ML20148F935
| ML20148F935 | |
| Person / Time | |
|---|---|
| Issue date: | 11/01/1978 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 7811090255 | |
| Download: ML20148F935 (39) | |
Text
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I NUCLEAR REGUI.ATORY COMMISSION - '
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! IN THE MATTER OF:
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f PUBLIC MEETING BRIEFING ON SECY-78-560 - PROPOSED STAFF RESPONSE TO THE J. HONICKER PETITION l
FOR EMERGENCY & REMEDIAL ACTION ,
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Place - Washington, D. C.
1 Date - Wednesday, 1 November 1978 Pages 1 - 38
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. DISCt. AIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on 1 November 1978 in the Commission's offices at 1717 H Street, N. W. , Wasningt.on, D. C. The meeting was open to public attendance and observation. Th'is transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies.
The transcript is intended solely for general infoma'tional purposes.
As provided by 10 CFR 9.103, it is not part of the formal or infomal' record of decision of the matters discussed. Expressions of opinion .in this transcript do not necessarily reflect final determinations or beliefs. No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any statement or argument contained herein, except as the Commission may authorize.
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2 NUCLEAR REGULATORY COMMISSION 3
4 5
PUBLIC MEETING 6 ..
7 BRIEFING ON SECY-78-560 - PROPOSED 8
STAFF RESPONSE TO THE J. HONICKER PETITION 9
FOR EMERGENCY & REMEDIAL ACTION 10 11 Room 1130 12 1717 H Street, N. W.
Washington, D. C.
13 Wednesday, 1 November 1978 14 15 The Commission met, pursuant to notice, at 3:45 p.m.
16 BEFORE:
17 DR. JOSEPH M. HENDRIE, Chair!Aan 18 RICHARD T. KENNEDY, Commissioner 19 PETER A. BRADFORD, Commissioner 20 JOHN F. AHEARNE, Commissioner 21 22 23 24 .
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p,g q C_ g g g I_ N_ g g tpe 3A 2 CHAIRMAN HENDRIE: Okay, if we may come to order, tvid 1 3 The next subject is a briefing by the staff on a proposed 4
staff response to the petition submitted by Mrs. Honicker, 5
petitioning for emergency and real action along the lines f shutting down the active nuclear industry for reasons 6
7 set for in that petition. .
Now, I want to tell the Commissioners that this 8
i 9
is the second instance recently when I have gone ahead and ;
10 scheduled a briefing for the Commission in the sense of an introduction to the subject, literally. That is, I 11 12 knew perfectly well that the staff paper was not going to 13 arrive in any reasonable time for the Commissioners or 34 their assistants to read it. ;
15 In fact, I guess I'm not quite sure when it ,
came into my office, but it was quite recent. But the 16 j7 scheduling was to, as we did the other day. with the business l of' the licensee evaluation system from INE so provide 18 I I;
19 sort of the start of your consideration and your assistance i in reading the paper with this opportunity to hear the ! l 20 ; I i
21 staff say, now here is where we've gone and here is sor' '
l 22 guidepos ts in it. ,
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23 And we certainly ask quuicions and discuss ,
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24 any items that anybody is interested in, bat I certainly :_
merci Reporters, Inc.
25 don't look for -- I'm not going to ask you to decide anything !
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. . 4 avid 2 this afternoon.
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Having had this in hand only a very short time, 2
and that was not the intent of this meeting, but it did 3
seem to be a very complex subject and one which after some 4
discussion with Harold Denton, I thought it would be 5
useful to have an introductory session.
6 I would consult with the secretary, but may 7
want to in the future characterize this sort of situation 8
by noting -- by having the agenda, for instance, the 9
10 introductory briefing on proposed staff response or jj some way to signal you that the intent here was not that 12 every ne would come fully read and decided and ready to 13 close on all the issues.
jg COMMISSIONER AHEARNE: That would be a help not 15 niy to us, but to others.
CHAIRMAN HENDRIE: John, keep that in mind.
16 17 MR. HOYLE: Yes, we certainly will.
CHAIRMAN HENDRIE: In a sense a briefing is of 18 39 that character, but we often also brief subjects where 20 we've had papers for some time and people are getting their ideas well developed, and'the briefing is really 21 22 shorthand for discussion.
With that caveat to keep us from having outraged 23 24 comments on the timing, Harold.
- e. o neoon m ,Inc.
25 MR. DENTON: There have been a number of I,
5 rid 3 )
individuals involved in the preparation of this response, 2
and I have two principals here today, Bill Kreger on 3 my left and Harold Nash on my right, and they will summarize 4 for you some of the major substantive aspects of our 5 review.
6 If I could have the first slide.
7 (Slide.)
8 This is an outline of our approach to the 9 issue. It was a substantive petition, 152 pages. It 10 involved both the medical and physical aspects of releases 11 of radiation and the impacts of radiation.
12 We put together, members of tne staff who are 13 experts in these" areas, and have assembled the proposed 14 response that is before you today.
15 If I could go to the next slide.
16 (Slide.)
17 There are two considerations that I wanted to l 18 call your attention to that are somewhat unique. One is 19 we are treating in the proposed response the relative 20 health effects of the nuclear fuel cycle and other cold l 21 cycles, and you may recall we had -- we were doing this 22 Prior to the completion of the Lewis Committee. As a 23 result of the Lewis Committee, we have revised our table 24 and have put in the text of the proposed reply findings of L Meril Reparars,1% !
25 the Lewis Committee.
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ride We have expanded the range of uncertainty. This 2
is shown, I think, on page 17, 18, and 19 of the proposed 3
reply, and Bill Kreger will illustrate some of the impacts of that a little later.
