ML20009H179

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Requests That Util Consider Class 9 Accident Analyses in Eia Required by Nepa,Per NRC 800613 Statement of Interim Policy. Accident Analyses Should Be Presented in Environ Rept When Applications for OL Are Tendered.Fr Notice Encl
ML20009H179
Person / Time
Site: Marble Hill
Issue date: 08/03/1981
From: Tedesco R
Office of Nuclear Reactor Regulation
To: Shields S
PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA
References
NUDOCS 8108060381
Download: ML20009H179 (6)


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ESTEl50-546'/

Docket Hos.:

RVollmer and STN 50-547 /

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TMurley RMattson W'N P RHartfield, MPA i

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hr. S. W. Shields OELD Senior Vice President OIE (3) gY h6 y /tUU g 3 IS81am D, 2

Public Service company of Inciana Post 0f fice Box 190 L

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New Washington, Indiana 47162 d '.

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Dear hr. Shields:

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Subject:

Class 9 Accident Analyses in the fiarble Hill, Uni

  • 4 &2 Environmental Report The Connission's Statement of Interin Policy dated June 13,1980, (45 FR 40101),

states that, "Environnental Reports submitted by appiicants for construction pernits and operating licenses on or af ter July 1,1980, should include a discussion of the er.vironmental rists associated witn accidents that follow the guidance herein." Therefore, in accordance with tnis policy statement, we request that you consider the rnore severe kinds of very low probability accidents that are physically possible in environmental impact assessments required by the National Environnental Policy Act. Such accidents are connoaly referred to as Class 9 accidents. A copy of tnis statement is enclosed.

4 I

Your analyses of these accidents should be presented in tne Environmental Report regarding liarble Hill at the time you tender your application for an operating license.

Sincerely, Odstmal stnoed by Rolnet L. Totmas

[

Robert L. Tedesco, Assistant Director for Licensing Division of Licensing

Enclosure:

Statenent of Interim Policy (45 FR 40101) cc w/ encl.:

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1Mr. S. W. Shields Senior Vice President-Nuclear Division Public Service Company of Indiana P. O. Box 190 New Washington, Indiana ' 47162 cc:- Charles W. Campbell, 'Esq.

U. S. Nuclear Regulatory Commission.

Vice President and General Counsel Resident Inspectors Office Public Service of Indiana 3738 Marble Hill Road 1000.E. Main Street habb, Indiana 47147 Plainfield, Indiana 46168 Mr. E. P. Martin Mr. William Kortier General Manager Water Reactor Divisions Wabash Valley Power Association l

Westinghouse Electric Corporation P. O. Box 24700 P. O. Box 355 Indianapolis, Indiana 46224 i

Pittsburgh, Pennsylvania 15230 Mr. P. L. Wattelet Sargent & Lundy Engireers 55 East Monroe Street Chicago, Illinois 60603 Harry H. Voigt, Esq.

LeBoeuf, Lamb, Leiby & MacRac 1333 New Hampshire Avenue, N. W.

l

. Washington, D. C.

20036 Thomas.M.

Dattilo, Esq.

311 East Mcin Street Madison, Indiana 47250 l

l Joseph B. Helm, Esq.

' Brown, Todd & Heyburn l

Sixteenth Floor Citizens Plaza Louisville Kentucky 40202 o

David K. Martin, Esq.

Assistant Attorney General l

Room 34, State Capitol Frankfort, Kentucky 40601 Mrs. David G. Frey Sassafras Audubon Society-

- 2625 S. Smith Road Bloomington, Indiana 47401 n.

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i lead te relm.". cf radeor..dior Teo;eth e rnate-:als. inci6na muen&s that can cesult in modt.quate ca :ijnp of it.riClor fue) 8*1d 10 F e!?'r!F of the :enctor core. In this regard. attentmn shall be F sen both to the probabihty of i

ocurrence of such releases and to the cnvironrnental cc,nsequerues of such re!9ses Tnis statenent of interim pe: ev is tden ir. coordmation wnh otteiongoing safety-related activit'ies that a c directly vehted to accident considerations in the areas of plant design. eperational safety. siting policy, and emrpacy planning. The Com :Msion inttnds to continut the ru!cmdiag on this rnatter when new silmg requirernents and other safety related requirements inco:porating accident considerations are in place.

dates:This statement ~f interim pohcy is effective June 13. P - Cornment period expires Septenu :11.1940.

