The development of the TMI Action Plan has provided a useful, if controversial, vehicle for debating and deciding on the methods and timing of the needed safety improvements, consistent with a variety of resource restraints.

In the following paragraphs, the principal elements of the plan are summarized.

l All of the investigations seem to agree that, although the accident stemmed from many sources, the most significant deficiencies were in the general area that some of us have come to call operational safety.

Operational safety includes the number, organization, qualifications, training and support of both the operating staff and the management of the plant. The general conclu-sion is that these human elements in reactor safety have been underemohasized

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in the past compared with the attention given to the hardware or equipment aspects of reactor safety.

The actions in the plan directed toward improving operational safety have two objectives. The first is to improve the operation of nuclear plants so as to reduce the frequency of initiating events that could lead to accidents with significant adverse effects on the health and safety of workers or the general puclic.

The second objective is to improve the ability of the cperating staff to recognize promptly any abnormal events and to take corrective actions.

Lower tncidence of initiating events that cause accidents is being adcressed through improvements in the selection and training of reactor operators and other plant staff and improvements in utility management techniques and capa-bilities.

Lower incidence and better control of initiating events are also addressed by specific improvements being required in the content and level of training courses, tne use of plant simulators, the content of casualty procedures, the design of the controls and instrument displays in the contro? room and the

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addition on every shift of tectmical adyisors with engineering qualifications and other special trairring.

Improvements in the evaluation by licensees and NRC of operating experience and the audtting of day-to-day plant operations are also to be irstituted to provide continual feedback of new lessons and to develop a %,.;.sive body of knowledge and experience upon which to found future improvements in the capability to prevent accidents.

l Although operational safety merits primary emphasis in our future work, means of improving current plant design are also necessary and the Action Plan 1

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l-9 includes several of them.

Even though there were no debilitating equipment failures during the initial sequence of events, other than the relief valve that stuck open, the TMI accident reempnasized the importance of system reliability.

Therefore, the Action Plan contains requirements for the assess-ment of tne reliability of some of the engineered safety features (e.g.,

auxiliary feedwater, emergency core cooling, containment isolation, and decay-heat removal) and an overall assessment of accident prcbabilities and conse-quences using integrated reliability analyses.

These analyses are directed toward identifying and correcting specific weaknesses in the design features of currently operating plants as well as plants still under construction.

The Action Plan also contains studies of the desirability of additional design requirements and safety systems to reduce the risk from accidents involving significant melting or degradation of the reactor core even worse than that at TMI.

Besides studies of possible future requirements for core selt, the plan contains short-term actions to make interim improvements in the capability of nuclear power plants to mitigate the consequences of accidents in which the core is severely damaged. These interim improvements include reducing the possible leakage paths for the highly radioactive material that would accompany such an accident.

Other actions to aid in the management and control of severe" accidents are included in the plan, such as improved shielding to aid access to highly

" Severe accidents are those which involve full or partial melting of the reactor core or that cause extensive damage to the fuel elements.

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10 radioactive fluid systems, better means of sampling the reactor coolant and containment atmosphere, increased range of instruments so that accident condi-tions can be sonitored, and better training of operators on the capability and use of the currently installed equipment during severe accidents.

Finally, in this area of severe accidents, the action plan includes a rulemaking action involving the possible need for adctitional hydrogen control features as appro-priate for various types of containment structures, and mitigation features for other ef fects of accidents involving core damage.

An action in the plan that is related to design for severe accidents and that applies to future plants is the reexamination of NRC policy on remote siting of nuclear po=.er plants.

The idea is to place greater reliance on distance between population centers and reactor sites as a means of reducing safety and health consequences to the general public in the event of a core melt that leads to offsita r:1*mm of radioactivity.

In this regard and well before the TMI accident., the Nuclear Regulatory Commission in August 1978 directed the staff to develcp a general policy statement regarding tnese and other aspects of nuclear power reactor siting. A Siting Policy Task Force was organized and its report., published in August 1979, contained a nuncer of recommendations to accoselish the following goals (Ref.19):

L To strengthen siting as a factor in defense in depth by establishing requi. _..ts for site approval that are inoependent of plant design l

consideration.

The present policy of permitting plant design features to compensate for unfavoraDie site characteristics has resulted in improveo oesigns but has tended to deespnasize site isolation.

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To take into consideration in siting the risk associated with ar,cidents beyond the design basis (Class 9) by estaolisning population density and distribution criteria.

Plant design feprovements have reduced the oro-bability and consequences of design basis accidents, but there remains the residual risk from accidents not considered in the design basis.

Although this risk cannot be completely reduced to zero, it can be signi-ficantly reduced by selective siting.

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To require that sites selected will minimize the risk for energy genera-tion.

The selected sitas should be among the best available in the region where new generating capacity is needed.

Siting requirements should be stringent enough to limit the residual risk of reactor ocera-tion but not so stringent as to eliminate the nuclear cotton from large regions of the country.

This is because energy generation from any source has its associated risk, with risks from some energy sources being greater than that of the nuclear option.

In addition to the weaknesses identified in operational safety, system design, and reactor siting, the reports of investigations of TMI have generally agreed that the state of planning and preparedness for emergencies at nuclear power plants was inadequate.

This inadequacy resulted from the low priority assigned to emergency planning by NRC and its licensees, a poor definition of the NRC role in emergencies, and insufficient coordination among licensees, NRC, and other Federal, State anc local agencies. A major action tnat occurred in this area since the accident was the President's centralization of eme.gency

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planning and response in a single Federal agency - the Federal Emergency Management Agency (FEMA).

Emergency response improvements that fall to NRC are contained in the Action Plan. They include better emergency centers and upgraded organization of onsits utti.ity personnel for emergencies, imerovement of the emergency plans for of fstte acttctr by the utfitty and by State and local governments, and improvement frt the emergency response capability of NRC.

The accident also incrwased' our amareness of the importance of informing the public before and during eagergencies,, and actions are provided in the plan tc improve the uncer-standing of the news media and the pubite as te. how, nuclear plants operate.

This.wou.1d includet key safety f. sat.ures; how radiation affects health; and what additional protective actions will be provided during emergencies.

The investigations of the accident at TML-2~ have criticized the worker radia-tion protection programs at nuclear power plants, particularly under accident 7,,

ennditions The plan includes improvements in radiation protection plans, healtn physics operations, inplant radiation morrttaring, and the habitability of contre 1: rooms, alt intended ta leeep the egosures to workers during both norsa.T operations and ac=fdants as Tom as reasonably achievable. The Action PTan aise Tays out programs for improvements in-the protection of the public from radiatfort. fneluding tacreased monitaring of radioactive effluents fres plants, bettar inplant radicanalytical measurements, more rapid estimation of offsite doses, and acre secure control of the release of radioactivity.

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13 Investigative studies of the accident have also shown the need for improvements in the practices and procedures for regulation of nuclear power plants.

The areas of improvement within NRC include a clearer definition of the overall safety policy and goals, including backfit policy; improvement in the agency's rulemaking practices; reorganization of the functions and interactions of the Commission and the staff; improved administrative procedures; and counteractions to some of the financial disincentives to safety that have apparently existed in the past.

The Action Plan and the Rgje ::sation of Reactor Licensino:

The End of a Pause For almost a year tvisowing the TMI accident there were no new ifcenses, authori:ations or permits issued by NRC. The licensing pause was necessary for NRC to be able to concentrate its efforts on assuring the safety of operat-ing reactors and to control the situation at TMI-2 as well as to undertake extaasive work in identifying and resolving the broad safety issues raised by the accident.

Until recently, these efforts absorbed a large portion of the available staff resources, and little work could be accomplished on liceasing reviews until it was complete.

Thus, the pause in licensing was designed to provide time and resources for the assessment of the TMI accident to be suestantially completed and for improvements in both the operation and regulation of nuclear power plants to ce set in sotion.

The pause assured that the staff would not be distracted or delayed from saking a coecrehensive assessment of the accident and applying

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14 the lessons learned to operating plants.

In addition, the pause addressed the concern that the risk from new plants not be added to the risk of presently operating plants until after the full implications of the accident had been addressed.

As outlined above, the NRC staff has developed and issued a numter of new requirements, many of which are already implemented in operating plants and verified by NRC, which have provided immediate and substantial improvement in the safety of operating reactors.

The Commission has also reviewed and given preliminary approval to a list of TMI-related requirements recommended by the staff as prerequisite to issuance of full power operating licenses for future plants.

In the context of the Action Plan we have also defined what further, longer term studies and research are required.

Until the Action Plan has been approved, the conditions for ending the licensing pause and granting the first full power license since TMI will not have been met. However, the NRC has recognized an obligation to act on license applica-tions with reesonaole dispatch sir.ce delays in licensing of fully constructed nuclear plants can involve large economic costs to utfiities and, ultimately, consumers of electric power. There is an opportunity to reduce these costs without compromising the afas of the Ticensing pause, and without incurring any significant public risk, through the issuance of restricted if censes that permit newly completed plants to load fuel and perform rero and icw power testing. By completing these necessary preliminary steps, licensees can reduce the time which would otherwise be necessary before the plant could

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15 begin generating substantial amounts of electricity. Near the end of this summer, the first new plant should finish this low power testing phase.

A number of the improvements derived frte TMI studies are required to be implemented on new plants prior to loading fuel.

These requirements provide additional assurance that the risk to the public will be extremely small during the low power testing.

They include improvements in the number, train-ing, and qualifications of the reactor operating staff; augmented management and technical support of the operating staff; better emergency preparedness and improvement of some equipment.

Procedural controls on the duties and responsibilities of various operating personnel during both normal and accident situations are required to be reassessed and clearly specified.

The management and technical support organization and staff are being given much closer scrutiny than in the past to assure that they are adequate.

An improved safety audit function and an improved operating experience evaluation function are also to be provided by the licensees at each new plant.

l The emergency preparedness of the plant staff is to be improved by better organization with more closely specified functions, and by the addition of special facilities for the groups designated to perform these functions.

The emergency plans of the utility and State and local authorities are reviewed and, with FEMA's advice, approved by the NRC before loading fuel.

In addition, drills of the emergency plans are conducted and observed by the NRC.

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T 16 There is only a small possibility of serious error during the authorized testing at low power and any errors at these power levels are not likely to result in serious consequences.

Additionally, test procedures are to be reviewed by the supplier of the reactor to provide further assurance that operational errors are not committed.

The NRC will have a resident inspector at each pl. ant before fuei ts loaded to audit the testing program.

Each new plant wf TT have dedicated telephone lines to the NRC for rapid communicatiert in the event of an accident. Dedicated telephone lines have already been installed for presently operating plants.

Consistent with these special prerequisites, the Commission has already acted on the merits of three applications for fuel. Toading and zero-and low power testing of power reactors for which construction had been completed.

The Commission has decided to license the Sequoyah, North Anna 2 and Salem 2 nuclear plants to Toad fuel and conduct tests up to 5 percent power.

In sum,. a number of very important steps toward regulatory recovery from the TMI accident have been accompiished.

First, a numoer of major investigations of the TMI acefdent Itave been compTeted and their conclusions and recommenda-tions assessed. Second, and most important, the safety of operating plants has beers significantTy improved. Third, NRC has been through severai itera-tions and reff nements of a comprehensive Action Plan for responding to the recommendations of the fnvestigations. That plan f s nearing final approval.

Fourth, a set of requirements withfri the Action Plan has been developed for those operating license aoplicants wir2se construction is complete and who are

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i 17 otherwise ready to be licensed except for the TMI-related concerns.

Having accomplished these steps, the NRC has made real progress towards getting its house in order, and the stage is now set for ending the licensing pause and granting full power operating licenses.

Some Remaining Issues and the Need for Further Articulation of Safety Policies and Objectives It is readily apparent that regulatory uncertainty will not end when ifcensing has resumed.

There it, more to be done at both the technical level and at the policy level.

The technical projects that follow from TMI are described and arranged in the Action Plan, and, although their final outcome cannot be predicted with complete certainty, the areas of interest and concern have been set forth for review by all interested persons. However, this is not the case with reactor safety policy and backfit policy.

Their future study and develop-ment are not well described in the plan and therein lies a considerable measure of uncertainty.

l The majority of the uncertainty for the future of nuclear reactor safety seems to stem from the fact that NRC regulates in an environment that is largely governed by perceptions and subjective judgments rather than the more objective considerations of engineering, science, and law.

For example, the fundamental proposition of NRC's role in accidents is subject to substantially different interpretations according to whether it is considered in the general statutory i

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18 framework prior to the TMI accident, or as it occurred in fact during tne accident, or as it is variously perceived and desired by others.

