ML20134F678

Expresses Appreciation for Visit of a Drozd in Sept.Policy Statement, Safety Goals for Operation of Npps, Issued by NRC in 1986 Encl

ML20134F678
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Issue date:	01/30/1997
From:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
To:	Ming W AFFILIATION NOT ASSIGNED
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NUDOCS 9702100094
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l_DfL b

UNITED STATES 1

e-t NUCLEAR RE!3ULATORY COMMISSION WASHINGTON, D.C. 20555 0001

/

January 30, 1997 CHAIRMAN J

i Mr. Wu Jian Ming Vice-Chairman Science & Technology Committee Shanghai Nuclear Engineering Research and Design Institute i

P.O. Box 7633 Shanghai 200233 China

)

Dear Mr. Wu:

Thank you for your recent letter expressing appreciation for the visit of Mr. Andrzej Drozd in September.

I am pleased that y:u and other members of your I'.;titute found his brietings on source term calculatic s and fission product transport under post accident conditions to be informative and useful.

4 Post-accident containment analysis is a complex task involving licensing requirements, design-basis criteria, and severe accident considerations.

In your letter, you ask for assistance in establishing safety goals for nuclear power plants.

Since the early 1970s, the Nuclear Regulatory Commission (NRC) has devoted significant effort towards developing probabilistic risk assessment (PRA) methodology. These techniques provide a structured way to assess the likelihood and consequences of severe accidents at nuclear power plants. As the insights and results from a number of plant-specific PRA studies became available in the 1980s, this Agency believed it would be appropriate to establish expectations and goals relating to public risk contributions. These goals were not intended to be specific safety criteria for nuclear plants, but rather to identify acceptable public risk contribution for the overall population from U.S. commercial nuclear plants.

4 Consequently, in 1986, the NRC issued a policy statement, " Safety Goals for the Operation of Nuclear Power Plants." A copy of this policy statement is 1

enclosed.

The objective of this policy statement was to establish goals that broadly defined an acceptable level of radiological risk to the public, for which nuclear power plant operations should not be a significant contributor to a person's risk of accidental death or injury These goals also assisted us in i

considering the necessity and benefits of proposed regulatory changes as they related to groups of plants.

//

The qualitative safety goals were stated as follows:

4 Individual members of the public should be provided a level of protection from the consequences of nuclear power plant

[

v operation such that individuals bear no significant additional risk to life and health.

pL k[j)./0yM k 9702100094 970i30 PDR COMMS NRCC 7

CORRESPONDENCE PDR

. Societal risks to life and health from nuclear power plant operation should be comparable to or less than the risks of generating electricity by viable competing technologies and should not be a significant addition to other societal risks.

l The following quantitative health objectives are to be used in determining achievement of the qualitative goals:

The risk to an average individual in the vicinity of a nuclear power plant of prompt fatalities that might result from reactor accidents should not exceed one-tenth of one i

percent (0.1 percent) of the sum of prompt fatality risks resulting from other accidents to which members of the U.S.

population are generally exposed.

The risk to the population in the area near a nuclear power i

plant of cancer fatalities that might result from nuclear power plant operation should not exceed one-tenth of one percent (0.1 percent) of the sum of cancer fatality risks resulting from all other causes.

You may find the above public risk objectives helpful in developing safety goals for your nuclear plants. While such an approach does ensure that the relative risk contribution from nuclear power is very small compared to other

. societal risks, it does require relatively complete severe accident evaluations to be completed, which include dose and consequence assessments for either a surrogate site or some group of individual reactor sites.

At the time the Safety Goal was being developed, the NRC also considered goals related to other measures of risk that did not require completion of a full Level 3 PRA, which requires an assessment of risk to the public.

In addition to the quantitative health objectives defined above,4the Commission identified a subsidiary objective for core damage frequency (10 / reactor-year) to ensure that a severe reactor accident would be unlikely at any operating reactor.

Additionally, a subsidiary objective for large early radioactive material release frequency (10 / reactor-year) was suggested as a possible criterion to 4

ensure that adequate defense-in-depth and accident mitigation capabilities were maintained.

Since comparisons of core damage and large early release frequencies to these subsidiary guidelines are more directly determined than public dose and impacts, they provide useful insights when assessing proposed regulatory actions.

As stated above, these goals, quantitative health objectives and subsidiary objectives were not initially intended for plant-specific decisions.

Rather, they were utilized to assess the generic impacts of proposed regulatory action.

The NRC continues to increase the use of probabilistic risk assessment in its regulatory processes. At this time, the Commission is considering whether safety goal subsidiary objectives should be applied to plant-specific safety decisions.

. It is expected that draft regulatory guidance documents proposing the use of plant-specific decision criteria will be issued for public comment in early 1997.

These documents will focus upon what risk and safety criteria should be applied when considering modifications to a plant's licensing basis.

You may find the draft guidance to be of interest and the staff will make such documents available to you when they are issued.