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I also wanted to say that we are also including 6
in the proposed reply some discussion of the impact of the petition. We looked at the petition first from the 0
Atomic Energy Act point of view and what the health and 9
safety aspects were, but we also looked from a NEPA 10 standpoint to see what the costs would be in granting the 11 petition.
12 So, with this preliminary background, let me 13 turn it over to Bill to go through the type of review 14 performed. l MR. KREGER: If we could go back to the first i
16 l vu-graph for a minute.
17 (Slide.) j 18 l '
You will recognize that this is not quite the ;
19 way the response is organized; the 84 page response has 20 these aspects in it, but by a table of contents it's not ,
21 quite the same. We felt for the purpose of this briefing 22 that it would be useful to touch first briefly on the medical 23 aspects, secondly on the physical aspects and thirdly on the 24 , '
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effects of shutdown, since we can't begin to cover in any 25 depth the complete substance of the 80 some page response.
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- id5 If I could have the ' third vu-graph now.
2 (Slide.)
I will talk first about the medical aspects. .
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The petition had 11 specif4 . what were. called medical 5
principles'in'the stateme e f fact section; in addition -
6 to about 30 pages of technical detail we treated in the 7
response . in detail our analysis of the 11 medical principles 8
and of the view that we were able to supply to it from the basis of staff information'and references, technical.
information in the community, radiation protection community, medical principles on the effects of radiation in the 12 community. ,
The main thrust of the petition, to try to >
14 summarize in a very simple way, the 11 principles, I could ,
15 say that my analysis was that the summary is that radiation i 16 is more harmful than the standard setting bodies and medical 17 authorities have thought. To quote from the petition: " observed 18 .
effects on human populations confirm the serious underestimation
- I 19 of health effects predictions embodied in the present f
regulations."
That was referring to regulations for radiation f protection and primarily 10 CFR part 20 and other regulations f 23 '
set by' standard setting bodies.
14 t-i e ,,,, c n ,,,ine, The. main emphasis of the response we summarized in
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'a very early part of the document relative to medical. The ;
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I idh response goes as follows: "It has not been scientifically established that there are any health effects from the 3
very low levels of human population exposure that result t 4
from the normal operation of the nuclear fuel cycle.
5 Nevertheless, NRC takes the prudent course and uses t 6
standards for radiation protection based on a linear non--
7 threshold hypothesis which says that you have to look at 8
known effects that happen at very, very much higher 9
levels of radiation exposure and extrapolate them down to 10 these very, very low levels as if the effects are linearly 11 related to the dose or the radiation imposed.
"Then on that basis we calulate -- the staff ;
3 calculates health effects and uses those health effects 14 in the impact analysis for licensing, and it makes every 15 attempt in all of our regulations and in looking at these 16 license applications to assure that the doses resulting.
17 from operation of the nuclear fuel cycle facility will be 18 as low as reasonably achievable, rather than just meeting l, I
19 t the standards which exist." l I '
20 I'm going to discuss a little bit radiation !
21 protection standards, population exposure perspective, and j 22 health effects summary, pulling just a few things out of the ]
23 petition response that you have in hand. - i 24 s cwei Qoorms. im. If I could have the next vu-graph. -
25 i (Slide.) :
9 tid 7 1 This is a graphical presentation of how 2 radiation protection standards are developed;in a sense 3 both internationally and nationally a great deal .of 4 consideration is given in medical, biological, socioeconomic 5 aspects by various bodies. Off to the right you see l 6 reference to UNSCEAR, to the nas?beir reports which only 7 the 1972 one is out.
8 These go into basic recommendations that are 9 made by a number of bodies and the National Council on 10 Radiation Protection and Measurements and the International 11 Committee on Radiation Protection, internationally, and 12 those committees have put out documents 39 and 43 and 13 71, 75 and ICRP 26 and 59 and 77, which provide the 14 guidance on which federal agencies establish radiation 15 Protection standards.
16 The primary one on which our regulations are J
17 based is the Federal Radiation Council's radiation 18 Protection guides issued in 1960 and approved by 19 President Eisenhower, and that guidance goes down into 20 the federal agencies and the regulations which we have 1
21 developed on that basis or the federal agencies have 22 developed are listed in the lef thand corner of the right 23 bottom block.
24 If I could go to the next slide. ,
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I 25 (Slide.)
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10 I The Council's radiation protection guies of
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1960 are shown in this slide. Radiation worker guides
-18 3
for 5 X N rem per year where N was the age of the employee for a 13 week dose of 3 rem for the population, )
5 the federal radiation guides had an individual dose of l
6
- 500 millirem or .5 rem whole body or 30 year average 7
gonadal dose of 5 which results in an average population J
8 dose of .17 per year.
9 i There is an additional criteria in the federal l
10 radiation protection guides that I did not show in this 11 slide, and that is for an average dose to unaffected 12 population in the vicinity of a facility of 170 millirem I3 whole body per year.
I# so, the actual radiation limit set by the
" federal government were proposed an d approved by the l
16 president were these, with that additional 170 millirem
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17 per year local population.
I-18 These have been reviewed in the recommendations i I
l of ICRP 26 which came out in 1977 and other than the 20 -18 i l l proposed elimination of 5 X N rule and many other jI j l 21 1 substantive things regarding details, the guidance remains l
22 just about the same in 1977 and ICRP guidance as it was 23 in these guides which came out in 1960.
24 If I could have the next vu-graph. -
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Cft 1191 11 HEER t-4 mte J (Slide.)
