ML19345A762
| ML19345A762 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/17/1980 |
| From: | Fleischaker D FLEISCHAKER, D.S. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19345A759 | List: |
| References | |
| FRN-45FR65474, RULE-PR-50, RULE-PR-50-45FR65474, TASK-OS, TASK-RS-220-5 NUDOCS 8011250108 | |
| Download: ML19345A762 (4) | |
Text
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- oN3 son. car aan DAVID 5. FLEISCHAKER ATkORNEY AT tm,AW 1735 EYE STREET N.W.
WASHINGTON. D. C. 2 coos susTE 7os October 17, 1980 i
Dr. Harold Denton Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C.
20555
Dear Dr. Denton:
I am writing on behalf of the Joint Intervenors to the Diablo Canyon Nuclear Power Plant operating license proceeding to request that the Commission prepare a supplemental environmental impact statement which will consider the serious environmental consequences of a Class 9 accident at the Diablo Canyon nuclear facility'.
Although the C)mmission has refused to require that the Diablo Canyon impact statement consider. the potential effects of a Class 9 accident, the need for such a study is plainly manifested by the recent shift in Commission policy on the Class 9 issue and the August 14, 1980 Jecommendation of the President's Council on Environmental Qua.'ity ("CEQ") to Commission Chairman Ahearne that supplemental impact. statements " occur to the maximum extent possible while there is still time to correct earlier decisions based on the Commission's 'former erroneous position on Class 9 accidents' (45 Fed. Reg. 40103).'
(Letter of CEO Chairman Speth, August 14, 1980).
Joint Intervenors concur in that recommendaticn.
We believe it is critical that this supplemental study be completed prior to the issuance of any operating license, for either low or full power, in order to assure that radioactive contamination of the reactor will not preclude necessary modification of plant design or install-ation of additional safety features, substantially increase their cost, or foreclose the full and impartial consideration of disputed issues still to be decided by the Commission in connection with the pending license app]ication.-
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Dr. Harold Denton October 17, 1980 Page Two Consistent with the basic purpose of the National Environ-mental Policy Act ("NEPA"), 42 U.S.C. SS4341 et seq., to fully inform the public and the decisionmaking agencies of the potential I
consequences of federal proposals, CEQ has promulgated regulations specifically requiring an agency to prepare supplements to either draf t or final impact statements if "[t]here are significant new circumstances or information relevent to environmental concerns, bearing on the proposed action or its impacts."
40 C.F.R. 51502.9(c).
These regulations are entitled to sub-stantial deference in the application of NEPA.
Andrus v. Sierra Club, 442 U.S. 347 358, 99 S. Ct. 2335 (1979).
Last year CEQ initiated a study of the Commission's regula-tions and policy regarding the consideration of Class 9 accidents and their environmental consequences in its environmental impact statements.
In a March 20, 1980 letter to Commission Chairman Ahearne, CEQ Chairman Speth described the Council's "very Jf sturbing" findings that "[t]he discussion in these statements of potential accidents and their environmental consequences was...largely-perfunctory, remarkably standardized, and uninformative to the public, [containing] essentially-identical,-
boilerplate language written in an unvarying format."
The Council noted that Class 9 accidents, "which have the potential for greatest environmental harm and which have led to the greatest public concern," are not even considered, and it reccamended that the Commission adopt a new policy " based on the sensible approach of discussing the environmental and other consequences of the full range of accidents that might occur at nuclear reactors, including accidents classified as Class 9."
On August 14, 1980, the CEQ Chairman again wrote the Commission Chairman applauding.the Commission's announcement of Interim Policy on June 13, 1980 which adopted the position that impact statements "shall include coordination of the site-specific environmental impacts ettributable to accident sequences i
that-lead to releases of radiatien and/or radioactive materials, including sequences that can rescit in inadequate cooling of reactor fuel and to melting of the reactor core."
CEQ Chairman Speth indicated, however, the Council's strong disapproval of the Commission majority's statement that such new NEPA reviews."will lead to conclusions regarding the environmental risks of accidents similar to those that would be reached by a~ continuation of current practices...."
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Dr. Harold Denton October 17, 1980 Page Three 45 Fed. Reg. 40103.
This statement, Speth continued, "in-appropriately prejudges the NEPA analysis yet to be performed on a site-by-site basis by staff [and is] contrary to the purposes of the NEPA to provide information which serves as a guide to the decisionmaker..."