Considerable activities related to risk informed decision making are also ongoing at such organizations as the Nuclear Energy Agency (NEA) and International Atomic Energy Agency (IAEA).

You may find their work useful in your safety goal activities.

If we can be of further help in this area, please contact our Office of International Programs.

Sincerely, k

J Shirley Ann Jackson

)

Enclosure:

Safety Goal Policy Statement l

W 30028 Fed:rcl R:gister / Vol. 51 No.162 / Thursday. August 21,1986 / Rules and Regulations NUCl. EAR REGULATORY

7. On page 28048. In the first column.

Acnow: Policy statement.

COMMISSION in the fourth paragraph under the C heading, in the 7th line, the word suestsann This policy statement focuses 10 CFR Part 50

" exceed" should read " exceeds",

on the risks to the public from nuclear

a. On page 28046,in the third column.

Power plant operation. its objective is to Safety Goals for the Operation of in the second complete paragraph, in the establish goals that broadly define an Ndear Power Planta; PoHey toth line, the word "estmates" should acceptable level of radiological risk. In Statement; Co.-Gr. and read " estimates".

developing the policy statement, the J

NRC sponsored two public workshops Reputscetion

9. On page 28047. In the first column.

d p,

Aeasect Nuclear Regulatory in the second paragraph under V. in the I

ur p i e

sd Commission.

2nd ime the word " goal, should read 1982, conducted a 2. year evaluation Acnosc Policy statement: correction and goals.

during 1983 to 1985, and received the I

republication.

10. On page 28047, in the first column.

views of its Advisory Committee on in the second paragraph under V. in the Reactor Safeguards.

susssaann This document corrects a 18th line, the word "guidence" should

%e Commission has established Iwo number of typographical errors found m, read " guidance".

qualitative safety goals which are a

a as pu s in

11. On page 28047. in the second supported by two quantitative 9

c lumn. in the 1st line, the word ob ectives.These two supporting (51 FR 28044). %e policy statement

" Sitting" should read " Siting", and in the ob,ectives are based on the principle M

',I

, t at broad $y define an 2nd line, the word "in" should read "is".

that nuclear risks should not be a acceptable level of radiological risk with

12. On page 28047, in the third column. s,ignificant addition to other societal under General Perfonnance Guideline, noks ne Commission wants to make

~ regard to the operauon ot nuclear power plants. In addition, the policy statement in the 2nd line. the phrase "to a low" clear that no death attributable to should read "to an as low".

nuclear power plant operation will ever la being republished in its entirety in order to highlight the key elements of 11 On page 28048, in the second be " acceptable" in the sense that the the policy statement.

column. in the second rargraph under C:mmission would tegard it as a, routine Commissioner Bernthara separate or permissible event. The Commission is ron FURTHER INFontsADON CONTACT.

Merrill Taylor, Regional Operations and views. In the 4tl2 line, place the word discussing acceptable nsks not "does" between the words "it" and acceptable deaths.

Generic Requirements Staff. Office of

• F the F.xecutive Director for Operations.

U.S. Nuclear Regulatory Commission.

14. On page 28048, in the second follows:

Washington, DC 20555. Telepho m :501-column. in the last paragraph of the

-Individus! members of the public g

492-4356.

column. on the 7th line, the word should be provided a level of in FR Doc. 86-17496. published in the

" options" should read " option".

protection from the consequences of FederalRegister of Monday. AugaM 4.

15. On page 28048, in the third column.

nuclear power plant operation such 1986. make the followmg corrections:

in the 2ndline, the term " defense-in-that individuals bear no significant

1. On page 2a044, in the first column.

dept" shotfld read," defense.m-depth",

additional risk to life and health.

In the Summary statement,in the 12th Dated si Bethesda. Maryland. this 14th day -Societal risks to life and health from line. the word " Commission" should of August.tae6.

nuclear power plant operation should For the Nuc! car Regulatory Comsnission.

be comparable to or less than the

2. On page 28044. In the third column.

in the 6th hne, the word "on should l*h" Phili *'

risks of generating electricity by P

viable competing technoIogies and read "of". end in the 11th lme following Chiel. Aules cadhocedures Branct. Divisio, the word "everything" add the word of/ths ennecoMs. Office of should not be a significant addition to Adnutueuction.

Other societal risks.

"tha t".

3. On page 28045. In the heading of the IFR Doc. as-tant Fded s-2us, a 4s sm)

. The following quantitative first column. the word "This" should sa m a coorrese4s objectives are to be used in determining read "this".

echievement of the above safety goals:

4. On page 28045. in the second

-The risk to an average individualin column. in the second complete 10 CFR Part 50 the vicinity of a nuclear power plant paragraph. in the 13th line, the word of prompt fatalities that might result from reactor accidents should not

" goals" should read " goal".

Safety Goals for the Operations of

5. On page 28045, in the second Nuclear Power Plants; Policy exceed one. tenth of one percent (0.1 percent) of the sum of prompt fatality column, the last word at the bottom of Statement; Repubscetion nsks resulting from other accidents to th C I.urnn.p1 ants" should read

[ Editorial Note-The following document which members of the U.S. population "p

was originally published at pase 28044 in are generall exposed.