10 CFR Parts 50 and 51 addresses:The Commitsion intends the interim policy guidance contained Nuclear Power Plant Accident herein to be iramed.ately effective.

f Considerations Under the National Howeser, all mterested persons w ho En<ironmental Po' icy Act of 19G9 desire to submit writtrn cornments or AGE NCY: U.S Nuclear Regulatory suggestions for consideration in Commission connection with this staternent shculd send them (3 the Secretary of the AcTros: Statement of Interin. Policy.

Commission. U.S. Nuclear Regulatory SUM 9 A9Y:The NucIcar Regulatory Commission. Wa shington. D C 20555, Commission (NRC) is revising its policy Attention: DxLcting an( Senice for considering the more severe kinds of Branch.

very low probability accidents that are ron ruaTsca swreauATsus cowT acT!

physica!!y possible in environmcntal p g.avr:e llouston. Chief. Accident impact.issessments required by the 7 33;atmn Branth Office of Nuclear National Environmentai) obcv Act Leat r at.mn. M M. ear (NEPA). Such accidents are commonly Regulat ry Co:maission. %,ashington.

referred to as Clau 4 acri6nts~

', foMowing an aTMeY classification D.C. 205%. Telephone: (301) -192-7323.

scheme proposed by the Atomic Eneigy SUPPLE ME N T ARY IM ORM A TION:

Commission (predece=sor to NRC; sn Accident Con <.iderations in Past NEPA 1971 for purposes of implementing g, y.ews NFPA.'The March 23,2979 accident at Unit 2 of the Three Mile Island nuclear The proposed Annex to Appendix D plant has emphasized the need for of 10 CFR Part 50 [bereaf ter the changes in NRC policrs re2arding the

" Annex") was published fer comment considerations to be given to serious on December 1.1971 by the (former) accidents from an environmental as well Atomic La rg; Commission. Il proposeo as a safety point of view.

to specif, e se' of standa.dized accident This statement of interim policy assumptions to be used in announces the withdrawal of the Environcnental Reports sahmitP:d by proposed Annes in Append.x D of10 applicant, for constr9ctian permits cr CFR Part 50 and the suspension of the operating licenses for nuclear power rulemaking proceeding that began with re-tors. it al;o included a system for the pubhcation of tha' proposed Ar.nex classifying accidents according to a i

on December 1,1971. h is th2 paded scale of severity d probabihty Commission's position that.ts o.',ccurrence. Nine cla,.ses of accidents ErwironmmtalImpact Statements shall were defmed. eangirig fzom trivist to include considerations of the site-verv 8erious. It directeo tLi "for each specific environmental irnpacts cla$s mcept classes 1 and S. the attributable to eccident sequences that environmental cor.scyuences shall be ev fuated es indicated." Ciao 1 events

'Proarsed as en Annen to 10 CFR Part 50.

wc!c Dot t 7 he considered because of Appene D. 3t, F11228s1. The Co*nssion's NFPA-gj g g 9

.k 9 s b impt err:hra rep!*t.ons

  • ere s Awuently [ July r, tard to Class 9 cvents. the An7ex f e. W4) rev. ed v.d. cost n 10 CFR Pet si ba at that time t) e %mmion ernd that Te Pm;.oned stated as fo!!Ows:

i A.nm n siitt s.mW res:durat.w *

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Tne retLnea u L Gm 9 invch.c within a Tcm;le radius of the p! ant and 1.nJy on which the plant !io ats Ijere the f

ataff unph:,shd i g fom on rw 19 tne i

mp.ences of ps%is wccmis e (Ares Sr.e ddfennce' between bmbn; eter ernimmrn! but cic not I.nd that :he Aae.eure tun iWw pwented tw the rectors IDWR) und pressurued water