The foregoing CEQ recommendations and the June 3, 1980 repudiation by the Commission of its " prior erroneous position" on Class 9 accidents demonstrate beyond question that the Diablo Canyon environmental impact statement is deficient and, therefore, under 40 C.F.R. S1502.9(c) of CEQ's regulations, must be supplemented.
This conclusion is mandated by such significant new developments as the Class 9 accident at the Three Mile Island Nuclear Power Plant in March 1979 and the Commission's discovery that the accident probability estimates utilized in WASH-1400 on which it had previously based its Class 9 policy were not well founded.
At least as compelling, however, are the special circumstances surrounding the Diablo Canyon facility itself.
As appears in detail in the attached af fidavit of Richard. Hubbard,. construction. was already underway.
when the existence of the Hosgri fault off. shore and running.
within four miles of the plant was confirmed.
The exceptional nature of these circumstances was recognized by the Appeal Board in ALAB-519 (Jan. 23,1979):
We have here a nuclear plant designed and largely built on one set of seismic assump-tions, an intervening discovery that those assumptions underestimated the magnitude of potential earthquakes, a re-analysis of the plant to take the new estimates into account, and a post hoc conclusion that the plant is essentially satisfactory as is -- but on the-oretical bases partly untested and previously unused for these purposes.
We do not have to reach the merits of those findings to conclude that the circumstancen surrounding the need to make them are excectional in every sense of that werd.
(Id. at 12)
(emphasis added)
The Commission has a continuing obligation under the Atomic Energy Act and under NEPA to review information which may indicate a need to reconsider or modify a construction permit or'an operating license.
42 U.S.C.
S 2232(a) ; C.F.R.
S1502.9(c); Calvert Cliffs' coordinating Committee, Inc. v.
Atomic Energy Commiss"an, 449 F.2d 1109, 1112 (D.C. Cir. 1971),
4 Dr. Harold Denton October 17, 1980 Page Four cert. denied, 404 U.S. 942 (1972); Public Service Co. of New Hampshire v. Nuclear Regulatory Commission, 582 F.2d 77 (1st Cir. 1978), cert. denied, 439 U.S.
1046 (1979); Ft. Pierce Utilities Authority of the City of Ft. Pierce v. United States and the Nuclear Regulatory Commission, Nos. 77-1925, 77-2101, Slip op. at 19-20 (D.C. Cir. March 23, 1979).
Recognizing the Commission's responsibility and the significiance of the new circumstances and information discussed above, Joint Intervenors request that prior to the issuance of any operating license for the Diablo Canyon Nuclear Plant, the Commission prepare a supplemental impact statement to consider the environmental consequences of a Class 9 accident at the facility.
Very truly yours,
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David S. Fleischaker, Esq.
1735 Eye Street, N.W.
Suite 709 Washington, D.C.
20006 (202) 638-6070 Joel Reynolds, Esq.
John Phillips, Esq.
CENTER FOR LAW IN THE PUBLIC INTEREST 10203 Santa Monica Boulevard Fifth Floor Los Angeles, California 90067 (213) 879-5588 Attorneys For Joint Intervenors SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
SAN LUIS OBISPO MOTHERS FOR PEACE ECOLOGY ACTION CLUB SANDRA A. SILVER GORDON SILVER JOHN J.
FORSTER ELIZABETH APFELBERG
- 6.. a RECENED SEP 1 8 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter Of:
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)
PACIFIC CAS AND ELECTRIC COMPANY
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Docket Nos. 50-275 OL
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50-323 OL (Diablo Canyon Nuclear Power
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Plant, Units 1 and 2)
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AFFIDAVIT OF RICHARD BURTON HUBBARD CONCERNING THE NEED FOR CLASS NINE ACCIDENT ANALYSIS STATE OF CALIFORNIA
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ss.
COUNTY OF SANTA CLiRA )
RICHARD B. HUBBARD, being of legal age and duly sworn, deposes and says as follows:
I.
INTR 0aU u ION 1.
I am a Professional Quality Engineer, technical censultant, and a founder-in 1976 and vice-president of MH3 Technical Associates, technical consultants on energy and the environment, with offices at 1723 Hamilton Avenue, Suite K, San Jose, California.