6. On page 28045,in the third column, the issue of Monday. August 4.1 sees it is

--The risk to e population in the area in the third complete paragraph. in the being republished in its entuety, wtih near a nuclear power plant of cancer 4th line, the last word "have" 6hould conections, at the request of the agency l fatalities that might result from read "has", and in the tith line, the AotNew Nuclear Regulatory nuclear power plant operation should word "need" should read "needed".

Commission.

not exceed one-tenth of one percent

~

t r

Federal Register / Vel 51, No.162 / Thursd3y, August 21, 1986 / Rules and Regulations30029 (0.1 percent) of the sum of cancer determined to be quite small.They will B. Development of this Stotement of fatahty risks resulting from all other

. continue to receive careful Safety Pblicy causes.

considerstion. The possible effects of IIPescTsvt oATE: August 4,1986.

sabotage or diversion of nuclear in developing the policy statement.

pon surrwen sospeassaTeoes coerra,cT:

material are also' not presently included the Commission sohcited and benefited Merri'l Tsylor, Regional Operations and in the safety goals. At pmaent there is from the information and suggestions Generic Requiressants Staff. Office of no basis on which to provide a measure provided by workshop discussions.

the Executive Director for Opere tions, of risk on these motien. It is the NRC-sponsored workshops were held in U.S. Nuclear Regulatory Commiwlon, Commission's intention that everything Washington, DC 20555. Telephone (301/

that is needed will be done to keep Palo Alto, California,on April 1-3,1981 482 4356).

these types of risks at their present very and in Harpers Ferry, West Virgin July 23-24.1981.The first workshop low level; and it is the Commission's addressed general issues involved in foUowing pmeento the Commission a

• • Pac 88 tion that eNorts on this point developing safety goals.ne second Pohey Staten t on Se y Goals wul continue to be a-aful With these exceptions,it is the Commission's workshop focused on a discussion paper O

pg pers on o intent that the risks from all the various which presented roposed safety goals.

c ar wer I

L letroduction initiating a+-R' _z be taken into Both workshope Ieatured discussions among knowledgeable persons drawn account to the best of the capability of from industry, public interest groups, A. AirposeondScope arrent evaluation techniques.

universities, and elsewhere, who in its response to the la the evaluation of nuclear power represented a broad range of recosranendations of the President's plant operation, the staff considers perspective: and disciplines.

Commission on the Accident at Th ee Sever #I types of releases. Current NRC ne NRC Office of Policy Evaluation Mile Island, the Nuclear Regulatory practice addresses the riska to the submitted to the Commission forits Commission (NRC) stated that it was pubhc resulting from operating nuclear consideration a Discussion Paper on

" prepared to move forward with an power plants. Before a nuclear power explicit pohey statement on safety plant is licensed to operate. NRC Safety Goals for Nuclear Power Plants r

in November 1981 and a revised safety :

philosophy and the role of safety-cost prepares an environmentalimpact goal report in July 1982.

l tradeoffs in the NRC safety decisions."

8Qent Md

, o the redi ca! impacts of The Commission also took into his policy statement is the result.

Current regulatory practices are routine operation of the plant and consideration the comments and believed to ensure that the basic accidents on the population in the region suggestions received from the pubh,c m,,

statutory re)uirement. adequate around the plant site.ne assessment response to the proposed Pohey l

pmtection o the public,is met.

d nd m be Statement on " Safety Coals for Nuclear g

Nevertheless, current practices could be

,""g,'j;Qp bli eom Power plants." pubbshed on February g

e, 9 g

improved to provide a better means for hearinge. For all plants licensed to 17,1m (47 FR 7023). FoHowing pubhc g

testing the adequacy of and need for operate, NRC has found that there will comment, a revised Policy Statement current and proposed regulatory be no measurable radiologicalirnpact on was issued on March 14,1963 (48 FR requirements. He Commission believes any member of the public from routine 10772) and a 2-year evaluation period opera tion of the plant. (

Reference:

NRC began.

I"M'n'd staff calculations of radiciogicalimpact et 8ulat on oy nuc3 ear power pgants, a more on humans contained in Final ne Commission used the staff report and its recommendations that resulted predictable regulatory process, a pubh.

Environmental Statements for specific from the 2-year evaluation of safety c

understanding of the regulatory criteria nuclear power plants; e.g. NUREG-0779, that the NRC applies, and pubhc NURECA812, and NUREG-0854.)

goals in developing this final Policy Statement. Additionally,the t

confidence in the safety of operating ne objective of the Commission's Commi sion had benefit of further plants.nis staternent of NRC safety policy statement is to establish goals comments from its Advisory Committee policy expresses the Commission's that broadly define an acceptable level on Reactor Safeguards (ACRS) and by views on the level of risks to public of radiological risk that might be senior NRC management.

health and safety that the industry imposed on the public as a result of

. Based on the results of this

-J should strive for in its nuclear power nuclear power plant operation. While mformation, the Commission has plants.

this policy statement includes the risks determined that the qualitative safety his policy statement focuses on the of normal operation, as well as goals will remain unchanged from its risks to the public from nuclear power accidents, the Commission believes that March 1983 revised policy statement, plant operation.nese are the risks from because of compliance with Federal and the Commission adopts these as its release of radioactive mater'als from the Radiation Council (FRC) guidance, (40 safety goals for the operation of nuclear reactor to the environment from normal CFR Part 190), and NRC's regulations (10 power plants.

operations as well as from accidents.