Similarly, although the NRC staff deals daily in concepts of safety and risk from a predominantly scientifi: and analytical perspective, the public, the Congress, and the media generally react to their perception of risk independently of whether that perception concerts with reality. We lack a national consensus, a Congressional sandate, or even a popular understanding of national nuclear safety objectives. We even lack agreement on the correct appec-ach to making safety judgments.

There is an acute need for policy on what is an acceptable safety goal and supporting safety standards for reactor regulation.

In the past, :many of us have suggested that our basic overall objective was to contnal the safety of nuclear power plants to achieve a level of risk that was less than the risk of any realistic alternative method of producing electricity.

General agreement today on this overall objective would provide a si:eable reduction in the present uncertainty.

Similarly, it wou'd help considerably

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if agreement could be reached that the accident prevention measures already implemented and others soon to be in place return us to the level of safety we thought we had attained prior to TNI (for which I think there is now a strong l

argument). With these accomplishments we could then proceed at a sore deli-berate pace to study and debate whether there is a need for further significant risk recuction, especially through seasures to mitigate the severity of con-sequences of potential core selt accidents.

By mitigation measures, I sean those distinct from the reduction of the procacility of accidents to which initial seasures since DdI, and indeec the overall regulatory program, have l

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A 19 largely been directed.

In the meantime, we are already pushing rapidly ahead to decide whether some operating plants require special emergency preparations or design features for core melt accidents.

Lacking any such articulation of safety objectives, the incentive is strong for NRC engineers and scientists to continue to develop and issue piecemeal, prescriptive licensing requirements that slowly accumulate on the complex patchwork of past regulatory practice.

This patchwork has become important to safety, and there is no strong indication that plants cannot be safely operated in conformance with the somewhat abstract pattern of requirements.

However, there can also be no question that 20 years of this form of regulation have taught the regulated industry that the only certainties in the regulatory process are those of uncertainty and delay.

The patchwork system of regula-tion and attendent uncertanties and costs of delay are equally unsatisfactory to the people it was designed to protect.

Whatever national reactor safety goal and supporting safety standards are eventually decided upon, it is clear that we have an opportunity to set some new and constructive precedents with the development and implementation of the TMI Action Plan.

For example, it contains an implementation policy for future requirements that will eventually be developed in accord with its long-term studies. During the past year, our policy on the short-term, urgent actions related to TMI has been one of prompt implementation, at the expense of possible l

delay in the startup of new units or special shutdowns for some operating 9

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These prompt and costly actions were judged to be necessary for public health and safety.

Having continued to examine and reexamine these urgent requirements in the broad context of the Action Plan, and having decided that only a small number of requirements needed to be added to the list for new plants, it follows that the remaining changes need not be imple-mented in the same urgent manner.

Thus, we should be able to adopt a more deliberate implementation policy as we continue to pursue changes that are desirable for long-term improvements in safety or maintenance of improvements already gained in the short-term.

There is an additional reason to be more deliberate in our future changes - that is, the need to avoid counterproductive actions because of finite resources or, worse yet, changes that may prove to be unsafe because they were inadequately studied.

The patchwork of requirements can become so complex in its details that it is not always clear taat some changes actually improve safety.

Accordingly, it has been proposed that an implementation policy for future regulatory changes in keeping with the lessons learned from the TMI accident would have four principal ingredients:

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Develop and implement additional TMI-related requirements in a priority I

j order that gives consideration both to risk reduction and to resource requirements (i.e., a priority system that gives greater weight to actions with a high potential for risk reduction and low resource requirements).

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Cbtain public comment on the substance and scheduling of implementation of the most significant new requirements prior to their issuance.

In nost cases, the opportunity for such review would be the formal public commeat period for a Regulatory Guide, a Standard Review Plan revision, or a regulation.

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Apply future requirements developed in accordance with the Action Plan uniformily to operating plants and to plants under construction, with due consideration of design or other differences among plants.

Require that implementation be complete by a specified date on all plants in operation or going into operation after that date.

Allow case-by-case exceptions to the deadlines for good cause.

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In order to minimize the cost of the future requirements to be derived from the Action Plan, and ausent new information to the contrary, set implementation deadlines so as to avoid downtime on operating alants and delay in startup of plants under construction beyond that ;cessary to accomplish the change in an orderly manner.

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An implementation policy of this kind, in conjunction witn wide dissemin& tion of the Action Plan and NRC sanagement adherence to resource priorities, shculd reduce uncertainties of significance to the public and the industry regarding the regulatory effects of TMI.

That would be a step in the right direction, but it would still fall short of wnat our long-range target ought to be -- the definition of an acceptable set of national reactor safety goals and standards l

inclucing a stable and generally aoplicable backfit policy, i

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v 22 REFERENCES 1.

John G. Kemeny et al., " Report of the President's Commission on the Accident at Three Mile Island: The Need for Change--The Legacy of TMI, U.S. Government Printing Office, Washington, DC 20402, October 1979, p. 63.

2.

Robert L. DuPont, M.D., " Nuclear Phobia--Phobic Thinking About Nuclear Power" (The Media Institute,1627 K Street, N.W., Washington, DC 20006, March 1980).

3.

U.S. Congress, Senate, Cannittee on Environmental and Public Works, Three Mile Island Nuclear Powerolant Accident, Hearings, before the Succommittee on Nuclear Regulation of the Committee on Environmental and Public Works, Ser. ate, Parts I, II and III, 96th Cong., 1st sess.,

1979.

4.

U.S. Congress, House, Committee on Interior and Insular Affairs, Accident at Three Mile Island Nuclear Powerolant, Oversight Hearings, before the Succommittee on Energy ano the Environment of the Cannittee on Interior and Insular Affairs, House of Representatives, Parts I and II, 96th Cong.,

1st sess., 1979.

5.

U.S. Congress, House, Committee on Science and Technology, Three Mile Island Nuclear Plant Accident, Hearing, before the Subcommittee on Natural Resources and Environment of the Committee on Science and Technology, House of Representatives, 96th Cong.,1st sess., June 2,1979.

6.

U.S. Congress, House, Comnittee on Science and Technology, Plans for Improved Safety of Nuclear Power Plants Following the Three Mile Island Accident. Hearing, before the Succommittee on Energy Research and Production of the Cannittee on Science and Technology, House of Representatives, 96th Cong.,1st sess., September 19, 1979.

7.

U.S. Congress, House, Cannittee on Interior and Insular Affairs, Salient Points of Hearings on Nuclear Policy Review, Ccanittee Print No. 4, a sunnary prepared for the Cannittee on Interior and Insular Affairs of the House of Representatives, 96th Cong.,1st sess. by the Congressional Research Service, Library of Congress, (Washington, D.C.

20402:

U.S.

Governnent Printing Office, December 1979).

8.

U.S. Congress, House, Comnittee on Science and Technology, Nuclear Power-plant Safety after Three Mile Island, report prepared by the Subcommittee on Energy Research and Production of the Committee on Science and Technology, House of Representatives, 96th Cong., 2d sess., March 1980.

9.

Mitchell Rogovin et al.., Three Mile Island: A Recort to the Commissioners and to the Public, Special Inquiry Group, U.S. Nuclear Regulatory Ccanission.

Available for purchase from the GPO Sales Program, Division of Technical Information and Document Control, U.S. Nuclear Regulatory Connission, Washington, D.C.

20S55.

.o-5 23 10.

U.S. Nuclear Regulatory Commission, "NRC Views and Analysis of the Recommendations of the President's Ccmmission on the Accident at Three Mile Island," USNRC Report NUREG-0632, November 9, 1979.

Available for purchase frcm National Technical Information Service, Springfield, Virginia 22161.*

11.

U.S. Nuclear Regulatory Commission, "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations," USNRC Report NUREG-0578, July 1979. Available for purchase from National Technical Information Service, Springfield, Virginia 22161.*

12.

U.S. Nuclear Regulatory Commission, "TMI-2 Lessons Learned Task Force,"

Final Report, USNRC Report NUREG-0585, October 1979. Available for purchase from National Technical Information Service, Soringfield, Virginia 22161.*

13.

U.S. Nuclear Regulatory Commission, " Investigation into the March 28, 1979 Accident by Office of Inspect 9an and Enforcement," USNRC Report NUREG-0600, August 1979. Available for purchase from National Technical Information Service, Springfield, Virginia 22161.*

14 U.S. Nuclear Regulatory Commission, Advisory Committee on Reactor Safeguards, Various letters to the Ccmmissioners by the NRC Advisory Committee on Reactor Safeguards regarding safety recommendations following the accident at Three Mile Island with the following dates: 4/7/79, 4/18/79, 4/20/79, 5/16/79, 5/16/79, 8/13/79, 8/14/79, 8/14/79, 10/9/79, 11/14/79, 11/14/79, 11/14/79, 12/10/79, 12/13/79, 12/17/79, 1/15/80, 1/15/80, 2/11/80, 3/11/80, 3/11/80, 3/12/80, 4/1/80, and 4/17/80.

~

15. Byron Lee, "An Appraisal of the TMI Accident," an address presented at the Annual Conference of the Atomic Industrial Forum, San Francisco, Calif., November 12, 1979.

16. Nuclear Safety Analysis Center, " Analysis of Three Mile Island-Unit 2 Accident," Report NSAC-1 prepared by the staff of the Nuclear Safety Analysis Center, Electric Power Research Institute, 3412 Hillview Ave.,

P. O. Box 10412, Palo Alto, Cal. 94303, July 1979.

17.

U.S. Nuclear Regulatory Commission, "NRC Action Plans Developed As a Result of the TMI-2 Accident," USNRC Report NUREG-0660, Vols.1 and 2, May 1980.

18. Miller B. Spangler, " Methodological Concepts and Issues Involving Psychic Costs and Benefits, Risk Perception, and Risk Aversion in the Use Management of Alternative Energy Sources," in Changing Enerov Use Futures, R. A. Faz:olare and C. B. Smith, Eds. Vol. 2 (Pergamon Press, New York, 1979) pp. 648-657.

19.

D. R. Muller, V. A. Mcore et al., "Recort of the siting Policy Task l

Force," USNRC Recort NUREG-0625, August 1979. Available for purchase fecm National Technical Information Service, Soringfield, Virginia 22161.*

'The documents are also available for purchase from the GPO Sales Program, Division of Technical Information and Occument contral H<

Nuclear Ligulatory Ccmmission, Washington, Dt.

20555.

l l

...... ~

m O professional reports FEDERAL-STATE COOPERATION IN NUCLEAR POWER PLANT LICENSING:

Federal Initiatives to Improve Federal-State Cooperation Part 111 Dr. Miller B. Spangler U.S. Nuclear Regulatory Commission ABSTR.4 CT Tne Caisert Ciffs decsson of the U.S. Chuit Court Quiy :3.1971) esuetisned a requirement for an expanded Environmenul Impact Statement (EIS) imotving an :ndependent evaluatters and balancng of ens:ronmental factors against benents bv the U.S. Atomic Energy Comm:ssion and its successor agencv. tee Nuclear Regulatory Commisuon (NRO. Since then, the AEC;NRC has prepared we:1 oser a nundred EISs represent:rg estensne reues expenence m dealing w,th highly vaned emircnmentalissues ci2 eg:on-spec:nc and site-specfic nature as wellas a numee-i of heanng :ssues of genene imporunce. In recent years. a growing number of States are meressmg their tmohement in emironrnental resiew and decsion makt::g affecung the licensing of nuclear power plants. The enersttv of <iung and permitung '.aws as weil as admimstrative polices and procecures by the vanous States are potentalsources cfincricency.n Federal-State coeperation. There are also probiems of wasteful duplicat:on and potennahties for deiay and confusion in the licensing of nuc! car power piants unless sign:6 cant impresements are made in Federal-State coc;eranon. This pape.

onginally presented at tne Third Annual Meeting of the Naucnal Assoc:ation of Enstrenmental P ofesnonals.n Feeruarv 1973..s presented in three parts for sequent:al publication. Part !. Frie cl. State Cooper:rien ut Nuclear P cr Mant f.xrmmt dtscusses: 10 env:ronmental.ssues in licensing and tte related roles of the NRC. tac uni:ty applican:. as *eil as other State and Federal agences; tiit the basis of mterest for increasing State :nvoisement :n licenung actmues; ad itiis the basis of interest :n a contmued Federal roie. Part 11. Crvers:ry o(Sure P :crace m Nuc!cer ?ower ?' ant I.ce ts:ng. proudes a renew of contrasung State roies and pracuces :n the'icensmg process from selected cases. gning s;e=21 attenuon to sev enwronrnental issues such as need for faclity and ute sciecuen. Part !!1. Fede-al Imricmcr to Improw Fede mi-Sair Coopererron :n Nucitar ibw-Pant lictmmt, desenbes a number cf Irinames bv the NRC to imprese Ticensing cooperauon including spec:al programs to involve State orTacais in NRC workshcps. formal agreeme::ts with States regarding hcensing procecures. contractual and inhouse research studies on safety and enstror. mental rene= =cthodolcres of possible ate est to 3tates,improsed :oordinatson with other Federal agene:es a-d genene uiemaiung and otner e: Torts to increase '.icensing efTcency.