-aimn bas:s im pintective symms and reactors (PWR). Beyond these few ProbzNhty of a core meh event omring in the fy p% was enpneersd safety femmies. near spec fics the discuhions have nsenuaHy any Snent tnen for land, co.nequena s wJd be overc. How ever. t,.e a terated the guidance of the An.s based lant. In its Memorandum and nes probabihty of their occurrent c is so small and yrr.,c relied upon the Annex Order a,n the Abtrer oyg7fgwe pow.er that their ensiron i. ental rd.s utttmely conchision that the prol.abihty of SyAtemr? the Commission canct.rred m Iow Defense in depth (mhtte phpical oc'currence of a Class 9 cunt is 100 low the staffs hgrnent hs. M by bomen). quahty assurance for dusgn.

to warrr.nt consideration. a cenc!usion Safety Study and NRC ex;mience witn.

sunntactwe. and og eration continued seve&nte and tettag and conurvative based upon gent. rally stated safety

&c. e cases hn served to relocus

..cies:gn are At ap;hed to provide and tonsiderations.

aHection on the need to mmph. ash snaintam the required h!gh degree of With the publication of the Reactor that envimwentaltid entaus boe,

snurance that !.ntential accidents in this Safety Study (WASili1400). ia draft probshili:ses and casequences a pomt class are, and will renain. suff.crently remote form in Auyust 19N and final fm in that was made in the pubhcrition of the in probabihty that the environrn: ntil rM is Octnber 1975* the accident discvsions Annet,gsut ss.as not gh.en adequale estremely low. For these reauns it ss ret in Environmentalirr: pact Sittements necessary to dncuns surh events in began to refer to this first de: ailed study Pyh8 1977 the NRC commissioned a 5

appennts' r.nnmnmenid Reports.

of the risks associated wn, h nuclear Risk Assestment Eev.iew Group "to, "*

}

A iootnote to t!se Annex stated:

power plant ntc! dents, particularly At:hnuyh th;s annex refers to apphcant's events which can lead to the ine! ting of d"8 b "

of the Reactor Safety Study. One of the rnviror. mental Ret. orts. she current the fuelinside a reactor.2 The reference.s c ncbsions of tnis study. published m soumptions and c.ther pic,vmons thereof are to this study were in keeping with the September 1976, as NU, REG /CR 4400.

app! cabte, neept as the content rr.my intent and spirit of NEPA "to disclose.

Risk Assessrnent Review Croup Report otherwise etwne.to AEC draft and fmal re)evant information, but it.is obvious to the U..S. Nuclear Regulatory j

i Detailed Statements, that WASil-1400 did not form the bas.

l omnussion,.. was that.The Review

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Durang the public comment peried that for the conclusion expressed in the m up was unable to deterrnine whether l

followed pub,lication of the Annex a Annex in 1972 that the probabHity of the aMolute probabilities of accsdent nurnber of cr ticisms of the Annex were occurrence of Class 9 events was too 5 " """'*

  • I" l

receivn' Principal among these werc low in warrant their (site-s;>ecific) low. but believes that the error 1:o"' ids i

the fd aing:

consideration under NEPA.

n 6 se ntcates arein general.

(1)'I 7 philosophy of prescribg.ng The Commission's staff has. however.

yreatly understated. This and other assump%ns does not lead to objeco. ce identified in certain cases unique I*U

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F circumstances which it felt warranted subwntly been rcierred to m

""q*I 828+)it failed to treat the probabihties of rnore extensive and detailed with a refer ente to !! e Comm?

I*P"d lp acc. dents in any but the most general consideration of Class 9 es ents. One of

mon's wav.

t) tyq p p sed Ch.nen River poliev statement on the Reactor Safety.

i (5) No supporting analysis w's E ven fheder Reactor Plant (CRi3RP), a lyu.d Stud 0 in light of the Risk Assessment r

to show that Class 9 ai:cidents are metal cooled fast breeder reactor very Review Group Report published on su'ficiently low m probabihty tl e their different from the more conventional January 18.1979. The Commission's consequenree in terms of environn.cntal

@ water mctm p ants f r which the statement accepted the fmd:n3 s of the risks need not be discussed.