CFR Part 20 and Appendix ! to Part 50).

He Commission will refer to these risks the risks from routine emissions are II. Qualitative Safety Goals as the risks of nuclear power ; lant small compared to the safety goals.

The Commission has decided to adopt operation. The risks from the nuclear nerefore, the Commission believes that qualitative safety goals that are fuel cycle are not included in the safety these risks need not be routinely supported by quantitative health effects goals.

analyzed on a case by case basis in These fuel cycle risks have been order to demonstrate conformar ce with objectives for use in the regulatory considered in their own right and the safety goals.

decisionmaking process. The Commission's first qualitative safety c>

-- ~.---

30030 Federal Regi ter / Vol. 5L No.162 / Thursday. August 2L 1986 / Rules and Re,gulationn goalis that the risk hum nuclear power core damage accident will not occur at a acceptable risks. not acceptable deaths.

plant operation should not be a U.S. nuclear power plant.

In any fatal accident.a course of conduct posing an acceptable risk at one i

significant contributor to a person's risk IIL Quantitative Ob}ec6ves Used To moment results in an unacceptable of accidentaldeath orJnjury.Heintent U*"8* ^C

• * **' ' O ' 8'I*'I death mcments later.This is true is to require such a level of safety that individusis living orworking near A. GenemlConsidemtions whether one speaks of driving.

swimining. Dying or genuating nuclear power plants should be able t he quantitativebeattli effects electricity from coal.Eachof these so about their daily lives without,special objectives establish NRC guldance for scuvities poses a calculable risk to concern by virtue of their proximity t pubhc protection which nuclearplant sodety and to individuals.Some of these planta.hs, the Comunission's designers and operators should strive to those who accept the risk (or are part of O"' **I*'Y 8**I I*-

achieve A key element in formulating a a society that accepts risk) do not Individualmemben ofthepublic qualitative safetysoal whose survin We intend est no such l

should be providado derelefpmsection achievement is measured by accidents willoccur, but the possibility fran the mnseguances safmudeerpower quanotative bealth effects objectives is cannotbe enurdy chminated.

plant opemtion such Jhat indiridaals to understand both the strengths and Furthermore. Individual and socletal bearno sq'rnifiant"Wrisk to Jif* hmlutions of b techniques by which risks from nuclear power plants are andheal A

%dges whede guahtatin generally estimated to be considerably Even though protectionefindividust safety goal has been met.

less dan th risk eat society is now members of the public inherently A major step forwardin the provides substantf ai societal protection, development and 4 atof acddent exposed to from each of the other activities mentioned above.

the Commission alsodecided that a kmit risk quantification was takeninthe should be placed on the societalrisks ReactorSafety StudyMASH-MOD)

C Health Effects-Pmmpt andLotent posed by nuclear power plantoperation. completed in tera.Nobjective of the CancerNoriality /tlaks ne Commission also believes that the Study was "to try to reach some ne Commission has decided to adopt risks of nuclear power plant operation meaningful conclusions about the aiskof & Mlowing two health effects as 6e should be comparable to or less than the nuclear socidents." & Study did not quanmauve objectives conceming risks from other viable means of directly address the question of what mortality n,sks to be used in determ,imng generating the same quanttty of level of risk from nuclear socidents was achievement of the quaittative safety electrical energy. ms.the acceptaWe.

g als-i Commission's second safety goat is-S nce the completion of the Reactor

• The risk to an avemse individualm, Societalrisks to hfe andheotth from Safety Study, further progress in the vicinity of onuclearpowerplant of g nuclectpowerpfant operation should be developing probabIlistic risk a esesement pmmptfatalities that might resultfmm compamble to orless than due risks of and la occumulating re1evant data has reactor accidents shouldnot exceed generating electricity by a?iable led to a recognition thatit is fearMe to one tenth of one percent (0.t, percent) of competing technologies and should not begin to use quantitative safety the sum ofpmmptfotclity risks be a significant addition to other objectives ior timited purposes.

resultingfmm otheraccidents to which societalrisks.