NRC INITIATIVES TO 13tPROVE FEDERAL.

STATE COOPERATION IN THE LICENSING T..V PROCESS-ACTIVITIES OF THE OFFtCE OF STATE PROGRAMS

'i-The Office of State P egrar=s (OSP) of he Nue! ear M b M'

Regulatory Commission has engaged in numerous I

actnities directed toward improving Federal-State s /['

cooperatien in the lice : sing of nuefear power plants

-y ; f-and dealing with related fuel cycle issues. Many of L

.ie -

these activities hase drawn upcn the techrucal exper-tise of other NRC disisions as well as the OSP suffin

, j its lead reie. One primary objectise of these actait:es 4

is to tac:litate an eacnange of informanen on meth-

, lj 1;,

odologies, procedures. gardes. standards and factual nw twooa.wa u reonssoua. vet i, a wsa. n Pnciec n +e m 7191-5.% 41F* #65ccJc.C

J

.y 134 MILLER B. SPANGLER data on safety and environmental issues associated (1) Early arrangements to work with the staff and with nuclear power plant licensing and other areas of committees of the National Governor's Confer-NRC responsibility in which the States have an ence including two workshops under their aus-interest or shared responsibility.

pices (Atlanta and Chicago) to deselop an ex-Useful forums for the ex, change of such informa-change of views on the study's objectives and tion have been arranged by the OSP through work-potential proposals.

1 shops and conferences. Two Federal-State confer-(2) Exchange of views through direct contacts and ences were sponsored by the OSP on Power Plant correspondence with the Governors and various Siting in which experts and administrators from regulatory offices.

various State and Federal agencies were brought (3) A review of the purpose and scope of the program together for an exchange of information, ideas and by representatives of other Federal agencies at i

concepts. Proceedings of these conferences have been two meetings organized by the Council on Envi-i issued to reach a wider audience (NRC,1975a and ronmental Quality.

NRC,19764).

(4) The organization within NRC of a Study Task A number of special study efforts were initiated by Force to relate NRC experience to study objec-the OSP following the directive of the Nuclear Regu-tives and receive comments on possible alterna-

! story Commission in September 1976 to examine the tives.

matter of regulatory activity in environmental deci-(5) The organization of two important panels of sion making regarding nuclear power plants and to national experts to focus on two specific areas:(a) suggest steps that could be implemented to improve need for power or facility, and (b) the definition of tfus aspect of the licensing process. The following criteria for efTectiveness in regulatory activity.

reports relate to this OSP program:

(6) Contracts with five individuals and groups to assist in study areas where additional professional

• Improving Regulatory Effectiveness in Federal /

support was needed on special subjects such as State Siting Actions, NUREG4195.

funding regulatory activity, legal review of sta-

• Success Factor Evaluation Panet NUREG4196.

tutes-involving planning and matters of regional

• State Regulatory Activity involved in Need for organization.

Power, NUREG-0197.

• State Perspectives on Energy Fac:lity Siting, Regarding the study report on Water Supplies and NUREG-0198.

the Nuclear /.icensmg Process, the procedural steps

• Environmental P!anning and the Siting of Nuclear were far simpler with 'imited involsement of the NRC Facilities The Integration of Water, Air Coastal, staff (WRC,1977L The report was prepared for and Comprehensive Planning into the Nuclear transmittal to the NRC under contract with the U.S.

Siting Process, NUREG-0199.

Water Resources Council, which in turn assigned the

• Federal! State Regulatory Permitting Actions in study effort to the Interstate Conference on Water Selected Nuclear Power Station Licensing Cases, Problems (ICWP). The ICWP Executive Committee NUREG 0200.

serves as the Standing State Advisory Committee to

• Water Supplies and the Nuc!est Licensing Process, the U.S. Water Resources Council and manages the NU REG-0201.

activities of the ICWP. The ICWP is a national

• Nuclear Power Plant Licensing-A New England association of State, intrastate and interstate officials Perspective, NUREG-0202, and legislators whose purpose is to facilitate coopera-

• State and Local Planning Procedures Dealing with tion, consultation and exchange of information on the Social and Economic impacts from Nuclear Power conservation, use. development and administration of i

Plants. NUREG-0203.

water and related land resources, legal aspects, and

• Alternative Financing Methods, NUREG-0204.

Federal-State relationships in the field of water and l

l

• Need for Power: Determinants in the State Deci-related resources and to promote a harmonization of l

sion-king Processes, NUREGICR-0022.

State and intrastate views on these matters. Although 24 States and two interstate agencies participated in The manner by which these studies were prepared developing the report through attendance at formal reflects in itself a notable spirit of Federal-State meetings and review of drafts, no endorsement by any I

cooperation in improving regulatory effectiveness in State or Federal agency of the report'. findings and Federal-State nuclear power plant licensing actions.

conclusions was sought or is claimed. To preside a Two examples are meaningful in this regard. The plan spectrum of sariations in State and interstate proce-of execution in the preparation of the Preliminary dures for licensing or control of water uses by enern Staff Report on Improving Regulatory Effectiveness facilities, nine appendices were provided in the report m Federal / State Sirmg Actions involved the follow-by the following States: Georgia. North Carolina.

ing procedures (NRC,19'7at Wyoming. Montana. Washington. Minnesota. Penn-

\\

i l

t

~

~

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185 FEDERAL STATE COOPERATION IN NL1 LEAR POWER PLANT LICENSING sylsania. South Carolina. and the Delaware Riser funding scheme to be administered by the NRC and Basin Commission (WRC,19").

public comment was invited in the Federal Regurer The NRC Office of State Programs has also (Vol. 44, No. 218. Nov. 8,1979).

initiated a number of studies and workshops with Still another safety-related issue involving Federal-State agency participation invohing a variety of State cooperation is that of nuclear power plant safety-related issues. A number of States are imohed decommissioning policy. In March 1973 a report was in legal actions or have expressed serious concerns published on a" Plan for Reevaluation of NRC Policy over the lack of facilities for the permanent and safe on Decommissioning of Nuclear Facilities" (NRC disposal of high level nuclear wastes. He U.S. Energy 1978b). The Office of State Programs and the Office Research and Development Administration (ERDA),

of Standards Development sponsored three regional now the Department of Energy, has been authorized workshops during September 18-30,1978 in order to by the Congress to develop repositories for comm:r-receive comment from State representatives and pub-cial high level wastes. Its schedule calls for an opera-lished the Conference Proceedings (NRC 1978c).

tional facility by 1985. The U.S. Nuclear Regulatory Following the publication of Revision I to NRC's Commission has licensing and regulatory authority March 1973 plan, two regional State workshops to be over the repositories. including the authority to set held in September 1979 were announced in the red-siting critena which the repositories will be required cral Regurer (Vol 44, 50. 150, Aug. 2,1979). The purpose of the workshops was to discuss the modified to meet.

The NRC Waste Management Program and the plan and the progress made during the past year. This Office of State Programs held three regional work-included additional technical infcrmation consisung shops to solicit ideas from State executives and of an expanded report on the decommissioning of legislators on the siting and licensing procedures for pressurized water reactors and reports on the decom-high leve! waste repositories and to solicit comments missioning of boiling water reactors and low level on the NRC preliminary site suitability criteria. The waste bunal facilities. Comments were sought on workshops were attended by 170 invited State execu-preliminary staff reports on financial assurance and tives and legislators from 46 States. In addition, there residual activity limits, were over 30 observers from diverse backgrounds including the general public, government, industry, professional consultants and university faculty. Dis-PROCEDt'RES OR COOPERATIVE REVIEW cussion group reports and the analysis and recom-EFFORTS mendations of the workshops have been published (N RC,1977b,19783).

Dere are numerous examples of cooperative NRC-Another important problem imching Federal-State efforts regarding safety and environmental State coordination is that of emergency response and aspects of nuclear power plant licensing and related evacuation planning. In March 1977, the NRC Office activities in the mining, milling, transport and storage of State Programs had issued a report on " Standards of nuclear fuels and wastes or emergency evacuation and Procedures for Concurrc. ice in State and Local planning in the esent of accidental radioactive re-Government Radiological Emergency Re:ponse leases. The NRC has entered into formal agreements Plans' (NRC 197 c). In January 1979, the OSP with certain qualifying States regarding procedures issued a handbook entitled:-Radiological Emergency for safety and environmental protection in the mining Response P!anning: Handbook for Federal Assis-and milling of uranium, Moreover, prior to the tance to State and Local Government'(N RC 1979a).

formation of the NRC, the States of South Carolina Following the onset of the accident at the Three-and Louisiana, for example, entered into contractual Mile Island (TMI) Nuclear P! ant on March 23,1979, agreements with the AEC and the Department of public and governmental concern became heightened Transportation to provide studies of existing flows of over the adequacy of emergency response and evacua-radioactive materials in their respective States and to tion planning and governmental coordination of provide recommendations to make desirable improve-related activities. In October 1979, NRC's Office of ments in the transport and storage of nuclear materi-State Programs issued a staff report. -Beyond als (SCDHEC 1975 and LDC 1975).

Defense-in-Depth: Cost and Funding of State and A different kind of example of NRC-State cooper-Local Government Radiological Emergency Re-ation designed to improve the efTectiveness of nuclear sponse P!ans and Preparedness in Support of Com-power plant licensing is the agreement recently con-mercial Nuclear Power Stations" (Salomon,1979).

summated betweeri r.e Virginia State Water Control This report desenbes as -inadequate. sporadic, uncer-Board and the NRC on requirements pursuant to the tain and frustrating' the current hodgepodge funding Federal Water Poilution Control Act Amendments of approach to State and local government radiological 1972 (FWPCA) (NRC 197~d). Specifically, the emergency response plans. The report proposes a cooperatise efTons willextend to requirements for the e

L 186 MILHR B. SPANCUR control and consideration ofimpacts on water quality than proposed. Despite the frequency and con-and aquarc biota assoc:ated with the licensing and troversy of the "need" issue at NRC environmental J

regulatu 1. including early site approval, of nuclear heanngs oser the past four years. if past rxperience is power plants located within the Commonwealth in a reliable guide. it would appear unlikely that NRCs accordance with pnne:ples embodied in the Second evaluation of need will differ from the applicant's Memorandum of Understanding between the U.S.

determination by more than sescral years, and the Nuclear Regulatory Comnussion and the Environ-Atomic Safety and Licensing Boards of NRC, which mental Protection Agency. A brief summary of the make initial decisions on these matters (subject to points of the NRC Virginia agreement include:

appeal) have found that forecast differences of need by se eral years would be insufficient grounds for (1) Cooperation in the compilation of environmental denial of a construction permit. Moreover, no such information needed for early evaluations on water initial decision has yet been resersed.

quality and aquatic biota in meeting the jomt Malcolm Ernst. NRCs Assistant Director of En-information needs of NRClicensing and the State vironmental Technology, makes the following obser-issuance of water quality certifications pursuant vations. outlining certain procedures and principles to Section 402 of the FWPCA and the State for increased informational and analytical inputs by Water Control Law, including, where applicable.

States in esaluating the "need" issue (Ernst.1977)-

Section 316(a) and Section 316(b) considerations.

(2) An early meeting of Virginia and NRC prior to or The NRC believes that cooperatne efforts wnh States in during the environmental licensing review process this area would be useful, in that this could reduce the to discuss potential water quality and aquatic amount of duplicative review done by State and Federal impacts.

govemments. As a result. the NRC is in vanous stages of discussion with a umber of States to m what kind of (3) As early as practicabic, to make investigation and evaluation of these matters to issue a timely CNpeatm agmments can usefudy be wormed at.

U* P ""** P

• D** I"d *h*** *# "' ' **'

• h* **

• I permit pursuant to the State Water Control Law

• '3*""8 and Section 402 of the FWPCA as wellas Section them to the States or by relying upcn State analyses, the 401.