2 One of the criteria of harm is the total collective 3
exposure received by a population from whatever the source of radiation. This viewgraph puts in perspective the various 4 ]
sources of radiation to which the U.S. population is exposed, 5
6 and in fact many other populations.
But the quantitative figures on the right-hand column 7
are the man-rems of collective exposure received by the U.S.
8 9
population, 1978 population, from natural background, from 10 !
medical-dental sources, nuclear weapons-related, non-nuclear 11 energy-related, nuclear energy, consumer products, and ot'eer sources of radiation such as accelerators, research reactors and -
12 13 some other kinds of products. ,
ja And these are placed in order of descending collective ,
l 15 exposure. As you can see, the two major sources, and in fact 16 the source that is providing 98 percent of the exposure to the population, are the first two. Nuclear comes fifth in line, 17 with 0.2 times 10 to the 6th man-rems in 1978, resulting from 18 l
19 51,000 megawatts electric' power generation, again, on the basis i of normal operation of the fuel cycle. And that is not only 20 21 the 51,000 megawatts electric power generation, but that is 22 amortizing all aspects of the fuel cycle onto that fuel genera-23 tion.
24 COMMISSIONER AHEARNE: Nuclear weapons are in there?
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25 MR. KREGER: That is almost all atmospheric testing l
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mte 2 12 remnants.- Medical-dental is some 130 million procedures a year in medical to 90~million people of various diagnostic aspects. ,
2 CHAIRMAN HENDRIE: I account for several percent of 3
4 that personally.
(Laughter.)
5 6
MR. KREGER: Could I go to the next viewgraph, please?
7 (Slide.)
We made the assumption that I mentioned before, that 8
health effects can be obtained on a linear, non-threshold basis ]
9 1
from population exposures. We also made the assumption that 10 j
.j the BEIR Committee values still stand. And on that basis, using both the absolute riss. estimater of BEIR, 1972, and the relative 12 risk estimater of BEIR, which gives the higher number, we calcu-13 ja lated the eventual cancers per year due to these seven major 15 sources of radiation.
16 Again, you can see that nuclear energy in our staff 17 evaluation provides from two to nine cancers in the 200 million 18 population in the United States in 1978, based on the 51,000 ,
19 megawatts electric.
The American Cancer Society --
20 COMISSIONER KENNEDY : So that is cancers per year.
21 S that is from here on it is two to nine per year for the 22 23 present number of reactors and the present population?
24 MR. KREGER: Yes. For most of the kinds of cancer the ,
- .oer. neconm, inc. . -j 25 latency may be as much as 20 years, though, from time of exposurp.
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The American Cancer Society has estimated the number 2 of new cancer cases and the number of cancer deaths in 1978, 3 and they are shown on the bottom of the slide.
4 COMMISSIONER BRADFORD: If I have understood you, 5 those last two numbers don't really relate to each other. That 6 two to nine figure is actually the number that won't have any 7 meaning until the 1990s.
8 MR. KREGER: Yes, that would be correct. Well, you 9 can't really say when those cancers are going to occur. I'm 10 j ust saying that for most --
11 COMMISSIONER BRADFORD: But they should not be com-12 pared to the 700,000.
13 MR. KREGER: No, not in the sense that they are not 14 occurring this year, that is correct.
15 MR. DENTON: There could be some occurring this year 16 from operations that began 20 years ago, a smaller number, 17 CHAIRMAN HENDRIE: If you had a steady state situation 18 in which the annual population exposures f rom the seven cate-v(\ 19 gories of source -- whereas on the previous slide, then I think I 20 they would be comparable,. right?
21 VOICE: Only if the 700,000 did not change over time.
22 CHAIRMAN HENDRIE: To be sure.
23 MR. KREGER: That two to nine would be cancer deaths.
24 COMMISSIONER KENNEDY: In other words , all of the ,
federal Reporters, Inc. - 4 25 eventual cancers, that is cancer deaths?
1
mte 4' . 14 MR. KREGER: Yes, it should be eventual cancer 3
deaths. It is the column of eventual cancer deaths. The real' ,
2 risk estimaters are cancer deaths'per man-rem, really, to cancer i 3
4 deaths eventually.
One of the things that I would like to emphasize 5
6 about this slide is that the National Council on Radiation {
Protection and Measurements, for example, refuses to' use the 7
i term man-rem, and to convert man-rem, which was~what.I had in- :
8 the previous slide, to cancers by this mechanism I've used,
_9 10 which is just to multiply the collective man-rem by the risk 11 estimater from BEIR. And the reason !!CRP refuses to do that -- ,
12 and it has been a policy of NCRP all during Mr. Taylor's reign 13 as president -- is that he believes that the effect of very j4 low levels of radiation, and many of the Council believe that 15 the effects of very low levels, are actually much less than a 16 linear hypothesis would predict, and unless you know the expo-j7 sure to which a particular person has been exposed, you can't ;
18 determine what his health effect will be.
2 19 Now, we ignore that and add all the exposures as' if 20 they had exactly the same meaning and come up with these kind of numbers of eventual cancers. j 21
\
COMMISSIONER KE11NEDY: So that this, these estimates, 22 23 w uld be higher than Taylor 's estimates , were he to make them.
24 MR. DENTON: If Taylor is correct.
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1 25 MR. KREGER: Now, the petition argues the othe-l l
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- direction, that based on Mancuso and a number of other medical 2
evidences, low levels may be a higher risk than a linear extra-3 polation would argue. And we have cited a number of references 4
in the medical part of the staff response that we believe 5
are contradictory to that position.