'" 'If T.xperience base is much b oader.

p,. clew Group, both as to the Beactor (4) No guhlarice was given as to how In the I mal En conm ntal Statement Safety Study's achievemeats und as to accident and normaircleases of radioactive efflucnts (urks plant for Me WRI t staff mcludjd a ini M aH h de e.ussion of he cor. sideration d had A few Draft Environmental s

operation should be factored into the givt n t Class 9 csents-Statemena have been published cast 4ent fit analysis.

la the early site reew for Se subwquent to the Three Mi!c Island p)The accident anumptions re not Perryman site. the staff performed an accident. These were for c onventional pentrally app!scahte to gas cooled or Inf unal assemnent f thy reMive

'and based light water reactor,dants heuid n[etal cooled reactors.

differences in Clan 9 act. dent and continued to r flect the oast lG)Saf-ty and environmental risks are consequences am ng the ahernah.

practice with respec: in accidents at ve not essentiallv different considerations.

sks. (SECW78-137) such plants, but noted that the Ndtber theitomic Diergy I"'"e case of the application by exper ence gained from tha Tnste Afile Cornmission nor the NRC took any O!!sh re Power Systems to manufactu:e Island acciden. was not factored into fudher attion on this ru! croaking excer, hatmg nuclear power plan:s. the staff the diset. sien.

in 1974 whe s to CFR Part M was jedged ihat tha environmental risks of Our en crienc with,ast NU%

prutnuyated. Owr the intervening yea,6 s me C1 ss 9 events warranted special review of accidents at d the TEt the accident considerations discussed in considerabon.The special accident deuriy leads us to believe that EnvironmentaSpact Stuements for circumstances were the potenbdiv a change is needed.

proposed nucice power plants rer'ected se 'ous ynsequences assaciated w,th Accordindy, the prnpon d Annex to i

thquidant - of;he Annex with few water (hqm,d) pathways.eading to Appendix D of 10 CFR part 50, published cueptions..ypcally, the discussions of radiological emosures if a molten on December t n 71. is hereby accident con equences through Class a reador core were t. fal!into the water w;thdrawn and shall not hereaf ter bc i

(design basis a:cidents) for each cart M "'*

  • reasons for t'.e withdrawal are as used by apphcants erhy the staff. ihe

$nve reflecteri specific site char.gteristil5.ansociated with roer rWes to ru,'r ma the ierm$

'9 etndent

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Ch g U" meteorofcpy (tne dispersion of re! eases shgh %s term is comrr t,nh ed.. leely of radioactive raatcrialinto the eWen to a we ed eWdent

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  • N!!Rf&#!32. Tclanry tim' a:rnospherc) the actual papulation 1

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%.. t m o' the kin h of e:cW W re:e:, e p.aMHity of e-c;ra:

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ha been. :nmated sh d! ab,

e (C'.s m tL h t edaw to thr Reactor d:scasen in p:olebstic lennt Wh recreak - e es;~ cd..g any ;>rev. m cr S&. j"ah, ibnadthe accn!ent

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consequences shall be che.racterized m onping ja:n.' ng>

I The defu.ttk of Clus 9 acciden's terms of ;*ntial r4d.ob/ cal Hoaes n it in alsa the i cat of the in th Annex is nat saffmienth gnecke expmures to in,iividuals, to popu! tion Corrar.issian that he.eaff tak-s! cps to to w urant its f anher uw in Couardssion poups. and wht te apphcah% to bota.

ident:fy adddanal cm3 that nught puhry. r ules. ar.d reguLtams. nor as a f lerJtt ni r.fcty rh.b that my be warrant early comHe,ation of, nher dechmn critenon in a3cacy prac tice.

as sociated with expo eres to pgple additiens! fecurcs or othm act;ons 3 The Anneis prestnphou of shall be discussed in a manner inat which wou!d pre ver.: or mitiWe the ass eptions to be esed in the cnalysis fairly reflects the current state of t.onsegurnces of serious accidents.

of the envi:onnental consequences of knewledge rr garding such risks.