However, becanse of the sktable i

ne broad spectrum of expert opinion uncertainties stillpresent in the mefhods members of the U.S.popufation are on the risks posed by electrical and the gaps in the data bese-essen6al genemTly exposed

• b risk to the population in the generation by coaland the absence of elements needed togauge whether the crea near a nuclearpowerplant of authoritative data make it impractical to objectives have been schleved-dre concerfatalities that might resultfrom calibrate nuclear safety goals by quantitative objectives shouldbe nucfearpowerplant opemtion should comparing them with coalriska based viewed es alming points or numerical not exceed one-tenth of one percent (O.t on what we know today. Howevet. the benchmarksof performance. In Commission has established the particular, because of the present percentf of the sum ofcancerfatality quantitative health effects objectives in limitations in b state of the art af risks resulting fmm all other causes.

ne Commission believes bt his such a way that nuclearrisks are not a quantitatively a=H-Hn= cisks, the ratio of 0.1 percent appsopriately reflects significant addition to othersecaetal quantitative heshh effects objectives are both of the qualitativegoals-to provide riska.

not a substitute for axisting segulations.

Severe core damage accidents can ne Commission recognizes the that individuals and societybear no lead to more serious accidents with the importance of mitigating the significant additional risk. However, this potential for life-thseatening offsite consequences of a core-melt accident does not necessarily mean that an release of radiation,for evacuation of and continues to emphasize features additional risk that exceeds 0.1 percent members of the public, and for such as contalament,alting in less would by itself constitute a signIricant antamination of public property. Apart populated areaa.andemergency additionst risk.De 0.1 percent refio to from their heal 0 and safety planning as integral parts of the defense. other risks is low enough to su) port an consequences, severe core damage in<lepth concept associated withits expectaGon that people living or accidents can erode public conGdence la accident prevention and mitigation working near nuclear power plants the safety of nuclear power and can lead philosophy.

would have no special concern due to the plant's proximity.

to furtherinstabihty and R4uoneofin M Mfectins The average Individual in the vicinity unpredictability for the industry. In order to avoid these adverse De Commission wants to make clear of the plant is dermed as the average consequences, the Commission intends at the beginning of this section that no individual biologically (in terms of age to continue to pursue a regu$atory death attributable to nuclear power and other risk factors) and locationally program that has as its ob}ective plant operation will ever be who resides within a mile from the plant providing reasonable assurance, while

" acceptable" in the sense that the site boundary.This means that the giving appropriate consideration to the Commission would regard it as a routine average individualis found by uncertainties involved, that a severe or permissible event. We are discussing accumulating the estimated individual l'

i i

l Focieral Register / Vol. 51. No.182 / "Ihursday. August 21, 1986 / Rules and Regulations 30031 risks and dividing by the number of rotection, since the risk to the people should also be reasonably balanced and individuals residing in the vicinity of the ond 10 miles will be less than the supported through use of deterministic l

P ant.

rien to the people within 10 miles.

arguments. In this way judgements can in applying the objective for IV.Treatusesst of Uncer al=Haa be made by the decisionmaker about the r

individual risk of prompt fatality the degree of confidence to be given to these Commission has defined the vicinity se

%e Commission is aware that estimates and assumptions.nis is a the area within 1 mile of the nuclear uncertainties are not caused by use of key part of the process of determining power plant site boundary, since unntitative methodology in the degree of regulatory conservatism calculations of the consequenas of afaammMng but are merely that may be warranted for particular saspor reactor accidents suggest that highlighted thmugh use of the decisions. %Is defense-in. depth individuals within a mile of the plant quantification pmcesa. Confidence in approach is expected to continue to site boundary would generally be the use of pmbebiliatic and risk ensum the protection of public health subject to the greatest risk of prompt assessment techniques has steadily and safety.

death attributable to radiological imprmd since the time these were used causes. If there are no individuals la the Rasetor Safety Study. In fact.

Muidelmas For L_._,,,

sesiding within a mile of the plant through use of quantitative techniques.

totion boundary an individual should, for important uncertainties have been and

%e Commission approves use of the evaluation purposes, be assumed to continue to be brought into better focus qualitative safety goals, including use of reside 1 mile fmm the site boundary.

and may even be reduced compared to the quantitative health effects objectives in applying the objective for cancer those that would remain with sole in the regulatory decisionmaking l

allance on detenministic f;talities as a population guideline for process.De Commission recognizes i

individuals in the area near the plant, decialaamaHng To the extent that the safety goal can provide a useful the Commission has defined the practkable. the t'amminalao intends to tool by which the adequacy of ensure at ee quantitative techniques regulations or regulatory decisions population generally considered subject to significant risk as the population

' "8"

• 7 08 8 8

regarding changes to the regulations can within 10 mile? of the plant site.He -

8 8CC unt a Potennal uncensinte be luc _114kewise, the safety goals that niet so eat an esumste can be i

bulk of significant exposures of the could be of benefit in the much more made on the confidence level to be population to radiation would be difficult task of assessing whether l

concentrated within this distance, and exi8 ting plants, designed. constructed n

mi so as a op ed t use thus this is,the appropriate population of mean estimates for purposes of and operated to comply with east and for campanson with cancer fatality risks implementing the quantitative objectives

1. "'"I '*I" "I " * * * * " " "

9"*!*'Y frorn all other causes. His objective of this safety goal policy (Le., the with the intent of the safety goal pohey.