6 But in any case, we have assumed for the purpose of 7
all of our regulatory activity that the linear non-threshold hypothesis applies.
8 COMMISSIONER AHEARNE: Can I ask a question on the 9
10 linkage of these two? As I understand it, you're going from 11 your population exposure in '78 to then saying what is the 12 eventual cancer deaths. In '78, as you mentioned, there are 13 X numbers of plants operating.
14 MR. KREGER: 70. ,
15 COMMISSIONER AHEARNE: Now, isn't it the case that 16 those plants will continue to require fuel over their lifetime, j7 and' that fuel mining, milling, et cetera, will generate some 18 additional radiation background? It may not be a large amount, 19 but when you say that the eventual effect of those plants, it 20 is the eventual effect of the 1978 year of operation of those 21 plants?
22 MR. DENTON: For different parts of the fuel cycle it 23 is different effects. Those that are short-lived do tie into 24 that year. What we have attempted to do is to take all of the ,
federal Reporters, Inc.
25 imp' acts out in the future, say, with regard to radon releases , {
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2 of '78 even though they may show up much later in time.
COMMISSIONER AHFARNE: The '78 level of exposure is 3
4 greater than actually would occur in '78?
5 MR. DENTON: That is correct.
MR. KREGER: The so-called reference reactor year 6
7 aspect of the man-rem analysis is that we have looked at not 8
just the dose that is given by the reactor itself and the 9
operation for that year, but all of the need that that reactor 10 will have during its lifetime of more mined fuel and processed 11 fuel and so forth.
12 If I could go to the next slide.
13 (Slide.)
ja Just for perspective on an energy production basis, we use the data of Herbert Inhaber from Canada in AECB report 15 16 1119 to show how nuclear compares on a deaths per thousand 17 megawatt a year basis with other ways of producing energy. And all the data is inhaber's except the parenthetical number with 18 19 the asterisk behind it right after the nuclear column, and that is the numbers that would be ecuivalent to what is in the report, 20 21 except in the report I've got the same number for 800 megawatt -
22 electric per year rather than 1,000, because Inhaber put his 23 in terms of 1,000 megawatt electric years.
24 This number, .67 to 4.6 deaths per thousand megawatt .
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25 electric year, is the number that NRC would come up with, and
mte 7' 17 that includes using the very highest amount.of uncertainty that 3
2 is suggested by the Lewis Report for reactor accidents. The 3
4.6 number is much higher than the number that we had been 4
using, which was based strictly on direct' interpretation of the
-5 WASH-1400 data.
COMMISSIONER AHEARNE: Are you saying you interpret 6
Lewis as'giving a specific uncertainty?
7 MR. DENTON: No, what we did was take the old numbers 8
that were available from '1400, consider those in the light of 9
10 the Lewis Committee recommendations, which concludeg that there 11 was a great deal of uncertainty in.the numbers, and that the 12 uncertainty might be as great as indicated by the amount of 13 experience.
14 The numbers in 1400 were based on a 4-milligram possi-15 bility over one in 20,000. If you back up two orders of magni- ,
16 tude and had one in 200 reactor years, the amount of experience j7 in this country with commercial-sized power reactors is about 18 300 reactor-years. So we backed into the level.
j9 COMMISSIONER AHEARNE: So it is the experience level?
l MR. DENTON: We tried to'put uncertainty bounds on it, 20 l
21 to say this is an upper bound, assuming that it is more'likely than the amount of experience that we have had to date.
22 MR. KREGER: Now, the spread in numbers here, as 23 24 explained in Inhaber's report, is just backing up the energy. ,
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If you back up nuclear by nuclear, you get the low number.
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you have to back up on -- if you are producing the outside 2
res urces for nuclear by coal energy, then the higher number 3, applies . So in each case, if you use oil and you back it up I
4 by oil-supplied resources, you get the lower number; and if you
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5 back it up by coal-supplied resources, you get the hipher 1
number.
6 COMMISSIONER AHEARNE: How- about the coal?
7 8
. : e a nder reflecu de medaW 9
over the effects of air pollution. Of course,.it's fairly 10 '
easy to tabulate the mining and transportation-related fatalities,-
l' 11 but not the air quality-related.
12 MR. EILPERINS : Are his numbers for nuclear power 13 t much higher than yours? Because when you rultiply -- ,
jg MR. KREGER: His are much lover.
15 MR. EILPERINS : When you multiply that by the nurber 16 f p wer plants or what? j j7 MR. DENTON: This is per 1,000 megawatts electric, fl 18 in whichever way you make that 1,000 megawatts .
j9 Now, the previous slides I was using considered -- the; '
i 20 one on man-rems, for example, in 1978 took into account the !
I 21 51,000 megawatts provided nuclear, in the nuclear line, and the l I '
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" ther energy sources line, the fact that about 90 percent of 5l 22 our power today is produced by other energy sources. So the ;
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- .e.<o m.oonm, inc. 1 25 would have been multiplied by a much bigger number to get the 4
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mth 9 19 1 total man-rems in the U.S. population.
2 COMMISSIONER BRADFORD: What is it about wind that 3 would make that the most dangerous of all?
4 MR. DENTON: What we find when you examine the whole 5 energy cycle -- you tend to think of just the generation 6 f acility, but you have to look back into the mining of the 7 resources that it takes to build it, and the amount of materials 8 that it takes to build a sufficient number of windmills to 9 generate that much power. So you have to have a flow chart and 10 account for the entire e nergy. cycle.