NRC can utilize State data and analvses in the NRCs (4) Maintain close communications throughout the decisional process. Several types of coo'perauve efforts are licensi'g review process including a status meet-posubic:

ing to 1ssess any significant new considerations (1) Establish common data needs.

that m.ty develop.

C) Establish common analytical methodologv.

(5) Condt:t combined or concurrent hearings, where (3) Utilize State data and analyses as an aciunct to NRCs feasible, on the Board's Section 402 pertr.its and 2naly585-NRCs construction permits, or other actions.

(4) Utilize State data, analyses and experuse directly in NRCs EIS and heanns process.

(6) Explore means by which joint or cooperative All f the above stop short of accepting a State decision preparation of parts of Environmental Impact regarding *nced as being dispositive in the NRC decisional Statements for nuclear power plants could be process. Even in the founh case, the N RC would be famthat accomplished with NRC assistance to the Board with the States methodology and would be prepared to in the form of appropriate information and tech

• tesufy that the NRCs methodology is similar and would nical support-likely have yielded a similar answer. However, in the founh case, the NRC reviene would not testify regarding the Three other States have entered into similar agree-spec:fic analyns performed by the State-that would be the ments with the NRC to coordinate revieiv activities responsibility of the State's representauve.

related to the water quality requirements of the FWPCA Amendments of 1972: Indiana. Nebraska Of special interest in view of the variable and and South Carolina.

unsettled nature of forecasting methodologies as Another area in which it ;s desirable that NRC and desenbed above for different State experiences are affected States work in closer cooperation is the issue certain procedural features and entera which have of *need for power"-or more appropriately. need been proposed for NRC-State agreement. It is sug-for baseload facility." since generating cost advan-gested that portions of environmental impact state-tages and improved fuel mix in the applicant's system ments and associated environmental evaluations on may,in some instances, provide sufficient reasons for need-(ar-baseload facility addinons would involve adding baseload capacity even in the face of reduced analysis of:

l rates of growth in electncity demands. The "need-l issue. of course, is re!cvant to NEPA requirements

• Need-for-power, ine!uding likefy positive or nega-since one alternative to the proposed construction of a tive errors in forecasting e:ectricity demand.

baseload ; hnt is not to build it at all, or at a later time

• Net economic benefits through retiring or placing 1

I l

187 FEDERAL-STATE COOPERATION IN NUCLEAR POWER PLANT LICENSING on resene status existing units with high operating electricity demand growth in the senice area or power pool region (to be esaluated whether the cost.

• Adsantages of system fuel diversification.

impact is deemed sienificant or nott

• Cost-benefit comparisons of starting construction of a nuc! car power plant earlier than actually (i) growth in regional population. number of households or residential customers.com-needed comparea to later than actually needed due mercial and industrial activity (especially to forecasting error, large firms that are heavy users of electric-Such evaluations and input to NRC's environmen-ity);

tal impact statements will be prepared under guide-(ii) a sensitivity analysis of the impact of high and low assumptions of rising real prices lines and criteria mutually acceptable to a cooperating of electricity, but not necessarily a specific State and NRC in order to assure that the needs of form of rate restructuring; both are met. and will be subject to review and modification by NRC as necessary to meet its full (iii) the collective impact of voluntary and NEPA responsibilities. Specific guidelines have been government-induced nonprice conserva-tion measures that are reasonably foresee-proposed (Denton,1977a) able to occur within the forecast period of The need for adding baseload (nuclear) generating relevance to the immediate investment de-capacity to an applicant's system can be justified in cision:

the public interest if the following criteria applied in combination (or possibly singly) are persuasive:

(iv) regional saturation and baseload implica-tions in the use of electricity in both (a) A need-for-power analysis that determines the summer and winter space-conditioning adequacy of baseload generating capacity which and for other appliances using substantial would encompass (i) all proposed additions or electricity; deletions of generating facilities for several years (v) the relationship of fuel substitution in the beyond the planned inservice date of the proposed region such as the use of heat pumps or plant: (ii) forecasts of electrical energy demand solar energy in space heating and cooling, for the general service area of the utility as well as the growth of all-electric systems in new the interconnected power pool which :nay serve as building construction, industrial conver-a market for export sales of baseload energy as sion from gas to electric furnaces, etc.,

well as a source of baseload energy purchases: and including the stimulus of alternative sce-(iii) the contribution of baseload capacity to total nario assumptions on relative price move-capacity needs for meeting reliability or reserve ments and fuel interruption uncertainties margin requirements in view of changing trend for the key fuel options:

relationships between baseload, intermediate and (vi) a discussion of the outlook for technologi-peaking needs as reflected in system load duration cal advances improving the efficiencies of curves or production simulation models.

electrical consumption or in developing (b) An analysis of the net economic benefits of new uses for electricity of importance to proposed or potential actions for placing higher the regional analysis within the forecast i

cost units on reserve or in retirement, especially period of relevance.

those units whose high operating costs have resulted from a sharp escalation of fuel prices.

(f) Forecasts of electrical demand should be pro-(c) A judgmental evaluation of public interests of vided separately for the major custorner classes:

national and regional importance stemming from residential, industrial and commercial.

an improved mix of fuel for the applicant's system (g) In ascertaining need for power, the unreliabilities so as to reduce vulnerability to unexpected inter-mherent in forecasting methodologies would not ruptions of a given fueltype (such as imported oil) require a precise year of need, or scheduled or risk of a dramatic rise in prices for any fuel of inservice data, but rather a

• window oflaunch" of substantial use in the applicant's system.

perhaps several years would suffice corresponding to a range of high and low forecasts of demand (d) No specific forecasting technique (econometric or growth for baseload capacity additions with feasi-judgmental) will be required, but the rnethod-ble interconnection. An analysis of the likely l

ology selected shall fall within the range of ac-ceptable professional practices.

positive or negative errors in forecasting that l

(e) No forecasting methodology will be deemed ac-could reasonably be expected for the regica ceptable unless it includes a reasoned considera-served by the applicant's system. as well as tne tion of the following causal factors which poten-likely asymmetry of cost penalties of starting tially might have a significant impact on future construction of a nuclear plant earlier than actu-G

-,,-,,-.._.,.,.n

.n.

.e.---...-,.

o 188 MILLER B. SPANGLER ally needed compared to later than actually sharing of propnetary information in NRC's possession needed, should be developed as the basis for mth the State.

determining an appropriate window of launch.

5. Each agency will explore means by which its traming (h) Further detailed guidance on form and content is pr grams may be made available to the other.

6. Nothing in this Memorandum is mtended to restrict or provided in NRCs Draft Environmental Stan-extend the statut ry auth r:ty (e:ther NRC or the State dard Review P!an. Any substantive revisions of this draft will be sub'ect to discussion by the I

between the State and NRC under section 274b of the parties of this Agreement with the objective of Atomic Energy Act of 1954. as amended.

resolving any differences of viewpoints regarding

7. De principal NRC contact under this Memorandum input requirements to NRC environmental state' shall be the Director of the Office of State Programs.

ments in need for baseload facility analysis.

The principal State contact shall be the Chairman of the Energy Facihtv Site Evaluation Counc:l(EFSEC). Sub-The flexibility permitted in the previous guidelines agreements wdl name appropnate individuals, agencies regarding the specific form of forecasting method-or offices as contacts.

ology (as distinguished from substantive elements to S. This Memorandum shall take effect immediately upon be included in whatever methodology is selected) is an signing by the State and the Nue! ear Regulatory Com-important feature that would make practicable its mission. and may be termmated upon 30 days wntten application to a number of State forecasting proce-nouce by either party.

dures. For example. discussions held between the technical staffs of the State of New York and the A pioneering agreement was signed on April 6.

NRC on forecasting methodologies and review proce-1979 by the NRC and New York State (NRC,1979b).

dures as related to need-for-facility analysis revealed a This agreement between the New York Departments high degree of parallelisms which would indicate a of Public Service (DPS) and Environmental Conser-need for relatively modest changes in the above vation (DEC) and the United States Nuclear Regula-proposed guidelines and criteria in order to reach tory Commission (NRC) sets forth mutually accept-agreement on specific wording.

able levels of cooperation between the State of New Several States (New York, Indiana and Washing-York and NRC related to providing NRC with ton) have entered into agreements with the NRC specific technical support of the DPS staffin prepara-regarding principles of cooperation in the regulation tion of designated sections of the NRCs Draft Ensi-of nuclear activities covering a broad range of review ronmental Statement (DES) and Final Ensironmen-and hearing activities. An example is the "Memoran-tal Statement (FES) for New Haven Nuclear Station, dum of Agreement between the State of Washington Unit Nos. I and 2.

and the U.S. Nuclear Regulatory Commission," dated it is the intent of this agreement that the technical September 6,1978, which provides for the following staff of the DPS will provide services insolsing Pnnciples of Cooperation:

analysis, evaluation and written rater:al in pre-selected subject areas, utilizing the NRCs Environ-

1. Toward these goals, the State and NRC agree to explore mental Standard Review P!ans. This cooperatise together use development of detailed subegreements in endeavor is intended to reduce duplication, provide areas of mutual concem. including, but not necessanly for more effective use of resources and permit a more

!amited to, environmental reviews (or portions thereof) orderly and efficient hearing.

of nuclear fac:lities subject to licensing by NRC or The eighteen-point agreement is both comprehen-certtfication by the State Energy Facility Site Evaluation sive and detailed. The staff of the DPS will provide to Council (EFSEC): siting consuferatio's; conduct and n

the NRC information for inclusion in the DES and structure; format of heannes: confirmatory radiological environmental monitoring' around operating nuclear FES which shall primarily consist of technical review facilities: decommissioning of nuclear facilities; emer-assistance in the subject areas of need for power, gency preparedness pisaning; response to radiological hydrology, land use, demography, ecology (aquatic incidents: and radioactive material transportation moni-and terrestrial) socio-economics, plant and trans-tonng.

mission facility description (to include nor.-

2. Subegreements under this Memorandum may provide radiological waste systems), non-radiological moni-for activines to be performed by the NRC or the State toring ' programs, impacts from construction and under mutua3y acceptable guidelines and enteria which operation, environmental noise, alternative plant and assure that the needs of both are met.

transmission systems, J. For acuvitics performed by the NRC or the State at the The staffs of NRC and the State of New York request of NRC or the State under specific subagree, developed a " Protocol for the Conduct of Joint ments to thts Memorandum. the agencv, making the request will explore means by which compensation may Hearings before the United States Nuclear Regula-be made available to the other agency or by which the tory Commission and the New York State Board on costs may be shared.

E'ectrical Generating Siting and the Environment:

s. NRC agrees to explore with the State the possibility of New Haven I and :" which was proposed for consid-

.y.,.

,,,y w

---.----ore-

~

i 189 FEDERAL STATE COOPERATION IN NUCLEAR POWER PLANT LICENSING eration by both parties on April 27.1979 ( Flynn et al..

coordinatise efforts from a largely passne or reactne 1979). One of the key provisions of the protocol mode to a more actise or initiating mode msohes the invokes the conduct of the esidentiary hearing. It was alloation of increased tinancial and manpower re-proposed that the evidentiary heanng shall proceed sources within NRC and other governmental agen-on a contention issue basis--either a designated cies. This, of course, would require resolution through contention (NRC) or a contest:d issue ( Artic!c Vill).

budgetary procedures or possibly an adnunistratne After an adequate period for full discovery of the reallocation of prioritics involving resource assign-applicants' direct case on a contention! issue, proper ments.

parties shall file the:r direct cases on that conten-Tables 1-3 show various research studies (com-tron / issue. Thus, both parties (NY State and NRC) pleted, in progress, or planned) initiated by the NRC would establish staff positions on alternatives and Cost-Benefit Analysis Branch and the Environmental related issues before the start of the evidentiary Specialists Branch. All of these studies are of generic hearing. At previous hearings on proposed nuclear significance to the improvement of environmental power plants in New York State, there was a diver-reviews in the nuclear power plant licensing process gency of practice in this regard since the NRC StatT even though some are oriented to specific cases. Since took conclusive positions before the start of hearings many socioeconomic, water quality and ecological whereas the staffs of the involved New York depart-impacts are site-specific and. plant. design-specific ments did not take affirmative positions on issues (especially cooling system alternatives). a spectrum of throughout the conduct of the hearings.

confirmatory case-related studies covering a vanety of However, another divergency of analytic proce-situations and circumstances will be needed to pro-dure remains unresolved. Whereas Article Vill re-vide a comprehensive set of empirical data on impacts quires that the proposed site and at least one alterna-actually realized that will serve to improse the quality tive site be examinei with equal detail regarding and defemibility of estimates or forecasts of these beneficial and adversi environmental impacts, the kinds of impacts in an adsersarial type of hearing. It practice of the NRC is to examine only the proposed should be noted that, in confirmatory impact assess-site at a high level of detail with analysis of alternative ments it is no less important to ascertain which sites made on the basis of reconnaissance leselinfor-impacts on the human environment were msigmjicant n'ation (N RC,1978d).

as it is to determine the magnitude of significant Although a detated schedule was agreed upon for impacts. This is so because the potentiality for public the cooperative-staff reviews and joint hearing con-controversy covers a wide spectrum ofimpacts, many duct regarding the New Hasen I and 2 Nuclear of which are subsequently determined to hase been Station, further stati activity has been suspended insignificant for specific sites or which can be reduced pending the outcome of an appeal to the New York to acceptable levels through mitigative measures State Siting Board.