I have participated as an expert wit-ness in licensing proceedingc before the U.S. Nuclear Regulatory
-_.1 -
Comnission (NRC) including the Diablo Canyon seismic hearings; have testified at the request of the NRC's Advisory Co* ctee on Reactor Safeguards; have appeared before various comnittees of the U.S. Congress; and have testified in various state 11-censing and regulatory proceedings.
I am thoroughly familiar with the safety analyses of the Diablo Canyon license Appli-cant (Pacific Gas and Electric Company) and the Nuclear Steam Supply System supplier (Westinghouse) as a result of my service as a consultant since the fall of 1976 to the Center for Law in 'the Public Interest, attorneys for the Joint Intervenors in the Diablo Canyon Operating License proceeding.
I received a 3.5. in electrical engineering from the University of Arizona in 1960 and an MBA from the University of Santa Clara in.1969.
From 1964 to February 1976 -I was employed in the Nuclear Power Division of the General Electric Company, with the final eleven of the twelve years working in increasingly responsible man-agement positions.
2.
Samples of my recently ecmpleted projects directly related to various aspects of nuclear plant risk assessment are as follows:
a.
Criticue of WASH-1400:
The Union of Concerned Scientists (UCS) pre-pared a critique of the U.S. Reactor Safety Study (WASH-1400). 1/
The UCS Critique 2_/ was released in November,1977, and was the culmination of over a year's effort by about a dozen technical people.
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for the D2..sblo Canyon nuclear station.
The purpose of this affidavit is to identify present state-of-the-art safety features which have not been evaluated for Diablo Canyon and which have the potential for significant risk reduc-tion.
These additional safety features, both preventive and mitigative, include such features as filtered vented containment, molten core retention, hydrogen co'ntrol sys-tems, and groundwater interdiction.
In addition, as des-cribed in this affidavit, the Applicant has not conducted a plant-specific system reliability analysis using event-tree and fault-tree logic techniques, the methodology utilized in WASH-1400 for a generic plant risk assessment, to identify design weaknesses.and possible system'modifica.; ;
i tions that should be implemented at the Diablo Canyon sea-ts.on to improve the capability and reliability of reactor systems under various transient and LOCA events, including seismically induced accidents.
Further, this affidavit 1-dentifies the need to conduct the Class Nine and reliabili-ty analyses prior to the granting of an Operating License, either low power or full power, in order to assure that radioactive contamination of the reac:or will not preclude the installation of additional safety features or increase substantially their economic and health costs.
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basis of occupational radiation exposure for the two-unit j
station, was esti=ated to be 450 man-re=s per year per unic.7/
Finally, background information describing Class Nine Acci-dent analyses and past NRC practices, is sumarized in the
" Description of Problem" portion of NRC Task Action Plan A-33.8/
q 6.
A recent and thorough critical review of 'JASH-1400 was conducted for the NRC by the Risk Assessment Review Group (RARG).1I In light of the criticisms and limitations of '4 ASH-1400 revealed by the RARG, the NRC Cor:missioners concluded, in part, that ".... the Commission does not regard as reliable the l
Reactor Safety Study's numerical esti= ate of the overall risk i
of reactor accidents."
(Page 3 of NRC Statement on Risk As-sessment. andu the. Reactor ' Safety S tudy Report-in: Light of f ther Risk Assessment Review Group Report.)
Thus, the NRC Staff has little or no theoretical basis to exclude the considera-i cion of Class Nine accidents for Diablo Canyon.
In addition, the NRC Staff has concluded that the accident at TMI-2 was a Class Nine accident, even though the release of radioactive material to the off-side population was very small.10/
7.
The Council on Environmental Quality (Council or CEQ) is directed by NEPA ".... to review and appraise the various programs and activities of the federal government....for the purpose of determining the extent to which such programs and
postulated accidents.
A limited range of accidents with varying consequences are discussed.
Esti-mates of materials released from such accidents or ' release fractions,' are provided.
- However, based on the conclusion that it is highly impro-able that serious accidents will occur, the policy prohibits the discussion of cerrain severe accidents, the Class 9 events."
8.
The Council recommended a new NRC policy on Class Nine events as follows:
"We believe that the new policy should be based on the sensible approach of discussing the environ-mental and other consequences of the full range of accidents that might occur at nuclear reactors, in-cluding accidents now classified as Class 9.
This should include core melt events.
In addition, EIS 's should present the best estimates of the likelihood of such events.
In order to comply with the disclo-sure requirements of NEPA, the NRC should include in the analyses the likely range of environmental and other consequences from severe and other accidents.