11 COMMISSIONER AHEARNE: Should I interpret it that the 12 staff is endorsing this report?
13 MR. DENTON: We are citing it as one other example.
14 We have a table that compares -- on coal, for example, in the 15 report -- and I would say we are citing that table. And what 16 we have done is, we have also given Inhaber's and we have pulled 17 out of our other table the nuclear number.
18 COMMISSIONER AHEARNE: But when you cite a report,
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19 does that indicate that you are endorsing it?
20 MR.EENTON: I think in this case it is not cited as 21 an authority as maybe some of the medical documents are. But 22 there are so few examples of this around to find, we tend to i
23 cite them all. ;
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24 COMMISSIONER AHEARNE: I recognize that you,have not .j
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25 answered what I asked. I therefore conclude that you are a littie' ;
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- uneasy about --
2 MR. DENTON: These are not the staff's expert numbers.
3 We have prepared numbers for nuclear, oil, coal and natural 4
gas, and we have put in the report our own numbers on nuclear J and coal, and I think we would cite those and say they are the 5
6 staff's numbers.
These are numbers that were generated by someone else.
7 We have met with him. We understand the bases. But whether or 8
not the staff experts can really cite them as their own, I don't 9
10 know.
1j COMMISSIONER AHEARNE: Are you familiar with any 12 Peer reviews, comments, on Inhaber's report?
13 MR. DENTON: Yes.
14 COMMISSIONER AHEARNE: What do they end up with?
15 MR. KREGER: There is a significant technical 16 community which has interacted with Inhaber, and in fact our staff has met with him. He has been in Bethesda, he has been 37 very many places giving this representation. And we know of 18 19 no substantive technical contradictions to these data. And 20 that is why we use them.
COMMISSIONER KENNEDY: Except that they don't agree 21 22 with your own.
MR. KREGER: That's true. I put the table primarily 23 24 to show the relative, not the absolute, because we do feel that
- ecerei neponen, 25 inc. I he is taking into account most of the' factors that show the i
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_ relative risks of these various ftel cycles.
3 COMMISSIONER KENNEDY: Relatively speaking, the !
2 t evidence is that your own data are considerably more conserva- :
3 I i tive. f f
i MR. DENTON: Yes. There is some dispute, I think, j 5
about the backup. energy source and the way Inhaber has it, so ,
6 7
that . is why we have shown both numbers, the number:by itself I and the with regard to the backup. And we also have talked to !
8 i
9 other government agencies, including DOE, CEO and EPA, about ;
s' i 10 getting them to provide such numbers, because it does sound j 1
11 promotional for NRC to be citing numbers that show nuclear _as ;
lower than others. But I have not been able to get these other ,
12 13 gr ups to do similar studies.
j, COMMISSIONER AHEARNE: I want to be sure I understand. j 15 Your statement was you know of no substantive technical disagree I i
ment with Inhaber, is that correct? l 16 With this relative kind of display of' i j7 MR. .iREGER:
i jg energy, of risk from energy sources. f MR. DENTON: We had individuals meeting on risk just l 19 l a week or two ago within Canada. Let me ask who is here, and j 20 i
21 maybe they can give you a better answer than I could. l l
Red, were you at the meeting with Inhaber? l 22 23 MR. GOTCHY: Yes.
-24 MR. DENTON: Could you respond to the Commissioner?
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25 MR. GOTCHY: Well,.we really didn't get into his lj
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into l'2 22 study. Mc were talking there about the question of trying to
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determine what an acceptable risk is for society.
2 MR. DENTON: What about the other question? Do you 3
know of any substantive differences?
4 MR. GOTCHY: We haven't attempted to evaluate any of 5
Inhaber's numbers because some of the sources that he quotes are 6
relatively obscure and we haven't been able to get them yet.
7 I don't know anybody that has looked at them, other than Bill 8
Rowe made a comment once at a meeting -- I think it was in 9
10 April -- where he said something to the ef fect that he was 11 critical that Inhaber had used his assumption for back?p sources, 12 for example, solar thermal and solar voltaic, that the backup would be coal, one of the hard technologies, which tends to 13 ja raise the impact of those fuel cycles.
MR. LEROHL: As one representative, I would say we 15 16 have not analyzed that. I heard the one comment he made here
( 37 at a meeting locally several months ago, and he was not very
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explicit about how he calculated the nuclear.
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COMMISSIONER AHEARNE: That I think answers my ques-19 20 tion.
MR. KREGER: Well, to summarize the staff's response 21 f the petition in the medical area, I could put it as follows:
l 22 23 Based upon the findings of standard-setting and review groups, 24 such as the BEIR Committee and the others that were cited, the , ;
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25 staff analysis supports the use of 1972 BEIR health effects l
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estimaters to show that current standards for radiation protec-2 tion and the use of the ALARA principle do protect the health 3
and safety of the public in the manner to which we are charged, 4
or for which we are charged, by the Atomic Energy Act. This 5
is quantified in the medical principles part of the paper.
Could I have the next one, Steve?
6 7
(Slide.)
8 Physical evidence. Evidences in the petition were 9
17 in number. The main thrust of those was that the nuclear 10 fuel cycle produces enormous cuantities of long-lived ionizing 11 radiation which are released to the biosphere; the NRC has been 12 underestimating both the amount of the releases and the effects.
13 The staff analysis has addressed each of these 17, 14 again, as we did in the medical, bringing into the response the 15 very latest analysis of releases and radiation output from the 16 nuclear fuel cycle facilities and related to transportation, 37 which was one major point in the petition.
18 If I could have the next viewgraph.
19 (Slide.)
20 This viewgraph summarizes the off-site total body 21 dose commitment in man-rems that have been ascribed to the 22 various fuel cycle components as listed in the left column.