(Cleary,1977; Spangler,1978). States which are engaged in their own Etnironmental impact State-ment preparation or licensing review functions would GENERIC STUDIES,31ETHODOLOGICAL undoubtedly find many of these confirmatory studies PROCEDURES, AND CONFIRatATORY helpful to their own analyses as well as decision making on further delineation of programs and poli-RESEARCH EFFORTS OF THE NRC cies t deal with environmental matters, including If the NRC' licensing review process would be legis ative acti ns. For those States with an interest in strengthened and wasteful duplication of effort would gaining more insight regarding NRC's safety reviews be avoided by increased infnrmation and analytical I # ****'

inputs in selected areas from the technical staIfs of 8'"*""**'**I5

• * * * * * *d '"

various States, it would also appear that information the (NUREG) Accession L2sts for U.S. Nuclear Regu-and analyses produced by the NRC staff and their lat ry Commission Publications. Several such studies research contractors would be of potential benefit to a f widespread interest are:

number of States in the exercise of their licensing reviews and permitting functions regarding proposed nuclear plants and sites. Such a two-way flow of e Reactor Safety Study: An Assessment of Accident information has already been practiced to some Risks in U.S. Commercial.Vuclear Power Plants degree through individual or agency contacts and (known as the Rasmussen! MIT Study), W ASH-formally organized workshops.

1400 (NUREG-75.014). U.S. Nuclear Regulatory However. much of this exchange of information Commission. October 1975.

has been opportunistic or based on happenstance oi e Health Effects Attributable to Coal.md.Vuclear contacts rather than the result of systematic efforts or fuel Cycle Alternatives. Draft, N U REG.0332, formalized agreements for the exchange of informa-Office of Nuclear Reactor Regulation U.S. Nu-tion. One of the problems is that converting such clear Regulatory Commission, September.19 7.

e 190 MILLER 8. SPANCLER TABLEI study on the generic capital cost and intal generat;ng cost for Confirmatory and Gener.c coal and nuc! car-power plants t N UREG 024I through Research Program Related to Socioeconomic Impact Auessment

,d 48) 1.

Como/eted Contraer Studier "Sensinvity of Generation Cost with Changes in E:ectncity

• Development of Methodologies and Analytical Procedures Nuclear Power Ptants* INUREG46346 to Quantify the impact of Nuclear Power P! ant Construcuon and Operanon on Local Commumnes"(Turkey Point)

"The Enuronmental Effecu of Using Coal for Generaung

• • • "'*'7

• Assessment of the impact of Nuc! car Powr P' ant Construc-non and Operation on Small Regions"(Robinson) ggj,,

g "A Post Licensing Case Study of Commumty Effects at Two

.!mprovement of ORNL CONCEPT Computer Code and Operaung Nuclear Power Plants

• IPJgnm and Wilstone)

Updated Data Inputs for the Estimanon of P! ant Capital (ORNL. NUREG.TM 22)

Cosu and Operanon and Maintenance Costs.

• Socioeconomic Impacts: Nuclear Power Station Siung*(A

.Commumty. Regional. Health. and Environmental Impacts Lterature Review)(NUREG4150) of the Coal Fuel Cycle"

• Effects of Nuclear Power P! ants on Co nmumty Growth and Residential Property W4ues"(NUREG.CR-0454)

Ill. Manned Studier-

"A Post L censing Case Sudy of Community Effects at Two

• tpdate of Genene Investrnent Cost Study for Nuclear and Operaung Nuclear Power Ptants (Haten i BrunswicL)

Coal Generaung P' ants" (NUREGiCR4916)

Source Cost-Benc6: Analysis Branch. Omsson of Site Safety and

• Post Lcensing Commumty Impact from Trojan Nuclear Enuronmental Analysis. Nuclear Reactor Regulation.

Power Plant"(NUREG,CR-0973)

N RC.

-trapact of Offshore Nuclear Generaung Stauons on Recrea-TABLE 3 uonal Benavtor at Adjacent Coastal Sites"(NUREG-0394)

ConArmatory and Generic Research Programa Related to

" Study of the Visual Change Within a Region Due to Environmental Assessaients Alternative Cosed Cycle Cooung Spiems and Associated 1.

Como/cred Comroct Studier Socioeconomic Impacu* (NUREG, CR-0975. 0977. 0986 0949. there are three addiuonal vols. **'ch have not yet been "The Use of Reconnaissance LevelInformauon for Environ-assigned numbers) mental Assessment *(NUREGlCR 0990)

• Three %1e Island Telephone Survey

• NUREG/ CR-1093)

• Comparuon of Simulation Models Used in Assessing the AlTects of Power-Ptant-induced Mortahty on Fish Popula-II.

Studies in P ogrest tions* (NUR EG/ CR4C4)

• Nuclear Power Station Construct:on; aber Force %gra.

" Fish P-ocecuan at Steam-E!ectne Power P! ants: Alternauve tion and Residential Choice

• Screemns Devices * (Published by Oak Ridge Nanonal Laoo.

"Small Region Forecasts of Populauon and Economac Actmty*-Tecanacal Assistance From U.S. Departrnent of

• The Applicanort of Fishenes Management Techruques to Cornmerce A=mns Impacts: Tast I Report"(NUREGr CR 05*:)

"Construccon Labor Force Esurnates"-Techmcal Assist.

" Management of Transmission Line Rignu of Way Far Fish ance From U.S. Department of Labor and Wildlife *(An anteragency report being pubhshed by the

'E*"'""' ' ""*'I

" Twelve Post Ucensing Studies of the Socioecononne Im-pacts of Nuc!aar Power Plant Siung*

"The Application of Aerial Photography Using Infrared Imascry f r Environmental Momtonns of Operaung Nuclear 5-of TMI we Plants (A report being pnnted by the U.S. Government

• Effect of TMI on Real Estate Markets

• Pnnung Office)

• The Social and Economic Effects of the Accident at Three g,

gag,, jy %

Wie Island-Findings to Date* (NUREd/ CR-1215.)

• Saocide Discharges from Nuclear Power Ptants into Receiv-

!!!. Mamed Studws:

ing Waters"

" Land Use and Demograpnic Changes in the Vicimty of

" Simulation Models to Determine impacts of Nuc! car Power Nuclear Power P!anu*

Fac:hties on Fishenes*

Source-Cost-Benefit Analysis Branch. Dmsson of Site Safety and ecu d Nwr mat Operanon on he BW Environmental Analysis. Nuclear Reactor Regulanon.

• sigmficance of Threadfin Shad Impingement at Nuclear NRC.

po er Ptants in Southeastern Reservoirs *

• The Use of Energv Flow Analysis in Land Use Impacu of

(

TABLE 2 Alternative Caoling Sprems for Nuclear Power P' ants

• ConGrunstory and Genene Research Program Related to Technology Aueesment

• Methods to Assess impacts on Hudson River Stnped Bass Populauons 1.

Conwdered Contreer Studer

• Methods to Assess Impacu on Hudson River White Perca

" Commercial Elec.nc Power Cost Sundies* ( An 8-wolume Populations

• 191 FEDERAL-STATE COOPERATION IN NUCLEAR POWER PLANT LICENSING Reactor Safety Study Report (W ASH 1400) in

-source M Condenser Entrainment Mortahty on uuat.c Light of the Risk Assessment Resiew Group Re-orfanism*

%snetics of Chlortne-Ammonia interaction in Sea Water port.' a statement issued by the U.S. Nuc! ear Regulatory Commission on January 18. 1979.

• The Products. Pathays. Effects and Fates of Chionnanon

• Final Uguid Pathway Generic Study Report.

By-productc NUREG-0440. a comparatise study of radiological impacts on man and biota of a postulated core-melt 111. Planned Smd*5--

(Class 9) accident for floating nuclear plants versus

-Chenucal Effluems in Sarface Waters from Nucicar Power land based plants. U.S. Nuclear Regulatory Com-Ptantf mission. February 1973.

"Value of Populanon Replacement and Habitat Ennance.

ment to Compensate for Nuclear Power Ptant Impacts on

• Radiological Ef)7uent Technical Specifications.

NUREG-0472 for PWRs and NUREG-0473 for Fishenes-BW Rs. U.S. Nuclear Regulatory Commission. July

-EnnronmentalImpact Assessment Methods and Mitiganon Measures to Reduce Risk to Aquauc and Terrestnal Biota 1979.

• Activities. Effects. and Impacts of the Coal Fuel Apphcability of Ptankton Studies in Power P! ant Momtor.

Cvelefor a 1,000-MWe Eectric Power Generaung ins Pmsranu' P' ant, a repott prepared by Teknekron. !nc. for the

• Apphcatnlity of Aenal Photograonse Techmques for Site U.S. Nuclear Regulatory Commission. October Assessment Relative to Terrestnal Ecology-I9I9-

-Environmental Momionns Data Renew" Source: Enwonmental Spectahsts Branch. Divmon of Site Safety A study of special significance for those States and Environmental Analysis. Nuclear Reactor Reguia-interested in siting policy with particular focus on non. NRC.

safety-related issues is the Report of the Siting Policy Task Force (NUREG-0625. Auzust 19 9). Nine pol-

• Public Comments and Task Force Responses Re-icy change reenmmendations we$t made by the Siting

~

garding the Environmental Survey of the Repro-Policy Task Force to achieve the following goals cessmg and Waste Management Portions of the

{p, ;;;y LWR Fuel Cvcle. NUREG-Oll6. Office of Nuclear Material Safety and Safeguards, U.S. Nuclear (1) To strengthen siting as a factor in defense in depth hv Regulatory Commission March 1977.

establishing requirements for site approval that are

• 7he Nuclear Argulatory Commzssion Low-Level independent of plant design consideration. The present Rad!oacnvc Waste Management

Program, policy'of permitting plant design features to compensate NUREG-0240. Office of Nuclear Material Safety for unfavorable site charactensucs Sas resulted in im-and Safeguards. U.S. Nuclear Regulatory Commis.

proved designs but has tended to deemphasize site "I* 'i*"-

sion. September 1977.

(::) To take into consideration in siting the risk associated

• Joint ERDA-NRC Task Force on Safeguards (U),

with accidents bey nd the design basis (Class 9) by Final Report (Unclassified Version), U.S. Nuclear establishing population density and distnbution ente-Regulatory Commission and U.S. Energy Research n,, p, ant design improvt ments have reduced the proba-I 1

and Development Admimstration. July 1976.

bility and consequences of design bests acciaents, but

• A Study of the Nuclear Regulatory Commission there remains the residuni nsk from accidents nos Queality Assurance Program. NUREG-0321, pre-considered in the design basis. Although this nsk cannot pared by Sandia Laboratories for the U.S. Nuclear be complete!y reduced to zero, it can be sistuiscandy Regulatory Commission. August 1977.

reduced Sy selective siting.

• Transport of Radioactive Materialin the [].S.: A (3) To requnte that sites selected will msnimize the nsk from energy generation. The selected sites shculd be among Detailed Summary of " Survey of Radioactive th* bc't available in the region where new generating Material Shipment in the lhtted States *, NU REG-capacity is needed. Siting requirements should be strin-0073 prepared b= the Battelle Northwest Labora,

' 8.ent enoush to limit the residual risk of reactor opera-tory for the Office of Standards Development. U.S.

'*#i"8'"' "' * 'li *i"***

• h' ""*!**'

Nuclear R'I"latory Commission May 1976.

option from !arge regions of the country. This is because

• Orcupadonal Radiation Exposure as Ught Water energy generation from any source has its associated Cooled Pbwr Reactors: 1969-1975, T. D. Mur-nsk. with risks from some energy sources being greater phy, et al., NUREG-0109, Office of Nuclear Reac-than that of the nuc! car option.

tor Regulation. U.S. Nuclear Regulatory Commis-As a result of the accident at the Three Mile Island sion. August 1976.