In describing-reactor: accidents:and their'possible.~
effects in impact statements,'. the NRC 'should follow. -
closely the relevant provisions of the Council's NEPA regulations, including the provision on ' worst case' analysis.
We also urge the Commission to broaden its range of variables (e.g., radiation pathways) in determining accident impacts, and expand its discussions in EIS's of the impacts of nuclear accidents on human health, the natural environment and local economies.
Site specific treatment of data should be substituted for
'boilerplate' assessment of accident initiating events and potential impacts, and EIS's should be comprehensible to non-technical members of the public."
t 9.
Subsequently, the NRC Commissioners, in a June 13, 1980, policy statement adoped a statement of interim policy which withdrew the proposed Annex to J.ppendix D and temporarily l l l
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theoretical or practical basis to continue to justify exclud-ing the safety and environmental assessment of Class Nine accidents for Diablo Canyon.
IV.
DISCUSSION OF ISSUF.S 11.
The special circumstances required to justify a Class Nine environmental and safecy analysis and a system re-liability aralysis are present at Diablo Canyon.
Construc-tion of both units was underway when the existence of the Hosgri fault offshore and running within four miles of Diablo Canyon was confirmed.
Further, the ability of nuclear power plants to withstand earthquake damage is undeniably crucial in California, where seismic phencmena are not unknown.12/
As concluded by : the ~ Appeal ; Board in : ALG-519 :
'%.have here : - -
a nuclear plant designed and largely built on one set of seis-mic assumptions, an intervening discovery that those assump-tions underestimated the magnitude of potential earthquakes, a re-analysis of the plant to take the new estimates into ac-count, and a post hoc conclusion that the plant is essentially satisfactory as is -- but on theoretical bases partly untested and previously unused for these on= poses.
We do not have to reach the merits of those findings to conclude that the cir-cumstances surrounding the need to make them are exceotional in every sense of that word." (emphasis added)El
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features in order to establish design criteria and bases, as well as perfor=ance or reliability requirements.15/
14 In addition, in response to the studies of the TMI-2 accident, the NRC is planning to initiate a long-ter=
rulemaking on consideration of degraded or melted cores.
The schedule for the rulemaking and the application to Diablo Canyon are yee to be determined.
The rulemaking vill include consideration of (a) the use of filtered-vented contai= ment systems to mitigate the consequences of core-degraded and core-melt accidents, (b) hydrogen control measures to deal with ac-cident conditions involving large amounts of hydrogen genera-tion, (c) core-retention devices, (d) reexamination of design criteria for-decay heat removal, radwaste :and other related sys -
tems, such as the ukaup and purification systems, so that they can perform their functions under degraded-core conditions, (e) plans and other preparation for postaccident recovery, (f) cri-teria for locating highly radioactive sys tems (e.g., should they be in isolated buildings), and (g) effects of an accident in a reactor plant on an adjacent plant in a multiple reactor site.
In addition a number of other TMI-related studies will be coordinated, and, as appropriate, factored into this long-term rulemaking activity.
These other studies are (a) avalua-tion of radwaste system design features to aid in accident re-covery and decontamination, (b) provision of a ventilation
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i che reactor core to prevent, monitor, or control a degraded core.
Likewise, radioactive contamination will increase the worker occupational exposures resulting from modifications to the reactor system.
The additional security measures institut-ed ones fuel is loaded will also increase the time and costs of any post fuel-load construction (time delay is also very ex-pensive).
Thus, modifications or additions of safety feat'.2.res installed af ter the granting of an Operating License may be pre-cluded or will result in an increase in the economic costs and health risks associated with the implementation.
17.
The need for plant-specific assessment of accident probabilities, including Cisss Nine events, at all U.S. reactors has been recognized folle.41ng the' M -2'accidenttbyca numbernof -
groups, including the NRC's Advisory Committee on Reactor Safe-guards (ACRS). b In response, the Integrated Reliability Evaluation Program (IREP) has now been instituted by the Prob-abilistic Analysis Staff of the NRC.
IRE? has as its charter the evaluation of the probabilities of accident sequences leading to core meltdown and (to a limited extent) the as-sessment of the consequences associated with the specific sequences for each U.S. operating reactor.