23 These numbers are for normal operation of each of the components .
24 The total off-site man-rem per 800 megawatt electric year and
- 't ederal Reporters, Inc.
25 for 100-year dose commitment to a 210 million population is l
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24 j between ' 640 and 710 man-rems . The difference between the two numbers in the case of reprocessing and LWR effluents is related 2
to whether one uses_a 100-year effective period for Carbon-14 3
4 or a 1,000-year, and that is only applicable to those two e-4 5
. components. There is very little difference.
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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 .4
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- 1. CHAIRMAN HENDRIE: Let me ask about the R1191 2 normalization. When you talk about 100 MWe per year, ape 5 3 is that in fact 800 megawatt electric years ~of energy,
- vid 1 4 electrical energy produced?
5 MR. KREGER: In the previous slides where we 6 used 1000, it was as if 1000 is produced. We used a 7 reference' reactor year of 800 megawatt electric effective 8 energy, if the reactor is a 1000 megawatt electric 9 reactor.
10 CHAIRMAN HENDRIE: So this 800 MWe years are Il energy production. They would correspond to -- the 12 equivalent words would be per 1 GWe electric plant year at 13 80 percent plant factor, would be a precisely equivalent i
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14 statement.
15 MR. KREGER: Yes.
16 CHAIRMAN HENDRIE: And the 1000 back over i 17 here on mortality in the medical section, which kind was 18 that?
I9 MR. KREGER: That came primarily -- the 20 summary table came out of an EPA report, and to the best 21 of my knowledge, that is 1000 megawatts of electric 22 actually produced.
23 CHAIRMAN HENDRIE: That is actual energy.
24 MR. KREGER: Yes. ' !
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25 COMMISSIONER KENNEDY: Which was is this?
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.svid2 1 CEAIRMAN HENDRIE: The publ'c i risk of mortality 2 a couple of slides earlier.
3 MR. KREGER: And also the earlier one on 4 manrems.
5 CHAIRMAN HENDRIE: Okay, sorry to quibble.
6 COMMISSIONER AHEARNE: When you have your-7 reprocessing added in, this is then the nuclear fuel 8 impacts of the current system; is that correct?
9 MR. KREGER: When you add what?
10 COMMISSIONER AHEARNE: When you've added'in 11 reprocessing;there is no reprocessing now, as you point 12 out, so this total of 647 -- 710 is not of the current.
13 MR. KREGER: That is correct. It is made on the 14 assumption that something 'is likely to happen with 15 regard to reprocessing, but it shouldn't.
16 COMMISSIONER AHEARNE: So it would be like 270 to 17 300.
18 CEAIRMAN HENDRIE: A better way to put it, John, l l
19 instead of labeling that item " reprocessing," a better 20 . way to put- it would bethe dose commitment from fission 21 product gases in fuel rods, if it gets out, as it is-I 22 assumed to get out if you reprocess. Now, if you don't 23 reprocess, does that mean it doesn't get out? Well, not 24 necessarily.. You've got some rods that are leakers. ~
You {
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25 may develop some cracks from the fuel sitting in AFRs for l
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2 MR. DENTON: You have gases like krypton 85. If 3 they are punctured, then the gases would be very similar.
4 CHAIRMAN HENDRIE: The dose from reprocessing, 5
these sorts of terms, I'believe the dose commitment from 6 reprocessing aside from the gaseous releases, is not 7
very large.
8 MR. DENTON: That is my understanding.
9 CHAIRMAN HENDRIE: The kind of accuracies here 10 Probably are okay.
11 Onward.
12 MR. KREGER: This slide in a sense summarizes 13 our response to practically the whole physical evidences 14 section because her petition argues at very much higher 15 releases, at almost each stage of the process, and we have ;
16 summarized in the response the testimonies, for example, 17 that have been given by the staff up to the most recent i 18 hearings, for example, on radon and these have withstood 19 those hearing processes.
20 And we have given the basis on which they are made. I 21 We believe that they represent accurate estimations of 22 the releases in the fuel cycle, and including consideration 23 of many generations in the future.
24 So, our argument is that these are the true c eral Reporters, Inc. !^
numbers and not the numbers that are presented in the I 25 l
28 Ivid4 1 petition.
2 That is all I wanted to cover in the two sections 3 on medical and physical.
4 MR. DENTON: Thank you. I would like for 5 Darryl then to run through quickly the effects of granting 6 the petition. We recognize that this is one side of a cost 7 benefit equation. This side is the cost. The benefits would 8 be cessation of the generation of the types of impacts that 9 Bill has described. i 10 MR. NASH: Could I have the next slide, please.
11 (Slide.)
12 We looked at the generating capacity of the 13 nuclear industry and to a considerable extent, I think, 14 you could relate the same impacts independently of the 15 type of generating system you have.
16 In other words, displacement of 13 percent of 17 the electricity output would have the same impacts l l
18 regardless of whether that was anuclear plant or some other !
l 19 equivalent capacity in the industry.
20 But indeed it is the case that with the approximately 21 50,000 megawatts of nuclear generating capacity now on-line 22 that this is about 9 percent of the nation's capacity.
23 These plants produce about 13 percent of the electrict.1 l
24 output in the long term, and we said very simply that 10 L
m erit Reporters, Inc. l 25 years from now that this is projected to increase to about !
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. 29 id5 1 20 percent of the generating capacity'and about 27 percent 2 of the electrical output.
3 Could I have the next slide please.
4 (Slide.)