• Risk Assessment Review Group Report to the U.S Nuclear Power Station. the President's appointed Nuc/ car Regulasory Commission. H. W. Lewis.

Commission has made a number of recommendt. ions Chairman NUREGiCR-0400. September 1978.

to improve safety and emergency evacuation planning

• *NRC Statement on Risk Assessment and the (Kemeny,1979). A preliminary analysis and siews of l

O 192 MILLER B. SP%CLER the Nuclear Regulatory Commission regarding these difficulties in forecasting future electricity pr:ce elas-and other recommendations was released on Novem-tic: ties which is a frequent and troublesome issue m ber 9,1979 (NRC.1979c). A number of other NRC need for power analysis in nuclear power !icensing studies related to the safety aspects of the Three Niile actions. Ntany other hearing testimomes would also Island (TNil) accident are:

provide valuable insight on methodological proce-dures of generic importance.

• T.tfl-2 f.essons Learned Task Force Status Report Regarding Environmental Impact Statements.

and Short-Term Recommendations, NUREG-there are also a large number of examples (not yet 0578, July 1979.

catalogued) that would lend useful insight for the

• Title f.ist: Publicly Available Documents.17tr*e treatment of special environmental and socioeco-Ele Island Unit 2, NUREG-0568. Rev.1 Cumu-nomic issues. One such example is the EIS for the lated to June 30,1979.

Indian Point Unit No. 2 nuclear plant, which exam-

• Investigation into the.4(arch 23,1979 77:ree.tfile ined at greater than customary depth the internal and Island Accident by Office ofinspection and En-external (or indirect social) costs associated with forcement, NUREG-0600, August 1979.

various cooling system alternatives in compliance

• Evaluation of I.ong-Term Pbst-Accident Core with the ASLB's decision to require backfitting of a Cooling of 77:ree.4 file Island Umr 2, NUREG-closed-cycle cooling system to reduce adverse impacts 0557, 5tay 1979.

on certain important fishery species of the presently

• Population Dou and Health Impact of the Acci-operating open cycle (once-through) cooling system dent at the 77 tree.tfile Island Nuclear Starian, (NRC,1976b). In support of the analysis of the NUREG 0558, Niay 1979.

aesthetic (and related water and land use) impacts of

• 77 tree.tfile Island Telephone Survey: P eliminary different types and heights of cooling towers, the Report on Procedures and findings. NUREG/ CR-NRC contracted for a special methodological study 1093. prepared by Niountain West Research, Inc.

by Jones and Jones (1975), a landscape architecture for the U.S. Nuclear Regulrtory Commission, and planning consulting firm. Another useful exam-October 1979.

pie involving the issue of risk perception and its possible impact on nearby tourism is found in the s c ec n m mpact treatment of tk proposed NRC INHOUSE EFFORTS TO IMPROVE THE fl atin8 nuclC2r power plant near Atlantic City as set 1.lCENSING PROCESS forth m the Draft Environmental Statement for the Those States which hae; expanded or are contemplat-Atlantic Generating Station and a supporting con-ing an expanded role in b.iuclear licensing review tract study by Baker et al. (1977) on related impact process may find useful information in a number of assessment methodology (NRC,1976c).

studies or published materials that are designed to Regarding the possible interest of States in impacts improve the effectiveness of NRC's licensing process associated with nuclear energy centers, a special or that provide a more in depth investigation of projects study by the NRC commands attention. The controversial issues than are normally provided in Energy Reorganization Act of 197.1, which estab-l routine case reviews. The latter would include special lished the NRC as an independent agency, mandated staff treatment and more thorough development of in Section 207 the development of a report which methodologies regarding issues of unusual difficulty would provide any appropriate conc!usions and rec-or complexity in certain Environmental lmpact State-ommendations concerning the feasibility and practi-ments or supplemental hearing testimonies. An exam-cality of locating nuclear power reactors and other pie of a useful testimony is that prepared by Dr.

elements of the nuclear fuel cycle on nuclear energy Sidney Feld, Regional Environmental Economist in center sites including information on a survey of NRC's Cost-Benefit Analysis Branch,regardinginter-possible sites (NRC,1976d). The study design features venor Contention 1-19 in reference to the proposed and issues to which attention was directed are de-Wolf Creek Nuclear Generating Station (Feld,1976):

scribed in the Executive Summary-The applicants' projections of demand, and thus the assess-ment of the need for the proposed WCGS, are inadequate The Nuclear Energy Center Site Survey (NECSS)is a study and overstated because they fail to take into account pnce of a potential altemative siting approach for nuclear power elasticity of demand for electricity. The real pnce of electric-and fuci-cycle fac:lities--an approach that would cluster ity per kilowatt hour will increase, and will result in a sizeable groups of such facilities on a relatively small decrease in demand from that predicted by the applicants.

number of sites, as contrasted with current "dispe"ed" siting pracuces. The largest aggregation of reactors on a in his supplemental testimony, Dr. Feld provides single site being planned today is four, and this quaa is an tiluminating review of the diversity of expert assumed tfor comparatise study purposes) to be the typical opinion and some of the serious methodological dispersed

• site by the year 2000.

I l

1 FEDERAL-STATE COOPERATION IN NUCLIAR POWER PLANT LICENSING 193 Three basic types of nuc! ear energy centers are consid-Analysis and Cost-Benefit Balancing" includes para-cred:

metnc studies on the influence of growth (through the

• Power plant centers.,;onsisting of 10 to.t0 nuclear year 2000) in electncity demand: effects on uranium electnc generating units of 1:00-megawatt electne capac-

• price, the price of separative work, MOX fuel fabnca-ti n price, fuel disposal cost; effect of discount rates e c!e centers. consisting of fue! reprocessing plants, on decisions to reevele; ettect of the fast breeder j

mixedhxide fuct fabncation faclities. sad radioactive reactor; and effect of uncertainties on fuel cycle :osts, j

waste management facilities.

in order to achieve the societal benefits of makmg

• Combmed centers, contaimng both power plants and thi. 'icensing process more stable a.1d predictable and fuel-cycle faelities.

Concentraung on differences from dispersed siting ap-the cos: advantages of reducing the oserall time proaches, the survey evaluates the feasibility and pract: cal-required tra issue a construction permit and construct icy of the nuclear energy center (NEC) concept.

the nuclear power plant, the NRC has developed a The major techrucalfmnbdhy issues include dissipation number of i:.itiatives resulting in studies or reports of waste heat from the energy center;transnnssion systems that would be useful to States in the exercise of their design, reliability, and economics: economics of energy licensing or Wttig godilih h h center construcuon: and radiolog: cal and environmental fits, of course are principally realized at the State impacts.

I" P*

N ** O' C "5"*'I I*I applicant's general service area. Hence, N'5"

• The major procrical#y issues include jurisdictional and it would insututional constraints: social. socopolitical and soc:o.

appear that States would have substantialinterest in econotrue factors: financing: questions related to ace: dent such initiatives, lending support and encouragement nsk, natural disasters, and national security: and safeguard.

to facilitate the attainment of these objectives. A ing of strategic specal nuclear matenals from theft and nuclear plants from sabotage.

number of NRC e! Torts are noteworthy in this regard:

While feasibility evaluation is primanly a technical study, the pracucality isst, are people-oriented they (1) Development of policy and the review of specific involve she various interests, perceptions and values of applications for standardized nuclear power people and the characteristics of institutional instruments.

plants (AEC,197,5 and NRC,1977e).

The sursey also meluded a ges.aal screening effort (2) The formulation of acceptable procedures for directed towards identifying large land areas that would be early site review (NRC 1977f).

likely to contam potenttally suitable NEC sites. The screen-(3) The development of safety and environmental ing was done for each of the nine electne re!iability regions Standard Review Plans which provide specific into whicn the area of the continuous t/nited States is dmded for co -dinated planning of dependable electne procedural instructions to the NRC staff responsi-ble for conducting reviews for licensing applica-power supply.

The screemng was accomplished by use of selected tions in the construction and operation of nuclear coarse entena involving water resources, seistructy, popula-power plants, inc!uding appropriate methodoio-uon distnbution. and public lands. Both retinement of gies and review enteria where practicable and entena applied and the factoring-in of additional considera-desirable (N RC,1975b.1979d,1976f).

tions would be needed to identify specfic sites. This would

(-1) The development or improvement of standards require substantial expenditures of time and money, and and technical specifications for plant operations I

f could not have been accomplished under the NECSS.

which set effective linuts on safety and environ-Another study of potential value to States which mental impacts pertaining to each reactor or plant would participate at greater depth in nuclear power design (NRC 1976g.h: 1975c).

plant licensing reviews is the GESMO study (Generic (5) The development or improvement of regulatory Environmental Statement on the Use of Recycle guides which provide information on the kinds of Plutonium ir. Mixed-Oxide Fuel I.ight Water Cooled information and analyses to be submitted by the Reactors). The scope of safety, environmental and applicant for a construction permit or operating license (NRC 1975d.ef.g: 1976i: 1977g).

economic analysis of options regarding plutonium reevele found in this study provides far more useful information reprding short-range and long-range A number of the above NRC initiatives are in-fuel cycle and (LWR) nuclear plant review considers-tended to provide other benefits or advantages in tions than its rather narrowly-defined title might addition to their role in making the licensing process suggest (NRC 1976c). The study was prepared to aid more uniform ano predictable or to achieve the cost the Nuclear Regulatorv Commission in the process of reductions in shortening the licensing and construc-arriving at a decision as to whether or not the use of tion time. For example, early site reviews hold prom-t f

mixed-oxide fuel (a mixture of recycled plutonium

!se of earlier and more effective public participation in oxide and uranium os:de) in light water reactors the licensing process. Standard Review P!ans will t

should be psemitted on a wide scale basis and, if so.

reduce unproductise detailed information and anal-under what conditions. Chapter !! on *Econonue yses for !ess censequential impacts and focus more 1

194 MILLER 5. SPANGLER effecusely on the more imporunt safety and ensiron-pacity. (a) methodolocical and information require-mental issues, thus contnbuting to sounder and rnere ments in the analysis of alternatne sites. (5) cntena defensible licensing dec:sions induding nutigatne for the assessment of nuclear piant impacts and measures. The dese!opment or improsement of stan-

=inga:ne =casures: te) gener:c procedural entena to dards. technical spe 6 cations and regulatory guides denne :nore concretely NRC responsibility in assess-will have simdar bene 5ts.

=ents and decisions regarding cenain water-related A staff report by an NRC study group (Denton.

impacts in relation to the statutory authonties of EPA 19'~b) made a number of recommendations involving and permitung states. (~) NEPA dec:sion critena for opportunities for impresing the licensing of nuclear OL reviews. (3) occupational radiation exposure power plants invobing the refining of a number cf the control (9) generic radiolog: cal impact for normal abose measures plus additional initiatives desersing lightwater reactor radionuclide re! cases, and (10) of staff etTort-thresheid limits for genene dispositien of cooling tower e:Tects. Cnteria developed by the Steenng (1) Impro.e the qualitv of applications byimproving Committee on Reactor Licensing Rule =aking to aid guidance and str engthening acceptance critena.

in identifying suitable candidate issues for rule =aiing C) Improve the quality cf applications by elimina -

include the following-the issue must be generic: there ing unnecessary :nformauon.

nust be a tikelihood of a useful deilruuve Me: and

0) Increase pre-tendenng coordination with appli-there must be a likehhood cf a suble rule. Value-cants.

impact enteria for appraising tne desirabdity and (a) Expand and restructure the Acceptance Resiew.

prienties of sWe proposals for genene rules in-(5) Modify the current rniew process by descioping dude:

an Early Safetv Evaluation Report based on the application as docketed.

• Achievement of more effecise puoiic input and (6) Ircrease public panicipation during start review.

improved pubiic understanding of NRC's analpi-(~) Improse the heanng process.

ca! procedures and decision nteria in treanng

($) Study oflong-range standardization policy.

potential environmental and safety issues in the (9) Modify LWA (Limited Work Authoruation) licensing process for nuc! car power plants.

rules.

• Improve =ent of the stability and predictability of (10) Increase use of rulemaking.

the licensing process, ine!uding the pronsion of (11) Eliminate mandatory ACRS review, orderly and clear procedures for State-Federal cocperation in treating genenc licensing issues.