1 would ensure that the estimated mortality risk objectives). Use of the

.H wever,in onfer t do this, the staff i

increase in the risk of delayed cancer mean estimates comports with the will require 8pecific guidelines to use as fatalities from all potential radiation customary practices for cost-benefit a basis for determining whether a level releases at a typical plant would be no analyses and it is the correct usage for f safety ascribed to a plant is more than a small fraction of the year-purposes of the mortality risk cons! stent wi6 Ge safety goal pohy to-year normal variation in the expected comparisons. Use of mean estimates As a separate mauer. Se Cornmission cancer deaths from eonnuclear causes.

does not however resolve the need to intends to review and epprove guidance i

Moreover, the prompt fatality objective quantify (to the extent reasonable) and to the staff regardmg suc,n for protecting individuale generally understand those important determinations. It is currently i

provides even greater protection to the uncertainties invclved in the reactor envisi ned that this guidance would population as a whole.That is,if the accident risk predictions. A number of address matters such as plant quantitiative objective for prompt uncertainties (e.g thermal-hydraulic performance guidelines,incicators for fatality is inet for individuals in the assumptions and the phenomenology of operational performance, and guidelines immediate vicinity of the plant, the core-melt progression, fission product This guidance would be den,nelyses.

I0r conduct of cost. benefit a estimated risk of delayed cancer fatality release and transport, and containment ved from to persons within to miles of the plant loads and performance) arise beca :se of additional studies conrincted by the staff end beyond would generally be much a direct lack of severe accident and resulting in recommendations to the lower than the quantitative objective for experience or knowledge of accident Commission.%e guidance would be cancer fatality.nus, compliance with phenomenology along with data related based on the following general i

the prompt fatality objective applied to to probability distributions.

performance guideline which is individuals close to the plant would in such a situation,it is necessary that proposed by the Commission for further generally mean that the aggregate proper attention be given not only to the staff examinatior>-

estimated societal risk would be a range of uncertainty surrounding Consistent with the imditional tumber of times lower than it would be probabilistic estimates, but stao to the defense.in-depth approach and the if compliance with lust the objective phenomenology that most influences the occident mitigation philosophy applied to the population as a whole uncertainties. For this reason. sensitivity requiring reliableperformance of were involved. The distance for studies should be performed to containment systems, the overo// mean i

cveraging the cancer fatality risk was determine those uncertainties most frequency ofo lorge release of tiken as 50 miles in the 1483 policy important to the probabilistic estimates.

todioactive matericls to the 4

statement. The change to 10 miles could

%e results of sensitivity of studies envimnment from a reactor occident be viewed to provide additional should be displayed showing. for should be less than 1 in J.000.000per protection to individuals in the vicinity example, the range of variation together year oficoctor operotson.

cf the plant, although analyses indicate with the underlying science or To provide adequate protection of the that this objective for cancer fatality engineering assumptions that dominate public health and safety, current NRC will not be the controlling one. It also this variation. Depending on the regulations require conservatism in provides more representative societal decision needs, the probabilistic results design, construction. testing operetion

i o 30032 Feder;l Registir / Vol. 51, No.162 / Thursday. August 21, 1986 / Rules and Regulations and maintenance of nuclear power emphasis to be given to eccid nt compromise.1 bellsva it is an objective plants. A defense-in-depth appmach has prevention and accident mitigation.

that is consistent with the been mandated in order to prevent Such guidance is necessary to ensure recommendations of the Commission's accidents from happening and to that the principle of defense-in-depth is chief safety officer and our Director of mitigate their consequences. Siting in maintained.ne Commission's Advisory Research, and past urgings of the less populated areas is emphasized.

Committee on Reactor Safeguards has Advisory Committee on Reactor Furthermore. emergency response repeatedly urged the Commission to do Safeguards. Unfortunately, the capabilities are mandated to provide so. As a step in that direction. I offered Commission stopped short of adopting e

additional defense.in-depth protection for Commission consideration the this guideline as a performance to the surrounding population.

following containment performance objective in the policy statement, but i These safety goals and these criterion:

em encouraged that the Commission is willing at least to examine the implementation guidelines are not in order to awure a proper balance Possibility of adoptingit. Achieving such meant as a substitute for NRC's between accident prevention and accident regulations and do not relieve nuclear saltisation. the mean frequency of a standard coupled with the

]

power plant permittees and limnsees containment failure in the event of a severe containment perfottnance objective imrn complying with regulations. Nor core damage accident should be less than s in given above would go a long way are the safety goals and these too severe core damage accidents-toward ensudng that the operating implementation guidelines in and of Since the Chernobyl accident, the reactors suomasfully complete their usefullives and that the nuclear option themselves meant to serve as a sole nuclear industry has been trying to basis for licensing decisions. However, distance itselfimm the Chernobyl remains a viable component of the if pursuant to these guidelines, accident on the basis of the expected nation's energy mix.

information is developed that is performance of the containments amund in addition to preferry adoption of app!! cable to a particular licensina the U.S. power reactors. Unfortunately, this standard now,I also believe the decision.It may be considered as one the industry and the Commission are Commission needs to define a "large factor in the licensing decisic.t.

unwilling to commit to a level of release" of radioactive materials. I ne additional views of Commissioner performance for the containments.

would have defined it as "a release that Asselstine and the separate views of The argument has been made that we would tesult in a whole body dose of 5 Commissione' Bernthal are attached-do not know how to develop rem to en individual located at the site Dated at Washington. DC, this 30th day of containment perionnance cdteria boundary."%is would be consistent 1 4 1988.