5 I think we can be fairly safe in saying that 6 the least impact of closing down the nuclear plants in y terms of dollar costs would be that the coal fired plants i
8 would be called in to replace this power. Now, if th3s ;
9 were done, this would increase the nation's coal use by i
10 about 20 percent, ad it would increase the use'of coal in 11 the generating industry by about 25 percent.
12 This increased use, when you take the difference 13 between the cost of operating coal plants -- well, take 14 the cost of operating coal plants and subtract out the i
15 cost of operating nuclear plants.for an immediate shutdown, i
16 then it would be about $175 million per month in additional j j
17 cost.
18 COMMISSIONER KENNEDY: Does that take into account i
19 any figure for plant investment that would be required if I
20 a plant doesn't exist? ,
21 MR. NASH: Well, that is what I want to go on to 22 next, that if you make the bold assumption that you can 23 replace this capacity with coal, then this would be the 24 impact. ,
L mrol Reporters, Inc.
25 COMMISSIONER AHEARNE: Are there operating costs?
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rid 6 MR. NASH: Yes.
2 Now, in actuality an immediate increase in coal 3
requirements of 20 percent would put severe strains on i
d the mining industry, transportaton industry and so forth, 5
not to mention that there likely is not immediately 6
available 20 percent additional capacity in coal plants 7
that can be used to take up the slack.
O COMMISSIONER AHEARNE: An immediate increase 9
of 20 percent, like a switch tomorrow to replace that kind l l
10 of a strain, but certainly over the next few years, there 11 is a planned increase of more than 20 percent. So, that 12 in itself depends upon the phase-in. ,
MR. NASH: That is correct, although in addition 14 to the planned 20 percent, there would have to be an 15 addit.1onal 20 percent or more as we go thrsagh time, and 16 the nuclear portion becomes larger. It would have to be I7 added to whatever planned additions.
18 COMMISSIONER AHEARNE: But since there is a l l
19 big expansion underway, the degree of strain that 20 percent }
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20 increase places depends upon how repidly it would be phased !
l 21 . 1 in.
22 MR. NASH: Yes, that is correct. And one of 23 the aspects of the petition was directed toward an immediate 24 e erei cono m ri,inc. shutdown,and that is what this speaks to. -
f 25 I And then we do recognize that certainly there is .
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'id7 i a capacity for adjustments .in output and these things could 2 be handled.
3 So, taking another extreme, if we look at 4 replacement by oil only, this would require an 5
additional 6 percent of our current use of oil, and if 6 we assume now that all of that increase would come from 7
imports, we would have to increase our oil imports by 8
13 percent.
9 And making the dollar cost comparison, if we 10 again take the fuel and operating cost of oil plants and 11 subtract out the same cost for the nuclear plants, this 12 would cost something on the order of $550 million per month.
. 13 In addition --
14 COMMISSIONER AHEARNE: What are you paying for 15 011 Per barrel?
16 MR. NASH: This is 12 to S14.
17 Now, I think that there other considerations too;
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18 obviously the availability of oil plants and coal plants by l 19 region in the country has not really been taken into account 20 here. So, I think that the coal only and oil only would i extremes, and the figures at the f
21 Perhaps bound the -
l 22 bottom of the chart, the combination of coal and oil, 23 assume that 20 percent of this capacity covid be made up 24 by coal plants, and the basis for that was that it is ,
enoi steponm. inc.
perhaps -- well, this would require an additional 5 percent
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.d 8 1 increase in the output from coal plants.
2 And that much I think could reasonably be 3 made up in coal plants and the additional 80 percent 4 from oil plants, io that the way you average those 5 two would be where we get the S475 million permonth.
6 We thought it was aJso prudent to look at --
7 if the additional output is not forthcoming from coal and 8 oil plants ant' 'here were actually energy shortages, the 9 output represented by nuclear plants supply about 10 20 percent of the commercial and industrial capacity.
11 So, if in the case of an immediate shud own 12 and without time for adjustments to other kinds of 13 generating capacity, this gives some indication of the 14 magnitude of the electrical output of the nuclear plants.
15 That is, it supplies something equivalent to 20 percent of 16 the industrial and commercial use. And so there may be 17 an impact if there is an energy shortage.
18 This would be an upper bound of the impact on 19 our electrical usage.
20 COMMISSIONER AHEARNE: It wouldn't be an upper 21 bound because in some cases you've got nuclear being used 22 as the base and backup power, which is more expensive. But 23 if the nuclear isn't operating as many plants may have an 24 emergency shutdown, there is other power that they can ;_
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.d9 I MR. NASH: And the purpose for showing that 1 2 was.ttat -- not to indicate that.this was about to happen, 1
3 but I think again looking at an' immediate adjustment, say, l 4 tomorrow, closing down, this would be an upper bound l 5 impact of such an action.
6 Could we, go to the next slide please.
7 (Slide.)
8 This shows a very quick suimary of the long term 9 impacts, and this gets into -- again, we are talking about i 10 10 years -- that if this shutdown were permanent, then it II would be the job of replacing the existing nuclear capacity 12 with new or other types of capacity and also replacing the i
13 capacity of nuclear plants that are now under construction, Id essentially writing thatoff and replacing that with 15 alternative generating capacity.
16 That would be on the order of $600 billion to 17 replace the capacity now existing, and that it would be 18 planned over the next 10 years. I l
19 COMMISSIONER AHEARNE: Is this $600 billion to 20 replace all sunk monies, or does it include monies not yet 21 spent?
22 MR. NASH: It is the sunk cost. There is 23 approximately 70 plants now under construction, and so if 24 the decision were made now that these would not be allowed 4 scer:t Reporters, Inc. .
