ML20148M839
| ML20148M839 | |
| Person / Time | |
|---|---|
| Issue date: | 07/11/1978 |
| From: | Pedersen K NRC COMMISSION (OCM) |
| To: | Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM) |
| Shared Package | |
| ML20148M724 | List: |
| References | |
| NUDOCS 8012240085 | |
| Download: ML20148M839 (2) | |
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, UNITED STATES "6 * - ' S 3 ..(
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 n m f2 p[.3
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July 11, 1978
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MEMORANDUM FOR: Chairman Hendrie ,,,.
CommissionerGjlinsky [.).}
Commissioner Kenvady s:7 Cor=tissioner pdfo d y};
FROM: Ken Ped se il j
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SUBJECT:
POLICY ON ALTERNATIVE SITE EVALUATIONS: LESSONS FROM ,
[E SEABROOK f
Seabrook has shcrply accentuated.some troublesome gaps in our policy on r
F alternative site evaluations, These gaps gave rise to widely differing interpretat. ions of requirements by applicants, stuff, intervenors, and i E
Licensing Board and Appeal Board members. The gaps, identified below, .i.y pose difficult policy formulation problems. Nonetheless, I believe they p can and must be dealt with. '
!4 Specifically, I recom=end that you ask the staff to develop and prepare S)::.
for publication groundrules that would narrow these gaps as much as N:
possible. This can be done by amplifying the draf t pclicy statement in h the alternative-sites staff paper (SECY-78-163), which you would then [
consider for issuance as a proposed rule. E p
The gaps that I am referring to are as fo]1ows:
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- 1. Interpretation of "obviously superior." b
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Difficulties with assigning a settled meaning to the term "obviously .
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superior" and determining what it takes to show the presence or absence of -
" obvious superiority" in an alternative (or an " obvious inferiority" i in a proposed site) were significant obstacles to agreement on when a study has been adequate. The comparison with Seabrook-with-towers and the southern New England sites issue were both impacted. '
- 2. How many sites to evaluate.
There was uncertainty as to how many if not all of the 21 alternative sites (including the three in sout ern New England) cust be evaluated
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in comparison to Seabrook-with-towers. In the Seabrook case the Com-i7 Ey cission directed a narrowing to a few sites, but some generic guidance " '
on criteria for selecting an appropriate number of candidate sites $
will be needed for future cases. ~
'O 5 NTACT:
George Sege (OPE) 634-1643 0 3
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- 3. How far to look for alternative locations.
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The southern New. England sites controversy emphasized the need' for guidance on how far to. look for alternative sites, in relation ' to - ., !
such factors as an operating utility's service area,<a major non-lead: S applicant's service area, st:te boundaries, distances involved, and power-pool arrangements.
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- 4. How much' data and analysis. O.in In Seabrook, the Appeal Board majority found. meteorological data inadequate and thought that consideration should have been given to
- site-specific choice of tower type at the alternative sites evaluated. -
The Licensing Board dissenter' commented' adversely on the absence of N a " comprehensive analysis...on the aesthetics of cooling towers at Litchfield." These views were not held by-the staff or the Licensing- U Board majority. -
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. There is need.for a'better and more specific. common understanding on h how to set reasonable limits on what is required to be done without jeopardizing adequacy. of the result. .
As noted earlier, I believe the policy statement in SECY-78-163 is the appropriate place to address these issues. It would require additional amplification by the staff.- This work could proceed while we await the First Circuit Court's decision on the consolidated Seab' rook cases (believed likely to be issued late this summer).
I enclose for your consideration a draft guidance memorandum that would ask the staff to proceed along the lines that I am recommending. Please let us have your concurrence or comments by COB,: Friday, July 14.
Enclosure:
As stated
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cc: James Kelley ,
Sam Chilk u
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