(accident mitigation) because core with the EPA's emergency planning For the Nuclear Regulatory Commission.

meltdown phenomena and containment Protective Action Guidelines and with Lando W. Zech. Ir.,

response thereto are very complex and t'te level proposed by the NRC staff for involve substantial uncertainties. On the defining an Extraordinary Nuclear other hand, to measure how close a Occurrence under the Price-Anderson Chairmas Additional Views by Comnu.ssioner plant comes to the quantitative Act. In adopting such a definition, the Asselstine on the Safety Goal Policy guidelines contained in this policy Commission would be saying that its Statement statement and to perfonn analyses objective is to ensure that tl ere is no

%e commercial nuclear power required by the Comenission's backfit more than a 1 in 1,000,000 chance per industry started rather slowly and mie, one must perform just those kinds year that the public would have to be cautiously in the early 1960's. By the late of analyses.1 find these positions evacuated from the vicinity of a nuclear reactor and that the waiver of defenses 1960's and early 19 O's the growth of the inconsistent.

industry reached a feverish pace. New ne other argument against a provisions of the Price-Anderson Act orders were ccming in for regulatory containment performance criterion is would be invoked. I believe this to be an review on almost a weekly basis.%e that such e standard would overspecify appropriate objective in ensuring that result was the designs of the plants the safety goal. However, a containment there is no undue risk to the public outpaced operational experience and performance objective is an element of health and safety associated with the development of safety standards. As ensuring that the principle of defense-in. nuclear power.

experience was gained in operational depth is maintained. Since we cannot Cost-Bendt Analym characteristics and in eefety reviews.

rule out core meltdown accidents in the safety standerds were developed or foreseeable future. given the current I believe it is long overdue for the modified with a general trend toward level of safety,I believe it unwise not to Commission to decide the appropriate stricter requirements. nus, in the early establish an expectation on the way to conduct cost-benefit analyses.

tir/O's, the industry demanded to know performance of the final barrier to a ne Comrnission's own regulations "how safe is safe enough."In this Safety substantial release of radioactive require these analyses, which play a Goal Policy Statement. the Commission materials to the environment, given a substantial role in the decisionmaking is reaching a first attempt at answering core meltdown.

on whether to improve safety. Yet, the Commission continues to postpone the question. Much credit should go to General Performance Guideline addressing this fundamentalissue.

Chairman Palladino's efforts over the past 5 years to develop this policy While I have previously supported an Future React

statement. I approve this policy objective of reducing the risks to an as statement but believe it needs to go low as reasonatly achievable level, the in my view, this safety goal policy fitrther.nere are four additional general performance gu'deline statement has been developed with a aspecis which should have been articulated in this policy (i.e "... the steady eye on the apparent level of addressed by the policy statement.

overall mean frequency of a large safety already achieved by most of release of radioactive materials to the operating reactors.%at level has been g,

p environrnent from a reactor accident arrived at by a piecemeal approach to First. I believe the Commission should should be less than t in 1.000,000 per designing. constructing and upgrading of have developed a policy on the relative year of reactor operation.")is a suitable the plants over the years as experience

,t Federal Regist:r / Vol. 51. No.182 / Thursday. August 21, 1986 / Rules and Regulations 30033 i

P was gained with th'e plants and as the Commission were to find 100 percent offsite consequences deserves careful results of required tesearch became confidence in some impervious thought. Is it reasonable that Zion and available. Given the performance of the containment design, but ignored what Palo Verde, for example, be assigned the i

. cunent generation of plants,I believe a was inside the containment, the primary same theoretical " standard person" risk, safety goal for these plants is not good mandate would be satisfied, but in all even though they pose considerably enough for the future. nis policy thlihood, the second would not.

different risks for the US population as statement should have had a separate.