25 to operate, then the cost to replace those 69 plants plus
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.d10 1 the approximately. appreciated amount of:the approximately 2 70 plants that are now operating --
3 COMMISSIONER AHEARNE: That is the $600' billion?
4 MR. NASH: Yes.
5 COMMISSIONER AHEARNE: So there are about 140 6 plants that you are talking about.
7 MR. NASE: Yes.
8 COMMISSIONER AHEARNE: -And since right now I 9 . guess you have about 50 GWe, well you are.saying roughly 10 around $4 billion per GWe replacement.
11 MR. NASH: Right.
12 COMMISSIONER AHEARNE: This is undiscounted?
13 MR. NASH: Yes, this is undiscounted. This is 14 just a pure money figure, i
15 COMMISSIONER AHEARNE: All right.
l 16 MR. NASH: Then with regard to replacement power, 17 by the year 1987 this would be 59.8 billion. This is under j 18 the assumption of the 80-20 mix that we talked about. Now 19 that 80 percent oil and 20 percent coal --
20 COMMISSIONER AHEARNE: This per year is l 21 operating cost?
22 MR. NASH: Yes.
23 COMMISSIONER KENNEDY: Net?
24 MR. NASH: Yes. ,
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25 COMMISSIONER KENNEDY: $9.8 billion?
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a 35 tvidll 1 MR. NASH: That concludes my report.
2 MR. DENTON: Can I have the last slide?
3 (Slide.) ,
4 I realize today is not a decision making meeting, 5 but my conclusion based on the staff's review of this 6 petition would be that it would be to deny the petition 7 based on the finding that we have not underestimated the 8 effects of the fuel cycle, ar>d they are in accordance 9 with the Commission's recommendations .
10 CHAIRMAN HENDRIE: All right.
11 MR. SHAPAR: Excuse me. You say you recommend 12 denial of the petition? I assume we're still under the 13 mode with the Commission observing its supervisory
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14 authority over the staff's review process. I assume that 15 is unchanged.
16 COMMISSIONER KENNEDY: I thought he said he 17 would.
18 MR. SHAPAR: Yes.
19 CHAIRMAN HENDRIE: I thought he said he would 20 deny the petition.
21 MR. SHAPAR: I just wanted to make that point 22 clear.
23 COMMISSIONER KENNEDY: I listened to what he said.
24 MR. DENTON: There was a question last time we
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25 met over how we should respond.
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'36 I avidl2 -I COMMISSIONER KENNEDY: But is that still open?
2 I thought Howard just described that.
3 CHAIRMAN HENDRIE: .When we sent this petition 4 to the staff, we agreed to treat it as a 2.206 petition 5 in effect until further notice. This is further notice.
6 The question now that the Commission will have to decide j 7 is whether to leave the responsibility for dealing with 8 this petition with the director of nuclear reactor 9 regulations, that is, for it to be continued to be treated as 10 a 2.206 petition, or whether the Commission would choose to Il take the petition itself and to use the staff's work 12 which had to be done in any case to provide some basis 13 for looking at things in making its judgment.
Id And I think one of the things that lies before 15 I don't ask you to decide today -- at this us -- and 16 time, certainly is whether you would like to take up the 17 petition.
18 I guess what happens is we just order that the I9 Commission thanks the staff for its work and has the report 20 in hand.
2I COMMISSIONER AHEARME: So it is still open?
22 CHAIRMAN HENDRIE: Of course, that was the 23 arrangement under which we started here back some weeks L
24 ago. We recognized at that time that the Commission -and our cerol Reporwn, Inc.
25 poor little offices were hardly equipped to deal with the
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tvidl3 sweep of this Commission.
And we needed staff experts to look ht these matters and discuss them, and so on. There is a consent sheet I think in the book -- well, I'm not sure whether we will want to meet again and discuss this matter before deciding that jurisdictional question.
I wouldn't be surprised. It may be useful to 7
have the interaction of the Commissioners for or against 8
or if they don't care, as the case may be.
COMMISSIONER KENNEDY: Even if we did not take 10 it up ourselves, but rather left it in a 2.206 mode, this does not deny the possibility of our giving some views and guidance to the staff with respect to its response. And staff I suppose, if it were in a 2.206 mode could refuse to accept the guidance.
But knowing the staff as I do, I hardly consider that likely.
MR. SHAPAR: I do want to point out though that i
if you do authorize the staff to follow 2.206 as written g
the Commission will have another crack at it, but the standard for review is the discretion on the part of the 4 I
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CHAIRMAN HENDRIE: We maybe prejudicing the i 23 g ability to make that finding.
"*' So it is a completely different MR. SHAPAR:
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'Aw e 38 rid 14 standard if you. go the formal' 2.206 route as written. I
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think thatis an important point.
2 COMMISSIONER AHEARNE: I would like to'think about 3
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CHAIRMAN HENDRIE: Of course. And as I say, 5
the intent of the briefing today was to provide an 6
introduction to what is a fairly husky paper and a ,
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hance to ask a few questions'as slides come across,
( 8 but not in the sense of saying, okay, let's decide. l 9
And I think we really ought to come eyeball to ;
10
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I jj eyeball or maybe it is ear to ear the way we sit along this table and discuss where we go from here.
12 I thank the staff for the paper in hand here 13 14 which will keep me off the streets a couple of nights 15 I'm afraid, and for your presentation this afternoon which !
g is helpful in terms of seeing the guideposts and the j points of interest in them. {
37 l i Other comments that we might make? l 18 39 (No response.)
Thanks very much.
20 (Whereupon, the meeting was adjourned at 4:50 p.m.) !
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