Cases for such ccasidnation are those aceHents does not contribute tu Socieeconenic imp

  • cts that might be for which a rina! Envircanmntal objn !n e ( cnr.ider ation, associated with encipency measures Statement hc3 a! ready been assued at
4. The Anm s does not pin adequate duriy or fo!!owing an acident shou!d tha Cem"udica Pamit st.rge but for rons:dn ation tn the de: ailed trea tment also be dbumed. The eraircnmental which the 0;wratm;'Iianse enew of measures take n to prnent and to rid of accioents should t.lso b" sta;;u has not y et been reached. In mitwate the conrequences of accidents r empared to end contras ted with carrying ca' th:s d: rec'ive. the staff in tha safety redew of each apphtatinn.

radmingical risks associated wch should consider re:e. ant site features, The cW.sifimion of accidenb nonnat and antic; pated operational including pz utation density, associated pro; osed in t at Annex shall no longer relea s es.

with accident risk in co:cparison to such h

he med. In its olac-the following in promulgating this interirn pidance.

featurns at p:esendy operating p! ants mter:m guidance is given for the the Comrnission is aware that there are Staff should also consider the hit hnood treate ent of accident risk and williikelv remain for some time to that substanuve changs in plant design rensiderations in NEPA reviews.

conw rnany Enc ertainties in the features which may cam;>ensate further apptiradon of risk as.tessment rnethods.

for adverse site feattaes may be more Atddent Considerations in Tuture and it expects that its Environmental easily incorporated in piants when NEPA Reviews Impact Statements willidentifv major constructien has not yet progrened very It is the posilm.n of the Co,nm.issmn uncertaintins in its probabihstic f a r.

g

' hat its I as nonmer tallmpact est. mates. On the other hand tae EnvironmenSI Reports subnu.tted by t

< tatements, pursuant to Section 10 4c)(i)

, myong;n m t)W t m sye oy apphcanb for comtructma ptrrn:Is and J

3 of the National Environment.d PoHcv art is Mnewn@ ahannd pd a for opmSng b ~ e on or n9er jufy L Act of 1!m shal!indude a rmenej beginning should now lg mac,e m the um shou:d inciade a discussion of the cons;deration cf the environmental risks uu of O se methodologies in tae ensiron cental risks ameiated with

(;npcts) athibutable to accidents at the accidents that foMows the guidance Use W

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particular facihty or facihties within the "d * *"I a conquct.m and radonal gis en herein.

sr ope of each such staicment. In the forward step.m the dischu *- of its Related Polig.Nia'tersTnder aedy sis and dmussion of such risl.s.

y approxanately equa. attention sha!! be 7

Consh!wtion it is the.u. tent of the Commissba in g;ven to the probabihty of occurrence of issuing this Statement of Interim Pohcy la cddition to its respansibihties nebser and to the probability of mcmrence of the (nvironmen'tal that the staff willinitiate treatments of under NEPA.11." NRC also bean acrident considerations,in ancordance responsibility under tht Atomic Energy isnwouences of those reirases itefeas'es rrfer to radiation and/or with the foregoing guidance. in its Act for the protection of the pubhc on@g NFPA reviews i e.. for any health and safety from the haards radioactis e materials entering prmchng at a licensing stage where a associated with the use of nudear envbonmental exposme pathway s, Final EnvircamentalIrnpact Statement energy. Pursuant to this responsibihty inr6dme air. water, and ground w ater.

I: vents or accider.t sequences that has not y et been issned. These new the Con.m:ssica notes that there are lead to ie?casm shallinc!nde but not be treatments, which will take in' account currently a nurnber of ongoing acti'.ities si nificar.t site-nnd plant-spi being considered by the Comr.Jssion hmited to those that can reasonab!v be 3

espected to on cr. In g lant accideEt features, wiH result in rnore det.nled and its staff which intimately relate to disomions of accident risks than in the Chss 9 accident" question and mpences that can lead to a spectrum of senses shall be chsressed bnd shall previous environmental statements, which are eithe r the subject of current indude sequences that can result in particularly for those related to rulemaking or a*e rand,date s@/ cts for inu#equale cN!mg of reactor fud ar'd to conventional hght water plants at land-rule m.d ing.