Techniques developed I
in WASH-1400 (i.e., event-tree and fault-tree techniques, ac-cident radioactive release categorier Met 0, are being used on the individual plants in conjuneri,ir. L '.th data compiled-in
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In summery, the accident at TMI-2 demonstrated the reality of the risk, previously only theoretically as-sessed, of accidents that result in substantial degradation and melting of the core.
V.
CONCLUSIONS 20.
Based on the foregoing discussion and background information, I conclude that a Class Nine accident analysis and system reliability analysis of the Diablo Canyon plant.
should be performed by the Applicant and reviewed by the NRC.
The Class Nine and reliability analyses should be performed prior to the granting of any Operating License for Diablo Canyon, either low power or full power, because radioactive a
contamination of the reactor;will' either foreclose 'orLin- ~:
crease the economic c asts and health risks associated with su'ch er.gineering safety features as filtered vented contain-ment, molten core retention, hydrogen control systems, and J
grout.dwater interdiction that have the potential for pre-venting or mitigating accidents.
21.
All of the matters herein are known to me of my personal knowledge or of my personal opinion based on my education and ergrience.
If called as a witness, I am com-petent and would testify thereto.
. 'r$2 RICHARD 3. HU33ARD Subscribed and sworn to before f 'h' *=ve -sw3%
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me this pr w day of September,1980
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NOT.ARY PUBLIC a~ en-m_x__y_,
My comunission eroires: /bsm // /ffV
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Leeter, Gus Spach, CEQ Chairman, to John Ahearne, NRC Chairman, Augus t 14, 1980, NRC Public Document Room,
- 4ashington, D.C., co=nents on proposed rule PR 50.51.
M/
ALA3-519, January 23, 1979, page 8.
_13 /
Ibid 12.
14/
NUREG-0660, NRC Action Plan Develcued as a Result of the TMI-2 Accident, Vol. 1, U.S. Nuclear Regulatory Co= mission, Wasnington, D.C., May, 1980, Page II-1.
15_/
Ibid 14, page II.3-8 M/
Ibid 14, pages II.3-ll anc II.B-12.
17/
Letter, Plesset, Milton S., ACRS Chai man, to Ahearne, John F., NRC Chairman, entitled "ACRS Report on Near Term Op-erating License Items from Draf t 3 of NUREG-0660," dated March 11, 1980, NRC News Release 80-56.
LIST OF ATTACHMENTS Attachmen:
D e s c r i c c i o n '.
A Latter, Speth to Ahearne, March 20, 1980.
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. March 20, 1950 The Honorat!
Johe,Ahearne b
Chair =an Nuclear Recul atory Cc=ris sion D
Vashington.
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20555 Dea'r Chair =an Ahearne:
Section 204(3) of the National Envirou= ental Policy Act (NE?A) directs the Council on Environ =tntal Quality "to reviev and appraise the various progra=s and activities of the Tederal Govern =ent... for the purpcse of deter =inint the extent to which such progrs=s and activities are contributing to the achieve =ent of the policy (of NEPA]...." Last year, as part of the.Ccuncil's overall effort to meet,this responsibility, the Council initiated a study of the Nuclear Regulatory Cc==ission's regulations and policy on the environmental analysis of pessible nuclear accidents under NEPA.
This letter contains the conclusions of our study.
We uere assisted in this reviev by the Environmental Law Institute, which has prepared for us a report entitled "NRC's Environ = ental Analysis of Nuclear Accidents: Is It Adequate?", which I a= providing to the Co= ission with this letter.
The Council believes the report constitutes an accurate and i=portant assessment of the NRC',s regulations and gelicy.on the-analysis ~ of nuclear accicants in e.nvirennental i= pact stacaments.
The results of'our review of i= pact staterents prepared by the NRC for nuclear pow'er reactors are very disturbing.
The discussion in these statements of potential accidents and their environmental impacts was found to be largely perfunctory, remarkably standardized, and uninformative to the public.
Despite the broad diversity of size, design, and location of the nuclear reactors licensed by the Com=ission over the years, virtually every EIS contains essentially identical, "boilerplate" language written in an unvarying format.
The typical EIS does not consider or analyze the pessibility of a major accident even though it is these " Class 9" accidents which have the potential for Freatest environ = ental ha r= and which have led to the great est pub 11e concern.