StatT task forces and committees are being orga-

• Acco=plishment of an oserall savings of man-mzed within NRC to explore more fully the oppcrtu-power armi financial resources of the NRC. me nines for licensing improse=ent of most of the aeove public, the utility industry, and other !ocal State.

recommendations. Genene issues. or issues that are and Federal agencies insolved in the nuclear li-frequently raised in hearings and whose treatment has censing process.

becorne re!atisely routine, might suitably be dealt

• The short-term increase in dollar costs of the with through rulemaking. In response to a Commis.

various participants in the ru!c=aking action. in-sion directive, the start prepared an interim statement ciuding centractual support.

of general poliev and plans for rulemaking, which the

• The addinonal impacts (i.e., opportunity costs) of Commission approved for publication in the Ecdcral divening manpower and cther resources to the Register (December 14 19 8). This interim wiicy ruum=We process and away from other produc-statement fully supports Executive Order IFl4 of tisc uses for a temporary penod.

March 23.19'3. requesting improver;3mt of e.isting future government regulations so as to be as,imple As noted abost, one of the ten issues identified for and clear as possible and avoid imposing unnecessary possible generic rulemaking was that of alternative burdens on the economy, on individuals, on public site :nethodology and information requirements. In and private organizations, or on 5 sate and local order to clanfy this issue, the sta1 Tissued for coniment gose nments. The interim policy statement and sup-simultaneously a report on Decembe-la.1973 enti-porting discussions are presented in an NRC report, tied. Cerral Consideretions and Isn.es of Sg'ufi-Prelimmary &arement on Coeral Policyfor R:de.

cance on the Evaluanon of Alremarrve stes for

~

maicmg to improw Nuc! car Power P' ant Ucensmg Nuclear Gene armt sanons :.nder NEPA (NCREG-(NRC.1975et 0499. Supple =ent 1). In addition to rees-ing pubiic Ten candidate issues were identified by the staff for cornments on the report, the sta:T cenducted a three-genene ruiemaking-(I) future availability and price of day public workshop in March 19 9 to actisely seek uranium.(2) alternative energy sources to the nuclear comments and ideas on rulemaking for alternatise option. Q) need for adding baseload generating ca-sites. Representatives from industry. S:ste and ged-

_[

t95

'FEDERALST COOPERATION IN Nt:CL AR PO%ER PLANT LICENSING situations when economics are likely to be a sicnifi-eral gosernment. public interest groups and others cant factor in denying or delaying the issuance of a participated. Utilizing public comments and the re-construction permit. An analysa is prosided of the sults.of the workshop, the staff drafted proposed amendments to 10 CFR Part 51 which pertain to the impacts on planning schedules and the sensitiuty of evaluation of alternative sites. These amendments generation cost with changes in forecasts of electricity were submitted to the Comrmssion in July 1979 for demand and changes in issuances of construction permits. The report is based on a genene study of four their consideration.

scenarios for a large system that is representatise of a There are a number of useful in-house studies of genene signi5cance prepared by the NRC staff which very large utility or a regional reliability council and a would be appropriate references for case-related anal-small system large enough to accommodate a 1200 MWe nuclear unit either in a single utility system or in yses in the preparation of environmental impact a cooperative arrangement involving several smaller statements. As a desirable method of reducing paper work in EIS preparation. the new CEQ regulations utilities.

(sec. !$02.21) encourage the incorporation by refer.

A preliminary estimate resulting from the 77rce ence of materials relevant to impact analysis (CEQ.

.t/i/c Island Telephone Survey (supra) is that about 1978). Moreover, the greater in-depth treatment of 144.000 persons temporarily moved out of the zone analytical methodologies. citations of pertinent data within 15 miles of the plant site. travelling an aserage and discussions of the complexities and uncertainties distance of 100 miles to a total of 21 states. This, in of impact causal factors and potential mitigative itself, is an indicator of substantial psychological measures which are pursued in generic studies make stress. Staff studies are in progress w hich deal with the for sounder. more defensible environmental decisions.

interrelated topics of psychic (or anxiety) costs. risk One such generic study is the NRC staff report on perception and risk aversion related to alternattve

" Coal and Nuclear: A Comparison of the Cost of sources of energy for generating electricity (Spangler, Generating Baseload Electricity by Region'(Roberts 1979). Other staff studies of generic value as related to risk assessment include:

et al.,1978). The purpose of this study is to irnprove the basis for the staff's independent analysis of the (1) Demographic Statistics Pertaimng to.Vuclear comparative economic evaluations of alternative fuel Power Reactor SitescNUREG-0318. December choices as provided by an applicant for a nuclear

gg77, construction permit. The study compares the econom-(2) Aircraft Impact Risk Assessment Data Basefor ncs of a 2400 MWe nuclear and coal electric generat' Assessment of fixed Wing Air Carrier impact ing station in 10 different regions of the United States.

in the Ficinity of Airports. NUREG-0533. June Delisered coal costs are the primary cause of regional

g979, generating cost variations; therefore the regions were based on the Department of Energy's(DOE) regions IMPROVED LIAISON AND COORDINATION for delivered coal costs. The capital cost for coal-fired WITH OTHER FEDERAL AGENCIES WHOSE generating units includes the cost of sulfur removal.

ACTIVITIES RELATE TO NUCLEAR The economics are based on a station beginning LICENSING operation about 1990 for an investor-owned utility.

The study is based on data inputs from numerous In Figure 6 of Part I (see Vol 1. No. I of this journal) sources, and it avoids the pitfalls of cost analyses s shown a variety of activities of other Federal based on national averages by highlighting regional agencies which relate to nuclear power plant licensing.

differences which-in addition to the transportation The NRC has already achieved a good measure of costs of coal affecting the delivered cost of coal to liaison and cooperation with such agencies in the different regions.--include variations in coal charac-performance of the licensing function. Copies of tensucs, and construction costs for labor and maten-Draft Environmental Statements are routinelv sent als, as well as labor productivity.

for review to potentially affected Federal State and A companion report by the NRC staffis a generic local agencies. For example, the DES for the pro-study of the " Sensitivity of Generation Cost with posed Black Fox (nuclear) station was sent by the Changes in Electricity Growth Rates and issuance of NRC to the following governmental agencies for l

Construction Permits for Nuclear Power Plants" review (NRC,1977h)-

(Roberts et al,1980). The study was done from the licensing point of view. In addition to meeting the Advisory Council on Historic Preservation a

NEPA *need for the facility" requirements, the study Department of Actculture also provides a generic view of the impacts and costs Department of the Army. Corps of Engineers incurred when it is necessary to deny or delay a Department of Commerce construction pernut for reasons other than "need for Department of Health. Education and We! fare facility" The study identifies areas of the country and Department of Housing and Urban Development a

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156 MILLER B. 5PANGLER Department of the Interior wise, any concern oser historic impacts would require Department of Transportation consultation with the Advisory Council on Historic Energy Research and Development Administration Conservation which prosides an updating senice Environmental Protection Agency regarding a list of sites throughout the United States Federal Power Commission of historic and cultural salue (NPS.1977).

Federal Energy Administration Other consultations on technical data and related Office of the Governor of Oklahoma analyses are frequently made with cognizant F:deral Mayor of Inola agencies regarding geology and seismology, hydrol-ogy. meteorology, ecology and the like. Since water Because of the frequent interrelation of NRC supply problems are becoming more acute in various licensing reviews of certain environmental and safety regions or water basins of the United States. increased issues with areas of responsibility and expertise of the liaison with cognizant State, regional or Federal Environmental Protection Agency and the Army agencies or. these matters is assunung greater impor-Corps of Engineers, Memoranda of Understanding tance. The same is true for the developing State and have been -ntered into between NRC and these regional programs under the Coastal Zone Manage-agencies. A description of this relationship on a case ment Act which provides for various kinds of Federal basis is found in the FES for the Black Fox station assistance to these programs including problems (p. xiv):

arising from large-scale ene:gy developments in coas-tal areas (CZM A.197"').

Additional detailed information on cooperation In response to #cmoranda o/ Understanding ( N RC.1975h, 1976j) which govern certain interactions of the U.S. Nuclear with other Federal agencies in the review of environ-Regulatory Comnussion w th the U.S. Environmental Pro-mental and safety it.1 pacts involsed in the licensing of tection Agency and the U.S. Army Corps of Engmeers, the nuclear power plants may be found in Chapter 3 of statT has submitted to those agencies, and received com-the 1979 Annual Report for the U.S. Nuclear Regu-ments thereon. Statements of Posmons (EPA.1976 and latory Commission. The past five years has witnessed ACE.1976) which previewed intenm staff conclusions and a substantial growth in cooperation between Federal positions of environrnental matters of mutual interest. The State and local agencies in environmental impact staff has censidered these comments during the preparation analyses awociated with nuclear power facilities.

of this Environmental Statement. While exclusive junsdic.

There is good reason to suppose this trend will tion resides with the U.S. Environmental Protection Agency e ntinue: the alternative to increased cooperation is (EPA) to regulate nonradiological effluents (and it will do so via its NPDES permit when issued), the NRC is required wasteful dumlication. delay, and loss of effectiveness to assess the environmental impact of permitted discharges.

in serving t;e public interest of reconciling the coun-However. in order to ascertam the environmental conse, try's needs 'or increased domestic sources of energy quences of power plant licensing. NRC is placing increas.

with protecting or enhancing environmental values.

ing reliance on EPA's permit system. a result of the Nauon-al Polluuon Discharge Elimmatioa System (NPDES). A major step to avoid the confusion and inequity resulting RETERENCES from regulation of the aquatic environment by two Federal agencies was taken with the closely coordinated review of ACE.1976. Statement of Posinons for U.S. Army Corps of TVA's (:llow Creek Nuclear Stauon Construction Permit i

Engineers. Febrary 27.19*6.

ApplicatiorL As a consequence of the Yellow Creek Pro-AEC.197a. P ogrammauc Informanon for the L2 censing of Stan-creding, which suggested that this approach was not only dardued Nuclear Power P'ams. WASH-I3al. U.S. Atomic desirable but legally necessary, the NRC statT is stnving io Energv Commission. August 1974 obtain EPA or State agency resolution of questions pertam-Baker. E. J. et at 1977. Impact of CITshore Nuefcar Genersung I

ing to water quality that may anse dunng NRC's environ.

Stations on Recreation Behavior at Adjacent Coastal Sites.

mental review.

NUREG43 -4. prepared by the &nda Resources and Environ-mental Analysis Center of &nda State Uruversity for the Cfrice of Nuclear Regulatory Research. U.S Nuclear Regula-Other relationships with other Federal agencies are tory Com ussion. December 1977.

generally emblished on an ad hoc case-by-case basis.

CIQ.197. Nuional Environmental Policy Act implementauon l

For example, the licensing review of the generic of Procedural Provisions: Final Regulanons. Ecdcral Ammer.

• 3

• 2'* * **"2' '" #P'55 #

i statement for the Offshore Power System floating Ceary. D. P.1977. Treatment of Socioecononne Impacts in the i

nuclear plant concept and the proposed floatmg ututs Licensmg of Nue! car Power P' ants. a paper presemed to The l

(

off the Atlantic Generating Station offshore of New Associanon for Lmvemtv Business and Econonuc Research l

Jersey required very close liaison and frequent meet-First Annual Econonncs of Energy Workshop. Snowbird. UT.

l ings with the U.S. Coast Guard. The emergence of

• *D" 22 3'"

1. ' C#'"

"'"'"'8'"*"'^'*

^ ' '

l any cencerns oser endangere) spec:es habitats which PL W83. See espec:aily the Amendments of 1076. Secuens l

might be affected by a "soposed nuclear plant would 308(c) ani. JoN dW ai. anich proude smas to coastal States for i

require close Consultatkn with the cognizant office in energy facanes pianmns.

the U.S. Department of Interior (UhC.197h L:ke.

Denton. H. R.1Ma. Letter dated March 23.197* from Haroid R.

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e 197 FEDERAL 4 TATE COOPERATION IN NUCLEAR POWER PLANT LICENSING Denton of the U S. Nuclear Regulatory Comrnission to L.aw-N RC.19'ea. ProceeJings of the Second Sttte Federal Power P' ant rence 4. Goilomp of the New York Public Seruce Commission.

Sitmg Confe ence. NF-CONF 403. OfGce of State Programs.

U.S. Nuc! car Regulators Commisuon. Demer. CO. June Denton. H R.19'*b. %cicar Pewr P! ant Lcensing-Opporturu-nes for Improsement NUREG-0292. Study Group Report of 16-18 i9'e the U.S. Nuclear Regulatory Commission. June 1977 NRC 19?$a Final Environmental Statement Related to Selecuan EP A.19?6. Statement of Posatons for U.S. Environmemal Protec-of the Preferred Closed-Cyc!c Cooung System at Indian Potat Unit No. 2. Docket No. 50 *a7. NUREG 0042. U.S. Nuclear rson Agency. Februarv 27. 1976.