sne! ting of the reactor core. The extent to based sites. !! is espected that these On De endo r 19. W9 the revised treatments willlead to Coraminion i.;. sued far pubhc comment s which events arisie.g Isom tauses conclush ns reptding thu envitenmental a p;oposed rule which would ex!cru,d to the plant which are considered passible contributors to the risks of accidents simMar to those that dgnificantly resise its rcquirunents in risk anociated with the particular p!cnt would be reached by a continuatim of 10 CFR Part 50 for emergen:y pienning cases for nuclear peer plants. One of the sha!! also be drscussed. Detailed current practices. Nrticularly fo:

iraolving special t.scumshaces where considerations in this ru?cmaking was quantitntise considerations that form Class 9 risks have been corniderrd by the Lahis of probabilistic estinntes of schse need not be incorpmated in the the staff, as described above. Thus, this

  • c m...em c1 y rmma ay, d - WW v 6e res t* e rm Environmental!mpact Statements but thange in peiicy is not to be construed

' " '"'h Nb P*J %'3 " ;9 *",,%' g,b e' 'y 3 shal: be re'er nced therein. Such as anylack of conf.dence in cuarlusiens o I b'-

ref-rence, shall indude, as app!icabic.

ruan.mg t,.w en vircamental rm.. 3 o.r

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e, reports on ofety evaluatione acciders e xpr::ssed in any p.evsusly

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e e the p win 1 ct.e epearts of Clars 9 d.dems m,e gn-nc sense.'

la A@.st l').i. p 3:suar.t to the Cc:nnustds request a Sd.nu Pohcy Tksk Force ma@ teco:r.rnendations with respect to pessiNe chenps in NRC scanor sit.rq pol'cy and criteria."

c urrent!y set forth m 10 CFh Part Un As stated therein,its recomniendations were inade 10 accomp!!sh (among otaers) thy fdex.;ng goal.

lo in e smo coatmleraben ja ainng tne risk nociated weh act ' 'enu bey:>nd the t%ip b m fCMs 9.' b3 embi shes p ;afation vi ns tv and d unbuSon crite na.

Thn rraner is currently before ?he Cornmission This and other recommerlations that bae b-en rnade as a result of the im entigatior.s into the Three Mde Is!a ni accident are ct,uent y being brought

%c c ther bs the Corunission's staff in tC 'orm oIpn posed Actroa Plans?

A:nang other matters. these incorporate ru ommendatians fo; rulerraking related to degraded co.e coo!as and core melt accidents. ~l he Commission xpects to irae.e decisions on these Act.an Plans in the near future. it is the Com nirsion's poILy ar.d intent to devote NRC's majo.

r.3nurces to scatters which the Commipion bd.es es williaeke existing and future tenhar power plants safes.

and to pre,ent a a currence of the kind of actidem that occurred at Three Mile Island in the interim. however and pt r.d ng ornpletion of ru!cm king r evitms in the areas of cau rpocy

planmng. sitmg criteria, and design and o;+rationa! ufety. all of which involve
cc
siderations of serious acch!ent
potential. the Commission finds it cu.ential to impros e its procedures for descnbinF and disclosing to the public

' the basis for arriving at conclusions

! regarding the environmcotal risks due to acddents at nucle.sr power plants. On ccmpletion of the rulemaking artisities lin these area; and based alsn upon the

experie ne.e gained with this stattruent of

. interim whey ar:d guidante. the

Commission intends to pursue possible

'ch;.nges or additions to 10 CFR Part 61 lto rodify its pasitinn on the role of accident risks under NEPA.

'Cf NUsTCM 4.*Mmics Pa s for the t).ei.tr.ent of 5 aie end h.c e! Cuertment

. E a.aleg.cel be,*3cy Re=pon*e ihn t m Suppmt Ol t sght W9t*f b.ar Pef I*Dewe* Esf.IS. ' bt.wrif'I>Tf tra

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  • s er.ug becweerb: or s (! t!.e ites ae nt's Cuemese 6 id Owr SMen of the 1MI-2 A:rdent." Decenler W 1 C9 e

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