.Moreover, for those accidents which are typically discussed in an EIS, the potential impacts on human health and the environment are presented in a cursory 'and inadequate manner with little attention to public understanding; Each Els relies on the NRC accident analysis policy, which has remained essentially unchanEed and in interim form since 1971, asserting that " correct canufacture, design, operation and quality assurance" vill provide "a high degree of protection" aEainst the occurrence of pesculated accidents.
A limited range of accidents with varying consequences are discussed.
Esti=ates of =aterials released fro: such accidents, or " release fractions," are pros;oed.
However, based on the conclusion that it is highly improbable that serious accidents will occur, the policy prohibits the discussion of certain severe accidents, the Class 9 events.
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..ae ace:c.e : analysis in de Ils f:: e, nfe, 3g..e Island Nuclear 5:a:1ct,
,,- i:s 1 a:d 2 (I'.I), ese=plifies de def hie:: des of such a........
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.,e 22:te of pessibili:Les sugges:sd by de acciden:.
Typica Zy, public c::=ents, includhg th:se cf oder federal age =ef es, c: de ita:equaeies of aceide : a:alysas b :af: IISs re:eiva N?.C res:::sas which si ply rei: era:e :he' 1971 "isteri=" acciden: policy.
yor esa: pie, ce yac resp: se :o a Capart=en: of ::arier c:==en: c= :he ad.. g13 vas as fellevs:
. : e :..:: !apar res: suggests d a: a specific s:udy of de
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- seruan:es =f a Class 9 accides: a: t =. we a Island, Cri:
No. 2 up:: :he Susqueha::a River shculd be =ade.
ne [Np,C]
s:aff disagrees vi d dis view. A ge:eral discussion of Class 9 accidents has bes= given 1: the Reac:or Safety Study.
ne staff believes, is v'av of de re=:ce pessibili:7 of occur-re :e of a Class 9 e sen:, :ha: de 4:vir::=en:21 risk of such an eves: is ac:aptably Icv, and da: ge:eric dis::ssim of dese eve: s are adequa:e."
ne pas: fai ure :o disenss the :: sequences 'of de. full a=ge. of poten:121-acci:en:s a=d ded: <!!ec:s uh? d-L=es da hasic-purp:ses cf de Sa:i::aL yv ::::en:aa pelicr Me': := inf::= :he public and c:har age:cies ful.y of
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'al c:: sequences of f ederal p:c.::sais and :s pr vida a basis f::
- .nfor:ad decisicas. Over de years :he public and federal age:cies have -
repda:edly reques:ed :he AIC and NRC to c:: sider :he severe c:nsecuences of
=uclear accidas:s in :he con ext of :he Cc=ission's envi:===e::21' licensi:g reviews.
nese recuests for full disclesure have been c::sistently rejected
.during this period, dis C:~issis:'s Sepre=har 14, 1979, decisi:n 1: Offshere
_::ver*sys
==s bef=g a cc:spicuous and a:couragi:g excep:io=.
cives :3e in:: casing public cc :ern regardi:g :ueles: safety a:d :he :eed :o i=m;cve pusi': con:'desce is =uclear regula: ion, we believe the rise is ripe ' or de f
,'c=:is sion to depar: sharply h:= the i=heri ed policy is favor of a =ev
.:pr:a:
s:ressi:g full and ca did discussics of acciden risks.
Se Ceu cil's assess =e:: of de C:==ission's s:2 u:o;7 obliga:!ons :o discuss fully ::e envir==escal effec:s of =uclear accides:s, including Class 9 accidas:s, is sat for:h is de a::ach=e:: :o :his ler:er.
3ased on our reviev' Je co :o: believe tha: :he Cc=issica's prio: legal jus:ificatien for severalv li=1:ing de discussion of :uclear accidents and deir ecusecue:ces in I:5s i$
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e a:7 ac:ger sus:ainable, assu=i=g 1: ever vas.
yce bed legal and policy reascus, se believe da: de C
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ve qu:cx17 :o revise 1:s policy on ac:iden a:alysis in I*,ss.
A c ::le:ely ney solicy, pref erably involving a reject'en of de ents:e -
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sys t e:=,.sh uld he adepted.
yor :hese :e.tscas, ve c::=a. d de C: =irsica for de 1:pc::as: steps 1: has reces:17 :a'ses :eJard revising i:s ;clicy is :his
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I would be pleased to discuss the Ceuncil's vfevs vi:5 yeu a: any. time.
Please let me know hev ve can be of assistance to you in =oving. forward in this i=;creant area.
Sincerely, l T i
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