Consistent with the fiammission's long-a whole? As they stand, these 0.1 pool that would require substantially standing defense.in-depth philosophy, percent goals do not explicitly include cetter plants for the next generetion. To both core-melt and containment population density considerations; a argue that the level of safety achieved perfonnance criteria should therefore be power plant could be located in Central by, plant designs that are over 10 years clearly stated parts of the Commission's Park and still meet the Commission's oso is good enough for the next safety goals.

generation is to have little faith in the in short, this paddmg lacks a theme.

quantitative offsite release standard.

ingenuity of engineers and in the Maaningful aneurance to the public:

I believe the Commission's standards potenual for nuclear technology.1 would substantive guidance to the NRC staff; should preserve the important principle aave required the next_ generation of the regulatory path to the future for the that site-specific populauon density be plants to be substantiaUy safer than the industry-all these should be provided quantitatively considered in formulating currently operating plants.

by plainly stating that, consistent with the Commission's societal risk objective:

the = -"='s " defense-in-depth" e

y req ng at f th e mUS SepmWe Views of Comehr Borothal on Safety Goals Policy g

gg) g,,[ core-damage accidents consequence of UA nuclear power plant I do not disapprove of what has been should not be expected, on average, to operations should not exceed some said in this policy statement, but too occur in the US more than once in 100 appropriate specified fraction of the sum much remains unsaid.ne public is years:.

of the expected risk of fatality from all understandably desirous of reassurance (2) Containment performance at other hazards to which members of the since Chernobyh tne NRC staff needs nuclear power plcnts should be such UA population are generally exposed.

clearguidance % cany out its that severe acciderts with substantial I am L.ther concemed by the respensibilities to assure public health offsite damages are not expected, on arbitrary nature of the 0.1 percent and.afety; the nuclear industry needs to aversge. to occur in the US more than incremental" societal" health risk plan for the future. All want and deserve once in 1,000 years; to see clear, unambiguous, practical (3) He goal for offsite consequences standard adopted by the Commission, a concept grounded in a purely subjective i

safety obice:tives that provide the should be, expected to be met after I

Commission's answer to the question, conservative consideration of the assessment of what the public might "llow safe is safe enought" at UA uncertainties associated with the accept.%e Commission shouId nuclear power plants. ne question estimated frequency of severe core-seriously consider a more rational remains unanswered.

damage and the estimated mitigation standard, tied statistically to the It is unrealistic for the Commission to thereof by containment.'

average variations in natural exposure expect that society, for the foreseeable ne term " substantial offsite to radiation from all other sources.

future, will iudge nuclear power by the damages" would correspond to the Finally, as noted in its introductory same standard as it does all other risks.

Commission's legal definition of comments, the Commission long ago De issue today is not so much

" extraordinary nuclear occurrence."

committed to " move forward with an calculated risk: the issue is public

" Conservative consideration of explicit policy statement on safety acceptance and, consistent with the associated uncertainties" should offer at philosophy and the role of safety-cost intent of Congress, preservation of the least 90 percent confidence (typical good tradeoffs in NRC safety decisions."

nuclear option.

engineering judgment,I would hupe)

While this policy statement may not be In these early decades of nuclear that the offsite release goalis met.

very " explicit", as discussed above, it power, BU-style incidents must be ne broad core-melt and offsite-contains nothing at all on the subject of rendered so rare that we would expect release goals should be met "for the

"

• safety-cost

• tradeoffs in NRC safety to recount such an event only to our average power plant":1.e., for the decisions." For example, is $1,000 per grandchildren. For today's population of aggregate of UA powerplants.%e person-rem an appropriate cost-benefit reactors, that implies a probability for decision to fix or not to fix a specific standard for NRC regulatory action?

severe core damage of 10' per reactor plant would then depend on achieving While I have long argued that such year; for the longer term. It implies "the goal for offsite consequences." As a fundamental decisions are more rightly something better. I see this as a practical matter, this offsite societal risk the responsibility of Congress, the NRC straightforward policy conclusion that objective would (and should) be staff continues to use its own ad-hoc every newspaper editor in the country significantly dependent on site-specific judgment in lieu of either the understands only too well. If the population density.

Commission or the Congress speaking to Commission fails to set (and realize) this

%e absence of such expheit the issue objective then the nuclear option will population density considerations in the In' summary, while the Commission cease to be credible before the end of Commission's 0.1 percent goals for has produced a document which is not the century. In other words, if TMI style events were to occur with 10-15 year in conflict with my broad philosophy in

. g,,,,,un,,y mA the commswan has such matters. I doubt that the publi regularity, public acceptance of nuclear

.dopia propo.ed sons mitar to the above core.

expected a philosophical dissertat.c power would s!most certainly fail.

melt sad contdameai performance objecove.--

ion.

C ken asether. the however erudite. It is a tribute to And while the Commission's primary c"ommi.'h** **Y".:'peran*t orrew prompt r.:. hey "h'*'. on e ti) o Chairman Palladino's eflort: that the charge is to protect public health and soak m pnrpo d e per.eper t*'P safety,it is also the clear intent of onsim ra e" crnerioca m communwrw io Commission has come this far. But the Congress that the Commission,if p=ide reasonabk==rina.. thm a se=+

task remains unfinished.

possible, regulate in a way that

• *"id*"' "*H '** "' m e u s preservos rather than jeopardizes the N7t[

p Doc. es-m N s-m e o amj e

sin n the nuclear option. So, for example, if the plainly stated criterte svarsed abma.

a8 C00E **-* '-*'