Regulatory Commission. August 1976.

Ernst M. L 1977. Implementauon of Eary Site Reviews and Oth-NRC 1976c. Draft EnvironmentalStatement Related to Construc-er NEPA Dec:sional issues. a paper presemed at the AIF Con-tion of Atlanne Generaung Stanon Umts I and 2. Docket Nos.

ference on Current issues on Environmental Reguiauon of Nu-STN 50 477 and STN 50-a't. NUREG 0058. U.S. Nuc. ear

tear Power Fac lines. Washington. DC. October 1977.

Regulatory Commasuon. Apnl 1976.

Feld. S. E.1976. Suppirmental Testimony of Sidney E. Feid on N RC 19764. Nucicar Energy Center Site Survey-1975. NUREG-Comenuens I-i9. I-20. and I-2ffaL (dL (e) in the Matter of 0001, vols. I V plus E.xecuuse Summary U.S. Nuclear Regu-Wolf Creek Generstmg Stauon. Umt No.1. Docket No. STN latory Commission. January 19. 1976.

50-a82. before the Atomic Safety and Licensing Board. U.S.

NRC 1976c. Final Genenc Environmental Statement on the Use of Nuclear Regulatory Comnusuon. January 6.1976.

F!ynn er 4L 1979 Letter dated Aprd 27. 1979 to members of the Recycle Ptutoniumin Mixed-Oxide Fuelin L;gnt W ater Cooled York Puelic Service Comnussion and Department of Reactors: Health. Safety and Enstronment. NUREG 0002.

New Environmental Cornersation and the Atonne Safety and Lcen-Vols.1-5 plus Execuuve Summary. Office of Nuclear Marenal sang Board of the U.S. Nuclear Regulatory Comnussion by Safety and Safeguards. U.S. Nue: car Regulatory Commisuon.

Michact F!vna(DPSL David A. EngellDEC and Stepnen H.

August 1976.

NRC 1976f. Safety Evaluation Report for the SWESSAR-Lewis ( N RO.

GESSAR Standard Nuckar Steam Supply System Design.

Jones and Jones. !975. Visuallmpact Study Statement of Findtngs NUREG4096. U.S. Neclear Regulatory Comrnission. August for Alternauve Cosed-Cycle Cochng Systems. Indian Pmnt 1976.

Nuclear Generaung Plant. an unpublished consulting study NRC 1976g. Calculatierts of Reicases of Radioactive Matenais in prepared $y Jones & Jones of Seattic. WA. ander subcontract Gaseous and Liquid Efnuents for Boihng water Reactors to Batteile Northwist for the U.S. Nuclear Regulatory Comrras-IBWR-TALE Codeh NUREG 0016. U.S. Nuc! ear Regulatory sion. November 19*S.

Commissaan. Apnl 1976.

Kemeny, J. G.19'9 Report of the President's Commission on the NRC 1976n. Standard Techmcal Spect6 canons for Babcock 4nd Accident at Three Mile Island. Jons G. Kemeny. Chastman.

Wacon Pressurued Water Reactors. NUREG.0l03. U.S. Nu-October 30.19*9.

clear Regulatory Commission. August 19*6 LDC 197$. Transportation of Radioactive Matenals in Loutsaana.

N RC 1976i. Regulatorv Guide 4.2 for the Preparauon of Environ-prepared under a memorandum of agreement wit $ the U.S.

mental Reports for Nucfear Power Stauons. NUREG4099 Atomic Energy Commission and the U.S. Department of Transportanon by the Divnion of Radiation Control Loui-U.S. Nuclear Regulatory Commsssion. July 19*6.

uana Department of Conservauon. June 1975.

NRC 1976j. Second Memorandum of Undentanding Regarding Implementauon of Certa n NRC Posinons and Responsibi.

NPS.1977..Nauonal Register of Histanc Ptaces. National Ptrk ues. U.S. Nuclear Regulatory Commission. Januarv 30. (9*6 Senice. U.S. Depanment of Intenor. federal Rettsre. Vol 42.

NRC.1977a. Improving Reguiatory Effectiseness m Federal State No. 21. Fesruarv !. (977. pp. 6398-6362.

NRC 1975a. Proceedings of the 1975 Federal-State Conference on Siang Actions. NUREG-0195. a preiiminary stati report of the Power Ptant Siung. NUREG-75iO68. OfGce of International Off:ce of State Programs. U.S. Nuclear Regulatorv Commm-sion. May 1977.

and State Prog-sms. U.S. Nuclear Regulatory Commusion.

NRC 1977b. Workshops for State Review of Site Sustabdity Wastimston. DC July 1975.

NRC 1975b. Standard Review Pian for the Review of Safety Cntens for High-Lesel Radioscuse Waste Repositor es Dis.

Analysis Reports for Nuclear Power P' ants: LWR Ediuon.

cusaon Group Reports. NUREG 0353. U.S. Nuclear Reguia-tory Commassion. October 1977 NUREG 75 087. Office of Nucicar Reactor Regulanon. U.S.

NRC 197"c. Standards and Procedures for Concurrence ;n State Nuclear Regulatorv Commisuon. December 1975 l

NRC 197$c. Regulatorv Guide 4.8: Environenecial Technacci and Local Government Radiciogical Emergency Response Plans. NUREG-75 Ili Office of State Programs. U.S. Nuc: ear Speci6 canons for Nuclear Power P! ants. U.S. % clear Reguia-Regulatory Comnussion. March 1977 tors Comnusuon. Decemeer 1975.

NRC 197'd. Agreement between the Virgima State Water Controi NRC 1975d. Standard Format and Content of Safety Analysis Board and the U.S. Nucicar Regulatory Comnussion pursuant Reports for Nuclear Power P'ents: LWR Edition. Regulatory to tae Fedemi Water Polluuon Control Act Amendmenu of Guide 1.*0 Revision 2L NUREG 75,094. U.S. Nuclear Regu.

1972 (FWPCA). October 26.197*.

tatory CJmmnsson. January 1975.

NRC 197*e. Interfaces for Stedard Designs. NUREG.0f02.

=

N RC 1975e. Regulatory Guide 4.7 General Site Sintability Cate-na for Nuclear Power Stauons (Revision I). Office of Stan-Office of Nuclear Reactor Regulauon. U.S. Nueest Regulatory t

dards Development. U.S. Nuclear Regulatory Commusion.

Commassson, May 1977.

NRC 197"f. Early Site Reviews for Nuc! car Power Facilices November 1975.

Procedures and Possible Tecamcal Review Opuons. NUREG-NRC 197!f. Regulatorv Gusde 8.3. Information Retennt to 0180. Office of Nuclear Reactor Regulation. U.S Nus: car Mamtamms Occupauonal Radsauon Eaposure as Low as is Reasonably achievabee-Nucicar Power Reactors (Revmon 11.

P.egu'atory Commission. May 1977.

' U.S. Nuclear Regulatorv Commusion. October 1975.

NRC 197*g. Regulatory Guide 153. Design Baus Floods for 1

l

[

NRC 19*$g. Regulatorv Guide 8.10. Operating Phdosophy for Nuclear Power Ptants (Revtsion :). U.S. Nuclear Regulatory Marntainmg Occupanonal Radiauon Eaposures as Low as is Commission. August 197*

Reasonaby uesaSe iRois.on !). U.S Mc! car Regu!ston NRC !9"h. Final Envronmemal State nent Reuted to Construc-i

.on of 3Mck Fos Statiert. Umts ! su 2. Docket w STN %

Commiss.on. Octoect 1973 NRC 1975h. Memorandum of Lndentandmg Set *een Corps of

!!6 and STN 50 557. NUREG41*e. Ofnce of Nucl car Reactor Engmeen. United States Army. and the Umred States Regula-Regulanon. U.S. Nuc! car Regu:atc-rv Commisuon. February Commisuon for Regulanon of Nuc: car Power Piants. U.S.

[9'*. p. ii.

NRC 19'33. Worbhops for State ReMew of Site Suitability tor Nuc! car Regulatory CJmmisuon. July 2. l975.

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2 194 MILLER B. SPA %CLER Cmeria for High-Lesel Radioacuse w aste Repouiones. Analy-Nucie.sr kegulators Commnuon. December 191 us and Recomrnendations. Vols I and 2. NU REG 4354. U.S.

Roberu. J O et al I"O Sensitnm os Generanon Cast oth Nuclear Regulatorv Commission. Feeruars 19's.

Changes in E!ectncits Growth Rates and louance or C *n.

NRC 197bb. P'an for Reesatuauon of NRC Pohey on Decommis-strucuan Permits for Nuc! car Power P! anis. NL REGm.14 %

uomns of Nuc! car Faciliues. NUREG4836. U.S. Nuclear J. O Rocerts. S. M. Daus. D A. Nash. and S. J. ) aungeiend.

Regulatory Comasuon. March 1978 U.S. Nuclear Regulators Commission. June 1980 NRC 19*3c. Conference Proceedings for Sute Workshops for Salomon. S. N.19*9 Beyond Defense m Depen. Cwt and Fund:ng Reuew of the Nuc! car Regulatory Comnussion's Decommis-of State and Local Government Radiological Emergency Re.

norung Pohey, NUREG. CP4003. U.S. Nuclear Regulatory sponse Pfans and Preparedness in Support of Comrnerc:al Comasuon December 1978.

Nuclear Power Suuons. NUREG4553. Office of State Pro.

N RC 19784. General Consaderauons and issues of Signaficance on grams. U S. Nuc! car Regulatory Commisuon. October 109 the Esaluauon of Alternauve Sites for Nuclear Gener.ung SCDHEC 1975. Transportauon of Radioactive Matmals in South Stauons Under NEPA. NUREG4s99. Supplement 1. U.S.

Carolina prepared under contract to the U.S. Atomac Energ>

Nuc! car Regulatorv Comnusuon December 1978.

Commise.on and the U.S. Department of Transportanon by the NRC 1978e. Prehmmary Statement on General Pohcy for Rule.

Divtuon of Radiological Heahh. South Carohna Department maasng to improve Nuclear Power Ptant Lacenung. NUREG-of Health and Environrnental Control Januarv 19?5.

0499. U.S. Nuclear Regulatory Comnussion. December 197g.

Spangler. M. B.1978. Methodology Guidelines arid Decision NRC 1979a. Radiological Ernergency Response Pianrung Hand-Cntena for Social Impact Assessment m the Lxenung of booit for Federal Assistance to State and Local Government.

Nuclear Power Ptants. Workshop on Formulaung Guidetines NUREG4093. Otrwe of State Progrsrns. U.S. Regulatory for Social impact Assessment. Ninth Annual Conserence of :he Commission. January 1979.

Environrnental Design Research Associauon. Tucscn. Anzona.

NRC 19*9b. Agreement Between the New York State Depart-Apnl 7-8.1978.

ments of Pubhc Service and Enuronmenui Conservauon and Spangler. M. B.19*9. Methodological concepts and :ssues msoiv-the U.S. Nuclear Regulatory Commission. Apnl 6.19*9.

ing psychic costs and 5enefits, risk percepuon. and nsk asernon NRC.19*9c. N RC Views and Analyus of the Recommendauons of in the use nanagement of alternauve energy sources. In Chace.

the P*esident's Commisuon on the Accident at Three Mile mg Encery f!se rurwes. R. A. Fazzoiare and C. S. Smnh. eds.

! stand. NUREG4632. U.S. Nuclear Regulatory Commisuon.

Vol :. Pergamon Press. NY pp. 643-657.

November 9.19*9.

USC 1973. Endangered Specze Act of 1973,16 USC. lSec also NRC 19*9d. Environmental Standard Revww Plans for the Title 50. Chapter IV. Part 402. Interagency Cooperanon.

Enwronmenul Reuew of Construction Permit Apphcauons for Endangered Species Act of 1973, rederal Regurer. Vol. 43. No.

Nuclear Power Ptants. NU REG.0555. Offia of Nuclear Renc.

2. January 4.19*8. pp. 870-876.)

tor Regulauon U.S. Nus! car Regulatory Commission. May WRC 1977. Water Supplies and the Nuc! car Lrensing Pmcess.

1979.

NUREG4:01, prepared by the U.S. Water Resources Council Roberts. J. O. et al 1978. Coal and Nuclear: A Compenson of the for the Office of State Programs. U.S. Nuclear Regulatory Cosi of Generstmg aascioad Electncity by Region. NUREG-Comrnasuon. July 1977 Ga80. by J. O Roberts. S. M. Davis. and D. %. Nash. U.S.

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